Form Approved O M .B. No . 2070-0012 U

. A proval Expires ]0-31-96 .

.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONL

A • Date of receip

Y i

PREMANUFACTURE % ;#EPA NOTICE

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I IIIII t il~'lIftII~~~ (HI ,t~ I $1 I' I'I' 'II ~o~„ Vanv Sanitized

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in the Premanufacture Notice ~

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GENER . INSTRUCTIONS TS

• 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 ifyou do not have actual data .

• Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603 )

• If a user fee has been remitted for this notice (40 CFR 700 .45), indicate in the boxes above the TS-user fee identification number you have generated . Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P

360399M, Pittsburgh, PA 15251-6399, Attn .O . TSCA User fe e

Part I- GENERAL INFORMATION TEST DATA AND OTHER DAT A

You must provide the currently correct Chemical Abstracts (CA) Name of the new You are required to submit all test data in your possession or control and to provide a chemical substance, even if you claim the identity as confidential

. You may authorize description of all other data known to or reasonably ascertainable by you, if these data are another person to submit chemical identity information for you, but your submission wil l

not be complete and the review will not begin until EPA receives this information . A related to the health and environmental effects on the manufacture, processing distribution

letter in support of your submission should reference your TS user fee identification in commerce, use, or disposal of the new chemical substance . Standard literature citations

number. You must submit an original and two copies ofthis notice including all test data . may be submitted for data in the open scientific literature . Complete test data (written in

Ifyou claimed any information as confidential, a single sanitized copy must also be Enelishl, not summaries of data, must be submitted if they do not appear in the open

submitted literature. You should clearly identify whether test data is on the substance or on a n

analog . Also, the chemical composition of the tested material should be characterized .

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

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE the requirements of §720 50 of the Premanufacture Notification Rule (40 CFR Part 720)

.

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

,

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

Part III - LIST OF ATTACHMENTS Test Data (Check Below any included in this notice )

Attach additional sheets if there is not enough space to answer a question fully

each continuation sheet with the corresponding section heading

. Label • Environmental fate data ❑ Yes Other data ❑ Yes . In Part lII, list these

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

notice . ❑ Yes Risk assessments

Environmental effects data ❑ Yes Structure/activity relationships

OPTIONAL INFORMATION PhysicaVChemtcal 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 * A physical and chemical properties worksheet is located on the last page of this form substance . . On page I 1 of this form, space has been provided for you to describe d

pollution prevention and recycling information you may have regarding the new TYPE OF NOTICE (Check Only One)

substance.

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 delays INTERMEDIATE PMN (submitted in sequence wittAnal product PMN) that routinely accompany the development of consent orders or Significant New Us e

Rules. Except in the case of exemption applications (such as T ME A, L VE, LOREX )

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

the Agency approves the exemption application, checking a binding box in this notic 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 w a ~

❑ LVE (Low Volume Exemption) Ca 40 CFR 723 .50(c~~1) -"y ~3

~

You may claim any information in this notice as confidential To assert a claim on the ❑ LOREX (Low Release,Lo~k Exposure Exemption) .4tt0 CFR 723 50(c)(2)

form, mark (X) the confidential box next to the information that you claim as @l

confidential To assert a claim in an attachment, circle or bracket the information you ❑ LVE Modification ❑ LOREX Modification claim as confidential If vou claim information in the notices as confidential, you must

also provide a sanitized version of the notice. (including attachments . For additional ❑

instructions on claiming information as confidential, read the Instructions Manual IS THIS A CONSOLIDA"fED PMN° Yes

® # of chemtcals

Mark (x) if any mfonnanon in this notice is claimed as confidential (Prenotiee Communtcahon : required, enter # oti page 3 )

EPA FORM 7710-25 (Rev . 5 -9 5

) Page I Replaces previous editions ofEPA Form 7710-2 5

~7i ~~~
Public reporting burden for this collection of information is estimated to average 1 10 hours per response, including time for rev i

P- 2

ewing

instructions.

. searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of

information . Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for

reducing this burden, to Chief, Information Policy Branch, PM-223, U .S . Environmental Protection Agency, 401 M . St., S.W., Washington, D .C.

