FormA ires 10-31-96.i 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

SANITIZED COpy IllIte of receipt 

,'1 ;G.ENf.1¥ USE ONLY 

~EPA " PREMANUFACTURE 

NOTICE 

'j 

i,. l 

When 

completed 

send tlllS 

{ormto 

FOR NEW CHEMICAL SUBSTAl"iCES 

DOCUMENT CONTROL OFFICER Company Sanitized 

iEnter the total number of pages 

; in the Premanufacture Notice 

OFFICE OF POLLUTION PREVENTION 

AND TOXIC SUBSTANCES, 7407 

U.S. E.P.A. 401 M STREET. SW 

WASHINGTON, D.C. 20460 

.3 

GENERAL INSTRUCTIONS 

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 limn, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 


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


Ifa user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identilication number you have generated. Remember, 


your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P.O. 


360399M. Pittsburgh, PA 15251-6399, Attn. TSCA User fee. 

Part (-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name ofthe new 

chemical substance, even if you claim the identity as confidential. You may authorize 

another persoll to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin Wltil EPA receives this iuformation. A letter 

in support of your submission should reference your TS user fee identification number. 

You must submit an original and two copies of this nohce including aU test data. If you 

claimed any iuformation as confidential, a single sanitized copy must also be submitted. 

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

(fthere are several manufacture, processing, or use operations to be described in Part II, 

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

Part nr - LIST OF A TT ACHMENTS 

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

continuation sheet with the corresponding section heading. In Part III, list these 

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

OPTIONAL INFOR.V!ATION 

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

substance. On page II of this fom~ space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new substance. 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section, such as use, 

production volume, protective equipment. .. This option is intended to reduce delays that 

routinely accompany the development of consent orders Or Significant New Use Rules. 

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

certain infom13tion provided in such notification is binding on the submitter when the 

Agency approves the exemption application, checking a binding box in this notice does not 

by itself prohibit the submitter from later deviating from the information (except chemical 

identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To assert a claim on the 

form. mark (X) the confidential box ne"t to the iuformation that you claim as confidential. 

To assert a claim in an attachment, circle or bracket the infomution you claim as 

confidential. If you claim [nfonnalion in the notices as confidential you must also provide 

a sanitized version of the notice (including attachments). For additional instructions on 

TEST DATA AND OTHER DATA 

You are required to submit all test data in your possession or control and to provide a 

description of all other data known to or reasonably ascertainable by you, if these data 

are related to the health and environmental effects on the manufacture, processing, 

distribution in commerce, use, or disposal ofthe new chemical substance. Standard 

literature citations may be submitted for data in the open scientific literature. 

Complete test data (written in English), not summaries of data, must be submitted if 

they do not appear in tbe open literature. You should clearly identify whether test 

data is on the substance or on an analog. Also, the chemical composition of the tested 

material should be characterized. Following are examples of test data and other data. 

Data should be submitted according to the requirements of §720.50 or the 

Premanufacture Notification Rule (40 CFR Part 720). 

Test Data (Check Below any included in this notice) 

Envirorunenta] fate data 0 Yes Other data ~ Yes 

Health effects data 0 Yes Risk assessments 

Envirorunental effects data 0 Yes Structure/activity relationships 

Physical/Chemical Properties' ~ Yes Test data not in the possession 

or con~ the submitter c .." L:.:) 

A physical and chemical properties worksheet is located on the~1ISt page of this fonn. 

TYPE OF NOTICE (Check Only One) 

~ 

o 

o 


o 

o 

o 


o 


PM~ (Pre manufacture Notice) 


INTERMEDIATE PMN (submitted in sequence wit~tinal pr~uct PMN) 


SNUN (Significant New Use Notice) 


c .' TMEA (Test Marketing Exemption Application) 


LVE (Low VolWlle Exemption)@40CFR 723.50(c)(I) 


LOREX (Low ReleaseJLow E"posure Exemption) @40 CFR 723.50(c)(2) 


LVE Modification o LOREX Modification 


claiming inlbrrnation as confidential, read the Instructions Manual. 

IS THIS A CONSOLIDATED PM~? o Yes

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

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

/ 
Public reporting burden for this collection of infonnation is estimated to average 110 hours per response, including time for reviewing 

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

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

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

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

CERTIFICATION 

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

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

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

Section B. 

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

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


reasonably ascertainable by me as required by §720.S0 of the Premanufacture Notification Rule. 


