## PMNPage 1 ; Page 1 of 18 

# PREMANUFACTURE NOTICE FormApproved O .M .B. No . 2070-0012. App

roval Expires 

## U .S. ENVIRONMENTAL PROTECTIONAGENCY I AGENCY USE ONLY ~ ofT~~pc . 

# :~ .CDe

~rtter the total number of pages in the Prremanufactnre Notice

. 

### 0t, 1j1 t*, i' 7 " ., * :3 {_ . . r . , " 4 

# Company Sanitized 

# r 18 GENERAL INSTRUCTIONS 

## P. 1 10-31-96 .

Youmust provide all information requested in this formtothe extent that it is known to or reasonably ascertainable by you Make reasonable estimates ifyou do riot have actual data. Beforeyou complete this form, you should read the "Instructions Manual forPrernanufacture Notification" (the Instructions Manual is available fr omthe Toxic Substances Control Act (TSCA) Infomtation Service by calling 202-5541404, or faaing 202-5545603) . If a user fee has been remitted for this notice (40CFR700 .45~ indicate in the boxes above the TS-user fee identification number you have generated . Remember, your user fee 11) number must also appear on yourcorresponding fee remittance, which is sent to EPA, Washington Financial Management Center (3303), P .O . 360399M

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

. Part I - 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 authonze another person to submit chemical identity information for you, but your submission will not be complete and the reviewwill not begin until EPAreceives this information A letter in support of your submissionshould reference your TS user fee identification number. You must submit anoriginal and twocopies of this notice including all test data. If you claimed any information as confidential, a single sanitized copy most also be submitted- Part 11-HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE If there ace several manufact ure, processing, or use operations to be described in Part II, sections A and B of this notice, reproduce the sections as needed

Part III - LIST OF ATTACIIMEI3TS Attach additional sheets if there is not enough space toanswer a question fully. Label each continuation sheet with the corresponding section heading. In Part III, list these attachments, any test data or other data and any optional information included in the notice. OPTIONAL INFORMATION You may include any information that youwant EPA toconsider in evaluaung the new substance. On page I 1 of this form, space has been provided for you todescribe pollution prevention and recycling information you may have regarding the new substesice. So-called "binding" boxes are included throughout this form for you to indicate your willingness to be bound to certain statements you make in this section, such as use, 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 cage of exemption appticatiots (such as TMEA, LVE, LOREX) where certain information provided m such notification is bvidmg on the submitter when the Agency approves the exemption application, checking a binding box m this notice does not by itself prohibit the submitter fromlater deviating fromthe information (except chemical identity) reported in the form CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a clavn on the form, mark (X) the confidential box next tothe information that you claimas confidential . To assert a claun in an attachment, circle or bracket the information you claimas confidential . If ou claiminformation in the notices as confi dential . you mist Lsn nrovide a sanitized version ofthe notice, (including attachments) . For additional imtructio`s on claiming information as eonfidertial, read the Instructions, Manual . © Mark (x) if arry infonnaion in this notice is claimed as cciifidential . TEST DATA AND OTHERDATA You are required to submit all test data in your possession or control and to provide a description of all other data known toor 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 ofthe new chemical substance . Standard literature citations may be submitted for data in the open scientific literature . Contnlete test data (written in Ennlishl, not summaries of data, must be subntitted if they do not appear in the open literature. You should clearly identify whether test data is on thesubstance or on an analog. Also, the chemical composition of the tested material should be characterized. Following are examples of test data and other data . Data should be submitted according to the requirements of §720 .50 of the Premamtfacture Notification Rule (40 CFR Part 720) . Test Data (Check Below any included m

this notice) " Environmental fate data O Yes " Other data O Yes " Healtheffects data 11 Yes Risk assessments O " Environmental effects data D Yes Structure/activity relationships Physical/Chemical Ihoperties" O Yes Test data not m the possession or control of the submitler n ' A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE ((.'heck Only One) 

# IKI PiL(N (Prenanufactive Notice)

INTERMEDIATE PMN (submitted in sequencewith final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing ExemptionApplication) LVE (Low

Volume Exemption) @ 40 CFR 723.50(cxl ) LOREX (LowRelease/LowExposure Exemption) @ 40 CFR 723

.50(cx2) 1.VEModfication n LORFXModification IS THIS A CONSOLIDATED PMN1 Yes # of chemicals orpolymers (Prenotice Communication #requued, enter 9 on page EPA FORM

7710-25 (Rev. 5-95) Replaces previous editions of EPAForm7710-25.