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

CERTIFICATION

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

1 . The company named in Part I, section A, subsection 1 a of this notice form intends to manufacture or import for a

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I,

Section B.

2 . All information provided in this notice is complete and truthful as of the date of submission .

3 . I am submitting with this notice all test data in my possession or control and a description of all other data known to or

reasonably ascertainable by me as required by §720 .50 of the Premanufacture Notification Rule .

Additional Certification Statements :

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

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

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

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

❑ 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.

i

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substanc described herein e . Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001 .

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

Date

X

Signature of agent - (ifapplicable) Date

X

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

Part I -- GENERAL INFORMATION

Section A -- SUBMITTER IDENTIFICATION

Confi- Mark (X) the "Confidential" box next to any subsection you claim as confidential

7

dential

] a Person Name of authorized official Position

Submittin g

Notice (in U S.) X

Compan y

Mailing address (number and street)

City, State, ZIP Cod e

b . Agent (if Name of authorized official Position

applicable)

X

Company

Mailing address ( number and street)

City, State, ZIP Code Telephone Area Code Number

c . If you are submitting this notice as part of a joint submission, mark (X) this box . ❑

Joint Submitter (if Name of authorized official Position

applicable)

X

Compan y

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

2 . Technical Name of authorized official Position

Contact (in

U .S) X

Company

Mailing address ( number and street)

City, State, ZIP Code Telephone Area Code Number

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

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

Mark (X) ---~

if none ❑ X

4 . If you previously submitted an exemption application for the chemica l

substance covered by this notice, enter the exemption number assigned

EPA . If you previously submitted a PMN for this substance enter the by Mark (X) ---{i ❑ X

PMN number assigned by EPA (i .e. withdrawn or incomplete). ---► ifnone

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

for the chemical substance covered by this notice, enter the notice numbe r

assigned by EPA 0 Mark(X) --- {r ❑ X

ifnone

6 . Type of Notice - Mark (X) I' ❑

Only Onl

Manufacture 2 . El Import 3_ ❑ Both

v

❑ Binding Option ❑ Binding Option

Mark (X) Mark (X)

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

Part I -- GENERAL INFORMATION -- Continued

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

the ninth Collective Index (9C1) of CA nomenclature rules and convennons . Mark (X) the "Confidential" box next to any item you claim as confidential

Complete either item I (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 I or 2), mark (X) the box at the right

. Identify the name, company, and address of that person in a continuation sheet

. ❑ dentia l I

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

a

b

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

. 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 9C1 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 be

submitted as an a tt achment to this notice)

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

X

CAS#

X

e . 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

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

diaeram. as comnlete as can he known . if one can he reasonably ascertained

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

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

Part I -- GENERAL INFORMATION -- Continue d

Section B -- CHEMICAL IDENTITY INFORMATION -- Continue d

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

.) Confidential a . Indicate the numbcr-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 an d

below 1,000 absolute molecular weight of that composition

Describe the methods of measurement or the basis for your estimates

. X

: GPC ❑ Other ❑: (Specify)

i) lowest number average molecular weight:

ii) maximum weight % below 500 molecular weight :

iii) maximum weight % below 1000 molecular weight :

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

b . You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information . Mark (X) the "Confidential" box next to any item you claim as confidentia l

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

the polymer.

(2) - Mark (X) this column ifentry 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 entries 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 confidential .

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X) dential residual dential

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

X X X

)

X X X

X X X

X X X

X X X

X X X

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

X X X

c

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

. X

❑ 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 attachment 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 representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained

.

❑ Mark (X) this box if you attach a continuation shee t

EPA FORM 7710-25 (Rev . 5-95) Page 5
Part I -- GENERAL INFORMATION -- Continued p

Section B--,CHEMICAL IDENTITY INFORMATION -- Continue d

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 ('AS Registry Number if available . If there are unidentified impurities, enter "unidentitied . "

(b) - Estimate the Maximum weight % of each impurity . If there are unidentified impurities, estimate their total weight % .

