p. 1 

SANITIZED COPY 

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

PREMANUFACTURE 

NOTICE 

Date of receipt 

07 JNJ -8 M! 6: Ol-t 

~CES 

lillllltllllltllill!i: ill!i Ill!! 1111:11 i: tk 11:1: 1u: 1 :n ~~ n 4 3 (J I) ll ll il (; il .' < 

tnter the total number ot pages 

in the Premanufacture Notice 

17 

GENERAL INSTRUCTIONS 

• 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, Attn. TSCA User fee. 

Part I-GENERAL INFORMATION 

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

chemical substance, even if you claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you. but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in support of your submission should reference your TS user fee identification 

number. You must submit an original and two copies of this notice including all test data. 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted. 

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part II, 

sections A and B of this notice, reproduce the sections as needed. 

Part Ill-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 Ill, list these 

attachments, any test data or other data and any optional information included in the 

notice. 

OPTIONAL INFORMATION 

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

substance. On page II 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 form for you to indicate your 

willingness to be bound to certain statements you make in this section. such as use, 

production volume, protective equipment . . . This option is intended to reduce delays 

that routinely accompany tbe development of consent orders or Significant New Use 

Rules. Except in the case of exemption applications (such as TMEA. LYE. 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 later deviating from the information (except 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

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. To assert a claim in an attachment, circle or bracket the infonnation 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 claiming information as confidential, read the Instructions Manual. 

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

TEST DATA AND OTHER DATA 

You are required to submit all test data in your possession or control and to provide 

a description of all other data known to or reasonably ascertainable by you, if these 

data are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature. Complete test data (written in Englishl. not summaries of data. 

must be submitted if they do not appear in the ooen literature. You should clearly 

identifY whelher test data is on the substance or on an analog. Also, the chemical 

composition of the tested material should be characterized. Following are 

examples of test data and other data. Data should be submitted according to the 

requirements of §720.50 of the Premanufacture Notification Rule (40 CFR Part 

720). 

Test Data (Check Below any included in this notice) 

Environmental fate data 

Health effects data 

Environmental effects data 

Physical/Chemical Properties• 

0 Yes 

0 Yes 

0 Yes 

181 Yes 

Other data 0 Yes 

Risk assessments 

Structure/activity relationships 

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) 

D 

D 

~ 

D 

D 

D 

D 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with ftnal prodiiqi-=PMN) r·. ~, c---.' 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) -

::~~ 

LYE (Low Volume Exemption) (ti) 40 CFR 723.5iln:)(l) 

C,) 

LOREX (Low Release/Low Exposure Exemption) (ti) 40 CFR 723.50(c)(2) 

L VE Modification LOREX Modification 

IS THIS A CONSOLIDATED PMN? 

D 

D Yes 

# of chemicals 

(Prenotice Communication# required, enter# on page 3) 

Page I 

30 t;>-85 
p.2 

Public reporting burden for this collection of information is estimated to average II 0 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: 

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: 

I2SI The Company named in Part I, Section A has remitted the fee of$2500 specified in 40 CFR 700.45(b), or 

0 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 

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b). 

If you are submitting a low volume exemption (L VE) 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 terms of 40 CFR 723.50. 

0 The manufacturer is familiar with the terms of this section and will comply with those terms; and 

0 The new chemical substance for which the notice is submitted meets all applicable exemption conditions. 

0 If this application is for an LYE in accordance with 40 CFR 723.50(c){l), 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 

described herein. Any knowing and willful misinterpretation Is subject to criminal penalty pursuant to 18 USC 1001. 

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

Signature of agent -(if applicable) Date 

EPA FORM 7710-25 (Rev. 5-95) Page2 

Confidential 

X 
la. Person 

Submitting 

Notice (in U.S.) 

b. Agent(if 

applicable) 

Mailing address (number and street) 

City, State, ZIP Code 

Name 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

c. If you are submitting this notice as part a joint submission, 

Joint Submitter (if 

applicable) 

Name 

Company 

Mailing address (number and street) 

City, State, ZIP 

2. Technical 

Contact (in 

U.S.) 

Name of authorized official 

3. 

4. 

5. 

6. 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

If you have had a prenotice communication (PC) concerning this notice 

and EPA assigned a PC Number to the notice. enter the number. 

