Form 9600-031 12b Export Notification

OMB Control Number 2070-0030 expires 6/30/2024

TSCA Section 12(b) Export Notification
Submission Alias: 12b-65-8892
Submitter Information

CBI

First Name

James

Last Name

Goldsmith

Phone Number

3364234784

Email Address

james.goldsmith@cgifederal.com

Job Title

Consultant

Organization
Name

CGI FEDERAL

Address Line 1

12601 FAIRLAKES CIRCLE

Address Line 2
City

State

Postal Code

Country

FAIRFAX

Virginia

22033

United States

Exporter Information
Company Name

CGI FEDERAL

Address Line 1

12601 FAIRLAKES CIRCLE

Address Line 2
City

State

Postal Code

Country

FAIRFAX

Virginia

22033

United States

Exported Chemicals
Export - 1
Chemical Name Naphthalene, 1,2,3,4-tetrahydro(1-phenylethyl)CASRN

63674-30-6

TSCA Section

Section 5

Form 9600-031

CBI

X

CBI

X

X

Paperwork Reduction Act: This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB
Control No. 2070-0030). Responses to this collection of information are mandatory for certain persons, as specified at 40 CFR 707 Subpart D. An
agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB
control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 0.62 hours per response. Send
comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing
respondent burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW,
Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.

Category

Perfluoroalkyl Sulfonates (PFAS)

Import Country

Australia

CBI

X

Export Date

01/12/2023

CBI

X

CBI Substantiation
Regular File

CBI

General Claim: Submitter Information
Applicable Only to General CBI Claims
A person may assert a claim of confidentiality for the specific chemical identity of a
chemical substance as described in § 711.15(b)(3) of this part only if the identity of that
chemical substance is treated as confidential in the Master Inventory File as of the time the
report is submitted for that chemical substance. Generic chemical identities and accession
numbers may not be claimed as confidential. To assert a claim of confidentiality for the
identity of a reportable chemical substance, you must submit with the report detailed written
answers to the questions from subsection (b) and to the following questions.
Question
G1) Please specifically explain what harm to the
competitive position of your business would be likely to
result from the release of the information claimed as
confidential. How would that harm be substantial? Why is
the substantial harm to your competitive position likely
(i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of
information to be confidential (e.g. site information,
exposure information, environmental release information,
etc.), explain how disclosure of each type of information
would be likely to cause substantial harm to the
competitive position of your business.

Yes

No

X

CBI

X

Comment: Test

Question
G2) Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but

Yes

No

CBI

not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If
the same or similar information was previously reported to
EPA as non-confidential (such as in an earlier version of
this submission), please explain the circumstances of that
prior submission and reasons for believing the information
is nonetheless still confidential.

X

X

Comment: Test

Question
G3A) Is any of the information claimed as confidential
required to be publicly disclosed under any other Federal
law? If yes, please explain.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G3B) Does any of the information claimed as confidential
otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or
promotional material; professional or trade publications;
state, local, or Federal agency files; or any other media or
publications available to the general public? If yes, please
explain why the information should be treated as
confidential.

Yes

X

Comment: Test

Question
G3C) Has a patent been published for the chemical identity
you claim confidential? What chemical identity information
is not revealed by the patent? How is release of that
specific information likely to cause substantial competitive
harm? And failure to explain this harm may lead to denial
of your confidentiality claim.

Yes

X

Comment: Test

Question
G4) Is the claim of confidentiality intended to last less than
10 years (see TSCA section 14(e)(1)(B))? If yes, please

Yes

X

indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.
Comment: Test

Question
G5) Has EPA, another federal agency, or court made any
confidentiality determination regarding information
associated with this chemical substance? If yes, please
provide the circumstances associated with the prior
determination, whether the information was found to be
entitled to confidential treatment, the entity that made the
decision, and the date of the determination.

