PMN Page 1 ; Page 1 of 18 ,~'" 

p. 1 

Form Approved, O.M.B . No: 2070-0012 . Approval Expires 10-31-96 . 

U.S . ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt . 

0 6 . 

V I IIIIII IIIII III I 1111111111 III 111111111111 1 111111111111 1 111111111 1 111111 5 1 1 0 0 0 0 0 2 2 4 1 S ~...w 

, ~ C 

_ __ __ company Sanitized et 

U.S . E.P .A . 1200 Pennsylvania, NW 

WASHINGTON, D.C. 20460 ' 

nteT t}ie tot~T iiiztriber of pages 

44~8- .7 in the Premanufacture Notice 

ocument control nu ber PA case number 

(/ 2 

GENERAL INSTRUCTIONS 

IS _~ ~ ~ O 

1 I 1~j 

t 

P You must provide all information requested 

o 

" the extent that t is kn own 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 Pre manufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, o r 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, Washington Financial Management Center (3303) P.O. 360399M, Pittsburgh, PA 15251-6399, Attn . TSCA User fee. 

, 

Part I -GENERAL INFORMATION TEST DATA AND OTHER DATA 

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

chemical substance, even if you claim the identity as confidential . You may authorize You are required to submit all test data in your possession or control and to 

another person to submit chemical identity information for you, but your submission will provide a description of all other data known to or reasonably ascertainable by 

not be complete and the review will not begin until EPA receives this information . A letter you, if these data are related to the health and environmental effects on the 

in support of your submission should reference your TS user fee identification number. 

manufacture, processing, distribution in commerce, use, or disposal of lhe;new 

You must submit an original and two copies ofthis notice including all test data. Ifyou chemical substance. Standard literature citations may be submitted for?aafa in the 

claimed any information as confidential, a single sanitized copy must also be submitted . open scientific literature . Complete test data (written in English) not safffittaries 

of data, must be submitted if they do not appear in the open literature . Yoia should-- , 

clearly identify whether test data is on the substance or on an analog . AJsd~the 

Part fi-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE chemical composition of the tested material should be characterized . Following - 

are examples of test data and other data . Data should be submitted accof4ipg to If there are several manufacture, processing, or use operations to be described in Part 11, the requirements of §720 .50 of the Premanufacture Notification Rule (40 CPR sections A and B of this notice, reproduce the sections as needed . Part 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 each " Environmental fate data El Yes " Other data El Y st 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 . " Health effects data 

0 Yes Risk assessments O 

" Enviromnental effects data ~ Yes Structurc/actiyity relationships 

OPTIONAL INFORMATION " Physical/Chemical Properties* O Yes Test data not in the possession 

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

or control of the submitter El 

substance. On page I I of this form, space has been provided for you to describe * A physical and chemical properties worksheet is located on the last page of this form. pollution prevention and recycling information you may have regarding the new substance. 

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

TYPE OF NOTICE (Check Only One) 

willingness to be bound to certain statements you make in this section, such as use, ~ ?MN (Premanufacture Notice) production volume, protective equipment . . This option is intended to reduce delays that 

routinely accompany the development of consent orders or Significant New Use Rules. 

Except in the case of exemption applications (such as TMEA, LVE, LOREX) where El 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

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 ~ SNUN (Significant New Use Notice) by itself prohibit the submitter from later deviating from the information (except chemical 

identity) reported in the form. 

TMEA (Test Marketin g Ex emp ti on A pp li cat i on) 

CONFIDENTIALITY CLAIMS 

El 

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 

form, mark (X) the confidential box next to the information that you claim as confidential . ~ LOREX (Low Release/Low Exposure: Exemption) @ 40 CFR 723 .50(c)(2) 

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

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

a sanitized version of the notice. (including attachments). For additional instructions on 

~ LVE Modification ~ LOREX Modification 

claiming information as confidential, read the Instructions Manual . 

IS THIS A CONSOLIDATED PMN? a Yes 

Mark (x) if any information in this notice is claimed as confidential. # of chemicals or polymers 

Prenotice Communication # req uired, enter # on a e 3 

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

~ 

t=, °~ ~,/- Replaces previous editions of EPA Form 7710-25. 
p. 2 

PMN Page 2 ;Page 2 of 1$ 

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 Director, Collection Strategies Division (2822), U.S . Environmental Protection Agency, 1200 Pennsylvania Ave., N.W., 

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

CERTIFICATION -- A Printed copy of this signature page, with original signature, must be submitted 

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

1 . The company named in Part I, section A, subsection 1 a of this notice form intends to man Iufacture 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 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 CF(2 700 .45(b), or 

El The Company named in Part 1, 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 

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 : 

0 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 terrxls of 40 CFR 723.50. 

0 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 . 

