ASHLAN13® 

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5 March 2012 

Document Control Office (7407M) 

Office of Pollution Prevention and Toxics 

Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 - 0001 

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mR03 (1Z~4 00.rAshland Inc. 

5200 Blazer Parkway 

Dublin, OH 43017 

Tel : 614-790-3333, Fax: 614-790-6080 

ashland .com 

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Attn: 40 CFR 799.5089; 

Docket ID Number EPA-HQ-OPPT-2009-0112 

Dear Sir: 

Ashland Inc. (Ashland) submits this application for exemption from the requirements for testing 

Acetaldehyde, reaction products with formaldehyde, by-products from the complex combination 

obtained by the reaction with acetaldehyde (CAS# 68442-60-4) (Corpent) under TSCA Section 4 Test 

Rule: Testing of Certain High Production Volume Chemicals: Third Group of Chemicals. 

Ashland acquired Hercules Incorporated (Hercules) in 2008 . Hercules' 2006 IUR submission identified 

Corpent as a manufactured substance . Hercules is a wholly-owned subsidiary of Ashland. On March 2, 

2011, Hercules exited the market for Corpent by selling the production facility to an unrelated company. 

Neither Ashland nor Hercules imports this substance. 

Ashland acknowledges that if it or Hercules re-enters the market at a later date, we must comply with 

40 CFR 790.99 and will be financially responsible to those who have committed to testing. In 

accordance with 40 CFR 790 .99, Ashland states the following in support of this application for 

exemption: 

I (Ashland Inc) understand that if this application is granted before the reimbursement period 

described in section 4(c)(3)(B) of TSCA expires, Ashland or its relevant affiliate must pay fair and 

equitable reimbursement to the person or persons who incurred or shared the costs of complying 

with the requirement to submit data and upon whose data the granting of my application was 

based. 

If you have any questions please feel free to contact me. 

Sincerely, 

Thomas H. Keenan, Ph.D . 

Director, Environmental and Regulatory Programs CONTAINS N O CB' 
p. 2 

Page 1 of 1 

From : (614) 780-6682 

Stacy Kavy 

Ashland 

5200 Blazer Parkway 

Dublin, OH 43017 E 

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SHIP T0: (614) 790-6682 BILL SENDER 

Document Control Office (7407M) 

EPA-Office of Pollution Prev. & Tox 

1200 PENNSYLVANIA AVE NW 

WASHINGTON, DC 20460 

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TRK# 7981 4043 3291 

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