SCI~NC~S 

WASHINGTON 

1150 18th Street, N.W. 

Suite 1000 

Washington, D.C. 20036 

Telephone 202 223-4392 

Fax 202 872-0745 

SACRAMENTO 

712 Fifth Street 

Suite A 

Davis, CA 95616 

Telephone 530 757-1298 

Fax 530 757-1299 

CANADA 

275 Slater Street 

Suite 900 

Ottawa, Ontario 

K1P 5H9 

Telephone 613 247-6285 

Fax 613 236-3754 

T~CHNOlOGy" 

GROU~ 

INC '0 FED 'r Pi; r~: ~ 0 

February 16,2010 

Document Control Officer (",._ 

Office of Pollution Prevention and Toxic Substances, 7407 ..·./Ui {~Pclny ":-\ 'oanitized U.S. EPA 


1201 Constitution Avenue Ave., NW 


Washington, DC 20004 


Re: Premanufacture Notice TS-lOIRVl 

Dear Sir or Madam: 

On behalf of the [ ], Technology Sciences Group, Inc. 


(TSG) is hereby submitting in accordance with 40 CFR Section 720.50 the 


attached Premanufacture Notice (PMN) TS-10IRV1 for review. 


In accordance with 40 CFR Section 700.45(b), the fee of $2500.00 has 


been submitted through pay.gov. 


This PMN notification does contain confidential business information 

(CBI). Accordingly, a sanitized copy is enclosed along with the three confidential 

copIes. 

Finally, the PMN form used is an electronic version purchased from CMA. 


The document showing EPA approval of the form is attached. 


If there are any questions regarding this submission, please do not hesitate 


to contact me at 202-828-8992. 


