KAI

KURARAY AMERICA, INC. O I I A

KIORA RAY

March 18, 2005 -o

Document Control Officer

Office of Pollution Prevention

And Toxic Substances, 7407

U.S. E.P.A. 1200 Pennsylvania, NW

Washington, D.C. 20460

Dear Document Control Officer:

This is a request of filing the significant new use notice for the usage that is mentioned on

page 7 of the premanufacture notice.

SNUN: 721 .532

CHEMICAL: I -Butanol, 3-methoxy-3-methyl, acetate

CAS RN: 103429-90-9

Sincerely yours,

Manager Oas

Fine Chemicals Division

Enclosure:

-Premanufacture Notice (TS-KR8254): 18 pages

KURARAY AMERICA, INC. . 101 EAST 52ND STREET. 26TH FLOOR *NEW YORK, NY 10022

TEL: 212 986-2230 1 FAX: 212 867-3543 * WEB: WW.KURARAY-AM.COM
PMN Page 1

'ProTi.,Awived. O.M B. No.-2-070-0012. Approval Expires 10-31-96.

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY

$# PAPREMANUFACTURE- F 

Contain No OBI

4i' (1~~ I i'~11 0 lI~ ~~I

cas er in the Premanufacture Notice I- t

GENERAL INSTRUCTIONS TS -K IIR 18 12 15 4

" 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 202.554-5603).

" 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, Attn. TSCA User fee.

Part I - GENERAL INFORMATION TEST DATA AND OTHER DATA

You must provide the currently correct Chemical Abstracts (CA) Name of the nlew You are required to submit all test data in your possession or control and to chemical substance, even if you claim the identity as confidential. You may authorize provide a description of all other data known to or reasonably ascertainable by another person to submit chemical identity information for you, but your submission will yoithsdaareeledotehathndnvomnalfecsnte

not be will omplet ot and begi th untilEPA revie reeivmanufactureatiprocessingmanfdistributionsinin icommerce, iuseme or, dispor salso oflthehenew 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 chemical substance. Standard literature citations may be submitted for data in the

claimed any information as confidential, a single sanitized copy must also be submitted open scientific literature. Complete test data (written in English), not summaries

of data. must be submitted if they do not agpear in the open literature. You should

clearly identify whether test data is on the substance or on an analog. Also, the

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE chemical composition of the tested material should be characterized. Following

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

If there are several manufacture, processing, or use operations to be described in Part 11, the requirements of §720.50 of the Premanufacture Notification Rule (40 CFR

sections A and B of this notice, reproduce the sections as needed. Part 720).

Part Ill - LIST OF ATTACHMENTS Test Data (Check Below any included in this notice)

Attach additional sheets if there is not enough space to answer a question fully. Label each * Environmental fate data [] Yes *Other data [ e

continuation sheet with the corresponding section heading. In Part III, list these0Ye

attachments, any test data or other data and any optional information included in the notice. Health effects data El Yes Risk assessments 1

* Environmental effects data E] Yes Structure/activity relationshipsf

OPTIONAL INFORMATION Physicat./Chemical Properties* [E] Yes Test data not in the possession

or control of the submitter i

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

substance. On page I I of this form, space has been provided for you to describe * A physical and chemical properties worksheet is located on the last page of this form.

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

TYPE OF NOTICE (Check Only One)

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

willingness lo be bound to certain statements you make in this section, such as use, F'"1 PMN (Premanufacture Notice)

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, LyE, LOREX) where L..] INTERMEDIATE PMN (submitted in sequence with final product PMN)

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

Agen~cy approves the exemption application, checking a binding box in this notice does not SNUN (Significant New Use Notice)

by itself prohibit the submitter from later deviating from the information (except chemical I3

identity) reported in the form. El TMEA (Test Marketing Exemption Application)

CONFIDENTIALITY CLAIMS M] LVE (Low Volume Exemption) @ 40 CFR 723.50(c)1

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. El. LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(c)X2)

