## U .S. ENVIRONMENTAL PROTECTION AGENCY

#  _ PRFMAN,F,Cr,IaF 5u1ii0m9;~0u0u0ii0m4 mi,6uiiiu

Whrn complctcd Send thlS fonn to Enter the total number of pages in the Premanufacture Notice

. 

### GENERAL INSTRUCTIONS TS- P 0 1 I=T You must provide all information requested in this formto the extent that it is known to or reasonably ascertainable byyou. 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 taxing 202-554-5603) . If a user fee has been remitted for this notice (40CFR 700 .45), indicate in the boxes above the TS-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, HQAccounting Operations Branch (PM-226), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee. Part 1-GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance. even ifyou claim the 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 until EPA receives this information. A letter in support ofyour submission should reference your TS user fee identification number . You must submit an original and two copies of this notice including all test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part 11-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part 11 . sections A and B of this notice, reproduce the sections as needed. Part 11I - LIST OF ATTACHMENTS 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 II L list these attachments, any test data or other data and any optional information included in the notice. U .S . E .P.A. 401 M

STREET, SW WASHINGTON, D

.C. 20460 

## 101 p

## .1 Fonn Approved. O

.M .B. No. 2070-0012. Approval Expires 10-31-96. Date of receipt 

# AGENCY USE ONLY

CS

TEST DATAANDOTHERDATA You are 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, ifthese 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 of data, must be submitted if they do not appear in the open literature. Youshould clearly identify whether test data is on the substance or on an analog. Also, the chemical composition ofthe 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 ofthe Premanufacture Notification Rule (40 CFR Part 720) .

Test Data (Check Belowany included in this notice) Environmental fate data D Yes " Other data E] Yes " Health effects data ® Yes Risk assessments " Environmental effects data 0 Yes Structure/activity relationships OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page 11 of this form, 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 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 TM EA . 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 from later deviating fromthe information (except chemical identity) reported in the fonn. 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 claimas confidential . To assert a claim in an attachment, circle or bracket the information you claimas confidential . If you claiminformation in the notices as confidential, you must also provide a sanitized version ofthe notice, (including attachmentsl . For additional instructions on claiming information as confidential, read the Instructions Manual . ® Mark (x) if any information in this notice is claimed as confidential .

cDn cnun,n 77tn IC ,D, . ., c ncN Physical/Chemical Properties* 0 Yes Test data not in the possession or control of the submitter * A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One) ® PMN (Premanufacture Notice)

INTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant NewUse Notice) TMEA (Test Marketing Exemption Application) LVE (LowVolume Exemption) (rg 40 CFR723.50(c)(1) LOREX (LowRelease'LowExposure Exemption) (& 40 CFR 723.50(c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? LOREX Modification Yes N of chemicals (Prenotice Communication 4 required, enter #t on page 3) 

# 319944- 09JUN 19



# Company Sanitized 1

Docgme control umb4q - EPA case number/~~~

, 6 (f' T~'7ID~

D. .. .1 .. .. .. . . .- ... ., . : . . .. .,r . : . . . . .. ,.e cDA c, . ._. . 771 1) ~e

### Public reporting burden for this collection ofinformation is estimated to average 1 10 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 information. Send comments regarding the burden estimate or any other aspect of this collection ofinformation, including suggestions for reducing this burden, to Chief, Information 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 formintends 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. 1 am

submitting with this notice all test data in my possession or control and a description of all other data known to or reasonably ascertainable by me as required by §720.50 ofthe Premanufacture Notification Rule. Additional Certification Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: ®The Company named in Part 1, Section Ahas remitted the fee of $2500 specified in 40 CFR700 .45(b), or F-1 The 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 F-1 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) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR723.50(c)(2), check the following certification statements : The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 CFR723.50 . F~ The manufacturer is familiar with the terms of this section and will comply with those terms; and 0The new

chemical substance forwhich the notice is submitted meets all applicable exemption conditions. Ifthis 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 of the date of the expiration ofthe 30 day reviewperiod. The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An y knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001 . Confidential Signature and title ofAuthorized Official (Original Signature Required) Date 

