# ~ ^J ~~~%ksIon/ PMNPage 1 ; Page 1 of 18 p. 1 U .S. ENVIRONMENTAL PROTECTION AGENCY 

# A 

# ~'.FPA 11 1 PREMANUFACTURE NOTICE

in the Premanufacture Notice

.

.

. 

# r y$ j o GENERAL INSTRUCTIONS FormApproved. O .M .B. No. 207

0-0012 Date or n

:cei Approval Expires 10-31-96 

# AGENCY USE ONLY

b'A .. .~t~,~~f"!"~a'~~ ~~'~~t,~.I - 

# )~k ffr ~I ><~,



# Ts -[Hj -- You must provide all information requested in this formtothe extent that it is known to or reasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-5545603) . If a user fee has been remitted for this notice (40CFR700 .45), indicate in the boxes above theTS-user fee identification number you have generated . Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, Washington Financial Management Center (3303), P .O . 360399M, Pittsburgh, PA 15251-6399, Arm . TSCA User fee

. Part I - 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 person to submit chemical identity information for you, but your submission will not be complete and the reviewwill not begin unfit EPA receives this infmmation. A letter in support of your submission should reference your TS user fee identification number. You must submit an original and twocopies of this notice including all test data Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture, processing, or use operations to bedescribed in Part II, sections A and B of this notice, reproduce the sections as needed. Part III-LIST OF ATTACHMENTS Attach additional sheets if there is not enough space toanswer a question fully. Label each continuation sheet with the corresponding section heading. In Part 111, list these attachments, any test data or other data and any optional information included in the notice . OPTiONAL INFORMATION You may include any information that you want EPA toconsider in evaluating the new substance. On page 1 I ofthis form, space has been provided for you to describe pollution prevention and recycling information you may have regarding the new substance . So-called `binding" boxes are included throughout this formfor 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 of exemption applications (such as TMEA, LVE, LOREX) where certain information 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 fran later deviating fromthe information (except chemical identity) reported in the form CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claim as confidential . To assert a claimin an attechment, circle or bracket the information you claimas confidential . Ifvou claiminformation in the notices as confidential you must also movide a sanitized version of the nonce (m ludina attachna;ntsl . For additional instructions on claiming information as confidential, read the Instructions Manual .

Mark (x) ifany information in this notice is claimed as confidential . EPA FORM

7710-25 (Rev. 5-95) TEST DATA ANDOTHERDATA Youare required to submit all test data in your possession or control and to provide a description ofall 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 of the new ' chemical substance

. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English)

. not summaries ofdata. must be submitted if they do not appear inthe oven literature. You should clearly identify whether test data is on thesubstanceor on ananalog. 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 of the Premanufacture Notification Rule (40 CFR Part 720) . Test Data (Check Below any included in this notice) " Environmental fate data " Health effects data " Environmental effects data 11 " Physical/Chemical Properties* 0 Yes Yes Yes Yes Other data a Yes

Risk assessments 

# 13 Structure/activity telationshipsO Test data not in the possession or control ofthe submitter 0 ' A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One)

PMN (Premanufacnue Notice) INTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (Low

Volume Exemption) @ 40 CFR 723.50(c)(1) ' '

~. r LOREX (LowReleaselLowExposure Exemption) @ 40 CFR 723.50(cx2) LVE Modification 1 :1 LOREX Modification IS THIS A CONSOLIDATED PMN7 Yes # ofcta:micals or polymers 1 (Prenotice Communication # required enter # on page 3) Replaces previous editions of EPAForm7710-25. 

# 304-7'10

## PMN Page 2 ; Page 2 of 18 p, 2

Public reporting burden for this collection of information is estimated to average 110hours per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Director, Collection Strategies Division (2822), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., N.W ., Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503.