## PMN Page 2 ; Page 2 of 18 p. 2

Public reporting burden for this collection of information is estimated to average 110 hours per response, including time 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 ofthis collection of information, including suggestions for reducing this burden, to Director, Collection Strategies Division (2822), U .S. Environmental Protection Agency, 1200 Pennsylvania Ave., N.W ., Washington, D.C

. 20460 ; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

## CERTIFICATION-- A Printed copy of this signature page, with original signature, must be submitted I certify that to the best of my knowledge and belief: 1 . The company named in Part I, section A, subsection I a of this notice formintends 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 : Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: F-1 The Company named in Part I, Section A has remitted the fee of $2500specified in 40 CFR 700 .45(b), or 0 The Company named in Part 1, Section A has remitted the fee of $1000 for an Intermediate PMN (defined (d_~ 40CFR 700.43) in accordance with 40 CFR 700.45(b), or 

## 0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 in accordance with 40 CFR 700,45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release and lowexposure exemption (LoRex) application in accordance with 40 CFR 723 .50(c)(2), check the following certification statements: 0 The manufacturer submitting this notice intends to manufacture or import the newchemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 C FK 123.50 . The manufacturer is familiar with the temis of this section and will comply with those terms: and 0 The new

chemical substance for which the notice is submitted rneets all applicable exemption conditions. If this application is lox an LVF in accordance with -l0 CFR 723.50(c)( I ), the manulacturrer in(ends to commence manufacture of the exempted substance for commercial purposes within I year of the date of the expiration of the 3(1 day reNiew period. I he accuracy af the st .itements iou make in this nntice should reflect Pint- best prediction of the enticipatcd facts ngardink the rh." n rnl sut, .tance _dc .cribed h, rein . 1n knossing and ,s illful rnhinterprctaliun iv snbjccl In etitnin:d pen alts~ ntnu .tnt to IS 1 sC Illtll . 1yr ncia .ual till, .,( d f llk, .J 1( b :un.il ti,__n iti .re R,,quuwdl I) .dr 9- '-- - - T tii . :r .M~n :~,l r~,nl ~A ,rph, ,il" I :I --1

t .P .\ FUR1.I ; ; 10 25 IRcV ~-~751

## p. 3 PMNPage 3 ; Page 3 of 18 Part 1 -GENERAL INFORMATION Section A - SUBMITTERIDENTIFICATION ConfiMark () the "Confidential" box next to an subsection you claimas confidential dential 1 a . Person Name ofauthorized official Position Submitting Notice (in US )

. . Company Mailing address (number and street) 544 Beacon Knoll Lane City, State Postal Code b. Agent (if Name ofauthorized official Position applicable) N/A

Company Mailing address (number and street) City, State Postal Code I Telephone (include area code)

c . Ifyou are submitting this notice as part ofajoint submission, mark (X) this box. Joint Submitter (if Name ofauthorized official Position applicable) N/A

Company Mailing address (number and street) City, State Province, Country Postal Code Telephone (include country or area code) 2 . Technical Name of authorized official Contact (in Position U .S.) Company

Mailing address (number and street) 544 Beacon Knoll lane 

### City, State Postal Code Telephone (include area code) 3. Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number. Mark (X) -- 

# F if none 4. tfyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by Mark (X) - EPA . Ifyou previously submitted a PMN for this substance enter the PMN if none number assigned by EPA (i .e. withdrawn or incomplete) . - 5. I f you have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number - Mark X) assigned by EPA. ~ if none 6 . Type of Notice - Mark (X) Manufacture Only Binding Option Mark (X) I 2 . I I 0 Import I