## X Signature of agent - (if applicable) Date 

## .2

EPA FORM

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

## p. 3 Part I -- GENERAL INFORMATION Section A-- SUBMITTER IDENTI FICATION 1a. Person Name ofauthorized official Position Submitting Notice (in U

.S.) Company Mailing address (number and street) 

### City, State, ZIP Code b. Agent (if Name of authorized official Position applicable) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number

e . If you are submitting this notice as part of ajoint submission, mark (X) this box. Joint Submitter (if Name of authorized official Position applicable) Company

Mailing address (number and street) 

### City, State, ZIP Code Telephone Area Code Number 2 . Technical Name of authorized official Position Contact (in 

## X U.S.) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number

3 . Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number . Mark (X) -~ ® if none 4. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by Mark (X) ~ ® EPA. Ifyou previously submitted a PMN for this substance enter the if none PMN number assigned by EPA (i .e. withdrawn or incomplete) .-~ 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 Mark (X) ~ ® assigned by EPA. ~ if none 1 . ® Manufacture 2 . ~ Import 6 . Type of Notice - Mark (X) Only Only 3. El Both Binding Option El Binding Option Mark (X) Mark (X) Mark () the "Confidential" box next to an subsection you claimas confidential Confidential

EPA FORM

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

## p. 4 Part I -- GENERAL INFORMATION-- Continued Section B-- CHEMICAL IDENTITY INFORMATION : You must provide a currently correctChemical 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 an itemy ou claim

as confidential Complete either item 1 (Class 1 or 2 substances) or 2(Polymers) as appropriate. Complete all other items. Ifanother person will submit chemical identity information for you (for either Item l or 2), mark (X) the box at the tight . Confi

### Identify the name, com

pany, and address of that person in a continuation sheet . 0 dential 1 . Class 1 or 2chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class of substance - Mark (X) 1 [:] Class 1 or 2 [ :] 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 Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9C1 nomenclature rules and conventions) .

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

Method 1 (CAS Inventory Expert Service - a copy ofthe Identification ~ Method 2 (Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

### CAS#

e. For a class 1 substance, provide a complete and correct chemical structure diagram . For a class 2substance - (1) List the immediate 

### precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the range ofcomposition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diaemm, as complete as can be known, if one can be reasonablv ascertained. 

# ****This page intentionally left blank.****

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

EPA FORM

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

## p. 5 Part I -- GENERAL INFORMATION-- Continued Section B-- CHEMICAL IDENTITY INFORMATION -- Continued 2. Polymers (For a definition of polymer, see the Instructions Manual .) Confidential a. Indicate the number-average weight of the lowest molecular weight composition ofthe polymer you intend to manufacture. Indicate maximum

weight percent of lowmolecular weight species (not including residual monomers, reactants, or solvents) below 500 and X below1,000absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC EI Other Fl : (Specify)

i) lowest number average molecular weight : ii) maximum

weight %

below500 molecular 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 infonnation. 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 monomer or other reactant used in the manufacture of

the polymer. (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent of each monomer or other reactant in the polymer. (4) - 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 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 Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential (1) (2) (3) (4) (5) (6) (7) 

## X % X % X X % X % X X % X % X X % X % X X % X % X X % X % X X °ia X % X ®Mark (X) this box if you attach a continuation sheet. c. Please identify which method you used to 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 report ~ Method 2 (other source) X obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice) d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers. X

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

## X 

# See Attachment 3

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

EPA FORM

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

## p. 6 Part I -- GENERAL INFORMATION-- Continued Section B--CHEMICAL IDENTITY INFORMATION--Continued 2 . Polymers (For a definition of polymer, see the Instructions Manual .) Confidential a. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymer you intend to manufacture . Indicate maximum

weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below500and below [,000absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC E] Other 0 : (Specify) i) lowest number average molecular weight: 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 (ifa number exists) of each monomer or other reactant used in the manufacture of

the polymer.

