Arch Chemicals, B.V. Watery Lane Swords Dublin Ireland i Tel. No: 353-1-8908000

/ I Fax No: 353-1-8908011

Ms. Tracey Berney, Licensing Unit, Environmental Protection Agency, P.O. Box 3000, Johnstown Castle Estate, Co. Wexford. 22"d. Dec. 2008

LICENCE NO. POO60-0 1

Dear Ms. Berney,

Our Licensing Inspector Ms. Maeve O'Reilly has advised that our application under condition 1.2 of our IPPC License for the introduction of a new product, Wayhib S, a Phosphate Ester Sodium Salt to our site at Watery Lane Swords, CO Dublin cannot be accommodated under our currlznt activity class 5.3. From the attached documentation (1) our initial submission dated 1 Ot". Nov. 2008 and (2) our correspondence dated 1 gth. Dec. 2008, which is our response to request for further information by the Agency, we now submit this application to the Licensing Unit.

As pointed out in our previous correspondence with the Agency there is a strict deadline on the start-up of of this product. In this regard we would request that this application could be accommodated by way of a technical amendment to above License.

Furthermore the company doe:s envisage that in the next 1 to 2 year timeframe the product mix at our site could change somewhat and in this regard we are aware that a full License review would have to be undertaken as it becomes clear what the new product profile might be. I would be happy to provide any further information required to further this request.

Yours Sincerely, FOR A R C H Z A L S BV.

Larry Hanlon Y

I Quality & Environmental Manager.

Attachments: Letter to OEE dated 1 Oth. Nov. 2008 Facsimile to OEE dated 191h. Dec. 2008 Material Data Sheets for Wayhib S and associated raw materials Wayhib S Process overview P&ID of Wayhib Process

Directors: P.J. Craney (U.S.A.), B. Van Ophuizen (Dutch) (Managing), S.P. Schmedelin (US A.). Statutory Domicile: The Hague, Netherlands. 'S. I.S. EN EN IS0 ISo 14001 9002 OH. SAS 18001

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I . ,

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. . . _ . . I

.... . .. - . * ..

c -. . . .. . . . . .. . .

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Arch Chemicals, B.V. Watery Lane Swords Dublin Ireland Tel. No: 353-1-8908000 Fax No: 353-1-8908011

Office of Environmental Enforcement, Environmental Protection Agency, McCumiskey House, Richview, Dublin 14, loth. November 2008

Attn. Ms. Maeve O'Reilly, LICENCE NO.

Dear Ms. O'Reilly,

Pursuant to condition 1.2 of above IPPC License Arch Chemicals B.V. wishes to notify the Agency of it's intent to become involved in the manufacture of an additional product, Wayhib S, at its Watery Lane, Swords Co. Dublin site. The manufacture will be carried out in an existing vessel RE603, modified to suit the process.

The process involves an Amine type reaction using Polyphosphoric Acid and Triethanolamine at elevated temperatures followed by neutralization with Sodium Hydroxide. An outline of the process is included as an attachment. I have also included the material safety data sheets for the raw materials referred to above and the finished Wayhib S product. Under normal operating conditions there will not be any air emissions from the process as the reaction is being carried out under vacuum, with an in line condenser and liquid receiver, with venting through a vacuum pump. As there is no liquid effluent fi:om this process other than routine vessel boil-out, it is envisaged that there will be negligible impact on the site WWTP and the resulting effluent discharged to Fingal County Council WWTP. The start-up date for this project is envisaged as lSt March 2009.

If further clarification or inforrnation is required please feel free to contact the undersigned.

Yours Sincerely,

F O R A R Z BV.

Larry Hanlon Quality & Environmental Manager.

-

Directors: P.J. Craney (U.S.A.). B. Van Ophuizen (Dutch) (Managing), S.P. Schniedelin (U.S.A.). Statutory Domicile: The Hague. Nerherlands. I"' I.S. EN EN IS0 Is' 141111 I ~ . . -.,. ..,,>.*.

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Swords, Co. Dublm, Ireland

Tel. 353-1-8908000

Fax 353-1-8908011

FACSIMILE T R A N S M I T T A L SHEET

TO FROM

Ms. Maeve O'Reilly Latry Hanlon

Environmental Protection Agency.

01 2680199 2

COMPANY DATE

19m. DEC. 2008 FAX NUMBER TOTAL NO OF PAGES INCLUDING COVER

PHONE NUMBER

01 2680100 SENDER'S REFERENCE NUMBER

RE: YOUR REFERENCE NUMBER

Request for further infornlation [Clickkandtypen&xnenumbeij

URGENT x FOR REVIEW 0 PLEASE COMMENT 0 PLEASE REPLY 0 PLEASE RECYCLE

NOTES/COMMENTS:

miyhib S - Our letter dated IO". Nov. 2008 Dear Ms. O'Rdy,

Further to our telephone conversation, where -er information was requested on above, we are in a position to address the issues you raised as follows:

1. With regard to the emergency vent, I can confirm that the bursting disc is rated to 48.4~4 (3.34bar). The bursting disc is primarily a safety feature designed to protect the vessel which has a design rating of 1OOpsi. Due to the process controls being put in place we can not envisage any abnormal procesi; condition which might give rise to failure of the bursting disc. Furthermore our sister plant in the US has been running this process for a number of years without incident

2. With regard to emissicas from this emergency vent, in the event of bursung disc failure the most hkely emission would be steam / steam condensate.