If you 

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

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

PMN number assigned by EPA (i.e. withdrawn or incompleleteteT.).---• 

If you have submitted a notice 

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

assigned by EPA. 

Type of Notice- Mark (X) 

I. 

D 

Manufacture 

Only 

Binding Option 

Mark 

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

Telephone 

Telephone 

2. 

D 

Page 3 

Import 

Only 

Mark(X) 

if none 

Mark(X) 

if none 

Mark(X) 

if none 

Binding Option 

Mark 

p.3 

3. D Both 

Confidential 

X 
p.4 

either item I (Class I or 

If another person will submit chemical identity information for you (for either Item I or 2), marl< (X) the box at the right. 

the address of that in a continuation sheet. 

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

a. Class of substance - Mark (X) I D Class I or 2 D Class 2 

b. Chemical name (Currently correct (CA) Name TSCA Inventory 

For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name orCA 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 reported in this notice: 

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

obtained from the CAS Inventory Expert Services must be 

to this 

d. 

e. For a I substance, provide a complete and correct chemical structure diagram. For a 

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). ( 4) Provide a correct representative or partial chemical structure 

diagram. as comolete as can be known. if one can be reasonablv ascertained. 

This page does not apply. 

D Marl< (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page4 
p.5 

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

Confidential 

Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500 and X 

below I ,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC [8J Other 0: (Specify) 

i) lowest number average molecular weight: 

ii) maximum weight %below 500 molecular weight: % 

iii) maximum weight %below 1000 molecular weight: % 

You must separate monomer or other reactant identity, composition information, and residual information. Mark (X) the 

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

(I) 

(2) - (3) -

(4) -

(5) -

(6) -

Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

Mark (X) this column if entry in column (I) is confidential. 

Indicate the typical weight percent of each monomer or other reactant in the polymer. 

Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

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

Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes. 

X 

you 

(CAS Inventory Expert Service- a copy of the identification report 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this 

% X X 

% 

% 

% 

reported in this notice (check one). 

Method 2 (other source) 

correct Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for 

% 

% 

% 

% 

e. Provide a correct representative or partial chemical structure diagram, as complete as can be ascertained. 

X 

this box if you attach a continutation sheet. 

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

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." 

%of each· If there unidentified estimate their total %. 

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

you chemical identify as confidential, you must provide a generic name for your substance that 

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

TSCA Chemical Substance Inventory, 1985 Edition, Appendix 8 for guidance on developing generic names. 

Phenol-biphenyl polymer 

Confidential 

% X 

% X 

% 

% 

% 

new chemical substance. Provide the CAS Registry 

CAS Number Confidential 

Methanol 67-56-1 

EPA FORM 7710-25 (Rev. 5-95) Page6 
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 I 00% 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 the volume and mark (x) in the binding box. If granted, you are bound to this volume 

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

(100% new chemical substance basis) ( 1 00% new chemical substance basis) dential Option 

Mark(x) 

-kg -kg 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. (I) -- Describe each intended category of use of the new chemical substance by function and application .. 

(2) -- Mark (X) this column if entry column (I) is confidential business information (CBI). 

(3) -- Indicate your willingness to have the information provided in column (I) 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 (I ) 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) (3) (4) (5) (6) (7) limited sumer trial mercia! Option (9) 

Phenol-biphenyl Polymer used as a 100% 2-8% 100% 

component in photoresist manufacture. 

% % 

% % 

% % 

% % 

% % 

* 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. 

0Mark (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 

0 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 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. Mark(x) 

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

EPA FORM 7710-25 (Rev. 5-95) Page 7 
p.8 

EXPOSURE 

Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER box next to any 

Complete section A for each type of manufacture, processing, or use operation involvmg the new 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 or use · after · You must describe these See instructions manual 

1. 

Site address (number and street) 

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. 

I. Batch 

2. Continuous 

Maximum kg/batch (100% new chemical Hours/batch 

substance) 

Batches/year 

d. Process description Marl< (X) to indicate your willingness to have your process description binding. 

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

drum, rail car, tank truck, etc.). 

you 

X 

X 

(2) Provide the identity , the approximate weight (by kg/day or kg/batch on a I 00% 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. 

See Appendix C for a Description of NCS Processing. 

Marl< (X) this box if attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 8 
p.9 

Part 11-- 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. 

