PMN (Premanufacture 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) LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(c)(2)
LOREX Modification

• Yes IS THIS A CONSOLIDATED PMN?

LVE Modification 

# Li


# 1 SES 

## p. 1

Form Approved. 0.M.B. No. 2070-0012. Approval Expires 10-31-96. 

### U.S. ENVIRONMENTAL PROTECTION AGENCY 

# or.P A PREMANUFACTURE NOTICE AGENCY 

## USE ONLY D lie of receipt



# 5: f



# or' Company Sanitized
Enter the total number ot pages in the Premanufacture Notice 

# i t 

# 'oh io l OCI EPA e num

.... 

# I ■ GENERAL INSTRUCTIONS 

## TS - G 

# 10 

# 181 C 

# 101

• 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, HQ Accounting Operations Branch (PM-226), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee.

Part I — GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even if you 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 until EPA receives this information. 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 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 open 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 ta_the requirements of §720.50 of the Premanufacture Notification Rule (40 CFR Part 720).

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 continuation sheet with the corresponding section heading. In Part III, list these attachments, any test data or other data and any optional information included in the notice. • Environmental fate data

• Health effects data

• Environmental effects data

• Physical/Chemical Properties* El Yes • Other data 

### 1:1 Yes

• Yes Risk assessments El Yes Structure/activity relationships Yes Test data not in the possession 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 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 from 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 attachment, circle or bracket the information you claim as confidential. If you claim information in the notices as confidential, you must also provide a sanitized version of the notice, (including attachments). For additional instructions on claiming information as confidential, read the Instructions Manual. 

# n Mark (x) if any information in this notice is claimed as confidential. or control of the submitter

• A physical and chemical properties worksheet is located on the last page of this form. IYPE OF NOTICE (Check Only One)

# of chemicals XT Li Manager, Product StewardshipL1 FORMTEXT LILIXL1 EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 

### company Li LI H FORMTEXT LILIEvonik Goldschmidt Corporation 

### ri 

# 315007

## .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 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 la of this notice form commercial purpose, other than in small quantities solely for research and Section B. 2. All information provided in this notice is complete and truthful as of the 3. I am submitting with this notice all test data in my possession or control reasonably ascertainable by me as required by §720.50 of the Premanufacture



### Additional Certification Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, statement that applies: intends to manufacture or import development, the substance identified

date of submission. and a description of all other data known Notification Rule.

check the following 

### user fee certification
specified in 40 CFR 700.45(b), or for an Intermediate PMN (defined @

40 CFR 700.43 and has remitted
with 40 CFR 723.50(c)(1) or a 723.50(c)(2), check the following

the new chemical substance for commercial under the terms of 40 CFR 723.50. with those terms; and applicable exemption conditions.
the manufacturer intends to commence 1 year of the date of the expiration of

facts regarding the chemical substance USC 1001. 

### for a in Part I,

to or

40 CFR

a fee of $100 in



### Low release certification

the 30 day The Company named in Part I, Section A has remitted the fee of $2500 The Company named in Part 

### I, Section A has remitted the fee of $1000 700.43) in accordance with 40 CFR 700.45(b), or The Company named in Part 

### I Section A is a small business concern under accordance with 40 CFR 700.45(b). If you are submitting a 

### low volume exemption (LVE) application in accordance 

### and low exposure exemption (LoRex) application in accordance with 40 CFR statements: The manufacturer submitting this notice intends to manufacture or import purposes, other than in small quantities solely for research and development, The manufacturer is familiar with the terms of this section and will comply
The new chemical substance for which the notice is submitted meets all If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), manufacture of the exempted substance for commercial purposes within review period.
The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 Confidential Signature and title of Authorized Official (Original Signature Required) Date X
Signature of agent - (if applicable) Date

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

## P. 3 Part I -- GENERAL INFORMATION

Section A — SU BMITTER IDENTIFICATION ConfiMark 0 the "Confidential" box next to any subsection you claim as confidential dential I a. Person Name of authorized official Submitting Notice (in U.S.) Position 

## X

Company
Mailing address (number and street)
City, State, ZIP Code

Position b. Agent (if Name of authorized official applicable) Company

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

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

Company
Mailing address number and street , City, State, ZIP Code Telephone Area Code Number

. Technical Name of authorized official Contact (in U.S.) Position X

Company
Mailing address number and street

City, State, ZIP Code Telephone Area Code Number

.. 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) LII X if none

. If you previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA. If you previously submitted a PMN for this substance enter the Mark (X) X if none PMN number assigned by EPA (i.e. withdrawn or incomple v).

