P.

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

Date of receipt • •

A PREMANUFACTURE

NOTICE

FOR NEW CHEMICAL SUBSTANCE S

DOCUMENT CONTROL OFFICER

OFFICE OF POLLUTION PREVENTION Company Sanitized

AND TOXIC SUBSTANCES, 7407

U .S . E.P .A. 401 M STREET, SW

WASHINGTON, D .JTLQK

Enter the total number o pages 31 ocument control number PA case number

in the Premanufacture Notice

C)

' ~

GENERAL INSTRUCTIONS TS

• 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 COPY

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

number. You must submit an original and two copies of this notice including all test data . P. Standard literature citations may be submitted for data in the one

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 chemical

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 ATTACHMENTS 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 these

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 described

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 your

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 Use

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

where certain information provided in such notification is binding on the submitter when ❑ 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 CONSOLIDATED 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 company named in Part I, section A, subsection 1 a of this notice form intends to manufacture or import for a

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

Section B .

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

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

reasonably ascertainable by me as required by §720 .50 of the Premanufacture Notification Rule .

Additional Certification Statements:

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

statement that applies:

® The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700 .45(b), or

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), or

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 ; and

~ 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 substance

descri bed he rein. Any knowing and willful misinterpreta tion is subject to c ri minal penalty pursuant to 18 USC 1001 . Confidential Signature and title of Authorized Official (Original SignatureRequired) Date

X

Signature of agent - (if applicable) Date

~

EPA FORM 7710-25 (Rev . 5-95) Page 2
p. 3

Part I -- GENERAL INFORMATION

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 Position

Submitting

Notice (in U .S) X

Company

Mailing address (number and street)

CP~~I

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 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 Position

Contact (i n

U .S) X

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

3 . If you have had a prenoti ce communication (PC) concerning this noti ce

and EPA assigned a PC Number to the notice, enter the num ber . Mark (X) ---------~ ®

if none

4 . If you previously submi tted an exemption application for the chemical

EPA

substance

. If you previously submitted a PMN

covered by this notice, enter the exemp

for this substance enter

ti on number assigned by Mark (X) ~♦ ®

PMN number assigned the if none by EPA (i .e . withdrawn or incomplete). ---♦

5 . If you have submitted a notice ofBona fide intent to manufacture or import

for the chemical substance covered by this notice, enter the noticenumber Mark (X)

assigned by EPA

. ~ if none

1 . ® Manufacture 2. Impor . Type of Notice - Mark (X)

Only Only 3

t 6

. ~ Both

® Binding Option ~ Binding Option

Mark (X) Mark (X)

EPA FORM 7710-25 (Rev . 5-95) Page 3
p. 4

Part I - GENERAL INFORMATION - Continued

Section B -- CHEMICAL IDENTITY INFORMATION: You must pro vide a currently correct Chemical Abstracts (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 "Confiden ti al" box next to any item you claim as con fidential

Complete either item 1 (Class 1 or 2 substances) or 2(Polymers) as app ropriate . Complete all other items.

If another person will submit chemical identi ty information for you (for either Item I or 2), mark ( X) the box at the ri ght. Confi- Identify the name, company, and addre ss ofth 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 - Mark (X) 1 [:] Class 1 or 2® Class 2

b . Chemical name (Currently correct Chemical Abs tracts (CA) Name that is consistent with TSCA Invento ry listings for simil ar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances eith er a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

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

Method 1 (CAS Inventory Expert Service - a copy ofthe Identification Method 2(Other Source)

report obtained from the CAS Inventory Expert 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 structure diagram . For a class 2 substance - (1) List the immediate

p

ran

recursor subst

ge of composition and

an ces with th

the

eir

ty

re

pical composi

spective CAS Regist

tion (whe

ry

re

Numbers

appropri

. (2) Desc

ate). (4) P

ri

ro

be

vide a

th e nature of

correct re

th

presentative or pa

e reaction or p ro

rt

cess. (3) Indicate the X

ial chemical structure

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.

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

Part I - GENERAL INFORMATION -- Continued

Section B-- CHEMICAL IDENTITY INFORMATION - Con tinued

2 . Polymers (For a definition of polymer, see the Instructions Manual .) Confidenti al

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

Indicate maximum weight percent of low molecul ar weight species (not including residual monomers, reactants, or solvents) below 500 and below 1,000 absolute molecular weight of that compositi on .

Describe the me thods ofmeasurement or th e basis for your estimates : GPC E] Other E]: (Specify)

i) lowest number average molecular weight:

ii) maximum weight % be low 500 molecul ar weight: ~~~0~X

iii) maximum weight % below 1000 molecular weight:

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

b . You must make separ ate con fidentiality claims for monomer or oth er reactant identity, composi tion information, and residual information . Mark (X) th e

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

(1) - Provide th e specific chemical name and CAS Regist ry Number (if a number exists) of each monomer or o ther re actant used in the manufacture of the polymer.

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

(3) - Indicate the typical weight percent of each monomer or o th er re actant in the polymer.

(4) - Mark (X) the identity column if you want a monomer or o ther reactant used at two weight percent or less to be listed as part of the polymer description on the TSCA Chemical Substance Inventory .

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

(6) - Indicate the maximum weight percent of each monomer or o th er react 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 tial . Monomer or o ther reactant and CAS Registry Numbe r Confi- Typical Identity Confi- Maximum Confidential composition Mark den tial residual denti 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 rted in th is notice (check one).

F ] Method 1(CAS Inventory Expert 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 Abstracts (CA) name for th e 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 as certained.