Impurity and ('AS Registry Number Maximum Confi-

(a) (b)

percent dential

X

X

X

X

X

X

X

❑ 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

. Confidentia l

X

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

5

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

X

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

6

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

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

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

.

Modified amidoamine

❑ 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

Number if available . Provide the CAS Registry .

Byproduct CAS Registry Number Confi-

(1) (2) dential

X

X

X

X

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

.

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

consecutive 12-month period during the first three years ofproduction

Estimate the maximum production volume during the first 12 months of production

. Estimates should be on 100% new chemical substance basis For a Low Volume Exemption

. Also estimate the maximum production volume for any . EE

application, if you choose to have your notice reviewed at a lower production volume than 10,000 kg/yr, specify the volume and mark (x) in the binding box . If granted, you are bound to this volume

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

(100% new chemical substance basis) (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 commercial

purposes at sites under your control associated with each category of use.

(7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI) .

(8) -- Indicate % of product volume expected for the listed "use" sectors . Mark more than one box if appropriate . Mark (X) to indicate your willingness to

have the use type provided in (8) binding .

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

.

Category of use (I) Binding Produc- % in % of substance expected per us

e

CBI Option tion % CBI Form- CBI (8) CBI

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

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

X X X X

Option (9 )

X X X X

X X X X

X X X X

X X X X

X X X X

X X X X

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

.

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

substance loses its identity in the consumer product .

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

b . Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category . Read the Instructions Manual for examples of generic use descriptions.

description

Intermediate of various cleaners.

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

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

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

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

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

FPA FORM 7710-25 (Rev . 5-95) Page 7
Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

8

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

claim as confidentia l

Complete section A for each type of manufacture , processing. or use operation involving the new chemical substance at industrial sites you control . Import ers do not have to complete this section for operations outside the U .S , however, }ou may still have repo rt ing requirements if there are further industrial processing or use operations after import. You must describe these operations . See instructions manua l

I Operation description Contia . Identity -- Enter the identity of the site at which the operation will occur dential

Name

X

Site address ( number and street)

City, County, State, ZIP cod e

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

additional sites on a continuation sheet, and if any of the sites have significantly different X

production rates or operations, include all the information requested in this section for thos e

sites as attachments.

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

b . Type --

Mark (X)

D

Manufacturing

c . Amount and Duration -- Complete I or 2 as appropriate

E]Processing OUse X

Maximum kg/batch (100% new Hours/batch Batches/year

chemical substance) X

l . Batch

Maximum kg/day ( ioo^i new chemical Hours/day Days/year

2 . Continuous

subslance) ~

d . Process description

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

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

. Include interim storage and tr an sport containers (specify- e

. X

.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 subst an ce basis), and entry point of all start ing materials and feedstocks ( including reactan ts, solvents, catalysts, etc .), and of all products, recycle streams, an d wastes. Include cleaning chemicals ( note frequency if not used daily or per batch .).

(3) Identify by number the points of release, including small or intermi ttent releases, to the environment of the new chemical substance .

❑ M ark (X) this box if you att ach a continuation sheet

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

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

Section A--.INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continue d

2 . Occupational Exposure-You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, number of works exposed, and duration of activity . Mark (X) the "C'ontidential" 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 (I ) is confidential business information (CBI).

(3) --Describe any protective equipment and engincering controls used to protect ~Norkers .

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

(5) -- Indicate the physical fonn(s) of the new chemical substance (e .g ., solid . crystal, granule, powder, or dust) and % new chemical substance (if part of a mixtut'e)

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 (I 1) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year

.

( 1 2) -- Mark (X) this column if entries in columns (10) and (I 1) are confidential business information (CBI)

.

Physica l

Worker activity CBI Protective Equipment/ Binding forms (s) Binding C'B1 # of CBI Maximum Duration CBI

(i .e., bag dumping, filling drums) Engineering Controls Option and % new Option Workers Hrs/day Days/y

r

Mark (x) substance Mark (x) Exposed

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12

X X X X

)

X X X X

X X X X

❑

X X X X

X X X X

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

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

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

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

.

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

.

(3) --Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI) .

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

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

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

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

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

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

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

.

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

NPDES numbers of the POTW (Publicly Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CBI)

.