Sincerely, 

Richard 

~~~~ A. JOU~de1;i~, ~~~.~. Director, Chemicals Division 


Attachments 


E-mail tsg@tsgusa.com 

http://www.tsgusa.com 

II 
U.S. ENVIRONMENTAL PROTECTION AGENCY 

Date 

IC If ;':'[::1...0 

COmpany Sanitized 

D.C. 20460 

28 

GENERAL INSTRUCTIONS 

You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do not 

have actual data. 

• 	 Before you complete this form, you should read the "Instructions Manual for Prernanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Infonnation Service by calling 202-554-1404, or faxing 202-554-5603). 

• 	 If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P.O. 360399M, 

Pittsburgh, PA 15251-6399, Attn. TSCA User fee. 

Part 1-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance, even if you claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in support of your submission should reference your TS user fee identification 

number. You must submit an original and two copies of this notice including all test data. 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted. 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part 11, 

sections A and B of this notice, reproduce the sections as needed. 

Part 111- LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully. Label 

each continuation sheet with the corresponding section heading. In Part III, list these 

allachments, any test data or other data and any optional information included in the 

notice. 

OPTIO:'-lAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance. On page II of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new 

substance. 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingncss to be bound to certain statements you make in this section, such as usc, 

production volume, protective equipment.. This option is intended to reduce delays 

that routinely accompany the development of consent orders or Significant New Use 

Rules. Except in the case of exemption applications (such as TMEA, LVE, LOREX) 

where certain information provided in such notification is binding on the submitter when 

the Agency approves the exemption application, checking a binding box in this notice 

does not by itself probibit the submitter from later deviating from the information (except 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To assert a claim on tbe 

form, mark (X) the confidential box next to the information that you claim as 

confidential. To assert a claim in an attachment, circle or bracket the information you 

claim as confidential. If you claim information in the notices as confidential, you must 

also provide a sanitized version of the notice. <including attachments}. For additional 

instructions on claiming information as confidential, read the Instructions Manual. 

Mark (xl if any information in this notice is claimed as confidential. 

TEST DATA AND OTHER DATA 

You are required to submit all test data in your possession or control and to provide a 

description of all other data known to or reasonably ascertainable by you, if these 

data are related to the health and environmental effects on the manufacture, 

processing. distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature. Complete test data (written in English), not summaries of data, 

must be submitted if they do not appear in the open literature. Yau should clearly 

identify whether test data is on the substance or on an analog. Mso, the chemical 

composition of the tested material should be characterized. FoUnwing are examples 

of test data and other data. Data should be submitted according'to the requirements 

of §720.50 of the Premanufacture Notification Rule (40 CfoR parinO). 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes . Other dat~ 0 Yes 

Health effects data 0 Yes 	 Risk assessments 

~ .. Environmental effects data 0 Yes 	 Structure/activity relationships 

Physical/Chemical Properties' 181 Yes 	 Test data not in the possession 

or control of the submitter 

A physical and chemical properties worksbeet is located on the last page of this form. 

TYPE OF NOTICE (Check Only One) 

~ P\1N (Pre manufacture Notice) 

D INTERMEDIA TE PMN (submitted in sequence with final product PMN) 

D SNUN (Significant New Use Notice) 

D TMEA (Test Marketing Exemption Application) 

D LVE (Low Volume Exemption) @ 40 CrR 723.50(c)(I) 

D LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(c)(2) 

D 	 LVE Modification D LOREX Modification 

IS THIS A CONSOLIDATED PM!'!? D Yes

# of chemicals 


(Pre notice Communication # required, enter # on page 3) 


EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 
Public reporting burden for this collection of information is estimated to average 110 hours per response, including lime for reviewing instructions, 

searching existing data sources, gathering and maintaining the data needed. and completing and reviewing the collection of information. Send 

comments regarding the burden estimate or any other aspect of this collection of information. including suggestions for reducing this burden. to 

Chief, Information Policy Branch. PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington. D.C. 20460; and to the Office 

of Management and Budget, Paperwork Reduction Act (2070-0012), Washington. D.C. 20503. 

CERTIFICATION 


I certify that to the best of my knowledge and belief: 

I. 	 The company named in Part I, section A, subsection 1 a of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I. 

Section B. 

2. 	 All information provided in this notice is complete and truthful as of the date of submission. 