Additional Certification Statements: 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or Sl';'UN, check the following user fee certification 


statement that applies: 


[8J 	The Company named in Part I, Section A has remitted the fee of$2S00 specified in 40 CFR 700.4S(b), or 

D The Company named in Part I, Section A has remitted the fee of $ I 000 for an Intermediate PYfN (defined @ 40 CFR 


700.43) in accordance with 40 CFR 700.4S(b), or 


D The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $1 00 

in accordance with 40 CFR 700.4S(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.S0(c)(I) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.S0(c)(2), check the following certification 

statements: 

D 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.S0. 


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

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

D If this application is for an L VE in accordance with 40 CFR 723.S0(c)( 1), the manufacturer intends to commence 


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


review period. 


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

described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001. Confidential 

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

9118i02 

Signature of agent - (if applicable) Date 

D 

-------

Part I -- GENERAL INFORMATION 

Section A -- SUBMlTIER IDENTIFICATION 

lao 	 Person 

Submitting 

Notice (in U.S.) 

b. Agent (if 

applicable) 

c. 

Joint Submitter (if 

applicable) 

2. 	 Technical 

Contact (in 

U.S.) 

3. 	 If you have had a prenotice commwlication (PC) conceming this notice and 

EPA assigned a PC Nwnber to the notice, enter the number. 

4. 	 If you previously submitted an exemption application for the chemical 

substance covered by tbis notice, enter the exemption nWlmer assigned by 

EPA. If you previously submitted a PMN for !ltis substance enter the PMl' 

nWllber assigned by EPA (i.e. withdrawn or incomplete). 

S. 	 (fyou have submitted a notice ofBona fide intent to manufacture or import 

for the chemical substance covered by this notice, enter the notice nwnber 

assigned by EPA. 

1. Manufacture 2. 0 Import 6. Type of Notice - Mark (X) Only Only

o Binding Option 0 Binding Option 

Mark Mark 

ITelephone Area Code INumber 

[f you are submitting this notice as part of a joint submission, mark (X) this box. _______________________ 

IPosition 

Telephone Area Code INumber 

Position 

ITelephone Area Code INumber 

Mark (X) 

ifnone 

Mark (X) 

if none 

Mark (X) 

[8J 

[8J ifnone 

Mark 0 the "Confidential" box next to any subsection you claim as contidential 

Name of authorized otlicial IPosition 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

Name of authorized ofticial 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

Name of authorized official 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

Name of authorized official 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

Confidential 

3 0 Both

~ 
Part I -- GENERAL INFORMATION - Continued 

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

the ninth Collective Index (9CI) of CA nomenclature rules and conventions. 

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

Complete either item 1 (Class I or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity infonnation for you (for either Item I or 2). mark (X) the box at the right. 


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


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

a. 	 Class of substance Mark (X) Class I or 2 D Class 2 

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

For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA lndex Name or CA Preferred Name must 

be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions). 

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

one). 

[SJ 	 Method I (CAS Inventory Expert Service· a copy of the Identitlcation D Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

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

e. 	 For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance (I) List the immediate 

precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) lndicate the 

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

attach a continuation sheet. See continuation sheet 

Confidential 

r":71 

~ 
PAGE 4(a) 

Chemical Structure Diagram. Nature of reaction. 
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 weight of that composition. 

Describe the methods of measurement or the basis for your estimates: OPC D Other D: (Specify)________ 

1) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight: 

iii) maximum weight % below 1000 molecular weight: 

attach a continuation sheet 

Confidential 

b. You must make separate contidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Contidential" box next to any item you claim as confidential 

(I) 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. 

Mark (X) this column if entry in column (I) is confidentiaL 

Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(2) 

(3) 

(4) Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) Mark (X) this column if entries in columns (3) and (4) are conlidential. 

(6) - Indicate the maximum weight percent of each monomer or other reactant that ntay be present as a residual in the polymer as manufactured for 

commercial purposes. 

this column if is confidential. 

Confi- Typical 

% 

% 

% 

% 

% 

% 

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

D Method [(CAS Inventory Expert Service - a copy of the identitication report D Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

d. the polymer that is consistent with TSCA Inventory listings for similar polymers. 

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

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

Confi­

% 

% 

% 

% 

% 

% 
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." 


Estimate the of each [[there are unidentified estimate their total %. 


Impurity and CAS Registry Number Maximum Confipercent dential 

% 

% 

% 

% 

% 

% 

Confidential 

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

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

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

6. 	 Generic chemical name - [fyou 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. 

Alkyl phosphate derivative 

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

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

Number if available. 

