### U

.S. ENVIRONMENTAL PROTECTIONAGENCY 

# &FPA

in the Premanufacture Notice 

# PREMANUFACTURE NOTICE p. 1 FormApproved. O

.M .B. No. 2070-0012. Approval Expires 10-31-96. Date of receipt



# > AGENCY USE ONLY 

# Company Sanitizec

GENERAL INSTRUCTIONS TS 44 Ju IT S 8 S

. You must provide all information requested in this formto 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 fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or taxing 202-554-5603)

. Ifa user fee has been remitted for this notice (40 CFR700 .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, HQAccounting Operations Branch (PM-226), P.O . 360399M, Pittsburgh, PA 15251-6399, Arm . TSCA User fee

. Part I -GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even ifyou claimthe identity as confidential . You may authorize another person to submit chemical identity information foryou, but your submission will not be complete and the review will not begin until EPA receives this information. A letter in support ofyour submission should reference your TS user fee identification number . You must submit an original and two copies of this notice including a11 test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part li-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part ll, sections A and B of this notice, reproduce the sections as needed. Part I(I-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 111, list these attachments, any test data or other data and any optional information included in the notice. TEST DATAANDOTHERDATA Youare required to submit all test data in your possession or control and to provide a description ofall other data known to or reasonably ascertainable by you, ifthese 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 ifthey do not appear in the open literature. You should clearly identify whether test data is on the substance or on an analog. Also, the chemical composition of the tested material should be characterized. Following are examples oftest data and other data. Data should be submitted according to the requirements of §720.50ofthe Premanufacture Notification Rule (40CFR Part 720) .

Test Data (Check Belowany included in this notice) Environmental fate data 0 Yes " Other data ® Yes Health effects data ® Yes Risk assessments " Environmental effects data D Yes Structure/activity relationships, _ OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page I 1 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 formfor 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 NewUse Rules. Except in the case ofexemption 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 prohibit the submitter from laterdeviating fromthe information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claimas confidential . To assert a claimin an attachment, circle or bracket the information you claimas confidential . Ifyou claiminformation 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 (x) if any information in this notice is claimed as confidential .

1v17710-25 (Rev. 5-95) Physical/Chemical Properties* ® Yes Test data not in the possession or control of the submitter * A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One)

® 

# 0 PMN (Premanufacture Notice)

INTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (LowVolume Exemption) (N, 40 CFR723.50(c)(1) LOREX (LowRelease/LowExposure Exemption) (ail 40 CFR 723.50(c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? 

# 0 LOREX Modification Yes # ofchemicals (Prenotice Communication # required, enter# on page 3) Replaces previous editions of EPA Form7710-25. 

# ~i~i73

### p. 2

Public reporting burden for this collection of information is estimated to average 1 10hours 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 ofinformation, 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 ; andto theOffice ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D .C. 20503 . 

## CERTIFICATION I certify that to the best of my knowledge and belief: 1 . The company named in Part 1, section A, subsection 1 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 1, Section B

. 2. All information provided in this notice is complete and truthful as ofthe date of submission. 3 . I am submitting with this notice all test data in my possession or control and a description ofall 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 Ahas remitted the fee of $2500 specified in 40 CFR700 .45(b), or ® TheCompany named in Part I, Section Ahas remitted the fee of $1000for an Intermediate PMN(defined @ 40 CFR 700 .43) in accordance with 40 CFR 700 .45(b), or 0 The Company named in Part I Section Ais a small business concern under 40 CFR 700 .43 and has remitted a fee of $100 in accordance with 40 CFR700 .45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR723.50(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 CFR723.50 . 0Themanufacturer is familiar with the terms of this section and will comply with those terms ; and F~ The new

chemical substance forwhichthe notice is submitted meets all applicable exemptionconditions. 0 Ifthis application is for an LVE in accordance with 40 CFR723.50(c)(1), the manufacturer intends to commence manufacture of the exempted substance for commercial purposes within 1 year ofthe 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 substance described herein. An knowing and willful misinter pretation is sub'ect to criminal penalty pursuant to 18 USC 1001 . Confidential Signature and title ofAuthorized Official (Original Signature Required) Date 

