## P. 1 Form A pproved. O

.M .B. No. 2070-0012. A

pproval Expires 10-31-96

. 

## U .S. ENVIRONMENTAL PROTECTIONAGENCY AGENCY USE ONLY Date of receipt b~ ` 

# PREMANUFA(''rrTmIP A A 

# / ` 

# E r 

# IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII

II 11 1 IIIIIIIIIIIIIIIIIIIIIIIIIIII~IIII ,



# ~~:~u~; J :#:.. ._ . 31Vi 

# z - . 

# ~U o o 4 0 5 1 0 

# COMPany Sanitized

--' . - . .w ronnsytvat»a, NW 

### WASHINGTON D.C.2046 30 nter the total number of pages ~ oc en PA case number O in the Premanufacture Notice 

## GENERAL INSTRUCTIONS TS 

# -Uuuuu u " You must provide all information requested in this formto the extent that it is knownto 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 forPremanufacture Notification" (the Instructions Manual is available fromtheToxic 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 (40CFR 700 .45), indicate in the boxes above the TS-user fee identification number you have generated . Remember, your user fee ID number must also appear on your corresponding feeremittance, 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 ANDOTHERDATA You must provide the currently correct Chemical Abstracts (CA) Name of the new Youare required to submit all test data in your possession or control andto chemical substance, even ifyou claim the identity as confidential . You may authorize provide a description ofall other data knownto or reasonably ascertainable by another person to submit chemical identity information foryou, but your submission will you, if these data are related to the health and environmental effects on the not be complete and the review will not begin until EPAreceives this information. A letter manufacture, processing, distribution in commerce, use, or disposal of the new insupport ofyour submission should referenceyour TS user fee identification number. chemical substance. Standard literature citations maybe 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 .50of the Premanufacttue Notification Rule (40CFR 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 thatyou want EPAtoconsider in evaluating the new substance. On page 11 of this form, spacehas been provided for you todescribe " Aphysical and chemical properties worksheet is located on the last page of this form . pollution prevention and recycling information you may have regarding the new substance. TYPE OF NOTICE (Check Only One) , So-called"binding" boxes are included throughout this formfor you to indicate your willingness to be bound to certainstatements 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 submitterwhen the i " ' ce ~ .psl Agency approves the exemption application, checking a binding boxin this not ® SNUN (Significant New UseNotice) , by itself prohibit thesubmitter from later deviating from

the information (except chemical - . identity) reported inthe form . © " TMEA (TestMarketing ExemptionApplication) CONFIDENTIALITY CLAIMS rl LVE (Low Volume Exemption) Q40CFR 723.50(cXl) You may claimany information in this notice as confidential . Toassett a claimon the form, mark (X) the confidential box next to the information that you claimas confidential . ® LOREX (LowRelease/LowExposure Exemption) @ 40 CFR 723.50(c)(2) To assert a claimin an attachment, circle or bracket the information you claimas

If ^^^ claiminformation 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 THISA 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 EPAForm7710-25.

## 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 ofthis collection of information, including suggestions for reducing this burden, to Director, Collection Strategies Division (2822), U .S. Environmental Protection Agency, 1200 Pennsylvania Ave., N .W ., Washington, D

.C. 20460 ; and to the Office of Management and Budget, Paperwork ReductionAct (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 1a ofthis notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B

. 2 . All information provided in this notice is complete and truthful as ofthe date of submission. 3 . I am submitting with this notice all test data in my possession or control and a description ofall other data known to or reasonably ascertainable by me as required by §720 .50 ofthe Premanufacture Notification Rule. Additional Certification Statements: Ifyou 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 Ahas remitted the fee of $2500 specified in 40 CFR 700 .45(b), or

~ The Company named in Part I, Section Ahas remitted the fee of $1000 for an Intermediate PMN(defined @ 40CFR 700 .43) in accordance with 40 CFR700 .45(b), or

~ The Company named in Part I Section Ais a small business concern under 40CFR 700 .43 and has remitted a fee of $100 in accordance with 40 CFR 700 .45(b) . Ifyouare submitting a low volume exemption (LVE) application in accordance with 40CFR 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 : 0The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50 . 0 The manufacturer is familiar with the terms ofthis section andwill comply with those terms; and 0 The new

chemical substance for which the notice is submitted meets all applicable exemption conditions . ~ Ifthis application is for an LVE in accordance with 40 CFR723.50(c)(1), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year ofthe date ofthe expiration ofthe 30day reviewperiod. The accuracy of the statements you make in this notice should reflectyour best prediction of the anticipated facts regardingthe chemical substance described herein. An knowing and willful misinterpretation is subject to criminal pe nal ty p ursuant to is USCIOof . Confidential Signature and title ofAuthorized Official (Original Signature Required) F5 

# 1 :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 ofauthorizedofficial applicable) Position 

# IF

Company 

### Mailing address (number and street) City, State Postal Code Telephone (include area code) c. Ifyou are submitting this notice as part of ajoint submission, mark (X) this box. Joint Submitter (if Name ofauthorized official Position applicable) Company