Release Amount of new substance Media of releas e

Number released CBI e.g . stack air Control technology and efficiency (you may wish to optionally attach efficiency data) CBI

(1) (2a) T

(2b) (3) (4) (5a) Binding (5b) (6)

X X

Mark (X )

X X

X X

X X

X X

(7) Mark (X) the

destination (s) of releases X waterway Specif

❑ POTW provide name(s) below : CBI ❑ Navigable ❑ Other provide NPDES # CBI

to water X

y

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

EPA FORM 7710-25 (Rev . 5-95) Page 9
Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued

Section B -- ,INDUSTRIAL SITES CONTROLLED BY OTHER S

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 niust report any processing or use activities after import. See the Instructions Manual . Complete a separate section

B for each type of processing, or use operation involving the new chemicnl 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 cornersions, 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):

# of sites

Confidential Business Information Has Been Removed.

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

2 . Worker Exposure/Environmental Releas e

(1) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described .

(2) -- Estimate the number of workers exposed for all sites combined .

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year

.

(6) --Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to

protect workers.

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

.

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

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

.

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

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

.

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

(3),(5),(8),(I 1),(13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI).

Protective Equip . /

Letter # of Duration Eno bineering Controls/ Amount of

%in New Media of Release of Workers of Physical Form and % Fomi- Release Substance & Contro

Activity Exposed CBI Exposure CBI new substance l

ulation CBI Number Released CBI Technology CBI

(t) (2 ) (3) (4a) (4b) (5) (6) (7)

X X X

(8) (9) (toa) (tOb) (I1) ( 1 2) (13)

X X

X X X X X

X X X X X

X X X X

J

X

(14) -- Byproducts :

(15)

X

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

EPA FORM 7710-25 (Rev 5-95) Page 10
P. 11

OPTIONAL POLLUTION PREVENTION INFORMATIO N

To claim information in this section as confidential circle or bracket the speci fi c information that you claim as confidential .

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal

of the PMN substance. Please include new information pertinent to pollution prevention, including source

reduction, recycling activities and safer processes or products available due to the new chemical substance

.

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological

modification, process and procedure modification, product reformulation, raw materials substitution, and/or

inventory control . Recycling refers to the reclamation of useful chemical components from wastes that would

otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution

prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance

with existing regulatory requirements and can be either quantitative or qualitative . The EPA is interested in the

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting

of risks to other environmental media or non-environmental areas (e .g., occupational or consumer exposure). In

addition, information on the relative cost or performance characteristics of the PMN substance to potential

alternatives may be provided .

All information provided in this section will be taken into consideration during the review of this

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and

examples.

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment ; (2) a reduction in the volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means ; (4) a

reduction in potential toxicity or human exposure and/or environmental release ; (5) an increase in product performance, a decrease in

the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemica l

substances used in similar application ; or (6) the extent to which the new chemical substance may be a substitute for an existing

substance that poses a greater overall risk to human health or the environment

.

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

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

Part III -- LIST OF ATTACHMENT S

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 a tt achment and the section of the form to

which it relates, if appropriate . Number consecutively the pages of the attachments . In the column below, enter the inclusive page

numbers of each attachment .

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on

how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized

version of any attachment in which you claim information as confidential .

Attachment name Attachment Confipage number(s) dential

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

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

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and

include i t in the notice . Identify the property rneasured, the page of the notice on which the property appears, the value of the property, the

units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . The physical state of the

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

measured for mixtures or formulations should be so noted (%, PMN substance in _). You are not required to submit this worksheet;

however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential information is properly

protected . You should submrt this worksheet as a supplement to your submission of test data . This worksheet is not a substitute for

submission of test data

Property Mark Page Value Measured Confi-

(X) if number or dential

provided Estimate Mark (X)

(a) (b) (c) (M or E) (d)

X

Physical state of neat substance (s) (1) (g)

