P. 1

Form A t xo x ed . O .M.B. No. 2070-0012 . Approval Expires 10-31-96 .

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY

SANITIZED

PREMANUFACTURE

OWN P D e NOTICE

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111'lil ~I~~~~~ ~~~~ ~~li~l ~~~~~ ~~~~i 1 ~II~~ ~~~~ii iii~i IE~ ~'~~ It

o - 0 0 0 0 3 Company Sanitized

Enter the total number „f pa6es - 2$ i t t P ~ s

17

er

in the Prenianutiacture Notice

GENERAL INSTRUCTIONS TS J M H 0 7 A

• 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 d o

not have actual data .

• Before you complete this form, you should read the "Instructions Manual for Premanufaeture 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 IDnumber 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 TEST DATA AND OTIIFR DAT A

You must provide the currently correct Chemical Abstracts (CA) Name of the new You a re required to submit all test data in your possession or control and to provide

chemical substance, even if you claim the identity as confidential You may authonze a description of all other data known to or reasonably ascertainable by you, if these

another person to submit chemical identity information for you, but your submission will data are related to the health and environmental effects on the manufacture,

not be complete and the review will not begin until EPA receives this information A processing, distribution in commerce, use, or disposal of the new chemical

letter in support of your submission should reference your TS user fee identification substance Standard literature citations may be submitted for data in the open

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 scientific literature . Complete test data ( written in English), not summari es of data,

submitted

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

identify whether test data is on the substan ce or on an analog. Also, the chemical

composition of the tested material should be characterized . Following are

Pan II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE examples of test data and other data. Data should be submitted according to the

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

If there are several manufacture, processing, or use operations to be described in Part II, 720)-

sections A and B ofthis notice, reproduce the sections as needed

Part Ill --- LIST OF ATTACHMENTS

Test Data (Check Below any included in this notice)

Attach additional sheets if there is not enough space to answer a questi on filly Label

each continuation sheet with the corresponding section heading in Pail III, list these Environmental fate data ❑ Yes • Other data ❑ Yes

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

notice • Health effects data ❑ Yes Risk assessments

• Environmental effects data ❑ Yes Structure/activity relationships

OPTIONAL INFORMATION • PhysicallChermcal Properties* ❑ Yes Test data not in the possession

or control of the submitter

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

substance On page I 1 of this form, space has been provided for you to described ' 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 TYPE OF NOTICE (Check Only One)

So-called "binding" boxes are included throughout this form for you to indicate your ® PMN (Premanufacture Notice )

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 delay s

that routinely accompany the development of consent orders or Significant New Use ~ INTERMEDIATE PMN (submitted in sequence with final product PMN)

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

where certain information provided in such notification is binding on the submitter when ~ SNUN (Sigmfcant New Use Notice)

the Agency approves the exemption application, checking a binding box in this nonc e

does not by itself prohibit the submitter from later deviating from the information (except

chemical identity) reported in the form. ~ TMEA (Test Marketing Exemption Application) --

CONFIDENTIALITY CLAIMS E] LYE (Low Volume Exemption) n 40 CFR 723-50(c)(1 )

You may claim any information in this notice as confidential To assert a claim on the El LOREX (Low Release/Low Exposure Exemption) (0 4[) CFR 723 50(c)(2)

form, mark (X) the confidential box next to the information that you claim a s

confidential- To assert a claim in an attachment, circle or bracket the information yo u

al, you must El LVE Modification E] LOREX Modification claim as confidential. Ifyou claim information in the notices as c onfidenti

also prov~de a sanitized version of the notice, ( including attachments . For additional

instructions on claiming information as confidential, read the Instructions Manual IS THIS A CONSOLIDATED PMN1 El Yes

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

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

u0'3'73c;~,

EPA FORM 7710-25 (Rev . 5-95) Replaces previous editions of EPA Form 7710-25.
p. 2

Public reporting burden for this collection of information is estimated to average 110 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:

I

. The company named in Part 1, section A, subsection la 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 . 1 am submitting with this notice all test data in my possession or control and a description of all other data known to or

reasonably ascertainable by me as required by §720_50 of the Premanufacture Notification Rule .