. (2) - Mark (X) this column ifentry in column (1) is confidential . (3) - Indicate the typical weight percent of each monomer orother reactant in the polymer. (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 ofthe polymer

description on the TSCA Chemical Substance Inventory . (5) - Mark (X) this column if entries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. (7) - Mark (X) this column if entry in column (6) is confidential . Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential (1) (2) (3) (4) (5) (6) (7) 

## X °i° X X °i° X X °i° X X °i° X

°i° °i° °i° °i° °i° °i° °i° % °i° °i° Mark (X) this box if you attach a continuation sheet. c . Please identify which method you used to 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 report El Method 2 (other source) obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice) d. Thecurrently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers.

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

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

EPA FORM7710-25 (Rev. 5-95) Page 5 6~-

## p. 7 

# 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.

CAS Registry Number if available. Ifthere are unidentified impurities, enter "unidentified." (b) - Estimate the maximum wei g ht % of each im

purity. Ifthere are unidentified im p urities, estimate theirtotal wei g ht % . Provide the Impurity and CAS Registry Number

(a) Maximum percent (b) Confidential 

## % X % % % % % 

# _T

% Mark (X) this box if you 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 . 

## X

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

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

### X

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 ofthe 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. 

## 2-Propenoic acid, 2-methyl-, C12-15-branched and linear alkyl esters, telomers with Alkyl 2- [[(alkylthio)thioxomethyl]thio]-2-alkanoate, aminoalkyl methacrylate and alkyl methacrylate, tert-Bu 2- ethyl hexanoperoxoate-initiated

Mark (X) this box if you attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal ofthe new chemical substance. Provide the CAS Registry Number ifavailable. Byproduct (I) CASRegistry Number (2) Confidential 

# X

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

EPA FORM

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

## p. 8 

# Part I -- GENERAL INFORMATION -- Continued Section C-- PRODUCTION, IMPORT,ANDUSE INFORMATION : Mark (X) the "Confidential" box next to any itemyou claimas confidential . 1 . Production volume -- Estimate the maximumproduction volume during the first 12 months ofproduction. 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, specify the volume and mark (x) in the binding box. If ranted, you are bound to this volume 

## Maximum

first 12-month production (kg/yr) Maximum12-month production (kg/yr) Confi- Binding (100%new

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

## X 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 claimas confidential . a. (1) -- Describe each intended category of use of the new chemical substance by function and application. . (2) -- Mark (X) this column if entry column (1) is confidential business information (CBI) . (3) -- Indicate your willingness to have the information provided in column (1) binding. (4) -- Estimate the percent of total production for the first three years devoted to each category ofuse. (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 %

ofproduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) -- Mark (X) this column if ent (ies) in column (8) is (are) confidential business information (CBI) . Category of use (1) CBI B ;nding Opuon Produc- CBI % in CBI % ofsubstance expected per use CBI tion % Form- (8) (by function and application i .e. a dispersive dye Mu3(<t ulation Site- Con-* Indus- Com- Binding

forfinishing polyester fibers) (2) (4) (5) (6) (7) limited sumer trial mercial O p tion (9) 

## X 100% X 50% X 100 X

n

n u

o n

n a 

## n n o * If you have identified a "consumer" use, please provide on a continuation sheet a detailed descri tion of the use(s) f thi h i l b i p o s c em ca su stance nconsumer products. In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. OMark (X) this box ifyou attach a continuation sheet. b . Generic Ifyou 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 ofgeneric use descriptions. 

## description Lubricant additive

~ 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 Binding information which will be provided to any person whois reasonably likely to be exposed to this substance regarding protective equipment or practices Option for the safe handing, transport, use, or disposal of the new substance

. List in part III hazard information you include . Mark (x) ® Mark (X) this box if you attach hazard information.

