### P . Form Approved . O .M .B . No . 2070-0012 . Approval Expires 10-31-96 . U .S . ENVIRONMENTAL PROTECTION AGENCY 

## AGENCY US 

## E -ONLY Date of receipt • • 

# A PREMANUFACTURE NOTIC E FOR NEW CHE MI CAL SUBSTANCE S DOCUMENT CONTROL OFFICER 

# Compan y OFFICE OF POLLUTION PREVENTION 

# Sanitize d AND TOXIC SUBSTANCES, 7407 U .S . E .P .A . 401 M STREET, SW WASHINGTON, D .JTLQ K Enter the total number o pages 31 ocument control number PA case number in the Premanufacture Notice C) ' ~ GENERAL INSTRUCTIONS T S • 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 Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information 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, Atm . TSCA User fee . Part I- GENERAL INFORMATION TEST DATA AND OTHER DATA 

# SANITIZED COP Y You must provide the currently correct Chemical Abstracts (CA) Name of the new You are required to submit alI test data in your possession or control and to provide chemical substance, even if you claim the identity as confidential . You may authorize a description of all other data known to or reasonably ascertainable by you, if these another person to submit chemical identity information for you, but your submission will data are related to the health and environmental effects on the manufacture , not be complete and the review will not begin until EPA receives this information . A processing, distribution in commerce, use, or disposal of the new chemical letter in support of your submission should reference your TS user fee identification substance . Standard literature citations may be submitted for data in the on number . You must submit an original and two copies of this notice including all test data . P e If you claimed any information as confidential, a single sanitized copy must also be scientific literature . Complete test data (written in English), not summaries of data, submitted . must be submitted if they do not appear in the open literature . You should clearly identify whether test data is on the substance or on an analog . Also, the chemica l Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE composition of the tested material should be characterized . Following are examples of test data and other data . Data should be submitted according to the If there are several manufacture, processing, or use operations to be described in Part II, requirements of §720 .50 of the Premanufacture Notification Rule (40 CFR Part sections A and B of this notice, reproduce the sections as needed . 720) . Part III-LIST OF A TT ACH ME NTS Test Data (Check Below any included in this notice ) Attach additional sheets if there is not enough space to answer a question fully . Label • Environmental fate data ❑ Yes • Other data ❑ Yes each continuation sheet with the corresponding section heading . In Part III, list thes e attachments, any test data or other data and any optional information included in the • Health effects data ❑ Yes Risk assessments notice . • Environmental effects data ❑ Yes Structure/activity relationships • Physical/Chemical Properties' 0 Yes Test data not in the possession OPTIONAL INFORMATION or control of the submitter You may include any information that you want EPA to consider in evaluating the new • A physical and chemical properties worksheet is located on the last page of this form
. substance . On page I 1 of this form, space has been provided for you to describe d pollution prevention and recycling information you may have regarding the new TYPE OF NOTICE (Check Only One) substance . So-called "bindin " boxes are included through ® PMN (Premanufacture Notice)

B out this form for you to indicate you r willingness to be bound to certain statements you make in this section, such as use, N production volume, protective equipment . . . This option is intended to reduce delays ❑ INTERMEDIATE PMN (submitted in sequence witl4al product PMN) that routinely accompany the development of consent orders or Significant New Us e 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 ❑ SNUN (Significant New Use Notice ) the Agency approves the exemption application, checking a binding box in this notice ; ; --~ does not by itself prohibit the submitter from later deviating from the information (except ❑ TMEA (Test Marketing Exemption Application ) chemical identity) reported in the form . CONFIDENTIALITY CLAIMS ❑ LVE (Low Volume Exemption) @ 40 CFR 723 .50(c)( .1) -` ! You may claim any information in this notice as confidential . To assert a claim on the ❑ LOREX (Low Release/Low Exposure Exemption) ~a•40 CFR 723 .50(c)(2) form, mark (X) the confidential box next to the information that you claim as 1 5 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 ❑ LVE Modification LOREX Modification also provide a sanitized version of the notice, (including attachments) . For additional instructions on claiming information as confidential, read the Instructions Manual . IS THIS A CONSOL ID ATED PMN? ❑ Yes

Mark (x) if any information in this notice is claimed as confidential . # of chemicals I (Prenotice Communication # required, enter # on page 3)



# ~ EPA FORM 7710-25 (Rev . 5-95) / Replaces previous editions of EPA Form 7710-25 .

### p . 2

Public reporting burden for this collection of information is estimated to average I 10 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 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: 