## CERTIFICATION-- A Printed copy of this signature page, with original signature, must be submitted I certify that to the best of my knowledge and belief 1 . The company named in Part 1, section A, subsection 1 a of this notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part 1, Section B

. 2 . All information provided in this notice is complete and truthful as ofthe date ofsubmission. 3. 1 am

submitting with this notice all test data in my possession or control and a description ofall other data known to or reasonably ascertainable by me as required by §720.50 ofthe Premanufacture Notification Rule. Additional Certification Statements : Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: P-cl The Company named in Part 1, Section Ahas remitted the fee of$2500specified in 40 CFR 700 .45(b), or DThe Company named in Part I, Section Ahas remitted the fee of$1000for an Intermediate PMN(defined @ 40 CFR 700 .43) in accordance with 40 CFR 700 .45(b), or El The Company named in Part I Section Ais a small business concern under 40 CFR 700 .43 and has remitted a fee of$100 in accordance with 40 CFR 700 .45(b) . Ifyou 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 : 0The 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 of40 CFR723.50 . ~ The manufacturer is familiar with the terms ofthis section and will comply with those terms; and 0The new

chemical substance for which the notice is submitted meets all applicable exem tion conditions p . 0If this application is for an LVE in accordance with 40 CFR723.50(c)(1), the manufacturer intends to commence manufacture of the exempted substance for commercial purposes within 1 year ofthe date ofthe expiration of the 30 day reviewperiod. 1'he accuracy of the statements you make in this notice should reflect your best prediction of theanticipated facts regarding the chemical substance described herein. An knowin g and willful misinterp retation is subject to criminal penal ty P ursuant to 18 USC 1001 . Confidential Signature and title ofAuthorized Official (Original Signature Required) Date Signature of agent - (if applicable) Date

EPA FORM

7710-25 (Rev. 5-95) Page 2

## PMN Page 3 ; Page 3 of 18 Part I - GENERAL INFORMATION Section A - SUBMITTER IDENTI FICATION la. Person Name ofauthorized official Submitting Position 

# F)cI Notice (in U

.S.) Company Mailing address (number and street) City, State Postal Code b. Agent (if Name ofauthorized official applicable) Position 

# F

Company Mailing address (number and street) 

### City, State Postal Code Telephone (include area code) c. If you are submitting this notice as part ofajoint submission, mark (X) this box . Joint Submitter (if Name ofauthorized official Position 

# - applicable) 

# F 1

Company - Mailing address (number and street) City, State 

### Province, Country Postal Code Telephone (include country or area code) 2. Technical Name ofauthorized official Position Contact (in v U .S.) /~

Company Mailing address (number and street) City, State Postal Code Telephone (include area code) 3. If you have had a prenotice communication (PC) concerning this notice and EPAassigned a PC Number to the notice, enter the number . Mark (X) -- " if none X 4 . If you previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA . Ifyou previously submitted a PMN for this substance enter the PMN Mark (X) ~-1 Z E 1 number assigned by EPA (i .e. withdrawn or incomplete) . --- if none - 5. If you have submitted a notice of Bona fide intent to manufacture or 'Import for the chemical substance covered by this notice, enter the notice number assigned by EPA

. Mark (X) ,--- if none 6 . Typeof Notice - Mark (X) Mark () the "Confidential" box next to any subsection y ou claimas confidential

Manufacture Only Binding Option Mark (X) I 2 . I I I I 0 Import

Only Binding Option Mark (X) I I 3. I I I Both 

## p. 3

Confidential

EPA FORM

7710-25 (Rev. 5-95) Page 3

## p. 4 PMN Page 4 ; Page 4 of 18 Part I - GENERAL INFORMATION - Continued Section B- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substancebased on the ninth Collective Index (9C1) ofCA nomenclature rules and conventions . Mark (X) the "Confidential" box next to an itemy ou claim as confidential Complete either item I (Class 1 or 2substances) or 2 (Polymers) as appropriate . Complete all other items. If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. ConfiIdenti the name, com pan y, and address of that person in a continuation sheet. 10 O dential 1 . Class 1 or 2chemical substances (for definitions ofclass 1 and class 2substances see the Instructions Manual) a. Class of substance - Mark (X) Class I or Class 2 b . Chemical name (Currently correctChemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class I substances aCA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9CI nomenclaturerules and conventions) .

