PMN Page 1 ; Page 1 of 18 

p. 1 

Form Approved. O.M .B . No. 2070-0012. Approval Ex pires 10-31-96 

U.S . ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt 

PREMANUFACTURE 

11 Ef 11~ 1~~ IE~ IE~ IH~ 1E1 IE~ 111 ~~l 1h 11111 i . ._ . - . ~ . ~ .,- 

5 1 1 0 0 0 0 0 0 3 9 1 

Company Sanitized 

WASHINGTON, D.C . 20460 

nter the total number of pages ,) $ PA ql~ pp~yev~ 9 

in the Premanufacture Notice f + 

_ ------ 

" You must provide all information requested 

GENERAL 

in this form 

INSTRUCTIONS 

to the extent that it is kn own to or reasonably ascertainable 

TS 

by you

J

. 

O 

Make 

1 10 

reasonable 

110 

estimates 

Ill 1u 

if you do 

u 

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, Alto . TSCA User fee. 

Part I -GENERAL INFORMATION TEST DATA AND OTHER DATA 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 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 you, if these data are related to the health and environmental effects on the not be complete and the review will not begin until EPA receives this information. A letter manufacture, processing, distribution in commerce, use, or disposal of the new in support of your submission should reference your TS user fee identification number . chemical substance. Standard literature citations may be submitted for data in the 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 . 

open scientific literature . Complete test data (written in English), not summaries 

of data, must be submitted if they do not aooear in the ooett literature. You should 

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

Part 11- 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 III-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 El Yes 

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 . " Health effects data a Yes Risk assessments 

" Environmental effects data ~ Yes Structure/activity relationships 

OPTIONAL INFORMATION " Physical/Chemical Properties* ~ Yes Test data not in the possession 

or control of the submitter a 

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 to be bound to certain statements you make in this section, such as use, ~ 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 ofexemption applications (such as TMEA, LVE, LOREX) where ~ INTERMEDIATE PMN (submitted in sequence with final product PMN) 

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

Agency 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 

identity) reported in the form. 

TMEA (T es t M ar k e ti ng E xemp ti on A pp li ca ti on) , 

CONFIDENTIALITY CLAIMS © LVE (Low Volume Exemption) (a? 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. ~ LOREX (Low Release/Low Exposure Exemption) (r4 40 CFR 723 .50(c)(2) 

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

confidential . 1_fyou claim information in the notices as confidential. you must also provide 

a sanitized version of the notice. (includine attachments) . For additional instructions on 

~ LVE Modification ~ LOREX Modification 

claiming information as confidential, read the Instructions Manual . 

IS THIS A CONSOLIDATED PMN? ~ Yes 

© Mark (x) if any information in this notice is claimed as confidential . # of chemicals or polymers 

Prenotice Communication # requ ired, enter # on pag e 3 

EPA FORM 7710-25 (Rev . 5-95) P-1(1-39 Replaces previous editions of EPA Form 7710-25. 
PMN Page 2 ;Page 2 of 18 

p. 2 

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

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

information . Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for 

reducing this burden, to Director, Collection Strategies Division (2822), U.S . Environmental Protection Agency, 1200 Pennsylvania Ave., N.W., 

Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C . 20503. 

CERTIFICATION -- A Printed copy of this signature page, with original signature, must be submitted 

I certify that to the best of my knowledge and belief: 

1 . The company named in Part 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. I 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 PIVIN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies: 

F1 The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

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

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

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b) . 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723 .50(c)(2), check the following certification 

statements : 

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

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50. 

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

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

0 If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period . 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance 

described herein. An knowing and willful misinterp retation is subject to criminal penal ty p ursuant to 18 USC 1001 . Confidential 

Signature and title of Authorized Official (Original Signature Required) Date 

IVv '-ld~C~- WE A2SSt01c"~' cQuAU~r ( pfad 4 

Signature of agent - (if applicable) - 

l'~I AFFpIA-S 

Date 

4/65 0 

EPA FORM 7710-25 (Rev . 5-95) Page 2 
p. 3 

PMN Page 3 ; Page 3 of 18 

Part I -- GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION 

la . Person Name of authorized official 

Submitting Mark A . Banash 

Position 

Vice President, Quality & Regulatory Affairs 

Notice (in U.S.) F 

Company 

Nanocomp Technologies Inc 

Mailing address (number and street) 

162 Pembroke Road 

City, State Postal Code 

Concord, NH 03301 

b. Agent (if Name of authorized official 

applicable) 

Position 

Company 

Mailing address (number and street) 

City, State Postal Code Telephone (include area code) 

c. If you are submitting this notice as part of a joint submission, mark (X) this box. 