# SANNITIZED COPY 1 . The comp 

### an y named in Pa 

### rt I, section A, subsection 1 a of 

### th is notice form intends to m 

### an ufacture or impo 

### rt for a commercial purpose, o 

### th er th 

### an in small qu 

### an tities solely for research 

### an d development, 

### th e subst 

### an ce identified in Pa 

### rt 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 : ® The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700 .45(b), o r F-1 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 700 .43) in accordance with 40 CFR 700 .45(b), o r F-1 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 low exposure exemption (LoRex) application in accordance with 40 CFR 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 CFR 723 .50 . ~ The manufacturer is familiar with the terms of this section and will comply with those terms ; an d ~ The new chemical substance for which the notice is submitted meets all applicable exemption conditions . E] If this application is for an LVE in accordance with 40 CFR 723 .50(c)(1), 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 reflect your best prediction of the anticipated facts regarding the chemical substanc e descri bed he re in . Any knowing and willful misinterpreta ti on is subject to c ri minal penalty pursuant to 18 USC 1001 . Confidential Signature and title of Authorized Official ( Original Signature Required) Date X Signature of agent - (if applicable) Date

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

### p . 3 Pa rt I -- GENERAL INFORMATIO N Section A- SUBMITI'ER IDENTIFICATION ConfiMark 0 the "Confidential" box next to any subsection you claim as con fi dential dential I a . Person Name of authorized official Positio n Submitting Notice (in U .S ) X

Compan y Mailing address ( number and street) 

# CP~~I City, State, ZIP Cod e b . Agent (if Name of authorized official Position applicable) Company

Mailing address ( number and s treet ) City, State, ZIP Code Telephone Area Code Number
c . If you are submitting this notice as part of a joint submission, mark (X) this box . Joint Submitter (if Name of authorized official Position applicable) Company

Mailing address (number and street ) City, State, ZIP Code Telephone Area Code Number 2 . Technical Name of authorized official Positio n Contact (i n U .S ) X

Compan y Mailing address (number and street ) City, State, ZIP Code Telephone Area Code Number 3 . If you have had a preno ti ce communica ti on (PC) concerning this no ti ce and EPA assigned a PC Number to the notice, enter the num be r . Mark (X) ---------~ ® if non e 4 . If you previously submi tted an exemp ti on applica ti on for the chemica l substance covered by this notice, enter the exemp ti on number assigned by Mark (X) ~ ♦ ® EPA . If you previously submitted a PMN for this substance enter the if non e PMN number assigned by EPA ( i .e . withdrawn or incomplete) . --- ♦ 5 . If you have submi tted a notice of Bona fide intent to manufacture or impo rt for the chemical substance covered by this no ti ce, enter the no ti ce number Mark (X) assigned by EPA . ~ if non e 1 . ® Manufacture 2 . Im port 6 . Type of Notice - Mark (X) Only Only 3 . ~ Both ® Binding Option ~ Binding Optio n M ark (X) M ark (X) EPA FORM 7710-25 (Rev . 5-95) Page 3

### p . 4 Part I - GENERAL INFORMATION
- Continue d Section B -- CHEMICAL IDENTITY IN FORMATION : You must p ro vide a curren tly correct Chemical Abs tracts ( CA) name of the subst ance based on the ninth Collec ti ve Index ( 9CI) of CA nomenclature rules and conventions . Mark ( X) th e "Con fi den ti al" box next to any item you claim as con fi dential Complete ei ther item 1 ( Class 1 or 2 substances) or 2(Polymers) as app ro pri ate . Complete all o ther items . If ano ther person will submit chemical identi ty information for you (for ei ther Item I or 2), mark ( X) th e box at the ri ght . Confi- Identify the name, company, and add re ss of th at person in a continuation sheet . ❑ dential I . Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances, see the Instructions Manual ) a . Class of substance - M ark (X) 1 [ :] Class 1 or 2® Class 2 b . Chemical name (Currently correct Chemical Abs tracts ( CA) Name that is consistent wi th TSCA Invento ry listings for simil ar substances . For Class 1 substances a CA Index Name must be provided . For Class 2 substances ei th er a CA Index Name or CA Preferred Name must be provided, which ever is app ro priate based on CA 9CI nomenclature rules and conventions) .

c . Please identify which me thod you used to develop or obtain th e speci fi ed chemical identi ty information re ported in this notice : ( check one) .

