P. 1 

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

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt 

b~ ` 

A A PREMANUFA(''rrTmIP 

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5 1 0 

COMPany Sanitized 

--' . 

- . . w ronnsytvat»a, NW 

WASHINGTON D.C .2046 

nter the total number of pages 30 ~ oc en PA case 

number 

O 

in the Premanufacture Notice 

GENERAL INSTRUCTIONS TS -U u u u u u 

" You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do 

not have actual data. 

" Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603). 

" If a user fee has been rentitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, Washington Financial Management Center (3303), P.O. 

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

Part I-GENERAL INFORMATION TEST DATA AND OTHER DATA 

You must provide the currently correct Chemical Abstracts (CA) Name of the new You are required to submit all test data in your possession or control and to 

chemical substance, even if you claim the identity as confidential . You may authorize provide a description of all other data known to or reasonably ascertainable by 

another person to submit chemical identity information for you, but your submission will you, if these data are related to the health and environmental effects on the 

not be complete and the review will not begin until EPA receives this information. A letter manufacture, processing, distribution in commerce, use, or disposal of the new 

in support of your submission should reference your TS user fee identification number. chemical substance. Standard literature citations may be submitted for data in the 

You must submit an original and two copies of this notice including all test data. If you 

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

claimed any information as confidential, a single sanitized copy must also be submitted . 

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

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

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE chemical composition of the tested material should be characterized . Following 

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

If there are several manufacture, processing, or use operations to be described in Part II, the requirements of §720.50 of the Premanufacttue Notification Rule (40 CFR 

sections A and B of this notice, reproduce the sections as needed. Part 720). 

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

Attach additional sheets if there is not enough space to answer a question fully. Label each " Environmental fate data D Yes " Other data a 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 El Yes Risk assessments 

" Environmental effects data O Yes StructureJactivity relationships[] 

OPTIONAL INFORMATION " Physical/Chemical Properties' ~X Yes Test data not in thq possession 

or control of the submitter ~ 

You may include any information that you want EPA to consider in evaluating the new 

substance . On page 11 of this form, space has been provided for you to describe " A physical and chemical properties worksheet is located on the last page of this form. 

pollution prevention and recycling information you may have regarding the new substance . 

TYPE OF NOTICE (Check Only One) , 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section, such as use, ~ PMN (Premanufacture Notice) _ 

production volume, protective equipment . . . This option is intended to reduce delays that 

routinely accompany the development of consent orders or Significant New Use Rules . 

Except in the case of exemption 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 submitter when the 

i 

" 

' ce ~.psl Agency approves the exemption application, checking a binding box in this not ® SNUN (Significant New Use Notice) , 

by itself prohibit the submitter from later deviating from the information (except chemical - . 

identity) reported in the form . © " 

TMEA (Test Marketing Exemption Application) 

CONFIDENTIALITY CLAIMS 

rl 

LVE (Low Volume Exemption) Q 40 CFR 723 .50(cXl) 

You may claim any information in this notice as confidential . To assett a claim on the 

form, mark (X) the confidential box next to the information that you claim as confidential. ® LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723 .50(c)(2) 

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

If ^^^ claim information in the notices a4 confidential. you must also provide confidential . © LVE Modification ~ LOREX Modification 

9 sanitized version of the notice. (Lcludin¢ attachments) . For additional instructions on 

claim'mr,uation as confidential, read the Instructions Manual . 

IS THIS A CONSOLIDATED PMN? ~ Yes 

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

otice Communication # required, enter # on a e 3 

PMN Page 1 ; Page 1 of 30 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 
p. 2 

PMN Page 2 ; Page 2 of 30 

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

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

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

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

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

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

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

1. The company named in Part I, section A, subsection 1 a 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 

~ 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 

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

in accordance with 40 CFR 700.45(b). 

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

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements : 

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

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

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

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

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

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

review period . 

