Company Sanitized 


SANITIZED SUBMISSION 

Cover Letter PIO-571

September 20. 2010 

, (' r>c>' , U.S. Environmental Protection Agency 

Office of Pollution Prevention and Toxics 

Confidential Business Information Center (CBIC) 

EPA East Building. Room 6428 

1201 Constitution Ave., N.w. 

Washington, DC 20004-3302 

This PMN is being submitted under the Sustainable Futures Initiative 

Dear Madam or Sir, 

Enclosed is a Pre-Manufacture Notification (PMN) filed by {XXX} for {XXX}, listed as Structure I, and {XXX}, listed 

as Structure II, the names for which were assigned by CAS-IES based on our description of the structures and 

manufacturing process. This reaction was determined to be a one pot mixture in which the two structures would not 

intentionally be isolated. This assessment was confirmed by David Schutz via Prenotice Communication number 

{XXX}. The chemical names have not been assigned Chemical Abstracts Service Registry Numbers (CASRN) in 

order to protect confidentiality. Solutions of the PMN substance {XXX} are currently identified by {XXX}, with {XXX} 

being the primary product we are most interested in pursuing. Claims of confidentiality are being made on any of 

the enclosed information. 

{XXX} has remitted the ''TSCA User Fee" of $2500 to EPA's HQ Accounting Operations Branch in St. Louis, MO as 

required at 40 CFR 700.45(b). 

{XXX} 

If you have any questions, please contact {XXX}, respectively. 

Sincerely, 

{XXX} 

{XXX} 

Page 1 
. '~ LfOmpany Sanitized 

111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2010P1 PMN Page 1 

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

u.s. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt: 

";"' ,-... , !', '1, i " \,.... _ j

, E f 111111111111111111111111111111111111111111111111111111111111111111111111111 

511000005711S 51100000571 "P~1'O~571 When 

completed, Submission Re ort Number 

VX991 00920229890480 

TS Number 

10PW9A 

• 	 You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do not have actual data. 

• 	 Before you complete this form, you should read the ~lnstNctions Manual for Premanufacture Notification- (the Instructions Manual is available from the Toxic Substances Control Act 


(TSCA) Information SeNice 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-user1ee identification number you have generated. Remember, your user fee 10 number 

must also appear on your corresponding fee remittance. For mailing address information see the Help instructions in the e-PMN tool. 

Part 1- GENERAL TEST DATA AND OTHER DATA INFORMATION 

You are required to submit all test data in your possession or control and to provide a You must provide the currently correct Chemical Abstracts (CA) description of all other data known to or reasonably ascertainable by you, if these data are Name of the new chemical substance, even if you claim the related to the hea~h and environmental effects on the manufacture, processing, distribution in identity as confidential. You may authorize another person to commerce, use, or disposal of the new chemical substance. Standard literature citations may submit chemical identity information for you, but your submission be submitted for data in the open scientific literature. Complete test data (written in English) will not be complete and the review will not begin until EPA not summaries of data must be submitted if they do not appear in the open literature. You receives this information. A letter in support of your submission should clearly identify whether test data is on the substance or on an analog. Also, the should reference your TS user fee identification number. For all chemical composition of the tested material should be characterized. Following are examples Section 5 Notice submissions (paper or electronic) you must of test deta and other data, Data should be submitted according to the requirements of submit an original notice including all test data; if you claimed any §720.50 of the Premanufacture Notification Rule (40 CFR Part 720). information as confidential, an original sanitized copy must also be 

submitted. 

