~ ^J ~~~%ksIon/ PMN Page 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 

Form Approved . O.M .B . No. 2070-0012 

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 form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do 

not have actual data. 

Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-5545603). 

If a user fee has been remitted for this notice (40 CFR 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, 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 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 review will 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 two copies of this notice including all test data If you 

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

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described 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 to answer 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 to consider in evaluating the new 

substance. On page 1 I of this 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 form for you to indicate your 

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

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

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

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

certain 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 from the information (except chemical identity) reported in the form 

CONFIDENTIALITY CLAIMS 

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

form, mark (X) the confidential box next to the information that you claim as confidential . To assert a claim in an attechment, circle or bracket the information you claim as 

confidential . Ifvou claim information 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 AND OTHER DATA 

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

provide a description of all other data known to or reasonably ascertainable by 

you, if these data are related to the health and environmental effects on the 

manufacture, processing, distribution in commerce, use, or disposal 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 oven literature. You should clearly identify whether test data is on the substance or on an analog. Also, the 

chemical composition of the tested material should be characterized . Following 

are examples of test data and other data. Data should be submitted according to 

the requirements of §720.50 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 of the 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 (Low ReleaselLow Exposure Exemption) @ 40 CFR 723 .50(cx2) 

LVE Modification 

1:1 

LOREX Modification 

IS THIS A CONSOLIDATED PMN7 Yes 

# of cta:micals or polymers 1 

(Prenotice Communication # required enter # on page 3) 

Replaces previous editions of EPA Form 7710-25. 

304-7'10 
PMN Page 2 ; Page 2 of 18 p, 2 

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

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

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 form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part 1, 

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 of the Premanufacture Notification Rule. 

Additional Certification Statements : 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies: 

P-cl The Company named in Part 1, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

D The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

700.43) in accordance with 40 CFR 700.45(b), or 

El The Company named in Part I Section A is 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 CFR 723.50(c)(2), check the following certification 

statements : 

0 The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723 .50. 

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

0 The new chemical substance for which the notice is submitted meets all applicable exem p tion conditions . 

0 If this application is for an LVE in accordance with 40 CFR 723 .50(c)(1), the manufacturer intends to commence manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period . 

1'he 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 knowin g and willful misinterp retation is subject to criminal p enalty Pursuant to 18 USC 1001 . Confidential Signature and title of Authorized 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 

Notice (in U.S.) F)c I 

Company 

Mailing address (number and street) 

City, State Postal Code 

b. Agent (if Name of authorized 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 of a joint submission, mark (X) this box. 

Joint Submitter (if Name of authorized 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 of authorized 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 

EPA assigned 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 

number assigned by EPA (i .e. withdrawn or incomplete). --- 

if none Z E - 1 

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. Type of Notice - Mark (X) 

Mark () the "Confidential" box next to any subsection you claim as 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 substance based on the ninth 

Collective Index (9C1) ofCA nomenclature rules and conventions. 

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

Complete either item I (Class 1 or 2 substances) 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, company, and address of that pe rson in a continuation sheet. 10 O dential 

1 . Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances see the Instructions Manual) 

a. Class of substance - Mark (X) Class I or 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 9CI 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 I (CAS Inventory Expert Service - a copy of the Identification a Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula CBI CAS Registry Number 

(if a number already 

exists for the substance) 5c I 

e. For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance, provide a correct representative or 

partial chemical structure diagram, as complete as can be known, if one can he reasonably ascertained. Please see the IrPMN Instruction Manual for 

discussion of "native format" diagram software which can be helpful in reviewing your substance. 

Mark (X) this box if you 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 500 and 

dential 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC U 

(i) lowest number average molecular weight : 

Other U : (Specify below) 

pMN substance not polymeric 

(ii) maximum weight % below 500 molecular weight : 

(iii) maximum weight % below 1000 molecular weight : 

Mark (X) this box if you 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 item you claim as confidential 

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the man 

the polymer. 

ufacture of 

(2) - Mark (X) this column if entry in column (1) is confidential . 