### X Signature ofagent -(if applicable) Date

EPA FORM

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

### p. 3 Part I -- GENERAL INFORMATION Section A -- SUBMITTER IDENTI FICATION Ia. Person Name of authorized official Position Submitting Notice (in U

.S.) Company Mailing address (number and street) City, State, ZIP Code b . Agent (if Name of authorized official Position applicable) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number

c. If youare submitting this notice as part of ajoint submission, mark (X) this box. - Joint Submitter (if Name ofauthorized official Position applicable) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number 2. Technical Name ofauthorized official Position Contact (in X U.5.) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number 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) 10 X if none 4. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by Mark (X) 10 EPA. Ifyou previously submitted a PMNfor this substance enter the if none PMN number assigned by EPA (i .e. withdrawn or incomplete) . 10 5. Ifyou have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number i Mark (X) 10 ass gned by EPA

. ---No . if none I . ~ Manufacture 2. F-1 Import 6 . Type of Notice - Mark (X) Only Only 3. ® Both Binding Option El Binding Option Mark (X) Mark (X) Mark () the "Confidential" box next to an subsection you claim as confidential Confidential

EPA FORM

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

### p. 4 Part I -- GENERAL INFORMATION-- Continued Section B- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth Collective Index (9C1) of CA nomenclature rules and conventions. Mark (X) the "Confidential" box next to an itemyou claimas confidential Complete either item I (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. If another person will submit chemical identity information foryou (for either Item l or 2), mark (X) the box at the right . ConfiIdentify the name, com

pany, and address of that p erson in a continuation sheet . El dential 1 . Class 1 or 2 chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class ofsubstance - Mark (X) I Ej Class I or 2 [ :] Class 2 b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class I substances a CA Index Name must be provided. For Class 2substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9Cl 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 ofthe Identification El Method 2 (Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula and CAS Registry Number (ifa numberalready exists for the substance) 

### X CAS# 

### X e. For a class 1 substance, provide a complete and correct chemical structure diagram . For a class 2substance - (1) List the immediate precursorsubstances 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 comnlete as can he known. ifone can be reasonablv ascertained.



# See Pages 4A and 4B

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

EPA FORM

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

# Synthesis of PMN Substance

# Inventory Expert Service

A division of the American Chemical Society Phone : 800-631-1884,614-"7-3870

Fax: 614-447-3747 E-mail : answers@cas.org Web: www

.cas.org/products/client/

INVENTORY EXPERT SERVICE REPORT

r

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

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 PPIIA before submitting it to the EPA.

Page 413 n', " :51ilr~Ir ~r~ v, R 11 ,i " f . P( - R~, . 1 143 " 1 ,i,- hw ~ . , 4 1' W i ~i4 " 1 i, a

### p. 7 Part I -- GENERAL INFORMATION-- Continued Section B - CHEMICAL IDENTITY INFORMATION -- Continued 2. Polymers (For a definition of polymer, see the Instructions Manual .) Confidential a. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymer you intend to manufacture. Indicate maximum

weight percent of low

molecular weight species (not including residual monomers, reactants, or solvents) below 500and below1,000absolute molecular weight ofthat composition. Describe the methods of measurement orthe basis for your estimates: GPC EI Other 0 : (Specify) i) lowest number average molecular weight : ii) maximum

weight %

below 500 molecular weight : iii) maximum

weight %

below1000 molecular weight : Mark (X) this box ifyouattach a continuation sheet. b. 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 itemyou claim as confidential (1) - Provide the specific chemical name and CAS Registry Number (if a number exists) ofeach monomer or other reactant used in the manufacture of

the polymer. (2) - Mark (X) this column ifentry 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 ifyouwant a monomer orother reactant used at twoweight percent or less to be listed as part ofthe polymer

description on the TSCA Chemical Substance Inventory. (5) - Mark (X) this column ifentries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent ofeach monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. (7) - Mark (X) this column if ent ry in column (6) is confidential . Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential (1) (2) (3) (4) (5) (6) (7

% % % % Mark (X) this box ifyou attach a continuation sheet. c. Please identify which method you used to develop orobtain the specified chemical identity information reported in this notice (check one) .

