~

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Form Approved . O.M .B. No . 2070-0012 . Approval Expires 10-31-96 . U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY.IJ.S.KONLY

Date of receipt . .

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4 , ~.

.

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PREMANUFACTURE

; . ; ,

. . E P A . ,

NOTICE

FOR NEW CHEMICAL SUBSTANCES COC~p~'~

DOCUMENT CONTROL OFFICE R

OFFICE OF POLLUTION PREVENTION

s~~~~~~ AND TOXIC SUBSTANCES, 7407 §~ P Sanitized

U.S. E.P.A. 401 M STREET, SW

WASHINGTON, D.C. 20460

nter the total number of pages ocument control number PA case number

in the Prem anufacture Notice

r.~T 0 O

GENERAL INSTRUCTIONS TS

• You must provide all information requested in this form to the extentthat it is known to or reasonably asce rtainable by you . Make reasonable estimates if you do not have actual data .

• Before you complete th is form, you should read th e "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 noti ce (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 remitt an ce, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P.O.

360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee

. O n

Part I- GENERAL INFORMATION TEST DATA AND OTHER DATA S ~~

You must provide the currently correct Chemical Abs tracts (CA) Name of the new You are required to submit all test data in your possession or control an d to provide chemical substance, even if you claim the identity as confidenti al . You may authori

an ze a description of all other data known to or reasonably ascertainable by you, if these other person to submit chemical iden tity information for you, but yoursubmission will data

not be complete and

are related to th e heal th and environmental effects on th e man ufacture , the review will not begin until EPA receives th is information.

le A processing, distribution in commerce, use, or disposal ofthe new chemical tter in support of your submission should reference your TS user fee identifi cati

number . You must submit an o ri ginal an d two copies of this notice including all test data on substance. Standard literature citations may be submi tted for data in the open .

If you claimed any information as confiden ti al, a single saniti zed copy must also be scientific literature . Complete test data (written in English), not summaries of data,

submi tt ed . must be submitted if they do not appe ar in the open literature. You should clearly

identify wheth er test data is on the substance or on an analog . Also, th e chemical

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE composition ofthe tested materi al should be characteri zed . Following are

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

If there are several man ufacture, processing, or use operations to be described in Part II, requirements of §720.50 of the Prem an ufacture Notification Rule (40 CFR Part sections A and B of this notice, reproduce the sections as needed . 720).

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

Attach addi tional sheets if there is not enough space to answer a question fully. Label • Environmental fate data ❑ Yes • Other data ❑ Yes each con tinuati on sheet wi th the corresponding section heading . In Part III, list th es e

attachments, an y test data or other data an d an y optional informati on included in the • Health effects data ❑ Yes Risk assessments notice.

• Environmental effects data ❑ Yes Structure/activity relati onships

• Physical/Chemical Properties* Yes Test data not in the possession OPTIONAL INFORMATION or control of the submitter

You may include any information that you wan t EPA to consider in evaluating the new • A physical an d chemical properties worksheet is located on the last page of this form .

substance. On page 11 of this form, space has been provided for you to described ill

pollu ti on prevention an d recycling information you may have regarding the new TYPE OF NOTICE (Check Only One) r,= substance .

So-called "binding" boxes are included th roughout this form for you to indicate your PMN (Prem anufacture Notice)

willingness to be bound to certain s tatements you make in this secti on, such as use,

production volume, protective equipment . . . This option is intended to reduce delays INTERMEDIATE PMN (submitted in sequence with fingTorroductP)"l that routinely accompan y the development of consent orders or Signific ant New Use

Rules. Except in the case of exemption applicati ons (such asTMEA, LVE, LOREX) O 1

where certain information provided in such notification is binding on the submitter when SNUN (Signific ant New Use Notice )

the Agency approves the exemp ti on application, checking a binding box in this no ti ce

does not by itself prohibit the submi tter from later deviati ng from the informati on (except ~ TMEA(Test Marketing Exemption Application) ~~ •' '- ;

chemical identity ) reported in th e form .