Me thod 1 (CAS Inventory Expe rt Service - a copy of the Identification Method 2( Other Source ) report obtained from the CAS Inventory Expe rt Se rv ices must be submitted as an attachment to th is notice ) d . Molecul ar formula and CAS Registry Number ( if a number already exists for the substance) 

### X CAS# X C . For a class 1 substance, provide a complete and correct chemical structu re diagram . For a class 2 substance - (1) List the immediat e pre cursor subst an ces wi th their re specti ve CAS Registry Numbers . (2) Desc ri be th e nature of th e re action or p ro cess . ( 3) Indicate th e X r an ge of composition and th e ty pical composi ti on ( whe re appro pri ate) . ( 4) Pro vide a correct re presentative or pa rtial chemical structu re diagram, as complete as can be known, if one can be reasonably asce rtained .

® Mark (X) th is box if you attach a continuation sheet .

~ EPA FORM 7710-25 ( Rev . 5-95) Page 4

### p . 5 Part I - GENERAL INFORMATION
-- Continue d Section B-- CHEMICAL IDENTITY INFORMATION - Con ti nue d 2 . Polymers ( For a definition of polymer, see the Instructions Manual .) Confidenti al a . Indicate the number-average weight of th e lowest molecular weight composi ti on of the polymer you intend to manufacture . Indicate maximum weight percent of low molecul ar weight species ( not including re sidual monomers, reactants, or solvents) be low 500 and below 1,000 absolute molecular weight of that composi ti on . Describe the me th ods of measurement or th e basis for your estimates : GPC E] Other E] : (Specify)

i) lowest num be r average molecular weight : ii) maximum weight % be low 500 molecul ar weight : ~~~0~X iii) maximum weight % below 1000 molecular weight : ~ M ark (X) th is box if you attach a continuation sheet . b . You must make sep ar ate con fi denti ality claims for monomer or o th er reactant identity, composi ti on information, and residual information . M ar k (X) th e "Confidential" box next to any item you claim as con fi dential (1) - Provide th e specific chemical name and CAS Regist ry Number ( if a number exists) of each monomer or o th er re actant used in the manufacture of

the polymer . ( 2) - M ark (X) this column if entry in column ( 1) is confidential . ( 3) - Indicate the typical weight percent of each monomer or o th er re actant in the polymer . (4) - Mark ( X) the identi ty column if you want a monomer or o ther reactant used at two weight percent or less to be listed as pa rt of the polymer

description on the TSCA Chemical Substance Invento ry . ( 5) - M ark ( X) th is column if en tries in columns ( 3) and ( 4) are confidential . (6) - Indicate the maximum weight percent of each monomer or o th er re act ant th at may be present as a residual in the polymer as manufactured for

commercial purposes . ( 7) - Mark ( X) th is column if entry in column ( 6) is confiden ti al . Monomer or o ther reactant and CAS Regist ry Numbe r Confi- Typical Identity Confi- Maximum Confidential composition Mark den ti al residual den ti al (1) (2) (3) (4) (5) (6) (7)
% % % % % % % % % % Mark (X) this box if you attach a continuation sheet . c . Please identify which me th od you used to develop or obtain the specified chemical identity information repo rt ed in th is notice ( check one) . F ] Method 1(CAS Inventory Expe rt Serv ice - a copy of the identification report ~ Method 2 (oth er source )

obtained fr om CAS Inventory Expe rt Service must be submitted as as attachment to this notice ) d . The currently correct Chemical Abs tracts (CA) name for th e polymer that is consistent with TSCA Inventory listings for simil ar polymers . e . Provide a correct representative or pa rtial chemical structu re diagram, as complete as can be known, if one can be reasonably as certained .

~ Mark (X) th is box if you attach a continutation sheet .