Method 1 (CAS Inventory Expert Service - a copy of the identification report ~ Method 2(other source) obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice) d. Thecurrently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers. e. 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 ifyou attach a continutation sheet. EPA FORM

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

### p. 8 

## Part I -- GENERAL INFORMATION -- Continued Section B - CHEMICAL IDENTITY 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

CAS Registry Number if available. Ifthere are unidentified impurities, enter "unidentified ." (b) - Estimate the maximum wei g ht % ofeach im

purit y. Ifthere are unidentified im purities, estimate their total wei ght % . . Provide the Impurity and CAS Registry Number

(a) Maximum percent (b) Confidential %

% 

### X

% 

### X

% %

%

% Mark (X) this box ifyou attach a continuation sheet. 4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2 . Confidential

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

### X

5. Trade identification - List trade names for the new chemical substance identified in subsection l or 2.

Mark (X) this box ifyouattach a continuation sheet. X

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 ofthe new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names . Mercaptosilane ester

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

. Provide the CAS Registry Number if available

. Byproduct

(1) CAS Registry Number (2) Confidential 

## X X X

I O Mark (X) this box ifyouattach a continuation sheet. EPA FORM

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

### p. 9 

## Part I -- GENERAL INFORMATION-- Continued Section C-- PRODUCTION, IMPORT, AND USE INFORMATION : Mark (X) the "Confidential" box next to any itemyou claimas 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 ofproduction. Estimates should be on 100% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10,000 k / , sp

ecif y the volume and mark (x) in the binding box. If anted, 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 Mark (x) 

### X 2. Use Information -- You must make separate confidentiality claims for the description ofthe category ofuse, the percent of production volume devoted to each category, the fonnulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claimas confidential . a. (1) -- Describe each intended category of use ofthe newchemical substance by function and application. . (2) -- Mark (X) this column ifentry 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 ifentry 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 ifentry 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 ent (ies) in column (8) is (are) confidential business information (CBI) . Category of use (1) CBI Binding option Produc- CBI % in CBI % ofsubstance expected per use CBI tion % Form- ($) (by function and application i .e. a dispersive dye M ~ ; (x) ulation Site- Con-* Indus- Coin- Binding forfinishing pol y

ester fbers) (2) ~ (4) (5) (6) (7) limited sumer trial mercial O 

## p tion (9) % % % % o~ o~

o~ o~ o~ o~

o~ o~ o/ % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) of this chemical substance in consumer products. In addition include estimates ofthe 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. ~ Mark (X) this box ifyou 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 ofgeneric use descriptions . 

### description Processing Additive Intermediate

Mark (X) this box ifyou attach a continuation sheet. 3 . Hazard Information - Include in the notice a copyof reasonable facsimile ofany 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 rprotective p equipment orpractices Option for the safe handing, transport, use, or disposal ofthe new substance. List in part Ill hazard information you include . Mark (x) ® Mark (X) this box ifyou attach hazard infonnation.

