NCS000041_Letter Response to NOV_20080701

2, and 3..AIso complete
item 4 if ResDelivery is desired._
Com lete ite1:returri,_ihecardto
■ Print your nand address on the reverse
so that We-dyou.
s ■ Attach this and to the back. of the maiipiece,
or on the ront if space permits.
A. Signature
X ' ❑Agent
❑Addressee
B. eceived by.(Printe Name)
C. Date of Delivery '.
D. Is delFvery addr Ali ia+yn Ft
If YES; enter elive�r ddress b'�Iy:
'. 1. ArticleAddre d to.
,
MR KEN GOLDER, PRESIDENT
CLARIANT CORPORATION- -
PD BOX 18278
CHARLOTTE NC 28218
Sw' /ma 6/17/08 I
'JUN 23 2008
--
a, Service Type
Certified Mail ail
teglslered ❑ Return newpt for Morchandlea
❑ Insured Mail 0 C.O.D.
4. Restricted Delivery? (Fkdra Fee) ❑ Yes
2 Ari'-
�r ?Q�7 '1490-:0004 - -45-09 : 5324
PS Form 381 1,,February 2004 Domestic Return Receipt 102595-02-M-1540
�� 1 // A\FAYAribWAVNAA`flNN+ C .K.YMIUY4HaS�.��V+\N\\ HV�.Cp
First -Class Mail
UNITED STATES POSTAL SERVICE a b'a Pal
tom! '% GA0
• Sender: Plea in our name, addresS;'anif
�
NCDENR
CL WATER PROTECTION
10 EAST CENTER AVE
SUITE 301
ORESVILLE NC 28115
c

:Z��
Clariant
Clariant Corporation
July 1, 2008
4000 Monroe Road
Charlotte, NC 28205
704.331.7000
Ms, Marcia Allocco
Surface Water Protection Section
Division of Water Quality — Mooresville Regional Office
610 East Center Ave: Suite 301
Mooresville, NC 28115
Re: Notice of Violation — NOV-2008-DV-0267
Clariant — Mount Holly West Facility
Stormwater Permit NCS000041
Gaston County, North Carolina
Dear Ms. Allocco:
Michael A. Teague
Writer's Direct Dial No.: 704/331-7104
Fax No.: 704/330-1528
E-Mail: [e-mail]
J U L - 1)^^0
NC DENR MR0
M-Surface Waller Protection
This letter responds to the June 17, 2008 Notice of Violation (NOV) referenced above.
You will find in the paragraphs below a full description of the incident described in the NOV as
well as Clariant's response actions. We have incorporated in this text responses to each question
listed in the NOV.
Investigation of Incident Cause
On June 3'd Clariant and representatives from the Mooresville Regional Office
discovered the presence of an unknown substance at Stormwater Outfall 006 and its collection
system. After undertaking immediate response actions, described below, Clariant investigated
the circumstances and cause of the incident. Clariant's investigation revealed that a chemical
sump pump and an electronic level detector for this sump malfunctioned. The sump is designed
to receive waste water from an air pollution control device (scrubber), vacuum pump drainage
and stormwater from material storage areas. The failure of the sump pump and level detector
resulted in an overflow from the chemical sump into the stormwater drain. The underlying
reason for the pump malfunction could not be determined; however the damage is consistent
with damage from a power surge (for example, during an electrical storm).
Initial Response Actions and Remediation
In response to finding the material in the stormwater drain, and as a protective measure,
plant environmental personnel immediately blocked the drain at the river's edge to prevent any
flow of water through it. All visible material was then removed from both the pipes and the
ditch. The system was then flushed several times with water until only clear rinse water was
observed. Additionally, on June 4, the top several inches of soil were removed from the ditch, as