Part Test Data (Check Below any included in this notice) 11- HUMAN EXPOSURE AND ENVIRONMENTAL 

RELEASE 

If there are several manufacture, processing, or use operations to Environmental fate data 	 D Other Data 

be described in Part II, sections A and B of this notice, reproduce 

the sections as needed. Health effects data ~ Risk Assessments 

Part 111- LIST OF ATTACHMENTS Environmental effects data o 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 Properties (A physical and chemical properties worksheet is 

sheet with the corresponding section heading. In Part III, list these located on the last page of this form.) 

attachments, any test data or other data and any optional 

information included in the notice. Test data not in the possession or control of the submitter 

OPTIONAL INFORMATION TYPE OF NOTlCE (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. 

o 

D SNUN (Significant New Use Notice) "Binding" boxes are included throughout this form for you to 

indicate your willingness to be bound to certain statements you 

make in this section, such as use, production volume, protective TMEA (Test MarXeting Exemption Application) 

equipment ... The intention is to reduce delays that routinely 

accompany the development of consent orders or Significant New D 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 from the information 

D 

D 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 TMEA, LVE, LOREX) D LVE Modification certain information provided in such notifications is binding on the 

submitter when the Agency approves the exemption application, D LOREX Modification especially if the production volume "binding" box is chosen in a 

LVE. 	 D Mock Submission 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To Mark (X) if pending Letter of Support 

assert a claim on the form, marX (X) the confidential box next to 

the information that you claim as confidential. To assert a claim in 

D 

IS THIS A CONSOLIDATED PMN (Y/N)? 

an attachment, circle or bracket the information you claim as 

confidential. If you claim information in the notices as confidential, # of chemicals or polymers (Prenotice Communication # required, enter # on 

you must also provide a sanitized version of the notice (including p.3). 

attachments). For additional instructions on claiming information 

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

send this 

form to 

133 

ment 10 Number 

check # 0000934403 

GENERALINSTRUcnONS 

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

Page 2 
1111111111111111111111 111111111111111111 SANITIZED SUBMISSION 

PMN2010P2 PMN Page 2 

The public reporting and record keeping 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 OMS 

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. 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 

o 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 

o 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 

Low Release and Low Exposure Exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check 

the following certification statements: 

o 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 

o 

0 If this application is for an LVE in accordance with 40 CFR 723.50(c)(1). the manufacturer intends to commence manufacture of 

the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period. 

· The accuracy of the statements you make in this notice should reflect your best prediction of the 

I antiCipated facts regarding the chemical substance described herein. Any knowing and willful Confidential 

misrepresentation is subject to criminal penalty pursuant to 18 USC 1001. 

I Signature and title of 

· Authorized Official (Original Date [RJ • Signature Required) 

I 

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

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

Page 3 
1111111111111111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2010P3 PMN 3 [et::l~I::I:f.!.'i 

SeCtiOi1A~ MSrk(){lthe l ' box next to any <o ..k"At'tinn YOU claim as WIlIIUtllll'''' 

1a. Notice (in U.S.) i ·""'''VII Q, I(first) XXX (last) XXX Name of Authorized Official 

I Position XXX 

Company XXX 00 Mailing Address (number & street) XXX 


City 
 XXX I State I Postal Code XXX 


email 
 XXX 

Agent (if A .\ b. ....v 'U':"UO,

(first) (last) Name of Authorized OffICial 


Position 


Company 


Mailing Address (number & street) 
 D

City 
 I State I Postal Code 


e-mail 
 (i~~I~d'~'~~ea code) 

\';VIIIIUtlIlU", 

If you are submitting this notice as part of a joint submission, mark (X) I [ ] 

(first) (last) 

C. •Joint Subrr (if

Name of Authorized Official 

Position 

Company D 

Mailing Address (number & street) 

City IPostal Code 

Telephone 

IState 

e-mail (include area code) 

·\,;onnOellllal 

Name of Authorized Official 

2. I """'IIU''''CIl' .,;,,,,,,.--- ~~ fin U.S.) 

I(first) XXX (last) XXX 

Position XXX 


Company 
 XXX 

Mailing Address (number & street) 00 XXX 


City 
 XXX IState IPostal Code XXX 

e-mail XXX ;i~cl~d'~'~~ea code) XXX

If you have had a prenotice communication (PC) concerning XXX MarJ< (X) if none \,;VIIIIUt!l1\...1

this notice and EPA assigned a PC Number to the notice, 


enter the number. 


