FormA ires 10-31-96.i 

### U.S. ENVIRONMENTAL PROTECTION AGENCY 

## SANITIZED COpy IllIteofreceipt ,'1 

# ;G.ENf.1¥USE ONLY 

# "**~EPA** PREMANUFACTURE NOTICE 'j i,. l

When completed send tlllS {ormto 

### FORNEW CHEMICAL SUBSTAl"iCES DOCUMENT CONTROL OFFICER 

# CompanySanitized

iEnter the total number ofpages 

### ;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 ifyou 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). Ifauser 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 AccountingOperations 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 ifyou claimthe identity as confidential. You may authorize another persoll to submitchemical identity information for you, but your submission will notbe complete and the review will not begin Wltil EPA receives this iuformation. A letter in support ofyour submission should reference yourTS user fee identification number. You must submit anoriginal and two copies ofthis nohce including aU testdata. Ifyou 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, oruse operations to be described in Part II, sections A and B ofthis notice, reproduce tlle sections as needed. Part

## nr- LIST OF A TTACHMENTS Attach additional sheets ifthere is not enough space to answer

### aquestion fully. Label each continuation sheet with the corresponding section heading. In Part III, list these attachments, any test data orotherdata 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 ofthis**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 ofconsent orders Or Significant New Use Rules. Except in the case ofexemption applications (such asTMEA, LVE, LOREX) where certain infom13tion provided in such notification is binding on the submitter when the Agency approves the exemption application, checking abinding box in this notice does not by itselfprohibit the submitter from laterdeviating 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"tto the iuformation that you claim as confidential. To assert a claim in an attachment, circle orbracket the infomution you claimas confidential. Ifyou claim [nfonnalion in the notices as confidential you must also provide a sanitized version ofthe notice (including attachments). For additional instructions on TEST DATA AND OTHER DATA You are requiredto submit all testdata in yourpossession or control and to provide a description ofall other data known to or reasonably ascertainable by you, ifthese data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, ordisposal ofthe new chemical substance. Standard literature citations may be submitted for data in theopen scientific literature. Complete test data (written in English), not summaries ofdata, must be submitted if theydo not appear in tbe open literature. You should clearly identify whether test data is on the substance oron an analog. Also, the chemical composition ofthe tested material should be characterized. Following are examples oftestdataand otherdata. Datashould be submitted according to the requirements of§720.50 orthe Premanufacture Notification Rule (40 CFRPart 720).
Test Data (Check Below any included in this notice) Envirorunenta] fate data 

## 0 Yes Otherdata**~** Yes Health effects data 

## 0 Yes Risk assessments Envirorunental effects data 

## 0 Yes Structure/activityrelationships Physical/Chemical Properties'**~** Yes Test data not in the possession or**con~** the submitter c .." L:.:) Aphysical and chemical properties worksheet is located on**the~1ISt** page ofthis fonn. TYPE OF NOTICE (CheckOnly One)

# ~ 

# o 

# o o o 

# o o**PM~** (Premanufacture Notice) INTERMEDIATE PMN (submitted in sequence**wit~tinal pr~uct**  PMN) SNUN(Significant New Use Notice) 

# c .' TMEA (TestMarketing 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 LOREX Modification 

# o claiming inlbrrnation as confidential, read the Instructions Manual. IS THIS ACONSOLIDATED**PM~?** Yes 

# o Mark (x) ifany information ill this notice is claimed as confidential. # ofchemicals EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 7710-25. 

# /

### Public reporting burden for this collection ofinfonnation 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 ofthis collection ofinfonnation, 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 ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

# CERTIFICATION I certifythat to the best ofmy knowledge and belief: 1. The company named in Part I, sectionA, subsection 1 a ofthis 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 informationprovided in this notice is complete and truthful as ofthe date ofsubmission. 3. I am submitting with this notice all test data inmypossessionor control and a description ofall otherdata known to or reasonably ascertainable byme as required by §720.S0 

## ofthe Premanufacture Notification Rule.
Additional CertificationStatements: Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or Sl';'UN, check the following user fee certification statement that applies: 

# [8J The Companynamed in PartI, SectionA has remitted the fee of$2S00 specified in 40 CFR 700.4S(b), 

## or 

# D The Companynamed in PartI, SectionA has remitted the fee of$ I000 for an Intermediate PYfN (defined @ 40 CFR 700.43) in accordance with 40 CFR 700.4S(b), 

## or 

# D The Companynamed in PartI SectionA is a smallbusiness concernunder 40 CFR700.43 and has remitted a fee of$100 in accordance with 40 CFR 700.4S(b). 