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

~
p. 6

Part I -- GENERAL INFORMATION -- Continued

Secti on B - CHEMICAL IDENTITY INFORMATION - Con tinued

3 . Impuritie s

(a) - Identify each impuri ty that may be re asonably anticipated to be pre sent in th e chemical substan ce as m anufactured for commercial purpose . Provide the CAS Registry Number if available . Ifth ere are unidentified impu rities, enter "unidentified. "

(b) - Estimate the maximum weight % of each impuri ty. Ifth ere are unidentified impurities, estimate their total weight %.

Impurity an d CAS RegistryNumber Maximum Confipercen percent dentia t 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 ric 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 identity ofthe new chemical substance to th e maximum extent possible. Refer to the

TSCA Chemical Substan ce Inventory, 1985 Edition, Appendix B for guidan 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 the manufacture, processing, use, or disposal of the new chemical substance . Provide the CAS Registry Number if available .

Byproduct CAS Registry Number Confi-

(1) (2) dential

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 - Continued

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

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

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

production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than

10,000 kg/yr, specify th e volume and mark (x) in the binding box . If granted, you ar e bound to this volume

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)

. Category 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- Binding for finishing 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]Mark (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 use

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

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

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

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

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 manual

1 . Operation description Confia. Identity -- Enter

Name X

th e identi ty of the site at which the operation will occur. dential

Site address (number and street) 1

V

~~~

City, County, State, ZIP code

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

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

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

sites as attachments.

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 appropriate

Maximum kg/batch (ioov. new chemical Hours/batch Batches/year

substance)

X

1 . Batch

Maximum kg/batch (100x new chemical Hours/batch Batches/year

substance)

2 . Continuous

d. Process description ® 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

. X

.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 sheets

® 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 -- Continued

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

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

(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 release

(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 Negligible

e equipped with 2 CC vials .

V1-V3 Negligible Not air Flare; efficiency 99 .9999% X Essentially 0

known

V4 Negligible Not air Caustic Scrubber X Essentially 0

known

(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 OTHERS

Complete section B for typical processing or use operations involving th e new chemical substan ce at sites you do not contro 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 Man ual . 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 one site describe the

typical operati on common to these sites. Identify additional sites on a conti nuation sheet.

1 . Operation Desc ription - - To claim information in th is section as confidential, circle or bracket the specific information th at you claim as confi dential .

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

drums, rail cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker acti vi ty . (2) -- Provide the identity, the 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 clean 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 the # of sites ( remember to identify th e locations of

these sites on a continuation sheet) :

1

# of sites

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

* (x) Indicates Confidential Business Information (CBI) .

Mark (X) th is box if you 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 activi ty described.

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

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

(6) -- Describe physical form of exposure and % new chemical substance (if in mixture), and an y protective equipment and enginee ring controls, 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 rocess diagram above, enter th e number of each release point. Complete 9-13 for each release point identified .

( 10) -- Estimate the amount ofthe new subst ance released (a) directly to th e environment or (b) into contro l technology to the environment (in kg/day or kg/batch).

(12) --Describe media of release i .e . stack air, fugitive air (optional-see Instructions M anual), surface water, on-site or off-site l and or incineration, POTW, or o ther

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

( 14) -- Identify byp roducts which may result from the operation .

(3), (5), ( 8), (11), (13) and (15) -- Mark (X) this column if any ofthe proceeding entries a re confiden tial business information (CBI) .

Letter # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI

of Workers of Engineering Contr ols/ Form- Number New & Control

Act- Exposed Exposure Physical Form and % ulation Substance Technology

ivity new substance Released

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (1ob) (11) (12) (13)

14) -- Byproducts: (15)

E] Mark (X) th is box if you attach a continuation sheet,

-10

EPA FORM 7710-25 (Rev. 5-95) Page 10
p.11

OPTIONAL POLLUTION PREVENTION INFORMATION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

alternatives may be provided .

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

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

examples.

Describe the expected net benefits, such as (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 ase ; (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 .

S~~~~~

lv

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

EPA FORM 7710-25 (Rev. 5-95) Page 11
p.12

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

CAS IES Report 20 X

Safety Data Sheet (MSDS)

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 WORKSHEET

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

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

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

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

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

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

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

is not a substitute for submission of test data.

Property Mark Page Value 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

@ Temperature °C Torr

e

Density/relative density Specific Gravity M

mu

X m

Solubility

@ Temperature °C

Solvent g/I,

Solubility 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 distribution

Octanol / water partition coefficient

Henry's Law constant

Volitalization from water

Volitalization from soi l

pH@ concentration

Flammability Flash Point (PMCC - ASTM D93) M X

Explodability

Adsorption / coefficient

Other - Specify

Evapouration Rate (Ethyl ether = 1) M X

PercentVolatile by Volume M X

ATTACHMENT

PAGE 13
p.14

SANITIZED COPY

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CONTINUATION SHEETS

TS-XXXXXXXX

- Page 1 - Health Effects Data

COrY

Page 1- Physical and Chemical Properties Data

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)

21

Page 1 of 4
p. 22

CONTINUATION SHEETS

TS-XXXXXXXX

COM

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

[X] - Part I - Section C, 3 - Hazard Information

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)

~. ~~ .

Page 2 of 4
p. 23

CONTINUATION SHEETS

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 Description

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 SHEETS

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

~~~ITItiE~ COX

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 .

• [X] Indicates Confidential Business Information (CBI)

Page 4 of 4
p. 25

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70
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