Joint Submitter (if Name of authorized official Position 

- 

applicable) F 1 

Company 

Mailing address (ntunber and street) City, State 

Province, Country Postal Code Telephone (include country or area code) 

2. Technical Name of authorized official Position 

Contact (in Mark A . Banash Vice President, Quality & Regulatory A ffairs 

U.S .) 

Company 

Nanocomp Technologies Inc 

Mailing address (number and street) 

162 Pembroke Road 

City, State Postal Code Telephone (include area code) 

Concord, NH 03301 603-442-8992 

3 . If you have had a prenotice communication (PC) concerning this notice and 

EPA assigned a PC Number to the notice, enter the number . Mark 

if none 

(X) - F] E] 

4 . 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 PMN 

Mark (X) --" 

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

if none El 

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) -0 ~ I 

if none 

6. Type of Notice - Mark (X) 

Mark the "Confidential" box next to an subsection you claim as confidential 

1 . Manufacture 

Only 

Binding Option 

Mark (X) 

I 2. 

I 

I 

I 

I 

Import 

Only 

Binding Option 

Mark (X) 

1 

1 3 . 

I 

I 

I 

Both 

Confidential 

EPA FORM 7710-25 (Rev . 5-95) Page 3 
p. 4 

PMN Page 4 ; Page 4 of 18 

Part I -- GENERAL INFORMATION -- Continued 

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

Collective Index (9Cq ofCA nomenclature rules and conventions. 

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

Complete either item 1 (Class I or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the tight. ConfiIdenti the name, company , and address of that person in a continuation sheet. a dential 

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

a. Class of substance - Mark (X) Class I or X Class 2 

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 9C1 nomenclature rules and conventions) . 

Carbon 

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 ~ 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 - 

C. sub. x (ifa number already 

~ 

exists for the substance) 

e. For a class 1 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, ifone 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. 

+ + 

1 

a . . 

r ,I 

r , , ~ F=+ r 

4h 

{ 

7 ` 

r 

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

EPA FORM 7710-25 (Rev . 5-95) Page 4 
PMN Page 4a ; Page 5 of 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 precutsor substances with their respective CAS Registry Numbers. ConfiName (CAS #) dential 

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

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

The material consists almost entirely of elemental carbon . 

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

EPA FORM 7710-25 (Rev . 5-95) Page 4a 
PMN Page 5 ; Page 6 of 18 

Part I -- GENERAL INFORMATION -- Continued 

Section B - CHEMICAL IDENTITY INFORMATION - Continued 

2. Polymers (For a definition of polymer, seethe Instructions Manual .) I 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 composition. 

-----

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

(i) lowest number average molecular weight: 

(ii) maximum weight % below 500 molecular weight : 

(iii) maximum weight % below 1000 molecular weight : 

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

1-1 

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 ifentry 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 ifentries in columns (3) and (4) are confidential. 

(6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured fbr 

commercial purposes . 

(7) - Mark (X) this column ifen in column 6 is confidential. 

Monomer or other reactant and CAS Registry Number Confi- Typical Include in Confi- Maximum Confidential composition identity dential residual dential 

1 2 3 4 5 6 -.- . (7) 

11 

11 

11 

0 

% 

% 

% 

0 

0 

0 1-1 

% 

% 

% 

0 

% 

0 

F-1 F-1 I 

% 

[] I 

% % 

% % 

u 

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

% 

% 

% 

% 

% 

% 

% 

1-1 

% 

% 

0 

% 

% 

% 

% 

0 

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

PMN Page 5a ; Page 7 of 18 

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 

n 

Method 2 (other source) 

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

CBI 

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

CAS Registry Number (if a 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 7710-25 (Rev . 5-95) Page 5a 
p. 8 

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 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 t % of each impuri ty. If there are unidentified impurities, estimate their total wei t %. 

Impurity and CAS Registry Number Maximum Confipercent dential 

a b 

% 

% 

% 

% 

% 

% 

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

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. Confidential 

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

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

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

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

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

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

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

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

Number if available. 