Byproduct 

(1) 

CAS Registry Number Confi­

(2) dential 

[8J 

'7 

i 

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

Part I -- GENERAL INFORlVlATION -- Continued 

Section C - PRODUCTION, IMPORT, AND USE INFORL'\IIATION: 

Mark eX) 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 (kgJyr) Maximum 12-month production (kglyr) I Confi- Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dential Option 

i Mark (x) 

[g] 

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

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

(3) -­ Indicate your willingness to have the information provided in column (I) 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 entrv(ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) CBI Binding Produc- CBI %in CBI % of substance expected per use CBI 

Option tion % Form­ (8) 

(by function and application i.e. a dispersive dye Mark (xl ulation Site- Con-* Indus- Com- Binding (3) for finishing polyester fibers) (2) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

[8J % [gJ % [gJ [gJ 

% % 

% % 

% % 

% % 

% % 

% % 

* 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. 

[n 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. 

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

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

use Instructions Manual for examples of generic use descriptions. 

description 

Processing aid 

i 

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

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

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

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

[gJ Mark (X) this box if you attach hazard information. Please refer to the Developmental Product Safety Information Sheet. 

Binding 

Option 

Mark (x) 
Part 11-- HUMAN EXPOSURE AND ENVIRONlVIENTAL RELEASE 

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

claim as confidential 

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 

further industrial or use after' You must describe these See instructions manual 

of the site at which the 0 will occur. 

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 operations, include all the information requested in this section for those 

sites as attachments. 

I. Batch 

Maximum kglbatch (100% new chemical Hours/batch 

substance) 

Maximum kglbatch (100% new chemical Hourslbatch 

.ubstance) 

2. Continuous 

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

Use 

Batches/year 

Batches/year 

Confidential 

(I) 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 materials and 

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

used daily or per batch.). 

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

attach a continuation sheet. 
Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued 

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

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

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

(2) -- Mark (X) this column ifentry in column (I) is confidential business information (CBI). 

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

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

(5) --Indicate the physical formes) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemica! substance (if part of a 

mixture) at the time of exposure. 

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

(IO) and (II) -- 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 (II) are confidential business information (CBl). 

Worker activity CHr Protective Equipment! Binding Physical fonns(s) Binding CHI # of CHr MaJ<Unwn duration CHI 

(Le., bag dumping, tilling drums) Engineering Controls Option and % new Option Workers Hrslday Dayslyr 

Mork(x) substance Mark (x) Expose 

(I) (2) (3) (4) (5) (6) (7) d (9) (!O) (11) (12) 

(8) 

(8J Goggles &gloves (8J kSl (8J 

(8J Goggles &gloves (8J (8J 

D D D D 

I 

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

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

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

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

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

(3) -- Mark (X) this column if entries in columns (I) and (2) are contidential business information (C8I). 

(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 etTiciency 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 (Public I Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (C8I). 

Release Amount of new substance eBI Media of Control technology and etTiciency (you may wish to optionally attach etTiciency data) CBI 

Number released release 

(I) (2a) (2b) ~.&, SI;Kt al! Bmding 

(3) (4) (Sa) Marl< (Xl (5b) (6) 

X (8J 

(7) Mark (X) the D POTW provide name(s) below: CBI D Navigable D Other - Specify provide NPDES # CBI '--­ destination(s) of waterway 

releases to water. (8J (8J 

ir8J Mark (X) this box if you attach a continuation sheet. See continuation sheet 9(a) 

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

II) 

Page 9(a) 

Continuation Sheet: Part II - Human Exposure and Environmental Release 

Section A Industrial Sites Controlled by the Submitter 

1/ 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not 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 ofprocessing. or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

iealo eration common to these sites. Identif additional sites on a continuation sheet. 

1. Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. 

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

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briet1y describe each worker activity. (2) -- Provide the identity, the approximate weight 

(by kg/day or kglbatch, 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 ifnot used daily or per batch). (3) Identify by number the points of release, 

including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet): 

[I # of sites 

[gJ Mark (X) this box if you attach a continuation sheet. Refer to Continuation Sheet Page lO(a) 

2. Worker Exposure/Environmental Release 

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

(2) -- 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 lormulated when packaged or used as a final product. 

(9) From the process diagram above, enter the number of each release point. Complete 9-lJ 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 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, 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 oroceeding entries are confidential business information (CBI). 