CONFIDENTIALITY CLAIMS LVE(Low Volume Exemption) @ 40 CFR 723.50(&Dj

You may claim an y information in this notice as confidential . To assert a claim on the LOREX Low Release/Low Ex form, mark ( X) the confiden ti al box next to the information that you claim as ~ ( ExposureExemption) @ 40 CFR 723.50(c)(2)

confidential . To assert a claim in an attachment, circle or bracket the informati on you ❑

claim as confidential . If you claim informati on in the notices as confidential, you must ❑ LVE Modification LOREX Modification also provide a s aniti zed version of the notice. (including attachments). For additi onal

instructi ons on claiming information as confidential, read the Instructions Manual . IS THIS A CONSOLIDATED PMN? F-1 Yes

® Mark (x) if any information in this noti ce is claimed as confi den tial . # of chemicals 1

(Prenoti ce Communication # required, enter 4 on page 3)

~.

EPA FORM 7710-25 (Rev . 5-95) Replaces previous editions of EPA Form 7710-25 .
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 Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M . St., S.W., Washington, D .C.

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

CERTIFICATION

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

SANITIZED

1 . The company named in Part I, section A, subsection 1a 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 PMN, Consolidated PMN, or SNUN, check the following user fee certification

statement that applies:

® The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700 .45(b), or

r-J 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

r-J 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:

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

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

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

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

E] 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 substanc e

described herein. Any knowing and willful misinterpre tation is subject to c riminal penalty pursuant to 1S USC 1001. Confidential Signature and title of Authorized Official (Original SignatureRequired) Date

X

Signature of agent - (if applicable) Date

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

Part I -- GENERAL INFORMATION

Section A -SUBMITTER IDENTIFICATION ConfiMark Q the "Confidential" box next to any subsection you claim as confidenti al dential la . Person Name of authorized official Position

Submitting

Notice (in U .S) X

Company

Mailing address (number and street)

City, State, ZIP Code

b. Agent (if Name of authorized official Position

applicable)

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

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

Joint Submitter (if Name of authorized official Position

applicable)

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

2 . Technical Name of authorized official Position

Contact (i n

U .S) X

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

3 . If you have had a prenotice communication (PC) concerning this notic e

and EPA assigned a PC Number to the notice, enter the number. Mark (X) --~ ®

if none

4 . If you previously submitted an exemption application for the chemica l

substance covered by this notice, enter the exemption number assigned by M

ink (X) EPA . If you previously submitted a PMN for this substance enter the if none

PMN number assigned by EPA (i .e. withdrawn or incomple te ):- ~

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 Mark (X) ----

assigned by EPA. ♦

01 if non e

6 . Type of Notice - Mark (X) 1 . Manufacture 2

Only Only 3

. Import

. ~ Both

Binding Option Binding Option

Mark (X) Mark (X)

~

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

Part I - GENERAL INFORMATION -Continued

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

the ninth Collec ti ve Index (9CI) of CA nomenclature rules and conven tions. Mark (X) the "Confidenti al" box next to any item you claim as con fidential

Complete either item 1 (Class 1 or 2 subst ances) or 2 (Polymers) as app ropriate . Complete all o ther items.

If an o ther person will submit chemical identity information for you (for either Item 1 or 2), mark ( X) the box at the ri ght. Confi- Identify the name, company, an d addre ss ofthat person in a conti nuation sheet . 10 E] denti a l

1 . Class 1 or 2 chemical subst ances (for definitions of class 1 and class 2 substan ces, see the Instructions Manual)

a

b

. Class of subst

. Chemical name

ance

(Currently

- Mark (X) 1

correct Chemical Abs

[:]

tracts (CA) Name

Class 1 or 2 [

that is consistent

:] Class 2 X

with TSCA Inventory listings for similar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances ei th er aCA Index Name or CA Preferred Name must X be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions).

SN~1111~~

c . Please identify which method you used to develop or obtain the specified chemical identi ty information reported in th is notice : (check one).