3. 	 I am submitting with this notice all test data in my possession or control and a description of all other data known to or 


reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 


Additional Certification Statements: 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 


statement that applies: 


cg] 	 The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CPR 700.45(b), or 

D The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CPR 


700.43) in accordance with 40 CPR 700.45(b), or 


D The Company named in Part I Section A is a small business concern under 40 CPR 700.43 and has remitted a fee of $100 in 

accordance with 40 CPR 700.45(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CPR 723 .50( c)(1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CPR 723.50(c)(2), check the following certification 

statements: 

The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 

purposes, other than in small quantities solely for research and development, under the terms of 40 CPR 723.50. 

D 	The manufacturer is familiar with the terms of this section and will comply with those terms; and 

D 	The new chemical substance for which the notice is submitted meets all applicable exemption conditions. 

D If this application is for an L VE in accordance with 40 CPR 723.50(c)( I), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period. 

The accuracy of the statements you make in this notice should reOeet your best predictlon of the antlcipared facts regarding the chemical substance 

described herein. Any knowin2 and wUlrul misinteroretation is subject to criminal peoalty pursuant to 18 USC 1001. Cool1deotial 

Signature and title of Authorized Official (Original Signature Required) Date 

Signature of agent - (if applicable) Date 

EPA FORM 7710-25 (Rev. 5-95) Page 2 

x 
Part I -- GENERAL INFORMATION 

la. Person 

Submitting 

Notice (in U.S.) 

b. Agent (if 

applicable) 

Company 

City, State, ZW Code 

Company 

and street) 

City, State, ZW Code 

c. If you are submitting this notice as part of a joint submission, mark (X) this box. 

Joint Submitter (if 

applicable) 

Name of authorized official 

Company 

Mailing address (number and street) 

2. Technical 

Contact (in 

U.S.) 

Name of authorized official 

4. 

Company 

Mailing address (number street) 

you ha ve had a pre notice communication (PC) 

and EPA assigned a PC Number to the notice, enter the number. 

If you an exemption application the chemical 

substance covered by this notice, enter the exemption number assigned by 

EPA. If you previously submitted a PMN for this substance enter the 

PMN number assigned by EPA (i.e. withdrawn or incomplete). .. 

a notice Bona tide intent to manufacture 

for tbe chemical substance covered by this notice, enter the notice 

assigned hy EPA. 

Telephone 

Position 

Telephone 

Telephone 

Mark (X) 

if none 

Mark (X) 

if none 

Mark (X) 

if none 

I. Manufacture 2 Import 6. Type of Notice Mark (X) Only Only 3. D Both

D Binding Option D Binding Option 

EPA FORM 7710-25 (Rev. 5-95) Page 3 
Section B·· 

Complete either item I (Class I or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. 


the and address of that in a continuation sheet. 


I. Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. 	 Class of substance· Mark (X) D Class I or 2 D Class 2 x 

b. 	 Chemical name (Currently correct Chemical Abstracts (CA) Name that with TSCA Inventory listings for similar substances. 


For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must 
 x

be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions). 

c. 	 Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one). 


~ Method I (CAS Inventory Expert Service - a copy of the Identification D Method 2 (Other Source) 


report obtained from the CAS Inventory Expert Services must be 


submitted as an attachment to this 


d. 	 Molecular la and CAS Registry Number (if a number already exists for the substance) 

x 

x 

e. 	 For a class 1 substance, provide a complete and correct chemical structure diagram. For a class the immediate 


precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the 


range of composition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical structure 


diagram. as complete as can be known. if one can be reasonably ascertained. 


Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710·25 (Rev. 5·95) 	 Page 4 
commercial purposes. 

Mark this column if 

Confi- Typical 

0/0 

X % 

X % 

X 0/0 

X % 

% 

% 

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. 

c. 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: OPC I:8J Other D: (Specify) 

i) lowest number average molecular weight: 500 

ii) maximum weight % below 500 molecular weight: 

iii) maximum weight % below 1000 molecular weight: 40.0 

attach a continuation sheet. 

You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Confidential" box next to any item you claim as confidential 

(I) Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

(2) Mark (X) this column if entry in column (1) is confidential. 

(3) Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(4) Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) Mark (X) this column if entries in columns (3) and (4) are confidential. 

(6) Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

Confi­

% 

X % X 

X % X 

X % X 

X % X 

% 

% 

d. The the polymer that is consistent with TSCA Inventory listings for similar polymers. 

See Part I Section B e. Provide a correct representative or as complete as can be known, if one can be reasonably ascertained. 

X 

this box if you attach a conti nutation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 5 
Impurities 

