p. 1

`"~ ~lll l Z t.=! C i

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Form Approved. O .M.B. No. 2070-0012. A a1 Expires 10-31-9 6

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY

Date of receipt

V F fiil

~ PREMANUFACTURE

~ ~ NOTICE ~`~, Z: 1,3

'ES

Company Sanitized

1 0 S 0 J U 1 1

I K0 in the Premanufacture Notice

I

E i er

GENERAL INSTRUCTIONS TS -[P 11 A C C 6 1

• You must provide all information requested in this form to th e extent th at it is known to or reasonably ascertainable by you . Make reasonable estimates if you do not have actual data .

• Before you complete this form, you should read the "Instructions Man ual for Preman ufacture Notification" (the Instructions Manual is available from the Toxic Substances Contr ol 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 remi ttance, which is sent to EPA, HQ Accounting Operations Br anch (PM-226), P .O . 360399M, Pi ttsburgh, PA 15251- 6399, Attn. TSCA User fee .

Part I -GENERAL INFORMATION TEST DATA AND OTHER DAT A

You must provide the currently correct Chemical Abstracts (CA) Name of th e new chemic al

subst an ce, even if you claim the identity as confidential . You may au thorize You are required to submit all test data in your possession or control and to provide a an other person to desc ri ption of al submit chemical identity informati on for you, but your submission will not be complete l other data known to or reasonabl ascertainable b and the

y y you, if these data are

review will not begin unti l EPA receives th is information . A letter in support of your submission related to the he alth and environmental effects on the m anufacture, processing, distribution

should reference your TS user fee identification number. You must submit an original and two in commerce, use, or dispos al of th e new chemical substance. St andard literature citations

copies of this noti ce including all test data. If you claimed any informati on as confidential, a may be submitted for data in the open scientific literature . Complete test data (written in single sani tized copy must also be submitted. Enalish ), not summaries of data, must be submitted ifthey do not appear in the open

literature . You should clearly identify whe ther test data is on the substan ce or on an

analog. Also, the chemic al composition of the tested material should be characterized . Part II -HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Following are examples of test data

and other data . Data should be submitted according to

If th ere are several manufacture, processing, or use operations to be described in PartII, secti ons

th e requirements of §720 .50 of the Premanufacture Notificati on Rule (40 CFR Part 720).

A an d B ofthis no tice, reproduce the secti ons as needed.

Part III - LIST OF A TTACHMENTS Test Data (Check Below any included in this no tice )

A ttach addi tional sheets if there is not enough space to an swer a questi on fully . Label each • Environmental fate data ❑ Yes • Other data ❑ Yes continuation sheet with th e corresponding section heading . In Part III, list these attachments, any

test data or other data and any optional information included in the noti ce . • Health effects data ❑ Yes Risk assessments

Environmental effects data ❑ Yes Structure/activity relati onships

OPTIONAL INFORMATION

• Physical/Chemical Properties* ® Yes Test data not in th e possession or

You may include any information th at you want EPA to consider in evalua ti ng th e new contr ol of th e submitter substance . On page I I of th is form, space has been provided for you to desc ri bed polluti on

prevention and recycling informati on you may have regarding the new substance. ' A physical an d chemical properties worksheet is located on the last page of this form.

So-call ed "binding" boxes are included throughout this form for you to indicate your willingness TYPE OF NOTICE (Check Only One )

to be bound to certain statements you make in th is secti on, such as use, producti on volume ,

protecti ve equipment . . . This opti on is intended to reduce delays that routinely accompany the

development of consent orders or Significant New Use Rules PMN ( premanufacture Noti ce) . Except in th e case of exemptio n

applica ti ons (such as TMEA, LVE, LOREX) where certain informa ti on provided in such

noti fica ti on is binding on the submi tter when th e Agency approves the exemp ti on application, ~ INTERMEDIATE PMN (submi tted in sequence with final product PMN) checking a binding box in this no ti ce does not by itself prohibit the submi tter from later deviatin g

fr om the information ( except chemical iden tity ) reported in the form .