! 3. D 00 

If you previously ~wu ,n,· I exemplIur I for the Mark (X) if none \';onnOt!llI"'l 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 


4. 00 D 

assigned by EPA {i.e. withdrawn or 


If you have submitted a notice of Bona fide intent to 
 Mark (X) if none \,;onnOenllal

manufacture or import for the chemical substance covered 


by this notice, enter the notice number assigned by EPA. 


5. [R] D 

(if Tvpe of Notice - Mafi(IX) 


I 

1. 

Manufacture 

Binding Option 

Only 
 00 2. 

Binding 

Import Only 

Option 

D 3. Both D D D 

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

Page 4 
11111111111111 111I 

1. Class 1 or 2 chemical substances (for definitions of class 1 and class 

2 substances, see the Instructions Manual) 

a. Class of substance - Mark (X) 

Class 1 

D 

SANITIZED SUBMISSION 

Identify D 

Class 2 CBI 

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar 'xl 

substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA ~ 

XXX 

Preferred 

Method 1 (CAS Inventory Expert Service - a copy of the 

Identification report obtained from the CAS Inventory Expert 

Services must be submitted as an attachment to this notice 

Enter Attachment filename for Part I, Section B, 1. c. 

Molecular formula XXX 

IES Order 

Number 

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 002 (Structural Information for - Sanitized.doc) 

c. 

d. 

e. 

Enter Attachment filename for Part I, Section B, 1. e. Structural Information for - Sanitized.doc D 

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

Page 5 
xxx 

11I1111111111111111111 I1111I11111111111111111 SANITIZED SUBMISSION 

PMN2010P4A PMN Page4a 

For a etass 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) I 

e. (2) Describe the nature of the reaction or process. 

xxx 

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

xxx 

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

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

Page 6 
1I111111~ 11111111 
 SANITIZED SUBMISSION 

PMN2010P5 PMNPage 5 


Part I -- GENERAL INFORMATION - Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued I 

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

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. D ! Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) 

below 500 and below 1 ,000 absolute molecular weight of that composition. 

i Describe the methods of measurement or the basis for your estimates: 

GPC D IOther (Specify Below) D I 

Specify Other: 

(i) lowest number average molecular (ii) maximum weight % below 500 molecular (iii) maximum weight % below 1000 molecular I 

weight: weight: weight: 

Enter Attachment filename for Part I, Section B, 2. a. I D 

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark 

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

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) 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 (Xl this column if entry in column (6) is confidential. 

Monomer or other reactant specific chemical name Typical Include in Max 

CBI composition identity CBI residual CBI (1) (2) (3) (4) (5) (6) (7) 

i CAS RegiStry Number (1) I 

i 

CAS Registry Number (1) I 

CAS Registry Number (1) I i 

CAS Registry Number (1) I 

CAS Registry Number (1) I i j 

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

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


Page 7 

11111111111111 

PMN2010PSA 

SANITIZED SUBMISSION 

PMN Pa e 5a c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice 

check one. 

Method 1 (CAS Inventory Expert Service 

- a copy of the identification report obtained 

from CAS Inventory Expert Service must be 

submitted as an attachment to this notice 

Enter Attachment filename for Part I. Section B. 2. c. 

D IES Order 

Number 

Method 2 

(other source) D

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

01 mers. 

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

eBI 

I",", 

0 

0 

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


Page 8 

11111111111111 SANITIZED SUBMISSION 

PMN2010P6 	 PMN Pa e6 

Part I -- GENERAL INFORMA"nON -- 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 weight % of each impurity. If there are unidentified impurities, estimate their total weight %. 

CAS Registry Maximum Confl- Impurity (a) Number Percent % 

(a) (b) dential 

. XXX XXX XXX X 

XXX XXX XXX X 

XXX XXX XXX X 

D .> 

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

Enter Attachment filename for Part I, Section B, 3. J D 

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. 