3. With regards to class of activity, we have reviewed the schedule and can see how this proposed activity might be clas;dfied as class 5.12&), but would also point out that it could be

[ C L I C K H E R E A N D T Y P E R E T U R N A D D R E S S ]

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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .

accommodated within the Company’s current IPPC license classification of 5.3, as the product is described as a phosphate ester sodium salt.

Given that there are no emksions to air from this process, other than the emergency vent. There is no direct liquid effluent from the process other than periodic vessel clean-out, which can be adequately handled by the on-site Wwrp and ,that projected demand for the product is in the order of 20 - 5Omt annually, (1-2.5Yo) of pcojected plant output, we would suggest that this request could be accommodated within our Current License class.

As stated in our letter the timing of this project is important, with a planned start-up date of March 1st. 2009.

As discussed at the conclusion of our conversation Arch Chemicals envisage changes in it’s product profile over the next 1 - 2 year timeframe. We are aware that a full License review would have to be undertaken as it becomes more clear what the new product profile might be.

If required I would be available to discuss any further Claafication required in this matter

Larry Hahon,

Quality & Environmental Manager.

2

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. -. .

Material Safety Data Sheet in accordance with 91/155LEEG

EC Material Safety Data Sheet

Version: SA

thermPhos

Annex-1 CAS-number number Conc. (w/w) Symbols R-phrases

Status : 19-05-2006 I Polyphosphoric Acid 11 3-1 15-1 16-1 17-1 18 I

see at

Information ortho-and. 8017-16-1 1 015-011-00-6 1 Further 1 C 1 R-34 Polyphosphoric Acid I

Further information : Polyphosphoric acid 113 : 81-82,5 % by weight, equivalent in P2O5

Polyphosphoric acid 115 : 82,5-83,5 % by weight, equivalent in P2O5

Polyphosphoric acid 116 : 83,5-84,5 % by weight, equivalent in P205 Polyphosphoric acid 1 17 : 84-85 % by weight, equivalent in P205 Polyphosphoric acid 11 8 : 85-86 YO by weight, equivalent in P2O5

L

3 Hazards identiflcatfon

Corrosive. Causes redness, pain and burns Corrosive. Causes redness, pain and poor visibility Read section 12 also

Causes sore throat, cough, shortness of breath and dyspnoez Skin :

Eyes : Environment :

fire : Not flammable Explosion : Forrns flammable and explosive hydrogen through corrosion of metals

Other: Phosphoroxide and phosphine could be released by heating 1 4 First aid measures

GENERAL ADVlCE : INHALA TlON :

Take off immediately all contaminated clothing (including shoes) Move to fresh air. Oxygen or artificial respiration if needed Hospitalize Wash immediately, abundantly and thoroughly with water. If possible rinse with : Bicarbonate solution

SK/N CONTACT:

Thermphos International B.V. Page 1 of 7

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Material Safety Data Sheet in accordance with 91/155/EEG

li(* I

I

Version: 5A

thermPhos

Technical measuredPmcautions :

Safe handling advice :

Storage and handling precautions applicable to products : CORROSIVE. Ensure appropriate exhaust and ventilation at machinery. Provide showers, eye-baths. Avoid splashing when handling. Do not pour water onto the acid (exothermic reaction)

I STORAGE: -

I 4 First ald measures

EYE CONTACT:

INGESTION :

Wash immediately and abundantly with water for at least 15 min. Consult an ophthalmologist immediately Do not induce vomiting, rinse mouth and lips with plenty of water if the subject is conscious, then hospitalize immediately

SUITABLE : In case of fire nearby :

Carbon dioxide (CO2)

Forms flammable and explosive hydrogen through corrosion of metals. Temperature > 200 "C: formation of : Polyphosphoric Acid (Dehydration). At high temperature : Thermal decomposition giving corrosive products : Oxides of phosphonrs. In case of fire : remove exposed containers In case of fire : wear a self-contained breathing apparatus.

EXTINGHUISHING Dry powder MEDIA Foam

SPECIFIC HAZARDS : Non-flammable product.

SPECIFIC METHODS : SPECIAL PROTECTIVE :

EQUIPMENT FOR Acid resistant clothing FIREFIGHTERS

PRO TEC TlON ENVIRONMENTAL :

PROTECTION drains. Contain by damming.

CLEANING UP

Do not release into the environment. Do not let the product enter into

METHODS FOR - Recovety

Neutralization

Pump into an inert labeled emergency container. Clean up puddles of product immediately. Dilute the puddles with water and recover it Dilute cautiously with water and then process. Neutralize with an alkaline carbonate or Neutralize with slaked lime (filter the salt obtained - Neutralize the liquid)

Therrnphos International B.V. Page 2 of 7

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.. .