EPA FORM7710-25 (Rev. 5-95) Page 7

## p. 9 

# Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section Afor 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 op erations. See instructions manual l . Operation description Confia. Identity -- Enter the identity of the site at which the op eration will occur. dential Name 

# X Site address (number and street) City, County, State, ZIPcode 

### 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 ifany of the sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

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

### b. Type -- 

# X Mark (X) DManufacturing OProcessing aUse c . Amount and Duration -- Com plete 1 or 2 as a ro riate Maximum

kg/batch (100°o new chemical Hours/batch Batches/year 

# X substance) 

## 1 . Batch 18,750 28 4-8

Maximum

kg/batch (100%new

chemical Hours/batch Batches/year substance) 2. Continuous d. Process description El Mark (X) to indicate your willingness to have your process description binding . (1) Diagramthe 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 ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance.

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

EPA FORM7710-25 (Rev. 5-95) Page 8

## p. 10



# 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 formof the new chemical substance, 

### number of works exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any itemyou claimas confidential . ( I ) -- Describe the activities (i .e. bag dumping, tote tilling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) --Mark (X) this column ifentry in column (l) 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 infonnation provided in column (3) or (5) binding. (5) -- Indicate the physical fonn(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if part ofa mixture) at the time of exposure. (7) -- Mark (X) this column if entry in column (5) is confidential business information (C131) . (8) -- Estimate the maximum number of workers involved in each activity for all sites combined. (9) -- Mark (X) this column if entry in column (8) is confidential business information (CBI) . (10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year. (12) -- Mark (X) this column ifentries in columns (10) and (11) are confidential business infonnation (CBI) .

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI m (i .e., bag dumping, filling drums) Engineering Controls Option and % new Option Worker Hrs/day Days/yr Muk t`I substance Mat (x) s (1) (Z) (3) (4) (5) (6) (7) Expose (9) (t0) (tI) (IZ) 

### d (8) 

## X X X X X X X X X X X X

~ Mark (X) this box if you attach a continuation sheet . 3. Environmental Release and Disposal -- You must make separate confidentialityclaims for the release number and the amount of the new chemical substance released and other release and disposal infonnation. Mark (X) the "Confidential" box next to each itemyou claimas confidential . ( I) -- Enter the number of each release point identified in the process description, part 11, section A, subsection l d(3). (2) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). (3) -- Mark (X) this column ifentries in columns (1) and (2) are confidential business infonnation (CBI). (4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which the new

substancewill be released fromthat release point. (5) --a. Describe control technology, if any, and control efficiency that will be used to limit the release ofthe new substance to the environment. For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste . On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment . b. Estimate the amount released to the environment after control technology (in kg/day) . 

### (6) --Mark (X) this column ifentries in columns (4) and (5) are confidential business information (C131) . (7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publicl Owned Treatment Works) . Mark (X) ifthe POTW name or NPDES # is confidential business infonnation (CBI) . Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Number released release ( 1) (2a) (2b) e .g. cisckmr Binding 

### (3) (4) (Sa) Mork(x) (Sb) (6) 

## X X X 2 X X X X X X

(7) Mark (X) the ~ POTW provide name(s) below : CB1 11 Navigable El Other - Specify provide NPDES# CBI destination(s) of waterway releases to water. la Mark (X) this box ifyou attach a continuation sheet. EPA FORM

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

## p. 11



# Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section B-- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfor 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. Ifthe same operation is performed at more than onesite describe the typical operation common to these sites

. Identify additional sites on a continuation sheet. 

### 1 . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claim as confidential . ( l ) -- 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 cats, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kg/batch, on an 100%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) -- Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enter the # of sites (remember to identify the locations of these sites on a continuation sheet) : 

### # of sites

~ Mark (X) this box ifyou attach a continuation sheet . 2. Worker Exposure/Environmental Release ( l ) -- Fromthe 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 fonn ofexposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, ifany, used to protect workers

. 