## If

## you are submitting a low volume exemption (LVE) applicationin accordance with 40 CFR 723.S0(c)(I) 

## or a Low release andlow 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 solelyfor research and development, under the terms of40 CFR 723.S0. 

# DThe manufacturer is familiar with the terms ofthis section and will complywith those terms; and 

# DThe newchemical substance for which the notice is submitted meets all applicable exemption conditions. 

# D Ifthis application is for anLVE in accordance with 40 CFR 723.S0( 

## c)(1), the manufacturer intends to commence manufacture ofthe exempted substance for commercialpurposes within I year ofthe date ofthe expiration ofthe 30 day review period. The accuracy ofthe slalements you make in this notice should reflect yourbest prediction ofthe 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 ofAuthorized Official (Original Signature Required) Dale 9118i02 Signature ofagent - (ifapplicable) Date 

# D

# ------- Part I -- GENERAL INFORMATION Section A

-- 

### SUBMlTIERIDENTIFICATION lao Person Submitting Notice (in U.S.)

b. Agent (if applicable)

c. Joint Submitter (if applicable)

2. Technical Contact (in U.S.)

3. Ifyou have had a prenotice commwlication (PC)conceming this notice and EPA assigned a PC Nwnberto the notice, enterthe number.
4. Ifyou previously submitted an exemption application for the chemical substance covered by tbis notice, enter the exemption nWlmerassigned by EPA. Ifyoupreviously submitted a PMN for !ltis substance enterthe PMl' nWllber assignedby EPA (i.e. withdrawn orincomplete). S. (fyouhave submitted a notice ofBona fide intent to manufacture orimport for the chemical substance covered by this notice, enterthe notice nwnber assigned by EPA. 1. Manufacture 

### 2. 

# 0 Import 

### 6. Type ofNotice

- Mark (X) Only Only 

# o Binding Option 

# 0 Binding Option Mark Mark 

# ITelephone Area Code 

# INumber [fyou are submitting this notice as part ofajoint submission, mark (X) this box.

_______________________ 

# IPosition

Telephone Area Code 

# INumber Position


# ITelephone Area Code 

# INumber

Mark (X) ifnone Mark (X) ifnone Mark (X) 

# [8J [8J ifnone Mark

## 0 the "Confidential" box next to any subsection you claim as contidential Name ofauthorized otlicial 

# IPosition Company Mailing address (number and street) City, State,ZIP Code
Name ofauthorized ofticial Company Mailing address (number and street) City, State, ZIP Code

Name ofauthorized official Company Mailing address (number and street) City, State,ZIP Code
Name ofauthorized official Company Mailing address (number and street) City, State,ZIP Code Confidential



### 3 Both 

# 0

# ~

## Part I -- GENERAL INFORMATION - Continued Section B -- CHEMICAL IDENTITY INFORMATION: You must provide acurrently correct Chemical Abstracts (CA) name ofthe substance based on the ninth Collective Index (9CI) ofCA nomenclature rules andconventions. Mark (X) the "Confidential"boxnext to any item you claim as confidential Complete either item 1 (Class I or 2 substances) or2 (Polymers) as appropriate. Complete all other items. Ifanotherperson will submitchemical identity infonnation for you (for either Item I or 2). mark (X) the box at the right. Identify the name, company, and address ofthat person in a continuation sheet. 