### ■ 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) Li X if none 1. Manufacture ) Type of Notice - Mark (X) Only Binding Option 2. Import Only Binding Option Mark (X) 3. El Both

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 correct Chemical Abstracts (CA) name of the substance based on the ninth Collective Index (9CI) 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) If another person will submit chemical identity information for Identify the name, company, and address of that person in a continuation as appropriate. Complete all other items. you (for either Item 1 or 2), mark (X) the box at the right. Contidential sheet.■ • 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) 1 Class 1 or 2 1=1 Class 2 X 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 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). X

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one). Identification El Method 2 (Other Source) must be Method 1 (CAS Inventory Expert Service - a copy of the report obtained from the CAS Inventory Expert Services submitted as an attachment to this notice) d. Molecular formula and CAS Registry Number (if a number already exists for the substance) X
CAS# X

e. For a class 1 substance, provide a complete and correct chemica structure diagram. 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). (4) Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.



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

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.)

a Indicate the number-average weight of the lowest molecular weight composition of the polymer Indicate maximum weight percent of low molecular weight species (not including residual below 1,000 absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC i) lowest number average molecular weight: you intend monomers, reactants,
Other : (Specify)

to manufacture. or solvents) below 500 and Confidential 

## X

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 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 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 (1) Contidential (2) Typical composition ( 3 ) Identity

Mark (X) (4) Confidential (5) Maximum

residual (6) Confidential ( 7 ) X % 

## X % 

## X X % 

## X % 

## X X % 

## 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 1 (CAS Inventory Expert Service

- a copy of the identification report Method 2 (other source) obtained from CAS Inventory Expert Service must be submitted as as attachment to this notice) X

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

## X

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

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 3. Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide the

CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." (b) - Estimate the maximum wei ht % of each im urity. If there are unidentified impurities, estimate their total weight %. Impurity and CAS Regktry Number

(a) Maximum percent (b) Confidential
% X

%

%

%

%

%

%

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.

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

5.


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

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

6.



# LIII Mark 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 chcmira1 cnhctance. tn the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

### Alcohol, alkoxylated

(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 (2) Confidential X



# LIII Mark (X) this box if you attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 6

## P. 7 

## 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 1 0,000 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 (kg/yr) (100% new chemical substance basis) Maximum 12-month production (kg/yr) (100% new chemical substance basis) Confi

dential Option

Binding 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 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 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 of use. (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 % of product 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 entry(ies) in column (8) is (are) confidential business information (CBI). Category of use (1) (by function and application i.e. a dispersive dye for finishing polyester fibers) CBI
(2) Binding

Option Mark (x) (3) Produc

### tion % (4) CBI
(5) % inFormulation (6) CBI
(7) % of substance expected per use (8) CBI
(9)Sitelimited Con-*

sumei Industrial Cornmercial Binding

Option X X X X

% %
% %

% %
% %
% % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description 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. Mark (X) this box if you attach a continuation sheet. 

### b. Generic If you 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 of generic use descriptions. 

### description 

### wetting agent



# LII 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 information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. 

# LII Mark (X) this box if you attach hazard information. Binding Option Mark (x)

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

## p. 8 

## 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 (kg/yr) (100% new chemical substance basis) Maximum 12-month production (kg/yr) (100% new chemical substance basis) dential Confi 

### - Binding

Option Mark (x)


### X 2. Use Information -- You must make separate confidentiality clai ns 

### 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 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 of use. (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 % of product 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 entry(ies) in column (8) is (are) confidential business information (CBI). Category of use (1) (by function and application i.e. a dispersive dye for fi nishing polyester fibers) CBI
(2) Binding

Option Mark (x) ( 3) Produc

### tion % (4) CBI
(5) % inForm

### ulation (6) CBI
(7) % of substance expected per use (8) CBI
(9) 

### Site limited 

### Con

- 

### *

sumer Industrial Comntercial Binding

Option X % X % X X

% %
% %
% %
% %
% %
% % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description 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. Mark (X) this box if you attach a continuation sheet. 