### (7) -- Estimate the percent of the newsubstance as fot7nulated when packaged or used as a final product . (9) -- From

the process diagramabove, enter the number ofeach release point

. Complete 9-13 for each release point identified. (10) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) -- Describe media ofrelease 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 ofthe new substance to the environment. (14) -- Identify byproducts which may result fromthe operation. (3), (5), (8), (11), (13) and (l5) --Mark (X) this column if any of the proceedingentries are confidential business information (CBI) . Letter # of CBI Duration CBI Protective Equip. / %in CBI Release Amount of CBI Media of Release CBI ofActWorkers

Exposed of Engineering Controls/ Formi Number New &Control ivity Exposure Physical Formand o/a ulat on Substance Technology new substance Released (1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (106) (I1) (12) (13)

( 14) -- Byproducts : (15) 11 Mark (X) this box if you attach a continuation sheet,

EPA FORM

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

## p. 12



# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in this section as confidential circle or bracket the specific information that you claimas confidential . 

# In this section you may provide information not reported elsewhere in this formregarding 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, 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 EPAis 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 reviewof this substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and exam ples. 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 humanexposure 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 a substitute for an existing substance that poses a greater overall risk to human health or the environment.

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

EPA FORM7710-25 (Rev. 5-95) Page 11

## 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 formto which it relates, if appropriate. Number consecutively the 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 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 of the notice forma sanitized version of an attachment in which you claiminformation as confidential . Attachment name Attachment a e number(s) Confidential 

## Material Safety Data Sheet SDS 

## 14-19 2. General comments 20 X 3. Idealized structure 21 X 4. Inventory Expert Services Report 22 X 5. Occupational Exposure During Manufacture (Part II .A .2) 23-24 X 6. Worker Exposure (Part II .B.2) 25 X 7. Process Description 26 X 8. Gel Permeation Chromatograms 27-34 X 9. UV Spectrum 35-36 X 10 . Infrared Spectrum 37-39 X 11 . NMRAnalyses 40-42 X 12. Acute Oral Toxicity in the Rat 43-58 X 13. Reverse Mutation Assay "Ames Test" 59-91 X 14. Confidentiality Statement 92-101 X

L ~ Mark (X) this box ifyou attach a continuation sheet . Enter the attachment name and number .

EPA FORM

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

## PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's reviewof 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 ofthe notice on which the property appears, the value ofthe property, the units in which the property is measured (as necessary), andwhether or not 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 (% PMNsubstance in ) . Youare not required to submit this worksheet ; however, EPAstrongly recommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected. Youshould submit this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission oftest data. Property (a) Mark (x) if provided Page

number b ( ) Value e) Measured o Estimate (M or E) Confideotial Mark(X) (d) 

## Physical state of neat substance (s) X (1)- (g) M Vapor pressure @ Temperature °C Torr Density/relative density 0 .9 g/cm3 E Solubility @ Temperature °C Solvent /L Solubility in water Temperature °C g/L Melting temperature Boiling / sublimation temperature cu torr pressure °C Spectra (UV-Vis, FTIR, NMR) X 35-42 M X Dissociation constant Particle size distribution Octanol / water partitioncoefficient Henry's Law

constant Volitalization fromwater Volitalization fromsoil

_ pH@v concentration Flammability Explodability Adsorption / coefficient Other - Specify 