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

described herein. An knowing and willful misinterpretation is subject to criminal pe nalty pursuant to is USC IOof . Confidential 

Signature and title of Authorized Official (Original Signature Required) 

F51:1 Date 

June 2, 2009 

EKI 

Signature of agent - (if applicable) Date 

EPA FORM 77]0-25 (Rev . 5-95) Page 2 
p. 3 

PMN Page 3 ; Page 3 of 30 

Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION 

la . Person Name of authorized official 

Submitting 

Position 

Notice (in U.S .) 

Company 

Mailing address (number and street) 

City, State Postal Code 

b. Agent (if Name of authorized official 

applicable) 

Position IF 

Company 

Mailing address (number and street) 

City, State Postal Code Telephone (include area code) 

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

Joint Submitter (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) City, State 

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

2 . Technical Name of authorized official Position 

Contact (in 

U.S .) 

Company 

Mailing address (number and street) 

City, State Postal Code Telephone (include area code) 

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

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

if none El 

4. If you previously submitted an exemption application for the chemical 

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

EPA. If you previously submitted a PMN for this substance enter the PMN Mark (X) --t 

number assigned by EPA (i .e. withdrawn or incomplete). '-0 if none EK 

5 . If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical substance covered by this notice, enter the notice number 

assigned by EPA. ----0 

Mark (X) 

if none IF 

6. Type of Notice - Mark (J~ 

1 . 0 Manufacture j 2. E] Import j 

Only I Only 13. ~ Both 

Binding Option ~ El Binding Option 11 

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

0 

Mark (X) I Mark (X) I 

Confidential 

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 9C of CA nomenclature rules and conventions. 

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

Complete either item I (Class 1 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 . ~ Confidential 

Identi the name, company , and address of that p erson in a continuation sheet . 

1 . 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) Class 1 or Class 2 

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

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). 

2-Propenoic acid, 3-(5,5,6-trimethylbicyclo(2 .2 .1]hept-2-yl)cyclohexyl ester 

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

E 

Method I (CAS Inventory Expert Service - a copy of the Identification 1 I Method 2 (Other Source) 

S erv i ces mus t b e report obtained from the CAS Inventory Expert 

submitted as an attachment to this notice) 

d. Molecular formula CBI CAS Registry Number 

(if a number already 

exists for the substance) 

903876-45-9 

For a class I substance, provide a complete and cotrect chemical structure diagram. For a class 2 substance, provide a correct representative or 

e . 

partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. Please see the &PMN Instruction Manual for 

discussion of "native formal" diagram software which can be helpful in reviewing your substance. 

Confi dentia l Diagram 

Removed 

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

PMN Page 4 ; Page 4 of 30 

EPA FORM 7710-25 (Rev . 5-95) Page 4 
PMN Page 4a ; Page 5 of 30 

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. 

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

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

e. (1) List the immediate precursor substances with their respective CAS Registry Numbers. 

ame (CAS #) Confidential 

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

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

U Mark this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 4a 
PMN Page 5 ; Page 6 of 30 

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 1,000 absolute molecular weigh t of that composition. 

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

(i) lowest number average molecular weight : 

(ii) maximum weight % below 500 molecular weight : 0 .000 

(iii) maximum weight % below 1000 molecular weight : 0 . 000 

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 man 

the polymer. 

ufacture of 

(2) - Mark (3C) 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) - Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of 

description on the TSCA Chemical Substance Inventory. 

the polymer 

(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 this column if en in column 6 is confidential. 

Monomer or other reactant and CAS Registry Number Confidential 

Typical 

composition 

Include in 

identity 

Confidential Maximum 

residual 

Confidential 

1 2 3 

% 

4 5 6 

0`0 

7 

F 7, % % 

0`0 1 E] 

--- 

[] 1 0`0 

% % 

% 

F] 

% 

% 

0 0 

% 

F-1 I 

% % 

% 

~ 

% 

% 

~ 

% 

% 

~ 

% 

% 

~ % 

% 

~ 

% 

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

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

PMN Page 5a ; Page 7 of 30 

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

~ Method l (CAS Inventory Expert Service - a copy of the identification report © Method 2 (other source) 

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

CBI 

El 

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

CAS Registry Number (if a number already exists for the substance) / 

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

see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance. 