D 

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

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

XXX 

[gJ 

Enter Attachment filename for Part I. Section B. 5. I [ ] 

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. 

Quaternary ammonium compound 

i 

I 

! 

I 

i 

I 

I 

i 

Enter Attachment filename for Part I. Section 5, 6. J 

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 Confi­ . (2)' dential 

I 

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

I 

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

Page 9 
111111111 SANITIZED SUBMISSION 

PMN2010P7 PMNPage 7 

Part I •• GENERAL INFORMATION •• Continued I 

Section C - PRODUCTION, IMPORT, AND USE INFORMA nON: I 

The information on this page refers to consolidated chemical number(s): 01 [ ] 2 3 4 Os J6 

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

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

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

For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 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) Confidential Binding Option 

(100% new chemical substance basis) (100% new chemical substance basis) Mark (X) 

XXX XXX [X] 0 

Enter Attachment filename for Part I, Section C, 1. I CBI 0 

2. Use Information ­ You must make separate confidentiality claims forthe description ofthe category of use, the percent of production volume devoted 

to each category, the formulation ofthe 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(les}'in column (Ii)'js (are}'confidential business information (CBI). 

Category of use (1) Binding Prod %in % of substance expected per use 

(by function and application i.e. a dispersive dye for CBI Option uction CBI Form- CBI (8) CBI 

finishing polyester fibers) Mark (X) % ulation Site-- Co,," Industrial Com- Binding 

(2) (3) (4) (5) (6) (7) limited turner­ mercia! Option (9) 

XXX X XXX X XXX X XXX XXX XXX XXX X 

i 

• If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the users) 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 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. 

i Inhibitor for oil field applications 

Enter Attachment filename for Part I, Section C, 2. b. I CBI 0 

3. Hazard Information Include in the notice a copy of reasonable facsimile of any hazard waming statement, label, material safety 

data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance Binding Option 

i 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. 

I Mark (X) this box if you attach hazard information. rxJ 0 

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


Page 10 

111111111111111111 SANITIZED SUBMISSION 

PMN2010P8 PMNPage 8 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

I Section A •• INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER IMark (X) the 'Confidential" box next to 

any item you claim as confidential 

i The Information on pages 8 and 8a refer to consolidated chemical number(s): l J 1 [ J 2 J3 J4 [ J 5 [ J 6 

i 

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites 

you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting 

requirements if there are further industrial processing or use operations after import. You must describe these operations. See 

instructions manual 

1. Operation description Confia. Identity ­ Enter the identity of the site at which the operation will occur. dential 

Name XXX 

Site address (number and 

street) XXX [ZJ 

City XXX County XXX 

State ZIP code XXX 

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 [XJ

operations, include all the information requested in this section for those sites as attachments. 7 

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

b. Type- Manufacturing 0 Processing 0 Use 0 [XJ Mark (X) I 

c. Amount and Duration ­ Complete 1 or 2 as appropriate Confidential 

Maximum kglbatch 

(100% new chemical Hours/batch Batches/year 

1. Batch substance) i [XJ

XXX XXX XXX 

Maximum kg/day Hours/day Days/year (100% new chemical substance) 2. Continuous 0

Mark (X) to indicate your willingness to 

0 I:.'. d. Process description have your process description binding. •:> 

7 " (1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon 

pails, 55 gallon drum. rail car, tank truck, etc.). 

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

mate~ials and feedstocks (i~cluding reac~ants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning 

chemicals (note frequency If not used dally or per batch.). 