(a) Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide the 

CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

Estimate the maximum . % of each' If there are unidentified . estimate their total %. 

Impurity and CAS Registry Number Maximum 

percent dential 

unidentified impurities 0.5 % 

% 

% 

% 

% 

% 

% 

I or 2. Confidential 

6. 	 Generic chemical name - If you claim chemical identify as you must name for your substance that reveals 


the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the 


TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 


Unsaturated polyester imide 

Mark (X) this box if attach a continuation sheet. 

Mark (X) this box if you attach a continuation sheet. 

Trade identification - List trade names for the new chemical substance lf1pnttlCtM 

Mark (X) this box if you attach a continuation sheet. 

7. Byproducts ­ Describe any byproducts resulting from the manufacture. processing, use, or 

Number if available. 

of the new chemical substance. Provide the 

CAS umber 

Water 7732-18-5 

EPA FORM 7710-25 (Rev. 5-95) Page 6 
Part I -- GENERAL INFORMATION -­ Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: I 

Mark (X) the "Confidential" box next to any item you claim as confidential. 

1. Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum ! 

production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 ' 

kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume 

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Confi- Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dential Option 

Mark (x) 

50,000 125,000 

2. Use Information •• You must make separate confidentiality claims for the description of the category of use, the percent of production volume 

devoted to each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item 

you claim as confidential. 

a. (1) -­ Describe each intended category of use of the new chemical substance by function and application.. 

(2) -­ Mark (X) this column ifentry column (I) is confidential business information (CBI). 

(3) -­ Indicate your willingness to have the information provided in column (I) binding. 

(4) Estimate the percent of total production for the first three years devoted to each category of use. 

(5) -­ Mark (X) this column if entry in column (4) is confidential business information (CBI). 

(6) -­ Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category of use. 

(7) -­ Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) -­ Indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate 

your willingness to have the use type provided in (8) binding. 

(9) -­ Mark (X) this column if entry(ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) CBI Binding Produc- CBI %in CHI % of substance expected per use CBI 

Option tion % Form­ (8) 

(by function and application i.e. a dispersive dye Mark (x) ulation Site- Con-* Indus- Com- Binding 

for finishing polyester fibers} (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

electrical insulating varnish for 100 % 37% 100 

tran:" 

% % 

% % 

% % 

% % 

% % I 

% % 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the users) of this chemical substance in consumer products. 

In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product. 

DMark (X) this box if you attach a continuation sheet. 

b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the 

use Instructions Manual for examples of generic use descriptions. 

description N/A 

D Mark (X) this box if you attach a continuation sheet. 

3. Hazard Information -­ Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding 

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option 

for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (x) 

I:8J Mark (X) this box if you attach hazard information. 

EPA FORM 7710 -25 (Re\.5-95) Page 7 
x 

I, Batch 

box next to any item you 

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you 

control. Importers do not have to complete this section for operations outside the U,S,; however, you may still have reporting requirements if 

there are further industrial or use after You must describe these ' See instructions manual 

I. Confiof the site at which the rmf'r~ti(\n will occur, dential

Site address (number and street) 

City, County, State, ZIP code 

If the same operation will occur at more than one site, enter the number of sites, Identify the 

additional sites on a continuation sheet, and if any of the sites have significantly different 

production rates or operations. include all the information requested in this section for those 

sites as attachments, 

x se 

x 

Batches/year 

2, Continuous 

d, Process description Mark (X) to indicate your willingness to have your process description binding, 

(I) 	 Diagram the major unit operation steps and chemical conversions, Include interim storage and transport containers (specify- e,g. 5 gallon pails, 55 gallon 

drum, rail car, tank truck, etc,). 

(2) 	 Provide the identity, the approximate weight (by kg/day or kglbatch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc,), and of all products, recycle streams, and wastes, Include cleaning chemicals (note frequency if not 

used daily or per batch,), 

(3) 	 Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 

See page 8a 

suhstance) 

Maximum kglbatch (IOO~ new chemical Hourslbatch 

substullce} 

[8J 	Mark (X) this box if attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 8 
\ 

\ 

\ 

\ \ 

\ 

\ 

\ \ i 

1 

\ ! \

L 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -­ Continued 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued 