### Mailing address (number and street) City, State 

## Province, Country Postal Code Telephone (include country or area code) 2. Technical Name ofauthorized official Position Contact (in 

# U .S.) Company

Mailing address (number and street) City, State Postal Code Telephone (include area code) 3. Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number. Mark (X) - 

# El if none 4 . Ifyou previously submitted anexemption application forthe chemical substance covered by this notice, enter the exemption number assigned by EPA . Ifyou previously submitteda PMNfor this substanceenterthe PMN Mark (X) --t 

# EK if none number assigned by EPA

(i .e. withdrawnor incomplete) . '-0 5. Ifyou have submitted anotice of Bonafide intent to manufacture or import for the chemical substance covered by this notice, enterthe notice number assigned by EPA

. ----0 Mark (X) 

# IF if none 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 claimas 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 acurrentlycorrect Chemical Abstracts (CA) name of the substancebased onthe ninth

Collective Index 9C of CAnomenclature ru les and conventions

. 

### Mark the "Confidential" box next to an itemyou claimas confidential Complete either itemI (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items.

_ Ifanother person will submit chemical identity information for you (for either ItemI or 2), mark (X) the box at the right . ~ Confidential Identi the name, com

pany, and address ofthat person in a continuation sheet . 1 . Class 1 or 2 chemical substances (for definitions ofclass 1 andclass 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. ForClass 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate basedon CA 9CI nomenclature rules andconventions) . 2-Propenoic acid, 3-(5,5,6-trimethylbicyclo(2 .2 .1]hept-2-yl)cyclohexyl ester

c. Please identifywhich methodyou 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) t b i S ces mus e erv report obtained fromthe CAS Inventory Expert submitted as an attachment to this notice) d. Molecular formula CBI CAS Registry Number (ifa number already 

### exists for the substance) 903876-45-9 For a class I substance, provide a complete and cotrect chemical structurediagram . For a class 2 substance, provide a correct representative or e. partial chemical structure diagram, as complete as can be known, ifone can be reasonably ascertained. Please see the &PMNInstruction Manual for discussion of "native formal" diagramsoftware which can be helpful in reviewing your substance. 

# C onf

# i d

# ent

# ia l D

# ia g

# ram R 

# emove d

Mark (X) this box ifyou 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 ofcomposition 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 y ou 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 .) Confi

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

weight percent of low

molecular weight species (not including residual monomers, reactants, or solvents) below 500 and below1,000absolute molecular wei ght of that com p osition. 

### 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 500molecular weight : 0.000 

### (iii) maximum

weight % below1000 molecularweight : 0 . 000 Mark (X) this box ifyou attach a continuation sheet. b . You must make separate confidentiality claims formonomer or other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any item you claim as confidential (1) - Provide the specific chemical name and CAS Registry Number (ifa 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" fromdrop down menu ifyouwant a monomer or other reactant used at two weight percent or less tobe listed as part of

description on theTSCA 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 maybe present as a residual in the polymeras 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 

# F7, % %

0`0

# 1E] --- 

# []1 0`0 % %

% 

# F] %

% 

# 0 0 % 

# F-1I % %

% ~ % % ~ % % ~ % % ~ % % ~ % Mark (X) this box ifyou 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 fromCAS 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-PMNInstruction Manual for discussion of "native format" diagram software which can be helpful in reviewingyour substance.

f DMark (X) this box ifyou attach a continuation sheet. EPA FORM

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

## p. 8 PMN Page 6 ; Page 8 of 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 ifavailable. If there are unidentified impurities, enter "inidentified." b - Estimate the maximum wei ht %

of each im

p uri ty. If there are unidentified im p urities, estimate their total wei ght % . Impurity and CAS Registry Number Maximum Confi

### percent dential a % 

# X % 

# X % %

%

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

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

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

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

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

### 6 . Generic chemical name - If you claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names.

Mark (X) this box ifyou attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number if available. Byproduct CAS Registry Number Confi1 2 dential

Mark (X) this box ifyou 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 ANDUSE INFORMATION : Mark X the "Confidential" box next to an item y ou claimas 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) Maximum12-month production (kg/yr) (100%new

chemical substance basis) Confidential Biading 

## M tion 

# bo= 2 . UseInformation -- 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 toany itemyou 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 associatedwith 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 

## Op tion g (g)

X 

# i %

# X 1 111XI % %

% %

% % 

# 111111 %

# []I %

% %

# F 1, ' % %

# Ei EIE] E 0111

1 * Ifyou have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products . In addition include estimates of the concentration 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 ifyou attach a continuation sheet . b. Generic use Ifyou claimany category of use description in subsection 2a as confidential, enter ageneric description of that category. Read the Instruction description Manual for examples of generic use descriptions. 