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

releasing to two media at the same step, aSSign a second release number for the second medium. 

o 

See attachments 4 and 5 for procedures and diagrams 

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


Page 11 

11111111111111 IIII SANITIZED SUBMISSION 

PMN2010P8A PMN Page 8a 

Confidential 

r Diagram of the major unit operation steps. o 

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

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

Page 12 
II11I11 11I11II1 SANITIZED SUBMISSION 

PMN2010P8-1 Continuation Sheet 

ml Field IPart II , , Section A 1 .. a (Additional Sites) 

1. Operation description Confia. Identity -- Enter the identity of the site at which the ooeration will occur. dential 

Name 

XXX 

Site address 

(number and street) XXX [XJ

City XXX County XXX 

State ZIP code XXX 

Name 

1 I 

Site address 

(number and street) 

I City County 

State ZIP code 

Name 

Site address 

(number and street) D

City County 

State ZIP code 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

Name i 

Site address 

(number and street) D 

City County 

State ZIP code 

Name i 

Site address 

(number and street) D 

City County 

! State ZIP code 

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


Page 13 

SANITIZED SUBMISSION 

PMN2010P9 PMNPage 9 

Part 11- 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 [ J4 [ 5 [ J 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 daim 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 formes) 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 Protective Equipment! Binding Physic;al Binding #of Maximum Duration (I.e., bag dumping. filling CBl Option formls) Option CBI Worke ... CBI CBI 

drum.) engineering Controls Mark (X) &%new Mark IX) Exposed 

(1) (2) (3) (4) substance (6) (7) (8) (9) HrsIDay DayslYr (12) 

15) (10) (11, 

XXX X XXX XXX X XXX X XXX XXX X 

XXX X XXX XXX X XXX X XXX XXX X 

XXX X XXX XXX X XXX X XXX XXX X 

XXX X XXX XXX X XXX X XXX XXX X 

XXX X XXX XXX X XXX X XXX XXX X 

XXX X XXX XXX X XXX X XXX XXX X 

I 

I 

I I 

I 

I 

\ 

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

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


Page 14 

SANITIZED SUBMISSION 

PMN2010P9A PMNPage 9a 

111111111111111111111111111 

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 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 kglbatch). 

(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 ofthe 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). 

(8) -	 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 

Enter Attachment filename for Part II. Section A. I 	 D I 

EPA FORM 7710-25 (Rev. 8-09) 	 Replaces previous editions of EPA Form 7710-25 

Page 15 

business information (CBI). 

Release Amount of New Medium of release Control technology and efficiency (you may wish to 

Num_r Substance Released CBI e.g. Stack air optionally attach efficiency data) eBI ! Binding 

I (1) (2a) (2b) (3) (4) (5a) Mark (Sb) (6) 

(X) 

XXX XXX XXX X XXX XXX X 

I 

! XXX XXX XXX X XXX XXX I X 

XXX XXX XXX X XXX XXX X 

i 

I 

I 

I 

I 

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

{7} Mark (X) the destination(s\ of releases to water. NPDES# C81 

[Xl POTW-provide xxx xxx ! [Xl name(s) I 

I 

I 0 Navigable watelWay- D I - provide name(s) 

, 

0 i Other-Specify DI 
PMN2010P10 

11111111111111111111111 SANITIZED SUBMISSION 

PMN Page 10 

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section B -INDUSTRIAL SITES CONTROLLED BY OTHERS 

The Information on pages 10 and 10a refer to consolidated chemical number(s): [J 1 [J 2 [J 3 [J 4 05 06 

I 

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. 

I Complete a separate section B for each type ofprocessing, or use operation involving the new chemical substance. If the same operation is performed at 

more than one site describe the !ypical operation common to these sites. Identitv additional sites on a continuation sheet. 

1(a). Operation Description ­ To claim information in this section as confidential, bracket (e.g. {}) the specific infomnation 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. 