Additional Certification Statements:

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

statement that applies:

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

❑ The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined (d, 40 CFR

700.43) in accordance with 40 CFR 700 .45(b), o r

❑ The Company named in Part I Section A is a small business concern under 40 CFR 700 .43 and has remitted a fee of $100

in accordance with 40 CFR 700 .45(b).

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723_50(c)(1) or a Low release

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification

statements:

❑ The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723 .50.

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

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

❑ If this application is for an LVE in accordance with 40 CFR 723 .50(c)(1), the manufacturer intends to commence

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day

review period_

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance

described he rein. Any knowing and willful misinterpretation is subject to criminal penalty pursuing to 18 USC 19b1 . Confidential

Signa re a title of Authorized Official (Original Signature R ~nred) Date

~

Signature of agent - (if applicable) Date

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

Part I - GENERAL INFORMATION

Section A - tiiTBDIITTER IDENTIFICATION

ContiMark O the "Co

nfidential"` box next ho am subsection ~ ou dauu as wonfidential dential

la . Person Name of authorized official Position

Submitting

Notice (in U.S.) Paul Newcomb Senior Manager Product Regulations

Compan y

J.M . Huber Corporattion

Mailing address (number and street)

1000 Parkwood Circle Suite 1000

City, State, ZIP Code

Atlanta, GA 3033 9

b. Agent (if Name of authorized official Position

applicable)

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

c . If cu arc .uhmittin~ tlus notice a~ part f a joint suhuussirni mark ( Z I thi . b~. ~

Joint Submitter (if Name of authorized official Positio n

applicable)

Company

Mailing address (number and street )

City, State, ZIP Code Telephone Area Code Number

2 . Technical Name of authorized official Positio n

Contact (in

U .S .) Paul Newcomb Senior Manager Product Regulations

Company

J .M. Huber Corporations

Mailing address (number and street)

1000 Parkwood Circle Suite 1000

City, State, ZIP Code Telephone Area Code Number

Atlanta, GA 30339 678 247-7403

3 It c ,,u h. .-r had a(,re n,,

trcr conunumcui' ,n -D ' o ,nceuun ' this notic e

.aid F:F' AnGs'1_neJ a P-' Numher to the notice enter the number Mark (X) --i ► ❑

if none

4 If ~ ou prenwuslc <uhnutteJ in rsernptton .ipphc .dion tor the chemte d

suh.et .nicr Co" ered hNtlus notice, enter the rtienyptwn number is>tanrd bN Mark (X) -~ ► ❑

EPA It von Pre~ wusl~ suhrnrtted .r Pb IN tor this ~ubst .mce enter the if none

F'hIN number assigned h~EFA u r«rtlydrann Or tnc, vuhlete-r-------------►

If <on h .nr suhnutted a nottce,,f Bnna tide intent to manutaeture or mnp,-r t

tor the chaiuc .d .eubst-rnie a-ered bt this notice enter the notice number Mark (X) ~-► ❑

assigned by EPA if none

1 . Manufacture 2. Import

6 . Type of Notice - Mark (X) Only Only 3. ❑ Both

❑ Binding Option ❑ Binding Option

Mark (X) Mark (X)

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

Part I - GENERAL INFORMATION -- Continue d

Section B-- CHEMICAL IDENTITY INFORMATION: i-,w must l,r„,, idr .i currentl~ e„rretWlxnut .d ahstri d v i CA, n:imr „i the suhst .incr b .isr~ „n

the nmth ,',dkcri~ r InJes o ?-I mxnencloture rules :md ,,,,nccnLwn,

Mark (X) the "l' o ntidential " box nett t o anc item N o u claim a., confidential

Complete either item 1(Class I 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 . ConfiIdentif\ the nautz_ ",nipau ,

. and addrea, of that person in a continuation hrzt, - ❑ dential

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

a. Class of substance - Mark (X) 1 1:1 Class I or 2 ® 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 X

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).

