## PMN Page 1 ; Page 1 of 18 ,~'" p. 1 FormApproved, O.M

.B. No: 2070-0012. Approval Expires 10-31-96. 

## U .S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY Dateof receipt . 

## 0 6 . V I IIIIII IIIII IIII 1111111111 III 111111111111

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# _____ U .S. E.P.A. 1200 Pennsylvania, NW WASHINGTON, D

.C . 20460 ' nteTt}ietot~T iiiztriber of pages 44~8- .7 in the Premanufacture Notic e ocument control nu ber PA case number (/ 2



### GENE RAL 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 reasonabl y ascertainable b y you . Make reasonable estimates ifyou 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 fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603) . " Ifa 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 providethe currently correct Chemical Abstracts (CA) Name of thenew chemical substance, even ifyou claimthe identity as confidential . You may authorize You are required to submit all test data in your possession or control and to anotherperson to submit chemical identity information for you, but your submission will provide a description ofall other data known to or reasonably ascertainable by not be complete and the reviewwill not begin until EPAreceives this information. A letter you, ifthese data are related to the health and environmental effects on the in support ofyour 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 oftest data and other data. Data should be submitted accof4ipg to Ifthere are several manufacture, processing, or use operations to be described in Part 11, the requirements of §720.50of 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 Belowany 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 ofthe submitter El substance. On page I I ofthis 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 formfor 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 fromlater deviating fromthe information (except chemical identity) reported in the form . TMEA (Test Marketin Ex ti A li i g emp on pp cat on) CONFIDENTIALITY CLAIMS El LVE (LowVolume Exemption) @ 40 CFR 723.50(c)(1) You may claimany 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 claimin an attachment, circle or bracket the information you claim as confidential . Ifyou claiminformation 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 . # ofchemicals or polymers Prenotice Communication # req uired, enter # on a e 3 EPA FORM

7710-25 (Rev. 5-95) .~ ~~ t=, °~ ~,/- Replaces previous editions of EPAForm7710-25.

## 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, searchingexisting data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or anyother aspect of this collection of information, includingsuggestions 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 -- APrinted 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 1a 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 amsubmitting 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 youare 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 $2500specified 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 Ais a small business concern under 40 CFR 700 .43' and has remitted a fee of $100 in accordance with 40 CFR700 .45(b) . Ifyouare 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 CFR723.50(c)(2), check the following certification statements: 0The 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 . 0The 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 ofthe 30 day reviewperiod. 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 misinter pretation is subject to criminal p enal 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 ofauthorized official Position Submitting c 

# F Notice (in U.S.) )

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. Ifyou are submitting this notice as part of ajoint 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 

# K U .S.) Company

Mailing address (number and street) 

### City, State Postal Code Telephone (include area code) 3. Ifyou have had aprenofice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number . Mark (X) " 1 if none 4. Ifyou previously submitted an exemption application for the chemical substance oovered by this notice, enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this subsfance enter the PMN Mark (X) - 

### EKI If none numberassigned by EPA(i .e. withdrawn or incomplete). --i 5. Ifyou have submitted a notice of Bona fide intent to manufacture or import - ---- for the chemical substance covered by this notice, enter the notice number assigned by EPA ----~ Mark (X) ---

. if none 6 . Type of Notice - Mark (X) 

### -- Mark the "Confidential" box next to any subsection you claimas 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 ofthe substance based on the ninth

Collective Index 9CI of CA nomenclature rules and conventions. 

### Mark X the "Confidential" box next to any itemyou claimas 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, com

p any , and address of that p

erson 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 ofsubstance - 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 fromthe CAS Inventory Expert Services must be 

### submitted as an attachment to this notice) d. Molecular formula CBI CAS Registry Number _ I (if a number already 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-PMNInstruction Manual for 

### discussion of "native format" diagramsoftware which can be helpful in reviewing your substance.



# R

# e d

# acte d

Mark (X) this box ifyou 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 ofcomposition 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 ofthe reaction or process.