EPA FORM

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

### p. 10 

## Part II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claim as confidential Complete section A for each type ofmanufacture, processing, or use operation involving the newchemical 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 p ort . You must describe these op erations. See instructions manual 1 . Operation description Confia. Identity -- Enter the identit y of the site at which the operation will occur . dential

Name 

# X Site address (number and street) City, County, State, ZIP code Ifthe same operation will occur at more than one site, enter the number of sites. Identify the 

# X additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

Mark (X) this box ifyouattach a continuation sheet. b. Type -- Mark (X) DManufacturing E]Processing ~U se c . Amount and Duration -- Com plete 1 or 2 as appropriate Maximum

kg/batch 000%newchemical Hours/batch Batches/year 

# X substance) l . Batch Maximum kg/batch 000%new

chemical Hours/batch Batches/year 

# X substance) 2. Continuous d. Process description El Mark (X) to indicate your willingness to have your process description binding. (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%newchemical substance basis), and entry point of all starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch .) . (3) Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance

. 

# See Page 8A

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

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

## u

C



# Z Q b 

# A

u 0 a .^., u 45- 0 C p. 11



# Q a

### p. 12



## Part II-- HUMAN EXPOSURE ANDENVIRONMENTAL 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 ofworks exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou claimas 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) ofthe new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart ofa mixture) at the time of exposure. (7) --Mark (X) this column ifentry 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 ifentry in column (8) is confidential business information (CBI) . (10) and (It) --Estimate the maximum duration ofthe activity for anyworker in hours per day and days per year. (12) --Mark (X) this column ifentries 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 Optton and % new Option workers Hrs/day Days/yr Mark (x) substance Mark (x) Exposed (1) (2) (3) (4) (5) (6) (7) (8) (9) (l0) (Il) (IZ)



### X gloves, goggles, X X X nrot . clothina_ vent . 

### X gloves, goggles, X X X nrot . clothina. vPnt . 

### X gloves, goggles, X X X nrot . dothinn. vPnt . 

### X gloves, goggles, X X X nrot . dothinn vent . 

### X gloves, goggles, X X X nrnt . clothina. vent ~ 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 ofthe new chemical substance released and other release and disposal information . Mark (X) the "Confidential" box next to each itemyou claim as confidential . (1) -- Enter the number of each release point identified in the process description, part ll, section A, subsection ld(3) . (2) -- Estimate the amount ofthe 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

substancewill be released fromthat 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 describeany additional disposal methods that will be used and whether thewaste 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 ifentries 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 (Publicl OwnedTreatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CB1). Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) Number released release (1) (2a) (2b) Us "wk - (4) Binding Mk X (3) (Sa) ar ( ) (5b) (6) 

### 1 X X 2 X X 3 X X X

(7) Mark (X) the El POTW provide name(s) below : C131 F Navigable ~ Other - Specify provide NPDES # CBI destination(s) of X waterway X releases to water. I® Mark (X) this box if you attach a continuation sheet.

EPA FORM

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

# Waste Disposal Management and

Conversion / Recycle o4 IProcess Materials

Page 9f>

### p. 14



## Part II-- HUMANEXPOSURE 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 B

for each type of

processing, or use operation involving the new chemical substance. Ifthe same operation is performed at more than onesite describe the typical op

eration common to these sites. Identify additional sites on a continuation sheet . 1 . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagramthe major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5gallon 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 approximate weight (by kg/day 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, andwastes. Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points ofrelease, including small or intermittent 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) : # of sites



# See Page 10A

® Mark (X) this box ifyou attach a continuation sheet. 2. Worker Exposure/Environmental Release (1) -- From

the diagram

above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) -- Estimate the number ofworkers exposed for all sites combined. (4) -- Estimate thetypical duration ofexposure per worker in (a) hours per day and (b) days per year. (6) -- Describe physical formofexposure and % new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) -- Estimate the percent ofthe new substance as formulated when packaged or used as a final product. (9) -- Fromthe process diagram above, enter the number of each release point. Complete 9-13 foreach release point identified. (10) -- Estimate the amount ofthe 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 ofrelease 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, ifany, 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), ( I 3) and (15) -- Mark (X) this column ifan ofthe p roceeding entries are confidential business information (CBI) . Letter # of CBI Duration CBI Protective Equip. / % in CBI Release Amount of CBI Media of Release CBI ofActWorkers

Exposed of Exposure Engineering Controls/ Physical Formand % Formulation Number New Substance & Control Technology 'vity new substance Released (l) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (IOb) (ll) (12) (13) 

### A X X gloves, goggles, prot . X X X clothing, ventilation

14) -- Byproducts : ` (15) 0 Mark (X) this box if you attach a continuation sheet, EPA FORM

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

### p. 15

v A CC



# a

0 

# a

.