E] SNUN (Significant New Use Noti ce)

CONFIDENTIALITY CLAIMS

TMEA (Test Marketing Exemption Application )

You may claim any informa ti on in th is no ti ce as confidential . To asse rt a claim on the form, ❑

mark (X) th e confidential box next to the information that you claim as confiden tial

claim in . To assert a LVE (LowVolume Exemption) @ 40 CFR 723 .50(c)(1) an attachment, circle or bracket the information you claim as confiden tial. If you clai m

informati on in the noti ces as confidential . you must also provide a sanitized version of the

notice, (including attachments l . For additional instructions on claiming informati on as ~ LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723 .50(e)( 2) confidential, read the Instruc tions M an ual .

Modification ~ LOREX Modifi cation Mark (x) if any informati on in this notice is claimed as confidential. LVE

IS THIS A CONSOLIDATED PMN? No

# ofchemic als

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

EPA FORM 7710-25 ( Rev. 5-95) PageI r ~, ~~

~
p. 2

Public repo rt ing burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions,

searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information . Send comments

regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information

Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S .W., Washington, D .C. 20460; and to the Office of Management and

Budget, Paperwork Reduction Act (2070-0012), Washington, D .C. 20503.

CERTIFICATION

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

1 . The company named in Part I, section A, subsection 1 a of this notice form intends to manufacture or impo rt for a commercial

purpose, other than in small qu an tities solely for research and development, the substance identifi ed 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 as ce rtainable 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 certifi cation statement

that applies:

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

❑ The Company named in Part I, Section A has remi tted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 700 .43) in

accordance with 40 CFR 700 .45(b), or

❑ The Company named in Part I Section A is a small business concern under 40 CFR 700 .43 and has remi tted a fee of $100 in

accordance with 40 CFR 700 .45(b).

If you are submitting a low volume exemption (LVE) application in accord an ce 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 ce rtification statements:

❑ The manufacturer submitting this notice intends to m anufacture or import the new chemical substance for commercial purposes,

other than in small qu an tities 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; an d

❑ The new chemical substance for which the notice is submitt ed meets all applicable exemption conditions.

❑ If this application is for an LVE in accordan ce 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 describe d

herein. Any knowing and willful misinterpretation issubject to criminal penalty pursuant to 18 USC 1001 . Confidential Signature and title of Authorized Official (Original Signature Required) Date

X

Signature of agent - (ifapplicable) Dat

e

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

Part I -- GENERAL INFORMATION

Section A -- SUBMITTER IDENTIFICATION ConfiMark O the "Confi dential" box next to any subsection you claim as confidential dential

1 a. Perso n

Submitting

Notice (in U X .S . )

b . Agent (if Name of authorized official Position

applicable)

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Numbe

r 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

. Technical i 2

Contact (in U.S .)

City, State, ZIP Code Telephone ~ Area Code ~ Number

i

i 3 . If you have had a prenotice communicati on (PC) concerning this notice and EPA

assigned a PC Number to the notice, enter the number . Mark (X)

if none

4 . If you previously submitted an exemp tion application for the chemical substance

covered by this notice, enter the exemption number assi gned by EPA

previously submitt ed a PMN for this substance enter the PMN number assigned if non . If you Mark (X) ----► ®

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

5 . If you have submi tted a notice of Bona fi de intent to manufacture or import for

the chemical

by EPA.

substance covered by this no tice, enter the notice number assigned Mark (X) ~-1 ®

0 if none

6 . Type of Notice - Mark (X) I' ❑ Manufacture 2

Only Only 3

. ❑ Import

. Both

E Binding Option ❑ Binding Option

Mark (X) ; Mark (X)

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

Part I - GENERAL INFORMATION -- Continued

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

ninth Collective Index (9CI of CA nomenclature rules and conventions.

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

Complete either item 1(Class 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 right . ConfiIdenti the name, company, and address of that person in a continuation sheet. ❑ dential

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

a . Class of substance - Mark (X) X Class 1 or Class 2

X

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

Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, X

which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

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

X Method 1(CAS Inventory Expert Service - a copy of the Identification report E] Method 2 (Other Source)

obtained from the CAS Inventory Expert Services must be submitted as a n

d . Molecular formula and CAS Registry Number (if a number already exists for the substance)

attachment to this notice) See Attachment 12

:4

X

CAS#

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

substances with their respective CAS Registry Numbers . (2) Describe the nature of the reaction or process. (3) Indicate the range of composition X

and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical structure diagram, as complete as can b e

known, if one can be reasonably ascertained .

