### p. 1 

# SANITIZED COPY U.S. ENVIRONMENTAL PROTECTION AGENCY 

# AGENCY USE ONLY 

# PREMANUFACTURE NOTICE Date ofreceipt 

# 07 JNJ 

# -8 M! 

# 6: Ol-t**~CES** 

# lillllltllllltllill!i:ill!iIll!! 1111:11 i:

## tk11:1:

# 1u: 1 

# :n**~~**

# n 4 3 (J I) ll ll il (; il .' <
tnterthe 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 orreasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. • Before you completethis 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 calling202-554-1404, 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 numberyou 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 ofthe new chemical substance, even ifyou 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 ofyour submission should reference your TS user fee identification number. You must submit an original and two copies ofthis notice including all test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted.
Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture, processing, or use operations to be described in Part II, sections A and Bofthis notice, reproduce the sections as needed. Part Ill- LIST OF ATTACHMENTS Attach additional sheets ifthere 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. Onpage II ofthis 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 ofconsent orders or Significant New Use Rules. Except in the case ofexemption applications (such as TMEA. LYE. LOREX) where certain information provided in such notification is binding on the submitterwhen the Agency approves the exemption application. checking a binding box in this notice does not by itselfprohibit 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 orbracket the infonnation you claim as confidential. Ifyou claim information in the notices as confidential you must also provide a sanitized version ofthe 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 ofall otherdata known to orreasonably ascertainableby you, ifthese data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, ordisposal ofthe new chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in Englishl. not summaries ofdata. must be submitted ifthey do not appear in the ooen literature. You should clearly identifY whelhertest data is on the substance or on an analog. Also, the chemical composition ofthe tested material should be characterized. Following are examples oftest data and other data. Data should be submitted according to the requirements of §720.50 ofthe 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 ofthe submitter
• A physical and chemical properties worksheet is located on the last page ofthis 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) LVE Modification LOREX Modification IS THIS A CONSOLIDATED PMN? 

# D D Yes # ofchemicals (Prenotice Communication# required, enter# on page 3) Page I 

# 30 

# t;>-85

### p.2
Public reporting burden for this collection ofinformation is estimated to average II0 hours perresponse, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing andreviewing the collection of information. Send comments regarding theburden estimate or any other aspect ofthis collection ofinformation, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 20460; and to the Office ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

## CERTIFICATION I certifythat to the best ofmy knowledge and belief: 1. The company named in Part I, section A, subsection 1 a ofthis notice form intends to manufacture orimport for a commercial purpose, otherthan in small quantities solely for research and development, the substance identified inPart I, Section B. 

### 2. All information provided in this notice is complete and truthful as ofthe date ofsubmission. 3. I am submitting with this notice all test data in mypossession orcontrol and a description ofall other data known to or reasonably ascertainable byme as required by §720.50 ofthe Premanufacture Notification Rule.
Additional Certification Statements: Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statementthat applies: 

# I2SI The Company named inPart I, Section A has remitted the fee of$2500 specified 

### in 40 CFR 700.45(b), or 

# 0 The Companynamed in Part I, Section A has remitted the fee of$1000 for anIntermediate PMN (defined @ 40 CFR 700.43) in accordance with40 CFR 700.45(b}, or 

# 0 The Company named in Part I SectionA is a small business concernunder40 CFR 700.43 andhas remitted a fee of$100 in accordance with 40 CFR 700.45(b). Ifyou are submitting a low volume exemption (LVE) application inaccordance with40 CFR 723.50(c)(1) or a Lowrelease and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), checkthe following certification statements: 

# 0 The manufacturer submitting this notice intends to manufacture orimport the new chemical substance for commercial purposes, otherthan in small quantities solely for research and development, under the terms of40 CFR 723.50. 

# 0 The manufacturer is familiar with the terms ofthis 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 Ifthis application is for an LYE in accordance with 40 CFR 723.50(c){l), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year ofthe date ofthe expiration ofthe 30 day reviewperiod. The accuracy ofthe statements you make In this notice should reflect your best prediction ofthe 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 ofAuthorized Official (Original Signature Required) Date
Signature ofagent -(ifapplicable) Date



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

### Xla. 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. Ifyou are submitting this notice as part ajoint submission, Joint Submitter (if applicable) Name Company Mailing address (number and street) City, State,ZIP
2. Technical Contact (in U.S.) Name ofauthorized official

3.