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

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

PMN Page 6 ; Page 8 of 30 

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 "inidentified." 

b - Estimate the maximum wei ht % of each impurity . If there are unidentified impurities, estimate their total weight %. 

Impurity and CAS Registry Number Maximum Confipercent dential 

a 

% 

X 

% 

X 

% 

% 

% 

% 

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

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

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

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

11 

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

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

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

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

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

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

Number if available. 

Byproduct CAS Registry Number Confi1 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 30 

Part I - GENERAL INFORMATION - Continued 

Section C - PRODUCTION IMPORT AND USE INFORMATION: 

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

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

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

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

10,000 k , speci fy the volume and mark x in the bindin box. If granted , you are bound to this volume 

Maximum first 12-month production (kg/yr) 

(100% new chemical substance basis) 

Maximum 12-month production (kg/yr) 

(100% new chemical substance basis) 

Confidential 

Biading 

M 

t ion 

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

bo= 

devoted to each 

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

a. (1) --Describe each intended category of use of the new chemical substance by function and application. (2) --Mark (X) this column if entry column (1) is onfidential business information (CBI). (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total 

roduction for the first three years devoted to each category of use. (5) --Mark (X) this column if entry in column (4) is confidential business information (CBI). (6) -- 

stimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under 

our control associated with each category of use. (7) --Mark (X) this column if entry in column (6) is confidential business information (CBI). (8) --Indicate % of 

roduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) indin . 9 --Mark X this column if en ies in column 8 is are confidential business information (CBI). 

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

n 

Prod- CBI % in CBI % of substance expected per use CBI dispersive dye for finishing polyester fibers) ~~ uction 

% 

Formu 

lation 

(8) 

(x) 

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

Bindin Option g (g) 

X i 

% 

X 1 11 1XI % % 

% % 

% % 

11 111 1 

% 

[] I 

% 

% % 

F 1 , ' 

% % 

* If you have identified a "consumer" use, please provide on a 

EIE] continuation sheet a E Ei 0111 1 

detailed description of the use(s) of this chemical substance in consumer products . In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. 

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

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

Thermoset adhesive component 

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

3. Hazard Information - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for 

Binding Option 

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

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

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

PMN Page 8 ; Page 10 of 30 

Part H-- 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 processin g or use operations after import . You must describe these operations . See instructions manual 

I . Operation description Confia. Identi ty -- Enter the identi ty of the site at which the operation will occur. dential 

Name 

; 

Site address (number and street) 

City, Coun ty , 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 . 

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

b. Type -- 

Mark (X) Manufacturing Processing Use 

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

Maximum kg/batch (i ooi ~ chemio.i 

substance) 

Hours/batch Batches/year 

1 . Batch 

Maximum kg/day (ioo^i new chemicai 

substence) 

Hours/day Days/year 

2 . Continuous 

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

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

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

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

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

used daily or per batch.) . 

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

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

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

EPA FORM 7710-25 (Rev . 5-95) Page 8 
PMN Page 8a ; Page 11 of 30 

Confidential 

191 

Confidential Diagram 

Removed 

EPA FORM 7710-25 (Rev. 5-95) Page 8a 
PMN Page 9 ; Page 12 of 30 

Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued 

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

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

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

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

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

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

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

time of exposure. 

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

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

(9) --Mark M 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 this column if entries in columns 10 and 11 are confidential business in tion (CBI) . 