Yes

No

CBI

X

Comment: Test

General Claim: Company Name
Applicable Only to General CBI Claims
A person may assert a claim of confidentiality for the specific chemical identity of a
chemical substance as described in § 711.15(b)(3) of this part only if the identity of that
chemical substance is treated as confidential in the Master Inventory File as of the time the
report is submitted for that chemical substance. Generic chemical identities and accession
numbers may not be claimed as confidential. To assert a claim of confidentiality for the
identity of a reportable chemical substance, you must submit with the report detailed written
answers to the questions from subsection (b) and to the following questions.
Question
G1) Please specifically explain what harm to the
competitive position of your business would be likely to
result from the release of the information claimed as
confidential. How would that harm be substantial? Why is
the substantial harm to your competitive position likely
(i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of
information to be confidential (e.g. site information,
exposure information, environmental release information,
etc.), explain how disclosure of each type of information
would be likely to cause substantial harm to the
competitive position of your business.
Comment: Test

Yes

X

No

CBI

Question
G2) Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but
not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If
the same or similar information was previously reported to
EPA as non-confidential (such as in an earlier version of
this submission), please explain the circumstances of that
prior submission and reasons for believing the information
is nonetheless still confidential.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G3A) Is any of the information claimed as confidential
required to be publicly disclosed under any other Federal
law? If yes, please explain.

Yes
X

Comment: Test

Question
G3B) Does any of the information claimed as confidential
otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or
promotional material; professional or trade publications;
state, local, or Federal agency files; or any other media or
publications available to the general public? If yes, please
explain why the information should be treated as
confidential.

Yes

X

Comment: Test

Question
G3C) Has a patent been published for the chemical identity
you claim confidential? What chemical identity information
is not revealed by the patent? How is release of that
specific information likely to cause substantial competitive
harm? And failure to explain this harm may lead to denial
of your confidentiality claim.
Comment: Test

Yes

X

Question
G4) Is the claim of confidentiality intended to last less than
10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.

Yes

No

CBI

No

CBI

X

Comment: Test

Question
G5) Has EPA, another federal agency, or court made any
confidentiality determination regarding information
associated with this chemical substance? If yes, please
provide the circumstances associated with the prior
determination, whether the information was found to be
entitled to confidential treatment, the entity that made the
decision, and the date of the determination.

Yes

X

Comment: Test

General Claim: Entire Address
Applicable Only to General CBI Claims
A person may assert a claim of confidentiality for the specific chemical identity of a
chemical substance as described in § 711.15(b)(3) of this part only if the identity of that
chemical substance is treated as confidential in the Master Inventory File as of the time the
report is submitted for that chemical substance. Generic chemical identities and accession
numbers may not be claimed as confidential. To assert a claim of confidentiality for the
identity of a reportable chemical substance, you must submit with the report detailed written
answers to the questions from subsection (b) and to the following questions.
Question
G1) Please specifically explain what harm to the
competitive position of your business would be likely to
result from the release of the information claimed as
confidential. How would that harm be substantial? Why is
the substantial harm to your competitive position likely
(i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of
information to be confidential (e.g. site information,
exposure information, environmental release information,

Yes

X

No

CBI

etc.), explain how disclosure of each type of information
would be likely to cause substantial harm to the
competitive position of your business.
Comment: Test

Question
G2) Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but
not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If
the same or similar information was previously reported to
EPA as non-confidential (such as in an earlier version of
this submission), please explain the circumstances of that
prior submission and reasons for believing the information
is nonetheless still confidential.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G3A) Is any of the information claimed as confidential
required to be publicly disclosed under any other Federal
law? If yes, please explain.

Yes
X

Comment: Test

Question
G3B) Does any of the information claimed as confidential
otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or
promotional material; professional or trade publications;
state, local, or Federal agency files; or any other media or
publications available to the general public? If yes, please
explain why the information should be treated as
confidential.

Yes

X

Comment: Test

Question
G3C) Has a patent been published for the chemical identity
you claim confidential? What chemical identity information
is not revealed by the patent? How is release of that

Yes

X

specific information likely to cause substantial competitive
harm? And failure to explain this harm may lead to denial
of your confidentiality claim.
Comment: Test

Question
G4) Is the claim of confidentiality intended to last less than
10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.

Yes

No

CBI

No

CBI

X

Comment: Test

Question
G5) Has EPA, another federal agency, or court made any
confidentiality determination regarding information
associated with this chemical substance? If yes, please
provide the circumstances associated with the prior
determination, whether the information was found to be
entitled to confidential treatment, the entity that made the
decision, and the date of the determination.