2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, 

number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you claim as confidential. 

(I) -- Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. 

(2) -- Mark (X) this column if entry in column (I) is confidential business information (CBI). 

(3) -­ D escn 'b e any protective ' equipment an d' engmeermg contro I d s use t t o pro ec t wor kers, 

(4) and (6) Indicate your willingness to have the information provided in column (3) or (5) binding. 

(5) Indicate the physical formes) of the new chemical substance (e.g., solid: crystal, granule, powder. or dust) and % new chemical substance (if part of a mixture) 

at the time of exposure. 

(7) Mark (X) this column if entry in column (5) is confidential business information (CBI). 

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined. 

(9) -- Mark (X) this column if entry in column (8) is confidential business information (CBI). 

(10) and (11) -- Estimate the maximum duration of the acti vity for any worker in hours per day and days per year. 

(12) -- Mark (X) this column if entries in columns (10) and (II) are confidential business information (CBI). 

Worker activity CBI Protective Equipment! Bimli!lg Physical forms(s) Binding eBI #of CBI Maximu duration CBI 

m 

(i.e., bag dumping, filling drums) Engineering Controls Optiun and % new Option Worker Hrs/day Days/yr Mark (X) substance Mark (xl S 

(I) (2) (3) (4) (5) (6) (7) Expose (9) (10) (11) (12) 

d 

(8) 

in-process sampling gloves, goggles, melt, 3 2 8 

local Axhaul'lt 100% 

QC testing gloves, safety liquid,40% 3 2 12 

nl:::>C!C!QC! 

drumming operation gloves, safety Iiquid,40% 2 8 8 

alal'll'lAl'l 

• clean equipment gloves, safety liquid, <5% 2 8 8 

nl::l!':!':pc 

[ ] Mark (X) this box if you attach a continuation sheet. 

3. Environmental Release and Disposal -­ You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. 

(1) -- Enter the number of each release point identified in the process description, part 11, section A, subsection Id(3). 

(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kglbatch). 

(3) -- Mark (X) this column if entries in columns (\) and (2) are confidential business information (CBl). 

(4) Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to 

which the new substance will be released from that release point. 

(5) a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). 

(7) -­ Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publici Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) eBI 

Number released release 

(I) (2a) (2b) e.g. ~ta;,;J:. air Binding 

(3) (4) (5a) Mark (X) (5b) (6) 

1 okg okg off- Liquid condensate is collected and okg 

site incinerated off-site. 

2 okg okg off- Liquid condensate is collected and okg 

site incinerated off-site. 

3 okg okg off- Liquid wash is collected and incinerated okg 

site off-site 

(7) Mark (X) the D POTW provide name(s) below: CBI D Navigable D Other Specify provide NPDES # CBI 

: destination(s) of - waterway 

releases to water. 

] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 9 

I 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this 

section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate 

section Bfor each type ofprocessing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typical operation common to these sites. Identify additional sites on a continuation sheet. 

1. Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. 

-1(1 ) Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 gallon pails, 55 gallon 

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) Provide the identity, the approxintate weight 

(by kg/day or kglbatch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts. etc) and all 

products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) Identify by number the points of release, 

including small or intcrmittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet): 

1-3 

# of sites 

See page 10a 

C8J Mark (X) this box if you attach a continuation sheet. 

2. Worker ExposurelEnvironmental Release 

(I) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -- Estintate the number of workers exposed for all sites combined. 

(4) Estintate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to 

protect workers. 

(7) Estintate the percent of the new substance as formulated when packaged or used as a fmal product. 

(9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identifIed. 

(10) -- Estintate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kglbatch). 

(12) -­ Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other 

(specify) and control technology. if any, that will be used to limit the release of the new substance to the environment. 

(14) -­ Identify byproducts which may rcsult from the operation. 

(3), (5), (8). (II), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confIdential business information (CBI). 

Letter 

of 

Activity 

(I) 

#of 

Workers 

Exposed 

(2) 

eBI 

(3) 

Duration 

of 

Exposure 

eBi 

(5) 

Protective Equip. I 

Engineering Controls! 

Physical Form and % 

new substance 

(6) 

%in 

Formulation 

(7) 

eSI 

(8) 

Release 

Number 

(9) 

Amount of 

New 

Substance 

Released 

CBI 

(11) 

Media of Release 

& Control 

Technology 

(12) 

eSI 

(4a) (4b) (lOa) (lOb) (13)

A 3 1 100 

I 

gloves, glasses, local 

exhaust 

33 1 0 0 incineration, 

landfill 

B 9 4 250 gloves, glasses, local 

exhaust 

33 1 0 0 incineration, 

landfill 

C N/A N/A N/A ~ured PMN substance N/A N/A N/A N/A none needed 

(14) Byproducts: 

none 

(15) 

C8J Mark (X) this box if you attach a continuation sheet, 