Method 1(CAS Inventory Expert Service - a copy of the Identification ❑ Method 2 (Other Source)

report obtained from the CAS Inventory Expert Services must b e

d

. Molecular formula and CAS Registry Number (if a number already exists for the substance)

submitted as an attachment to this noti ce ) E

X

CAS4

X

C . For a class I substance, provide a complete and correct chemical structure diagram . 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 X

range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure

diapram, as complete as can be known, if one can be reasonably ascertained.

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

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

Part I - GENERAL INFORMATION - Continued

Section B -- ('HEnII('AI. IDENTITY INFORIA IATION -- Continued

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

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

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

below 1,000 absolute molecul ar weight of that composition.

Descri be the methods ofmeasurement or the basis for your estimates: GPC ❑ Other ❑: (Specify)

i) lowest number average molecular weight:

ii) maximum weight % below 500 molecul ar weight:

iii) maximum weight % below 1000 molecul ar 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 specifi c chemical name and CAS Registry Number ( if a number exists) of each monomer or other reactant used in the manufacture of

the polymer.

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

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

(4) - 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 .

(5) - Mark (X) this column if ent ries 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 if entry in column (6) is con fidential .

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark 1 l l dential residual dential

(1) (2) (3) (4) (5) (6) (7)

" o

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

c . Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice ( check one).

❑ Method 1(CAS Inventory Expert Service - a copy of the identification report ❑ Method 2(other source)

obtained from CAS Inventory Expert Service must be submitted as

as atta diment to this notice )

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

C. Provide a correct representati ve or pa rt ial chemical structure diagram, as complete as can be known, if one can be reasonably ascertainedEPA FORM 7710-25 (Rev. 5-95) Page 5
p. 6

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

Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITI INFORAIATION -- Continue d

3 . Impuritie s

(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 . "

(bt - Estimate the maximum weight 00 .4 each iui writ N . It'thzre are unidentified un uritirs . estimate their t otal vk ri ~ght °o.

Impurity and CAS Registry Number Maximum Confipercent dential

la) lh)

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

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

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

5 . Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2_

Hymod M932-SN

El M ark (X) this box if you attach a continuation shee L

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

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

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

Aluminum trihydrate surface treated

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

7 . Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance . Provide the CAS Registry

Number if a N ailablr.

Byproduct CAS Registry Number Confi-

(1) (2) dential

X

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

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25 .
p. 7

Part I -- GENERAL INFORMATION - Continued

Section C - PRODUCTION, IMPORT, AND USE INFORMATION :

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

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

production volume for any consecutive 12-month period during the first three years of production . Estimates should be on 100% new chemical

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000

k specify the volume and mark (x) in the binding box. If led, 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) (100% new chemical substance basis) dential option Mark x

X

2. Use Information - You must make separate confidentiality claims for the description of the category of use, the percent of production volume

devoted to each category, the formulation of the new substance, and other use information . Mark (X) the "Confidential" Box next to any item

you claim as confidential.

a

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

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI) .

(3)- Indicate your willingness to have the information provided in column (1) binding .

(4) -- Estimate the percent of total production for the first three years devoted to each category of use .

(5)- Mark (X) this column if entry in column (4) is confidential business information (CBI) .

(6) - Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for

cotnmercial 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 en ies in column (8) is (are) confidential business informa tion (CBI).

Category of use (1) CBI Bir~g Produc- CBI % in CBI % of substance expected per use CBI

Oi6O° tion % Form- (8 )

(by function and application i .e. a dispersive dye MaEk (X) ulation Site- Con-* Indus- Com- Binding

for finishing polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9 )

Flame Retardant % X "'• X X

e/ ej

0 0/

oi o

oi e

% o

o' •

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products .

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

substance loses its identity in the consumer product .

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

b

. Generic 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

❑ 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 Bindmg

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

for the safe handing, transport, use, or disposal of the new substance . I,ist in part Ill hazard information you include .