X

Vapor pressure

@ Temperature 0C Tort

Density/relative density g/c

X

m3

Solubility X

@ Temperature °C

Solvent g/

X

Solubility in water @ Temperature °C g/

Melting temperature °

X

X

Boiling / sublimation temperature@ torr pressure °C

X

Spectra

X

Dissociation constant

x

Particle size distribution

x

Octanol / water pa rtition coefficient

x

Henry's Law constant

x

Volitalization from water

x

Volitalization from soil

x

pH concentration

x

Flammability

Explodability X

X

Adsorption / coeffi cient

x

Other - Specify

x

X

EPA FORM 7710-25 ( Rev . 5-95) Page 13 Replaces previous editions of EPA Fomi 7710-25.
p. 14

r ~

Material Safety Data

Sheet

Date Prepared : 8/20/03 ` Supersedes Date: 6/03/03

1 . PRODUCT AND COMPANY DESCRIPTION

Emergency Phone Numbers :

FOR EMERGENCIES INVOLVING A SPILL, LEAK, FIRE, EXPOSURE OR ACCIDENT

CONTACT: CHEMTREC (8~-424-~300 within the United States or 703-527-3887 for

international collect calls) o ,

1

For Product Information :

Chemical Name or Svnonvm :

2. GOMPOSITIONIINFORMATION ON INGREDIENT S

Component CAS Reg OSHA Percentage

Number Hazard

3 . HAZARDS IDENTIFICATION

A. EMERGENCY OVERVIEW :

Physical Appearance and Odor:

14
p. 15

Warning Statements:

WARNING!! EYE IRRITANT .

B . POTENTIAL HEALTH EFFECTS :

Acute Eye :

Irritant. Can cause redness, irritation, tissue destruction, on prolonged contact .

Acute Skin :

Low acute dermal toxicity . Slightly irritating . May cause redness, irritation .

Acute Inhalation :

Inhalation not likely . Mists may cause respiratory tract irritation .

Acute Ingestion :

Harmful if ingested . Can cause nausea, diarrhea, abdominal cramps .

Chronic Effects :

This product does not contain any ingredient designated by IARC, NTP, ACGIH or OSHA as

probable or suspected human carcinogens .

4. FIRST AID MEASU RES

FIRST AID MEASURES FOR ACCIDENTAL:

Eye Exposure :

Hold eyelids open and flush with a steady, gentle stream of water for at least 15 minutes . Seek

medical attention .

Skin Exposure :

In case of contact, immediately wash with plenty of soap and water for at least 5 minutes . Seek

medical attention. Remove contaminated clothing and shoes. Clean contaminated clothing and

shoes before re-use .

Inhalation :

Inhalation is not an expected route of exposure . If respiratory irritation or distress occurs remove

victim to fresh air. Seek medical attention if respiratory irritation or distress continues .

Ingestion :

If victim is conscious and a!ert, give 1-2 glasses of water to drink . Do not give anything by mouth

to an unconscious person . Seek medical attention . Do not leave victim unattended .

MEDICAL CONDITIONS POSSIBLY AGGRAVATED BY EXPOSURE :

Skin contact may aggravate existing skin disease .

NOTES TO PHYSICIAN :

All treatments should be based on observed signs and symptoms of distress in the patient . Consideration should be given to the possibility that overexposure to materials other than this

product may have occurred .

15
p. 16

Treat symptomatically . No specific antidote available .

5 . FIRE FIG HTING MEASURES

FIRE HAZARD DATA :

Flash Point:

Method Used :

Closed cu p

Flammability Limits (vol/vol%) : Lower : Upper:

No Data No Data

Extinguishing Media :

Recommended (small fires): dry chemical, carbon dioxide, Recommended (large fire) : alcohol

foam, universal foam, water spray, Not recommended : water jet (frothing possible).

Special Fire Fighting Procedures :

Firefighters should wear NIOSH/MSHA approved self-contained breathing apparatus and full

protective clothing.

Unusual Fire and Explosion Hazards :

Product will burn under fire conditions .

Hazardous Decomposition Materials ( Under Fire Conditions) :

oxides of nitroge n

oxides of carbon

6 . ACCIDENTAL RELEASE MEASURES

Evacuation Procedures and Safety :

Wear appropriate protective gear for the situation . See Personal Protection information in Section

8.

Containment of Spill :

Follow procedure described below under Cleanup and Disposal of Spill .