July 1, 2008
Page 2
well as visibly stained rocks. Clariant is storing the soil and wash water on -site while they are
being profiled for determination of disposal options.
The stormwater piping was also pressure washed to ensure that no residue remained.
This wash water was collected in a vacuum truck and disposed into the site's wastewater
treatment facility. The drain was unblocked on June 9.
Determination of Chemical Identity of Material in Stormwater Drain
Clariant investigated the identity of the substance found in the drain. On June 3, 2008,
plant environmental personnel took two grab samples of the unknown liquid discovered in
Outfall 6. One sample ("Sample 1") was taken approximately 10 feet above the confluence of
the outfall and the Catawba River. The second sample ("Sample 2") was taken immediately
above the outfall 6 control gate. (Attached map, Exhibit 1, identifies sample locations) The
samples were tested onsite for pH, which ranged from 8.0 (Sample 1) to 11.7 (Sample 2). They
were also sent for additional testing at Clariant's in-house analytical laboratory. Based on these
analyses and our knowledge of the materials discharged from the processes into the chemical
sump, we believe the material from the drain to be liquid from the air pollution control scrubber.
The scrubber liquid is generally composed primarily of water, with sodium hydroxide and raw
materials or products that are produced in Plant 5.
As described above, after the initial testing performed at the site, the in-house analytical
laboratory performed total metals analysis by ICP. Trace amounts of a variety of metals were
detected. Sodium was slightly elevated due to the presence of sodium hydroxide from the air
pollution control device.
In addition to the metals analysis, volatiles and semi-volatiles were extracted in
chloroform without further concentration. The resulting chloroform solution was scanned by
GC/MS for a qualitative analysis. The GC/MS scan showed one major peak, accounting for 99
percent of the extracted fraction, with numerous trace peaks accounting for the other one percent.
The major peak was determined by the lab to be to be N, N-dimethyl alkyl (C12-C18) amines.
This analytic result is consistent with our review of production records which show two amines
recently used in production campaigns. A copy of the MSDS for each of these amines is
attached as Exhibits 2 and 3.
Measures Taken to Prevent a Recurrence of This Problem
In response to this incident, the damaged pump and level detector were immediately
repaired and tested. All other drains, pumps and level detectors in Plant 5, the manufacturing
building where the malfunction occurred, have been thoroughly inspected and tested. The
system was also modified to prevent overflow to the stormwater system in the event of power
failure or other malfunction. Specifically, the sump was modified so that any future overflow
will be routed into a large contained area (a tank farm dike) that has more than enough capacity
to contain the entire sump volume. Here the overflow will be collected and readily apparent to

July 1, 2008
Page 3
employees during routine operations in the containment area. A picture of this modification is
attached as Exhibit 4.
This plant had been idled since 2001 date and was put back into service by Clariant in
March 2008. Clariant has examined all remaining sumps in this plant for similar issues and
found no other issues that might lead to potential sump overflows. Clariant also inspected the
other production units at the Mount Holly site and confirmed that similar sump configurations
did not exist.
Communication with Regulators and the Community
The North Carolina Department of Environment and Natural Resources was on -site at the
time of discovery of the materials in the storm drain. In addition to information provided to
DENR representatives at that time, on June 10, 2008, additional information was provided to the
Division of Water Quality during an in -person follow-up meeting. The additional documents
included information on analytical results from testing the material found in the storm drain
(Exhibit 5) and the MSDSs for the amines detected in the samples described above (Exhibits 2
and 3). Subsequent to this meeting, a picture showing the modification to the sump, which
rerouted any potential overflow to the tank farm dike was provided to Rob Krebs by email on
June 11, 2008. (Exhibit 4)
Clariant reviewed the substances identified in the lab analysis for reporting under
applicable regulations. The only substance present that is subject to reporting requirements is
sodium hydroxide. The amount of sodium hydroxide that could have been released was
determined using a worst -case estimation approach. These calculations show that no Reportable
Quantity release threshold was met under applicable regulations. As a result, no additional
regulatory reporting was determined to be required. However, Clariant voluntarily informed its
local Community Advisory Panel, the Catawba Riverkeeper Foundation, Charlotte -Mecklenburg
Storm Water Services, Mount Holly City officials and Gaston County's state legislative
delegation about the situation. Clariant also notified the local newspapers and television stations
of this incident in an effort to communicate to the public the facts about this incident and the
responses taken by Clariant.
If you have any further questions regarding this incident or Clariant's responses please
feel free to contact zne.
Very truly yours,
///1W/
Michael A. Teague
t�
Vice President Environmental, Safety and Health Affairs
c: Ken Golder
Andre Pollard