4.

5.

6. Company Mailing address (numberand street) City, State, ZIP Code

Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice. enter the number.
Ifyou substance covered by this notice, enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this substance enter the PMN number assigned by EPA (i.e. withdrawn or incompleleteteT.).---• Ifyou have submitted a notice for the chemical substance covered by this notice, enter the notice number assigned by EPA. Type ofNotice- 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) ifnone Mark(X) ifnone Mark(X) ifnone
Binding Option Mark 

### p.3

3. 

# D Both Confidential 

### X

### p.4

eitheritem I (Class I or Ifanotherperson will submit chemical identity information for you (for either Item I or2), marl< (X) the box at the right. the address ofthat in a continuation sheet. I. Class I or2 (for definitions ofclass I and class 2 substances, see the Manual) a. Class ofsubstance

- Mark (X) I 

# D Class I or 2 

# D Class 2 b. Chemical name (Currently correct (CA) Name TSCA Inventory ForClass I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name orCA Preferred Name must beprovided, which ever is appropriate based on CA 9CI nomenclature rules and conventions).

c. Please identify which method you used to develop orobtain the specified chemical identity reported in this notice: 

# D Method I (CAS Inventory Expert Service- a copy ofthe 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 theirrespective CAS Registry Numbers. (2) Describe the nature ofthe reaction orprocess. (3) Indicatethe range ofcomposition and the typical composition (where appropriate). ( 4) Provide a correct representative orpartial chemical structure diagram. as comolete as canbe known. ifone canbe reasonablv ascertained. 

# This page does notapply.

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

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

### p.5

a. Indicate the number-average weight ofthe lowest molecular weight composition ofthe 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 ofthat composition. Describe the methods ofmeasurement orthe 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 molecularweight: 

### %

You must separate monomeror otherreactant 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 (ifa number exists) ofeach monomer orotherreactant used in the manufacture of the polymer. Mark (X)this column ifentry in column (I) is confidential. Indicatethe typical weight percent ofeach monomer orotherreactant in the polymer. Mark (X)the identity column ifyou want a monomeror otherreactant used at two weight percent orless to be listed as part ofthe polymer description on the TSCA Chemical Substance Inventory. Mark (X} this column ifentries in columns (3) and (4) are confidential. Indicate the maximum weight percent ofeach monomer orother reactant that may be present as a residual in the polymeras manufactured for commercial purposes.



## X

you (CAS Inventory Expert Service- a copy ofthe identification report obtained from CAS Inventory Expert Service must be submitted as as attachmentto 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 orpartial chemical structure diagram, as complete as can be ascertained. 

### X

this box ifyou attach a continutation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 5

## p.G

Impurities (a)

- Identify each impurity that may bereasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide the CAS Registry Number ifavailable. Ifthere are unidentified impurities, enter "unidentified." %ofeach· Ifthere unidentified estimate their total %.



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

you chemical identify as confidential, you must provide a generic name for yoursubstance that the specific chemical identity ofthe new chemical substance to the maximum extent possible. Referto 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 

## PartI

-- 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 ofproduction. Also estimate the maximum production volume for any consecutive 12-month period during the first three years ofproduction. Estimates should be on I00% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lowerproduction volume than 10,000 kg/yr, specify the volume and mark (x) in thebinding box. Ifgranted, you are bound to this volume Maximum first 12-monthproduction (kg/yr) Maximum 12-monthproduction (kg/yr) Confi- Binding (100% new chemical substance basis) ( 1 00% new chemical substancebasis) dential Option Mark(x) 

### -kg -kg 

## X 2. Use Information

-- You must make separate confidentiality claims for the description ofthe category ofuse, the percent ofproduction 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 ofuse ofthe new chemical substance by function and application
.. (2)

-- Mark (X) 

### this column ifentry column (I) is confidential business information (CBI). (3)

-- 

### Indicate your willingness to have the information provided in column (I) binding. (4)

-- Estimate the percent oftotal production for the first three years devoted to each category ofuse. (5)