Cleanup and Disposal of Spill :

Absorb with an inert absorbent . Sweep up and place in an appropriate closed container (see

Section 7 : Handling and Storage). Clean up residual material by washing area with water . Collect washings for disposal .

Environmental and Regulatory Reporting :

Do not flush to drain . Spills may be reportable to the National Response Center (800-424-8802 )

16
p. 17

and to state and/or local agencies .

7 . HANDLING AND STORAGE

Minimum/Maximum Storage Temperatures :

4 to 49 C(39 to 120 F)

Handling :

Avoid breathing vapors and mists . Avoid direct or prolonged contact with skin and eyes .

Storage :

Store in tightly closed containers . Store in an area that is dry, well-ventilated, away from ignition

sources, away from incompatible materials (see Section 10 . Stability and Reactivity) .

8 . EXPOSURE CONTROLS/PERSONAL PROTECTION

Introductory Remarks :

These recommendations provide general guidance for handling this product . Because specific

work environments and material handling practices vary, safety procedures should be developed

for each intended application. While developing safe handling procedures, do not overlook the

need to clean equipment and piping systems for maintenance and repairs . Waste resulting from

these procedures should be handled in accordance with Section 13 : Disposal Considerations .

Assistance with selection, use and maintenance of worker protection equipment is generally

available from equipment manufacturers .

Exposure Guidelines :

Exposure limits represent regulated or recommended worker breathing zone concentrations

measured by validated sampling and analytical methods, meeting the regulatory requirements .

The following limits apply to this material, where, if indicated, S=skin and C=ceiling limit :

GLYCERIN

Notes TWA STEL

ACGIH 10 mg/cu m

OSHA 5 mg/cu m

OSHA 10 mg/cu m

Engineering Controls :

Where engineering controls are indicated by use conditions or a potential for excessive exposure

exists, the following traditional exposure control techniques may be used to effectively minimize

employee exposures : general area dilution/exhaust ventilation .

Respiratory Protection :

When respirators are required, select NIOSH/MSHA approved equipment based on actual or

potential airborne concentrations and in accordance with the appropriate regulatory standards

and/or industrial recommendations .

17
p. 18

For reasonably foreseeable industrial end uses of this material, respiratory protection should not

be necessary .

Eye/Face Protection :

Eye and face protection requirements will vary dependent upon work environment conditions and

material handling practices . Appropriate ANSI Z87 approved equipment should be selected for

the particular use intended for this material .

Eye contact should be prevented through use of chemical safety glasses with side shields or

splash proof goggles . An emergency eye wash must be readily accessible to the work area .

Skin Protection :

Skin contact should be minimized through use of gloves and suitable long-sleeved clothing (i .e .,

shirts and pants). Consideration must be given both to durability as well as permeation

resistance .

Work Practice Controls :

Personal hygiene is an important work practice exposure control measure and the following

general measures should be taken when working with or handling this material :

(1) Do not store, use, and/or consume foods, beverages, tobacco products, or cosmetics in

areas where this material is stored .

(2) Wash hands and face carefully before eating, drinking, using tobacco, applying

cosmetics, or using the toilet .

(3) Wash exposed skin promptly to remove accidental splashes or contact with this

material .

9 . PHYSICAL AND CHEMICAL PROPERTIES

Physical and Chemical properties here represent typical properties of this product . Contact the

business area using the Product Information phone number in Section 1 for its exact

specifications .

Physical Appearance :

Odor :

pH:

Specific Gravity: _

Water Solubility:

Melting Point Range :

~8
P. 19

Freezing Point Range :

Boiling Point Range :

Vapor Pressure :

Vapor Density :

10 . STABILITY AND REACTIVITY

Chemical Stability:

This material is stable under normal handling and storage conditions described in Section 7 .

Conditions To Be Avoided :

heat

open flame

spark

Materials/Chemicals To Be Avoided :

strong acids

strong oxidizing agent s

The Following Hazardous Decomposition Products Might Be Expected :

Decomposition Type : thermal

oxides of nitrogen

oxides of carbo n

Hazardous Polymerization Will Not Occur.