# o I. Class I or 2 chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class ofsubstance 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 eithera CA lndex Name orCA Preferred Name must be provided, which everis appropriate based on CA 9CI nomenclature rules and conventions).

c. Please identify which method you used 

### to develop orobtain the specified chemical identity infonnation reported in this notice: (check one). 

# [SJ Method I (CAS Inventory Expert Service· a copy ofthe 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 (ifa numberalready exists for the substance)

e. Fora class I substance, provide a complete and correct chemical structure diagram. Fora class 2 substance (I)List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature ofthe reaction orprocess. (3)lndicate the range ofcomposition 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 StructureDiagram. Nature ofreaction.a. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymer you intend to manufacture. Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500 and below 1,000 absolute molecular weight ofthat composition. Describe the methods ofmeasurement 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 contidentialityclaims for monomer orotherreactant 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 RegistryNumber (ifa number exists)ofeach monomer or otherreactant used in the manufacture ofthe polymer. Mark (X) this column ifentry in column (I) is confidentiaL Indicate the typical weightpercent ofeach monomerorother reactant in the polymer. (2) (3) (4) Mark (X) the identity column ifyou want a monomer or otherreactant used at two weight percent or less to be listed as part ofthe polymer description on the TSCA Chemical Substance Inventory. Mark (X) this column ifentries in columns (3) and (4) are conlidential. (5) (6) - Indicate the maximum weight percent ofeach monomer or otherreactant 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 orobtain the specified chemical identity information reported in this notice (check one). 

# D Method [(CAS Inventory Expert Service - a copy ofthe identitication report 

# D Method 2 (other source) obtained from CAS Inventory Expert Service must be submitted as d. the polymerthat 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, ifone can be reasonably ascertained.



# o Mark (X) this box ifyou 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 ifavailable. Ifthere are unidentified impurities, enter "unidentified." Estimate the ofeach [[thereare unidentified estimate their total 

### %. Impurity and CAS Registry Number Maximum Confipercent dential

%
%
%
%


### %
%



### Confidential 

# o Mark (X) this box ifyou 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 Ifyou 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 ofthe new chemical substance to the maximum extentpossible. 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 ifyou attach a continuation sheet. 

### 7. Byproducts

­ Describe any byproducts resulting from the manufacture. processing, use, ordisposal ofthe new chemical substance. Provide the CAS Registry Number ifavailable. Byproduct (1) 

### CAS Registry Number Confi­ (2) 

### dential 

# [8J 

# '7i

# 0 Mark (X) this box ifyou attach a continuation sheet. 

# PartI
-- GENERAL INFORlVlATION

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

## eX) the "Confidential" box next to any itemyou claim as confidential. 

### 1. Production volume

-- Estimate the maximum production volume during the first 12 months ofproduction. Also estimate the maximum production volume for anyconsecutive 12-month period during the first three years ofproduction. Estimates should be on 100% new chemical substance basis. Fora Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10,000kg/yr, specify the volume and mark(x) in the binding box. Ifgranted, you are bound to this volume Maximum first 12-monthproduction (kgJyr) Maximum 12-monthproduction (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 confidentialityclaims for thedescription ofthe category ofuse, the percent ofproduction 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 categoryofuse ofthe newchemical substance by function and application
.. 

### (2) -­ Mark (X) this column ifentrycolumn (I) is confidential business information (CBI). 

### (3)

-­ Indicate your willingness to have the information provided in column (I) binding. (4)

-­ Estimate the percent oftotal production for the first three years devoted to each category ofuse. 

### (5)

-­ Mark (X) this column ifentryin column (4) is confidential business information (CBI). 

### (6)

-­ Estimate the percent ofthe new substance 

### as formulated in mixtures, suspensions, emulsions, solutions, orgels as manufactured for commercial purposes at sites under your control associated with each category ofuse. 

### (7) Mark (X) this column ifentry in column (6) is confidential business information (CBI). 

### (8)

-­ Indicate % ofproduct volume expected for the listed "use" sectors. Mark more than one box ifappropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. 

### (9) -­ Mark (X) this column ifentrv(ies) in column (8) is (are) confidential business information (CBI). Category ofuse (1) 

### CBI Binding 

### Produc- CBI %in CBI %ofsubstance 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 % % % % % % % % % % % % * Ifyou have identified a "consumer" use, please provide on acontinuation sheet a detailed description ofthe use(s) ofthis chemical substance in consumerproducts.

[n 

### addition include estimates ofthe concentration ofthe new chemical substance as expected in consumerproducts and describe the chemical reactions by which this substance loses its identity in the consumerproduct. 