EC Material Safety Data Sheet thermPhos Aaterial Safety Data Sheet in accordance with 9 1/155/EEG I Version: 5A

Status : 19-05-2006 Polyphosphoric Acid 11 3-1 15-1 16-1 17-1 18

Keep containers tightly closed in a cool, well-ventilated place. Technical measuredstorage

conditions :

Incompatible products :

PACKAGING : MA TERIALS

Recommended :

To be avoided :

S1:ore in well-insulated area. Store protected from moisture and heat. Keep at temperatures above 30 "C. Provide a catch-tank and an impermeable corrosion-resistant floor with dr.ainage to a neutralization tank within a bunked area. Provide anti-corrosion electrical equipment. Bases-Quicklime Alcohol's - Ketones - Amines Wiater Nitrates - Chlorates - Calcium carbide Metals - Finely divided metals Ccmbustible material

Stainless steel 316 L - Carbon steel (Vulcanized or rubber coated steel). Plastic materials (Polyethylene). Srrtall quantities : glass protected by a fitted metallic covering Metals : Ordinary steel, Copper, Aluminium, (and alloys)

PROTECTIVE : PROVlSlONS

PARA METERS Exposure limits :

Ensure sufficient air exchange and/or exhaust in working areas

CONTROL: -

Phcsphoric Acid : FRANCE 1993 : VME = 1 mg/m3 FFWNCE 1993 : VLE = 3 mg/m3 USA-ACGIH 1997 : TLV-TWA = 1 mg/m3 USA-ACGIH 1997 : TLV-STEL = 3 mg/m3

PERSONAL: - PROTECTION EQUIPMENT

Respiratory protection In case of insufficient ventilation, wear suitable respiratory equipment Hand protection Gloves Eye protection Safety glasseslgoggles.

Face mask (in case of spattering) Prottxtive clothing Non-skid boots (Butyl rubber - chlorinated polyethylene - Neoprene - Poly('viny1 chloride) Avoid contact with skin and eyes and inhalation of hot vapours

Skin and body protection

Specific hygiene measures

9 Physical and chemical properties . .

I- I

Thermphos Internalional B.V. Page 3 of 7

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EC Material Safety Data Sheet 9 thermPhos Material Safety Data Sheet in accordance with 91/155/EEG

Polyphosphoric Acid 11 3-1 15-1 16-1 17-1 18 Version : 5A Status : 19-05-2006

9 Physical and chemical propertles PHYSICAL STATE (20°C) :

COLOUR :

ODOUR : pH:

DENSITY

SOLUBILITY: Water

Solvents OTHER DATA :

Viscosity (60 "C) )

liquid (viscous) Colourless (HAZEN colouring e= 50). Clear liquid however, under certain low temperature storage conditions (< 15 "C) this product may crystallize, requiring desolidification none in solution at 2 %, in alcohols : 1,9 - 2,l Liquid : (20°C) : Polyphosphoric acid 11 3 : 2010-2030 kg/m3 (20°C) : Polyphosphoric acid 115 : 2030-2060 kg/m3 (20°C) : Polyphosphoric acid 116 : 2030-2070 kg/m3 (20°C) : Polyphosphoric acid 1 17 : 2050-2070 kg/m3 (20°C) : Polyphosphoric acid 118 : 2070-2090 kg/m3

(at 20 "C) : Completely soluble. formation of Orthophosphoric Acid Soluble in : Alcohols

-

(60°C) : Polyphosphoric acid 113 : 340 mm2/s (cSt) approx. (60°C) : Polyphosphoric acid 1 15 : 1000 mm2/s (cSt) approx. (60°C) : Polyphosphoric acid 116 : 1000 mm2/s (cSt) approx. (60°C) : Polyphosphoric acid 1 17 : > 1000 mm2/s (cSt) approx. (60°C) : Polyphosphoric acid 118 : > 2000 mm2/s (cSt) approx. Due to action of humidity and cold temperatures (T , 20 "C) : Phosphoric acid 1 13 : freezing possible

CONDITIONS TO AVOID : Store protected from moisture and heat. Keep at temperatures above 30 "C Bases - Quicklime : Exothermic reaction - Violent reaction Alcohols - Ketones - Amines : Exothermic reaction Water : very exothermic reaction and possibility of spitting Nitrates - Chlorates - Calcium carbide : Explosive reaction (flammability) Metals - Finely divided metals Combustible material : Overheating and ignition Forms flammable and explosive hydrogen through corrosion of metals. Temperatures above 200 "C : formation of : Polyphosphoric acid (Dehydration). At high temperature : Thermal decomposition giving corrosive products : Oxides of phosphorus

MATERIALS TO AVOID :

HAZARDOUS : DECOMPOSITION

PRODUCTS

11 Toxicological information ACUTE TOXIDIN: -

Page 4 of 7 Thermphos International B.V.

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. I*

i

Material Safety Data Sheet in accordance with 91/155/EEG I Polyphosphoric Aciid 11 3-1 15-1 16-1 17-1 18

EC Material Safety IData Sheet

Version : 5A Status : 79-05-2006

thermPhss

_ .

I I

I 11 Toxicological information

Inhalation : At high vapourlfog concentrations : Irritating to respiratory system Ri:sk of pulmonary oedema Asthma-like after effect possible following a period of acute poisoning. Phosphoric acid : Experimental effects on animals : LC:&nhalation/l h/ rat > 0,85 mgh. Risk of serve burns in digestive system. Phosphoric acid : Experimental effects on animals : LD1&oral/rat = 1530 rngkg

At high vapour/fog concentrations : Severely irritating to respiratory system

Irritation and bums if not washed immediately.

Serious lesions with possible after-effects if not washed immediately

Ingestion

LOCAL EFFECTS: - Inhalation

Skin-contact Corrosive to skin.