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

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

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEAS E

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you

claim as contidentia l

Complete section A for each type of manufachire . Ixoces.urg. or use operation imolN ilig the neNN chemical suhst,utce at uulustrial sites \-Oil

control. Importers do not have to complete this section for operations outside the U .S. : hoxi eNer. N ou may still lliiNe reporting requirements if

there are further industrial vcxestim« or use o perttions after import Y ou must describe the se operations. See instructions manua l

1 . ( )peration description Contia . Identity -- Enter the identit\ of the site at winch the (j)eration N\ ill occur

Name X

dential

Site address (number and street)

City, County, State, ZIP code

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

additional sites on a continuation sheet_ and if any of the sites hM eSiU'llilicanth different

production rates or operations. include all the information requested in this section fi)r those

sites a ,

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

h . T%

Mark (X) ElManufacturing ❑Processing ❑Use

c . Ainount and Duration -- Complete I or 2 a s, appropriat e

Maximum kglbatch ( toosc new cl erincat Hours/batch Batches/year

subs ance )

1 . Batch

Maximum kg/batch (too^i new chemical Hours/batch Batches/year X

substance )

2 . Continuou s

d. Process

(1) Diagram the major unit operation steps and chemical conversions

description n

Mark (X) to indicate your willingness to have your process

. Include interim storage and transport containe

description binding . X

rs (specify- e .g . 5 gallon pails, 55 gallon

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

(2) Pro vide the identity , the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not

used daily or per batch).

(3) Identify by number the points of release, including small or intermittent releases, to the envir onment of the new chemical substance.

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

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

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

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued

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

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

(1) -- Describe the activities (i.e . bag dumping, tote filling, unloading drums, sampling, cleaning, etc .) in which workers may be exposed to the substance.

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

(3) -- Describe any protective equipment and engineering controls used to protect workers.

(4) and (

6) -- Indicate your willingness to have the information provided in column (3) or (5) binding.

(5) -- Indicate the physical form(s) of the new chemical substance ( e.g., solid: crystal, granule, powder, or dust) and % new chemical subst ance (if part of a mixture)

at the time of exposure.

(7) -- Mark ( X) this column if entry in column (5) is confidential business information (CBI).

(

8) -- Estimate the maximum number of workers involved in each activity for all sites combined .

(9) -- Mark ( X) this column if entry in column ( 8) is confidential business information (CBI).

(10) and (11) -- Estimate the maximum duration of the ac ti vity for any worker in hours per day and days per year.

(12) -- Mark this column if entries in columns (10) and 11 are confidential business informati on (CBI)-

Worker activity CBI Protective Equipment' Balding Physical forms(s) Bmdu+x CBI # of CBI Maximu duration CBI

in

( i.e ., bag dumping, filling drums) Engineering Controls option and % nep' OP°oi Worker Hrs/day Days/yr

Mark ( x) substance

Mark (x)

(1) (2) (3) (4) (5) (6) ("T) Expose (9) (10) (11) (12)

d

(8)

X Safety Glasses, X X X

Gloves

X Safety Glasses, X X X

Gloves

X Safety Glasses, X X X

Gloves

❑ 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 con fidential.

( 1) -- Enter the number of each release point identified in the process description, part II, section A, subsection ld(3) .

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

(3) -- Mark (X) this column if entries in columns ( 1) and (2) are confidenti al 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 re leased from that re lease 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 l and, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste . On a continuation sheet, for

each site descri be 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 cont rol 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 POTW (Publicly Owned Treatment Works). Mark ( X) if the POTW name or NPDFS # 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) C BI

Number released release

(1) (2a) (2b) Mamde~

1 X X

(3) (4) (5a) (Sb) (6)

2 X X

3 X X

4 X

X X

X

(7) Mark (X) the ❑ POTW provide name(s) below: BI ❑ Navigable ❑ Other - Specify provide NPDES # CBI

destination(s)of waterway

releases to water. NO RELEASE TO WATER

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

EPA FORM 7710-25 (Rev. 5-95) Page 9
P. 10

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continue d

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 contr ol . 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

secti onB 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_ Identify 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 .

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

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity . (2) -- 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) - 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):

1

1! of sites

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

2 . Worker Exposure/Environmental Release

( 1) -- From the diagram above, provide the lett er 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 an y, used to

protect workers.

(7) -- Estimate the percent of th e 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 identifie d

( 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, fugiti ve air (optional-see Instructions Manual), surface water, on-site or off-site land or incinerati on, 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 . / % 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

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (l0b) (11) (12) (13)

14) -- Byproducts

-7

: (15)

T__

E] 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 du ring 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.