® Method 1 (CAS Inventory Expert Se rvice - a copy of the Identi fication Method 2 (Other Source)

report obtained from the CAS Invento ry Expert Se rv ices must be

submi tted as an attachment to this notice)

d . Molecular formula an d CAS Registry Number (if a number already exists for the subst ance)

X

CAS#

None

C . For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance - (1) List the immediate

precursor substances wi

r ange of composition an

th th

d the

eir respec

typical composition (where app

ti ve CAS Registry Num

ro

be

p

rs

ri

.

ate)

(2) Desc

. (4) P

ribe th

rovide a correct representative or partial chemical structur

e nature ofth e reaction or process . ( 3) Indicate the X

e

diagram, as complete as c an be known, if one can be reasonably ascertained.

® Mark (X) th is box if you attach a continuation sheet.

EPA FORM 7710-25 (Rev. 5-95) Pa

g

e 4
p. 5

Part I-- GENERAL INFORMATION -Continued

Section B - CHEMICAL IDENTITY INFORMATION - Con tinued

2 . Polymers (For a definition of polymer, see the Instructions Manual .) Confiden ti al

a. Indicate the number-average weight ofth e lowest molecul ar weight composi tion ofthe polymer you intend to manufacture.

Indicate maximum weight percent of low molecul ar weight species (not including residual monomers, reactants, or solvents) be low 500 and

below 1,000 absolute molecular weight ofth at composition.

Describe the methods ofmeasurement or the basis for your estimates : GPC E] O ther []: (Specify)

i) lowest numbe r average molecul ar weight:

ii) maximum weight % below 500 molecular weight:

iii) maximum weight %below 1000 molecular weight:

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

b. You must make separate confi denti ality claims for monomer or other re actant identity, composi tion 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 o ther reactant used in the manufacture of the polymer.

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

(3) - Indicate the typical weight percent of each monomer or o ther re actant in the polymer.

(4) - Mark (X) th e identity column if you want a monomer or o ther reactant used at two weight percent or less to be listed as part of the polymer description on th e TSCA Chemical Substance Inventory .

(5) - Mark (X) th is column if entries in columns (3) and ( 4) are confidential .

(6) - Indicate th e maximum weight percent of each monomer or o th er reactant th at may be p resent as a re sidual in the polymer as manufactured for

commercial purposes.

(7) - Mark (X) this column if entry in column ( 6) is confiden ti al .

Monomer or o th er reactant and CAS Registry Numbe r Confi- Typical Identity Confi- Maximum Confidential composition Mark ( dential residual dential

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

% %

% %

% %

% %

M

% %

ark (X) th is box if you attach a continuation sheet .

c . Please identify which me thod you used to develop or obtain th e specified chemical identity information reported in this notice (check one).

F~ Method 1(CAS Inventory Expert Service - a copy ofthe identifi cation repo rt Method 2 (o ther source)

obtained from CAS Inventory Expe rt Se rv ice must be submitted as

as attachment to this notice)

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

e . Provide a correct representative or pa rt i al chemical structu re diagram, as complete as can be known, if one can be reasonably ascertained .

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

dJ
p. 6

Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITY INFORMATION - Continued

3 . Impurities

(a) - Identify each impurity th at may be reasonably anticipated to be present in th e chemical subst ance as m anufactured for commercial purpose . Provide the

CAS Registry Number if available. Ifth ere are unidentified impurities, enter "unidentified . "

(b) - Estimate th e maximum weight % of each impu rity . Ifthere are unidentified impurities, estimate their total weight %.

Impurity and CAS RegistryNumber Maximum Confi-

(a) (b

percent dential

)

1

°% X

~

S~~y %

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

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

X

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 .

X

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

6 . Generic chemical name - If you claim chemical identify as con fidential, you must provide a generic name for your substance th at reveals

the specific chemical iden tity ofthe new chemical substance to th e maximum extent possible . Refer to the

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

Distillation residues from reaction product of alkyl alcohol with hydrogen sulfide

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

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

Byproduct CAS Registry Number Confi-

(1) (2) dential

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

EPA FORM 7710-25 (Rev . 5-95) Page 6
p. 7

Part I -- GENERAL INFORMATION - Continued

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

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

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

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

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

10,000 kg/yr, specify the volume and mark (x) in the binding box. If gr anted, 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 Option

Mark (x)

SANITIZ D COPY "

X

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

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

a. (1) -- Describe each intended category of use of the new chemical substance by function and application . .