### p. 16



# 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 mayprovide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal ofthe PMNsubstance. 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 ofuseful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions ofpollution 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 ofrisks 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 PMNsubstance to potential alternatives maybe provided. All information provided in this section will be taken into consideration during the reviewof this substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and exam p les. 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 throughrecycling, 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 ofproduction 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 asubstitute for an existing substance that poses a greater overall risk to human health or the environment.

~ 0 Mark (X) this box if you attach a continuation sheet.

EPA FORM

7710-25 (Rev. 5-95) Page 11

### p. 17 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe 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 formto which it relates, if appropriate. Number consecutively the pages ofthe attachments. In the column below, enter the inclusive page numbers of each attachment . Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice forma sanitized version of any attachment in which you claiminformation as confidential . Attachment name I Attachment page number(s) 

### Material Safety Data Sheet (MSDS)

El Mark (X) this box ifyou attach a continuation sheet. Enter the attachment name and number. 

### A1--A8 Confidential 

### X X X X

EPA FORM

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

### p. 18 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 ofthe notice on which the property appears, thevalue 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 ofthe 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 reviewand 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 oftest data. Property (a) Mark (X) if provided Page number (b) Value (e) Measured o Estimate (M or E) confid-cial Mark (X) (d)



### , X A4 M X Physical state of neat substance (s) (1)- (g) X A4 Vapor pressure @ Temperature 20 °C Not available Torr X A4 X Density/relative density g/cm3 X Solubility @ Temperature °C Solvent g/L X A4 X Solubility in water Temperature °C g/L Melting temperature Not available °C Boiling / sublimation temperature torr pressure Not available °C X X Spectra Dissociation constant Particle size distribution Octanol/ water partition coefficient Henry's Law

constant X Volitalization fromwater X Volitalization fromsoil X pH@ concentration X A2 X Flammability Explodability Adsorption / coefficient Other - Specify

EPA FORM

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### p. 19 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 1 of 8 

# 1 . PRODUCT AND COMPANY IDENTIFICATION Product name: Chemical name: Supplier : Contact numbers : I



# 2. COMPOSITION/ INFORMATION ON INGREDIENTS MMMOMA COMPONENT CAS# CONCENTRATION



### Note(s) : SeeSection or chemicals appearing on Federal or State Right-To-Know lists. 

# 3. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW WARNING! CAUSES EYE. SKIN AND RESPIRATORY TRACT IRRITATION. 

# 4 . FIRST AID MEASURES Swallowing If patient is fully conscious, gi-,e two glasses of water. Obtain medical attention. Skin Remove contaminated clothing . Wash skin with soap and water. Obtain medical attention ifdiscomfort persists. Inhalation Remove to fresh air. Obtain medical attention. E%e contact Inim-liatelI . flush c~ e. \k ith ~~,Urr ,tnd cow inue \kashing, ti~r ,tt Ic.i .t I ~ ininutr . t tht,un tnMtK,al .ittentiun 

### Attachment Page AI

### p. 20 

# i

immediately

.



# 5. FIRE-FIGHTING MEASURES Flash point: 

# I MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 2 of 8

Flammable limits Lower limit: Not available Upper limit: Notavailable Special fire fighting procedures Due to the initial water-silane reaction, use remote spray monitors or fight fire frombehind barriers. Special protective equipment for firefighters Self-contained breathing apparatus . Body covering protective clothing. Extinguishing media Suitable: Large fires:

- alcohol-type foamor universal-type foams Small fires : - C02 - drychemical Unsuitable: None. Unusual fire and explosion hazards None known. 