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

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

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 confidenti al.

Attachment name Attachment Confipage number(s) dential

Material Safety Data Sheet 13-16

Physical Properties 17

Manufactu ringProcess 18-19 X

Risk Assessment 20-21 X

CAS IES Report 22 X

PMN Substance Structure 23 X

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

EPA FORM 7710-25 (Rev. 5-95) Page 12
p.13

MATERIAL SAFETY DATA SHEET

jJJ R

A FAMILY 01- S01-UTIONS

HYMOD® M932-S N

REVISION NUMBER: 0.1 REVISION DATE: 29/Jan/2007

1 . IDENTIFICATION OF THE SUBSTANCE / PREPARATION AND COMPANY I

UNDERTAKING

PRODUCT NAME: HYMOD® M932-SN

MANUFACTURER: J.M. Huber Corporation

1000 Parkwood Circle Suite 1000

Atlanta, GA 3033 9

Tel: 678-247-7300

EMERGENCY TELEPHONE : CHEMTREC : 800-424-9300 or 703-527-3887 International

INTERNET: www.hubermate rials .com

2. HAZARDS IDENTIFICATION

EMERGENCY OVERVIEW: This is a non-combustible, odorless white powder.

POTENTIAL HEALTH EFFECTS:

EYE CONTACT: Dust may cause mechanical irritation to eyes .

INHALATION : Inhalation of dust may cause respirato ry tract irritation.

CARCINOGENICITY: This product is not listed as a carcinogen by the IARC, NTP or OSHA .

3. COMPOSITION / INFORMATION ON INGREDIENTS

COMPONENT(S) CAS NUMBER %W/W

ATH Surface Treated Proprietary 100

4. FIRST AID MEASURES

EYE CONTACT: Hold eyelids apa rt and flush eyes with a steady, gentle stream of water for several minutes .

INHALATION : Remove person to fresh air.

GENERAL ADVICE: In case of doubt or when symptoms persist, seek medical attention.

5. FIRE-FIGHTING MEASURES

EXTINGUISHING MEDIA : Non-combustible . All extinguishing media can be used . Use suitable media appropriate for

the surrounding fire.

HYMOD® M932-SN 11 4

°

uff ~ S
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UNSAFE EXTINGUISHING MEDIA None .

SPECIAL EXPOSURE HAZARDS: None .

SPECIAL PROTECTIVE EQUIPMENT: Firefighters should wear protective clothing and use equipment that is suitable for

the materials involved in the surrounding fire .

6 . ACCIDENTAL RELEASE MEASURES

PERSONAL PRECAUTIONS : Avoid dust formation . In case of exposure to high levels of airborne dust, wear a personal

respirator in compliance with national legislation .

ENVIRONMENTAL PRECAUTIONS: Keep product from entering drains and waterways .

CLEAN UP METHODS: Collect mechanically and or by flushing with water. Avoid dry sweeping. Use water spraying or

ventilated vacuum system to prevent dust forma tion.

7. HANDLING AND STORAG E

HANDLING: Avoid dust formation . Provide appropriate exhaust ventilation in places where dust is formed . In case of

insufficient ventilation, wear suitable respirato ry equipment.

STORAGE: Keep containers closed and protect from physical damage . Store in a d ry area.

8 . EXPOSURE CONTROLS / PERSONAL PROTECTION

EXPOSURE LIMIT VALUES:

ENGINEERING CONTROLS: Use mechanical ven tilation (dilution and local exhaust) to control exposure .

EYE PROTECTION : Safety glasses with side shields .

SKIN AND BODY PROTECTION: Use suitable protective clothing, gloves and footwear, selected with regard for use

conditions and exposure potential.

HAND PROTECTION : Impervious gloves chemical resistant.

RESPIRATORY PROTECTION : In case of exposure to high levels of airborne dust, wear a respirator in compliance with

national legislation .

HYGIENE MEASURES : Handle in accordance with good industrial hygiene and safety practice .

ENVIRONMENTAL EXPOSURE : Keep product form entering drains and waterways .

9. PHYSICAL CHEMICAL PROPERTIES

APPEARANCE: White Powder ODOUR: Odourless .

pH: 8 .4-10.2, 5% water suspension FLASH POINT: Non-combustible.