EPA FORM 7710-25 (Rev. 5-95) Page 10 
Industrial sites controlled by others 

The PMN material is fonnulated into an overcoat varnish used to protect 

electrical equipment. This formulated coating is typically received in sealed 

55 gallon drums. In a typical manufacturing site the formulated material is 

either pumped, or poured into a storage reservoir as needed. The electrical 

equipment to be coated is then dipped into the liquid, removed, allowed to 

drain then baked in an oven at 150°C to 170°C. Once the coating is cured, 

the electrical equipment is allowed to cool before moving on to further 

assembly operations. 

A schematic of the coating operations is below with each point of exposure 

labeled. Exposure will typically be through casual, or accidental contact with 

the formulated liquid. 

Typical schematic of operations using the formulated coating 

Material is received at customer 

~ 

Material is transferred into s~orage reservoir (A) (I) 


~ 

Equipment is processed in formulated liquid coating (B) (I~ 

.J, 


Equipment is cured in oven at 150°C to 170°C (C) 

-!, 

Final parts assembly 

Page lOa 
OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in this section as confidential circle or bracket the specific information that you claim as confidential. 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce 

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal 

of the PMN substance. Please include new information pertinent to pollution prevention, including source 

reduction, recycling activities and safer processes or products available due to the new chemical substance. 

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological 

modification, process and procedure modification, product reformulation, raw materials substitution, and/or 

inventory control. Recycling refers to the reclamation of useful chemical components from wastes that would 

otherwise be treated or released as air emissions or water discharges, or land disposal. Descriptions of pollution 

prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance 

with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the 

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting 

of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics of the PMN substance to potential 

alternatives may be provided. 

All information provided in this section will be taken into consideration during the review of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (I) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a 

reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in 

the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical 

substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing 

substance that poses a greater overall risk to human health or the environment. 

Unsaturated polyester-imides, such as the PMN substance, have been used for many years as 

electrical insulation in the U.S. and Europe. This polymer allows the formulation of low volatile 

diluents, therefore dramatically redcing air emissions when compared to the products it is designed 

to replace. 

[ ] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 11 
Part III -- LIST OF ATTACHNIENTS 

Attach continuation sheets for sections of the form and test data and other data (including physicallchemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to 

which it relates, if appropriate. Number consecutively the pages of the attachments. In the column below, enter the inclusive page 

numbers of each attachment. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidential. You must include with the sanitized copy of the notice form a sanitized 

version of any attachment in which you claim information as confidential. 

Attachment name 

Material Safety Data Sheet (MSDS) 

IR spectrum 

GPC data 

CASIES report 

CMA electronic PMN form documentation 

manufacturing, processing information 

customer use, exposure and release information 

Attachment 

page number( s) 

14-19 

Confidential 

20 

21-24 

25 

I 

26 

8a 

10a 

! 

I 

i 

! 

i 

[ ] Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 

EPA FORM 7710·25 (Rev. 5-95) Page 12 
PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential. The physical 

state of the neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. 

Properties that are measured for mixtures or formulations should be so noted (% PMN substance in _). You are not required to 

submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential 

information is properly protected. You should submit this worksheet as a supplement to your submission of test data. This worksheet 

is not a substitute for submission of test data. 

Property Mark Page Value It'v!easured 0 Confi~ 

demial (X) if 

(a) provided 

Physical state of neat substance X 

Vapor pressure 

@ Temperature °C 

X 

Densitylrelative density 

Solubility 

@ Temperature °C 

Solvent -­

Solubility in water @ Temperature °C 

Melting temperature 

Boiling I sublimation temperature@ torr pressure 

Spectra: X 

Dissociation constant 

Particle size distribution 

Octanoll water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

pH@ concentration 

Flammability 

Explodability 

Adsorption I coefficient 

Other - GPC data X 

number 

(b) (c) 

(s) (I) (g) 

glcm3 

gil­

°C 

°C 

20 

21-24 

Estimate Mark (X) 

(M orE) (d) 

M X 

X 

M X 

I 

I 

I 

I 

I 

M 

ATTACHMENT 


PAGE 13 

[ ] 


:RBV:IS:ION NUllBBR: 0 

DATE OF PRINT:ING: 02/09/2010 J 

PRBPAlUm BY: C 

MANUFACTOltBD BY: 

PRODUCT ID: l J 

CHEM:ICAL PAM:ILY: INSULATING VARNISH 

CHEM:ICAL NAME: ACRYLATE POLYESTER SOLUTION 