Only I 3. I Binding Option I Mark (X) I Both

EPA FORM

7710-25 (Rev. 5-95) Page 3

## p. 4 PMN Page 4 ; Page 4 of 18 Part I -- GENERAL INFORMATION - Continued Section B- CHENBCAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth m : Collective

e 9CI of CA nomenclature rules and conventions . Mark the "Confidential" box next to an itemy ou claim as confidential Complete either item 1 (Class 1 or 2substances) or 2(Polymers) as appropriate . Complete all other items . If another person will submitchemical identity information for you (for either Item I or 2), mark (X) the box at the right . ConfiIden " the name,com

pany, and address of that on in a continuation sheet. ~ dential 1 . Class 1 or 2chemical substances (for definitions ofclass 1 and class 2substan see the Instructions Manual) a . Class ofsubstance - Mark (X) Class 1 or Class 2 b . Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings forsimilarsubstances . For Class 1 substances a CAIndex Name must be provided For Class 2substances either a CA Index Name or CAPreferred Name must be provided, which ever is appropriate basedon CA 9C1 nomenclaturerules 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 ~ Method 2 (Other Source) report obtained fromthe CAS Inventory Expert Services must be submittedas an attachment tothis notice) d . Molecular formula CBI CAS Registry Number (if a number alread -'

y exists for the substance) e. For a class I substance, providea complete and correct chemical structure diagram . For a class 2substance, provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. Please seethe E-PtvIN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance : .

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

7710-25 (Rev. 5-95) Page 4

## PMN Page 4a ; Page 5 of 18

For a ctass 2substance - (1) List the immediateprecursorsubstances with theirrespective CAS Registry Numbers. (2) Describe the nature of the reaction or process . (3) Indicate the rangeof composition and the typical composition (where appropriate) . e. (1) List the immediate precursor substances with their respective CAS Registry Numbers . COnlName (CAS #) dential 

## E]- N/A

e. (2) Describe the nature of the reaction or process.

N/A

e. (3) Indicate the range of composition and the typical composition (vihere appropriate~

N/A

~0 Mark (X) (his box ifyou attach a continuation sheet . EPAFORM

7710-25 (Rev. 5-95) Page 4a

## p. 6 PMN Page 5 ; Page 6 of 18 Part I - GENERAL INFORMATION- Continued Section B-- CHENIICAL IDENTITY INFORMATION- Continued 2. Polymers (For a definition of polymer, seethe Instructions Manual .) Confidential a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend tomanufacture. Indicate maximum

weight percent of low

molecular weight species (not including residual monomers, reactants, orsolvents) below 500and below1,000absolute molecularwei ght of that com position. Describe the methods of measurement or the basis for your estimates: GPC U Other EJ : (Specify below)

(i) lowest number average molecular weight : (ii) maximum

weight °i°below

500molecular weight: (iii) maximum

weight %below

1000 molecular weight : Mark (X) this box ifyou attach a continuation sheet. b . You must make separate confidentiality claims for monomer or otherreactant identity, composition information, and residual information. Mark (X)the "Confidential" box next to any item you claimas confidential (1) - Providethe specific chemical name and CAS Registry Number (ifa number exists) ofeach monomerorotherreactant used in the man

thepolymer. ufacture of (2) - Matt (X)this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or otherreactant in the polymer. (4) - Choose "yes" fromdrop down menu ifyou want a monomer or otherreactant used at twoweight percent or less to be listed as part of

description on the TSCA Chemical Substance Inventory. the polymer (5) - Mark (X) this column ifentries in columns (3) and (4)are confidential . (6) - Indicate the maximum weight percent ofeach monomer or otherreactant that may be present as a residual in thepolymer as manufactured for commercial purposes . (7) - Mark (X) this column if en in column (6) is confidential . Monomer orother reactant and CAS Registry Number Confi- Typical Include in Confi- Maximum Confi1 dential 2 composition

3 % identity

4

# Fdential

5 

# ,F] residual

6 % dential

7 

# 0 °,°

# F_1_F] -

I 

# °,° 

# - 0 _ °,° % - °,°0 a _% -1 

# o °.° °,° -

_ F11 

# °.°F-1 _ F11 

# o.°El % °,° o °.o o %o o % -- o ~%o o ° .°_ o %o o ° .° o %o o °.° o o °.° o ° .°o

Mark (X) this box ify

ou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 5

## p. 7 PMN Page 5a ; Page 7 of 18 c. Please identify which method you used to develop orobtain the specified chemical identit information reported in this notice (check one) . ~ Method 1 (CAS Inventory Expert Service - a copy of the identification report Method 2(other source) obtained from CAS InventoryExpert Service must be submitted as an attachment to this notice) CBI El d . The currently correct Chemical Abstracts (CA) name for the polymerthat is consistent with TSCA Inventory listings for similar polymers. N/A

CAS Registry Number (if a number already exists for thesubstance) e . Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. . Please see the E-PMNInstruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance .

I LJMaric (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 5a

## p. 8 PMN Page 6 ; Page 8 of 18 

## Part I -- GENERAL INFORMATION - Continued Section B- CHEMICAL IDEN7TTY INFORMATION-- Continued 3. 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 ifavailable. If there are unidentified impurities, enter"unidentified." ) - Estimate the maximum wei ht %

of each im

p uri ty. If there are unidentified im p urities, estimate their total wei g ht 0/a Impurity and CASRegistry Number Maximum Confia percent dential % %

% %

%

%

% Mark (X) this box ifyou attach a continuation sheet. 4. Synonyms -Enter any chemical synonyms for the new chemical identified in subsection 1 or 2 . Confidential Mark (X) this box ifyou attach a continuation sheet . 5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2 .

Mark (X) this box if you attach acontinuation sheet. 6 . Generic chemical name - If you claimchemical identify as confidential, you must provide a generic 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.

Mark (X) this box ifyou attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance

. Provide the CAS Registry Number if available

. Bypnoduct CAS Registry Number ConfiI 2 dential

10 Mark (X) this box ifyou attach a continuation sheet . J EPAFORM

7710-25 (Rev. 5-95) Page 6

## p. 9 PMN Page 7 ; Page 9 of 78 

# Part I - GENERAL INFORMATION-- Continued Section C - PRODUCTION, IMPORT,ANDUSE INFORMATION : Mark X the "Confidential" box next to an item y ou claim as confidential . 1 . Production volume - Estimate the maximumproduction 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 k r, spec

i fy the volume and mark x in the bindin box. If ranted, you are bound to this volume 

## Maximum

first 12-month production (kg/yr) Maximum12-month production (kg/yr) Confi- Binding (100%new

chemical substance basis) (100%new chemical substance basis) dential Option 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 itemyou claim as confidential . a . ( 1 ) --Describe each intended category of use of the new chemical substanceby function and application . (2) -Mark (X) this column if entry column (1) is nfidential business information (CBI) . (3) --Indicateyour willingness to have the information provided in column (1) binding . (4) --Estimate the percent of total roduction for the first three years devoted to each category of use . (5) -Mark (X) this column ifentry in column (4) is confidential business information (CBI) . (6) -- stimate thepercent of the new substance as formulated in mixtures, suspensions. emulsions, solutions, or gels as manufactured for commercial purposes at sites under our 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 roduct volume expected for the listed "use" sectors. Mark more than one box ifappropriate. Mark (X) to indicate your willingness to havethe use type provided in (8) indin . 9 --Mark X this column if ies in column 8 is are confidential business information (CBI . Category of use (1) (by function and application i .e. a CBI Bi°the Prod- CBI % in CBI %

of substance expected per use CBI dispersive dye for finishing polyester fibers) M~ uction Formu (8) tx % Iatlon (2) (3) (4) (5) (6) (7) sita Cae- tndnw Com- Binding (9) lvnited tual metciat on % % Acid Dye for Coloring Anodized _ Aluminum ~ 100 a5% 100°/ ° 'Y

## 11 1111 %

# 11 % 

# Ell % 

# 11 % 

# - 11 %

% 

# - ,

%

% % °/o _ ' Ifyou have identified a"consumer" use, please provide on a continuation sheeta detailed description of the use(s) 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 whichthis substance loses its identity in the consumer product (X) this box ifyou attach a continuation sheet b. Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category . Read theInstruction description Manual for examples ofgeneric usedescriptions . For Dyeing , .-arid_.u,?. . Dy= is :lade <<_c = - 5 - _ CvS r t~, ~ rar- _ . . n.Ei :11 .Zeu :~:~ :~__ a_ '_ ._ . ; . . __~3~' .'1~;-i ar'i~ ._ :u -