Byproduct CAS Registry Number ConfiI 2 dential 

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

EPA FORM 7710-25 (Rev . 5-95) Page 6 
P. 9 

PMN Page 7 ; Page 9 of 18 

Part I -- GENERAL INFORMATION -- Continued 

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

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

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

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

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

10,000 kg/ r, s p ecify the volume and mark (x) in the bindin box. If ranted, you are bound to this volume 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confi- Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dential M 

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 (CBI). (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total roduction for the first three years devoted to each category of use. (5) --Mark (X) this column if entry in column (4) is confidential business information (CBI). (6) -- stimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under 

our control associated with each category of use. (7) --Mark (X) this column if entry in column (6) is confidential business information (CBI). (8) --Indicate % of roduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) indin . 9 --Mark X this column if ent ies in column 8 is are confidential business information (CBI). 

Category of use (1) (by function and application i .e . a 

dispersive dye for finishing polyester fibers) 

CBI Binding 

oMt~~" 

Production 

CBI °i in 

Fotmu 

CBI % of substance expected per use CBI 

% lation 

(8) 

(2) (3) (4) (5) (6) (7) sitelimited Consuma Industrial Commadal 

Binding 

Option 

(9) 

% % 

% % 

% % 

% 

% 

% % 

% % 

% % 

" 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. 

ark (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. 

For all applications listed here the field is composite structures for aerospace . 

u 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 

Binding 

Option 

the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (s) 

Mark (X) this box if you attach hazard information. tj 

EPA FORM 7710-25 (Rev . 5-95) Page 7 
p. 10 

PMN Page 8 ; Page 10 of 18 

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 Confia . Identity -- Enter the identity of the site at which the operation will occur. dential 

Name 

Nanocomp Technologies Inc . Pembroke Road Facility 

Site address (number and street) 

162 Pembroke Road 

Ci ty , Coun ty , State, ZIP code 

Concord Merrimack NH 03301 

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 . 

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

b. Type -- 

Mark (X) x Manufacturing X Processing Use 

c. Amount and Duration -- Complete 1 or 2 as appropriate 

Maximum kg/batch ti(x)°i new chemicai 

substance) 

Hours/batch Batches/year 

l . Batch 

Maximum kg/day (ianneH chen,icat Hours/day Days/year 

substance) 

2. Continuous 

d. Process description U Mark (X) to indicate your willingness to have your process description binding. 

(1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon 

drum, rail car, tank truck, etc.). 

(2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc. ), and of all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch.) . 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. If releasing to two media 

at the same step, assign a second release number for the second medium . 

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

EPA FORM 7710-25 (Rev . 5-95) Page 8 
PMN Page 8a ; Page 11 of 18 

EPA FORM 7710-25 (Rev . 5-95) Page Sa 
PMN Page 9 ; Page 12 of 18 

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 (CB0 . 

(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 (CB I) . 

Worker activity CBI Protective Equipment/ Binding Physical 

forms(s) 

Binding CBI # of CBI Maximum duration CBI i (i .e ., bag dumping, filling drums) Engineering Controls Option 

Mark (x) 

and % new 

substance 

Option 

Mark (x) Workers 

Exposed 

Hrs/day Days/yr 

1 (2> 3 (4) (5) (6) (7) g (9) (ID) (11) (IZ) 

Harvesting of 

material from 

Impermeable gloves, 

dust mask, lab 

Finish 

ed 

furnace system coat/coveralls, safety 

glasses 

- E 

sheet 

l I I 

Cleaning of furnace 

system 

Impermeable gloves, 

respirator, impermeable 

Scrap 

sheet 

coveralls with hood, 

safety glasses 

materi 

al 

L 

Disposal of scrap 

material from waste 

Impermeable gloves, 

dust mask, lab 

Scrap 

sheet 

drums coat/coveralls, safety 

glasses 

materi 

asl 

Preparation of 

material for 

shipment 

Impermeable gloves, 

dust mask, lab 

coat/coveralls, safety 

Finish 

ed 

good 

glasses 

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

EPA FORM 7710-25 (Rev . 5-95) Page 9 
PMN Page 9a ; Page 13 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 11, section A, subsection 1 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 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 (C13 1) . 

(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 CB . 