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

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

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 Collec tive Index ( 9CI of CA nomenclature rules and conventions. Mark (X) the "Confi dential" box next to any 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 1 or 2), mark ( X) the box at the right . Confi- Identi the name, company, and address of that person in a continuation sheet . ❑ dential 1 . Class I or 2 chemical substances ( for definitions of class I an d class 2 substances, see the Instructions Manual )

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

X

b . Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances . For Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must be provided , which ever is appropriate based on CA 9CI nomenclature rules and conventions). X

c . Please identify which method you used to develop or obtain the specifi ed chemical identity information repo rted in this notice : ( check one).

X Method 1 (CAS Inventory Expe rt Serv ice - a copy of the Identification repo

rt Method 2 (Other Source) obtained from the CAS Inventory Expert Services must be submi tt ed as an

att achment to this notice) See Attachment 1 2

d . Molecular formula and CAS Registry Number ( if a number already exists for the substance)

X

CAS#

e . For a class 1 substan ce, provide a complete and correct chemical structure diagram . For a class 2 substance -( 1) List the immediate precursor

substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. ( 3) Indicate the range of compositio n

and the typical composition (where appropriate) . ( 4) Provide a correct representative or pa rtial chemical structure diagram, as complete as can be X

known, if one can be reasonably ascertained .

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

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

Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITY INFORMATION - Continued

2 . Polymers (For a definition of polymer, see the Instructions Manual

.) Confidential

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture .

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

1,000 absolute molecular weight of that composition .

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

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.

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information . Mark (X) the

"Confidential" box next to any item you claim as confidential

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of the

polymer.

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

(3) - Indicate the typical weight percent of each monomer or other reactant in the polymer

.

(4) - Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer description on

the TSCA Chemical Substance Inventory .

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

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

purposes.

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

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X) dential residual dential

(1) (2)

X X X

(3) (4) (5) (6) (7)

X X X

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

X X X

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one)

.

Method I (CAS Inventory Expert Service - a copy of the identification report ❑ Method 2 (other source) X

obtained from CAS Inventory Expert Service must be submitted as

as att achment to this notice )

d

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

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

.

X

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 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 weight % of each impurity . If there are unidenti fied impurities. estimate their total weight %.

Impurity and CAS Registry Number Maximum Confipercen t percent dentia l

(b)

X

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

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

X

❑ 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 .

There are 5 chemical substances in this PMN of which 3 are Class I substances and the rest 2 are Class II substances . The

generic name for each of the 5 chemical substances are given below .

Class I Substances

1 . Reaction product of polyether amine and methyl isobutyl keton e

2. Reaction product of aminopropyl morpholine and methyl isobutyl keton e

3. Reaction product of fatty acids, ethylene amine and methyl isobutyl ketone

Class II Substances

1 . Reaction product of formaldehyde, 1,3-benzenedimethanamine, phenol, and methyl isobutyl keton e

2. Reaction product of fatty acids, butoxymethyl oxirane, formaldehyde-phenol polymer glycidyl ether, aminopropyl morpholine,

polyether amine, ethylene amine and methyl isobutyl keton e

❑ 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 Confi-

(1) (2) dential

X

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

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

Part I -- GENERAL INFORMATION -- Continued

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

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

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

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

a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 kg/yr, specify the volume

and mark (x) in th e binding box . If granted, 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)

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) th is column if entry(ies) in column (8) is (are) confidential business information (CBI).

Category of use (1) CBI Binding Produc- CBI "/o in CBI % of substance expected per use CBI

Option tion % Form- (8)

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

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

Curing agent for epoxy coating 100% 50 % 100

s stems

~ro nro

~ro ~ro

~ro ~ro

°ra

% %

%

°io ~ro

* 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.