€ye-contact Corrosive to eyes.

I

Ecological informati PERSISTENCUDEGRAD -

ABILITY in water Hydrolysis, formation of: H3P04 (depends on the temperature)

t% life = few days (25 "C) ECOTOXICIN: -

AQUATIC TOXICITY: - Acute toxicity SUIBSTANCE CONCERNED : Orthophosphoric acid.

Slightly harmful to fish : LCeo, 96h (Gambusia affinis) = 138 mgh. Slightly harmful to daphnia : LCs0, 24h = 177 mgA (AQUEOUS SOLUTION 85 %) [H3P04]> 0,03 mg/l : Algal development

Disposal considerations DISPOSAL OF:

PRODUCT Dilute cautiously with water and then process. Neutralize with an alkaline carbonate or Neutralize with slaked lime (Filter the salt obtained - Neutralize the liquid)

I

14 TransDort information UN-number : 180!j

Hazard identification No. : Transportname : Polyphosphoric Acid

Thenphos International B.V. Page 5 of 7

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Material Safety Data Sheet in accordance with 91/155/EEG

Polyphosphoric Acid 11 3-1 15-1 16-1 17-1 18 I ,

Version: 5A Status .- 79-05-2006

Packaging group : I I I Label: 8

IATA Class : 8, UN No. 1805

SAFETY DATA SHEETS : D.91/155/EEC amended by D.93/112/EEC : Dangerous substances and preparations

EINECS (EU) : 232-417-0 EC CLASSIFICATION/: -

LA BEL LING HAZARDOUS : D.67/548/EEC amended by D.93/72/EEC (1 9" APT)

R34 : causes bums S26 : In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. 545 : In case of accident or if you feel unwell, seek medical advice immediately (show the label when possible) TSCA (USA) : listed

SUBSTANCES C-Corrosive

INVENTORIES :

REFERENCES FURTHER : THIS PRODUCT MUST BE HANDLED ONLY BY PERSONNEL WELL

INFORMATlON INFORMED ON SAFETY CONDITIIONS. WHEN USED IN FORMULATIONS, CONTACT US FOR LABELLING 2 + 9 Changes in rubric :

Date of printing : 5/22/2006

Thennphns international B.V. Page 6 of 7

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EC Material Safety Data Sheet

Material Safety Data Sheet in accordance with 9 1/155/EEG

Polyphosphoric Acid 11 3-1 15-1 16-1 17-1 18

thermPhos Version: 5A Status : 19-05-2006

Other informati

This information is based on ow present state of knowledge. It should not therefore be construed as guaranteeing specific properties of the products described or their suitability for a particular application.

Tharmphos Intarnational B.V. Page 7 of 7

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Science Lab .c Chemicals & Laboratory Equipment