J4) - Please enter the # of sitesjremember to identify the locations of these sites on a continuation shee!): I Number of Sites I IConfidential [g] 

See Attachment 006 (Use Diagram - Sanitized.doc) 

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

See attachments 6, 7 and 8 

Enter Attachment filename for Part II, Section B on the bottom of page lOa. I Use Diagram _ Sanitized.doc o 

I 

I 

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

Page 16 
xxx 

PMN2010P10-1 

11111111111111111111111 SANITIZED SUBMISSION 

Continuation Sheet 

ID IP10SB1(a)(4)1 I Field I Part II, Section B, 1 (a)(4). Operation Site Locations 

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


Page 17 

~IIIIIIII II11II1 SANITIZED SUBMISSION 

PMN2010P10A PMNPage 10a 

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) directty to the environment or (b) into control technology to the environment (in 

kg/day or kglbatch). 

(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. 

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

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

(3), (5), (8). (11), (13) and (15) - Mark (X) this column if any of the proceeding entries are confidential business information (CBI). 

Letter #of Duration of Protective EqulpJEngineering Controls/Physical "knew %in of Workers CBI CBI CSI 

Activity Exposed Exposure Form substance Fonmulatlon 

(i) (2) (3) (48) (4b) (5) (6) (6) (7) (8) 

XXX XXX X XXX XXX X XXX XXX XXX X 

I XXX XXX X XXX I XXX X XXX XXX XXX X I I 

I 

I I 

I 

I 

i 

I 

! 

I 

I Release 

Number Amount of New Substance Released CSI Media of Release & Control Technology CSI 

(9) (10a) (10b) (11) (12) (i3) 

\ 

XXX XXX XXX X XXX X 

I 

I 

Mark (X) this box if the data continues on the next page. [ ] " ..' 

(14) Byproducts: I (15) CSI 0 j 

I Enter Attachment filename for Part II, Section B. Description of Product Use ­ - Sanitized.doc [ ] 

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


Page 18 

11111111111111 1111111111111111 SANITIZED SUBMISSION 

PMN2010P11 PMN Page 11 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in the following section as confidential, bracket (e.g. {}) the specific information that you claim as confidential. 

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

associated with activities surrounding manufacturing, processing, use and disposal ofthe 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. andfor raw materials substitution. 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. Quantitative or qualitative 

descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing 

regulatory requirements. 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 media (e.g .. air to water) or nonenvironmental areas (e.g., occupational or consumer exposure). To the 

extent known, information about the technology being replaced will assist EPA in its relative risk determination. In addition, information on the 

relative cost or performance characteristics of the PMN substance to potential alternatives may be provided. 

Describe the expected net benefits, such as 

(1) an overall reduction in risk to human health or the environment; 

(2) a reduction in the generation of waste materials through recycling, source reduction or other means; 

(3) a reduction in the use of hazardous starting materials, reagents, or feedstocks; 

(4) a reduction in potential toxicity, human exposure and/or environmental release; or 

(5) 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. 

Information provided in this section will be taken Into consideration during the review of this substance. See PMN Instructions Manual 

and Pollution Prevention Guidance manual for guidance and examples. 

Enter Attachment filename for Pollution Prevention Page 11. I Pollution Prevention Information - Sanitized.doc l J 

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

Page 19 
11l111l111~1I11111 ~IIIIIIIIIIIIIIII ~IIIII SANITIZED SUBMISSION 

PMN2010P12 PMN Pa e 12 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form, test data and other data (including physical/chemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form 

to which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the Number of Pages column 

below, enter the inclusive page numbers of each attachment for paper submissions or enter the total number of pages for each 

attachment for electronic submissions, Electronic attachments can be identified by filename. 

Mark (X) the "Confidential" box next to any attachment name or filename 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 ~ou claim information as confidential. j 