-- 

### Mark (X) 

### this column ifentry in column (4) is confidential business information (CBI). (6)

-- Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, orgels as manufactured for commercial purposes at sites under your control associated with each category ofuse. (7)

-- 

### Mark (X) 

### this column ifentry in column (6) is confidential business information (CBI). (8)

-- Indicate % ofproduct 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) binding. (9)

-- 

### Mark (X) 

### this column ifentry(ies) in column (8) is (are) confidential business information (CBI). Category ofuse (I ) CBI Binding 

### Produc- CBI %in CBI %ofsubstance expected per

### use CBI Option 

### tion% Form- (8) 

### (by function and application i.e. adispersive dye Mark (x) 

### ulation Site- Con-* Indus- Com- Binding for finishing polyesterfibers) (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. 

### % % % % % % % % % % * Ifyou have identified a "consumer" use, please provide on acontinuation sheet adetailed description ofthe use(s) ofthis chemical substance in consumerproducts.

In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumerproducts and describe the chemical reactions by which this substance loses its identity in the consumerproduct. 0Mark (X)

### this box ifyou attach acontinuation sheet. b. Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter ageneric description ofthat category. Read the use Instructions Manual for examples ofgeneric use descriptions. description


# 0 Mark (X)

### this box ifyou attach acontinuation sheet. 3. Hazard Information

- Include in the notice acopy ofreasonable facsimile ofany hazard warning statement, label, material safety data sheet, orother Binding



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

### forthe safe handing, transport, use, ordisposal ofthe new substance. List in part III hazard information you include. Mark(x) 

# [g) Mark (X)

### this box ifyou attach hazard information.

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

### p.8 

## EXPOSURE Section A-- 

### INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER box nextto any Complete section A for each type 

### ofmanufacture, 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 havereporting requirements if there are further industrial oruse · after · You must describe these See 

### instructions manual 1.



### Site address (number and street)

Ifthe same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates oroperations, 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 yourprocess description binding. (I) 

### Diagramthe majorunit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5

### gallon pails, 55 

### drum, rail car, tanktruck, etc.). you



# X



# X
(2) 

### Provide the identity ,the approximate weight (by kg/day orkg/batch on a I00% 

### new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch.). (3) 

### Identify by numberthe points ofrelease, including small or intermittent releases, to the environmentofthe new chemical substance.



## See Appendix C fora Description ofNCS Processing.

Marl< (X)

### this box if attach acontinuation 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 ofworker activity, physical form ofthe new chemical substance, number ofworks exposed, and duration ofactivity. 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 ifentry 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) ofthe new chemical substance (e.g., solid: crystal, granule, powder, ordust) and% new chemical substance (ifpart ofamixture) at the time ofexposure. (7) --Mark (X) this column ifentry in column (5) is confidential business information (CBI). (8) --Estimatethe maximum numberofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI). (10) and (II)-- Estimate the maximum duration ofthe activity for any worker in hours perday and days per year. (12) --Mark(X) this column ifentries 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) 

# IThere 

# will beno U.S. operations by sites controlled bythe submitter. I 

# I

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

### 3. Environmental Release and Disposal

-- You must make separate confidentiality claims for the release number and the amount ofthenew chemical substance released and otherrelease and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (I)

-- Enterthe numberofeach release point identified in the process description, part II, 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 orkg/batch). (3) --Mark (X) this column ifentries 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, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. Forreleases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA 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 ortertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day). (6) --Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBI). (7) --IdentifY the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publici Owned Treatment Works). Mark (X) ifthe POTW name orNPDES #isconfidential business information (CBI). Release Amount ofnew 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 ifyou 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 oruse operations involving the new chemical substance at sites you do not control. Importers do not have to completethis sectionfor operations outside the U.S.; however, you must report any processing oruse activities after import. Seethe Instructions Manual. 