DENSITY: 2.4 g/cm3, 20° C WATER SOLUBILITY: Insoluble

DECOMPOSITION TEMPERATURE : 200° C

10 . STABILITY AND REACTIVITY

HYMOD® M932-SN 2/ 4

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10. STABILITY AND REACTIVITY

STABILITY : Stable under ambient temperature (21 °C) and pressure (760 mm Hg) .

CONDITIONS TO AVOID: None

MATERIALS TO AVOID: Strong Acids Oxidizers

HAZARDOUS DECOMPOSITION PRODUCTS : None

11 . TOXICOLOGICAL INFORMATION

ACUTE TOXICITY: No information available .

EYE IRRITATION: Slightly irritating, not classified .

SKIN IRRITATION : Non-irritating .

SENSITIZATION: Does not cause sensitization .

CHRONIC TOXICITY: No evidence of mutagenic, reproductive or carcinogenic effects .

12 . ECOLOGICAL INFORMATION

ECOTOXICITY: No information available .

13 . DISPOSAL CONSIDERATIONS

DISPOSAL : Dispose in accordance with local, state and national regulations .

14 . TRANSPORT INFORMATION

DOT: Not Regulated

15 . REGULATORY INFORMATION

NFPA: HEALTH : 1 FLAMMABILITY: 0 REACTIVITY: 0

HMIS: HEALTH : 1 FLAMMABILITY: 0 PHYSICAL HAZARD : 0

HARMONIZED TARIFF CODE: 2818 3000

AUSTRALIA AICS: Not Listed

CANADA DSL / NDSL: Not Listed DSL / NDSL

CHINA IECSC: Not Listed

EUROPE EINECS: Listed

JAPAN ENCS: Not Listed

KOREA KECI: Not Listed

PHILIPPINES PICCS: Not Liste d

US TSCA : This product is not listed on the US TSCA Inventory and is to be used for Research and Development

purposes under supervision of a technically qualified person.

HYMOD® M932-SN 3/ 4

v~~ ,s
p.16

CERCLA RQ: None

CLEAN AIR ACT: The components of this product are not regulated under any of the following sections of the Clean Air

Act: Section 111 Volatile Organic Compounds, Section 112 Hazardous Air Pollutants, Section 112 Statutory Air

Pollutants, Section 112 High-Risk Pollutants, Section 112(r) Accidental Release Prevention Substances or Section 602

Ozone Depleting Substance. As a powder product, it would be regulated under Section 109 Criteria Pollutants

particulates.

PROPOSITION 65: This product contains no chemicals at levels known to the State of California to cause cancer or

reproductive hazards.

CONEG: We certify that heavy metals defined as lead, mercury, cadmium and hexavalent chromium are not intentionally

introduced to this product and with respect to lead, mercury, cadmium and hexavalent chromium, the incidental level of

these four metals is less than 100 ppm .

16 . OTHER INFORMATION

The information contained in this Safety Data Sheet to the best of J .M. Huber's knowledge and belief as of the date

indicated is believed to be accurate and reliable . However, no representation, warranty or guarantee is implied or

expressed regarding the accuracy, reliability or completeness of this information or the use of the product . Nothing

contained herein should be construed as a recommendation to use this product in conflict with National or local

regulations or existing patents covering any material or its use.

END OF MATERIAL SAFETY DATA SHEET

HYMOD® M932-SN 4/4 '
p.17

PHYSICAL AND CHEMICAL PROPERTIE S

PROPERTY VALUE MEASURED CONFI

OR ESTIMATE DENTIAL

Physical state of Solid Observed NO

neat substance

Vapor pressure <0 .1 mm Hg Usual for NO

@ 20 C minerals

Density 2.4 g/cm Measured NO

Solubility in Slightly Soluble Measured NO

Water @ 20 C

NO

Flammability Flashpoint > Measured NO

100 C

Particle Size D10 0.7-1 .0 Measured NO

microns

D50 1 .5-2 .5

microns

D90 5 .0-6.5

microns

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CONFIDENTIAL BUSINESS INFORMATION

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