_ in` b _ _ ' as . .n . . ~ .k that

. _ _ _ ~ CL . :'JE Y' .3 :Ci .__ . , After C

.~: ._ dye

}'=' . is abs . :rhcCI 1i : JC_u Ct ._ _ , . .> ; ~ ~r~

. _ C_ ~ .i3r _Cc .z . .iv ._ . . -

, . _ . ts a_r

cc _ins .'- t

tY . !water . . water u,_Cl ._n,_ " Coating e5 B=~_~U t .^ . Cj _ y" _ -_____ _,_ ~n the ~~:a

_.-a_- .1<` _ !° ~ .~r._ ._t i " ~

: lE_f:n~

.~Q _YG . .1 ^ 0 Mark (X) this box ifyou 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 B_dMs , , , information whichwill be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for ()pfi°n the safe handing, transport, use, or disposal of thenew substance. Gist in part III hazard information you include. Mark (X) this box ifyou attach hazard information. EPAFORM

7710-25 (Rev. 5-95) Page 7

## p. 10 PMN Page 8 ;Page 10 of 18 

# Part II-- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBIVIIZTER Mark (X) the "Confidential" box next to any itemyou claim as confidential 

### Complete section Afor 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 processing or use operations after im po rt . You must describe these operations. See instructions manual I . Operation description Confi

### a. Identity -- Enter the identi ty ofthe site at which the operation will occur. dential Name Diversified Products Inc . Site address (numberand street) 1140 Memorial Park Road Ci ty, County

, State, ZIPcode Lancaster Lancaster SC 29721 

### If the same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly ditTerent production rates or operations, include all the information requested in this section for those sites as attachments.

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

### rb. Type --

Mark (X) ~ ~ Manufacturing Processing Use c. Amount and Duration -- Com plete 1 or 2 as appropriate Maximum

kg/batch (t oar new

ohemiwi subsume) Hours/batch Batches/year 1 . Batch 5 0 1 5o Maximum

kg/day (poosrnewct-at Homs/day Days/year - -

.abe~Ce) 2 . Continuous d . Process description (i Mark (X) to indicate your willingness to have your process description binding. (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage 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 kg/batch on a 100% new chemical substance basis), and entry point ofall 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 dally or per batch.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance

. If releasing to two media at the same step, assign a second release number forthe second medium . Product will be received in 5 lb sealed puncture resistant bags that will be packaged in sealed 

### containers . Most of the product will be reshipped as received without repackaging. Some product will be repackaged in smaller containers weighing from 5 - 40 lbs . This activity is expected to last 1 hour for 50 days in the year . One employee will be exposed to the bags when performing this activity .

Madc (X) this box ifyou attach a continuation sheet. EPAFORM

7710-25 (Rev. 5-95) Page 8

## P. 11 PMN Page 8a ; Page 11 of 18

EPA FORM

7710-25 (Rev. 5-95) Page 8a

## PMNPage 9 ; Page 12 of 18 Part II- 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 ofworker activity, physical formof the new chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box nexi to any itemyou claim as confideatial . (1)--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 (1) is confidential business information (CBI) . (3) -- Describe anyprotective equipmentandengineering controls used toprotect workers. (4) and (6) - Indicate your willingness to have the informationprovided in column (3)or (5) binding. (5) - Indicate the physical form(s) of the new chemical substance (e.g., solid : crystal, granule, powder, or dust)and % new chemical substance (ifpart ofa mixture) at the time ofexposure. (7) -Madc (X) this column if entry in column (5) is confidential business information (CBI). (8) -Estimate the maximum number ofworkers involved in each activity for allsites 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 activity for any worker in hours per day and days peryear. 12 --Mark this column ifentries in columns 10 and 11 are confidential business'nformation (CB I). Worker activity CB1 Protective Equipment/ B .~du6 Physical Hadms CB1 # of CBI Maximun diaation CB1

forms(s) (i .e., bag ) dumping, filling dn~ms 2) Eng ineerin g Controls 3 ~s Mark (x) (4) and "/ new

suL~ty~ice (5) ~n

Mark (x) (6) 7) Workers

Exposed ~~ 9) Hrs/day

10) Daysiyr

11) 12) Repackaging of sealed bags Gloves, Safety Glasses, Apron & Face Mask Powder