### Complete aseparate section B for each type of processing, oruse operation involving the new chemicalsubstance. Ifthe same operation isperformed atmore than one sitedescribe 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 orbracket 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 thediagram, identify by letter and briefly describe each worker activity. (2)- Provide the identity, the approximate weight (by kg/day orkg/batch, on an I00% new chemical substancebasis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch). (3)

-- Identify by numberthepoints ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. ( 4) Please enterthe# ofsites (rememberto identify the locations of these sites on a continuation sheet):
#ofsites 

# See 

# AttachmentB for description ofcustomerapplication.



# D Mark (X) this box ifyou 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) --Estimatethenumber ofworkers exposed for all sites combined. (4) --Estimatethetypical duration ofexposure perworker in (a) hours per day and (b) days peryear. (6) -Describephysical form ofexposureand% new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, usedto protect workers. (7) -Estimatethepercent ofthe new substance as formulated when packaged orused as a final product. (9) --Fromthe process diagram above, enterthenumberofeach release point. Complete 9-13 for each release point identified. (10) --Estimatethe amount ofthenew substance released (a) directly to the environment or(b) into control technology to the environment (in kg/day orkg/batch). (12)

-- Describe media ofrelease i.e. stack air, fugitive air(optional-see Instructions Manual), surface water, on-site oroff-site land orincineration, POTW, orother (specify) and control technology, ifany, that will be used to limit the release ofthe new substanceto the environment. ( 14)

-- Identify byproducts which may result from the operation.

(3), (5), (8), (11), (13) and (15) --Mark (X) this column ifany ofthe proceeding entries are confidentialbusiness information (CBI). Letter #of CBI Duration CBI Protective Equip. I %in CBI Release Amount of CBI Media ofRelease 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 ifyou attach a continuation sheet,

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

## p. 11 

# OPTIONAL POLLUTION PREVENTION INFORMATION To claim information inthis section as confidential circle orbracket the specific information that you claim as confidential. 

## In this section you mayprovide information not reported elsewhere inthis form regarding your efforts to reduce orminimize potential risks associated with activities surrounding manufacturing, processing, use and disposal ofthe PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and safer processes orproducts available due to the new chemical substance. Sourcereduction includes the reduction in the amount ortoxicity ofchemical wastes bytechnological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the reclamation ofuseful chemical components from wastes that would otherwisebetreated orreleased 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 existingregulatory requirements and can be either quantitative orqualitative. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks to other environmental media ornon-environmental areas (e.g., occupational or consumer exposure). In 

## addition, information onthe relative cost orperformance characteristics ofthe PMN substance to potential alternatives maybeprovided. 

## All information provided in this section will be taken into consideration during the review ofthis substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. Describe the expected net benefits, such as (1) an overall reduction inrisk to human health orthe environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation ofwaste materials through recycling, source reduction orothermeans; (4) a reduction inpotential toxicity orhuman exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance maybe a substitute for anexisting substance that poses a greater overall risk to human health orthe environment.



## No information is available at this time.

[ ] Mark (X) this box ifyou 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 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 ofthe form to which itrelates, ifappropriate. Number consecutively the pages ofthe attachments. In the column below, enter the inclusive page numbers ofeach 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 ofthe notice form a sanitized version ofany 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 ifyou 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'sreview ofphysical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page ofthe notice on which theproperty appears, the value ofthe property, theunits in whichtheproperty is measured (as necessary), and whether ornot the property is claimed as confidential. The physical state ofthe neat substance shouldbeprovided. These measured properties should be for the neat (I00%pure) chemical substance. Properties that are measured for mixtures orformulations should be so noted (% PMN substance in_). You are not required to submitthis worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential information is properlyprotected. You should submit this worksheet as a supplement to your submission oftest data. This worksheet is not a substitute for submission oftest data. Property Mark Page Value Measuredo Confi- (X) if number Estimate dcntial (a) provided (b) (c) Mark (X) (MorE) (d) 

### X..ight yellowpowder M Physical state ofneat substance X (s) 

### (l) (g) Vaporpressure 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 waterpartition coefficient Not Determined Henry's Law constant NotDetermined Volitalization from water Not Determined Volitalization from soil Neutral (ca. 7) E pH@ concentration 1-10% Non-flammable E Flammability Not Determined Explodability NotDetermined Adsorption 