### b. Generic If you 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 of generic use descriptions. 

### description 

### wetting agent

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 information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (X) this box if you attach hazard information. Binding Option Mark (x)

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

# 6,6

### P. 9 

## 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 (kg/yr) (100% new chemical substance basis) Maximum 12-month production (kg/yr) (100% new chemical substance basis) Confi

- dential Option

Binding Mark (x)


### X
2. Use Information -- You must make separate confidentiality clai ns 

### 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 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 of use. (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 % of product 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 entry(ies) in column (8) is (are) confidential business information (CBI). Category of use (1) (by function and application i.e. a dispersive dye for finishing polyester fibers) CBI
(2) Binding

Option Mark (x) (3) Production % (4) CBI
( 5 ) % inForm

### ulation (6) CBI
(7) % of substance expected per use (8) CBI
(9)

### Sitelimited 

### Con-*

sumer Industrial Cornmercial Binding

Option X % X % X X

% %
% %
% %

% % % % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description 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. 

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

### b. Generic If you 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 of generic use descriptions. 

### description 

## wetting agent



# I Mark (X) this box if you attach a continuation sheet. 3. information for Hazard Information

— Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other

which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (X) this box if you attach hazard information. Binding Option Mark (x)

EPA FORM 7710-25 (Rev. 5-95) Page 7 (b

## p. 10 Part II-- 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 operations. See instructions manual I

. Operation description a. Identity -- Enter the identity of the site at which the operation will occur. Confidential Name 

### Not applicable as new chemical substance will be imported. Site address (number and street)
City, County, State, ZIP code 

### If the same operation will occur at more than one site, enter the number additional sites on a continuation sheet, and if any of the sites have production rates or operations, include all the information requested sites as attachments. of sites. Identify the significantly different in this section for those . Mark (X) this box if you attach a continuation sheet. b. Type 

### -- Mark (X) Manufacturing Processing Use
c. Amount and Duration -- 

### Complete 1 or 2 as appropriate

1 . Batch 

### Maximum kg/batch (100% new chemical substance) Hours/batch Batches/year

2. Continuous Maximum kg/batch (100% new chemical substance) Hours/batch Batches/year

d Process description 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 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 feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency 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.


### Not applicable as new chemical substance will be imported.

Mark (X) this box if you attach a continuation sheet. gallon and if not

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

### 11



## . 

## 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 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 (CBI). Worker activity (i.e., bag dumping, filling drums)

(I) CBI

(2) Protective Equipment/ Engineering Controls (3) Binding Option Mark (a) (4) Physical forms(s)

and % new substance (5) Binding

Option Mark (x) (6) C131

(7) # of Worker s Expose d (8) C131

(9) Maxima

m duration (131

(12) Firs/day (10) Days/yr

(I 1) 

### Not applicable as new chemical substance will be imported.



# Liii Mark (X) this box if you attach a continuation sheet. 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, section A, subsection ld(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 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 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 POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). Release Number (1) Amount of new substance

released CBI

(3) Media of release e.g. slack air (4) Control technology and efficiency (you may wish to optionally attach efficiency data) CBI

(6) (5a) Binding Mark (X) (5b) (2a) (2b) 

### Not applicable as new chemical substance will be imported.

(7) Mark (X) the POTW provide name(s) below destination(s) of releases to water. " 31 I Navigable I Other - Specify provide NPDES P CBI waterway 

# LI Mark (X) this box if you attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 9

## p. 12



## Part II-- 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. I. Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim (1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify these sites on a continuation sheet):

Mark (X) this box if you attach a continuation sheet. as confidential. gallon pails, 55 gallon the approximate weight etc) and all the points of release, the locations of

# of sites

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 kg/batch). (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. (3), (5), (8), (11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI). Letter ofActivity (1) # of Workers Exposed 