(I)-- 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 (I) 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 (II)-- 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 (II) 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 Workers Hrslday Days/yr Mark (x) substance Mark(x) Exposed 

(I) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) 

I There will be no U.S. operations by sites controlled by the submitter. I 

I 

D 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. 

(I) -- Enter the number of each release point identified in the process description, part II, 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 (I) 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 (Publici 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 

(I) (2a) (2b) e.g. stack air Binding 

(3) (4) (Sa) Mark (X) (Sb) (6) 

(7) Mark (X) the D POTW provide name(s) below: CBI D Navigable D Other - SpecifY provide NPDES # CBI 

- destination(s) of waterway 

releases to water. N/A N/A N/A 

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

EPA FORM 7710-25 (Rev. 5-95) Page9 
p.10 

Part 11-- 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. ldentifv additional sites on a continuation sheet. 

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

(I)-- 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)- Provide the identity, the approximate weight 

(by kg/day or kg/batch, on an I 00% 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) -- 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 

See Attachment B for description of customer application. 

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

2. Worker Exposure/Environmental Release 

(I) --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 any of the proceeding entries are confidential business information (CBI). 

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

of Workers of Engineering Controls/ Form- Number New & Control 

Act- Exposed Exposure Physical Form and % ulation Substance Technology 

ivity new substance Released 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (11) (12) (13) 

1 1 0.25 250 Full body coverage, nitrogen Liquid (2- None None ~lanket 8%) 

2 1 8 250 Full body coverage, Liquid (2- R1 0 1.7- Offsite 

~utomated process, local 8%) 6.8% incineration 

exhaust, vent on spin bowl 

3 1 <0.25 250 (..;hemical resistant gloves, Liquid (2- R2 0 0.075- Onsite treatment, 

goggles, apron (liquid) 8%) 0.300% then to a POTW 

14) -- Byproducts: (15) 

[ ] Mark (X) this box if you attach a continuation sheet, 

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 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. 

No information is available at this time. 

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

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

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 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 Contipage number(s) dentia1 

X 

Appendix B: Customer Use Application A2 

Appendix C: Photoresist Manufacture Description A3 

X 

X 

X 

X 

X 

l ] Marl< (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.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 (I 00% 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 Measuredo Confi-

(X) if number Estimate dcntial 

(a) provided (b) (c) Mark (X) 

(MorE) (d) 

X..ight yellow powder M 

Physical state of neat substance X (s) (l) (g) 

Vapor pressure Negligible Torr 

E 

@2 Temperature oc 

E 

Density/relative density 0.7-1.0 glcm3 

Solubility 

@ Temperature 20 oc ~oluble in THF, alcohols, 

Solvent ~cetone and toluene giL E 

Solvent 

E 

Solubility in water@ Temperature 20 oc Negligible giL 

Melting temperature Not Determined oc 

Boiling I sublimation temperature@ torr pressure Not Determined oc 

X M X 

Spectra 

Not Determined 

Dissociation constant 

Not Determined 

Particle size distribution 

Not Determined 

Octanol I water partition coefficient 

Not Determined 

Henry's Law constant 

Not Determined 

Volitalization from water 

Not Determined 

Volitalization from soil 

Neutral (ca. 7) E 

pH@ concentration 1-10% 

Non-flammable E 

Flammability 

Not Determined 

Explodability 

Not Determined 

Adsorption I coefficient 

OtherEPA FORM 7710-25 (Rev. 5-95) Page 13 
p.14 

PAGE Al IS CONFIDENTIAL BUSINESS 

INFORMATION AND HAS BEEN REMOVED FROM 

THIS SANITIZED VERSION 
DESCRIPTION OF USE 

APPENDIXB 

CUSTOMER USE APPLICATION 

p.15 

The manufacturers of integrated circuits and other devices which would use products containing the NCS 

exercise extreme care in the use of the product to avoid contact between their personnel and the product. The 

manufacturing process for the production of integrated circuits requires this exceptional care. Personal 

protection is provided via engineering controls (e.g. laminar flow ventilation in "clean room" or local exhaust 

for other processing equipment) and personnel protective equipment use. Personnel in clean room 

environments are typically required to wear full coverage fabric coveralls (bunny suits) including chemical 

resistant gloves, head covering and boots or equivalent protection. 