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI) .

(3) -- Indicate your willingness to have the information provided in column (1) binding .

(4) -- Estimate the percent of total production for the first three years devoted to each category of use .

(5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI) .

(6) -- Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for

commercial purposes at sites under your control associated with each category of use .

(7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI) .

(8) -- Indicate % of product volume expected for the listed "use" sectors . Mark more than one box if appropriate . Mark (X) to indicate

your willingness to have the use type provided in (8) binding.

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

Category of use (1) CBI Binding Produc- CBI % in CBI % of substance expected per use CBI Option tion % Form- (8 )

(by function and application i .e. a dispersive dye M-k (x) ulation Site- Con-* Indus- Com- Binding

for finishing polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9)

Chemical Intermediate X 100 °io 100% X

% %

% %

% %

% %

% %

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

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

b . Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category . Read the

use Instructions Manual for examples of generic use descriptions.

description

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

3. Hazard Informati on - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, mate rial safety data sheet, or other Binding

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option

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

Mark (X) th is box if you attach hazard information. X

- -- ~

EPA FORM 7710-25 (Rev . 5-95) Page 7
p. 8

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 impo rt. You must describe these operations. See instructions manual

1 . Operation description Confia . Identity -- Enter

Name ~

the identity of the site at which the operation will occur . dential

~~R~

Site address (number and street)

City, County, State, ZIP code

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.

1 :1 Mark (X) this box if you attach a continuation sheet .

b . Type --

Mark (X) Manufacturing E]Processing [:]Use

c. Amount and Duration -- Complete 1 or 2 as appropriat e

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

substance) A

y

1 . Batch

Maximum kg/batch (1oo^i new chemical Hours/batch Batches/year

substance)

2 . Continuous

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

(1) Diagram the major unit operation steps and chemical conversions . Include interim storage and transport containers (specify- e

. X

.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 re actants, 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 .

Please see continuation sheet and Figure 1 .

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

EPA FORM 7710-25 (Rev . 5-95) Page 8
P. 9

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continue d

2 . Occupa ti onal Exposure - You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance,

number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you claim as confidential .

(1) --Describe the activities (i .e . bag dumping, tote filling, unloading drums, sampling, cleaning, etc .) in which workers may be exposed to the substance .

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

(3) -- Describe any protective equipment and engineering controls used to protect workers .

(4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding.

(5) -- Indicate the physical form(s) of the new chemical substance (e .g ., solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture)

at the time of exposure .

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

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

. (~~~Y

. l }

(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) th is column if entries in columns (10) an d (11) are confidential business information (CBI) .

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI

Eft

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

Mark (X) substance Mark (X) s

(1) (2) (3) (4) (5) (6) (7) Expose (9) (10) (11) (12)

d

(8)

Quality Control & Sampling See Cont. Sheet X LiqNapor X 2 X

Container Cleaning See Cont. Sheet X LiqNapor X 4 X

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

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

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

(1) -- Enter the number of each release point identified in the process description, part II, section A, subsection 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 (CBI) .

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

NPDES numbers of the POTW (Publicly Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CBI) .

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBt

Number released release

(1) (2a) (2b) c.g . .& i, Binding

(3) (4) (5a) Mark (x) (5b) (6)

S1-S5 0 Negligibl air 50 CC bottles, or closed sampling system X Negligibl e

e equipped with 2 CC vials .