~

## p . 6 Part I -- GENERAL INFORMATION
- - Continue d Secti on B - CHEMICAL IDENTITY INFORMATION - Con ti nued 3 . Impuritie s (a) - Identify each impuri ty that may be re asonably anticipated to be p re sent in th e chemical subst an ce as m anufactured for commercial purpose . Provide the

CAS Registry Number if available . If th ere are unidenti fi ed impu rities, enter "unidentified . " (b) - Estimate the maximum weight % of each impuri ty . If th ere are unidentified impurities, estimate their total weight % . Impuri ty an d CAS Registry Number Maximum Confipercent percent dentia l (b) % X ~A11~ %

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

# X

n Mark (X) th is box if you attach a continuation sheet . 6 . Gene ri c chemical name - If you claim chemical identify as confidential, you must provide a generic name for your subst ance th at reveals the specific chemical identi ty of the new chemical subst ance to th e maximum extent possible . Refer to the TSCA Chemical Subst an ce Inventory , 1985 Edition, Appendix B for guid an ce on developing generic names . Mercaptoalkyl alcoho l

Mark (X) th is box if you attach a continuation sheet . 7 . Byproducts - Describe any byproducts resulting from th e m anufacture, processing, use, or disposal of the new chemical substance . Provide the CAS Registry

Number if available . Byproduct CAS Registry Number Confi- ( 1) (2) dentia l 

## X X X X ~ Mark (X) th is box if you attach a continuation sheet .

~ EPA FORM 7710-25 ( Rev . 5-95) Page 6

### p . 7 Part I -- GENERAL INFORMATION - Continue d Section C -- PRODUCTION, IMPORT, AND USE INFORMATION :

Mark (X) th e "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 ye ars 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 th e volume and mark (x) in the binding box . If gr anted, you ar e bound to this volum e Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confi- Binding (100% new chemical substance basis) (100% new chemical substance basis) dential Option Mark (x ) 

# SANITI7, D COPY x x 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 if entry column (1) is confidential business information (CBI) . (3) -- Indicate your willingness to have the information provided in column (1) 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)
. Catego 

### ry of use (1) CBI Binding Produc- CBI 

### % in CBI % 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- Bindin g for fi nishing polyester fibers) (2) (4) (5) (6) (7) limited sumer trial mercial Option (9 ) 

# x x x X X % % % % % % % % % % % % % % 

### I- 

# L : : :~ _F_1 * If you have identified a"consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer p ro ducts . 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 . E] M ark (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 Destructive us e

~ Mark (X) th is box if you attach a continuation sheet . 3 . Hazard Informa ti on - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other B inding 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 . M"`k (" ) Mark (X) this box if you attach hazard information . X

► - v EPA FORM 7710-25 (Rev . 5-95) Page 7

## p . 8 Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEAS E Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you claim as confidential 

### 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 industri al processing or use operations after impo rt . You must describe th ese operations . See instructions manua l 1 . Operation description Confia . Identi ty -- Enter th e identi ty of the site at which th e operation will occur . dential

Name X Site address (number and street) 

# 1 V ~~~ City, County, State, ZIP cod e 

### 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 . 1 :1 Mark (X) th is box if you attach a continuation sheet . b . Type -- 

### Mark (X) Manufacturing E] Processing [ :] Use c . Amount and Duration -- Complete 1 or 2 as appropriat e Maximum kg/batch (ioov . new chemical Hours/batch Batches/yea r substance) X 1 . Batch Maximum kg/batch (100x new chemical Hours/batch Batches/year substance ) 2 . Continuou s d . Process description ® Mark (X) to indicate your willingness to have your process description binding . X (1) 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 kg/batch 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 . 

## Please see continuation sheet s

® Mark (X) th is box if you attach a continuation sheet . 

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

### P . 9

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continue d 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 . (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 any protective equipment and engineering controls used to protect workers . (4) and (6) -- Indicate your willingness to have the information provided 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 (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 activity for any worker in hours per day and days per year . (12) -- Mark (X) th is column if entries in columns (10) and (11) are confidential business information (CBI) . Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI m (i .e ., bag dumping, filling drums) Engineering Controls Option and % new option Worker Hrs/day Days/y r Mark (x) substance Mark (x) S (1) ( 2) (3) (4) ( 5) (6) (7 ) Expose ( 9) (10) (11) ( 12) d (8) 

### Equipment Cleaning See Cont . Sheets X LiqNapor X 8 X Drumming See Cont . Sheets X LiqNapor X 2 X Quality Control & Sampling See Cont . Sheets X LiqNapor X 2 X Manifold Hose Couplings 2 ® 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 II, section A, subsection ld(3) . (2) --Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) -- Mark (X) this column if entries 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 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 (Publicly 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) CBI Number released releas e (1) (2a) (2b) e .gnscicav Binding 

### (3) (4) (5a) Muk M (Sb) (6) S1-S7 0 negligibl air 50 CC bottles, or closed sampling system X Negligibl e 

### e equipped with 2 CC vials . V1-V3 Negligible Not air Flare ; efficiency 99 .9999% X Essentially 0 know n V4 Negligible Not air Caustic Scrubber X Essentially 0

know n
(7) Mark (X) the ~ POTW provide name(s) below : CBI F] Navigable Other -Specify provide NPDES # CBI destination(s) of waterway releases to water . Mark (X) th is box if you attach a continuation sheet . 

