## PMN Page 1 ; Page 1 of 18 

## p. 1 Form A pproved . O .M .B. No. 2070-0012. A

pproval Ex p

ires 10-31-96 

## U .S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY Date of receipt 

# PREMANUFACTURE 

# 11Ef11~1~~IE~IE~IH~1E1IE~111~~l1h 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

_ ------ 

## GENERAL INSTRUCTIONS TS 

# J O 

# 1

# 10 110 Ill 1u u " You must provide all information requested in this formto the extent that it is known to or reasonably ascertainableby you. Make reasonable estimates ifyou do not have actual data. " Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603) . " Ifa user fee has been remitted for this notice (40CFR 700 .45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, 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 ifyou claimthe 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 foryou, but your submission will you, if these data are related to the health and environmental effects on the not be complete and the reviewwill 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 ofdata, 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 oftest 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 thesections 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 formfor 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 submiuerwhen the Agency approves the exemption application, checking a binding box in this notice does not ~ SNUN (Significant NewUse Notice) by itselfprohibit the submitter fromlater deviating fromthe information (except chemical identity) reported in the form . TMEA (T t M k ti E ti A li ti es ar e ng xemp on pp ca on) , CONFIDENTIALITY CLAIMS © LVE (Low Volume Exemption) (a? 40 CFR 723.50(c)(1) You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claimas confidential . ~ LOREX (LowRelease/LowExposure Exemption) (r4 40 CFR 723.50(c)(2) To assert a claiminan attachment, circle or bracket the information you claimas 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 page 3 EPA FORM

7710-25 (Rev. 5-95) 

# P-1(1-39 Replaces previous editions of EPA Form7710-25 .

## PMN Page 2 ;Page 2 of 18 

## p. 2

Public reporting burden for this collection ofinformation 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 ofthis 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-- APrinted 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, sectionA, subsection la of this notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B

. 2. All information provided in this notice is complete and truthful as ofthe date of submission. 3 . I amsubmitting 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 feecertification statement that applies: F1 The Company named in Part I, Section Ahas remitted the fee of $2500specified in 40 CFR 700 .45(b), or 0 The Company named in Part I, Section Ahas remitted the fee of $1000for an Intermediate PMN(defined @ 40 CFR 700 .43) in accordance with 40 CFR 700 .45(b), or 0The 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 CFR700 .45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40CFR 723.50(c)(2), check the following certification statements: 0The 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 of40 CFR 723.50 . 0The manufacturer is familiar with the terms ofthis section and will comply with those terms; and The new

chemical substance for which the notice is submitted meets all applicable exemption conditions. 0If 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 reviewperiod. The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An knowing and willful misinterpretation is subject to criminal p enal ty pursuant to 18 USC 1001 . Confidential Signature and title ofAuthorized Official (Original Signature Required) Date 

## IVv pfad 

## '-ld~C~- WE A2SSt01c" ~' cQuAU~r( 4 l'~I AFFpIA-S 

# 4/ 65 0 Signature of agent - (if applicable) - Date

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 IDENTI FICATION la. Person Name ofauthorized official Submitting Mark A. Banash Position Vice President, Quality & Regulatory Affairs 

# F Notice (in U

.S.) Company Nanocomp Technologies Inc Mailing address (number and street) 162 Pembroke Road City, State Postal Code Concord, NH 03301 b . Agent (if Name ofauthorized 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 ajoint submission, mark (X) this box. Joint Submitter (if Name ofauthorized 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. Ifyou have had a prenotice communication (PC) concerningthis notice and EPA assigned a PC Number to the notice, enter the number . Mark (X) - 

# F] E] if none 4. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this substance enter the PMN Mark (X) -- " El number assigned by EPA (i .e. withdrawn or incomplete) . - if none 5. Ifyou 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) nameofthe substance based onthe ninth

Collective Index (9Cq ofCA nomenclature rules and conventions. Mark X the "Confidential" box next to an itemy ou claimas confidential Complete either item1 (Class I or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. Ifanother person will submit chemical identity information for you (for either ItemI or 2), mark (X) the box at the tight. ConfiIdenti the name, com pany, and address of that p erson in a continuation sheet. a dential I . Class 1 or 2chemical substances (for definitions ofclass 1 and class 2 substances see the Instructions Manual) a . Class ofsubstance - 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 similarsubstances. For Class 1 substances a CA Index Name must be provided. ForClass 2substances 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 ofthe Identification ~Method 2(Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d . Molecularformula 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 . Fora 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-PMNInstruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance .

+ +

1 a . . r ,I r r 

### , ~ , F=+

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 ofthe reaction or process. (3) Indicate the range ofcomposition and the typical composition (where appropriate) . e. (1) List the immediate precutsor substances with their respective CASRegistry Numbers . 

## ConfiName (CAS #) 

## dential

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

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

### The material consists almost entirely of elemental carbon .

10 Mark (X) this box ifyou 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, orsolvents) below 500and below1,000absolute molecular weight of that c omposition.