(3) - Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(4) - Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of 

description on the TSCA Chemical Substance Inventory. 

the polymer 

(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 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 

°,° 

. . . . . o LJ1 

°.° 0 

- 

_ °,° 

El °,° 

El 0 l 

°,o 

1 :1 °,° El F-1 1 

% 0 

. El °,° F1 1 - 

°,° 

o o - % °,° o o % °,° ~, 

o 0 o o %, o % o A o °,° 

Mark (X) this box if you attach a continuation sheet. o __ =1 % o ~ 

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 weight % of each impurity . If there are unidentified impu rities, estimate their total weight %. 

Impurity and CAS Registry Number Maximum Confipercent dential 

(a) (b) 

% ® 

% 

% 

© 

% 

% 

% 

% 

_J 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 if you attach a continuation sheet. 

© 

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

© 

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

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals 

the specific chemical identity of the new chemical substance to the maximum extent possible . Refer to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

Halide salt of an alkylamine 

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

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

Byproduct 

(1) 

CAS Registry Number Confi- 

(2) dential 

None 

Mark (X) this box if you 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 AND USE INFORMATION: 

Mark (X the "Confidential" box next to an item you claim as confidential . 

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

production volume for any consecutive 12-month period during the first three years of production . Estimates should be on 100% new chemical substance basis . For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10 .000 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) 

Maximum 12-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 other use information. Mark (X) the "Confidential" Box next to any item you claim as confidential . 

a. (1) -Describe each intended category of use of the new chemical substance by function and application . (2) -Mark (X) this column if entry column (1) is onfidential business information (CBI). (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total roduction for the first three years devoted to each category of use. (5) -Mark (X) this column if entry in column (4) is confidential business information (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 if entry 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 if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) indin . (9 -Mark X) this column if ent 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 % of substance expected per use CBI dispersive dye for finishing polyester fibers) ~ar t uction 

% 

Formu 

lation 

(g) 

hl 

(2) 13) (4) (5) (6) (7) Sitelimited 

Consumer 

Industrial Comerctal 

Binding 

Option 

(9) 

I ~ 

% 

I 

% 

NX 

- 

11 111 , 

% % 

I [] - 

11 M E Y%E!l l 

% 

% % 

t.~ 

°r° °ra 

I I El 

j i i111 

% 

' 1] 

% 

_ H 

* If you 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 if you attach a continuation sheet. 

b

description 

. Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the Instruction Manual for examples of generic use descriptions . An open non-dispersive use 

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

3. Hazard 

information 

Information 

which will 

- 

be 

Include 

provided 

in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding to any person who is 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 ance . List in part II[ hazard information Mark (x) you include . Mark (X) this box if you attach hazard information. maS ~?Tr~Fl~,~a ^I ' 

CD I`----rl A FORM 7710-25 (Rev . 5-95) Page 7 
p. 8 

PMN Page 8 ; Page 10 of 18 

Part H- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

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

claim as confidential 

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

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

there are further industrial processing or use operations after import. You must describe these o rations. See instructions manual 

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

Name 

Site address (number and street) 

City, Court , State, ZIP code 

If the same operation will occur at more than one site, enter the number of sites . Identify die 

additional sites on a continuation sheet, and if any of the sites have significantly different 

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

sites as attachtnents. 

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

b . Type -- 

Mark (X) a Manufacturing ~ Processing Ej Use 

c. Amount and Duration -- Complete 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 interim storage and transport containers (specify- e.g . 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). 

(2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch.). 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 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 if you 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 for the description of worker activity, physical form of the new chemical substance, number of works exposed, and duration of activity . Mark (X) the "Confidential" box next to any item you 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 protect workers. 

(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 (if part of a mixture) at the time of exposure. 

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

(8) -Estimate the maximum number of workers involved in each activity for all sites combined . 

(9) --Mark (X) this column if entry in column (8) is confidential business information (CBI). 

(10) and (11) --Estimate the maximum duration of the activity for any worker in hours per day and days per year . 

