# '11tlm11111tll11111111NAN111111lll11l SAN
I 

# TlZED.U.,.,,m

~ Form Approved. O.M.B. Nos. 2070-0012 and 2070-0038 

### ~ 

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

°"'
~ 

### PREMANUFACTURE : ~ 

### •, ; Date of receipt: NOTICE 

# •~ pQ
tl s e FOR NEW CHEMICAL SUBSTANCES

If sending by Courler: VVhen If sending by US Mall: Ofnce of Pollullon Preventlon and Toxics Ofilce of Pollutlon Preventlon and Toxlcs 

## Submission Re iVumber ort -• • •- Document Control O

~ ce (7407M) Document Control Offlce (7407M) -• this US EPA, 1201 Constitution Ave NW US EPA, 1200 Pennsylvanla Ave NW
• • WASHINGTON, D.C. 20460 WASHINGTON, D.C. 20460 

### FEA-110801029581242

Contact Numbers: 202-564-893018940 Fee Pa ment ID Number Total Number of Pa es User TS Number 

### 836 74221799406 D1474P GENERALINSTRUCTIONS

• You must provide all informaGon requested in this fonn to the eMent that it is kcown to or reasonably ascertainable by you. Make reasonable estimates if ycu do not have adual tlata.
• Before you complete lhis fonn, you should road the "Instructions Manual for Premanufacture NotYfication` (the Instrvcbons Manual is availab!o from the Toxic Substances Conlrol Act (TSCA) Infovnation 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). indicale in lhe boxes above lhe TS-user fee identification number you have generated. Remember, your user fee ID number must also appear on your coffesponding fee remittance. For mailing addrese information see the Help instnuctions in the e-PMN tool.

Part I— GENERAL INFORMATION TEST DATA AND OTHER DATA You must provide the currently correct Chemical Abstracts (CA) You are required to submit all test data in your possession or control and to provide a Name of the new chemical substance, even if you daim the description of all other data known to or reasonably ascertainable by you, if these data are identity as confidential. You may aulhorize another person to related to the health and environmental effects on the manufacture, processing, distribution in submit chemical identity information for you, but your submission commerce, use, or disposal of the new chemical substance. Standard literature citations may will nol be complele and the rev ew will not begin until EPA be submitted for data in the open scientific literature. Complete test data (written in English), receives this information. A letter in support of your submission not summaries of data must be submitted if thev do not appear in the open literature. You should reference your TS user fee identifcation number. For all should clearly identify whether test data is on the substance or on an analog. Also, the Section 5 Notice submissions (paper or electronic) you must chemical composition of the tested material should be characte zed. Following are examples submit an original notice including all test data; if you claimed any of test data and other data. Data should be submitted according to the requirements of information as confidential, an original sanitized copy must also be §720.50 of the Premanufacture Notification Rule (40 CFR Part 720). submitted.
Part II — HUMAN EXPOSURE AND ENVIRONMENTAL Test Data (Check Below any included in this notice) 

### RELEASE ❑ If there are several manufacture, processing, or use operations to Environmental fate data Olher Data be described in Part II, sections A and B of this notice, reproduce ❑ the seclions as needed. X ❑ Health effecls dala Risk Assessments
Part III — LIST OF ATTACHMENTS ❑ Environmental effects data ❑ Structure/activity relationships For paper submissions, attach additional sheets if there is not enough space to answer a question fully. Label each continuation ❑ Physical/Chemical Prope rt ies (A physical and chemical prope rt ies worksheet is sheet with the corresponding section heading. In Pa rt III, list lhese located on the last page of this form.) attachments, any test data or other data and any optional information induded in the notice. ❑ Test data not in lhe possession or control of the submitter