- Name CAS # % by Weight

Triethanolamine 102-71-6 100

1-1 Protection

Material Safety Data Sheet Trii et h a n o I a un i ne M S D S

~~~ ~ ~ ~~

Section 1: Chemical Product and Company Identification Product Name: Triethanolamine Contact Information:

Catalog Codes: SLT3841, SLT1822

CAS# 1 02-7 1 -6

RTECS: KL9275000

Sciencelab.com, Inc. 14025 Smith Rd. Houston, Texas 77396

US Sales: 1-800-901 -7247 International Sales: 1-281 441-4400

TSCA: TSCA 8(b) inventory: Triethanolamine

CI#: Not applicable.

Synonym: Trolamine; Tri(Zhydroxyethy1)arnine; Triethanolamine International CHEMTREC, call: 1-703-527-3887

Chemical Name: Ethanol,2,2',2"-nitrilotris-

Chemlcal Formula: (HOCH2CH2)3N

Order Online: ScienceLab.com

CHEMTREC (24HR Emergency Telephone), call: 1-800-424-9300

For non-emergency, assistance, call: 1-281-441 -4400

position and Information on Ingredients

3: Hazards Identification Potential Acute Health Effects: Hazardous in case of skin contact (permeator), af eye contact (irritant), of ingestion, of inhalation. Slightly hazardous in case of skin contact (irritant).

Potential Chronic Health Effects: CARCINOGENIC EFFECTS: 3 (Not classifiable lor human.) by IARC. MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Not available. The substance may be toxic to kidneys, liver, skin. Repeated or prolonged exposure to the substance can produce target organs damage.

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h

Section 4: First Aid Measures

Eye Contact: Check for and remove any contact lenses. Immediately flush eyes with running water for at least 15 minutes, keeping eyelids open. Cold water may be used. Get medical attention. Finish by rinsing thoroughly with running water to avoid a possible infection.

Skin Contact: Wash with soap and water. Cover the irritated skin with an emollient. Get medical attention if irritation develops. Cold water may be used.

Serious Skin Contact: Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek medical attention.

Inhalation: If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical attention.

Serious inhalation: Not available.

Ingestion: Do NOT induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious person. Loosen tight clothing such as a collar, tie, belt or waistband. Get medical attention if symptoms appear.

Serious ingestion: Not available.

I

Flammability of the Product: May be combustible at high temperature.

Auto-ignition Temperature: Not available.

Flash Points: CLOSED CUP: 179.44"C (355°F). OPEN CUP: 190.5"C (374.9"F) (Cleveland).

Flammable Limits: Not available.

Products of Combustion: These products are carbon oxides (CO, C02).

Fire Hazards in Presence of Various Substances: Slightly flammable to flammable in presence of open flames and sparks, of heat. Non-flammable in presence of shocks.

Explosion Hazards In Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available.

Fire Fighting Media and instructions: SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use water spray, fog or foam. Do not use water jet.

Special Remarks on Fire Hazards: Not available.

Special Remarks on Explosion Hazards: Not available.

~ ~~ ~ ~~ ~~

Section 6: Accidental Release Measures

Small Spill: Dilute with water and mop up, or absorb with an inert dry material and place in an appropriate waste disposal

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container. If necessary: Neutralize the residue with a dilute solution of acetic acid. Finish cleaning by spreading water on the contaminated surface and dispose of according to local and regional authority requirements.

Large Spill: If the product is in its solid form: Use a shovel to put the material into a convenient waste disposal container. If the product is in its liquid form: Absorb with an inert material and put the spilled material in an appropriate waste disposal. Neutralize the residue with a dilute solution of acetic acid. Finish cleaning by spreading water on the contaminated surface and allow to evacuate through the sanitary system. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.

Precautions: Keep locked up.. Keep away from heat. Keep away from sources of ignition. Empty containers pose a fire risk, evaporate the residue under a fume hood. Ground all equipment containing material. Do not ingest. Do not breathe gadfumed vapor/spray. Wear suitable protective clothing. In case of insufficient ventilation, wear suitable respiratory equipment. If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes. Keep away from incompatibles such as oxidizing agents, reducing agents, organic materials, metals, acids.

Storage: Hygroscopic. Light Sensitive. Store in light-resistant container. Keep container tightly closed. Keep container in a cool, well-ventilated area. Do not store above 23°C (73.4"F).

controls to keep the airborne concentrations of vapors below their wash stations and safety showers are proximal to the

work-station location.

Personal Protectlon: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent.

Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.

Exposure Limits: TWA: 5 from ACGIH (TLV) [United States] [2001] Consult local authorities for acceptable exposure limits.

Section 9: Physical and Chemical Properties

Physical state and appearance: Liquid. (Clear viscous liquid.)

Odor: Ammoniacal. (Slight.)

Taste: Not available.

Molecular Weight: 149.19 g/mole

Color: Colorless to light yellow.

pH (1% solnlwater): 10 [Basic.]

P. 3

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~~

Boiling Point: 335°C (635°F)

Melting Point: 21.5"C (70.7"F)

Critical Temperature: Not available.

Specific Gravity: 1.12 (Water = 1 )

Vapor Pressure: 0 kPa (@ 20°C)

Vapor Density: 5.1 (Air = 1 )

Volatlllty: Not available.

Odor Threshold: Not available.

WaterlOil Dlst. Coeff.: The product is more soluble in water; log(oi1hater) = -1