To assertsa claim in an attachment, circle or bracket the information you claim as

confidential. If you claim information in the notices as confidential. You must alto provide I1 LVE Modification [] LOREX Modification a sanitized version of the notice. includine attachments). For additional instructions on E :

claiming information as confidential, read the Instructions Manual.IST SACO OLD EDPNYe

Mark (a) if any informstion in this notice is claimed as confidential. # of chemicals or polymers 1

(Prenotice Communication # required, enter # on page 3)

EPA FORM 7710-25 (Rev. 5-95) ~2 .~ 3Replaces previous editions of EPA Form 7710-25.
PMN Page 2 ; Page 2of 18

Public reporting burden for this collection of information 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 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 I, section A, subsection la of this notice form intends to manufacture or import for a

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

Section B.

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

3. 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 SNIJN, check the following user fee certification

statement that applies:

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

E] The Company named in Part 1, 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:

QThe 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.

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

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

E] If this application is for an LyE 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.

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. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 1 UJSC 1001. Confidential

Signatue nd 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 3of 18

Part I1-- GENERAL INFORMATION

Section A -- SUBMITTER ]IDENTIFICATION ConfiMark ()the "Confidential" box next to any subsection ou claim as confidential dential

Ia. Person Name of authorized official Positon

Submitting HIROAKI YOSH-INO PRESIDENT

Notice (in U.S.)

Company

KU.RARAY AMERICA, Inc.

b. Aget (if Mameiof authriz(ued ofcald Posrteo)

CtSaePostal Code Tlpoe(ncueae oe

b.ointmt (if Name of authorized official Position

applicable) K

Coinpany

Mailing address (number and street)CiySte

Proine, Cuntry Postal Code Telephone (include con rarea code)

2.in Technical(i Name of authorized official Position

Company

Mailing address (number and street)CiySte

Croity, ate y Postal Code Telephone (include arcodr re) oe

3.ICouave had a prenotic OH comniainNP)cocAGnEhiRoic R n

byEAsietwtdawrrinop ~~~~~aln number assine drs et)

5. If you have sumtd a notice fomm natioein t t)onc turein ori iortic n

for th ge eial d sCu bc ere th y notice, s enter the n tier. inhe Mark (X) -

assgnd b EA. f rif noneE :

4. ~ ~ ~ ~ neepio ~ I plcto]freceia Maufctr 2.u [rvosysbite 6. btpe o ee otice ti , ene-h xmto nmesindb OnyIpot3 Mark (X) 

EPA. ~ ~ M ~ orti usac ~ etrtePI ~ ~ ~ P9-9 ~ Ol foe Bothrvosysumte 

Binding Optione Binyn Optionwihranoricopet)

Type ofNtc Mar Mark (X)Onyol13. Bt

EPA FORM 77 10-25 (Rev. 5-95) Page 3
PMN Page 4 ; Page 4of 18

Part I -- GENERAL INFORMATION - Continued

Section B - CHEMICAL EDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth

ICollective Index (9C) of CA nomenclature rules and conventions.

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

Complete either item 1 (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 esther Item I or 2), mark (X) the box at the right. ConfiIdentify the name, company, and address of that person in a continuation sheet. Edetstial

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

a. Class of substance - Mark (X) I El CasI o 2 D Cas2

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

Class 1 substances a CA hIdex 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).

1-Butanol, 3-methoxy-3-methyl-, acetate

C. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one). rn Method 1 (CAS Inventory Expert Service - a copy of the Identification 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

C8H1603 (ifsa number already I

[ ] exists for the substance)

103429-90-9

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 be reasonably ascertained. Please see the E-PMIN Instruction Manual for

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

CH30

H3C-C-CH2-- CH 2-0--CH 3

OCH 3
PMN Page 4a ; Page 5of 18

For a class 2 substance - (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 of composition and the typical composition (where appropriate).

e. (1) List the immediate precursor substances with their respective CAS Registry Numbers. ConfiName (CAS #) dential

El

e. (2) Describe the nature of the reaction or process.

e. (3) Idicate the range of composition and the typical composition (where appropriate). E

I1 Mark (X) this box if you attach a continuation sheet.