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

Method I (CAS Inventory Expert Service - a copy of the Identification a Method 2(Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula CBI CAS Registry Number (ifa number already exists forthe substance) 

# 5cI

e. For a class I substance, provide a complete and correct chemical structure diagram . For a class 2substance, provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can he reasonably ascertained. Please see the IrPMNInstruction Manual for discussion of "native format" diagramsoftware which can be helpful in reviewing your substance.

Mark (X) this box ifyou attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 4

## p. 5 PMN Page 5 ; Page 6 of 18 Part I - GENERAL INFORMATION - Continued Section B- CHEMICAL IDENTITY INFORMATION- Continued 2. Polymers (For a definition of polymer, see the Instructions Manual . ) Confia . 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 500and dential below1,000absolute molecular wei ghtof that com po sition. Describe the methods of measurement or the basis for yourestimates: GPC U

(i) lowest number average molecular weight : Other U : (Specify below) pMN substance not polymeric (ii) maximum

weight %

below 500molecular weight : (iii) maximum

weight %

below1000 molecular weight : Mark (X) this box ifyou attach a continuation sheet. b You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any itemyou claimas confidential (1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomeror other reactant used in the man

the polymer. ufacture of (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. (4) - Choose "yes" fromdrop down menu ifyou want a monomer or other reactant used at two weight percent or less to be listed as part of

description on the TSCA Chemical Substance Inventory. thepolymer (5) - Mark (X) this column ifentries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes . (7) - Mark (X) this column if entry in column (6) is confidential . Monomer or other reactant and CAS Registry Number Confidential Typical

composition Include in

identity Confidential Maximum

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

## 11 % % 

# 0 %

~ 

# F-1 %

# 0 El- 

# °,° F-1 F1 

# °,° LJ1

. . . . . 

# o ° .°0 - _ °,° El °,° 

# El

# 0

l °,o 

# 1:1 °,°

# ElF-11 

# %

# 0

. El °,° F11 

# -°,° o % o %~, - o °,° o °,° o o %, 0 o %o oA o °,° o %o =1 __ Mark (X) this box ifyou attach a continuation sheet . 

## ~ EPA FORM

7710-25 (Rev. 5-95) Page 5

## PMN Page 6 ; Page 8 of 18 

## p. 6 

# Part I - GENERAL INFORMATION- Continued Section B- CHEMICAL IDENTITY INFORMATION - Continued 3 . Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose . Provide the CAS Registry Number if available . If there are unidentified impurities, enter"unidentified." (b) - Estimate the maximum wei gh t % ofeach im

p uri ty. If there are unidentified im purities, estimate their total wei ght % . Impurity and CAS Registry Number Maximum Confipercent dential (a) (b)

% ®

% © %

%

%

%

% _J Mark (X) this box ifyou attach a continuation sheet. 4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2. Confidential © Mark (X) this box ifyou attach a continuation sheet. 5. Trade identification - List trade names for thenew chemical substance identified in subsection 1 or 2. © Mark (X) this box ifyou attach a continuation sheet . 6 . Generic chemical name - Ifyou 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. Referto the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names. Halide salt of an alkylamine

Mark (X) this box ifyou attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number ifavailable. Byproduct (1) CAS Registry Number Confi- (2) dential None

Mark (X) this box ifyou attach a continuation sheet. EPA FORM

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

## PMN Page 7 ; Page 9 of 18 

## p. 7 

# Part I -- GENERAL INFORMATION-- Continued Section C- PRODUCTION IMPORT ANDUSE INFORMATION : Mark (X the "Confidential" box next to an itemyou claimas confidential . 1, Production volume - Estimate the maximumproduction 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% newchemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10.000 k r, speci fy the volume and mark (x) in the bindin box. If ranted, you are bound to this volume 