Worker activity CB! Protective Equipment/ Binding Physical Binding CBI # of CBI Maximum duration CBI 

forms(s) 

(i .e., bag dumping, filling drums) 

1 (Z) 

Engineering Controls 

3 

Option 

Mark (x) 

(4) 

and % new 

substance 

(5) 

Option 

Mark (x) 

(6) (7) 

Workers 

Exposed 

8 (9) 

Hrs/day 

(I0) 

Dayslyr 

(tt) (12) 

a~ 

II 

Jul 

U U U 

U 

U 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9 
PMN Page 9a ; Page 13 of 30 

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 "ConfidentiaP' box next to each item you claim as confidential. 

(1) --Enter the number of each release point identified in the process description, part II, section A, subsection ld(3). 

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

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

(4) --Identify the media (stack sir, 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 if the POTW name or NPDES # is confidential business information CB . 

Release 

Number 

(1) 

Amount of new 

substance released 

(2a) (2b) 

CBI Medium of 

release 

e.e .aad .v 

~ 

Control technology and efficiency (you may wish to optionally attach 

efficiency data 

Binding 

CBI 

(3) (4) (5a) Mar` (5b) (6) 

+R + w 

(7) Mar k (X) the d estination(s) of releases to water. NPDES # CB1 

POTW--provide 

name(s) 

0 Navigable waterwayprovide name(s) 

- -- ---- 

Other--Specify 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9a 
PM N Page 10 ; Page 14 of 30 

Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section B - INDUSTRIAL SITES CONTROLLED BY OTHERS 

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

See the Instructions Manual. Complete a separate section B for each type of i ti v ities after im p ort . ng or use ac operations outside the U.S .; however, you must report any process 

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

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

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 

cars , tank trucks , 

identity, the approximate weight (by kg/day or kg(batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and 

catalysts, etc) and all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Either in the diagram or in the 

text field 1(b) below, identify by number the points of release, including small or intermittent releases. to the environment of the new chemical substance . (4) Please enter 

the # of sites (remember to identify the locations of these sites on a continuation sheet) : 5 CBI 

# of sites 

FX 

Confi dentia l Diagram 

Removed 

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

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

EPA FORM 7710-25 (Rev. 5-95) Page 10 
PMN Page 10a ; Page 15 of 30 

p. 15 

2. Worker Exposure/Environmental Release 

(1) --From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -- Estimate the number of workers exposed for all sites combined . 

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) -- Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect 

workers. 

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

(9) --From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified. 

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

(12) -- Describe media of release i.e . stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify) 

and control technology, if any, that will be used to limit the release of the new substance to the environment. 

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

3 5 8 11 13 and 15 -- Mark X this column if an of the proceeding entries are confidential business information (CB[). 

Letter 

of 

N of 

Workers 

CBI Duration of 

Exposure 

CBI Protective Equip. /Engineering Controls/Physical Form and/ % new substance °ia in 

FocmCBI 

Activity Exposed ulation 

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

Z , I Fil 

o a o Z 1 o 0 0 0 0 

Release -1 . E] o 

Number 

Amount of 

New 

CBI Media of Release & Control Technology CBI 

Substance 

Released 

9 IOa 106 11 12 13 

FXI . 

Fil l 

14) -- Byproducts : a o 

_ ------- 

(15) 

13 Mark (X) this box if you attach a continuat ion sheet, 

OPTIONAL POLLUTION PREVENTION INFORMATION 

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

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

associated with activities surrounding manufacturing, processing, use and disposal of the PMN substance. Please include new information 

pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new 

chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, 

process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the 

reclamation of useful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or 

land disposal. Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to 

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

assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or nonenvironmental areas (e .g ., occupational or consumer exposure). In addition, information on the relative cost or performance characteristics of 

the PMN substance to potential alternatives may be provided . 

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

Manual and Pollution Prevention Guidance manual for guidance and examples. 

EPA FORM 7710-25 (Rev . 5-95) Page l0a 
PMN Page 11 ; Page 16 of 30 

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

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

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

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

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

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

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

C I 

I! 