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

### p .10

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section B -- INDUSTRIAL SITES CONTROLLED BY OTHER S Complete section B for ty pical processing or use operations involving th e new chemical subst an ce at sites you do not cont ro l . Impo rters do not have to complete th is section for operations outside th e U .S . ; however, you must report any processing or use activities after impo rt . See th e Instructions M an ual . Complete a separate section B for each type of processing, or use operation involving the new chemical substance . If the same operation is performed at more than one site describe the ty pical opera ti on common to th ese sites . Identify additional sites on a con ti nuation sheet . 1 . Operation Desc ri ption - - To claim informati on in th is section as confidential, circle or bracket the specific informa ti on th at you claim as con fi dential . (1) -- Diagram the major unit operation steps and chemical conversions, including interim storage an d tran sport containers (specify - e .g . 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc) . On the diagram, identify by le tter an d briefly desc ri be each worker ac ti vi ty . ( 2) -- Provide the identi ty , th e approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), an d entry point of all feedstocks ( including react ants, solvents and catalysts, etc) and all products, recycle streams, and wastes . Include cle an ing chemicals (note frequency if not used daily or per batch) . ( 3) -- Identify by number th e points of release, including sm al l or intermi ttent releases, to the environment of the new chemical subst ance . ( 4) Please enter th e # of sites ( remember to identify th e locations of these sites on a continuation sheet) : 

### 1 # of site s 

## (X)* g~'~~ CO~~

* (x) Indicates Confidential Business Information (CBI) . Mark ( X) th is box if you attach a continuation sheet . 2 . Worker Exposure/Environmental Releas e ( 1) -- From the diagram above, provide the letter for each worker activi ty . Complete 2-8 for each worker activi ty described . ( 2) -- Estimate th e number of workers exposed for all sites combined . ( 4) -- Estimate th e typical duration of exposure per worker in (a) hours per day and (b) days per year . (6) -- Descri be physical form of exposu re and % new chemical substance ( if in mixture), and an y protective equipment and enginee ring contro ls, if an y, used to protect workers . ( 7) -- Estimate th e percent of th e new substance as formulated when packaged or used as a final product . ( 9) --From the p ro cess diagram above, enter th e number of each re lease point . Complete 9-13 for each release point identified . ( 10) -- Estimate th e amount of the new subst ance released ( a) directly to th e environment or (b) into cont ro l technology to the environment (in kg/day or kg/batch) . (12) --Describe media of release i .e . stack air, fugiti ve air ( optional-see Instructions M anual), surface water, on-site or off-site l and or incineration, POTW, or o ther (specify) and con trol technology, if any, th at will be used to limit th e release of th e new subst an ce to the environment . ( 14) -- Identify byp ro ducts which may result from the operati on . (3), (5), ( 8), (11), (13) an d (15) -- Mark ( X) this column if any of the proceeding entries a re confiden ti al business information (CBI) . Lett er # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI of Workers of Enginee ri ng Con tr ols/ Form- Number New & Con trol Act- Exposed Exposure Physical Form an d % ula ti on Substance Technology ivity new substance Release d (1) (2) (3) (4a) ( 4b) (5) (6) ( 7) (8) (9) (10a) (1ob) (11) ( 12) (13)

14) -- Byp ro ducts : (15) E] Mark ( X) th is box if you attach a continuation sheet, -10 EPA FORM 7710-25 ( Rev . 5-95) Page 10

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# OPTIONAL POLLUTION PREVENTION INFORMATIO N To claim information in this section as confidential circle or bracket th e 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 (1) 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 rele as e ; (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 . 