FORMULA: MIXTURE 

SYNONYMS: NONE 

EKBRGENCY OVERV:IBW: Refer to other MSDS sections for detailed information. 

TARGET ORGANS: Skin. Eyes. Respiratory System. 

EJ'FECTS FROM ActJ'l'E EXPOSlJRB: 

:INGEST:ION: Causes vomiting, nausea, and diarrhea. Irritation of the mouth, throat, and 


stomach. May cause pulmonary edema. 


SK:IN CONTACT: May cause an allergic skin reaction. Contains a component which is a 


known or suspected skin sensitizer. 


:INHALAT:ION: Excessive inhalation causes headache, dizziness, nausea and 


incoordination. May irritate mouth, nose, and throat. 


EYE CONTACT: May cause mild eye irritation. 


AGGRAVATED MED:ICAL COND:IT:IONS: Dermal ailments. 


Page: 1/6 
EFFECTS OF CHRONXC EXPOSURE: This product contains a component that is a suspected 


mutagen. 


CARCXHOGENXCXTY COMKBNT: This product or one of its ingredients present at 0.1% or 


more is NOT listed as a carcinogen or suspected carcinogen by NTP, IARC, or OSHA. 


CARCXHOGBNXCXTY: This space reserved for special use. 


ROUTBS OF ENTRY: Ingestion. Dermal - skin. Eyes. Inhalation. 


01'HBR.: None known. 


XNGESTXON: Do not induce vomiting. Slowly dilute with 1-3 glasses of water and seek 

medical attention. Never give anything by mouth to an unconscious person. 

SEXN CONTACT: Remove contaminated clothing and launder before reuse. Wash with soap 

and water. Remove contaminated shoes and discard. Get medical attention if 

irritation persists. 

XNBALATXON: If inhaled, remove to fresh air. If not breathing give artificial 

respiration using a barrier device. If breathing is difficult give oxygen. Get medical 

attention. 

BYE CONTACT: In case of contact, or suspected contact, immediately flush eyes with 

plenty of water for at least 15 minutes and get medical attention immediately after 

flushing. 

NOTES TO PHYSXCXAN: Treatment based on sound judgment of physician and individual 

reactions of patient. 

FLASH POXNT (F): >200 (C): >93 

FLASH POINT METHOD: Not specified 

IGNX~ION TEMP (F): Unknown (C): Unknown 

OSHA FLAKMABXLXTY CLASSXFICATXON: Combustible Liquid, Class IIIB 

F~LE LrKXTS XN AXR - LOWBR (%): Not Determined 

F~LE LrKXTS XN AXR - UPPER (%): Not Determined 

SBNSXTXVITY TO MBCHANXCAL rKPACT (YIN): No 

SBNSXTXVITY TO STATXC DXSCHARGE: Sensitivity to static discharge is not expected. 

Material has a Flash Point above 200F. 

EXTINGOXSBXNG MBDXA: Alcohol foam. Carbon dioxide. Dry chemical. Foam. Water mist. 

FIRE FZGHTXNG PROCEDURES: Vapors may form explosive mixture with air. combustible. 

Cool exposed containers with water spray after extinguishing fire. Positive pressure, 

self-contained breathing apparatus. Polymerization may take place during a fire due to 

elevated temperature where closed containers could violently rupture. Toxic vapors are 

emitted in a fire condition. Wear full protective clothing. 

ACTXON TO BE TAXER XF MATBRXAL XS RBLEASED OR SPXLLED: Wipe, scrape or soak up in an 

inert material and put in a container for disposal. Wear proper protective equipment 

as specified in the protective equipment section. Remove sources of ignition. Increase 

area ventilation. Persons not trained should evacuate area. 

PRECAUTXONS TO BE TAXER ZN HANDLXNG AND STORAGB: Recommended storage in original 

container at temperature below 30 C (85 F). Avoid contact with skin and eyes. Use only 

in a well ventilated area. Caution: Combustible. Keep container closed when not in use 

to prevent contact with acidic, basic or oxidizing materials. Keep away from food and 

smoking materials. Wash hands before eating and smoking. 

PRODUCT CODE: ["J Page: 2/6 
Von Roll recommends evaluation and selection of appropr ate neer controls (such 

as ventilation and eyewash/safety shower) as well as appropriate personal protective 

equipment (such as respiratory protection, protective gloves, eye protection) for 

safely handling this material. The following guidelines should be considered in this 

process. 

BNGZNBERZHG CONTROLS: Exhaust ventilation. Showers. Eyewash stations. Use in a well 


ventilated area. 


RESPZRATORY PROTECTZON: Use in a well ventilated area. Use approved NIOSH respiratory 


protection if TLV exceeded, or over exposure is likely. 


GLOVES: Rubber gloves. Neoprene gloves. 


EYE PROTECTZON: Splash Goggles. Face shield. 


OTHER PERSONAL PROTECTZON DATA: Rubber apron or other chemical-resistant apron. 


Rubber boots. Face shield. 


VENTZLA~ZON: Use only in well ventilated area. Localized mechanical ventilation. 


COMPON'EN'l' ZNFORMATZON: 

PRODUCT ZNFORMATZON: 

BOZLZNG POZRT (P): NOT DETERMINED (C): NOT DETERMINED 

PREEZZRG POZRT (P): NOT DETERMINED (C): NOT DETERMINED 

MELTZRG POZRT (P): NOT DETERMINED (C): NOT DETERMINED 

PHYSZCAL STATE: LIQUID 

DESCRZPTZON: CLEAR 

ODOR: MILD 

ODOR 'l'BRESHOLD (PPM): UNKNOWN 

% VOLATZLE BY WEZGft: NEGLIGIBLE 

EVAPORATZON RATE (BtrrYL AC~ATE • 1): NOT DETERMINED 

VAPOR PRESSURE (mmHg @ 20 C): NOT DETERMINED 

VAPOR DENSZTY (AZR==1): 

NOT DETERMINED 

SPBCZPZC GRAVZn • 25 C (WATER. 1): 1.10 

ACZD/ALKALZNZTY (MEG/G): NOT DETERMINED 

pH: NOT DETERMINED 

SOLUBZLZTY ZN WATER DESCRZPTZON: NEGLIGIBLE 

SOLUBZLZ~Y ZN ORGANZC SOLVENT (STA~E SOLVENT): NOT DETERMINED 

'-h <'r~_ '~.f"2-"_ 

,_ ,,:~___~" _ ;'.;'L:. ,', 

CHEHZCAL ~ABZLzn: Stable. 


HAZARDOUS POLYMERZZATZON: May occur. 


HAZARDOUS DECOMPOSZTZON PRODUCTS: Carbon monoxide. Carbon dioxide. Toxic fumes. 


Ammonia. Acrid fumes. 

MATZRXALS TO AVOID: Avoid contact with acidic, basic or oxidizing agents. Light. 

Contact with oxidizing agents. Inert gas. Ultraviolet radiation 