-

li d I L Maric (X) this box ifyou attach a continuation sheet . EPA FORM

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

## PMN Page 9a ; Page 13 of 18

3. Environmental Release and Disposal - You must make separateconfidentiality claims for the release number and theamount of the new chemical substance released and other release and disposal information . Mark (X) the "Confidential" box next to each itemyou claim as confidential . (1) -Enter thenumber ofeach release point identified in theprocess description, part IL section A, subsection ld(3). (2) -Estimate the amount of the new substance released (a) directly tothe environment or (b) into control technology (in kg/day or kg/batch) . (3) -Mark (X)this column ifentries in columns (1) and (2) are confidential business information (CBI) . (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 fromthat release point . (5) - a. Describe control technology, if any, and control efficiency that will be usedto limit therelease of thenew 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 shed, for each site describe any additional disposal methods that will be used andwhether the waste is subjex4 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) . C) - Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers fordirect discharges or NPDES numbers of theP(7fW (Pu blicly Owned Treatment Wodcs Madc if the POTW name or NPDES# is confidential business information (CB . Release Number Amount of new

substance released CBI Medi- of release Control technology and efficiency (you may wish tooptionally attach

efficienc y data CBI (1) (2a) (2b) (3) e g. sadc ai (4) - (Sa) Binding M~ _._- (5b) (6) NIA



### (7) Mark (X) the destination(s) of releases to water. NPDES # CBI POTW--provide name(s) Navigable waterway-- provide name(s)

--- Other--Specif?' Maric (X)this box ifyou attach a continuation sheet. EPAFnFM771n=25 (Rev. 5_05) page os

## PMNPage 10 ; Page 14 of 18 Part H- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE -Continued Section B- INDUSTRIAL SITES CONTROLLEDBY OTHERS Complete section B fortypical processing or use operations involving the new chemical substance at sitesyoudo not control . Importers do not have to complete this section for operations outside the U .S. ; however, you must report any processing or useactivities after im ort See the In t ti M l p . s ruc ons anua . Complete aseparatesection 8 foreach type of processing, or useoperation involving the new chemicalsubstance

. If the same operation is performed at more than one site describe the typical operation common to these 

### sites. Identi fy additional sites on acontinuation sheet. 1(a) . Operatiaa Description -To claiminformation inthis section as confidential, circle or bracket the specific information that you claimas confidential. ( 1 ) - Diagramthe major tmit operation steps andchemical conversions, including interimstorage and transportcontainers (specify - e.g. 5 gallon pails 55 gallon drums rail , , cars, tank bucks, etc) . On the diagram, identify by letter and briefly describe each workeractivity. (2) - Either in the diagramor in the text field l (b) below provide the , identity, the approximate weight (by kg1day or kg/batch, on an 100%new chemical substance basis), and entry point ofall feedstocks (including reactants solvents and , catalysts, etc) and all products, recycle streams, and wastes. Includecleaningchemicals (note frequency if not used daily or per batch) . (3) - Either in thediagram or in the text field I (b) below, identify by number the points of release including small or intermittent rel t th i 

### , eases. o e env ronment ofthe new chemical substance. (4) Please enter the # ofsites (remember to identify the locations ofthese sites on acontinuation sheet): -2-T-- # ofsites CBI



# 1

# 7

PARTS FROM ANODIZING TANK

l Process Imported to Distribution Metal Tank Rinse Seal Tank Finished the US in _ Center Finisher 5 gJltr . Water Dye is Part 2 5 or 10 ~ , dissolved locked in hi d s ppe to Ib. bags i n water coating customer

I (b). (Optional) This space is for a text description toclarify the diagramabove . a

Mark (X) this box ifyou attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 10

## PMN Page 10a ; Page 15 of 18 

## p. 15 2 . Worker Exposure/Environmental Release (1) --Fromthe diagram above, provide the letter for each worker activity. Complete 2-8foreach worker activity described. (2)-Estimate the number ofworkers exposed for all sites combined. (4) --Estimate the typical duration ofexposure per worker in (a) hours perday and (b) days per year. (6) --Describe physical formof exposure and % new chemical substance (ifin mixture), and any protective equipment and engineering controls, if any, used lo protect workers. (7) -Estimatethe percent of the new substance as formulated when packaged or used as a final product. (9) --Fromtheprocess diagramabove, enter thenumber of each release point . Complete 9-13 for each release point identified. (10) - Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). (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 result fromthe operation . ( 3 ) , (5) , 8 , (11) , 13 and 15 -- Mark X this column if an of the p roceeding entries are confidential business information (CBI ) . 