Letter #of CBI Duration CBI Protective Equip. / %in CBI Release AmoWltof CBI Media ofRelease CBI 

of Workers of Engineering Controls! Form- t'umber New & Control 

Act- Exposed Exposure Physical Form and % u1ation Substance Technology 

ivity new substance Released 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (II) (12) (13) 

L 

(14) -- Byproducts: (15) 

Mark (X) this box if you attach a continuation sheet. Refer to Continuation Sheet Page lOra) & lOeb) 

12" 

PAGE lO(a) 

Continuation Sheet: Part II - Human Exposure and Environmental Release 

Section B Industrial Sites Controlled by Others 

1.1 

PAGE lO(b) 

Continuation Sheet: Part II - Human Exposure and Environmental Release 

Section B - Industrial Sites Controlled by Others 
OPTIONAL POLLUTION PREVENTION INFORlV1ATION 

To claim infonnation in this section as confidential circle or bracket the specific information that you claim as confidential. 

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

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

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

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

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

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

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

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

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

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

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

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

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

alternatives may be provided. 

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

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

examples. 

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a 

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

the cost of production andlor improved operation efficiency of the new chemical substance in comparison to existing chemical 

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

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

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

16 

Part III -- LIST OF ATTACHMENTS 

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

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

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

numbers of each attachment. 

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

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

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

Attachment name Attachment 

page number(s) 

Attachment 1 

Attachment 2 

Confidential 

[XJ 

[XJ 

Attachment 3 

Attachment 4 

[XJ 

X 

Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 
PHYSICAL A.~D CHEMICAL PROPERTIES WORKSHEET 

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 properly measured, the page of the notice on which the properly appears, the value of the 

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

physical state of the neat substance should be provided. These measured properties should be for the neat (100% pure) chemical 

substance. Properties that are measured for mixtures or formulations should be so noted (% PMN substance in _). You are not 

required to submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that 

confidential information is properly protected. You should submit this worksheet as a supplement to your submission of test data. 

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

Properly Mark Page Value 

(X) if number 

(a) provided (b) (cl 

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

Vapor pressure 

@ Temperature °C Torr 

Density/relative density glml 

Solubility 

@ Temperature °C 

giL 

Solvent 

Solubility in water @ Temperature °C 

Melting temperature 

Boiling / sublimation temperature(ci) torr pressure 

Spectra Infrared Spectra 

Dissociation constant 

Particle size distribution 

Octanoll water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

pH @ concentration 

Flammability 

Explodability 

Adsorption / coefficient 

Other Specify 

lMeasuredo ConfiEstimate derltial 

Mark (X) 

(M or E) (d) 

X 

I 

X 

X 

I 

X i 

X 

X 

I 

! 

i 

I 

X I 

X 

ATTACHMENT 

PAGE 13 

17 
Attachment 1 

Developmental Product Safety Information Sheet 

2 Pages - Confidential 

Ii 

Attachment 2 


Inventory Expert Service (IES) Report 


2 Pages - Confidential 

In Expert Service 

A division of the American Chemical Society Phone: 800-63 1- 1884, 6 14-447 -3600 (ext. 2308) 

Fax: 614-447-3747 

E-mail: answers@cas.org .~ugust 22, 2002 

Stepan Company 

ATTN: Ms. Annie Gariepy 

22 W. Frontage Road 

Northfield, IL 6009] 

Dear Ms. Gariepy, 

Thank you for your Inventory Expert Service (IES) order of August 20, 2002. 

The processing results for your order are included on the following page. 

This page includes the CA index name that has been assigned to your substance, 

and the results of a confidential search of the CAS Registry File for your! 

substance. 

To ensure efficient processing of your substance, it is important that you 

include this page with your PMN report form when reporting your substance to 

the EPA. 

An invoice will be issued to cover the cost of the processing of your order. 

Thank you for the opportunity to provide this service. If you have any 

questions please do not hesitate to contact me at 614-447-]600, ext. 2]08 

between the hours of 8:00 a.m. and 4:00 p.m. weekdays. 

Sincerely, 

(!~~c!'~ 

Candice Egelhoff U. ~ Inventory Expert ServLce 


Enclosure(s): Inventory Expert Service Report 
em Inventory Expert Service 


A division of the American Chemical Society Phone: 800-631-1884.614-447-3600 (ext:2308) 

Fax: 614--447-3747 

E-mail: answers@cas.org 

INVENTORY EXPERT SERVICE REPORT 

IES-ORDER NU~BER: 

REGISTRY NUMBER: 

CA INDEX NAME 

Please print the above CA Index Name on the appropriate page of your PMN. 

~f this box is checked, CAS has made correction(s) marked in red to 

~ ;our IES order. Please make the same correction(s) to your PMN before 

submitting it to the EPA. 

2540 Olentangy River Road P,O. Sol< 3343 ~ • Columbus. Ohio 43210-0334 
Attachment 3 


Cover letter/copy of check submitted to EPA HQ Accounting Operations Branch 


2 Pages - Confidential 

Attachment 4 


EPIWIN® Analysis