(71
1"--tb"HE�7 of Contents
Diagram identifying sample locations
RFADY INDEXINDEXING YSTEC•,5 60001

f

Clariant
MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D Page 1
Substance key: SXR024598 Revision Date: 11/23/2007
Version: 1 - 5 / USA Date of printing :11/29/2007
Section 01 - Product Information
Identification of the Clariant Corporation
company: 4000 Monroe Road
Charlotte, NC, 28205
Telephone. No - [phone]
Trade name:
CAS number:
Synonyms:
Primary product use:
Chemical family:
Hazardous ingredients:
Information of the substance/preparation:
Product Safety 1-704-331-7710
Emergency tel. number: [phone] CHEMTREC
GENAMIN LA 302 D
112-18-5
Product Has No Synonyms
Raw material
Dimethyl lauryl amine, distilled
Component CAS -no. (Trade secret Concentration
no.)
Dimethyldodecylamine 112-18-5 100 %
Emergency overview:
Expected Route of entry:
Inhalation:
Skin contact:
Eye contact:
Ingestion:
Known effects on other illnesses:
Clear, colorless liquid.
Corrosive
I oxic to aquatic organisms
Vapors and/or mists are probably corrosive to
respiratory passages, and may cause ulcerations
of the nose, throat, and larynx.
Corrosive, may cause permanent skin injury.
Not expected to be toxic by skin absorption.
Corrosive to the eye.
The acute oral toxicity of this material is between
500 and 5000 mg/kg. Relative to other materials,
this material is classified as slightly toxic by
ingestion.
This material will probably cause chemical burns of
the mouth , pharynx, esophagus, and stomach in
humans following ingestion.
No known effects on other illnesses for this
product.

C1ariant
MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D Page 2
Substance key: SXR024598 Revision Date: 11/23/2007
Version: 1 - 5 / USA Date of printing :11/29/2007
Listed carcinogen: IARC: No
NTP: No
OSHA: No
Other: No
HMIS:
Health: 3 Flammability: 1 Reactivity: 0 Personal protection: D
Section 04 = First aid measures
After inhalation:
Get victim to fresh air. Give artificial respiration or oxygen if breathing has stopped. Get
prompt medical attention. Do not give fluids if victim is unconscious.
After oontoct with skin:
Immediately flush with large amounts of water. Remove contaminated clothing, including
shoes, and wash contaminated area(s) with soap and water. Seek medical attention. Failure
to decontaminate may result in delayed burns. Contaminated clothing cannot be washed
clean and should not be reused for any purpose.
After contact with eyes:
Immediately flush eyes with running water for at least 15 minutes, occasionally lifting the
upper and lower eyelids. Seek prompt medical attention if redness or irritation occurs.
After ingestion:
If conscious, give the patient 1-2 glasses of water (8-16 oz.) and call a doctor. Never give
anything by mouth to an unconscious person. Induce vomiting only at the instructions of a
doctor or nurse.
Advice to doctor / Treatment:
Corrosive. May cause stricture. If lavage is performed, suggest endotracheal and/or
esophagoscopic control. If burn is present, treat as any thermal burn, after decontamination.
No specific antidote. Supportive care. Treatment based on judgement of the physician in
response to reactions of the patient.
Section 05 - Fire f htin d ,measures
Flashpoint:
Lower explosion limit:
Upper explosion limit:
Self ignition:
Ignition temperature:
> 212 OF
Method: DIN/ISO 2592 (open cup)
not tested.
not tested.
Not applicable
not tested.
Hazardous combustion products:
In case of fires, hazardous combustion gases are formed: Carbon monoxide (CO)
Nitrous gases (NOx)
Extinguishing media: water spray jet
foam
carbon dioxide
dry powder

MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D
Substance key: SXR024598
Version: 1 - 5 / USA
CIariant
Page 3
Revision Date: 11/23/2007
Date of printing :11/29/2007
Special fire fighting procedure:
Exercise caution when fighting any chemical fire. Use NIOSH approved self-contained
breathing apparatus and full protective clothing.
Unusual fire and explosion None known.
hazards:
Steps to be taken in case of spill or leak:
Wear proper protective equipment. Contain spill. Spills should be collected as a liquid or
absorbed on suitable absorbant and placed in proper containers for disposal. Do not
discharge into storm drains or the aquatic environment.
Advice on safe handling:
Store in steel or glass lined storage vessels.
Further info on storage conditions:
Store in original container.
Keep containers closed.
No level has been established by OSHA, NIOSH, ACGIH.
Respiratory protection:
If airborne concentrations pose a health hazard, become
irritating or exceed recommended limits, use a NIOSH approved
respirator in accordance with OSHA respiratory protection
requirements under 29 CFR 1910.134
Hand protection:
Neoprene or Vlton
Eye protection:
Chemical splash goggles and full face shield.
Other protective equipment:
Protective clothing to minimize skin contact should be worn.
Chemically resistant safety shoes. Wash contaminated
clothing with soap and water and dry before reuse. Safety
showers and eyewash stations should be provided in all areas
where this material is handled.
Advice on system design:
Local ventilation recommended - mechanical ventilation may
be used.
MILK
Not Determined
Section 09 - Physical and chemical properties?
Form: Liquid