OPTIONAL INFORMATION TYPE OF NOTICE (Check Only One) You may include any information that you want EPA to consider in evaluating the new substance. On page 11 of this form, space has ❑ PMN (Premanufacture Notice) been provided for you to describe pollution prevention and ❑ recycling information you may have regarding the new substance. SNUN (Significant New Use Notice) "Binding" boxes are included lhroughout this form for you to indicate your willingness to be bound to certain statements you ❑ make in this section, such as use, production volume, protective TMEA (Test Marketing Exemption Application) equipment ... The intention is to reduce delays that routinely accompany the development of consent orders or Significanl New ❑ LVE (Low Volume Exemption) @ 40 CFR 723.50(c)(1) Use Rules. Checking a"binding" box in a PMN does not by itself prohibit the submitter from later deviating frorn the information ❑ LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(c)(2) (except chemical identity) reported in the form; however, in the case of exemption applications (such as TMFI+,, LVE, LOREX) ❑ LVE Modifir.ation certain information provided in such notifications is binding on the submitter when the Agency approves the exemption application, ❑ LOREX Modifcation especially if the produdion volume "binding" box is chosen in a LVE ❑ Mock Submission CONFIDENTIALITY CLAIMS Mark (X) if pending Letter of Support You may daim any information in this notice as confidential. To assert a claim on the form, mark (X) the conf dential box next lo IS THIS A CONSOLIDATED PMN (Y/N)? the information that you claim as confidential. To assert a claim in an attachment, cirde or brackel the information you claim as — # of chemicals or polymers (Prenotice Communicalion # required, enter # on confidential. If vou claim information in the notices as confidential, P. 3) you must also provide a sanitized version of the notice, (including att achments). For additional instructions on claiming information 

# I as confidential, read the Instructions Manual ❑ Mark (X) if any information in this notice is claimed as ccnfidential.

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 2

# V
SANI 

### TI ZED SUBMISSION

The public reporting and recordkeeping burden for this collection of information is estimated to average 93 hours per response. Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed EPA Form 7710-25 to this address. 

### CERTIFICATION -- A printed copy of this signature page, with original signature, must be submitted with CD or paper submission. 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, import or process for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B.
2. AII 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.
Add'otional Certification Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies:

X ❑ 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 concem 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 Lowr 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. 

# F

— I 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 herein. Any knowing and willful Confidential 

### misrepresentation is subject to criminal penalty pursuant to 18 USC 1001.
Signature and title of Authorized Official (Original Date ® Signature Required)

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 3SANITIZED SUBMISSION PMN2011P3 

# PMN Paae 3 INF ORMATIO 

## N Section A — SUBMITTER IDENTIFICATION Mark X the "Confidentiar' box next to any subsection you claim as confidential 

## 1a. Person Submittin Notice in U.S

. Confidential Name of Authorized Official (first) xxx (last) XXX
Position xlxX 

# a Company XXX Mailing Address (number & street) XXX City xxx State Postal Code xxX email xxx 

### b. A ent if Applicable Confidential Name of Authorized Official (first) (last)

❑ Position Company Mailing Address (number & street) City State Postal Code e-m ail Telephone (inGude area code) 

### C. Joint Submitter if a licable Confidential If you are submitting this notice as part of a joint submission, mark (X) ❑

❑ Name of Authorized Official (first) (last)

Position Company Mailing Address (number & street) City State Postal Code

e-mail Telephone (include area code) 

## 2. Technical Contact in U.S

. Confidential Name of Authorized Official (first) XXX (last) xxx
Position XXX Company XXX Fxl Mailing Address (number & street) XXX City XXX State Postal Code XXX
e-mail xxX Telephone include area code 

### ~
3, If you have had a prenotice communication (PC) conceming this notice and EPA assigned a PC Number to the notice, enter the number. )(XX 

### Mark X if none Confidential ❑ 

### ~

4. If you previously submitted an exemption apptication for the chemical substance covered by this notice, enter the exemption number assigned by EPA. If you previously submitted a PMN for this substance enter the PMN number assi ned bv EPA i.e. withdrawn or incom lete . X 

### ~ 

## Mark (X) if none Confidential

❑ a

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 number assigned by EPA. XXX 

## Mark (X) if none Confidential ❑ 

### ~ 

## 6, Type of Notice — Mark X

1. Manufacture Only ❑ Binding Option ❑ 2. Import Only ® Binding Option ❑ 3. Both ❑

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 4SANITIZED SUBMISSION PMN2011P4 