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

(i) lowest number average molecular weight: (ii) maximum

weight %

below500molecular weight : (iii) maximum

weight %

below1000 molecular weight : Mark (X) this box ifyou attach a continuation sheet 

# 1-1 b . You must make separate confidentiality claims formonomer or other reactant identity, composition information, and residual information . Mark (X) the "Confidential" box next to any itemyou claim as confidential (1) - Provide the specific chemical name and CASRegistry Number (ifa number exists) ofeach 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 ofeach monomer or other reactant in the polymer. (4) - Choose "yes" fromdrop down menu ifyouwant 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 orother 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 CASRegistry 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-1I % 

# []I % %

% % 

# u

Mark (X) this box ifyou 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 nMethod 2 (other source) obtained fromCAS 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 (ifa number already exists for the substance) e. 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" diagramsoftware which can be helpful in reviewing your substance.

Mark (X) this box ifyou 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 ifavailable . If there are unidentified impurities, enter "unidentified." b - Estimate the maximum wei t %

ofeach im

puri ty. If there are unidentified im p urities, estimate theirtotal wei t % . Impurity and CASRegistry Number Maximum Confipercent dential a b %

% %

%

%

%

Mark (X) this box ifyou attach a continuation sheet. 4. Synonyms - Enter any chemical synonyms forthe new chemical identified in subsection 1 or 2. Confidential Mark (X) this box ifyou 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 ifyou attach a continuation sheet . 6 . Generic chemical name - Ifyou claimchemical 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 Bforguidance on developing generic names.

Mark (X) this box ifyou attach a continuation sheet. 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance

. Provide the CAS Registry Number ifavailable. 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, ANDUSE INFORMATION : Mark X the "Confidential" box next to an itemyou claimas confidential . 1 . Production volume - Estimate the maximumproduction 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, ifyou choose to have your notice reviewed at a lower production volume than 10,000 kg/ r, specif

y 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 ofthe 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 itemyou claimas confidential . a . (1) --Describe each intended category of use of the new chemical substance by function and application. (2) --Mark (X) this column ifentry column (1) is onfidential business information (CBI) . (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent oftotal roduction for the first three years devoted to each category of use. (5) --Mark (X) this column ifentry 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 ifappropriate. Mark (X) to indicate your willingness to have the use type provided in (8) indin . 9 --Mark X this column ifent 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 % ofsubstance expected per use CBI % lation (8) (2) (3) (4) (5) (6) (7) sitelimited Consuma Industrial Commadal Binding

Op tion (9) % %

% %

% %

% %

% %

% %

% % " Ifyou 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 ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. ark (X) this box ifyou attach a continuation sheet . b. Generic use Ifyou claimany category of use description in subsection 2a as confidential, enter a generic description ofthat category. Read the Instruction description Manual for examples ofgeneric use descriptions. For all applications listed here the field is composite structures for aerospace .

u Mark (X) this box ifyou attach a continuation sheet. 3 . Hazard Information -- Include in the notice a copy of reasonable facsimile ofany hazard warning statement, label, material safety data sheet, or other information which will be provided to any person whois 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 ifyou 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 ANDENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section Afor each type of manufacture, processing, or use operation involving the 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 op erations after im

p ort . You must describe these op erations. See instructions manual I . Operation description Confia. Identity -- Enter the identity ofthe site at which the op eration will occur. dential Name Nanocomp Technologies Inc . Pembroke Road Facility Site address (number and street) 162 Pembroke Road Ci ty, County, State, ZIPcode 

### Concord Merrimack NH 03301 If the same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany of the sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

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

### b . Type -- Mark (X) x Manufacturing X Processing Use c. Amount and Duration -- Com plete 1 or 2 as appropriate Maximumkg/batch ti(x)°i newchemicai substance) Hours/batch Batches/year l . Batch Maximum kg/day (ianneHchen,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 interimstorage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100%new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch

.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment ofthe 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 ifyou attach a continuation sheet. EPA FORM

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

## PMN Page 8a ; Page 11 of 18

EPAFORM

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

## PMN Page 9 ; Page 12 of 18 Part II- HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE - Continued Section A-- INDUSTRIAL SITESCONTROLLED BY THE SUBMITTER- Continued 2 . Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical formofthe new chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou 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 ifentry 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) ofthe new chemical substance (e .g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart ofa mixture) at the time ofexposure. (7) -- Mark (X) this column ifentry in column (5) is confidential business information (CB0 . (8) -- Estimate the maximum number ofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI) . (10) and ( 11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year . (12) -- Mark (X) this column ifentries in columns (10) and (11) are confidential business 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 ifyou 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 therelease number and the amount ofthe new chemical substance released and otherrelease and disposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) -Enter the number of each release point identified in the process description, part 11, section A, subsection 1d(3) . (2) -- Estimate the amount of the new substancereleased (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) -- Mark (X) this column ifentries in columns (1) and (2) are confidential business 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 fromthat release point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limitthe release of the new substance to the environment. For releases disposed ofon 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 (C131) . (7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTW (Publicl y Owned Treatment Works ) . Mark X if the POTW name or NPDES#is confidential business information CB . Release Number Amount of new

substance released CBI Mediumof release Control technology and efficiency (you may wish to optionally attach

efficienc y 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 ifyou attach a continuation sheet. EPA FORM