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### this box if you attach a continuation sheet . EPA FORM 7710-25 (Rev . 5-95) Page 11

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# Part III -- LIST OF ATTACHMENT S Attach continuation sheets for sections of the form and 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 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 Attachment Confipage number(s) dential 14-19 X Material Safety Data Sheet (MSDS ) 

### CAS IES Report 20 X Continuation Sheets 21-24 X Figure 1 - Production Process 25 X GC Mass spectrum 26-31 X

Mark (X) this box if you attach a continuation sheet . Enter the attachment name and number . 1TA Aw EPA FORM 7710-25 (Rev . 5-95) Page 12

### p .13 PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T 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 Measured o consM if number Estimate denfial (a) provided (b) ( c ) Mark(X ) (M or E) ( d) 

### Physical state of neat substance (s) (1) _(g) X Vapor pressur e @ Temperature °C Torr Densi ty/relative densi ty Specific Gravity M X mu m Solubilit y @ Temperature ° C Solvent g/I, Solubili ty in water @ Temperature °C E X Melting temperature ° C Boiling /@ 44 mm Hg (@50 mm Hg) M X Spectra GC/Mass Spec X 11-16 M X Dissociation constan t Particle size distributio n Octanol / water pa rt ition coefficient Hen ry 's Law constant Volitalization from water Volitalization from soi l pH@ concentratio n Flammabili ty Flash Point (PMCC - ASTM D93) M X Explodability Adsorption / coefficient Other - Specif

y Evapouration Rate (Ethyl ether = 1) M X Percent Volatile by Volume M X

ATTACHMEN T 

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## TS-XXXXXXXX - Page 1 - Health Effects Data 

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Page 1- Physical and Chemical Properties Dat a Please see MSDS for numerical values on physical properties . We are submitting spectral data with this submission . [X]- Part I - Section B, 1(e) : Chemical Identity Information - Production Process Precursors are :

• [X] Indicates Confidential Business Information (CBI) 

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### p . 22 CONTINUATION SHEET S 

## TS-XXXXXXXX

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Vapor and Vapor Recovery : Distillation columns, product and by-product tanks are

[X] - Part I - Section C, 3 - Hazard Informatio n Please see MSDS Provided .

In summarv : Avoid all contact . XXXXXXXXXXXXXXXX have been found to cause XXXXXXXXXXXXXXXXXXXXXXXX For protection, chemical safety goggles or equivalent eye protection, impervious gloves, protective clothing, and respirator must be • [X] Indicates Confidential Business Information (CBI)

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### p . 23 CONTINUATION SHEET S 

## TS-XXXXXXXX when handling this material . Use of respirators is not required in areas where workplace XXXX XXXXXXXXXXXYXXX XXXXXXX . It is also assumed that anytime XXXXXXXXXXXXXXXXXXXX the airborne average concentration will exceed XXXXXXXXX . Therefore, Personal Protective Equipment listed below are used . Personal Protective Equipment : Any person who may have the potential to become exposed to the PMN substance shall wear : 

# SAI~I`~~~D C4t'Y Part II - Section A, 1(d) - Process Descriptio n Please see Part I, Section B,1(e), described above . Part II - Section A, 2- Occupational Exposur e Worker exposure is minimized by ventilation and personal protective equipment mentioned above (Part I - section C,3) . The PMN substance is packaged in polyethylene lined steel drums, and bungs are sealed with an epoxy compound after filling to prevent human exposure and environmental releases . Dermal exposure and exposure by inhalation during filling of drums is minimized by proper ventilation, wearing impervious gloves, clothing that covers exposed areas of the arms, legs and torso (Neoprene slicker suit and neoprene boots), and fresh air mask .

Sampling : Sample locations (Sl-S7) have been indicated in Figure 1 . Samples (50 CC) are collected through ports with small diameters in order to minimize possible air emissions during collection activities . Sampling is also performed using closed sampling system equipped with 2 CC sample vials . •[X] Indicates Confidential Business Information (CBI) Page 3 of 4

### p . 24 CONTINUATION SHEET S 

## TS-XXXXXXXX - Part II - Section A, 3- Environmental Release and Disposa l All rags and solid wastes associated with cleaning are sent to Class I industrial landfill . Container Cleaning : After completion of a run, an XXXXXXX is used to rinse out th e 

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S1-S7 : indicate locations where samples are taken for quality control analysis . Samples are collected either into 50 CC bottles through small sampling ports, or via closed sampling system equipped with 2 CC vials . Chemically impervious gloves and neoprene slicker suites and boots are routinely used . Vl-V3 : indicate location of possible vapor emissions from hose connections to distillation columns . Vapors are collected and sent to flare (efficiency : 99 .9999%) . V4 : indicates points of vapor emission from drumming operations . Vapors are collected and passed through XXXXXXXXXXXXXXXXXXXXXXY-X .

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