## etrc of a of Workers 

## Csl Duration of Exposure 

## CBI Protective Equip . /Engineering Controls/Physical Formand/ % new substance %

°' ~1Activity Exposed ulation (1) (2) (3) 4a 4b (5) 6 (7) (8) 1 ,,u F1 2_,2 :1 I Safety glasses/pH monitoring/Powder dissolved in water/0 .5% 0 .5% 

# 0 I 

# a F11 

# F-1

. 

# El l 

# 0 0 0~ 0 0 0 Release Number 

## Amountof New 

## CBl Media of Release &Control Technology CBl I Substance Released 9 l0a lOb 11 12 13 PO?'W I

14) -- Byproducts: None (15) ® Mark (X) thi s bo x if you attach a continuation sheet, 

# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in the followi ng section as confidential circle or bracket the spe cific information that y

ou claim as confidential . In this section you may provide information not reported elsewhere in this formregarding 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 ofchemical 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 fromwastes 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 nonenvironmental areas (e.g., occupational orconsumer 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 reviewof this substance. See PMNInstructions ~ Manual and Pollution Prevention Guidance manual for guidance and examples.

EPA FORM

7710-25 (Rev. 5-95) Page l0a

## p. 16 PMN Page 11 ; Page 16 of 18 Optional Pollution Prevention Information (Continued) lhscribe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment ; (2) a reduction in the volune 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 erviromnental 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 mav be a substitute for an existing substance that poses a greater overall risk to human health or the environment . 

# F-1

EPA FOR-7\1 7710-25 (Rev. 5-95) Page 11

## p. 17 PMN Page 12 ; Page 17 of 18 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the formto , which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the column below, enter the inclusive page numbers of each attachment. Electronic attachments can be identified by filename. ' Mark (X) the "Confidential" box next to any attachment name you claimas 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 forma sanitized version of an attachment in which you claiminformation as confidential . # Attachment name Attachment Filename Attachment num ber(s) Confidential I 1 1"r ~ Z 

# x ® 

# a 0 0 - 

# El 0 0 0 0 0 0 0 o 0 0 0 a 0 0 I u Mark (X)this box ifyou attach a continuation sheet. Enter the attachment name and number . t EPA FORM

7710-25 (Rev. 5-95) Page 12

## p. 18 PMN Page 13 ; Page 18 of 18 PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's review of physical and chemical properties data, please complete the following worksheet for datayou 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 whetheror not the property is claimed as confidential . If the attachments are electronic, give the attachment number (found on page 12) at (b) . 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 (% PMNsubstance in -_) . You are not required to submit this worksheet ; however, EPAstrongly recommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected . You should submit this worksheet as a supplement to our submission of test data. This worksheet is not a substitute for submission of test data. Property (X Page Value Measured Fsttmate (a) prov~ded num ber (b~ , (e) Mark (i~ (d) or E)



## ~ X ~ Ph ysical state ofneat substance s 1 Vapor pressure 

## a7 Tem p erature Torr a NK Densi ty/relative densi ty cm3 Solubility ) Temperature °C El El 

## Solvent N/A Solubili ty in water Tem perature 2e °C El l 

### 50 

# 9/L El El l 

## NK ° Meltingtem

perature C N/A Boiling / sublimation tem ature a) torr p ressure oc Spectra 

## F-1 Nx Dissociation constant F-1 Nx Particle size distribution F-1 NK Octanol / water partition coefficient He 's Law

constant 

# F-1 NK 

## Volatilization fromwater El None F1 NK 

## Volatilization fromsoil H concentration F-1 5 .5 - 6.0 Flammabilit F-] Not Flammable E lodabili F-1 Not Explodable 

## Adsorption / coefficient NK 

## F-] Other - S cif~

~ LJ Other - Specify 

# El EJ

FiMark (X) this box if you attach a continuation sheet. Enterthe attachment name and number . I I I I I I 

## ATTACHMENT PAGE 13