## Maximum

first 12-month production (kg/yr) (100% new chemical substance basis) Maximum12-month production (kg/yr) (100%new

chemical substance basis) Confdential Binding

Option - 

# LEK

. 2. Ltse 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 otheruse 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 onfidential business information (CBI) . (3) --Indicate your willingness to have the information provided in column (1) binding . (4) --Estimate the percent oftotal roduction for the first threeyears devoted to each category of use. (5) -Mark (X) this column ifentry in column (4) is confidential business information (CB1) . (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 our control associated with each category of use . (7)-Mark (X) this column ifentry in column (6) is confidential business information (CBI) . (8) -Indicate °/n of roduct 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) indin . (9 -Mark X) this column ifent ies in column (8) is (are) confidential business information (CBI) . Category of use (1) (by function and application i .e. a CBI Binding °n Prod- CBI % in CBI %

ofsubstance expected per use CBI dispersive dye for finishing polyester fibers) ~art uction % Formu

lation (g) hl (2) 13) (4) (5) (6) (7) Sitelimited Consumer Industrial Comerctal Binding

O p tion (9)

I ~ % I %NX

- 11 111, % %

I [] - 11 

# E

M Y% 

# E!ll %

% %



## t .~ °r° °ra 

# I I El j ii111 % 

# '1] %

# H _ * Ifyou have identified a "consumer" use l id 

# ] :1 % 

# %

, p ease prov e on a continuation sheet a detailed description of the use(s) of this chemical substance In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical substance loses its identity in the consumer product . in consumer products. reactions by which this Mark (X) this box ifyou attach a continuation sheet . b . Generic use Ifyou claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the Instruction description Manual for examples ofgeneric use descriptions.



### An open non-dispersive use

U Mark (X)this box ifyou 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, orother Binding information which will be provided to any person whois reasonably likely to be exposed to this substance regarding protective equipment or practices for option the safe handing, transport, use or disposal of the new b t , su s Mark (x) ance. List in part II[ hazard information you include. Mark (X) this box ifyou attach hazard information . 

## maS ~

?Tr~Fl~,~a ^I ' C D I`----rl AFORM

7710-25 (Rev. 5-95) Page 7

## p. 8 PMN Page 8 ; Page 10 of 18 

# Part H- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE Section A- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section A for each type of manufacture, processing, or use operation involving the newchemical 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 op erations after im

port. You must describe these o rations. See instructions manual 1 . Operation description Confia. Identity -- Enter the identity of the site at which the operation will occur. dential Name Site address (number and street) City, Court , State, ZIPcode 

### If the same operation will occur at more than one site, enter the number ofsites. Identify die 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 attachtnents. Mark (X)this box if you attach a continuation sheet. 

### b. Type -- Mark (X) a Manufacturing ~ Processing Ej Use c. Amount and Duration -- Com plete 1 or 2 as a ro riate Maximum

kg/batch (jowl

. tK,, cnenu~l Hours/batch Batches/year substmtce) 1 . Batch Maximum kg/day (ItN)%neit chenucal Hours/day Days/year

substance) 2. Continuous d. Process description U Mark (X) to indicate your willingness to have your process description binding. (1) Diagram

the major unit operation steps and chemical conversions Include interimstorage 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 kg/batch on a 100% new chemical substance basis), and entry point ofall 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. If releasing to two media at the same step, assign a second release number for the second medium . 

### Not applicable . PMN substance will be manufactured overseas and imported into the US

Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 8

## PMN Page 9 ; Page 12 of 18 Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued 2 . Occupational Exposure - You must make separate confidentiality claims forthe description ofworker activity, physical formof the new chemical substance, number of works exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any itemyou claim as confidential . (1) -Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc .) in which workers may be exposed to the substance . (2) -Mark (X) this column if entry in column (1) is confidential business information (CBI) . (3) --Describe any protective equipment and engineering controls used to protectworkers. (4) and (6) - Indicate your willingness to have the information provided in column (3) or (5) binding. (5) -Indicate the physical form(s) of the new chemical substance(e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart of a mixture) at the time ofexposure. (7) -Mark (X) this column ifentry in column (5) is confidential 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 confidential business information (CBI). (10) and (11) --Estimate the maximum duration of the activity for any worker in hours per day and days peryear . (12 -Mark (X) this column ifentries in columns (10) and (11) are confidential business information CBl . Worker activity CBI Protective Equipment/ Binding Physical f_(s) Binding CBI # of CBI Maximum duration CBI (i .e., bag dumping, filling drums)

(1) (2) Engineering Controls (3) Option Mark (r) (4) and %

new substance (5) Option

Marl tc1 (6) (7) Workers

Exposed (9) Hrslday

(1~) Days/yr

(11) (12) 

# u D

Di d 1 0

a Mark (X) this box ifyou attach a cont inuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 9

## p. 10 PMN Page 10; Page 14 of 18 Part LI-- HUMAN EXPOSURE ANDENVIR ONMENTA

L RELEASE -Continued 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 must report any processing or use activities after import . See the Instructions Manual . Complete a separate section B for each type of processing, or use operation involvingthe new chemical substance. If the same operation is performed at more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet . 

