v
Cytec
Industries
Inc.
Toxicology
&
Product
Regulatory
Compliance
Dept.
5
Garret
Mountain
Plaza
West
Paterson,
NJ
07424
OPPT
Document
Control
Officer
(
DCO)
Date:
December
16,2003
Mail
Code
7407M
Attention:
Inventory
Update
Rule
Office
of
Pollution
Prevention
and
Toxics
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Dear
Sir
or
Madam:

Cytec
Industries
Inc.,
requests
EPA
to
exempt
2­
Propenamide
(
CAS#
79­
06­
1)
from
the
processing
and
use
reporting
requirements
in
the
TSCA
Inventory
Update
Rule
Amendments
(
40
CFR
710.52(~)(
4)).

In
the
January
7,2003,
rulemaking
for
the
Inventory
Update
Rule
Amendments
(
IURA),
EPA
announced
that
it
was
exempting
certain
specific
chemical
substances
from
reporting
processing
and
use
information
for
the
IURA.
In
that
rulemaking,
EPA
also
noted
that
its
process
"
allows
anyone
to
submit
a
written
request
for
EPA
to
consider
revising
the
list
of
chemicals
substances
covered
by
this
partial
exemption."

Cytec
Industries
Inc.
is
requesting
that
2­
Propenamide
(
CAS#
79­
06­
l),
be
added
to
the
list
of
partially
exempt
chemicals
contained
in
40
CFR
710.46(
b)(
2)(
iv).
In
making
its
determination
whether
the
partial
exemption
should
apply
to
this
substance,
EPA
should
consider
the
following
criteria
for
selection:

40
CFR
710.46(
b)(
2)(
ii)(
A)
2­
Propenamide
(
CAS#
79­
06­
1)
qualified
for
the
reporting
of
the
information
described
in
710.52(~)(
4)(
Le.
at
least
one
site
manufactured
300,000
lbs
or
more
of
the
chemical)
as
reported
in
the
2002
IURsubmitted
by
Cytec
Industries
Inc.

40
CFR
710.46(
b)(
2)(
ii)(
B),(
C),
(
D),
(
E),
(
F):
The
information
previously
provided
to
EPA
for
2­
Propenamide
(
CAS##
79­
06­
1)
under
the
HPV
Challenge
Program,
found
on
EPA's
web
site
at:
http://
www.
epa.
Pov/
chemrtMnmac/
c13168tc.
htm
should
be
sufficient
for
EPA
to
make
the
necessary
determination
that
2­
Propenamide
(
CAS#
79­
06­
1)
is
"
of
low
current
interest",
and
that
2­
Propenamide
should
be
added
to
the
list
of
partial
reporting
exemption
under
IURA.
If
you
have
any
questions
regarding
this
request,
please
contact
me
at
973­
357­
3460.

Sincerely,

Daniel
P.
Liebowitz
Regulatory
Compliance
Manager,
Americas
Cytec
Industries
Inc.