Ionicity (In Water): Not available.

Dispersion Properties: See solubility in water, methanol, acetone.

Solubility: Easily soluble in cold water, hot water. Soluble in methanol, acetone. Very slightly soluble in diethyl ether, n-octanol.

nd Reacthity Dat

Stability: The product is stable.

instability Temperature: Not available.

Conditions of Instability: Excess heat, light, exposure to air, exposure to moist air or water, incompatible materials

Incompatibility with various substances: Highly reactive with oxidizing agents, acids. Reactive with reducing agents, organic materials, metals. Slightly reactive to reactive with moisture.

Corrosivity: Corrosive in presence of steel, of aluminum, of zinc, of copper. Non-corrosive in presence of glass.

Special Remarks on Reactivity: Very hygroscopic. Turns brown on exposure to air and light.

Special Remarks on Corrosivity: Not available.

Polymerization: Will not occur.

Section 11 : Toxicological Information Routes of Entry: Absorbed through skin. Dermal contact. Eye contact.

Toxicity to Animals: Acute oral toxicity (LD50): 2200 mg/kg [Rabbit].

Chronic Effects on Humans:

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I

CARCINOGENIC EFFECTS: 3 (Not classifiable for human.) by IARC. MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells. May cause damage to the following organs: kidneys, liver, skin.

Other Toxic Effects on Humans: Hazardous in case of skin contact (permeator), of ingestion, of inhalation. Slightly hazardous in case of skin contact (irritant).

Special Remarks on Toxicity to Animals: LD50 [Rat] - Route: Oral; Dose: 4920 ul/kg LD50 [Rabbit] - Route: Skin: Dose: >20ml/kg

Special Remarks on Chronic Effects on Humans: May cause cancer (tumorigenic) based on animal data. May affect genetic material (mutagen): cytogenic analysis (human lymphocyte) 100 umol/L: sister chromatid exchange (human lymphocyte) = 1 mmol/L.

Special Remarks on other Toxic Effects on Humans: Acute Potential Health Effects: Skin: May cause skin irritaiton with burning pain, itching, and redness. May be absorbed through the skin amd affect the liver, metabolism, and urinary tract. Eyes: Causes eye irritation with tearing and burning pain. May cause transient corneal injury. Ingestion: Causes gastrointestinal (digestive) tract irritation with nausea, vomitig, and diarrhea. May also affect behavior, sense organs, liver and urinary system. Inhalation: Inhalation of mist may cause respiratory tract irritation. May also affect the liver, blood, urinary system and cardiovascular system. Chronic Potential Health Effects: May cause liver and kidney damage. Prolonged or repeated contact may cause skin necrosis and /or ulceration of the skin.

on 12: Ecological Information

BODS and COD: Not available.

Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may

Toxicity of the Products of Biodegradation: The product itself and its products of degradation are not toxic.

tdation: Not available.

13: Disposal Considerations

Waste Disposal: Waste must be disposed of in accordance with federal, state and local environmental control regulations.

Sectian 14: Transport Information

DOT Classification: Not a DOT controlled material (United States).

Identification: Not applicable.

Special Provisions for Transport: Not applicable.

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1:

Section 15: Other Regulatory Information .

Federal and State Regulations: Rhode Island RTK hazardous substances: Triethanolamine Pennsylvania RTK: Triethanolamine Minnesota: Triethanolamine Massachusetts RTK Triethanolamine TSCA 8(b) inventory: Triethanolamine TSCA 8(d) H and S data reporting: Triethanolamine

Other Regulations: OSHA Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200). EINECS: This product is on the European Inventory of Existing Commercial Chemical Substances.

Other Classifications:

WHMIS (Canada): Not controlled under WHMlS (Canada).

DSCL (EEC): R36- Irritating to eyes. R40- Possible risks of irreversible effects. S2- Keep out of the reach of children. S36/37- Wear suitable protective clothing and gloves. S46- If swallowed, seek medical advice immediately and show this container or label.

HMlS (U.S.A.):

Health Hazard: 2

Fire Hazard: 1

Reactlvlty: 1

Personal Protection: h

National Fire Protection Association (U.S.A.):

Health: 2

Flammability: 1

Reactivity: 1

Specific hazard:

Protective Equipment: Gloves. Lab coat. Vapor respirator. Be sure to use an approvedkertified respirator or equivalent. Splash goggles.

~~

Section 16: Other Information

References: -The Sigma-Aldrich Library of Chemical Safety Data, Edition II. -Hawley, G.G.. The Condensed Chemical Dictionary, 1 l e ed., New York N.Y., Van Nostrand Reinold, 1987, RTECS

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.

data base.

Other Special Considerations: Not available.

Created: 10/10/2005 08:31 PM

Last Updated: 1011 0/2005 08:31 PM

The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to detetmine the suitability of the information for their parficularpurposes. In no went shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.

1 I I I

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.. ... . . . . .

A LOCAL - NATIONAL POISON CONTROL UNIT OR THE ARCH CHEMICALS EMERGENCY PHONE (24 hours: In the USA): (423) 780-2970.

PRODUCT NAME: WAYHIIBa S

1. IDENTIFICATION OF THE SUBSTANCED'REPARATION AND OF THE COMPANYKJNDERTAKING

REVISION DATE: 10-06-:!003 SUPERCEDE S : 09-05-;!003

MSDS NO: 00806-0002 - 100090 SYNONYMS: CHEMICAL FAMILY: Phosphate ester DESCRIPTION / USE: FORMULA: Not applicable/h.lixture

Polyphosphoric acids, esters with triethanolamine, sodium salts

FOR IADUSTRIAL USE ONLY

Arch Chemicals, Inc., B.V. Watery Lane Swords, Dublin, Ireland Telephone: +353 1 890 8000

2. COMPOSITION/INFORMATION ON INGREDIENTS - I m l u 3 w %Range l3JEks 69 - 71 Polyphosphoric acids, ester with triethanolarnine, 268-625-3 68131-72-6 NO data