### 1 (a) . Operation Description - To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . ( 1 ) - Diagram

the major unit operation steps and chemical conversions, including 'Interimstorage and transport containers (specify - e.g. 5gallon 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°/a new chemical substance basis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) - Either in the diagram or in the text field 1(b) below, identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of these sites on a continuation sheet) : 

### # ofsites CBI

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

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

# *1



# 0

EPA FORM

7710-25 (Rev. 5-95) Page 10

## PMN Page 10a ; Page 15 of 18 p. 11

c. rvoraer rarposurrrcnvironmeneai iceaesse (1) -- Fromthe diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) -Estimatethe number ofworkersexposed for all sites combined. (4) -Estimate the typical duration ofexposure per worker in (a) hours per day and (b) days peryear. (6) - Describe physical formofexposure and% new chemical substance (ifin mixture), and any protective equipment andengineering 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 ofeach release point Complete 9-13 foreach release point identified. (10) -Estimate the amount of the new substance released (a) directly to the environment or (b ) into control technol ogy to the environment (in kg/day or kgPoatch) . ( 12) -Describe mediaof release i .e. stack sir, fugitive air (optional-see Instructions Manual), surface water, on-siteor off -site land or incineration, POTw, or other (specify) and control technology, ifany, that will be used to limit the release of the new substance to the environment. (14) - Identify byproducts which may result fromthe operation. 3), (5 ) , ( 8 ), (11) . (13) and (15) - Mark (X) this column if any of the p roceedingentriesare confidential business information CBI) . Letter of # of Workers CBI Duration Of Exposure 

## CHI Protective Equip. /Engineering Controls/Physical Form and/ % new substance %

in F 

## CBIActivity Exposed ortnulation (1) (Z) (3) (4a) 4b (5) (6 (7) (8) 

### A 2 [] 0 .50 20 .& 1-1 Rubber gloves,Safety goggles, local ventilation/ liquid <1 B 4 D

1 .00 20 .b1 ~Rubber gloves,Safety goggles, local ventilation/ liquid <1 r 11 C 4 ~ 1 .00 20.u+ ~Rubber gloves,Safety goggles, local ventilation/ liquid <1 

# o a

_ 

# _ o 0- 

# 0 T 

# o Release 

## Anrounf of CBI Media of Release & Control Technology Number New 

## CBI Substance Released 9 l0a) (ltlb (I1)

_ (12 (13 1 <0 .01 <0 .01 ~Trapped in cooling system water 2 <0 .01 <0 .01 F1 Trapped in cooling system water 3 <0 .01 <0 .01 F1 Trapped in cooling system water

( 14)-By products: 

### none (15)

Mark (X) this box ifyou attach a continuation sheet, 

## you 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 PMNsubstance. Please include new information pertinent to pollution prevention, includingsource reduction, recyclingactivities and safer processes or products available due to the new chemical substance. Source reduction includes the reduction in the amount or toxicity ofchemical 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 nonenvironmental areas (e.g., occupational or consulner exposure) . In addition, information on the relative cost or performance characteristics of the PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the reviewof this substance . See PMN Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. To claiminformation in the following section as confidential circle or bracket the specific infotmation that claimas confidential .