# o Mark (X) this box ifyou attach acontinuation sheet. b. Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat category. Read the use Instructions Manual for examples ofgeneric use descriptions. description Processing aid



### i 

# o Mark (X) this box ifyou attach acontinuation sheet. 3. Hazard Information Include in the notice a copy ofreasonable facsimile ofany hazard warning statement, label, material safety data sheet, or other

information which will be provided to anyperson who is reasonably likely to be exposed to this substance regarding protective equipment orpractices for the safe handing, transport, use, or disposal ofthe new substance. List in part III hazard information you include. 

# [gJ Mark (X) this box ifyou 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 ofmanufacture, 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 ofthe site at which the 0 

### will occur.

Site address (number and street) City, County, State, ZIP code 

### Ifthe same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe 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 orkglbatch on a 100% new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch.). (3) Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance.

attach a continuation sheet.

## Part 

# II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

-- Continued Section A - INDUSTRIAL SITESCONTROLLEDBY THE SUBMITTER

-- Continued 2. Occupational Exposure
­ You must make separateconfidentialityclaims for the description ofworker activity, physical form ofthe newchemical substance, number ofworks exposed, and duration ofactivity. Mark (X) the "Contidentia!" box next to any item you claim as confidential. (I)

-- Describe the activities (i.e. bagdumping, 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) ofthe new chemical substance (e.g., solid: crystal, granule, powder, ordust) and % new chemica! substance (ifpart ofa mixture) at the time ofexposure. (7)

-- Mark (X) this column ifentry in column (5) is contidential business information (CBI). (8)

-- Estimate the maximum number ofworkers involved in each activity for all sites combined. (9)

-- Mark (X) this column ifentry in column (8) is contidential business information (CBI). (IO) and (II)

-- Estimate the maximum duration ofthe activity for any worker in hours perday and days per year. (12)

-- Mark (X) this column ifentries 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., bagdumping, 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 ifyou attach a continuation sheet. 3. Environmental Release and Disposal-- You must make separate contidentialityclaims for the release number and the amount ofthe new chemical substance released and otherrelease and disposal information. Mark (X) the "Contidential" box next to each item you claimas confidential. (I)

-- Enter the number ofeach release point identified in the process description, part 

## n, section A, subsection Id(3). (2)

-- Estimate the amount ofthe new substance released (a) directly to the environmentor (b) into control technology (in kg/day or kg/batch), (3)

-- Mark (X) this column ifentries 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 oroff-site land or incineration, POTW, orother (specify» to which the new substancewill be released from that release point (5)

-- a. Describe control technology, ifany, and control etTiciency that will be used to limit the release ofthe new substance to the environment For releases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA hazardous waste. On a continuation sheet, for each sitedescribe anyadditional disposal methods that will be used and whether the waste is subjectto secondaryor tertiary on-site treatment. b. Estimate the amountreleased to the environment after control technology (in kg/day). (6)

-- Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBI). (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (PublicI Owned Treatment Works). Mark (X) ifthe POTW name or NPDES # is confidential business information (C8I). Release Amount ofnew substance eBI Media of Control technology and etTiciency (you may wish to optionallyattach etTiciency data) CBI Number released release

(I) (2a) (2b)**~.&,** SI;Ktal! 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 ifyou attach a continuation sheet. 

## See continuation sheet 9(a) EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 7710-25. 

# II)

# Page 9(a) 

# Continuation Sheet: Part II
- Human Exposure and Environmental Release Section A Industrial Sites Controlledby 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 nothave to complete this section for operations outside the U.S.; however, you mustreport any processing or use activities after import. See the Instructions ManuaL 

### Complete a separate section B for each type of processing. oruse operation involving the new chemicalsubstance. 

### Ifthe 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 thatyou 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, identifyby 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 pointofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaningchemicals (note frequency ifnot used daily or perbatch). (3) Identify bynumber the points ofrelease, including small or intermittentreleases, to the environmentofthe new chemical substance. (4) Please enterthe # ofsites (remember to identify the locations of these sites on a continuation sheet): 

### [I # ofsites



# [gJ Mark (X) this box ifyou 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 numberofworkers exposed for all sites combined. (4)