## .14

ATTACHMENT per_G 1111

# Pgge l of 6

Material Safety Data Sheet

TS-P0151T

Prepared according to 29CFR 1910.1200 . 1 Chemical Product and Company Identification The Lubrizol Corporation 29400Lakeland Boulevard Wickliffe, Ohio 44092 Tel : (440) 943-4200 This material is to be used for research purposes only under the supervision of a technically qualified individual . The toxicological properties may have not been completely characterized. To determine your responsibilities under the Toxic Substances Control Act (TSCA), please see the Regulatory Information Section. If this material has been supplied to you under the terms of a secrecy or non-analysis agreement, the information included in this MSDS is hereby identified as "Confidential Information." Product Trade Name CAS Number Synonyms Generic Chemical Name Product Type Preparation/Revision Date Transportation Emergency Phone No. MSDS No. 2 Appearance Odor Principal Hazards TS-P0151T Unknown. None. Modified acrylic polymer Not applicable. 16 June 2009 FORTRANSPORT EMERGENCYcall CHEMTREC : (+1) 703-527-3887 (outside the U .S .), 1-800-424-9300 (in the U .S .) 27340430-2512956-0027910-102103 Hazards Identification Light amber liquid. Mild

. This material has no known health hazards. See Section 11 for complete health hazard information . 

# F 3 Hazardous Ingredients 4 Eyes Composition/Information on Ingredients This material has no known hazards under applicable laws . First Aid Measures Flush with water at least 30minutes. Get medical attention if eye irritation develops or persists. 

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Skin Inhalation Oral Additional Information 5 Flash Point Extinguishing Media Firefighting Procedures Unusual Fire &Explosion Hazards 

# F 6 Spill Procedures

7 Pumping Temperature Maximum

Handling Temperature Handling Procedures MaximumStorage Temperature Storage Procedures Loading Temperature 8 Exposure Limits Other Exposure Limits Engineering Controls Gloves Procedures Eye Protection Respiratory Protection Clothing Recommendation 9 Wash with soap and water. Get medical attention if irritation develops. Launder contaminated clothing before reuse. Remove exposed person to fresh air if adverse effects are observed. DO NOT INDUCE VOMITING. Get immediate medical attention. Note to physician: Treat symptomatically . Fire Fighting Measures

> 110°C, 230 °F PMCC (Minimum) C02, dry chemical, or foam . Water can be used to cool and protect exposed material . Recommend wearing self-contained breathing apparatus. Water may causesplattering. Not determined. rAccidental Release Measures Personal Protective Equipment must be worn, see Personal Protection Section for PPE recommendations. Ventilate area if spilled in confined space or other poorly ventilated areas. Prevent entry into sewers andwaterways. Pick up free liquid for recycle and/or disposal . Residual liquid can be absorbed on inert material . Handling and Storage Not determined. Not determined. Keep containers closed when not in use. Wash thoroughly after handling . Empty container contains product residue which may exhibit hazards of product . , Notdetermined. No special storage precautions required. Not determined. Exposure Controls/Personal Protection None established Contains mineral oil . Under conditions which maygenerate mists, observe the OSHA PEL of 5 mg per cubic meter, ACGIH STEL of 10 mg per cubic meter. Use with adequate ventilation. Use nitrile or neoprene gloves . Safety Glasses. Use NIOSH/MSHA approved respirator with a combination organic vapor and high efficiency filter cartridge if recommended exposure limit is exceeded. Use self-contained breathing apparatus for entry into confined space, for other poorly ventilated areas and for large spill clean-up sites. Long sleeve shirt is recommended. Launder contaminated clothing before reuse. Physical and Chemical Properties Flash Point > 110 °C, 230 °F PMCC (Minimum)

# Pa'ge 3 of 6

Upper Flammable Limit Lower Flammable Limit Autoignition Point Explosion Data Vapor Pressure pH Specific Gravity Bulk Density Water Solubility Percent Solid PercentVolatile Volatile Organic Compound Vapor Density Evaporation Rate Odor Appearance Viscosity Odor Threshold Boiling Point Pour Point Temperature Melting / Freezing Point