# 6 . ACCIDENTAL RELEASE MEASURES Personal precautions Avoid contact with eyes and skin. Avoid contact with liquid and vapors. Wear suitable protecti~e equipment. Environmental precautions Prevent runoff

. Methods for cleaning up ('o%cr with absorbent or contain. Collect ti)r kli .po.31 . t )h~rr~ ~~~ ~ticrnment rr~ ;ul<rn~~n. 

### Attachment Page A?

### p. 21 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 3 of 8 

# 7. HANDLING AND STORAGE HANDLING Handling precautions Do not swallow

. Do not get in eyes, on skin, on clothing. Avoid breathing vapor, aerosol and mist. Use with adequate ventilation. Wash thoroughly after handling. 

### STORAGE Storage requirements Keep away fromheat and flame. Keep container closed. 

# 8 . EXPOSURE CONTROLS / PERSONAL PROTECTION PERSONAL PROTECTION Respiratory protection Self-contained breathing apparatus in high vapor concentrations. Hand protection / protective gloves Recommended order of use: 4H Butyl Neoprene Nitrile (NBR) PVC-coated Eye protection Safety glasses. Skin protection Chemical protective clothing. Other protective equipment Eye bath Safety shower 

### ENGINEERING CONTROLS Ventilation General mechanical roomventilation is satisfactory for normal handling and storage operations. Special . local ventilation is needed at points where %apors can be expected to escape to the workplace air. 

## EXPOSURE LIMITS Comaonent TVae Value Remark

Attac}iment Page A3

### p. 22 

# [ MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 4 of 8 

# 9 . PHYSIC

AL AND CHEMICAL PROPERTIES APPEARANCE Physical state Color Odor 

### OTHER PROPERTIES Boiling point Melting point pH Specific gravity (H20=1) Vapor pressure Vapor density (air--1) Solubility in water Evaporation rate (Butyl Acetate=1) Flash point Upper explosion limits Lower explosion limits Percent volatiles Molecular weight 

# 10. STABILITY AND REACTIVITY Stability: Stable. Stability - Conditions to avoid None known

. Incompatible materials Acids. Base, . Strong oxidi zing agents. Attnchment Pa9P A

### p. 23 L 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 5 of 8 

# I Hazardous combustion products Burning can produce the following combustion products: r'des ofcarb Oxides of silicon. Carbon monoxide is highly toxic if inhaled; carbon dioxide in sufficient concentrations can act as an asphyxiant. Acute overexposure to the products ofcombustion may result in irritation of the respiratory tract. Hazardous polymerization: Will not occur. Hazardous polymerization - Conditions to avoid None known. 

# 11 . TOXICOLOGICAL INFORMATION SWALLOWING Maycause the following effects: 

# 1

- dizziness, faintness, drowsiness, decreased awareness and responsiveness, euphoria, abdominal discomfort, nausea, vomiting, staggering gait, lack of coordination and coma Effects of repeated overexposure Long-termrepeated oral exposumay result in thedevelopment 

### SKINABSORPTION Acute effects No evidence of harmful effects from available information. 

### INHALATION Acute effects Maycause irritation. 

### SKIN CONTACT Acute effects May cause irritation. 

### EVE CONTACT Acute effects May cause irritation. ofprogressive liver injury with fibrosis.



## Medical conditions aggravated by overexposure Repeated exposur F---Jmay aggravate liver injury produced from other causes. 