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

Mark (X) this box ify

ou 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 ofpolymer, 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 500and 

### dential below1,000 absolute molecular wei ght ofthat com position. Describe the methods ofmeasurement or the basis for your estimates: GPC LJ Other

(i) lowest number average molecular weight : U (Specify below) "- (ii) maximumweight %below500 molecular weight : (iii) maximumweight %below1000 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) ofeach

the polymer. monomer or other reactant used in the manufacture of 

### (2) - Mark (X) this column ifentry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. (4) - Choose "yes" fromdrop down menu ifyou want a monomer or other reactant used at two weight percent or less to be listed as part of

description on the TSCAChemical Substance Inventory. the polymer (5) - Mark (X) this column ifentries in columns (3) and (4) are confidential . (6) - 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 . 7 - Mark X this column ifentry 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 .___. 

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### Mark (X) this box ifyou attach a continuation sheet . EPAFORM

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 fromCAS 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, ifone can be reasonably ascertained. . Please see the E-PMN Instruction Manual for discussion of "native format" diagramsoftware 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 wei g ht % ofeach im

puri ty, If there are unidentified im p urities, estimate their total wei g ht % . 

### Impurity and CAS Registry Number Maximum Confipercent dential 

### a b

. ._ . . __----- % 

# K

, . . ° /° 

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

### 4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2. Confidential Mark (X) this box ifyou 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 ifyou attach a continuation sheet . 6 . Generic chemical name - Ifyou claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity ofthe new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix 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 ifyou attach a continuation sheet . 7 . Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

### Number ifavailable. Byproduct CAS Registry Number Confi1 2 dential None

., . .., . .... : . . ., Mark (X) this box ifyou attach a continuation sheet. EPAFORM

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

## P. 9 

# Part I -- GENERAL INFORMATION -- Continued Section C-- PRODUCTION, IMPORT, ANDUSE INFORMATION : Mark X) the "Confidential" box next to an item y ou claimas confidential . 1 . Production volume -- Estimate the maximumproduction volume during the first 12 months ofproduction. Also estimate the maximum production volume for any consecutive 12-month period during the first three years ofproduction. Estimates should be on 100% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 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) Maximum12-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 ofthe category ofuse, the percent of production volume devotedto each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any itemyou 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 ifentry 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 ifentry 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 ifappropriate. 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 % ofsubstance 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[], 1111 % % 

# 1111 %

# 11 %

# [I LI[I

% %

% %

* Ifyou have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consumer products. In addition include estimates of the concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product . Mark (X) this box ifyou attach a continuation sheet. b . Generic 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 ofany 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 Marktx) the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (X) this box ifyou attach hazard information. 

## PMN Page 7 ; Page 9 of 18

EPAFORM

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

## PMN Page 8 ; Page 10 of 18 

# Part II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next toany itemyou claimas confidential 

## Complete section Afor each type of manufacture, processing, or use operation involving the new chemical substanceat industrial sites you control . Importers do not have to complete this section for operations outside the U .S. ; however, you may still have reporting requirements if there are further industrial processing or use operations after im p ort . You must describe these operations. See instructions manual _ 1 . Operation description Confia. Identity -- Enter the identity ofthe site at which the operation will occur. dential Name Site address (number and street) Ci ty, County, 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 ifany ofthesites 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 ifyou attach a continuation sheet. 

### b. Type -- Mark (X) ~ ~ EJ Manufacturing Processing Use c. Amount and Duration -- Com plete 1 or 2 as a ro riate Maximumkg/batch (iooi newchemical 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) Diagramthe major unit operation steps and chemical conversions . Include interimstorage 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 ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot 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 ifyou attach a continuation sheet . EPA FORM

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

## PMN Page 8a ; Page 11 of 18

EPAFORM

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 CONTROLLEDBY THE SUBMITTER-- Continued 2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical formofthe new chemical substance, number of ' works exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any itemyou claimas confidential . ' (1) --Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) -- Mark (X) this column ifentry 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 (ifpart ofa mixture) at the time of exposure. (7) --Mark (X) this column ifentry in column (5) is confidential business information (CBI) . (8) --Estimate the maximumnumber 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. EPAFORM

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 ofthe new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) --Enter the number ofeach release point identified in the process description, part 11, section A, subsection Id(3) . (2) --Estimatethe amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) --Mark (X) this column ifentries 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 fromthat release point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release of the new substance to the environment . For releases disposed ofon 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 ofthe PO"fW (Publicl y Owned Treatment Works ) . Mark X ifthe POTW name or NPDES # is confidential business information CB . Release Number (1) Amount of new

substance released (2a) (2b) CBI Mediumof release e.g.Aackair Control technology and efficiency (you maywish to optionally attach

efficiency data Binding CBI 

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

# El El

- - _ .---



# 1~ El

(7) Mark (X) the d

estination(s) ofreleases 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 Bfor each type of processing, oruse operation involving the newchemical 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 acontinuation sheet . 1(a). Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagramthe major unit operation steps and chemical conversions, including interimstorage 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 diagramor 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 diagramor 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 ofthese sites on a continuation sheet) : ^' # of sites CBI 