Yes

X

Comment: Test

Chemical Claim: Import Country - Australia
Applicable Only to Chemical Identity CBI Claims
A person may assert a claim of confidentiality for the specific chemical identity of a
chemical substance as described in § 711.15(b)(3) of this part only if the identity of that
chemical substance is treated as confidential in the Master Inventory File as of the time the
report is submitted for that chemical substance. Generic chemical identities and accession
numbers may not be claimed as confidential. To assert a claim of confidentiality for the
identity of a reportable chemical substance, you must submit with the report detailed written
answers to the questions from subsection (b) and to the following questions.
Question
C1) Is this chemical substance publicly known (including
by your competitors) to be in U.S. commerce? If yes,
please explain why the specific chemical identity should
still be afforded confidential status (e.g., the chemical

Yes

No

CBI

substance is publicly known only as being distributed in
commerce for research and development purposes, but no
other information about the current commercial
distribution of the chemical substance in the United States
is publicly available). If no, please complete the
certification statement: I certify that on the date referenced
I searched the internet for the chemical substance identity
(i.e., by both chemical substance name and CASRN). I did
not find a reference to this chemical substance and have
no knowledge of public information that would indicate
that the chemical is being manufactured or imported by
anyone for a commercial purpose in the United States.
[provide date].

X

Comment: Test

Question
C2) Does this specific chemical substance leave the site of
manufacture (including import) in any form, e.g., as a
product, effluent, emission? If yes, please explain what
measures have been taken to guard against the discovery
of its identity.

Yes

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
C3) If the chemical substance leaves the site in a form that
is available to the public or your competitors, can the
chemical identity be readily discovered by analysis of the
substance (e.g., product, effluent, emission), in light of
existing technologies and any costs, difficulties, or
limitations associated with such technologies? Please
explain why or why not.

Yes

X

Comment: Test

Question
C4) Would disclosure of the specific chemical identity
release confidential process information? If yes, please
explain.
Comment: Test

Yes
X

Question
G1) Please specifically explain what harm to the
competitive position of your business would be likely to
result from the release of the information claimed as
confidential. How would that harm be substantial? Why is
the substantial harm to your competitive position likely
(i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of
information to be confidential (e.g. site information,
exposure information, environmental release information,
etc.), explain how disclosure of each type of information
would be likely to cause substantial harm to the
competitive position of your business.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G2) Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but
not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If
the same or similar information was previously reported to
EPA as non-confidential (such as in an earlier version of
this submission), please explain the circumstances of that
prior submission and reasons for believing the information
is nonetheless still confidential.

Yes

X

Comment: Test

Question
G3A) Is any of the information claimed as confidential
required to be publicly disclosed under any other Federal
law? If yes, please explain.

Yes
X

Comment: Test

Question
G3B) Does any of the information claimed as confidential
otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or

Yes

promotional material; professional or trade publications;
state, local, or Federal agency files; or any other media or
publications available to the general public? If yes, please
explain why the information should be treated as
confidential.

X

Comment: Test

Question
G3C) Has a patent been published for the chemical identity
you claim confidential? What chemical identity information
is not revealed by the patent? How is release of that
specific information likely to cause substantial competitive
harm? And failure to explain this harm may lead to denial
of your confidentiality claim.

Yes

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G4) Is the claim of confidentiality intended to last less than
10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.

Yes

X

Comment: Test

Question
G5) Has EPA, another federal agency, or court made any
confidentiality determination regarding information
associated with this chemical substance? If yes, please
provide the circumstances associated with the prior
determination, whether the information was found to be
entitled to confidential treatment, the entity that made the
decision, and the date of the determination.