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

## PMN Page 10; Page 14 of 18 Part II- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE -- Continued Section B - INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfor typical processing or use operations involving the new chemical substance at sites you do not control . Importers do not have to complete this section for operations outside the U .S. ; however, you must report any processing or use activities after import See the Instructions Manual . Complete a separate section Bfor each type o( processing, or use operation involvingthenew 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 claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagram

the major unit operation steps and chemical conversions, including interimstorage 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 ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Either in thediagramor 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 #ofsites (remember to identify the locations ofthese sites on a continuation sheet) : #ofsites CBl



# a

Diagramthe 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 b

ox ifyou a

ttach 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) --Fromthe diagram above, provide the letter for each worker activity. Complete 2-8for each worker activity described . (2) -- Estimate the number ofworkers 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 ofexposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, ifany, used to protect workers . (7) -- Estimate the percent ofthe new substance as formulated when packaged or used as a final product. (9) -- Fromthe process diagram above, enter the number ofeach release point. Complete 9-13 for each release point identified. (10) --Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) --Describe mediaof 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, ifany, that will be used to limit the release of the new substance to the environment . (14) -- Identify byproducts which may result fromthe operation. ( 3 ),( 5), ( 8 ( 11 ), 13 and 15 -- Mark X this column ifan of the proceeding entries are confidential business information ( CBI ). Letter of # of Workers 

## CBI Duration Of CBI Protective Equip. /Engineering Controls/Physical Formand/ % new substance %

in CBIActivity Exposed Exposure Formulation (I) (2) (3) 4a 46 (5) 6 (7) (g) 

# Ell Ell El F-11 El I F-11 

# a o

_ El 0 0 El l Release Number Amount of New CBI 

## Media of Release &Control Technology Substance Released 9 I0a IOb II I2 I3



# Ell El El . El El .. 

# . El . El El

_- 

# Ell 14) -- Byproducts: (15) Lil 

# 113 Mark (X) this box ifyou attach a continuation sheet,



# OPTIONAL POLLUTI ON PREVENTION INFORMATION To claiminformation in the following section as confidential circle or bracket the specific information that you claimas confidential In this section you may provide information not reported elsewhere in this formregardingyour efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal ofthe PMN substance. Please include newinformation 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 ofchemical 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 fromwastes 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 reviewof this substance . See PMN Instructions Manual and Pollution Prevention Guidance manual for guidance and exam ples.

EPA FORM

7710-25 (Rev. 5-95) Page l0a

## 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 thevolume manufactured; (3) a reduction in the generation ofwaste 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 ofthe 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 ifyou 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 formand test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section ofthe form to which it relates, ifappropriate. Number consecutively the pages ofany 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 claimas confidential . Read the Instructions Manual for guidance on howto claimany information in an attachment as confidential . You must include with the sanitized copy of the notice forma sanitized version ofan attachment in which you claiminformation as confidential . # Attachment name Attachment Filename Attachment a e num ber( 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 ifyou 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 ANDCHEMICAL 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 ofthe notice on which the property appears, the value ofthe 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 ofthe neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (% PMNsubstance in _) . You are not required to submit this worksheet; however, EPAstrongly recommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected . You should submit this worksheet as a supplement to our submission oftest data. This worksheet is not a substitute for submission oftest data. Property ark (X if Page number Value Measured o Estimate c-fid""al (a) provided (b) (e) Mark (X) (d) M or E 

## Physical state of neat substance ~ X s 1 Vapor pressure ° F 

## Tem p erature C Torr Densi ty/relative density g/cm3 

# 10 Solubility @ Temperature °C Solvent Solubility in water (&, Tem p erature Oc 

# El 9/L El 0 Melting temperature oC El Boiling / sublimation tem erature torr p ressure OC Spectra Dissociation constant Particle size distribution E] 0 Octanol / water p

artition coefficient Henry 's Law

constant Volatilization fromwater a 0 Volatilization fromsoil El 0 H concentration Flammability Ex lodabilit Adsorption / coefficient Other - S p eci fy 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 XAAseries Com position Synthetic carbon nanofibers in non-woven textile formfactor 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 CHEMTRECat 800-424-9300 

# 3 . Physical and Chemical Properties FormFactor 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 Or ganic Content % wt 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 Com ponent CAS No. Exp osure 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 Stabili ty Stable Incom patibilities Strong oxidizers, reducing ag ents Decom p osition 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

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

attention Inhalati on 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 Extinguishing Materials Water spray, 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 . Vacuumarea with equipment fitted with HEPA filter. Ventilate area and wash sp

ill 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 N95or 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 roomtemperature in a sealed container. 12. Toxicological Information E y es 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. Ingestion 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 fromsuch use or application. This material is for research and development (R&D) evaluation only. It may only be used for R&Devaluation until pre-manufacture notice (PMN) reviewby 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