t?
MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D
Substance key: SXR024598
Version: 1 - 5 / USA
Color:
colourless to slightly yellow
Odor:
amine -like
pH:
not tested.
Solubility in water:
insoluble
Soluble in ...:
fat
not tested.
Density:
0.77 g/cm3 (60 °C)
Method: DIN 51757
Pourpoint :
< 14 OF
Method: DIN/ISO 3016
Boiling temperature:
500 - 557 OF
Method: Calculated by Syracuse.
Vapor pressure:
< 0.01 Torr (25 °C)
Method: Calculated by Syracuse.
Bulk density:
Not applicable
Relative vapor density:
not tested.
Partitioning coef.
Not applicable
octanol/water:
Viscosity / (kinematic):
not tested.
Section 10 - Stabilit and reactivit"
Thermal decomposition: > 400 °C (Heating rate:3 K/min)
Method: DSC
Source: Analogy
Chemical stability: Stable.
Hazardous Polymerization: Will not occur.
Conditions to avoid: None known.
Section.11'-;Tozcolo `ical information
Product information:
Acute oral toxicity: LD50 1,200 mg/kg (rat)
Acute inhalation toxicity:
Acute dermal toxicity:
Skin irritation:
Eye irritation:
Method: OECD 401
not tested.
not tested.
Corrosive (rabbit)
Not available
Section 12 - Ecological information
Clariant
Page 4
Revision Date: 11/23/2007
Date of printing :11/29/2007

MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D
Substance key: SXR024598
Version: 1 - 5 / USA
Product information:
Biodegradation:
Fish toxicity:
Daphnia toxicity:
Algae toxicity:
Bacteria toxicity:
Chemical oxygen demand
(COD):
Zkt'
Clariant
Page 5
Revision Date: 11 /23/2007
Date of printing :11/29/2007
approx. 70 % (28 d)
readily degradable
Method: OECD 301 F
LC50 0.1 - 1 mg/I (96 h, zebra fish)
Method. OECD 203
EC50 < 1 mg/I (Daphnia magna)
EC50 < 1 mg/I (Scenedesmus subspicatus)
Method: OECD 201
EC50 80 mg/I
Method: OECD 209
2,580 mg/g
Waste disposal information:
This product may be a RCRA hazardous waste when it becomes a waste material due
to corrosivity. Recommended disposal is by incineration in approved facilities. Since
this product may have a pH of 12.5 or more, consideration should be given to treating it
as a hazardous waste for disposal purposes; or make an independent determination of
pH of the waste product or waste mixture for disposal classification purposes.
RCRA hazardous waste:
See Waste Disposal Information in Section 13.
DOT Regulation:
Proper shipping name:
Hazard class:
Packing group:
UN/NA-number:
Primary hazard class:
Technical Name:
Emergency Response
Guide:
IATA
Proper shipping name:
Class:
Packing group:
UN/ID number:
Primary risk:
Remarks:
Hazard inducer(s):
IMDG
Proper shipping name:
Amines, liquid, corrosive, n.o.s.
8
UN 2735
8
Alkyldimethylamines
153
Amines, liquid, corrosive, n.o.s.
8
UN 2735
8
Shipment permitted
Alkyldimethylamines
Amines, liquid, corrosive, n.o.s.

MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D
Substance key: SXR024598
Version: 1 - 5 / USA
Class:
Packing group:
UN no.:
Primary risk:
Hazard inducer(s)
EmS:
UN 2735
8
Alkyldimethylamines
F-A S-B
Section 15 - Regulatory information
TSCA Status:
All components of this product are listed on the TSCA Inventory.
SARA (section 311/312):
Reactive hazard:
no
Pressure hazard:
no
Fire hazard:
no
Immediate/acute:
yes
Delayed/chronic:
no
Clariant
Page 6
Revision Date: 11/23/2007
Date of printing :11/29/2007
SARA 313 information:
This product does not contain any toxic chemical listed under Section 313 of the Emergency
Planning and Community Right -To -Know Act of 1986.
Clean Water Act:
Contains no known priority pollutants at concentrations greater than 0.1%.
Volatile organic compounds VOC:
Remarks: Not Available
FDA:
This product is not registered with the FDA.
Section 16 'Other information, `
Other precautions:
Keep containers tightly closed when not in use.
Label information:
DANGER!
CORROSIVE TO SKIN AND EYES MAY BE HARMFUL IF SWALLOWED THIS
MATERIAL IS TOXIC TO AQUATIC ORGANISMS.
Avoid breathing fumes, vapors, mists or spray. Avoid contact with skin and eyes. Use
with adequate ventilation and/or respiratory protection. Wash thoroughly after handling.
Keep container closed when not in use. Avoid run-off into sewers leading to water
ways.
Eye contact: flush with water for at least 15 minutes while holding eyelids open. Seek
immediate medical attention. Skin contact: immediately flush skin with plenty of water
for at least 15 minutes while removing contaminated clothing and shoes. Get medical

Clariant
MATERIAL SAFETY DATA SHEET
GENAMIN LA 302 D Page 7
Substance key: SXR024598
Version: 1 - 5 / USA
Revision Date: 11/23/2007
Date of printing :11/29/2007
attention. Contaminated clothing cannot be washed clean and should not be re -used
for any purpose. Wash contaminated areas with soap and water.
This information is supplied under the OSHA Hazard Communication Standard, 29 CFR
1910.1200, and is offered in good faith based on data available to us that we believe to be
true and accurate. The recommended Industrial hygiene and safe handling procedures are
believed to be generally applicable to the material. However, each user should review
these recommendations in the specific context of the intended use and determine whether
they are appropriate for that use. No warranty, express or implied, is made regarding the
accuracy of this data, the hazards connected with the use of the material, or the results to
be obtained from the use thereof. We assume no responsibility for damage or injury from
the use of the product described herein. Data provided here are typical and not intended
for use as product specifications. (R) and TM indicate trademarks of Clariant AG, its
business partners or suppliers.

r

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version: 1 - 6 / USA
Identification of the Clariant Corporation
company: 4000 Monroe Road
Charlotte, NC, 28205
Telephone No.: [phone]
Trade name
CAS number:
Synonyms:
Primary product use:
Chemical family:
Hazardous ingredients:
Clariant
Page 1
Revision Date: 11/23/2007
Date of printing :12/22/2007
Information of the substance/preparation:
Product Safety 1-704-331-7710
Emergency tel. number: [phone] CHEMTREC
GENAMIN T 100
6'179'1-26-2
Product Has No Synonyms
Emulsifier
Ethoxylated tallow fatty amine
Component CAS -no. (Trade secret Concentration
no.)
Ethoxylated Tallow Amine 61791-26-2 100 %
Section 03 '- Hazards identification'
Emergency overview: Brown liquid.
Eye irritant.
Expected Route of entry:
Inhalation:
Skin contact:
Eye contact:
Ingestion:
Skin absorption:
Health effects of exposure:
Vapors and/or mists are probably irritating to
respiratory passages, nose, and throat.
Not expected to be irritating to skin.
Not expected to be toxic by skin absorption.
Irritating to eyes.
In humans, irritation of the mouth, pharynx,
esophagus, and stomach can develop following
ingestion of this material.
no
Genamin T 100
Based on animal studies, this product causes eye irritation.
Known effects on other illnesses: Pre-existing eye conditions may be aggravated by
exposure to this product.

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version: 1 - 6 / USA
Listed carcinogen:
HMIS:
Health: 2
[ARC: No
NTP: No
OSHA: No
Other: No
Flammability:1 Reactivity:0
Ztt'
Clariant
Page 2
Revision Date: 11 /23/2007
Date of printing :12/22/2007
Personal protection: D
After inhalation:
Get victim to fresh air. Give artificial respiration or oxygen if breathing has stopped. Get
prompt medical attention. Do not give fluids if victim is unconscious.
After contact with skin:
Wash thoroughly with soap and water for 15 minutes. If skin irritation occurs, seek medical
attention.
After contact with eyes:
Immediately flush eyes with large amounts of water for at least 15 minutes, holding lids apart
to ensure flushing of the entire surface. Washing eyes within 1 minute is essential to achieve
maximum effectiveness. Seek medical attention immediately.
After ingestion:
If ingested, seek medical assistance immediately.
Advice to doctor / Treatment:
None known.
Flashpoint: approx. 554 °F
Method: DIN/ISO 2592 (open cup)
Lower explosion limit: not tested.
Upper explosion limit: not tested.
Self ignition: not self -igniting
Ignition temperature: not tested.
Hazardous combustion products:
In case of fires, hazardous combustion gases are formed: Carbon monoxide (CO)
Nitrous gases (NOx)
Extinguishing media: water spray jet
alcohol -resistant foam
carbon dioxide
dry powder
Special fire fighting procedure:
Wear positive pressure self-contained breathing apparatus (SCBA) and full protective
equipment.
Unusual fire and explosion Emits toxic fumes under fire conditions.
hazards:

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version: 1 - 6 / USA
Clariant
Page 3
Revision Date: 11 /23/2007
Date of printing :12/22/2007
Steps to be taken in case of spill or leak:
Wear proper protective equipment. Contain spill. Spills should be collected as a liquid or
absorbed on suitable absorbant and placed in proper containers for disposal. Do not
discharge into storm drains or the aquatic environment.
Advice on safe handling:
Avoid getting on skin or in eyes when handling product.
Further info on storage conditions:
Keep containers closed.
Respiratory protection: If airborne concentrations pose a health hazard, become
irritating or exceed recommended limits, use a NIOSH approved
respirator in accordance with OSHA respiratory protection
requirements under 29 CFR 1910.134
Hand protection: Butyl Rubber, PVC Or Neoprene.
Eye protection: Chemical splash goggles.
Other protective equipment: Impermeable apron and shoes to prevent skin contact.
Advice on system design: Local ventilation recommended - mechanical ventilation may
be used.
IDLH:
Not Determined
Form:
Liquid
Color:
light brown
Odor:
amine -like
pH:
9 - 10 (20 °C, 10 g/1)
Solubility in water:
(20 °C)
soluble, clear
Soluble in ...:
fat
not tested.
Solubility / qualitative:
soluble in Glycol and Xylene

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version: 1 - 6 / USA
Density:
approx. 0.98 g/cm3 (50 °C)
Method: DIN 51757
Pourpoint :
approx. 23 OF
Method: DIN/ISO 3016
Boiling temperature :
> 482 OF
Vapor pressure:
< 0 Torr (25 °C)
Method: Calculated by Syracuse.
Bulk density:
Not applicable
Relative vapor density:
not tested.
Partitioning coef.
Not applicable
octanol/water:
Viscosity / (dynamic):
approx. 50 mPa.s (50 °C)
Method: DIN 53015
Viscosity / (kinematic):
not tested.
Thermal decomposition:
> 350 °C (Heating rate:3 K/min)
Method: DSC
Source: Analogy
Chemical stability:
Stable.
Hazardous Polymerization:
Will not occur.
Conditions to avoid: None known.
Conditions to avoid:
Avoid contact with strong acids.
Product information:
Acute oral toxicity: LD50 500 - 2,000 mg/kg (rat)
Source: RTFCS
Acute inhalation toxicity: not tested.
Acute dermal toxicity: not tested.
Skin irritation: Non -irritating (rabbit)
Eye irritation: Irritating (rabbit)
Product information:
Biodegradation: approx. 70 %
Method: OECD 302 B
C1ariant
Page 4
Revision Date: 11/23/2007
Date of printing :12/22/2007

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version: 1 - 6 / USA
Fish toxicity:
Bacteria toxicity:
Dissolved organic carbon
(DOC):
Chemical oxygen demand
(COD):
LC50 0.1 - 1 mg/I (96 h, zebra fish)
Method: OECD 203
Clariant
Page 5
Revision Date: 11/23/2007
Date of printing :12/22/2007
EC50 > 1,000 mg/I (Pseudomonas putida)
Method: DIN 38412 T.8
458 mg/g
2,140 mg/g
Waste disposal information:
Recommended disposal is by incineration in approved facilities.
RCRA hazardous waste:
No -- Not as sold.
Section 14':- Transportinformation'
DOT Regulation:
Proper shipping name: Environmentally hazardous substances, liquid, n.o.s.
Hazard class: 9
Packing group: III
UN/NA-number: UN 3082
Primary hazard class: 9
Technical Name: TALLOW FATTY AM INEOXETHYLATE
Emergency Response 171
Guide:
IATA
Proper shipping name:
Environmentally hazardous substance, liquid, n.o.s.
Class:
9
Packing group:
III
UN/ID number:
UN 3082
Primary risk:
9
Remarks:
Shipment permitted
Hazard inducer(s):
TALLOW FATTY AMINEOXETHYLATE
IMDG
Proper shipping name:
Environmentally hazardous substance, liquid, n.o.s.
Class:
9
Packing group:
III
UN no.:
UN 3082
Primary risk:
9
Hazard inducer(s):
TALLOW FATTY AMINEOXETHYLATE
EmS:
F-A S-F
Further information:
Not regulated for surface or air transportation in non -bulk containers under 119
gallons.