(12 -Mark (X) this column if entries in columns (10) and (11) are confidential business information 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 if you 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 AND ENVIRONMENTAL 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 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 of processing, or use operation involving the 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 claim information in this section as confidential, circle or bracket the specific information that you claim as confidential . ( 1 ) - Diagram the major unit operation steps and chemical conversions, including 'Interim storage and transport containers (specify - e.g. 5 gallon pails, 55 gallon drums, rail 

cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity . (2) -- Either in the diagram or in the text field 1(b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100°/a new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) - Either in the diagram or in the text field 1(b) below, identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. (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 if you 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) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -Estimate the number of workers exposed for all sites combined . 

(4) -Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) - Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect workers. 

(7) - Estimate the percent of the new substance as formulated when packaged or used as a final product 

(9) -From the process diagram above, enter the number of each release point Complete 9-13 for each release point identified. 

(10) -Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kgPoatch). 

( 12) -Describe media of release i.e . stack sir, fugitive air (optional-see Instructions Manual), surface water, on-site or off -site land or incineration, POTw, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the environment. 

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

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

Letter 

of 

# of 

Workers 

CBI Duration Of 

Exposure 

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

F 

CBI 

Activity 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 

Number 

Release 0- Anrounf of 0T 

CBI Media of Release & Control Technology 

o 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 if you attach a continuation sheet, 

In you 

associated 

this section 

with 

you 

activities 

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

pertinent to pollution prevention, 

surrounding manufacturing, processing, use and disposal of the PMN substance. Please include new information 

chemical substance. Source 

including source reduction, recycling activities and safer processes or products available due to the new 

process and procedure 

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

reclamation of useful chemical 

modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the 

land disposal . Descriptions of pollution 

components from wastes that would otherwise be treated or released as air emissions or water discharges, or 

compliance with existing regulatory requirements 

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

assess overall net reductions 

and can be either quantitative or qualitative. The EPA is interested in the information to 

environmental areas (e .g., occupational 

in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or nonthe PMN substance to potential alternatives 

or consulner exposure). In addition, information on the relative cost or performance characteristics of may be provided . 

Manual 

All information 

and Pollution 

provided 

Prevention 

in this section will be taken into consideration during the review of this substance. See PMN Instructions Guidance manual for guidance and examples . 

To claim information in the followin g section as confidential circle or bracket the specific info tmation that claim as confidential . 

OPTIONAL POLLUTION PREVENTION INFORMATION 

EPA FORM 7710-25 (Rev . 5-95) Page l 0a 
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 of waste 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 a substitute 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 if you 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 form and test data and other data (including physical/chemical properties and 

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

which it relates, if appropriate . Number consecutively the pages of 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 claim as confidential . Read the Instructions Manual for guidance on 

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

version of an 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 

Mark (X) this box if you attach a continuation sheet. Enter the attachment name 

0 

and number . 

EPA FORM 7710-25 (Rev . 5-95) Page 12 
PMN Page 13 ; Page 18 of 18 

p. 14 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

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

include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property 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 for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

formulations should be so noted (% PMN substance in _J. You are not required to submit this worksheet; however, EPA strongly 

recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should submit 

this worksheet as a supplement to our submission of test data . This worksheet is not a 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) 

(M or E) (d) 

Physical state of neat substance ~ ~ (s) 0(1) ~( ) M F-1 

Vapor pressure 

~ About zero (c~ Temperature °C Totr 

Densitv/relative density E:1 9/cm3 

Solubility 

@ Temperature °C 

Solvent 

Solubili ty in water c Temperature °C ~ readily soluble 9/L E 

- 

Melting temperature 0C ED 

Boiling / sublimation temperature c r, 

Spectra Infra red spectrum 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volatilization from water 

Volatilization from soil 

H n a, 

Flammabi lity 

Explodability 

Adsorption / coefficient 

Other - Specify 

Other - Specify 

torr pressure 

ElMark (x) this box if you attach a contiraiation sheet Enter on attachment n ." and ~b, 

F-1 

F7/1 

I ^ I 

r-1 

El 

F-1 

F-1 

r-1 

I 

F-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 from warm 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 

ACGIH 0 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