Yes

X

Comment: Test

Chemical Claim: Export Date - Thu Jan 12 00:00:00 EST 2023
Applicable Only to Chemical Identity CBI Claims
A person may assert a claim of confidentiality for the specific chemical identity of a
chemical substance as described in § 711.15(b)(3) of this part only if the identity of that

chemical substance is treated as confidential in the Master Inventory File as of the time the
report is submitted for that chemical substance. Generic chemical identities and accession
numbers may not be claimed as confidential. To assert a claim of confidentiality for the
identity of a reportable chemical substance, you must submit with the report detailed written
answers to the questions from subsection (b) and to the following questions.
Question
C1) Is this chemical substance publicly known (including
by your competitors) to be in U.S. commerce? If yes,
please explain why the specific chemical identity should
still be afforded confidential status (e.g., the chemical
substance is publicly known only as being distributed in
commerce for research and development purposes, but no
other information about the current commercial
distribution of the chemical substance in the United States
is publicly available). If no, please complete the
certification statement: I certify that on the date referenced
I searched the internet for the chemical substance identity
(i.e., by both chemical substance name and CASRN). I did
not find a reference to this chemical substance and have
no knowledge of public information that would indicate
that the chemical is being manufactured or imported by
anyone for a commercial purpose in the United States.
[provide date].

Yes

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
C2) Does this specific chemical substance leave the site of
manufacture (including import) in any form, e.g., as a
product, effluent, emission? If yes, please explain what
measures have been taken to guard against the discovery
of its identity.

Yes

X

Comment: Test

Question
C3) If the chemical substance leaves the site in a form that
is available to the public or your competitors, can the
chemical identity be readily discovered by analysis of the
substance (e.g., product, effluent, emission), in light of
existing technologies and any costs, difficulties, or

Yes

X

limitations associated with such technologies? Please
explain why or why not.
Comment: Test

Question
C4) Would disclosure of the specific chemical identity
release confidential process information? If yes, please
explain.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G1) Please specifically explain what harm to the
competitive position of your business would be likely to
result from the release of the information claimed as
confidential. How would that harm be substantial? Why is
the substantial harm to your competitive position likely
(i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of
information to be confidential (e.g. site information,
exposure information, environmental release information,
etc.), explain how disclosure of each type of information
would be likely to cause substantial harm to the
competitive position of your business.

Yes

X

Comment: Test

Question
G2) Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but
not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If
the same or similar information was previously reported to
EPA as non-confidential (such as in an earlier version of
this submission), please explain the circumstances of that
prior submission and reasons for believing the information
is nonetheless still confidential.

Yes

X

Comment: Test

Question

Yes

G3A) Is any of the information claimed as confidential
required to be publicly disclosed under any other Federal
law? If yes, please explain.

X

Comment: Test

Question
G3B) Does any of the information claimed as confidential
otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or
promotional material; professional or trade publications;
state, local, or Federal agency files; or any other media or
publications available to the general public? If yes, please
explain why the information should be treated as
confidential.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment: Test

Question
G3C) Has a patent been published for the chemical identity
you claim confidential? What chemical identity information
is not revealed by the patent? How is release of that
specific information likely to cause substantial competitive
harm? And failure to explain this harm may lead to denial
of your confidentiality claim.

Yes

X

Comment: Test

Question
G4) Is the claim of confidentiality intended to last less than
10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.

Yes

X

Comment: Test

Question
G5) Has EPA, another federal agency, or court made any
confidentiality determination regarding information
associated with this chemical substance? If yes, please
provide the circumstances associated with the prior
determination, whether the information was found to be

Yes

X

entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Comment: Test

TSCA CBI Certification
I hereby certify to the best of my knowledge and belief that all information entered on this form is
complete and accurate.
I further certify that, pursuant to 15 U.S.C. § 2613(c), for all claims for protection for any confidential
information made with this submission, all information submitted to substantiate such claims is true and
correct, and that it is true and correct that the person submitting the claim has:
i. taken reasonable measures to protect the confidentiality of the information;
ii. determined that the information is not required to be disclosed or otherwise made available to the
public under any other Federal law;
iii. a reasonable basis to conclude that disclosure of the information is likely to cause substantial harm
to the competitive position of the person; and
iv. a reasonable basis to believe that the information is not readily discoverable through reverse
engineering.
Any knowing and willful misrepresentation is subject to criminal penalty pursuant to 18 U.S.C. § 1001.

Cross-Media Electronic Reporting Regulation (CROMERR) Certification
I certify, under penalty of law, that this document and all attachments were prepared under my direction
of supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment
for knowing violations.