# PMN Pacqe 4 GENER AL INFORMATION• -• 

### Section S— CI-tENiICAL IDENTITY IrNFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on current CA index nomenclature rules and conventions. Mark (X) the "Confidentiaf' box next to any item you claim as confidential Complete either item 1(Class 1 or 2 substances) or 2(Polymers) as appropriate. Complete all other items. If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right. Identify ❑ the name, com an , and address of that person in a continuation sheet. 1. Class 1 or 2 chemical substances (for definitions of class 1 and class Class 1 Class 2 CBI 2 substances, see the Instructions Manual)
X ❑ ❑ ❑ a. Class of substance - Mark (X) b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA ❑ Preferred Name must be provided, which ever is appropriate based on current CA index nomenclature rules and conventions). 

### 2-Butene, 1,1,14,44-hexafluoro-, (2Z)-

~ 

### -

CAS Registry Number (if a number already exists for the substance) 

### 692-49-9

c. Please identify which method you used to develop or obtain the s ecified chemical identity inf_ ormation re orted in this notice: check one . Method 1(CAS Inventory Expert Service - a copy of the from the CAS Inventory Expert 

# ~ IES Order Method 2 (Other ❑ Identification report obtained Number Services must be submitted as an attachment to this notice 170702 Source Enter Attachment filename for Part I. Section B, 1. c. Attachment for PMN Page 4- CAS IES Response.pdf ❑
d. Molecular formula C4H2F6 ❑

e. For a class 1 substance, provide a complete and correct chemical structure diagram. For a class 2 substance.. provide a correct ❑ re resentative or artial chemical structure dia ram, as com lete as can be known, if one can be reasonabl ascertained. See Attachment 007 (molecular drawing.pdf)

Enter Attachment filename for Part I, Section B, 1. e. molecular

. drawin df 9P ❑

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 5

# 111111111 1111111 ,AN...o.U.w,.o.

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). Confidential e. (1) List the immediate precursor substance names with their respective CAS Registry Numbers. 

# ~

Enter Attachment filename for Part I, Section B, 1. e. (1) 

# ~ e. (2) Describe the nature of the reaction or process. F—I

Enter Attachment filename for Part I, Section B, 1. e. (2) 1:1 e. (3) Indicate the range of composition and the typical composition (where appropriate). El

Enter Attachment filename for Part I, Section B. 1. e. (3) El

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 6

# 1111111111111111111111111111111111111111111111111111111111 v

~ 

# w...

~ 

## Part I-- GENERAL INFORMATION — Continued Section B-- CHEMICAL IDENTITY INFORMATION -- Continued 2. Pol ers 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 molecular wei ht of that com osition. 

# ~

Describe the methods of ineasurement or the basis for your estimates: 

## GPC Other (Specify Below) 

# ~ Specify Other:
(i) lowest number average molecular

weight: (ii) maximum weight % below 500 molecular weight: (iii) maximum weight % below 1000 molecular weight:

Enter Aftachment filename for Part I, Section B, 2. a. b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the "ConfidentiaY' box next to any item you claim as confidential (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 if entry in column (1) is confidential. (3) Indicate the typical weight percent of each monomer or other reactant in the polymer. (4) - Choose "yes" from drop down menu 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 specific chemical name (1) CBI 2 Typical composition 3 Include in identity 4 CBI 5 Max residual 6 CBI 7

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1) Mark (X) this box if the data continues on the next page. 

# ~
EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 7

# i~~~~~ 

# wnemiw

SANITIZED SUBMISSION

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice CBI check one . Method 1(CAS Inventory Expert Service - a copy of the identification report obtained ❑ IES Order 

## Method 2 ❑ from CAS Inventory Expert Service must be Number (other source) submitted as an attachment to this notice Enter Attachment filename for Part 1, Section B, 2. c. ❑ d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar ❑ ol mers.

CAS Registry Number (if a number already exists for the substance)

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ❑ ascertained.