# OPTIONAL POLLUTION PREVENTION INFORMATION

EPA FORM

7710-25 (Rev. 5-95) Page l0a

## p. 12 PMN Page 11 ;Page 16 of 18 Optional Pollution Prevention Information (Continued) 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 ofwaste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be asubstitute for an existing substance that poses a greater overall ri sk to human health or the environment . No additional information to submit



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

# 0

EPA FORM

7710-25 (Rev. 5-95) Page 1 I

## PMN Page 12 ; Page 17 of 18 

## p. 13 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand 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 consecutively the pages of any paper attachments . In the column below, enter the inclusive page numbers of each attachment . Electronic attachments can be identified by filename. Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice forma sanitized version ofan attachment in which you claim information as confidential . il Attachment name Attachment Filename Attachment a e number ( s) Confidential 1 MSDS of PMN substance f 'ri / 2 IR Spectra of PMN substance .M- Z, 1 D © 3 Report of CAS Inventory expert service 4 Continuation of page 10 aC

~ . 

# L E:1_



# a 0 0 0 a 0 0 0 0 0 Mark (X) this box if you attach a continuation sheet . Enter the attachment name and number . EPA FORM

7710-25 (Rev. 5-95) Page 12

## PMN Page 13 ; Page 18 of 18 

## p. 14 PHYSICAL ANDCHEMICAL 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 property measured, the page of the notice on which the property appears, the valueof the property, the units in which the property is measured (asnecessary), and whether or not theproperty is claimed as confidential . If the attachments are electronic, give the attachment number (found on page 12) at (b). The physical state of the neat substance should be provided. 

### These measured properties should be fortheneat (100%pure) chemical substance. Properties thatare measured for mixtures or formulations should beso noted (% PMN substance in _J . You are notrequired to submit this worksheet; however, EPA strongly recommends thatyou do so, as it will simplify review and ensure that confidential information is properly protected. You shouldsubmit this worksheet as a supplement to our submission oftest data. This worksheet is nota substitute for submission of test data . Property Mark (X Page Value Measvred 01 Con6- (a) 'r provide number d (b) (c) Estimate d"", .l Mak IX) (d) (M or E) 

## Physical state of neat substance ~ ~ (s) 0(1) ~( ) 

# M F-1 Vapor pressure ~ About zero (c~ Tem p erature °C Totr E :1 Densitv/relative densi ty 9/cm3 Solubility @ Temperature °C Solvent Solubili ty in water c Tem p erature °C ~ readily soluble 9/L 

# E

- Melting tem

perature 0C 

# ED Boiling / sublimation temperaturec r, Spectra Infra red spectrum 

## Dissociation constant Particle size distribution Octanol / water p

artition coefficient Henry's Law

constant 

## Volatilization fromwater Volatilization fromsoil H n a , Flammabi lity Explodability Adsorption/ coefficient Other - Specify Other - Specify torr pressure

ElMark (x) this box if youattach a contiraiation sheet Enter onattachment n ." and ~b, 

# F-1 F7/1 I ^I 

# r-1 El F-1 

# F-1 r-1 IF-1 F-1 F-1 F-1 oc

11 ED

r\71 Lai 

# ED IF-1 F-1 F-1 

# El 

# FE:~~ E:~3 

# F El F-1 F-1

ATTACHMENT PAGE 13

## MATERIAL SAFETY DATA San

1. CHEMICAL PRODUCT & COMPANY IDENTIFICATION -CHEMICAL PRODUCT NAME : -NAME OF MANUFACTURER

Z . COMPOSITION / INFOR11ATION ON INGREDIENTS

" SUBSTANCE/IiI$TURE : Substance " CHEMICAL NAME: - " SYNONYMS: " CAS REGISTRY NUMBER: " INGREDIENTS AND camPosinow min . 98 . 0% -CHEMICAL FORMULA. " UN CLASS: none ' UN No. : none 3 . HAZARD INDFIVTIFICATION 'CUSS NAME OF HAZARDOUS CHEMICALS FOR MSDS *PHYSICAL AND CHEMICAL HAZARDS: Heating may -ADVERSE HUMAN HEALTH EFFECTS: cause harmful gases.