sodium salts Phosphoric acid 23 1-633-2 7664-38-2 c R34 20 - 22 Water 132-791-2 7732-1 8-5 No data 7-1 0 Triethanolamine 203-049-8 Proprietary None 1-3

3. HAZARDS IDENTIFICATION

Product Classification: Irritant

Routes of Entry: Chemical Interactions:

Medical Conditions Aggravated: None known

R36/38 : hitating to eyes and skin. Inhalation, skin, eyes, ingestion Mixture with nitrites can form nitrosamines which have caused cancer in laboratory animals.

WAYHIE%@ S Page 1 of 7

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i.

Inhalation:

nnation available.

If breathing is difficult, give oxygen. Call a physician.

comes in contact with the product, the clothing should be removed immediately and laundered before re-use. Call a physician. IF IN EYES: Immediately flush eyes with plenty of water for at least 15 minutes whi holding eyelids apart. Call a physician immediately. IF SWALLOWED: Call a physician immediately. DO NOT induce vomiting unless directed to do so by a physician. Never give anything by mouth to an unconscious person.

Eyes:

Ingestion:

WAYHIBB S Page 2 of 7

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u I I I - w u ~ ~ ~ ~ I ~ ~ ~ u U I C ~ L I I I I I ~ apparams (3LBA). Use water to cool containers. Carbon monoxide, Carbon dioxide, Oxides of nitrogen, Phosphorus compounds

Hazardous Combustion Products:

6. ACCIDENTAL RELEASE MIEASURES

Personal Protection for Emergency Situations:

, .

rocedures Air Release:

Water Release:

Land Release:

Additional Spill Information:

Additional protective clothing must be worn to prevent personal contact with this material. Those items include but are not limited to boots, impervious gloves, hard hat, splash-proof goggles, impervious clothing, i.e., chemically impermeable suit, self-contained breathing apparatus.

Vapors may be suppressed by the use of water fog. Hazardous concentrations in air may be found in local spill area and immediately downwind. Contain all liquid for treatment and/or disposal as a (potential) hazardous waste. This material is heavier than water. This material is miscible in water. Noti@ all downstream users of possible contamination. Divert water flow around spill if possible and safe to do so. If unable to divert, create a filtration dam to remove material. Continue to handle as described in land spill. Create a dike or trench to contain materials. Absorb spill with inert material (e.g., dry sand, clay, earth or commercial absorbent), then place in a chemical waste container. Do not place spill materials back in their original containers. Containerize and label properly and remove to a secure location forproper disposal. Decontaminate all clothing and the spill area using a detergent and flush with large amounts of water. Evacuate all non-essential personnel. Hazardous concentrations in air may be found in local spill area and immediately downwind. Stop source of spill as soon as possible and notify appropriate personnel. Utilize emergency response personal protection equipment prior to the start of any response. Dispose of spill residues per guidelines under Section 13, Disposal Consideration.

7. HANDLING AND STORAGE

Handling: Do not take internally. Avoid contact with skin, eyes and clothing. Upon contact with skin or eyes, wash off with water. Avoid breathing mist or vapor. Store in a cool, dry and well ventilated place. Isolate from incompatible materials. Store in a tightly closed container. 3 years If stored in the original container in a cool, dry place. ferrous metals, strong oxidizing agents, water reactive materials 43 Deg. C. 1 10 Deg. F.

FOR INDUSTRIAL USE ONLY

Storage:

Shelf Life Limitations: Incompatible Materials for Storage: Do Not Store At temperatures Above: DESCRIPTION / USE:

WAYHIBB S Page 3 of 7

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Eyes: Protective Clothing Type: Other PPE: Environmental exposure controls:

CHEMICAL NAME

Orthophosphoric acid

CHEMICAL NAME Phosphoric acid

suit is recommended if exposure is possible to a large portion of the body. Use chemical goggles. Neoprene An eye wash and safety shower should be provided in the immediate work area. Refer to Section 6, "ACCIDENTAL RELEASE MEASURES"

UK Occupational UK Maximum Exposure Exposure Imw

7664-38-2 1 mdm3 TWA Not established 2 mdm3 STEL Indicative Occupational Exposure Limit Values 1 mdm3 TWA 2 m g h 3 STEL

LilDiu . . CAS-#

i2W.t 7664-38-2

9. PHYSICAL AND CHEMICAL PROPERTIES

Physical State: Color: Odor Molecular Weight: PH OctanoVWater CoeE Solubility in Water: Fat Solubility: Viscosity: Bulk Density: Specific Gravity: Vapor Density:

Vapor Pressure: Evaporation Rate: Volatiles, % by vol.: Boiling Point:

Freezing Point:

Oxidising Properties:

liquid amber very mild ammonia

Not Applicable/Mixture (@ 25 Deg. C) 4 - 6 (5% solution in neutral, distilled water)

No data Miscible No data No data 1.5 - 1.56 CC 1.5 - 1.56 Approximately 1 .OO (water = 1) Vapor contains only water. (@ 25 Deg. C) < 24 mmHg

Approximately 1.00 (water = 1) 10 % > 100 Deg. C. > 212Deg.F. < 0 Deg. C. < 32 Deg. F.

No data

Flammable Properties Flash Point: None

WAYHIJ3B S Page 4 of 7

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o..ll~~~l V G LU nlecnanicru snock. Hazardous Polymerization: Will not occur Conditions to Avoid: High temperatures Chemical Incompat strong oxidizing agents Hazardous Decomposition P

Decomposition Temperature:

arbon monoxide, Carbon dioxide, phosphorus oxides, oxides of

es Above: > 100 Deg. C. > 212 Deg. F.

Oral LD50 value: Phosphoric acid Dermal LD50 value: Phosphoric acid

Rat Approximately 2 g k g

Rabbit > 2 g k g Inhalation LC50 value: No data

Product Animal Toxicity: Oral LD50 value: Dermal LD50 value: Skin Irritation: . . 'I%isdmatwial*is expected to be severely irritating. Eye Irritation: This material is expected to be severely irritating.