0 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 chetnical substance 

described herein . An knowing and willful misinterpretation is subject to criminal penal ty pursuant to 18 USC 1001 . Confidential 

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

Signature of agent - (if applicable) Date 

EPA FORM 7710-25 (Rev . 5-95) Page 2 
PMN Page 3 ; Page 3 of 18 

Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTIFICATION Confila . Person Name of authorized official Position 

Submitting 

Notice (in U.S . ) F ) c 

Company 

Mailing address (number and street) 

City, State Postal Code 

b . Agent (if Name of authorized official Position " 

applicable) F7 

Company 

Mailing address {number and street) 

City, State Postal Code ( Telephone (include area code) 

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 

Province, Country Postal Code Telephone (include country or area code) 

2. 

---- Technical Name of authorized official 

Contact (in 

-------- Position 

U.S .) K 

Company 

Mailing address (number and street) 

City, State Postal Code Telephone (include area code) 

3. If you have had a prenofice communication (PC) concerning this notice and 

EPA assigned a PC Number to the notice, enter the number . Mark (X) "1 

if none 

4 . If you previously submitted an exemption application for the chemical 

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

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

Mark (X) - 

If none EKI number assigned by EPA (i .e. withdrawn or incomplete). --i 

5 . If you have submitted a notice of Bona fide intent to manufacture or import - ---- 

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

assigned by EPA ----~ 

Mark (X) --- 

. if none 

6. Type of Notice - Mark (X) 

-- Mark the "Confidential" box next to any subsection y ou claim as confidential 

Manufacture j 2 . 

Only i 

Binding Option 

Mark (X) I 

0 Import 

Only 

Binding Option 

Mark (X) 

i 

i 3 u Both 

I 

i 

I 

dential 

EPA FORM 7710-25 (Rev . 5-95) Page 3 
PMN Page 4 ; Page 4 of 18 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chernical Abstracts (CA) name of the substance based on the ninth 

Collective Index 9CI of CA nomenclature rules and conventions. Mark X the "Confidential" box next to an y item you claim as confidential 

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

If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right . ConfiIdenti the name, company, and address of that person in a continuation sheet. _ D dential 

I . Class I or 2 chemical substances (for definitions of class 1 and class 2 substances see the Instructions Manual) 

a . Class of substance - Mark (X) Class I or 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 2 substances either 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 specified chemical identity information reported in this notice : (check one) . 

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

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula CBI CAS Registry Number _ I 

(if a number alread y 

exists for the substance) 

e. For a class I substance, provide a complete and correct chemical structure diagram . For a class 2 substance, provide a correct representative or 

partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. Please see the E-PMN Instruction Manual for 

discussion of "native format" diagram software which can be helpful in reviewing your substance . 

Re d acte d 

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

EPA FORM 7710-25 (Rev . 5-95) Page 4 
PMN Page 4a ; Page 5 of 18 

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process . 

(3) Indicate the range of composition and the typical composition (where appropriate), 

e. (I ) List the immediate precursor substances with their respective CAS Registry Numbers. Confi- 

~vame (CAS #). 

dential 

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

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

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

EPA FORM 7710-25 (Rev. 5-95) Page 4a 
PMN Page 5 ; Page 6 of 18 

Part I -- GENERAL INFORMATION -- Continued 

Seetion B -- CHEMICAL IDENTITY INFORMATION -- Continued 

2 . Polymers (For a definition of polymer, see the Instructions Manual .) Confia. Indicate the number-average weight of the lowest molecular weight composition of the polymer you in 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, 

tend to manufacture. 

reactants, or solvents) below 500 and 

dential 

below 1,000 absolute molecular wei g ht of that comp osition . 

Describe the methods of measurement or the basis for your estimates : GPC LJ Other 

(i) lowest number average molecular weight : 

U (Specify below) 

"- 

(ii) maximum weight % below 500 molecular weight : 

(iii) maximum weight % below 1000 molecular weight : 

Mark (X) this box if you attach 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 item you claim as confidential 

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each 

the polymer. 

monomer or other reactant used in the man ufacture of 

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

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

(4) - Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of 

description on the TSCA Chemical Substance Inventory. 

the polymer 

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

(6) - Indicate the maximum weight percent of each monomer or other reactant that may be presen t as a residual in the polymer as manufactu red for 

commercial purposes . 

7 - Mark X this column if entry in column 6 is confidential . 

Monomer or other reactant and CAS Registry Number Confidential Typical 

composition 

Include in 

identity 

Confidential 

Maximum 

residual 

Confidential 

1 2 3 

% 

4 

; 

5 6 

.% .- 

7 

.___ . a % 

. ._, . 