Activity 1 

In almost all cases, the user never touches products containing the NCS Chemical. Products are supplied in 

quart or gallon glass or plastic bottles, double wrapped in plastic bags. The first bag is removed and the package 

is transferred into the clean storage room. When the product is needed, the second wrapper is removed and the 

materials is transferred either through an air lock or directly fed via closed pipe system to dispensing equipment 

in the clean room environment. This process is employed to minimize the contaminants introduced into the 

clean room. The product is then opened and a fully enclosed autodispense tube and pump are employed to apply 

carefully measured amounts of photoresist to the silicon I passivation layers (substrates), where either these are 

used as insulation resins for wafer processing or solder dam applications. 

Activity 2/Release Rl 

The silicon or substrate is then spun at high speeds while photoresist is dispensed to its surface to create a very 

thin, defect-free film on the substrate. During the spinning process approximately 85% of the product is spun 

off the wafer. This waste is usually collected in a catch basin below the substrate spinning with some 

photoresist being deposited in the spin bowl. High level of air exhaust is employed during the spinning process 

to facilitate the formulation of defect free films. This exhaust also effectively isolates the operators from any 

exposure with the resist during the spinning process. 

The product is either deposited in the spin bowl or is captured in an integrated waste system during the wafer 

coating operation. Spin bowls are cleaned frequently by trained and properly equipped personnel. Photoresist 

waste is dissolved in an appropriate cleaning solvent, collected on a segregated basis and disposed of principally 

via incineration. 

Personnel contact with the NCS Chemical is possible during cleaning of the spin bowl or wafer spinner. 

However, the likelihood of this occurring is remote due to the use oflocal exhaust ventilation and personnel 

protective equipment as described above. 

Activity 3/Release R2 

Within the same photolithographic tool described above, the photoresist on the wafer is then dried and imaged. 

Then ~25% of the dried photoresist is developed and removed from the wafer using an alkaline developer. 

3.5% of the alkaline waste generated consists of dried photoresist. The alkaline developer waste is treated onsite and then sent to a POTW. Personnel handling the alkaline waste would wear chemical resistant gloves, 

goggles and aprons. 

Custapp.doc 
p.16 

APPENDIXC 

DESCRIPTION OF PHOTORESIST MANUFACTURING 

PROCESS DESCRIPTION (to be conducted outside the U.S.) 

Activity 1 

The NCS is first subjected to a quality control sampling program. This is required to verify the NCS 

meets the expected product specifications. Testing is conducted in a laboratory under controlled 

conditions. Employees use personal protective equipment (goggles, gloves, laboratory coats or 

work uniforms) and local exhaust ventilation to protect against inadvertent exposure to the NCS. 

Activity 2 

Blending the NCS with other ingredients to produce photoresist occurs in an isolated organic 

chemical mixing site. All of the components of the photoresist are introduced manually to a totally 

enclosed mixing tank equipped with a nitrogen gas blanket. After the chemical components are 

introduced into the blending tanks, the photoresist is not handled directly by personnel. Employees 

utilize personal protective equipment (goggles, impervious gloves, workwear) and local exhaust 

ventilation to minimize potential worker exposures during the handling and charging of all raw 

materials to the mix vessel (this includes the handling of containers and any waste packaging or raw 

materials). 

Activity 3 

The photoresist containing the NCS is subjected to an in-process quality control sampling program. 

This is required to verify the photoresist meets the expected product specifications. Testing is 

conducted in a laboratory under controlled conditions. Employees use personal protective 

equipment (goggles, gloves, laboratory coats or work uniforms) and local exhaust ventilation to 

protect against inadvertent exposure to the NCS. 

Activity 4 

Following blending, the photoresist is transferred via a closed pipe system through a filter to the 

packaging station. Packaging is conducted in an ultra clean environment comparable to Class 100 

standards used in the integrated circuit industry. Personnel protection is provided via engineering 

controls (laminar flow ventilation coupled with local exhaust) and personal protective equipment. 

Personnel in clean room environments are typically required to wear full coverage disposable tyvek 

coveralls (bunny suits) including gloves, head covering and boots or equivalent protection. 

Activity 5 

Lastly, all equipment is cleaned with a solvent and sent out for off-site disposal and/or destruction. 

The amount of the NCS left in the equipment is minimal. Personal protection is provided as above. 
PAGES A4 THROUGH AlO ARE CONFIDENTIAL 

BUSINESS INFORMATION AND HAVE BEEN 

REMOVED FROM THIS SANITIZED VERSION 

p.17