V1-V2 Negligible Not Air Flair (99.9999% efficiency) X Essentially 0

Known

(7) Mark (X) th e ~ POTW provide name(s) below : CBI El Navigable El Other - Specify provide NPDES # CBI

destination(s) of waterway

releases to water

. See cont. she TX0009148

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

~

EPA FORM 7710-25 (Rev . 5-95) Page 9
p.10

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 th e new chemical substance at sites you do not contro l . Importers do not have to complete th is section for operations outside th e U.S . ; however, you must report an y processing or use activities after impo rt. See th e Instructions Man ual . Complete a separate section B for each type of processing, or use operation involving the new chemical substance . Ifthe same operation is performed at more than one site describe the

ty pical operation common to these sites. Identify additional sites on a continuation sheet.

1 . Operation Desc ription -- To claim information in this section as confidential, circle or bracket th e specific information that you claim as confidential .

(1) -- Diagram th e major unit operation steps and chemical conversions, including interim storage an d 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 activi ty . (2) -- Pro vide the identi ty, the approximate weight

(by kg/day or kg/batch, on an 100% new chemical substan ce basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all

products, recycle streams, and wastes. Include cle aning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number th e points of release, including small or intermittent re leases, to th e environment of th e new chemical substance . (4) Please enter the # of sites (remember to identify the locations of th ese sites on a continuation sheet) :

1

# of sites

Solk"', G®ff~

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

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 th e ty pical duration of exposure per worker in (a) hours per day an d (b) days per year.

(6) -- Describe physical form of exposure and % new chemical subst ance (if in mixture), and an y p rotective equipment and enginee ring controls, if an y, used to protect workers.

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

(9) --From the p rocess diagram above, enter th e number of each release point. Complete 9-13 for each release point identifi ed .

( 10) -- Estimate the amount ofthe new substance released (a) directly to th e environment or (b) into contro l technology to the environment (in kg/day or kg/batch).

(12) -- Describe media of release i.e . stack air, fugitive air (optional-see Instructions M anual), surface water, on-site or off-site l and or incineration, POTW, or other (specify) and control technology, if any, th at will be used to limit the re lease ofth e new substan ce to the environment.

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

(3), (5), ( 8), (11), (13) and (15) -- Mark (X) th is column if any ofthe proceeding en tries are confi dential business information (CBI) . Le tter # of CBI Duration CBI Protective Equip. / "/o in CBI Release Amount of CBI Media of Release CBI

of Workers of Engineering Controls/ Form- Number New & Control

Act- Exposed Exposure Physical Form and % ulation Substance Technology

1vi

Ty new substance Released

(1) (2 ) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (10b) (11) (12) (13)

14) -- Byproducts

: (15)

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

EPA FORM 7710-25 ( Rev . 5-95) Page 10
p.11

OPTIONAL POLLUTION PREVENTION INFORMATION

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

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

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal

of the PMN substance. Please include new information pertinent to pollution prevention, including source

reduction, recycling activities and safer processes or products available due to the new chemical substance .

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

modification, process and procedure modification, product reformulation, raw materials substitution, and/or

inventory control . Recycling refers to the reclamation of useful chemical components from wastes that would

otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution

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

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

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting

of risks to other environmental media or non-environmental areas (e .g., occupational or consumer exposure). In

addition, information on the relative cost or performance characteristics of the PMN substance to potential

alternatives may be provided .

All information provided in this section will be taken into consideration during the review of this

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and

examples.

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment ; (2) a reduction in the

volume manufactured ; (3) a reduction in the generation of waste materials through recycling, source reduction or other means ; (4) a

reduction in potential toxicity or human exposure and/or environmental rele as e ; (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 chemica l

substances used in similar application ; or (6) the extent to which the new chemical substance may be a substitute for an existing

substance that poses a greater overall risk to human health or the environment .

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

EPA FORM 7710-25 (Rev. 5-95) Page 11
p.12

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 appropri ate . Number consecutively the pages of the attachments. In the column below, enter the inclusive page

numbers of each attachment. Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guid ance on

how to claim any information in an attachment as confidenti al. You must include with the s anitized copy of the notice form a sanitized version of any attachment in which you claim information as confidential.