Enter Attachment filename for Part I, Section B, 2. e. 1:1
EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 8

## PMN Paae 6 SANITIZED SUBMISSION 

# Part I-- GENERAL INFORMATION

-- 

# Continued Section B-- CHEMICAL IDENTITY INFORMATION

-- 

## Continued 3. Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide the CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." b- Estimate the maximum wei ht % of each im urit

. If there are unidentified im urities, estimate their total wei ht %. Impurity (a) CAS Registry Number a Maximum

Percent % b Confidential XXX XXX XXX 

## X

XXX XXX XXX 

## X

XXX XXX XXX 

## X

XXX XXX XXX 

## X

Mark (X) this box if the data continues on the next page. ❑

Enter Attachment filename for Part I, Section B, 3. Attachment for PMN Page 6- impurities (public).pdf ❑ 4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. 

## xxx 

# a

Enter Attachment filename for Part I, Section B, 4. 

# Li
5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. Formacel® ❑

Enter Attachment filename for Part I, Section B, 5. ❑ 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.

Enter Attachment filename for Part I, Section B, 6. 7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the

CAS Registry Number if available. Byproduct (1) CAS Registry Number 2 Confidential XXX XXX 

## X

Mark (X) this box if the data continues on the next page. ❑ EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 9

### ,....o,U,.„ON 

## Part I-- GENERAL INFORMATION -- Continued Section C-- PRODUCTION, IMPORT, AND USE INFORMATION: The information on this page refers to consolidated chemical number(s): 1 2 3 ❑ 4 ❑ 5 ❑ 6 

### Martc X the "ConfidentiaP' 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 produdion voiume 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 kg/yr, specify the volume and mark x in the binding box. If granted, ou are bound to this volume. Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confidential Binding Option (100% new chemical substance basis) (100% new chemical substance basis) Mark (X)


# XXX XXX ❑ X ❑
Enter Altachment filename for Part I, Section C, 1. CBI ❑ 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, emutsions, 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 ent ies in column 8 is are confidential business information CBI . Category of use (1) Binding Prod % in % of substance e 8 xpected per use () (by function and application i.e. a dispersive dye for CBI Option uction CBI Form- CBI CBIsRofirrWed co.

cumer ~"~ , co~ ,,.

maca e n a~

opoon finishing polyester fibers) (2) Mark (X) (3) %

(4 6) ulaGon (6) 7 (9) Foam Expansion Agent XXX X XXX X XXX XXX XXX XXX X



## XXX X XXX X XXX X XXX XXX XXX XXX X

x(X X XXX X XXX X XXX XXX XXX XXX X

XXX X XXX X XXX X XXX XXX XXX XXX 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 idenfity in the consumer product. Mark (X) this box if the data continues on the next page. ❑ b. Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. description Read the Instruction Manual for examples of generic use descriptions. Heat transfer fluid

Enter Attachment filename for Part I, Section C. 2. b. CBI ❑ 3. Hazard Information — Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonabiy likely to be exposed to this substance Binding Option regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III Mark (X) hazard information you include. Mark (X) this box if you attach hazard information. El ❑ EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 10

# IIIIIIIII 1111111111111111111111111111111111111111111111 S„IT,ZEDwa,.SIO.

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "ConfidentiaP' box next to any item you claim as confidential The information on pages 8 and 8a refer to consolidated chemical number(s): 1 

# 7 12 3 

### 4 El 5 6 Complete section A for each type of manufacture, processing, or use operation invoiving the new chemical substance at industrial sites you control. Importers do not have to compiete this section for operations outside the U.S.; however, you may still have reporting requirements if there are further industrial processing or use operations after import. You must describe these operations. See instructions manual 1. Operation description Confia. Identit -- Enter the id ntity of the site at which the o eration will occur. dential 

## Name 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 have significantly different production rates or Q ❑
o erations, inciude all the information re uested in this section for those sites as attachments. 4

Mark (X) this box if the data continues on the next page. ❑ b. Type -- Manufacturing ❑ Processing ❑ Use ❑ ❑ Mark (X) c. Amount and Duration — Complete 1 or 2 as appropriate Confdential Maximum kg/batch
1. Batch (100% new chemical substance) Hours/batch Batches/year 

# ~

o Maximum kg/day 100 /o new chemical substance Hours/day Days/year 2. Continuous ❑
Mark (X) to indicate your willingness to have your process description binding. ❑ d. Process description 4 (1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon paiis, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materiais and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicais (note frequency if not used daiiy or per batch.). (3) Identify by number the points of reiease, including small or intermittent releases, to the environment of the new chemical substance. If releasing to two media at the same ste , assi n a second release number for the second medium.