MATERIAL SAFETY DATA SHEET
GENAMIN T 100
Substance key: SXR024128
Version : 1 - 6 / USA
TSCA Status:
All components of this product are listed on the TSCA Inventory.
SARA (section 311/312):
Reactive hazard:
no
Pressure hazard:
no
Fire hazard:
no
Immediate/acute:
yes
Delayed/chronic:
no
C1ariant
Page 6
Revision Date: 11 /23/2007
Date of printing :12/22/2007
SARA 313 information:
This product does not contain any toxic chemical listed under Section 313 of the Emergency
Planning and Community Right -To -Know Act of 1986.
Clean Water Act:
Contains no known priority pollutants at concentrations greater than 0.1 %.
Volatile organic compounds VOC:
Remarks: Not Available
FDA:
This product is not registered with the FDA.
Other precautions:
Avoid contact with skin and eyes. Wear proper protective equipment. Wash thoroughly after
handling.
Label information:
WARNING!
CAUSES EYE IRRITATION MAY BE HARMFUL IF SWALLOWED
Avoid contact with eyes, skin and clothing. Wash thoroughly after handling. Wear
proper protective equipment. Keep container closed when not in use.
Eye contact: flush with water for at least 15 minutes while holding eyelids open. Seek
immediate medical attention. Skin contact: wash thoroughly with soap and water for 15
minutes. If skin irritation occurs, seek medical attention. Wash contaminated clothing
before reuse. Ingestion: seek medical attention immediately. Inhalation: remove to
fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen.
Seek medical attention if respiratory irritation continues.
This information is supplied under the OSHA Hazard Communication Standard, 29 CFR
1910.1200, and is offered in good faith based on data available to us that we believe to be
true and accurate. The recommended industrial hygiene and safe handling procedures are
believed to be generally applicable to the material. However, each user should review
these recommendations in the specific context of the intended use and determine whether

Clariant
MATERIAL SAFETY DATA SHEET
GENAMIN T 100 Page 7
Substance key: SXR024128
Version: 1 - 6 / USA
Revision Date: 11/23/2007
Date of printing :12/22/2007
they are appropriate for that use. No warranty, express or implied, is made regarding the
accuracy of this data, the hazards connected with the use of the material, or the results to
be obtained from the use thereof. We assume no responsibility for damage or injury from
the use of the product described herein. Data provided here are typical and not intended
for use as product specifications. (R) and TM indicate trademarks of Clariant AG, its
business partners or suppliers.

r drain

lariant
From the desk of:
Andre J. Pollard
Regional Head of ESHA
Functional Chemicals
625 Catawba Ave
Mount Holly, NC 28120
[phone]
[phone](Cell)
[phone](Fax)
TO: File
SUBJECT: Sampling & Analysis of Outfall 006
Samples 6/3/08
DATE: 6/7/08
June 3, 2008 two grab samples were taken of unknown liquid in outfall 6 by Clariant. One sample
("Sample 1") was taken approximately 10 feet above the confluence of the outfall and the Catawba River
The second sample ("Sample 2") was taken immediately above the outfall 6 control gate. No flow was
observed at the time of sampling. (Attached map identifies locations)
The samples were tested onsite for pH, which ranged from 8.0 (Sample 1) to 11.7 (Sample 2).
Each sample was sent to the corporate analytical laboratories for further analysis.
The laboratory performed total metals analysis by ICP. Trace amounts of a variety of metals were
detected. Sodium was slightly elevated level due to the presence of caustic from the air pollution control
device.
In addition to the metals analysis, volatiles and semi-volatiles were extracted in chloroform without further
concentration. The resulting chloroform solution was scanned by GC/MS for a qualitative analysis.
The GC/MS scan showed one major peak, accounting for 99 percent of the extracted fraction, with other
trace peaks. The major peak was determined by the lab to be to be N, N-dimethyl alkyl (C12-C18)
amines. The laboratory results are consistent with our review of production records which show two alkyl
amines recently used in production campaigns.