CONDITIONS TO AVOID: Keep away from heat, sparks and flame. Avoid any source of 

ignition. UV light exposure. Extreme heat. Avoid contact with heat, sparks, open 

flame, and static discharge. Inhibitor Depletion 

: 4,000 PPM 1 4H (RAT) 

ECOTOXICOLOGICAL INFORMATION: No data at this time. 


CHEHICAL PATE INFORMATION: No data at this time. 


PERSISTENCE: Not determined. 


APPRAISAL: Not determined. 


MOBILITY: Not determined. 


DISPOSAL OP WASTE METHOD: Disposal should be made in accordance with federal, state 


and local regulations. Incineration recommended in approved incinerator according to 


federal, state, and local regulations. 


EPA HAZARDOUS WASTE DISPOSAL CODE: Not regulated. 


PRODUCT CODE: C· ) Page: 4/6 

······c· ·,1 
DOT SHIPPING HAME: RESIN COMPOUND, LIQUID, NOT DOT REGULATED 

DOT HAZARD CLASS: NOT DOT REGULATED 

DOT PACKING GROOP: NOT DOT REGULATED 

DOT LABEL(S): NOT DOT REGULATED 

WID NUDER: NOT DOT REGULATED 

PLACA:RDS: NONE NOT DOT REGULATED 

ICAO/XATA: NOT REGULATED 

MARID POLLtrl'AN'l': NONE 

NMFC CLASSIFICATION: CLASS 55 

HAZARD lUTING SYSTBMS 

NFPA RATING: HEALTH 2, FLAMMABILITY 1 , INSTABILITY 2 

BMIS CLASSIFICATION: HEALTH *2 , FLAMMABILITY 1, PHYSICAL HAZARD 2 

vee EXCLUDING H2O 

&: BXBIIPTBD vee (LB/GL): NOT DETERMINED 

COtlNTRY RBGISTRATION 

TSCA INVENTORY STATUS: All components are NOT listed on TSCA Inventory. 


CANAD~ INVENTORY: This product does NOT comply with the Canadian DSL. 


BIDCS: This product does not comply with EINECS 


RBGt7LATORY INFORMATION: CA/IIJA/NJ/PA RIGB'l'-TO-KNOW 


thoxylated Bisphenol A 

iacrylate Ester 

401-02-1 

YES YES YES YES 

SARA 302 EXTREMELY HAZARDOOS SUBSTANCES LIST: No components of this product are listed 

as extremely hazardous substances in 40 CFR Part 355 and are present at levels which 

could require reporting and emergency planning. 

SARA (311, 312) HAZARD CLASS: FIRE HAZARD 

ACUTE HEALTH HAZARD 

SARA 313 CBBMICALS: This product contains toxic chemical(s) listed below which is(are) 

subject to the reporting requirements of Section 313 of Title III of SARA and 40 CFR 

Part 372. 

NONE - This product does not contain chemicals at levels with require reporting under 

the statue. 

WBHIS (CANADA): 

WHlUS HAZARD CLASS; B3 COMBUSTIBLE LIQUIDS 

D2B TOXIC MATERIALS 

WBHIS TRADE SECRET: NONE 

, ;, c'-'," ,\' 

)i"'~' 

Page: 5/6 
COMPANY DXSCLAXMBR: 

These data are offered in good faith as typical values and not as a product 

specification. No warranty, either expressed or implied, is made. The recommended 

handling procedures are believed to be generally applicable. However, each user 

should review these recommendations in the specific context of the intended use. 

ABBltBV:t.ATXORS: 

EST = ESTIMATED NEGL. = NEGLIGIBLE 

NA = NOT APPLICABLE UNKN = UNKNOWN 

ADDX'l'XORAL XHPORllATXOR: 

NONE 

PRODUCT CODE: ~ 11 
\ 
j 

l 

, __,J 
AM.ERICAN POLYMER STANDARDS CORPORATION 

8680 TYLER BL VD••IIlENTOJl. OB 44060 

. P,O. BOX 901. )(.B:NTOJl. OR 4.4061-0901 

PHONE: 440-255-2211 FA.x: 410.255.8397 

INT.IINET; ",..,,,.AMPOLYlIr£B.COIC E'MAIL~ "l'SC@J.M:rOLYMBl'.COV 

December 15, 2009 

Enclosed the gel penttea:tion chromatography results in TIIF at 30Q C on your polymer 

~l~ . 

ResuUs: InPolystyrene MW Numbers 

Sample Mn Mw MwlMn 

3630 500 28,800 526,400 57.60 

Sample % MW Below 1,000 % MW Below 500 

3630 40.0 23.7 

Esperimeatal 

Columns: AM ope Gel: Two Linear 

Solvent: THF 

Temperature: 30°C 

Flow Rate: 1.Omllmin 

Injection Volume: lOOpl 

Detector: M-15O-C (64/25) 

Data Module: GPCPR03.13 
[ J 


0-2 ENOED: 12/14/09 i1:c 

GPC-PRO 3.13 MOLECULAR WEIGHT DISTRIBUTION 

5.00 

4.00 

-rl 


J 


0 

~ 

x 3.00 I 

1-.J 

~ 

2.00 t -x 

D) 

0 

rl

-

c:::

:a: 1.00 + I 

,

( 


I
 .000 .~ 1.00 2.00 3.00 4.00 5.00 6.00 7.00

AMERICAN POLYMER 

STANDARDS CORPORATION LOG tv! II'" (4CCIl lllWlll 

pAl (440) a.....7 WW1'.~_ 
0....2 [ ~ ENDEO~ 12/14/09 ii:( GPC-PRO 3.13 DR! CHROMATOGRAM .000 

-4.00 

-rl 

+ 

o 

""' x -8.00 

lJ 

w 

-12.0 

> 

:2: 


-1 


<

Z 

(!) 


H 


CIl -16.0 


...20 •0 ,. , I I I I , 

6.00 10.0 14.0 18.0 22.0 26.0 30.0 

AMERICAN POLYMER 

STANDARDS CORPORATION RET VOL (mL) (44Ola....:m

PM (44«$ _.097 

--P'fiII'.rmer.c:llllft 
cal 

GPC-PRO 3.13 CALIBRATION PLOT 

7.00 Polystyrenes in THF at 30e 
 ~ December 15, 2009 


~ AO'" 1.205E1 

8.00 

0 

+ 5.00

0 

TI 

X 

4.00 

I(v 

~ 

3.00 

::E 

(!) 

0 

J 

2.00 

i.OO ,l 

~ 1;1-4.686£-1 

~ 

~~ 

Columns: AM GPC Gel 

Two Linear 

~. 

, 'f f I l 

11.0 19.0 15.0 17.0 19.0 21.0 


AMERICAN POLYMER 

STANDARDS CORPORATION RET. VOL (ml) (<NO) u ....u 

FAX 

_(<140) .1....." ........",...,.­
Inventory Expert Service 


A division of the American Chemical Society Phone: 8()()..631-1884. 614447-3870 

Fax: 614-447-3747 

E-mail: answers@cas.org 

Web: www.cas.orglproductslclientl 

INVENTORY EXPERT SERVICE REPORT 

IES-ORDER NUMBER: [ J 

REGISTRY NUMBER: L J 

CA INDEX NAME 

r 

L J

Please print the above CA Index Name on the appropriate page of your PMN. 

r1 If this box is checked, CAS has made correction(s) marked in red to 

your IES order. please make the same correction(s) to your PMN before 

submitting it to the EPA. 

CAS 2540 Olentangy River Road P.O. Box 3343 Columbus. Ohio 43210-0334 USA 

~5"
1 

, 


f 

, .. . . 

PreManufacture Notice and 


Notice of Commencement Forms 


~PA.Form 7710-25 (Rev. 5-95) 

EPA Form 7710-56 (Rev. -96) 

Installation and Use Instructions 


MS Word 6.0for·Windows 


u.s. EPA Approved December 12, 1996 


by Anthony Cheatham 


TSCA Data Administration Section 


.. 

COMP lANe ll!l ResponsibleC8r." 

ASSISTANCE , r ApulJnc CoRlDlitment TOOLS