❑



### EPA FORM 7710-25 (Rev. 6-09) Replaces previous edilions of EPA Form 7710-25 Page 11

# 1~ 

# 11 111 110 I 1u 1p 1



# u 1111W iu u1 u
F'



# _ _ tS 

# .....E D 

# ,,....,. F' MNLUIIriSH 

## rnnl

~ 

## ! a e a Diagram of the major unit operation steps. Confidential
❑

Enter Attachment filename for Part II, Section A, 1. d. Ll

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 12

# i
SANITIZED SUBMISSION 

### Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued The information on pages 9 and 9a refer to consolidated chemical number(s): ❑ 

### 1 ❑ 

### 2 ❑ 

### 3 ❑ 

### 4 ❑ 

### 5 ❑ 

### 6
2. Occupational Exposure — You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, number of workers 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 substance (if part of a mixture) at the time of exposure. (7) -- Mark (X) this column if entries in columns (3) and (5) are 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 activity for any worker in hours per day and days per year. 12 -- Mark X this column if entries in columns 10 and 11 are confidential business information CBI

. Worker activity (i.e., bag dumping, filling

drums) (1) CBI

(2) Protective Equipment/

Engineering Controls

(3) Binding Option Mark (X) (4) Physical

form(s) &% new substance 5 Binding

Option Mark (X) 

### (s) CBI

(7) # of Workers Exposed (8) CBI

(9) Maximum Duration CBI (12) HrslDay (10) Days/Yr

(11)

I

Mark (X) this box if the data continues on the next page. Enter Attachment filename for Part II, Section A on the bottom of page 9a. ❑

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 13

# i 111 

# ~ 111 11 

# ~ I 1 

# ~1 1~11~ SANITIZED SUBMISSION

3. Environmental Release and Disposal -- You must make separate confdentiality claims for the release number and the amount of the new chemical substance released and other release and disposal information. Mark (X) the "ConfidentiaP' 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 1d(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, POTW, or other (specify)) to which the new substance will be released from that release point. (5) -- a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day). (6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). (7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information CBI .
' Release Number Amount of New

Substance Released CBI Medium of release e.g. Stack air Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Binding (1) (2a) (2b) (3) (4) (5a) Mark (5b) (s) X

Mark (X) this box if the data continues on the next page. ❑ 

### 7 Mark X the destination s of releases to water. NPDES# CBI

❑ POT1N--provide

name(s) ❑

❑ Navigable waterwayprovide name(s) ❑

❑ Other--Specify ❑

Enter Attachment filename for Part II, Section A. ❑
EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 14

# illllllllllllllllllllll1lllllllllllllllll SAN
I 

# T I 

# ZED.U.,.:,O,.

Part II-- HUiVIAN EXPOSURE AND ENVIRONMENTAL RELEASE — Continued Section B-- INDUSTRIAL SITES CONTROLLED BY OTHE RS The information on pages 10 and 10a refer to consolidated chemical number(s): ❑ 1 ❑ 2 ❑ 3 ❑ 4 ❑ 5 ❑ 6 Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Comp/ete a separate section 8 for each type of processing, or use operation involving the new chemica/ substance. If the same operation is performed at more than one site describe the t ical o eration common to these sites. Identify additional sites on a continuation sheet. 1(a). Operation Description -- To claim information in this section as confidential, bracket (e.g. Q) 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) -- Either in the diagram or in the text field 1(b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Either in the diagram or in the text field 1(b) below, identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 4-- Please enter the # of sites remember to identify the locations of these sites on a continuation sheet : Number of Sites Confidential 

# ~ r See Attachment 015 (Attachment for PMN Page 10 (#1 a) (public).pdf)

1(b). (Optional) This space is for a text description to clarify the diagram above. Confidential IXI 

### XXX

I

Enter Attachment fllename for Part II, Section B on the bottom of page 10a. Attachment for PMN Page 10 (#1 a) (public).pdf ❑ EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 15

# I~I~~hII~ 

# RIIWI

~~ 

# Y SANITIZED SUBMISSION 

# Continuation Sheet

ID 

# I P10SB1(a)(4)1 Field 

# I Part II, Section B, 1(a)(4). Operation Site Locations



## XXX

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 16

# 111V 11I

1 

# 111 1111111 11I IYI 11I Ii 1I SAN I 

# T I 

# ZED SUBMISSION

2. Worker Exposure/Environmental Release (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), (11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI).