Release 

Number 

Amount of new 

substance released 

CBI Medium of 

release 

Control technology and efficiency (you may wish to optionally attach 

efficiency data 

(1) (2a) (2b) 

(3) 

eg ~~kair 

(4) 

_ 

(5a) 

Binding 

MXrt (5b) (6) 

El 

(7) Mark (X) the destination(s ) of releases to water. NPDES # CBI 

POTW--provide 

name(s) 

Navigable waterway-- 

provide name(s) 

Other--Specify 

Mark (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 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 o( 

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 . Identi fy additional sites on a continuation sheet. 

I (a). Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. 

(1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 gallon pails, 55 gallon drums, rail 

cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity . (2) -- Either in the diagram or in the text field 1(b) below, provide the 

identity, the approximate weight (by kg/day or kg/batch, on an 100% 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) : 

# of sites CBl 

a 

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

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

Ell 

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

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

p. 15 

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 an of the proceeding entries are confidential business information ( CBI). 

Letter 

of 

# of 

Workers 

CBI Duration Of CBI Protective Equip. /Engineering Controls/Physical Form and/ % new substance % 

in 

CBI 

Activity 

Exposed 

Exposure Formulation 

(I) (2) (3) 4a 46 (5) 6 (7) (g) 

Ell El l 

El F-1 1 

El I F-11 

a o 

_ 

El 0 0 Ell Release 

Number 

Amount of 

New 

CBI Media of Release & Control Technology 

Substance 

Released 

9 I0a IOb II I2 I3 

El l El 

El . 

El 

El 

. . . 

El. El 

El _- 14) -- Byproducts : Ell 

(15) 

Lil 113 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 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 PMN Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. 

EPA FORM 7710-25 (Rev . 5-95) Page l 0a 
p. 16 

PMN Page 11 ;Page 16 of 18 

Optional Pollution Prevention Information (Continued) Describe the expected net benefits, such as (1) an overall reduction in risk to 

human health or the environment; (2) a reduction in the volume manufactured ; (3) a reduction in the generation of waste materials 

through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental 

release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new 

chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new 

chemical substance may be a substitute for an existing substance that poses a greater overall risk to human health or the environment. 

CBI 

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

O 

EPA FORM 7710-25 (Rev . 5-95) Page 1 I 
p. 17 

PMN Page 12 ; Page 17 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 an attachment in which you claim information as confidential . 

# Attachment name Attachment Filename Attachment 

a e number( s) 

Confidential 

1 Material safety data sheet DSA-0002-06 

EL 

- 

a 

0 0 

a 

0 

0 

o 

0 

0 

0 - 

a EL 

0 

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

EPA FORM 7710-25 (Rev. 5-95) Page 12 
p. 18 

PMN Page 13 ; Page 18 of 18 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

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

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

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . If the attachments 

are electronic, give the attachment number (found on page 12) at (b). The physical state of the neat substance should be provided . 

These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

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

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

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

Property ark (X 

if 

Page 

number 

Value Measured o 

Estimate 

c-fid""al 

(a) provide d 

(b) (e) 

Mark (X) 

(d) M or E 

Physical state of neat substance ~ X s 1 

Vapor pressure 

Temperature ° C F Torr 

Density/relative density g/cm3 10 

Solubility 

@ Temperature °C 

Solvent 

Solubility in water (&, Temperature Oc El 9/L 

Melting temperature El oC 0 

Boilin g / sublimation tem erature torr pressure El OC 

Spectra 

Dissociation constant 

Particle size distribution E] 0 

Octanol / water partition coefficient 

Henry 's Law constant 

Volatilization from water a 0 

Volatilization from soil El 0 

H concentration 

Flammability 

Ex lodabilit 

Adsorption / coefficient 

Other - Specify 

Other - Specify 

1

0 

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

PAGE 13 
nanocomp 'TECHNOLOGIES, INC . 

MATERIAL SAFETY DATA SHEET 

1 . Product Information 

Product Descri ption Carbon Nanotube Sheet 

Product Number For XAA series 

Composition Synthetic carbon nanofibers in non-woven textile form factor 

2. Contact Information 

I 

Manufacturer Nanocom Technolog ies Inc. Address 162 Pembroke Road 

Concord, NH 03301 

USA 

Telephone 603-442-8992 

E-mail safet nanocom tech .com 

~ Emergency Telephone Call CHEMTREC at 800-424-9300 

3. Physical and Chemical Properties 

Form Factor Flat flexible sheet 

Color Black 

Odor None 

Freezin /Meltin /Boilin Points °C Not available 

Densit /cm > 1 

Vapor Pressure mm H Not available 

Va por Density BuAc = 1 Not available 

Volatile Organic Content % w t Not available 

Solubility Insoluble in water 

Flash Point °C Not available 

Explosive Limits Not available 

~Autoignition Temperature Not available 

NCTI Document number DSA-0002-06 Page 1 of 4 
4. Composition 

Component CAS No. Exposure Limits A rox. W % 

Carbon 

Nanotube 

N/A N/A > 90% 

Amorphous 

Carbon 

7440-44-0 OSHA PELs: 5 mg/m3 (TWA) 