Number Associated 

# Attachment Name Attachment Filename CBI! of Pages PMN Section 

Number 

001 CAS-IES report 11 Pt.I, Sec.B, 1 c. 

I 

i 

002 Structural information for - Sanitized Structural Information for - 1 Pt.!, Sec.S, 1 e. 

I ! Sanitized.doc 

003 MSDS - Sanitized MSDS - Sanitized.doc 10 i ! 

004 Plant Procedure - Sanitized Plant Procedure - Sanitized.doc 3 

1 

005 Manufacturing Flow Diagram· Sanitized page 8(a) Manufacturing Flow 3 

Diagram· Sanitized.ppt 

1 

006 Use Diagram - Sanitized Use Diagram - Sanitized.doc 1 Pt.2, Sec.B. 1a. 

1 

007 Description of Product Use • Sanitized Description of Product Use ­ 4 Pt.2. Sec.B. End 

• Sanitized.doc 

[008 Container Description - Sanitized Container Description· 2 

Sanitized.doc 

009 Pollution Prevention - Sanitized Pollution Prevention Information 2 Pollution Prevention 

- Sanitized.doc 

010 Published Version Review 2006 • Sanitized Published Version Review 2006 ­ 23 

Sanitized.doc 

1 

011 Use Article - Sanitized Use Article - Sanitized.doc 3 I 

:012 US Patent 1 - Sanitized US Patent 1 - Sanitized.doc 10 

013 US Patent 2 - Sanitized US Patent 2 - Sanitized.doc 8 i 

014 Sustainable Futures Assessment· Sanitized Sustainable Futures Summary 18 

Assessment· Sanitized.doc 

i 

I 

i 

I 

! 

i i 

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

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

Page 20 
SANITIZED SUBMISSION 1111111111111111111111 11111111111111111111111 

PMN2010P13 PMNPage 13 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

The information on this page refers to chemical number(s): l ] 1 []2 03 04 5 [ ] 6 

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

notice. Identify the property measured, the lIalue of the property, the units in which the property is measured (as necessary). and whether or not the 

property is claimed as confidential. Give the attachment number (found on page 12) in column (b). 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 the review and ensure that confidential information is properly protected. You should submit this worksheet as a 

supplement to your submission of test data. This worksheet is not a substitute for submission of test data. 

Property Unit~ Attachment Value Measured CSI 

Number or Estimate Mark (X) (a) (b) (c) 1M or E} (dl 

(solid) I (liquid) (gas) 

Physical state of neat substance 0 [Xl 0 • Vapor Pressure @ 

Temperature 

·C 0 I Torr 

0 xxx X 

Density/relative density g/cm3 

Solubility 

@ Temperature ·C gIL 

Solvent 

Solubility in Water @ ·C glL Temperature 

Melting Temperature ·c 

Boiling / Sublimation I .. ·c 

temperature @ I 

Spectra 

Dissociation constant 0 

Octanol/ water partition coefficient 0 

Henry's Law constant 0 

Volatilization from water 0 

Volatilization from soil 0 

pH@ concentration 0 

Flammability 0 

Explodability 0 

Adsorption I Coefficient 0 

Particle Size Distribution 0 

Other ­ Specify 0 

Page 21 
ATTACHMENT HEADER SHEET 


Attachment Number 001 

Attachment Name 


CAS-IES report 


Associated PMN Section Number 


Pt.l, Sec.B, 1c. 


Does not contain CBI 

Report Number 

VX991 00920229890480 
CAS - IES Report - Sanitized 
AITACHMENT HEADER SHEET 


Attachment Number 002 

Attachment Name 

Structural information for - Sanitized 

Associated PMN Section Number 

Pti. Sec.B. 1e. 

Does not contain eBI 

Report Number 

VX991 00920229890480 
Structural Information for 

Structure I Structure II 

80-90% 10-20% 

The New Chemical Substance is prepared by a two-step chemical reaction. 


The product of this first step reaction is not isolated. Once the conversion is complete, 


solvent is added to the reaction mass to form the New Chemical Substance, which consists of 80-90% 


Structure I and 10-20% Structure II. No byproducts are expected from either reaction, thus there are no 


purification steps. 


This solution is blended with in the same reaction vessel for product , or with 


in the same reaction vessel for product The blended commercial product is eventually filtered and 


packaged into returnable containers for shipment to customers. 