I Letter of Activity # of

Workers Exposed CBI Duration of Exposure CBI Protective Equfp./Engineering ControlslPhysical Form % new substance % in

Formulation CBI


### (1) (2) (3) (4a) (4b) (5) (6) (6) (7) (8)


## XXX XXX X XXX XXX X XXX XXX XXX X

XXX XXX X XXX XXX X XXX XXX XXX X

XXX XXX X XXX XXX X XXX XXX XXX X

Release Number Amount of New Substance Released :,BI Media of Release & Control Technology CBI (9) (10a) (10b) (11) (12) (13)


### XXX XXX XXX X XXX X

XXX XXX XXX X XXX X

XXX XXX XXX X XXX X

Mark (X) this box if the data continues on the next page. F—I (14) Byproducts: (15) CBI 

# ~

Enter Attachment filename for Part II, Section B. 

# ~

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 17

# I
SAN 

### I T 

### I ZED SUBMISSION 

## Part II-- HUPViAN EXPOSURE AND ENVIRONPUiENTAL RELEASE — Continued Section B-- INDUSTRIAL SITES CONTROLLED BY OTHERS The information on pages 10 and 10a referto consolidated chemical number(s): ❑ 1 ❑ 2 ❑ 3 ❑ 4 ❑ 5 ❑ 6 Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate section B for each type of processing, or use operation invo/ving the new chemica/ substance. If the same operation is performed at more than one site describe the typical o eration common to these sites. Identify additional sites on a continuation sheet. 1(a). Operation Description -- To claim information in this section as confidential, bracket (e.g. {}) 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) -- Either in the diagram or in the text field 1(b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Either in the diagram or in the text field 1(b) below, identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 4-- Please enter the # of sites remember to identify the locations of these sites on a continuation sheet : Number of Sites Confidential 

# ~ See Attachment 016 (Attachment for PMN Page 10 (#1 b) (public).pdf)

1(b). (Optional) This space is for a text description to clarify the diagram above. Confdential ®


### XXX

Enter Attachment filename for Part II, Section B on the bottom of page 10a. Attachment for PMN Page 10 (#1 b) (public).pdf ❑ EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 18

# IhYNYMNI ~IA~~~NVl~ 

# lll
SANITIZED SUBMISSION 

# Continuation Sheet
ID I P10SB1(a)(4)2 

# 1 Field 

# I Part II, Section B, 1(a)(4). Operation Site Locations



# xxx

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 Page 19

# 10.k ~N~ 

# NIGtlYVtlIW ~~V~~NIY~ 

# ,w,„o,U..<.e.

2. Worker Exposure/Environmental Release (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. Compiete 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 retease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POT1N, 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 conffdential business information (CBI).
Letter of # of Workers CBI Duration of CBI Protective Equip./Engineering Controls/Physical % new % in CBI Activity Exposed Exposure Form substance Formulation (1) (2) (3) (4a) (4b) (5) (6) (6) (7) (8) 

## XXX XXX X XXX XXX Xxcx xxx XXX X

XXX XXX X XXX XXX X XXX XXX XXX X

XXX XXX X XXX XXX X XXX XXX XXX X

XXX XXX X XXX XXX X XXX XXX XXX X

Release Amount of New Substance Released CBI Media of Release & Control Technology CBI Number (9) (10a) (10b) (11) (12) (13) 

## XXX XXX XXX X XXX X

XXX XXX XXX X XXX X

XXX XXX XXX X XXX X

XXX XXX XXX X XXX X

Mark (X) this box if the data continues on the next page. 

# ~ (14) Byproduds: (15) CBI 

# ~

Enter Attachment filename for Part 11, Section B. El

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 20