-- Estimate the typical duration ofexposure per worker in (a) hours per day and (b) days per year. (6)

-- Describe physical form ofexposure and 

### %new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) Estimate the percent ofthe new substance as lormulated when packagedor used as a final product. (9) From the process diagramabove, enter the number ofeach release point. Complete 9-lJ for each release point identified. (10)

-- Estimate the amount ofthe new substancereleased (a) directly to the environment or (b) into control technology to the environment (in kg/day orkglbatch). (12)

-- Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site oroff-site land orincineration, POTW, orother (specify) and control technology, ifany, that will be used to limit the release ofthe new substance to the environment. (14) --Identifybyproducts which may result from the operation.

(3), (5), (8), (11), (13) and (15)

-- Mark (X) this column ifanyofthe oroceedingentries 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 ifyou 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: PartII
- Human Exposure and Environmental Release Section B - Industrial Sites ControlledbyOthers

# OPTIONAL POLLUTION PREVENTION INFORlV1ATION To claiminfonnation in this section as confidential circle orbracket the specific informationthat you claim as confidential. 

# In this sectionyou mayprovide information not reported elsewhere inthis form regarding your efforts to reduce or minimizepotential risks associated with activities surroundingmanufacturing, processing, use and disposal ofthe PMN substance. Please include new informationpertinent to pollutionprevention, including source reduction, recycling activities and saferprocesses or products available due to the new chemical substance. Sourcereduction includes the reduction in the amount ortoxicity ofchemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventorycontrol. Recycling refers to the reclamation ofuseful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, orland disposal. Descriptions ofpollution prevention, source reduction and recycling should emphasize potential riskreduction subsequent to compliance with existingregulatoryrequirements and can be eitherquantitative or qualitative. The EPAis interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure). 

# In addition, information onthe relative cost orperformance characteristics ofthePMN substance to potential alternatives maybe provided. 

# All information provided in this section will be taken into consideration during the review ofthis substance. 

# See Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. Describe the expected net benefits, such as (1) an overallreduction in risk to humanhealth or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation ofwaste materials through recycling, source reduction or other means; (4) a reductioninpotential toxicity or human exposure andlor environmental release; (5) an increase in product performance, a decrease in the costofproduction andlor improved operation efficiency ofthe new chemical substance in comparisonto 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 overallrisk to humanhealth or the environment.



# o Mark (X) this box ifyou attach a continuation sheet. 

# 16

# Part III -- LIST OFATTACHMENTS Attach continuation sheets for sections ofthe 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 ofthe form to which it relates, ifappropriate. Number consecutivelythe pages ofthe attachments. 

### In the column below, enter the inclusive page numbers ofeach 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 ofthe notice form a sanitized version ofallY 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 ifyou attach a continuation sheet. Enter the attachment name and number.

## PHYSICAL**A.~D** 

## CHEMICAL PROPERTIES WORKSHEET To assist EPA's review ofphysical 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 ofthe notice on which the properly appears, the value ofthe properly, the units in which the property is measured (as necessary), and whetherornot the property is claimed as confidential. The physical state ofthe 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 submitthis 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 oftest data. This worksheet is not a substitute for submission oftest data. Properly Mark 

### Page Value (X) if 

### number (a) provided 

### (b) (cl 

## Physical state ofneat substance __(s) (1) (g) 

## Vapor pressure @

## Temperature 

## °C Torr Density/relative density glml 

## Solubility @ 

## Temperature 

## °C giL

Solvent Solubility inwater @ 

## Temperature 

## °C Melting temperature Boiling/ sublimation temperature(ci) torr pressure Spectra Infrared Spectra Dissociationconstant Particle size distribution Octanollwaterpartitioncoefficient 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 ProductSafety Information Sheet 2Pages
- Confidential



# Ii

# Attachment2 InventoryExpert Service (IES) Report 2 Pages
- Confidential

# In Expert Service
A division of theAmerican 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 InventoryExpert Service

A division of theAmerican 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 ofcheck submitted to EPA HQ 

# Accounting Operations Branch 2Pages
- Confidential

# Attachment4 EPIWIN® Analysis