ATTACHMENT HEADER SHEET 


Attachment Number 003 

Attachment Name 


MSOS - Sanitized 


Associated PMN Section Number 

N/A 

Does not contain eBI 

Report Number 

VX991 00920229890480 
MSDS - Sanitized 
AITACHMENT HEADER SHEET 


Attachment Number 004 

Attachment Name 


Plant Procedure - Sanitized 


Associated PMN Section Number 


N/A 


Does not contain eBI 

Report Number 

VX991 00920229890480 
Attachment 

Part II Human Exposure & Environmental Release 

Section A Industrial Sites Controlled by the Submitter 

D - Process Description ­

Exposures: 

Releases: 
ATTACHMENT HEADER SHEET 


Attachment Number 005 

Attachment Name 


Manufacturing Flow Diagram - Sanitized 


Associated PMN Section Number 


N/A 


Does not contain CBI 

Report Number 

VX991 00920229890480 
c... 

Q 

~ 

100 

,...,. = 


~ 

~ 

= 
 = 


~ 

~ 

,-, 

~ 

'-' IX) 

Q,j 

0.11 

~ 

~ 


ATTACHMENT HEADER SHEET 


Attachment Number 006 

Attachment Name 


Use Diagram - Sanitized 


Associated PMN Section Number 


Pt.2, Sec.B, 1a. 


Does not contain CBI 

Report Number 

VX991 00920229890480 

ATTACHMENT HEADER SHEET 


Attachment Number 007 


Attachment Name 


Description of Product Use - Sanitized 


Associated PMN Section Number 


Pt.2, Sec.B, End 


Does not contain CBI 


Report Number 


VX991 00920229890480 
CONFIDENTIAL BUSINESS INFORMATION 


Industrial Sites Controlled by Others, Part II, Section B.l 

How the PMN substance functions during use: 

Description ofUse Operations: 

List ofPotential Customer Sites 

Cleaning ofResiduals 

Exposures: 

Releases: 
ATTACHMENT HEADER SHEET 


Attachment Number 008 

Attachment Name 


Container Description - Sanitized 


Associated PMN Section Number 

N/A 

Does not contain CBI 

Report Number 

VX991 00920229890480 
Container Description - Sanitized 
ATTACHMENT HEADER SHEET 


Attachment Number 009 

Attachment Name 


Pollution Prevention - Sanitized 


Associated PMN Section Number 


Pollution Prevention 


Does not contain eBI 

Report Number 

VX991 00920229890480 
CONTINUATION SHEET, OPTIONAL POLLUTION PREVENTION 

INFORMATION 

Confidential Business Information removed - 2 pages 
ATTACHMENT HEADER SHEET 


Attachment Number 010 


Attachment Name 


Published Version Review 2006 - Sanitized 

Associated PMN Section Number 

N/A 


Does not contain eBI 


Report Number 


VX991 00920229890480 
Published Version Review 2006 - Sanitized 
ATTACHMENT HEADER SHEET 


Attachment Number 011 

Attachment Name 


Use Article - Sanitized 


Associated PMN Section Number 

N/A 

Does not contain eBI 

Report Number 

VX991 00920229890480 
Use Article - Sanitized 
ATTACHMENT HEADER SHEET 


Attachment Number 012 

Attachment Name 

us Patent 1 - Sanitized 

Associated PMN Section Number 


N/A 


Does not contain eBI 

Report Number 

VX991 00920229890480 
US Patent 1 - Sanitized 
AITACHMENT HEADER SHEET 


Attachment Number 013 


Attachment Name 


us Patent 2 - Sanitized 


Associated PMN Section Number 


N/A 


Does not contain CBI 


Report Number 


VX991 00920229890480 
US Patent 2 - Sanitized 
AITACHMENT HEADER SHEET 


Attachment Number 014 

Attachment Name 


Sustainable Futures Assessment - Sanitized 


Associated PMN Section Number 

N/A 

Does not contain eBI 

Report Number 

VX991 00920229890480 
Sustainable Futures Summary Assessment - Sanitized