_~-_-,- -. o _ a % 0 

11 

°,° 

D 

°,° 

I*] 

---- o °,° 

, 

°,° - x 0 % 0 °,° E~. % 

~ 

% 

.-_ 

% 

- 

; % 

% 

~ ~ 

% 

% 

% ~ % 

-------- 

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

EPA FORM 7710-25 (Rev . 5-95) Page 5 
PMN Page 5a ; Page 7 of 18 

c. Please identify which method you used to develop or obtain 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 from CAS Inventory Expert Service must be submitted as an attachment to this notice) 

CBI 

EK 

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers . 

CAS Registry Number (if a number already exists for the substance) 

EK 

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained . . Please 

see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance. 

- 

` 

Click on Add Picture button to add PDF illustration 

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

EPA FORM 7710-25 (Rev . 5-95) Page 5a 
PMN Page 6 ; Page 8 of 18 

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 . Provide 

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

b - Estimate the maximum weight % of each impurity , If there are unidentified impurities, estimate their total weight %. Impurity and CAS Registry Number Maximum Confipercent dential 

a b 

. ._ . . 

__----- 

% 

K 

, . . ° 

/° 

°,° a 

o 

_ 

°,° °,° o 

°,° o 

o 

. . 

. 

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

4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2 . Confidential 

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

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

. 

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

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals 

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

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

4,4'-B.ipyridinium, 1-(2-phophonoalkly)-1'-s.ubstituted-, salt with anion (1 :2) 

0 Mark (X) this 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 Confi1 2 dential 

None 

., . .., . .... :. . ., 

Mark (X) this box if you attach 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 an 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 

000 k / r, specify the volume and mark (x) in the bindin box. If granted, you are bound to this volume 10 , 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Conti- Binding 

dential option 

(100% new chemical substance basis) (100% new chemical substance basis) _ Mark x 

[K L-1 

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 

onfidential business information (CBI). (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total 

roduction for the first three years devoted to each category of use. (5) --Mark (X) this column if entry in column (4) is confidential business information (CBI). (6) -- 

stimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under 

our control associated with each category of use. (7) --Mark (X) this column if entry in column (6) is confidential business information (CBI). (8) --Indicate % of 

roduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) 

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

Category of use (1) (by function and application i.e . a CBI Binding 

Option 

Production CBI %a in 

Formu 

CBI % of substance expected per use 

(8) 

CBI 

dispersive dye for finishing polyester fibers) M~k 

) % lation 

(2) (3) (4) (5) (6) (7) Site- Cons- Indus- Com- Binding 

limited umer trial mercial tion 

(9) 

/_ 

% 

" ' 

% 

'- 

% 

[I 

% 

[I E [], 

11 11 

% % 

11 11 

% 

11 

% [I 

L I[I % % 

% % 

* 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 products . 

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

substance loses its identity in the consumer product. 

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

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

description Manual for examples of generic use descriptions . 

Constituent in ink formulation 

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

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

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

Binding 

Option 

Mark tx) 

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

Mark (X) this box if you attach hazard information. 

PMN Page 7 ; Page 9 of 18 

EPA FORM 7710-25 (Rev . 5-95) Page 7 
PMN Page 8 ; Page 10 of 18 

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 industrial processin g or use operations after import . You must describe these operations . See instructions manual _ 

1 . Operation description Con fia. Identity -- Enter the identity of the site at which the operation will occur. dential 

Name 

Site address (number and street) 

Ci ty , Coun ty, State, ZIP code lrs . 

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 

-01 

sites as attachments . 

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

b. Type -- 

Mark (X) ~ ~ EJ Manufacturing Processing Use 

c. Amount and Duration -- Complete 1 or 2 as a ro riate 

Maximum kg/batch (iooi new chemical 

Substance) 

Hours/batch Batches/year 

I . Batch 

Maximum kg/day (ioo%newchemical 

substance) 

Hours/day Days/year 

2. Continuous 

d. Process description u 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% 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. If releasing to two media 

at the same step, assign a second release number for the second medium . 

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

EPA FORM 7710-25 (Rev . 5-95) Page 8 
PMN Page 8a ; Page 11 of 18 

EPA FORM 7710-25 (Rev . 5-95) Page 8a 
PMN Page 9 ; Page 12 of 18 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

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

2. Occupational Exposure -- You must make separate confidentiality claims for the description 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. li 

(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 this column if entries in columns 10 and ( 11 ) are confidential business information CBI . Worker activity CBI Protective Equipment/ Binding Physical Binding CBI # of CBI Maximum duration CBI 

forms(s) 

(i .e ., bag dumping, filling drums) 

I (2) 

Engineering Controls 

3 

option 

Mark (x) 

(4) 

and °ia new 

substance 

(5) 

Option 

Mark (x) 

(6) (7) 

Workers 

Exposed 

8 (9) 

Hrs/day 

(10) 

Days/yr 

(11) (12) 

u 

E , E E E 

u 

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

EPA FORM 7710-25 (Rev . 5-95) Page 9 
PMN Page 9a ; Page 13 of 18 

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

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

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

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

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

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

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

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

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

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

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

NPDES numbers of the PO"f W (Publicly Owned Treatment Works) . Mark X if the POTW name or NPDES # is confidential business information CB . 