### (2) CBI



### ( 3 ) Duration

of Exposure CBI



### ( 5 ) Protective Equip. /

Engineering Controls/ Physical Form and % new substance (6) % in

Formulation (7) CBI



### ( 8 ) Release Number


### ( 9 ) Amount of

New Substance Released CBI

(11) Media of Release

& Control Technology 

### (12) CBI

(13) (4a) (4b) (10a) (10b) 

### X X X X X

X X X

(14) -- Byproduct : (15) 

# LI Mark (X) this box if you attach a continuation sheet, EPA FORM 7710-25 (Rev. 5-95) Page 10

### p. 13



# F., 1 0

## p. 14



## Part II-- 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. Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim (1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify these sites on a continuation sheet):

Mark (X) this box if you attach a continuation sheet. as confidential. gallon pails, 55 gallon approximate weight etc) and all the points of release, the locations of

# of sites

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

### Letter ofActivity (1) # 

### of Workers Ex 

### p osed (2) CBI

(3) Duration

of Exposure 

### CBI

( 5 ) Protective Equip. /

Engineering Controls/ Physical Fo rm and % new substance (6) % 

### in

Formulation (7) 

### CBI

(8) 

### Release Number

( 9 ) 

### Amount of

New Substance Released CBI

(11) Media of Release & Control Technology (12) C BI



### (13) (4a) (4b) (10a) 

### (10b) X X X X X

X X X
x
X x 

# X K )(

X >( X 

# X X ( 14 ) -- Byproducts: (15)
Mark (X) this box if you attach a continuation sheet, EPA FORM 7710-25 (Rev. 5-95) Page 10 (b)

### p. 15

## p. 16



## Part II-- 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. (1) drums, (by products, including these Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify sites on a continuation sheet):

Mark (X) this box if you attach a continuation sheet as confidential. gallon pails, 55 gallon the approximate weight etc) and all the points of release, the locations of

# of sites

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 kg/batch). (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. (3), (5), (8), (11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI). Letter ofActivity (1) # of Workers Exposed (2) CBI

(3) Duration

of Exposure CBI

(5) Protective Equip. /

Engineering Controls/



### an d Physical 

### % Form new substance (6) % in

Formulation
( 7 ) CBI

( 8 ) Release Number

( 9 ) Amount of

New Substance Released CBI

(11) Media of Release

& Control Technology (12) C BI

(11) (4a) (4b) (WM (Mb) X X X X X

X X X

(14) -- Byproducts: (15) Mark (X) this box if you attach a continuation sheet, EPA FORM 7710-25 (Rev. 5-95) Page 10 

# (a)

### p. 17

## p. 18



# OPTIONAL POLLUTION PREVENTION INFORMATION To claim information in this 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 PMN 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 non-environmental 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 Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. 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.

Mark (X) this box if you attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 11

## p. 19



# OPTIONAL POLLUTION PREVENTION INFORMATION To claim information in this 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 PMN 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 non-environmental 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 Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. 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.

.--- ......,

...■■ ••■■ •'.*1



### Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 5-95) Page 1161)

## p. 20



# OPTIONAL POLLUTION PREVENTION INFORMATION To claim information in this 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 PMN 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 non-environmental 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 Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. 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.

,

,----'

Mark (X) this box if you attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 11 (

# 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 the attachments. In the column below, enter the inclusive page numbers of each attachment. Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on how to claim any information in an attachment as confidential. You must include with the sanitized copy of the notice form a sanitized version of any attachment in which you claim information as confidential.Attachment name Attachment Confipage number(s) dential



## X 

# x

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

## p. 21

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

## p. 22 

### 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. 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 your submission of test data. This worksheet is not a substitute for submission of test data. Property (a) Mark (X) if provided Page number (b) Value

(c) Measured or Estimate (M or E) Confidential Mark (X) (co 

### Physical state of neat substance X
Vapor pressure @ Temperature °C Torr Density/relative density X Solubility @ Temperature °C g/L Solvent Solubility in water @ Temperature °C X
Melting temperature °C Boiling / sublimation temperature@ torr pressure °C Spectra X

Dissociation constant Particle size distribution Octanol / water partition coefficient Henry's Law constant Volitalization from water Volitalization from soil pH@ concentration Flammability X
Explodability Adsorption / coefficient Other - Specify Viscosity 25°C DIN 53015 X

ATTACHMENT PAGE 13

### p. 23



# c) IA