EPA FORM 7710-25 (Rev. 5 -95) Page 4a
PMN Page 5 ; Page 6ofl18

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 of the polymer you intend to manufacture.

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and

below 1,000 absolute molecular weight of that cornposition.

Describe the methods of measurement or the basis for your estimates: GPC LJ Other L : (Specify below)

(i) lowest number average molecular weight: __________

(ii) maximum weight % below 500 molecular weight:

(iii) maximum weight % below 1000 molecular weight:_________

C] 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 (ifsa 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) -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 the 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 Include in Confi- Maximum Confidential composition identity dential rcsidual dential

_ _ (__ _)__ (2) - (3) (4) -(5) (6) (7)

F1] % [illh]__

_____U[I]]__

_____DFI DEI-D _______% _%_

1:11 E1

____ ____ l__ ~ L%

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

EPA FORM 7710-25 (Rev. 5-95) Page 5
PMN Page 5a; Page 7 of 18

C. Please identify which method you used to develop or obtain the specified chemidcal identit information reported in this notice (check one). CB1

ElMethod 1 (CAS Inventory Expert Service - a copy of the identification report F]Method 2 (other source)

obtained from CAS Inventory Expert Service must be submitted as an attachment to this notice) EzI

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers.

CAS Registry Number (ifsa number already exists for the substance)

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

see the E-PMN 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 77 10-25 (Rev. 5-95) Page 5a
PMN Page 6 ;Page 8 of 18

Part I -- GENERAL INFORMATION -- Continued

Section B - CHEMICAL IDENTITY INFORMATION - Continued

3. Impurities

(a) - Identify each impurity that may be reasonably anticipated to he present in the chemical aubstance aa 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 impurities, estimate their total weight%._____

Impurity and CAS Registry Number Maximum Confi

percent dential

(a) _b

a -Methoxy-3 -methyl-l-mnethoxymethyloxybutane 0.3 0 Eii

3 -Mvethoxy-3 -methyl- 1-butanol 0.7

EMark (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. Confi3 -1ethyl -3 -methoxybutyl acetate dential

MMB -AC

Solfit -AC

U 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.

MMB -AC[I

E 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.

U 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.

BpoutCAS Registry Number Confi-

()(2) dential NONEi

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

EPA FORM 77 10-25 (Rev. 5-95) Page 6
PMNPagB7 ;Page9 of 18

Part I -- GENERAL INFORMATION -- Continued

-Section C - PRODUCTION, IMPORT, AND USE INFORMATION:

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

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

production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100%/ new chemical

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than

10,000 kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Confi- Binding

(10% ewcheicl ubtane ass)(100% new chemical substance basis) dential Opin (10% bais)Mark nw cemial ubsanc Wx

100,000 200,000 1111

2. Use Information - You must make separate confidentiality claims for the description of the category of use, the percent of production volume devoted to each

category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claim as confidential.

a. (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 (CR1). (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 colun 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

eour control associated with each category of use. (7) --Mark (X) this column if entry in column (6) is confidential business information (CR1). (8) --Indicate % of

3roduct 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)

)inding. (9) --Mark CX) this column if entry(iea) in column (8) is (are) consfidential business inforn ion_(CBI). ____________________

Category of use (1) (by function and application i.e. a CB1 Binding Prod- CBI % in CBI % of substance expected per use CBI fo oleserfier)Option fnihig uc on Forrnu (8) dispersive dye frfnsigpletribs)Mark ulto

(2) (3) (4) (5) (6) (7) 5s- Cons. indus- Com- Binding (9) lmited inner tial miercial Option ___

Organic solvent of polyurethane [1%F1o

plastic coating 5000

Ingredient of various kinds of [%F 1 O

paint thinner 37.5 i 100

Organic solvent of polyurethane % ~[ l=

resin L..ij6.5 L.... ~100

Ingredient of cleaning agent, %i [ %1 1[1-

especially for commercial use J 30 JJ 10 ~~

organic solvent for screen ink D -%0 IILi

______EIlF~l%[ % _ _ _ _ __ _ __ E1 *If you have identified a "consumer" use, please provide on a continuation sheet a detailed descniption of the use(s) of this chemical substance in consumer products.