Believed to be 2.0 - 5.0 gkg; slightly toxic Believed to be > 2.0 gkg; practically non-toxic..

Reproductive and Developmental Toxicity: development.

This chemical is not known or reported to affect reproductive function or fetal

/

Mutagenicity: Not known or reported to be mutagenic.

This product was determined to be non-mutagenic in the Ames assay. This produlct has been shown to be negative for cell transformation in the Syrian hams er embryo (SA7/SHE) cell assay. This product has been shown to be non-mutagenic based on a battery of assays. This chemical is not known or reported to be carcinogenic by any reference source including IARC or NTP.

The carcinogenicity has been evaluated through animal study and it was found not to be carcinogenic in most studies and equivocal in at least one study. Expowre would not be expected to pose a carcinogenic hazard.

Component Data: Phosphoric acid

Triethanol amine Carcinogenicity:

Component Data: Triethanol amine

Page 5 of 7 WAYHIBE S

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7-

CARE MUST BE TAKEN TO PREVENT ENVIRONMENTAL CONTAMINATION FROM THE USE OF THIS MATERIAL. THE USER OF THIS MATERIAL HAS THE RESPONSIBILITY TO DISPOSE OF UNUSED MATERIAL, RESIDUES AND CONTAINERS IN COMPLIANCE WITH ALL RELEVANT NATIONAL AND EU LAWS, DIRECTIVES AND REGULATIONS REGARDING TREATMENT, STORAGE AND DISPOSAL FOR HAZARDOUS AND NONHAZARDOUS WASTES.

14. TRANSPORT INFORMATION

Air (IATAACAO): Not Regulated Water (IMO): SAME AS AIR

Land (ADIURID): NOT REGULATED Flash Point: (C) Not Applicable

/ * . 15. REGULATORY INFORMATION

EU labeling: Product Classification: Risk Phrases:

Safety Phrases:

Symbols:

Irritant

Xi, R36/38

R36/38 : Irritating to eyes and skin.

S24/25 Avoid contact with skin and eyes. S36: Wear suitable protective clothing. S37 Wear suitable gloves.

WAYHIBQ S Page 6 of 7

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THIS SAFETY DATA SHEET (SDS) IUS BEEN PREPARED IN COMPLIANCE WITH THE RELEVANT EU DIRECTIVES AND REGULATIONS TIIE INFORMATION INTHIS SDS SHOULD BE PROVIDEDTO ALL WHO WILL USE, HANDLE, STORE, TRANSPORT, OR OTHERWISE BE EXPOSED TO THIS PRODUCT. THIS INFORMATION HAS BEEN PREPARED FOR THE GUIDANCE OF PLANT ENGINEERING, OPERATIONS AND MANAGEMENT AND FOR PERSONS WORKING WITH OR HANDLING THIS PRODUCT ARCH CHEMICALS BELIEVES THIS INFORMATION TO BE RELIABLE AND UP TO DATE AS OP THE DATE OF PUBLICATION BUT, MAKES NO WARRANTY THAT IT IS ADDITIONALLY, IF THIS SDS IS MORE THAN THREE YEARS OLD, YOU SHOULD CONTACT ARCH CHEMICALS AT THE PHONE NUMBER ON THE FRONT PAGE TO MAKE CERTAIN THAT THIS DOCUMENT IS CURRENT

WAYHIl363 S

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0

0

0

0

0

0

0

0

0

0

@

8

Warm Triethanolamine (TEA) and Polyphosphoric acid with drum warmers (Warm to approx 50°C to help materials to flow) Draw vacuum on reactor RE-603 and charge polyphosphoric acid Heat the batch to 80-85°C using tempered water loop Charge TEA through metering pump at controlled rates (the reaction is exothermic)Maintain the batch temperature at 80-90°C for the first part of the TEA charge and at 90-95°C for the remainder of charge (Highly elevated temperatures cause product disco1oration)Hold the batch for 1 hour at 90-95°C Charge water and hold for 30 minutes Cool the reactor to 40-45°C Charge 50% NaOH and hold (the reaction is also exothermic) Maintain the batch temperature between 40-70°C Break vacuum on the vessel Re-circulate the batch through external filters and sample Adjust pH as needed Drum-out through polishing filters at 40-60°C (Material is very viscous) Boil-out reactor with water and dry with vacuum after each batch

C:',,Docutnents and Settings\mogo\Local Settings\Temporary Internet Files\OLK8C\Swords Process Overvielv. doc Lmt printed 11/12/2005 4:08:00 PM

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Pamell House 14 Parnell Square, Dublin 1.

H 1785

Tel: (01) 8045200 Fax: (01) 8045222

- ARCH CJWMTCALS B.V.

Originally callcd OT,lN CHEMlCALS B.V.

1 certify that the particulars prcscribr by the above-named Company on thc Company is incorporated in the this country at

e Companies Act, 19 ulars disclosed that the I place of business in

Swords,

Ca.Dublin, -

and that

3 1 Be ttyslown, Co.Meath.

Is the person authorised to accept scwice of process and any notices required to be served on the company in this country.

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RETURN OF ALTERATION IN THE CHARTER, STATUTES, MEMORANDUM OR ARTICLES OF ASSOCIATION OR OTHER INSTRUMENT CONSTITUTING OR

DEFINING "ME CONSTHTUTION OF A COMPANY

Pursuant to Smtion 353 of the Comprnies Act, 1963 Pursunnt to Regulations 4(3) and 7(3) of &e Europctan Communities (Branch Disclosures) Regulations, 1993.

Name and legal form of Chmpariy

Arch Clismlcals R . V . (formerly called O l i n Chemi.cals R.V.) PrLvate I Xrnited company ,-

bsenter's Name ............................... A & L Golidbody .r Solicitors .......................................................................................

1 Earlsfort Centrct, Hatch Street., Dublin 2. Address ......................................................................................................................................

LRWNHM Reference Telephone Number ..................... ....................... 661 3311

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, I !

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. ~ . I - *... - I

I '

Chemicals B.V.)

Cerdfied copy of (i) any docurnen o r Articles of hssociauon and (ii) assmiation must accompany this

evidencing an alteration in company's Memorandum ended text of it$ memorandum or ankles of

Signature of a person authorised Section 352( I )(c> of the Compru

ease may be. (b) Country of incorporation.

r...

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