10 Stability Decomposition Temperature Incompatibility Polymerization Thermal Decomposition Conditions to Avoid 11 Eye Irritation Skin Irritation Respiratory Irritation Dermal Toxicity Inhalation Toxicity Oral Toxicity Dermal Sensitization Not determined. Not determined. Not determined. Material does not have explosive properties. Not determined. Not determined. 0 .93 (15.6 °C) Not determined. Insoluble. Not determined. Not determined. Not determined. Not determined. Not determined. Mild Light amber liquid. Not determined. Not determined. Not determined. Not determined. Not determined. The above data are typical values and do notconstitute a specification . Vaporpressure data are calculated unless otherwise noted . Stability and Reactivity Material is normally stable at moderately elevated temperatures and pressures . Not determined. Oxidizing agents. Will not occur. Smoke, carbon monoxide, carbon dioxide, aldehydes and other products of incomplete combustion. Not determined. [Toxicological Information 1 ---

-- ACUTE EXPOSURE -- Not expected to cause eye irritation Based on data fromcomponents or similar materials. Not expected to be a primary skin irritant . Based on data fromcomponents or similar mateials. Prolonged or repeated skin contact as fromclothing wet with material may cause dermatitis. Symptoms may include redness, edema, drying, and cracking of the skin. If material is misted or if vapors are generated fromheating, exposure may cause irritation of mucous membranes and the upper respiratory tract. Basedon data fromcomponents or similar materials. The LD50 in rabbits is > 2000 mg/Kg. Based on data fromcomponents or similar materials. No data available to indicate product or components may be a toxic inhalation hazard. The LD50 in rats is > 2000 mg/Kg. Based on actual data. No data available to indicate product or components may be a skin sensitizer .

# Pz'gA of 6

Inhalation Sensitization No data available to indicate product or components may be respiratory sensitizers.

-- CHRONIC EXPOSURE -- Chronic Toxicity No data available to indicate product or components present at greater than 1%are chronic health hazards. Carcinogenicity This product contains mineral oils which are considered to be severely refined and not considered to be carcinogenic under IARC . All of the oils in this product have been demonstrated to contain less than 3% extractables by the IP 346test . Mutagenicity No data available to indicate product or any components present at greater than 0 .1% are mutagenic or genotoxic. Reproductive Toxicity No data available to indicate either product or components present at greater than 0 .1°/o that may cause reproductive toxicity. Teratogenicity No data available to indicate product or any components contained at greater than 0.1%may cause birth defects.

-- ADDITIONAL INFORMATION -- Other No other health hazards known . 12 Ecol ogi cal Information

-- ENVIRONMENTAL TOXICITY -- Freshwater Fish Toxicity Not determined. Freshwater Invertebrates Not determined. Toxicity Algal Inhibition Not determined. Saltwater Fish Toxicity Not determined. Saltwater Invertebrates Not determined. Toxicity Bacteria Toxicity Not determined. Miscellaneous Toxicity Notdetermined.

-- ENVIRONMENTAL FATE -- Biodegradation Adequate data is not available to estimate the biodegradation potential of this material . Bioaccumulation There is no data available to evaluate this material for bioconcentration. Soil Mobility Not determined. 13 Disposal Considerations Waste Disposal This material, if discarded, is not a hazardous waste under RCRARegulation 40 CFR261 . Treatment, storage, transportation, and disposal must be in accordance with applicable Federal, State/Provincial, and Local regulations. 14 I Transport Information ICAO/IATAI Not regulated. ICAO/IATAII Not regulated. IMDG Not regulated. IMDG EMS Fire Notapplicable. IMDG EMS Spill Notapplicable. IMDG MFAG Notapplicable. 