ACGIH TI-Vs: 2 m /m3 TWA 

< 5% 

Iron Carbide 1 2011-67-5 N/A < 7% 

5. Stability and Reactivity 

Stability Stable 

Incompatibilities Strong oxidizers, reducing agents 

Decomposition Products Carbon monoxide, carbon dioxide 

Conditions to Avoid None 

[ Hazardous Polymerization Will not occur 

6. Hazards Information 

HMIS Rating Health 1, Flammability 0, Reactivity 0 

~NFPA Rating Health 1, Flammability 0, Reactivity 0 

7. Exposure Controls 

I 

En ineerin Controls Mechanical exhaust with HEPA filters recommended .~ 

Protective Equipment Wear safety gloves and eye protection when handling 

material. Half-face respirator with N95 or better filter 

recommended (see 10-Accidental Release Measures 

below) . 

8. First Aid Measures 

Eye Flush eyes thoroughly with water for at least 15 minutes . If irritation 

develops seek medical attention 

Skin Wash thoroughly with soap and water. If irritation develops seek medical 

attention 

Inhalation Not expected to si gnificant route of exposure. ~ Ingestion Not expected to require first aid 

NCTI Document number DSA-0002-06 Page 2 of 4 
9. Fire Fighting Measures 

Extinguishin g Materials Water spra y, foam, d chemical, or carbon dioxide 

Protective Equipment Wear self-contained breathing apparatus and protective 

clothing for skin and eyes. 

10. Accidental Release Measures 

Method Sweep up and place waste in plastic bags for disposal as outlined 

below. Vacuum area with equipment fitted with HEPA filter . Ventilate 

area and wash spill site with soap and water. 

Precautions Wear eye protection, protective clothing, and impermeable gloves . 

Although current testing indicates material does not generate 

respirable particles, a N95 or better respirator is recommended (see 

12. Toxicological Information below). Treat used protective 

equipment as waste and dispose of it as outlined below. 

11 . Handling and Storage 

Handling Exercise a ppropriate caution to minimize direct contact with skin . 

Storage 

conditions 

Material may be stored at room temperature in a sealed container. 

12. Toxicological Information 

Eyes Ma cause mild irritation . 

Skin Ma cause mild irritation . 

Inhalation Under common processing conditions and practices 

current testing indicates this material does not release 

res irable articles. 

In gestion Do not ingest. 

Additional Information 

~ 

To the best of our knowledge the complete toxicological 

properties of this material have not been investigated . 

13. Ecological Information 

NCTI Document number DSA-0002-06 Page 3 of 4 
14. Disposal Instructions 

Disposal Instructions Contact a licensed professional waste service to dispose of 

this material. Mix or dissolve with a combustible solvent and 

' burn in a chemical incinerator equipped with afterburner and 

scrubber. Observe all federal, state, and local laws. 

15. Transportation Instructions 

Transportation Regulations This material is not regulated . 

16. Disclaimer 

Nanocomp Technologies, Inc . (NCTI) believes the above information to be accurate but not 

does purport it to be all inclusive . This document is intended only as a guide to the safe handling 

of the described material by a properly trained person. NCTI makes no representations or 

warranties, either express or implied, regarding the suitability of this document or its contents for 

any other purpose. 

In employing this document individuals must exercise their independent judgment to determine 

its appropriateness for a particular use or application . Accordingly, NCTI will not be responsible 

for damages resulting from such use or application . 

This material is for research and development (R&D) evaluation only. It may only be used for 

R&D evaluation until pre-manufacture notice (PMN) review by the Environmental Protection 

Agency (EPA) is completed . If this material is used in plants or non-R&D locations for R&D 

evaluation, its use must be supervised by a technically qualified individual . Review all sections 

of this MSDS prior to use 

Date of issue: 12 October 2009 

NCTI Document number DSA-0002-06 Page 4 of 4