1:1 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 instructions

use Manual. for examples of generic use descriptions.

description Use categories not claimed as confidential

~ 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 Binding

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

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

Mark (X) this box if you attach hazard information . See attachment-l 1 for the MSDS

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

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 confidentia l

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

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

X

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

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 -- X

Mark (X) ~ Man ufacturing Processing Use

c . Amount an d Duration -- Complete 1 or 2 as appropriate

Maximum kg/batch (100^i new chenicai Hours/batch Batches/year X

substance )

1 . Batch

Maximum kg/batch (to(rnew chernical Hours/batch Batches/year

substance )

2 . Continuou s

d . Process description 11 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 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 .

Mark (X) this 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 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

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

time of exposure.

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

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

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

.

(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year .

(12) -- Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI)

.

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

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

Mark (x) substan ce Mark (x) Expose d

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (tt) (12)

X X X X

X X X X

X X X X

X X X X

X X X X

~ Mark (X) th is box if you a ttach 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 I d(3) .

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

.

(3) -- Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI)

.

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which

the new substance will be released from that release point .

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

on land, characterize the 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) CBI

Number released release

(1) (2a) (2b) e g stack air Binding

~ X X

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

2 X X

4 X X

3 X X

5 X x

6 X X

7 X X

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

destination(s) of X waterway X

releases to water.

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

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

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continue d

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control . Importers do not have to complete this section for

operations outside the U .S . ; however, you must report any processing or use activities after import . See the Instructions Manual . Complete a separate section B for each type of

processing, or use operation involving the new chemical substance . If the same operation is performed at more than one site describe the typical operation common to these

sites. Identify additional sites on a continuation sheet.

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

3

# of sites

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

2 . Worker Exposure/Environmental Releas e

(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), (I 1), (13) and (15) - Mark (X) this column if any of the proceeding entries are confidential business information (CBI) .

Letter # of CBI Duration CBI Protective Equip. / % 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

ivity Released new substanc e

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9)

X X X

(1 Oa) (lob) (11) (12) (13)

x X X X X X

X X X X X

X X

X

' `

X

(14) Byproducts: None (15)

® Mark (X) this box if you a tt ach a continuation sheet,

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

OPTIONAL POLLUTION PREVENTION INFORMATION

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

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

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

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

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

includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and

procedure modification, product reformulation, raw materials substitution, and/or inventory control . Recycling

refers to the reclamation of useful chemical components from wastes that would otherwise be treated or released as

air emissions or water discharges, or land disposal . Descriptions of pollution prevention, source reduction and

recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements

and can be either quantitative or qualitative . The EPA is interested in the information to assess overall net

reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media

or non-environmental areas (e .g., occupational or consumer exposure). In addition, information on the relative cost

or performance characteristics of the PMN substance to potential alternatives may be provided .

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

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

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

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

potential toxicity or human exposure and/or environmental release ; ( 5) an increase in product performance, a decrease in the cost of

production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in

similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a greater

overall risk to human health or the environment .

Confidential

❑ Mark (X) this box if you att ach a continuation sheet.

EPA FORM 7710-25 (Rev . 5-95) Page 12
p. 13

Part III -- LIST OF ATTACHMENTS

Attach continuation sheets for sections of the form and test data and other data (including physical/chemical prope rt ies and structure/activity

information), and optional information after this page . Clearly identify the attachment and the section of the form to which it relates , if appropriate . Number consecutively the pages of the attachments . In the column below, enter the inclusive page numbers of each attachment. Mark (X) the "Confidential" box next to any attachment name you claim as con fi dential . Read the Instructions Manual for guid ance on how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a s an itized version of any attachment in which you claim information as con fi dential .

Attachment name Attachment Confipage number(s) dential

X

X

X

X

X

X

X

X

X

X

X

X

X

X

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

EPA FORM 7710-25 ( Rev . 5-95) Page 13
p.14

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T

To assist EPA's review of physical and chemical prope rt ies data, please complete the following worksheet for data you provide and include it

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

which the property is measured (as necessary ), and whether or not the property is claimed as confidential . The physical state of the neat

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

measured for mixtures or formulations should be so noted (% PMN substance in _j You are not required to submit this worksheet ;

however, EPA strongly recommends that you do so, as it will simplify review and ensure that con fi dential 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 (X) Page Value Measured or Con6-

'f number Estimate den[ial

(a) provided (b) (e) Mark (X)

M or E) (d)

X

X

X

X

X

x

X

X

X

EPA FORM 7710-25 ( Rev. 5-95) Page 14