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MARPOL Annex II USCG Compatibility U .S. DOT Bulk U .S. DOT Non-Bulk DOT NAERG TDGBulk TDGNon-Bulk Mexico Mexico Non-Bulk Bulk Quantity Non-Bulk Quantity

115

USA

Other TSCA Reg

. EU Japan Australia New Zealand Canada Switzerland Korea Philippines China SARA Ext. Haz. Subst. SARA Section 313 SARA 311 Classifications

CERCLA Hazardous Substances FDAApproval Not determined. Not determined. Not regulated. Not regulated

. Not applicable. Not regulated

. Not regulated. Not regulated. Not regulated. 85000liters, 22457 gal . 207.8 liters, 55 gal . Review classification requirements before shipping materials at elevated temperatures . Regulatory Information

-- Global Chemical Inventories -- Requires notification in the U .S. Commercial shipments fromLubrizol's U .S. location must be exported to non U

.S. customers only. Research and development quantities must bear special labels and shipping papers. Sample recipients must comply with the requirements for an R&D exemptionunder TSCA. None known. All components are in compliance with the EC Seventh amendment Directive 92 /32/EEC . This product requires notification in Japan. This product requires notification before sale in Australia. This product requires notification before sale in New Zealand. This product requires notification before sale in Canada. All components are in compliance with the Environmentally Hazardous Substances Ordinance in Switzerland. This product requires notification before sale in Korea. All components are in compliance with the Philippines Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990 (R.A. 6969) . This product requires notification in China.

-- Other U

.S. Federal Regulations -- This product does notcontain greater than 1 .0%of anychemical substance on the SARA Extremely Hazardous Substances list. This productdoes not contain greater than 1 .0%(greater than 0.1% for carcinogenic substance) of any chemical substances listed under SARA Section 313 . A cute Hazard No Chronic Hazard No Fire Hazard No Reactivity Hazard No None known. Not applicable.

-- State Regulations -- Cal . Prop. 65 This product does not intentionally contain any chemicals known by the State of California to 

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cause cancer and/or birth defects. Moreover, we do not routinely analyze its products for impurities which may be such chemicals.

-- Product Registrations -- U .S. Fuel Registration Not applicable. U .S. Dept of Agriculture This product has not been filed with the USDA to support H2 approvals. NSF Nonfood Compounds This product has not been filed with the NSF to support H1 or H2 approvals. Registration Finnish Registration Number Swedish Registration Number Norwegian Registration Number Not Registered Not Registered Not Registered Danish Registration Not Registered Number Swiss Registration Number Not Registered Italian Registration Number Not Registered Korean Registration Number Not Registered

-- Other / International -- TDGRegulated Limit. None known. 16 Other Information US NFPA Codes

HMIS Codes Precautionary Labels Health Fire Reactivity Special 1 1 0 ~ N/E (N/E) - None established Health Fire Reactivity 1 1 0

. This material has no knownhealth hazards. Revision Indicators This MSDS has no revisions since 16 June 2009 As the conditions or methods ofuse are beyond our control, we do not assume any responsibility and expressly disclaimany liability for any use ofthis product. Information contained herein is believed to be true and accurate but all statements or suggestions are made without warranty, expressed or implied, regarding accuracy ofthe information, the hazards connected with the use ofthe material or the results to be obtainedfromthe use thereof . Compliance with all applicablefederal, state, and local regulations remains the responsibility ofthe user.



# 6/16/09

# ATTACHMENT 2 General Comments Page 20

# ATTACHMENT 3 Idealized Structure Page 21

# ATTACHMENT 4 Inventory Expert Services Report

Page 22

# ATTACHMENT 5 Occupational Exposure During Manufacture (Part II .A.2) Pages 23-24

# ATTACHMENT 6 Worker Exposure (Part II .B.2)

Page 25

# ATTACHMENT 7 Process Description Pages 26

# ATTACHMENT 8 Gel Permeation Chromatogram

Pages 27-34

# ATTACHMENT 9 UV Spectrum Pages 35-36

# ATTACHMENT 10 Infrared Spectrum Pages 37-39

# ATTACHMENT 11 NMR Analyses Pages 40-42

# ATTACHMENT 12 Acute Oral Toxicity in the Rat

Pages 43-58

# ATTACHMENT 13 Reverse Mutation Assay "Ames Test"

Pages 59-91

# ATTACHMENT 14 Confidentiality Statement Pages 92-101