## Other effects o overexposure Repeated ingestion ~ as been shown to adversel y affect the cc r I nen ous svstemof the fetus. producing a collecticm~~f cfferts hir i tc~gether c~~nstitute Fhe.e include mcntal and ph ical retardati n . iiaurh nces f m t r langu;»e etici ncie . hcha~ ioral nd

%s and

o d a () learning. o t) e s disorder, ; . a Smell .IiC hrad . Attachmpnt Prnge A5

### p. 24 

# [ MATERIAL SAFETY DATA SHEET Revision : 1 .0 01/28/2005 Page: 6 of 8 

## SIGNIFICANT DATAWITH POSSIBLE RELE VANCE TO HUMAN HEALTH r-- 

## - --- .



# 12. ECOLOGICAL INFORMATION All available ecological data have been taken into account for the development ofthe hazard and precautionary information contained in this Safety Data Sheet . 

# 13. DISPOSAL CONSIDERATIONS General : Incinerate in a furnace where permitted under appropriate Federal, State, and local regulations. 

# 14. TRANSPORT INFORMATION DOT Classification This product is not regulated by DOT. Freight description road: CHEMICALS, NOIBN 

## IMDGClassification This product is not regulated by IMDG . 

## ICAOClassification This product is not regulated by ICAO . 

# 15. REGULATORY INFORMATION Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) requires notification of the National Response Center of release of quantities of hazardous substances equal to or greater than the reportable quantities (RQ's) in -tOCFR302.4. Components present in this product at a level ~khich could require reporting under the statute are: **** NONE   Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III requires emergency planning based on Threshold Planning Quantities (TPQ's) and release reporting based on Reportable Quantities (RQ's) in 40CFR355 (used for SARA 302 and 304) . Components present in this product at a level which could require reporting under the statute are: ** ** NONE   Superfund Amendments and Reauthorization Act of 1986 (SAR:1) Title I11 requires submission of annual reports of release of toxic chemicals that appear in 1t1CFR372 (for ti %RA 313) . This information must he included in NiSUS's that are copied and di%tributed for this material . Attachment Page Ah

### p. 25 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 01/28/2005 Page: 7 of 8 Components present in this product at a level which could require reporting under the statute are: ** ** NONE   Massachusetts Right-To-Know Substance List (MSL)--Hazardous Substances and Extraordinarily Hazardous Substances on the MSL must be identified when present in products. Components present in this product at a level which could require reporting under the statute are: ** ** NONE   Pennsylvania Right-To-KnowHazardous Substance List--Hazardous Substances and Special Hazardous Substances on the list must be identified when present in products. Components present in this product at a level whichcould require reporting under the statute are: ** ** NONE   New Jersey Worker and Community Right-To-Know Act (Labeling Requirements) Chemical name CAS# New Jersey TS Number EPA Hazard Categories (SARA 311, 312) : Immediate Health Hazard California Proposition 65 This product contains no levels of listed substances, which the State of California has found to cause cancer, birth defects or other reproductive harm, which would require a warning under the statute. California SCAQMD Rule 443 .1 VOC's Volatile Organic Components (VOC's) = Substances with vapor pressure of => 0 .5 mmI-Ig at 104'C (219.2'F) . ** **NOT DETERMINED**** 

## CHEMICAL INVENTORY United States: This is a new chemical substance that is notcurrently on the TSCA Inventory . Under TSCA regulations, 40 CFRSection 720 .36, experimental products such as these can only be used for research and development purposes either directly by, or under the supervision of a technically qualified person. The law furtherstipulates that an evaluator may test and evaluate samples such as these but, with few exceptions, the sample or products derived fromit may not be used for commercial purposes until the new substance is added to the TSCA Inventory via Premanufacture Notification. 