In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this

substance loses its identity in the consumer product.

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

b. 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

description Manual for examples of generic use descriptions.

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

EPA FORM 7710-25 (Rev. 5-95) Page 7
PMN Page 8;Pagel 0 of 18

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RIELEASE

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 operations. See instructions manual

I. Operation description Confia. Identit -- Enter the identit of the site at which the operation will occur. dential

Name

Site address (number and street)

ICity, County, State, ZIP code F

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

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

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

sites as attachments.

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

b. Type --

Mark (X) ui Manufacturing Processing Use ] c. Amount and Duration -- Complete 1 or 2 as appropriate

Maximum kg/batch 0 00% new chemical Hours/batch Batches/year

1. Batchsubstance)

Maximum kg/day (itoo% new chemical Hours/day Days/year

2. Continuous Substance) [ I

d. Process description 1:1 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.

Enter your descriptive text here. There is space on the next page for a separate file name and/or

a PDF diagramn.

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

EPA FORM 7710-25 (Rev. 5-95) Page 8
PMN Page 8a; Pagel11 of 18

Confidential

-I

EPA FORM 7710-25 (Rev. 5-95) Page 8a
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 aa confidential.

(1) --Describe the activitiea (i.e. bag dumping, tote filling, unloading drams, aampling, cleaning, etc.) in which workera 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 (CB 1).

(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 (CB0.

(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 columrn if entries incolumns (10) and (11) are confidential business information(CB~ - ___ __.__ __ Worker activity CBI Protective Equipment/ Binding Physical Binding CBI # of CBI Maximum duration CBI

forms(s)

(i.e., bag dumping, filling drums) Engineering Controls Option and % new Option Workers Hrs/day Days/yr

Mark Wa substance Mark ( xoe

()(2) (3) (4) (5) (6) Exposed (9 (10) (11) (12

____ 5-5_ _____ _Liz2 (8)v 
PMN Page 9a; Pagel13 of 18

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

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

(1) -Enter the number of each release point identified in the process description, part II, aection A, subsection I d(3).

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

(3) -- Mark (X) this column if entries in columns (1) and (2) are confidential business information (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 substance will be released from that release point.

(5) -- a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases

disposed of on land, characterize the dispoal method and state whether it is approved for dispoal of RCRA hazardous waste. On a continuation sheet, for

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate the

amount released to the environment after control technology (in kg/day).

(6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI).

(7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or

NPDES numbers of the POT' (Pub~licly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (C 1)

Release Amount of new CBI Medium of Control technology and efficiency (you may wish to optionally attach CBI

Number substance released release efficiency data) __________

(1) (2a) (2b) c.g -ka Binding

(3) (4) (5a) (X)(b) (6)

_[I __D Dro

[I]e[I) D

- g ( Xvi a e w a te r.a--- t 

provide namne(s) D

EU Other--Specify

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

EPA FORM 7710-25 (Rev. 5 -95) Page 9a
PMN Page 10; Page 14 of 18

Part 11-- 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 Bfor 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 1 00%/ 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): # fstsCBI

Diagram the major unit operation steps and chemical conversions...

I1(b). (Optional) Thbis apace is for a text description to clarify the diagram above.II

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

EPA FORM 7710-25 (Rev. 5-95) Page 10
PMN Page IlOa ;Page 15 of 18

2. Worker Exposure/Environmental Release

(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 kgfbatch).

(12) --Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)

and control technology, if any, that will be used to limit the release of the new substance to the environment.

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

- ~ of8 ~ () (5) (11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI). ____

Letter o ~ DurationrOf CI Protective Equip. /Engineering Controls/Physical Form and! % new substance % i B

of Workers EposureFom

Acti- Exposed uao vity

(1) (2) (3) (a 4) (5) (6)(7 (8

_1 __ i __ _ _ El

_0E ______ El.