Avoid The Following To Inhibit Hazardous Polymerization :

not applicabl e

11 . TOXICOLOGICAL INFORMATION

Acute Eye Irritation :

The following data are for the specified ingredients .

Toxicological Information and Interpretation :

eye - eye irritation, rabbit . Moderately irritating .

19
p. 20

Acute Skin Irritation :

The following data is for the specified ingredient .

Toxicological Information and Interpretation :

skin - skin irritation, rabbit. Slightly irritating .

Acute Dermal Toxicity :

No test data found for product .

Acute Respiratory Irritation :

No test data found for product .

Acute Inhalation Toxicity :

No test data found for product .

Acute Oral Toxicity :

The following data is for the specified ingredients .

Toxicological Information and Interpretation :

LD50 - lethal dose 50% of test species, 1870 mg/kg, rat .

Chronic Toxicity:

This product does not contain any substances that are considered by OSHA, NTP, IARC or

ACGIH to be "probable" or "suspected" human carcinogens .

No additional test data found for product.

12. ECOLOGICAL INFORMATION

Ecotoxicological Information :

No data found for product .

Chemical Fate Information :

No data found for product .

13. DISPOSAL CONSIDERATIONS

Waste Disposal Method :

Chemical additions, processing or otherwise altering this material may make the waste

management information presented in this MSDS incomplete, inaccurate or otherwise

inappropriate. Please be advised that state and local requirements for waste disposal may b e

more restrictive or otherwise different from federal laws and regulations . Consult state and local

regulations regarding the proper disposal of this material .

Container Handling and Disposal :

Any containers or equipment used should be decontaminated immediately after use .

20
p. 21

EPA Hazardous Waste - N O

14 . TRANSPORTATION INFORMATIO N

Transportation Status: IMPORTANT! Statements below provide additional data on listed

DOT classification .

The listed Transportation Classification does not address regulatory variations due to changes in

package size, mode of shipment or other regulatory descriptors .

US Department of Transportation

Shipping Name :

NOT REGULATE D

15 . REGULATORY INFORMATION

Inventory Status

Inventory Status

UNITED STATES (TSCA) Y

CANADA (DSL) Y

EUROPE (EINECS/ELINCS) Y

AUSTRALIA (AICS) Y

JAPAN (MITI) N

SOUTH KOREA (KECL) N

Y = All ingredients are on the inventory .

E = All ingredients are on the inventory or exempt from listing .

P= One or more ingredients fa!l under the polymer exemption or are on the no longer polymer

list. All other ingredients are on the inventory or exempt from listing .

N = Not determined or one or more ingredients are not on the inventory and are not exempt from listing.

FEDERAL REGULATIONS

Inventory Issues :

All functional components of this product are listed on the TSCA Inventory .

SARA Title III Hazard Classes :

Fire Hazard - NO

Reactive Hazard - NO

Release of Pressure - NO

Acute Health Hazard - YES

Chronic Health Hazard - NO
p. 22

STATE REGULATIONS :

This product does not contain any components that are regulated under California Proposition 65 .

16. OTHER INFORMATI O N

National Fire Protection Association Hazard Ratings--NFPA(R) :

2 Health Hazard Rating--Moderate

1 Flammability Rating--Slight

0 Instability Rating--Minima l

National Paint & Coating Hazardous Materials Identification System--HMIS(R) :

2 Health Hazard Rating--Moderate

1 Flammability Rating--Slight

0 Reactivity Rating--Minimal

Reason for Revisions :

Regulatory Review and Update .

Key Legend Information :

ACGIH - American Conference of Governmental Industrial Hygienists

OSHA - Occupational Safety and Health Administratio n

TLV - Threshold Limit Valu e

PEL - Permissable Exposure Limit

TWA - Time Weighted Average

STEL - Short Term Exposure Limit

NTP - National Toxicology Program

IARC - International Agency for Research on Cancer

ND - Not determined

Disclaimer:

The information herein is given in good faith but no warranty, expressed or implied, is made .

** End of MSDS Document **
p. 23

CONFIDENTIAL BUSINESS INFORMATION

Page 23 has been removed.

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