# 16 . OTHER INFORMATION RECOMMENDED USES AND RESTRicrIONS Please consult the product and or application information bulletins for this product . HivIIS RATING Health: I Flammabilitv: 1 Reactivity I PPIX 

### LEGEND

STP Standard tem p erature and pressure ' 'Kei ght kk'ei ltt - u (H0, 11 's) !llinimal hai,ird Attachment Page A7

### p. 26



# , MATERIAL SAFETY DATA SHEET Revision: 1 .0 01128/2005 Page: 8 of 8 1 (HMIS) Slight hazard 2 (HMIS) Moderate hazard 3 (HMIS) Serious hazard 4 (HMIS) Severe hazard ~ X (HMIS) Personal protection rating to be supplied by user depending on use conditions 

### The opinions expressed herein are those of qualified experts withi We believe that the information contained herein is current as of the date of this Safety Data Sheet. Since the s_e of this information and of these opinions and the conditions of use of this product are not within the control of~ ~ it is the user's obligation to determine the conditions of safe useofthe products.

Attachment Pape AR

## HEALTHEFFECTSTATEMENT



# 0 The Intermediate PMN substance, has not been tested. However toxicology studies have been conducted with an

is of a very loworder of toxicity by swallowing or skin contact. is mildly irritating to the skin and is a minor eye irritant capable of producing corneal injury. ,~was not mutagenic in an Ames bacterial mutagenicity assay. Similar findings are anticipated fo4 Acute Oral Toxicit When undiluted was administered by oral gavage to rats, the acute oral LDS0 was determined to be > 2000mg/kg, indicating very low toxicity in the rat by this route. Acute Dermal Toxicity In order to determine the potential for systemic toxicity by absorption across the skin,

# I (undiluted) was applied to the skin of rabbits and maintained in contact for 24 hours. The acute percutaneous LDS was determined to be > 2000 mg/kg, indicating a very low order of toxicity in the rabbit by this route. Effect on Skin When 0 .01 mL of was applied uncovered to rabbit belly marked-to-moderate redness %4as observed, indicatin is a mild skin irritant under the conditions ofthis study. 

# 1

ti i ;-Ili ~ i c, il) IN (IX (I H AttnchmPnt PnKP A9

## Effect on Eyes

When rabbit eyes were flooded with 0 .5 mL o~trace corneal injury was observed on l of 5 rabbit eyes, indicating=is a minor eye irritant capable of producing corneal injury. Genotoxicit was evaluated for potential mutagenic activity in the Salmonella/Escherichia coli mutagenicity assay (Ames test) in the presence and absence of metabolic activation. The material was concluded to be negative under the conditions of this test. F



# I

AttacYhment Pip_e Al(1

# Preliminary Risk Assessment of Intermediate PMNSubstance

Worker Exposure Assessment and End-Use

. The_syn_thesi sT------- will take place in closed, Operators will obtain samples o 1t the end of the reaction and strip, using a self-contained and vented sampling system . QC laboratory personnel will use exhaust hoods when preparing samples and will followanalytical methods that have been develoved to maximize safety and minimize exnosure. Prior to samnlin j trained and experienced in handlin 'hazardous materials, such as the v arious olefinic raw

materials~interme iates, an products. ~ .____---~~ - specific manufacturing department . The operating personnel are required to use personal protective equipment (PPE) and are trained to follow all safety recommendations as specified in the MSDSs and within the Operating Instructions. The PPE worn by workers will effectively eliminate the potential for dermal or inhalation exposure. The personnel protective equipment includes safety hard hat, steel-toed shoes, chemical resistant gloves, and goggles. Breathing devices are available in the operating areas for emergency use, as

_ well as su lied air respirators for special tasks. In addition, operations personnel wear -- at all times within the processing areas as emergency equipment. The workers are trained in emergency procedures in the event of an unexpected exposure, accidental release, spill or fire. 

## Once the fin'she t CL has met specifications h __7~or the final synthetic st to n at the end ----I----~1 - - __ - _aoduct. known The long-termplan. e same trainin PPE, an procedures described above are used downstreamfor the

Attarhment Page All

### p. 30 GC (1F TNTERMRDTATE PMN SUBSTANCE

Attachment P3p,P AI?W

H d H A W W U W E-H Ea In 

## z pq F-1 ",D W O P4 E-H W



### Attachment Page A13