# R

# ed

# act

# ed

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

Mark (X) this box ifyou attach a continuation she et . EPAFORM

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

## p. 15 PMN Page 10a ; Page 15 of 18 - _------ 2. Worker Exposure/Environmental Release 

### (1) --Fromthe diagramabove, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) --Estimatethe number of workers exposed for all sites combined. (4) -- Estimatethe typical duration of exposure per worker in (a) hours per day and (b) days per year . (6) -Describe physical form ofexposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect workers. (7) -- Estimate the percent ofthe new substance as formulated when packaged or used as a final product. (9) --Fromthe process diagram above, enter the number of each release point. Complete 9-13 for each release point identified . (10) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) -- Describe media 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 ofthe new substance to the environment. (14) -- Identify byproducts which may result fromthe operation. ( 3) , ( 5 ), (8), ( 11), 13 and (15) -- Mark _(X this column if an ofthe proceedingentries are confidential business information CBI) . Letter f 

## a of CBI Duration Of CBI Protective Equip. /Engineering Controls/Physical Formand/ % new substance %

in CBI oActiWorkers Exposed Exposure Formulation vity (1) (z) (3) 4a 46 (5) (6) (7) ($) _-

. ~ _. __

, , . 

# )c]

: . . : : .. . -.

, 

# El Release Number 

## Amount of New 

## CBI Media ofRelease &Control Technology CBl Substance Released 9 10a 10b 11 12 13

,

---- ~ t-,J

I 

### ( 14)--Byproducts: 

# I (15) E__j

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



# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in the following section as confidential circle or bracket the specific information that you claimas 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 dueto 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, rawmaterials substitution, and/or inventory control . Recycling refers to the reclamation of useful chemical components fromwastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions ofpollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPAis 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 PMNsubstance to potential alternatives may be provided, All information provided in this section will be taken into consideration during the reviewof this substance. See PMN Instructions Manual -And Pollution Prevention Guidance manual for guidance and examples.

EPA FORM

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

## 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 ofwaste 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 thecost 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 whichthe new chemical substance may be asubstitute for an existing substancethat poses a greater overall risk to human health or the environment .

Mark X) this box ifyou attach a continuation sheet. CBI

EPAFORM

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

## PMN Page 12 ; Page 17 of 18 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe form and test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page . Clearly identify the attachment and the section of the formto which it relates, if appropriate. Number consecutively the pages ofany paper attachments . In the column below, enter the inclusive page numbers ofeach attachment . Electronic attachments can be identified by filename. Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on howto claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice forma sanitized version ofan 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 ifyou 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 ANDCHEMICAL PROPERTIES WORKSHEET ---- To assist EPA's review

ofphysical 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 ofthe property, the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . Ifthe attachments are electronic, give the attachment number (found on page 12) at (b) . The physical state ofthe neat substance should be provided. These measured properties should be for the neat (100%pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (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 supplement to our submission oftest 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) 

## Ph ysical state of neat substance (s) ~(1 ~( `. Vapor pressure ° a Tem perature C Torr 

## Densi /relative densi ty ~ cm3 0 Solubility @ Temperature °C F7 Solvent - ^ -- 9/1-



## - Solubili ty in water Tem perature °C - .--.-----



## ~ Melting tem

p erature °C F7 0 Boiling/ sublimation tem erature torr pressure °C E :1 ` Sp ectra Dissociation constant Particle size distribution Octanol / water p

artition coefficient ~ 0

- Henry's Law

constant ~ 0 Volatilization fromwater

~ 0 Volatilization fromsoil H concentration Flammabili ty Ex lodabili

~ u t Adsorption / coefficient --- Other - S eci ~ 0 Other - Specify 7 Mark (X) this box ifyou attach a continuation sheet . Enter the attachment name and number . 

## ATTACHMENT PAGE 13

# ATTACHMENTS Redacted