This product causes i .rritaing 4 . FIRST AID MEASURES skin and throat . *EYE CONTACT: Gently rinse the affected eyes with clean water

for at least 15 minutes keeping eyelids open. -SKIN CONTACT: Remove all contaminated clothing, shoes and socks

from the effected areas as quickly as possible. Wash the effected area under running water using a mild soap. ,INHALATION

: Remove the victim from the contamination immediately to fresh air. Keep the victim fromwarm sod quiet . If breathing is weak, irregular or has stopped, open his airway, loosen his collar and belt .Arrange for transport to the nearest medical facility for examination and treatment by a physician as soon as possible 

## 'INGESTION: Immediately give the victim one or two glasses milk

or water to dilute chemical .Do not attempt to make victim vomit.

## 6. FIRE-FIGHTING MEASURES

" EXTINGUISHING MEDIA : In case of fire, use water spray, foam dry chemical powder or carbon dioxide . 

## 6. ACCIDENTAL RELEASE MEASURES Evacurate non essential personnel .Sweep up and placed in a washed disposal container . Avoid raising dust . Do not wash away into sewer or water way. 

## 7. HANDLING & STORAGE -HANDLING: later protective equipment . Avoid contact with dust

directly. Avoid rough or dropping. " STORAGE : Store below 409C. Keep away from heat and sunlight .

Keep away from any possible contact with water . 8 . EXPOSURE CONTROL / PERSONAL PROTECTION -CONTROL PARAMETERS: Chemical name Cas No.

not established ACGIH0 OSHA 0 96100

not not (by wt) established established 98.5%up -ENGINEERING MEASURES : Use with local exaust ventilation . Make available emergency shower and eye wash in the wark area. -PERSONAL PROTECTIVE EQUIPMENT: Eye protection: Wear protective chemical safety goggles. Hand, skin and body protection: To prevent any contact, wear impervious clothing such as rubber gloves, rubber boots, long sleeved clothes, as appropriate . Respiratory protection : Dust respirator . Chemical cartridge respirator with an organic vapor cartridge. 

## - -- ------ ----- 9 . PHYSICAL & CHEMICAL PROPERTIES -PHYSICAL STATE: solid -APPEARANCE: white hygroscopic -SOLUBILITY IN WATER : soluble " DENSITY: not determined crystals

-BOILING POINT= not determined " MELTING POINT: 77°C -VAPOR PRESSURE: not determined

## 10

. STABILITY & REACTIVITY -FLASH POINT : not determined -AUTOIGNITION TEMPERATURE: not determined -UPPER AND LOWER EXPLOSION LIMIT: not determined 

## " FLAMMABILITY : not determined -SPONTANEOUS COMBUSTIBILITY : not determined -REACTIVITY WITH WATER: not determined

" OXIDIZABILITY: not determined ,SELF-REACTIVITY: not determined 

## -STABILITY A REACTIBITY: Stable under normal temperatures 

## " HAZARDOUS DECOMPOSITION: harmful fumes of NOx, far 11 .- TOXICOLOGICAL INFORMATION ,ACUTE TOXICITY= no relevant information found -SUB-CHRONIC TOXICITY: no relevant information found -CHRONIC TOXICITY: no relevant information found ,CORROSIVE AND IRRITANT PROPERTIES: eye-mucous and skin irritation test : moderately and pressures

irritative *SENSITIVE EFFECTS: no relevant information found " MUTAGENIC EFFECTS: no relevant information found

" CARCIN0GENICITY : no relevant information found -EFFECTS ON THE REPRODUCTIVE SYSTEM : no relevant information

" TERATOGENIC EFFECTS: no relevant information found 12 . ECOLOGICAL INFORMATION -BIODEGRADABILITY: no imformation " BIOA(xUMULATION: no imformation -FISH TOXICITY: no imformation 13. DISPOSAL CONSIDERATION found

Burn in a chemical incinerator equipped with an afterburner and scrubber. Do not put into other material in the used container and do not use it for other purpose. Treat the contents burned on the above and dispose it .

# 1,L TRANSPORT INFORMATION Any transportation practice must be in compliance with laws and regulation in your country or region. 

## 15 . REGULATORY INFORMATION Regulatory information with regard to this substance in your country or region should be examined by your own responsibility . 

## 16 . OTHER INFORMATION References : 1) These data are measured

## p. 19