Attachment name Attachment Confipage number(s) dential

14-20 X

Material Safety Data Sheet (MSDS)

CAS IES Repo rt COQ 21 X

Continuation Sheets 22-24 X

Production Process -Figure 1 25 X

GC Mass Spectrum 26-32 X

L] 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.13

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T

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 me asured, the page of the notice on which the property appears, the value of the prope rty,

the units in which the propert y is measured (as necessary ), and whether or not the property is claimed as con fi dential . The physical

state of the neat substance should be provided. These meas ured prope rties should be for the neat (100% pure) chemical substance .

Prope rt ies that are measured for mixtures or formulations should be so noted (% PMN substance in _J. You are not required to

submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential

information is properly protected . You should submit this worksheet as a supplement to your submission of test data. This worksheet

is not a substitute for submission of test data .

Property Mark Page Value Measured o Confi-

(X) if number Estimate dential

(a) provided (b) (

c

) Mark(X)

(M or E) (d)

Physical state of neat substance (s) (1) _(g)

Vapor pressure r ~ E X

@ Temperature 21 °C \~

Density/relative density Vapor Density g/cm3 E X

Solubility

@ Temperature °C

Solvent g11-

Solubility in water @ Temperature °C g/I

Melting temperature °C

Boiling / sublimation temperature@ 1 torr pressure °C M X

Spectra GC/Mass Spec M X

Dissociation constan t

Particle size distribution

Octanol / water partition coefficient

Henry's Law constant

Volitalization from water

Volitalization from soi l

pH@ concentration

Flammability

Explodability

Adsorption / coefficient

Other - Specify Flash Point (PMCC, ASTM D93) M X

4

._a

ATTACHMENT

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Continuation Sheets

TS-XXXXXXX

Page 1 - Physical and Chemical Properties Data

Please see MSDS for values on physical properties. We are submitting spectral data with

this submission.

[X]- Part I - Section B, 1(e): Chemical Identity Information - Production Process

Precursors are:

• [X] Indicates Confidential Business Information (CBI)

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Page 1 of 3
p. 23

Continuation Sheets

TS-XXXXXXX

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Part II - Section A, 2 - Occupational Exposure

Workplace air-born concentrations

Sampling: Sampling locations (S1-S5) have been identified in Figure 1 . Samples (50

CC) are collected through ports with small diameters in order to minimize possible air

born emissions during collection activities. Sampling is also performed using closed

sampling system equipped with 2 CC sample vials .

Personal Protective Equipment: Any person who may have the potential to become

exposed to the PMN substance shall wear:

[X] - Container Cleaning: XXXXXXXXXXXXXXXXXXXXXXXXXXXXXY-XXX

crude product tank is rinsed as described in Part II - Section A, 3 . The XXXXXXXX (see

Figure 1), used for collecting and storing the PMN Substance, is cleaned only when the

tanks is required to be used for collection/storage of other products . When XXXXXXXX

XXXXXXXX is cleaned, same procedures described in the next section are used .

In all cases, when there is potential for worker exposure, all required Personal Protective

Equipment (PPE) described above are used .

[X] - Part II - Section A, 3- Environmental Release and Disposal

All rags and solid wastes associated with cleaning are sent to Class I industrial landfill.

S1-S5 : indicate locations where samples are taken for quality control analysis . Samples

are collected either into 50 CC bottles through small sampling ports, or via closed

sampling system equipped with 2 CC vials . Chemically impervious gloves and neoprene

slicker suites and boots are routinely used.

VI-V2: indicate location of possible vapor emissions from vapor vent from product

receptacles. Vapors are collected and sent to flare (efficiency : 99.9999%).

• [X] Indicates Confidential Business Information (CBI)

Page 2 of 3
p. 24

Continuation Sheets

TSAXXXXXX

Waste water from Container Cleaning : XXXXXXXXXXXXXXXXXXXXXXXXX

solvent is used followed by XXXXXXXXXXXX. XXXXXXXXXXXXXXXXXXXXX

XXXXXXXX tank and contains low levels of the PMN Substance which, XXXXXXX

XXXXXXXXXXXXXXXXXXXXXXX. The XXXX X

SA NITIZED COPY

[X] Indicates Confidential Business Information (CBI)

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