### I coefficientOtherEPA FORM 7710-25 (Rev. 5-95) Page 13

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# PAGE Al IS CONFIDENTIAL BUSINESS INFORMATION AND HAS BEEN REMOVED FROM THIS SANITIZED VERSION

## DESCRIPTIONOF USE 

# APPENDIXB CUSTOMERUSE APPLICATION p.15



## Themanufacturers ofintegrated circuits and other devices which would use products containing theNCS exercise extreme care inthe use ofthe product to avoid contactbetween theirpersonnel and the product. The manufacturingprocess for theproduction ofintegrated circuits requires this exceptional care. Personal protectionis provided via engineering controls (e.g. laminar flow ventilation in "cleanroom" orlocal exhaust for otherprocessing equipment) and personnel protective equipment use. Personnel in clean room environments are typicallyrequired 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 orplasticbottles, double wrapped inplasticbags. The first bagis 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 inthe clean room environment. This process is employed to minimize the contaminants introduced into the cleanroom. The product is then opened and a fully enclosed autodispense tube and pump are employed to apply carefullymeasured amounts ofphotoresist to the silicon 

## Ipassivation layers (substrates), where either these are used as insulation resins for waferprocessing 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. Duringthe spinningprocess approximately 85% ofthe product is spun offthe wafer. This waste is usually collected in a catch basinbelow the substrate spinning with some photoresistbeing deposited inthe spinbowl. High level ofair exhaust is employed during the spinning process to facilitate the formulation ofdefect free films. This exhaust also effectivelyisolates the operators from any exposure with the resist during the spinningprocess. The product is either deposited inthe spinbowl or is captured in an integrated waste system during the wafer coating operation. Spinbowls are cleaned frequently bytrained and properly equipped personnel. Photoresist waste is dissolved in an appropriate cleaning solvent, collected on a segregated basis and disposed ofprincipally viaincineration. Personnel contact with the NCS Chemical is possible during cleaning ofthe spin bowl or wafer spinner. However, the likelihood ofthis occurring is remote due to the use oflocal exhaust ventilation and personnel protective equipment as described above. 

## Activity 3/Release R2 Within the samephotolithographic tool described above, the photoresist on the wafer is then dried and imaged. Then

**~25%** 

## ofthe dried photoresist is developed and removed from the wafer using an alkaline developer. 3.5% ofthe alkaline waste generated consists ofdried 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

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# APPENDIXC DESCRIPTION OF PHOTORESIST MANUFACTURING PROCESSDESCRIPTION(to be conductedoutside the U.S.) 

## Activity 1 TheNCS is first subjected to a quality control sampling program. This is required to verify the NCS meets the expectedproduct specifications. Testing is conducted in a laboratoryunder controlled conditions. Employees use personal protective equipment (goggles, gloves, laboratory coats or workuniforms) and local exhaust ventilation to protect against inadvertent exposure to the NCS. 

## Activity 2 Blendingthe NCS with other ingredients to produce photoresist occurs in an isolated organic chemical mixing site. All ofthe components ofthe photoresist are introduced manuallyto a totally enclosed mixingtank equipped with a nitrogen gas blanket. After the chemical components are introduced into theblendingtanks, the photoresist is not handled directlybypersonnel. Employees utilize personalprotective equipment (goggles, impervious gloves, workwear) and local exhaust ventilation to minimizepotential worker exposures during the handling and charging ofall raw materials to the mix vessel (this includes thehandling ofcontainers and any waste packaging orraw materials). 

## Activity 3 Thephotoresist containing the NCS is subjected to an in-process quality control sampling program. This is required to verifythe photoresist meets the expected product specifications. Testing is conducted in a laboratoryunder controlled conditions. Employees use personal protective equipment (goggles, gloves, laboratorycoats orwork uniforms) and local exhaust ventilation to protect against inadvertent exposure to the NCS. 

## Activity 4 Followingblending, 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 cleanroom environments are typicallyrequired 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 oftheNCS left in the equipment is minimal. Personal protection is provided as above.

# PAGES A4 THROUGHAlO ARE CONFIDENTIAL BUSINESS INFORMATION AND HAVE BEEN REMOVED FROMTHIS SANITIZED VERSION p.17