EPA FORM 7710-25 (Rev . 5-95) Page 11 
p. 17 

PMN Page 12 ; Page 17 of 30 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form and test data and other data (including physical/chemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to 

which it relates, if appropriate . Number consecutively the pages of any paper attachments . In the column below, enter the inclusive page 

numbers of each attachment . Electronic attachments can be identified by filename. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized 

version of an attachment in which you claim information as confidential. 

# Attachment name Attachment Filename Attachment Confia e number(s) dential 

2L 

CAS Inventory Expert Service Naming Report 13k 

EL 

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

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

PMN Page 13 ; Page 18 of 30 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

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

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

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

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

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

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

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

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

Page Value Measured Mark _ Property dential if number Estimate Mark (X) 

(a) provide 

(b) (c) or E (d) 

~ ^d 1 CL s : 

M ~X 

Physical state of neat substance . 1 ' 

Vapor pressure 

Temperature °C El l Torr 

© cm3 Density/relative density 

Solubility 

@ Temperature °C F E:1 

Solvent '' 

Solubility in water Temperature ° C F-1 9 1L 

El oc 

Melting temperature 

El o 

Boiling / sublimation tem erature torr pressure l c 

Spectra FTIR ® 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry ' s Law constant 

Volatilization from water 

Volatilization from soil 

H concentration 

® M EE Flammabili 

Ex lodabili 

Adsorption / coefficient 

Other - Speci fy 

NCS TGA & DSC, Refractive Index © 

Other-Specify Viscosity, Aaake, 5 RPM c/p © 

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

PAGE 13 
TS - 9KK5E6, Part 1, Section C, Question 3, Material Safety Data Sheet 

PMN Pages: 13a - 13e 

Redacted 
TS - 9KK5E6, Physical and Chemical Properties Worksheet, Technical Data Sheet 

PMN Page : 13f 

Redacted 
TS - 9KK5E6, Physical and Chemical Properties Worksheet, FTIR Trace 

PMN Page: 13g 

Redacted 
TS - 9KK5E6, Physical and Chemical Properties Worksheet, TGA Trace 

PMN Page: 13h 

Redacted 
TS - 9KK5E6, Physical and Chemical Properties Worksheet, DSC Trace 

PMN Page: 13i 

Redacted 
TS - 9KK5E6, Physical and Chemical Properties Worksheet, GPC Trace 

PMN Page: 13j 

Redacted 
TS - 9KK3C4, Part I, Section B .1 .b., CAS Inventory Expert Service Naming Report 

PMN Page: 13k 

Inventory Expert Service 

A division of the American Chemical Society 

INVMPBORY KKMT SERVlCB RgpORT 

IBS-ORDSR NIJNIER" 94269 

R80ISTRY NU1~ER : 903876-45-9 

4 

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Phaw8"1-1894. 614447,9870 

fmc 614447-3747 

Ereet uuvwrs@ator8 

Yan,ee hqrJlwww"at.orvSuPPaddenthtinl 

2-ProDenoic acid, 3-(5,5,6-trimetbSrlbicyclo[2 .2 .1]hept-2-yl)cycloboWl ester 

Please yrint the abore CB,Iades Nar a® the awroariate yape of poor P101 . 

I! t6le,bos it o3ealced. Cu has aade aorsectioa(e) aarlred In red to 

7roar sY order. Plea" now the w oozreotiaa(i) to pwr plpl belore sulnittiaQ it to ti, sD71 . 

3S40 OhwW NWr Road - PO. Bac 3343 " CohrmbuS Oq,b 43210.0734 
Premanufacture Notice Electronic Continuation Sheet 

Continued From: Part II, Section 131, pg 10 

Continuation Title: Ind. Sites Controlled by Others Cont . Sheet 

Insert narrative continuation here 

Insert any picture here (PDF) 

11 Check here to add another continuation sheet 

Page 30 of 30