Release 

Number 

(1) 

Amount of new 

substance released 

(2a) (2b) 

CBI Medium of 

release 

e .g.Aackair 

Control technology and efficiency (you may wish to optionally attach 

efficienc y data 

Binding 

CBI 

(3) (4) (Sa) MXk (Sb) (6) 

El 

El - - _ .--- 

1~ El 

(7) Mark (X) the d estination(s) of releases to water. NPDEs # CBI 

POTW--provide 

name(s) ' 

0 Navigable waterway-- 

provide name(s) 

Other--Specify 

---------- - 

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

EPA FORM 7710-25 (Rev . 5-95) Page 9a 
PMN Page 10 ; Page 14 of 18 

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

sites . Identi fy additional sites on a continuation sheet . 

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

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

cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity . (2) -- Either in the diagram or in the text field 1(b) below, provide the 

identity, the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and 

catalysts, etc) and all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Either in the diagram or in the 

text field 1(b) below, identify by number the points of release, 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 CBI 

Red acted 

I(b) . (Optional) This space is for a text description to clarify the diagram above. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 10 
p. 15 

PMN Page 10a ; Page 15 of 18 

- _------ 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 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 any protective equipment and engineering controls, if any, used to protect 

workers. 

(7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. 

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

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

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

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

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

( 3 ) , ( 5), (8), (11), 13 and (15) -- Mark _(X this column if an of the proceeding entries are confidential business information CBI) . 

Letter 

f 

a of CBI Duration Of CBI Protective Equip. /Engineering Controls/Physical Form and/ % new substance % in CBI 

o 

ActiWorkers Exposed 

Exposure Formulation 

vity 

(1) (z) (3) 4a 46 (5) (6) (7) ($) 

_- 

. ~ 

_. _ _ 

, , . )c] 

: . . : : .. . -. 

, 

Release El 

Number 

Amount of 

New 

CBI Media of Release & Control Technology CBl 

Substance 

Released 

9 10a 10b 11 12 13 

, 

---- 

~ t-,J 

I 

( 14)--Byproducts : E (15) __j I 

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

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in the following 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 nonenvironmental 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 PMN Instructions 

Manual -And Pollution Prevention Guidance manual for guidance and examples . 

EPA FORM 7710-25 (Rev . 5-95) Page I Oa 
PMN Page 11 ;Page 16 of 18 

Optional Pollution Prevention Information (Continued) 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 

release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new 

chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new 

chemical substance may be a substitute for an existing substance that poses a greater overall risk to human health or the environment. 

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

CBI 

EPA FORM 7710-25 (Rev. 5-95) Page 11 
PMN Page 12 ; Page 17 of 18 

Part III -- LIST OF ATTACHMENTS 

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 any paper attachments . In the column below, enter the inclusive page 

numbers of each attachment . Electronic attachments can be identified by filename . 

Mark (X) the "Confidential" box next to any attachment name you 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 an attachment in which you claim information as confidential . 

# Attachment name Attachment Filename Attachment 

a e number ( s ) 

Confidential 

a z 

3 

4 

5 

Uij 

: a 

0 0 

0 0 

0 

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

EPA FORM 7710-25 (Rev . 5-95) Page 12 
p. 18 

PMN Page 13 ; Page 18 of 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, (he 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 . If the attachments 

are electronic, give the attachment number (found on page 12) at (b) . The physical state of the neat substance should be provided . 

These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

formulations should be so noted (o/a 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 supp lement to our submission of test data . This worksheet is not a substitute for submission of test data. 

Property Mark (X Page 

number 

Value Measured o 

Estimate 

Confide"rW 

(a) provided 

(b) (~) M or E 

Mark (X) 

(d) 

Physical state of neat substance (s) ~(1 ~( `. 

Vapor pressure 

Temperature ° C a Torr 

Dens i /relative densi ty ~ cm3 0 

Solubility 

@ Temperature °C F7 

Solvent - ^ -- 9/1- 

-Solubility in water Temperature °C 

- .--.----- 

Melting temperature ~ °C 

Boilin g / sublimation tem erature torr pressure F7 °C 0 

Spectra E:1 ` 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient ~ 0 

-Henry's Law constant ~ 0 

Volatilization from water 

Volatilization from soil ~ 0 

H concentration 

Flammability 

Ex lodabili 

Adsorp tion / coefficient ~ u --- t 

Other - S eci ~ 0 

Other - Specify 

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

PAGE 13 
ATTACHMENTS 

Redacted