Release Amount of CBI Media of Release & Control Technology CR1

Number New

Substance

Released ____________________________________________________

(9) QlOa) (10b) (11) (12) (13)

14) -- Byproducts. (15)

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

OPTIONAL POLLUTION PREVENTION INFORMATION

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

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

associated with activities surrounding manufacturing, processing, use and disposal of the PMIN substance. Please include new information

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

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

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

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

land disposal. Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to

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

assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or nonenvironmental areas (e.g., occupational or consumer exposure). In addition, information on the relative cost or performance characteristics of

the PMN substance to potential alternatives may be provided.

All information provided in this section will be taken into consideration during the review of this substance. See PMIN Instructions

Manual and Pollution Prevention Guidance manual for guidance and examples.

EPA FORM 7710-25 (Rev. 5-95) Page 10a
PMN PagelI1 ;Pagel16 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 risk to human health or the environment.

MMB-AC is one of the alternatives of "'Butyl Cellosolve Acetate''. CBI

MMB(3-Methoxy-3-methyl-l-butanol) 

its toxicity thoroughly. The toxicological 

is the parent study compound 

revealed 

of 

that MMB-AC, 

MMB has 

and no we activity have investigated of

E

reproduction toxicity. so in Japan MMB is regarded as the best and the unique alternatives of Butyl Cellosolve.

In Japan, MMB and MMB-AC are commonly used as solvents with strong solvency, moderately high

boiling point and good volatility rate, suitable for resious paont such as polyurethane-type.

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

EPA FORM 7710-25 (Rev. 5-95) Page I11
PMN Page 12 ; Pagel17 of 18

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 any attachment in which you claim information as confidential.____________________

# Attachment name Attachment Filename Attachment Conni-

_______________________________________________________________________ _______page____number__ se)nmbes detia

1 CAS Registry Number(Inventry Expert Service Report) I _______ I

2 Material Safety Data Sheet (MMsB-AC) 115-24 11

3 Infra-Red Spectrum __________ ______ I

4 Physical and Chemical properties worksheet 13-14 l - 5 Chemnial Oxygen Demand __________j______ LI

6 Biological oxygen demand _________ ______ E L

7 Biodegradability ~Attached Data ij EL

Attached Data-2 J 1II

~Attached Data 3 j 11

8 Acute Oral Toxicity to Rats 1:1

9 Acute Dermal Toxicity in Rats I

10 Acute Dermal Irritation Test in Rabbits 11

11 Magnusson-Kligman maximisation test in Guinea Pigs 0 _i

12 Acute Eye Irritation Tset in Rabbits LI1

13 Mutagenicity test LI

14 Material Safety Data Sheet (MMB) ELl

15 Toxicity Testing Reports of Environmental Chemicals MMB:p571-6S5 1I1

Vol.10 2003(Chemicals Investigation Promoting Council) lii

16 SIDS Report of MMB LI

SIDS Initial Assessment Report for SIAM 18 LI

SIDS INITIAL ASSESSMENT PROFILE FII

(SIAM 18 Paris,20-23 Apr.2004) 1II

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

EPA FORM 7710-25 (Rev. 5-95) Page 12
UPS Internet Shipping: Shipment Label 1/1 'i $

UPS Internet Shipping: View/Print Label

1. Print the label(s): Select the Print button on the print dialog box that appears. Note: If your

browser does not support this function select Print from the File menu to print the label.

2. Fold the printed label at the dotted line. Place the label in a UPS Shipping Pouch. If you do not

have a pouch, affix the folded label using clear plastic shipping tape over the entire label.

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Customers without a Daily Pickup

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Hand the package to any UPS driver in your area.

Take your package to The UPS StoreTM, Customer Center or Authorized Shipping Outlet.

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Customers with a Daily Pickup

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FOLD HERE

C 0 

0-_ r: If)

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