### Thermoset adhesive component

Mark (X) this box ifyou attach a continuation sheet. 3. Hazard Information - Include in the notice a copyof 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 ifyou attach hazard information. EPA FORM

7710-25 (Rev. 5-95) Page 7

## P. 10 PMN Page 8 ; Page 10 of 30 

# Part H-- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claim as confidential 

### Complete section Afor each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you 

## control . Importers do not have to complete this section for operations outside the U .S. ; however, you may still have reporting requirements if there are further industrial processing or use op erations after im

p ort . You must describe these op erations. See instructions manual I . Operation description Confia. Identi ty -- Enter the identi ty ofthe site at which the op eration will occur. dential Name 

## ;

Site address (number and street) Ci ty, County, State, ZIPcode 

### 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 ofthe sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

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

### b . Type -- Mark (X) Manufacturing Processing Use c. Amount and Duration -- Com plete 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 yourwillingness to have your process description binding. x (1) Diagram

the major unit operation steps and chemical conversions . Include interimstorage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc .) . (2) Provide the identity , the approximateweight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc .), and of all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment 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 ifyou 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 makeseparate confidentiality claims for the description ofworker activity, physical formof the new chemical substance, number of works exposed, andduration ofactivity. Mark (X) the "Confidential" box next to any itemyou claimas 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 (ifpart of amixture) 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 ofworkers involved in each activity for all sites combined. (9) --Mark M

this column ifentryin column (8) is confidential business information (CBI) . 

### (10) and (11) -- Estimate the maximum duration of the activity forany 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 ifyou 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 itemyou claimas confidential . (1) --Enter the number ofeach release point identified in the process description, part II, section A, subsection ld(3) . (2) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) -- Mark (X) this column ifentries in columns (1) and (2) are confidential business information (CBI) . (4) --Identify the media (stack sir, fugitive air (optional-see Instruction Manual), surface water, on-site oroff -site land or incineration, POTW, or other (specify)) to which the new

substance will be released fromthat 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 . Forreleases disposed of on land, characterize the disposal method and state whetherit is approved fordisposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methodsthat 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 (inkg/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 (Pu blicl y 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

efficienc y data Binding 

### CBI (3) (4) (5a) Mar` (5b) (6) +R + w



## (7) Mark (X) the d

estination(s) ofreleases to water . NPDES # CB1 POTW--provide name(s) 

### 0 Navigable waterwayprovide name(s) - -- ---- Other--Specify

Mark (X) this box ifyou 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 fortypical 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 aseparatesection B foreach type of ort ities after im ti i . p v 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 claimas 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 tank trucks cars , , 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 frequencyif notused 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 # ofsites (remember to identify the locations ofthese sites on a continuation sheet) : 5 CBI # of sites 

# FX 

# Conf

# i d

# ent

# ia l D

# ia g

# ram

R 

# emove d

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

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

7710-25 (Rev. 5-95) Page 10

## PMN Page 10a ; Page 15 of 30 p. 15 2 . Worker Exposure/Environmental Release (1) --Fromthe diagram above, provide the letter for each worker activity. Complete 2-8for each worker activity described. (2) -- Estimate the number ofworkers exposed for all sites combined. (4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days peryear. 

### (6) -- Describe physical formofexposure and % newchemical substance (if in mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. (9) --Fromthe processdiagramabove, enter the number of each release point. Complete 9-13 foreach 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, thatwill be used to limit the release of the new substance to the environment . (14) -- Identify byproducts which may result fromthe operation. 3 5 8 11 13 and 15 -- Mark X this column if an of the p roceeding 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 inFocm

## CBIActivity Exposed ulation (1) (2) (3) 4a 4b (5) 6 (7) (8) 

# Z, I Fil 

# o a o Z1 

# o 0 0 0 0 -1

. 

# E] o Release Number Amount of New CBI 

## Media of Release & Control Technology CBI Substance Released 9 IOa 106 11 12 13



# FXI. Fill 

# a o 14) -- Byproducts :

_ ------- (15) 13 Mark (X) this box ifyou attach a con tinuat ion sheet, 

# OPTIONAL POLLUTION PREVENTION INFORMATION To claim

information in the following section as confidential circle or bracket the specific informationthat you claimas 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 PMNsubstance. 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 ofchemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control . Recycling refers to the reclamation ofuseful 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 EPAis interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks 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 PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the review of this substance

. See PMNInstructions Manual and Pollution Prevention Guidance manual for guidance and e xamples.

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 ofwaste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a eater overall risk to human health or the environment .

I~Mark (X) this box ifyou 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 formand test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section 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 howto claimany information in an attachment as confidential . You must include with the sanitized copy of the notice forma sanitized version of an attachment in which you claiminformation 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. ~ EPAFORM

7710-25 (Rev. 5-95) Page 12

## p. 18 PMN Page 13 ; Page 18 of 30 PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's review

of physical and chemical properties data, please complete the following worksheet for data youprovide and include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value ofthe property, the units in which the property is measured (as necessary), and whetheror not the property is claimed as confidential . Ifthe attachments are electronic, give the attachment number (found onpage 12) at (b) . The physical state ofthe neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (%PMNsubstance in _) . You are not required to submit this worksheet; however, EPAstrongly recommends that you do so, as itwill 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 nota substitute forsubmission 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 

# Ell Tem p erature °C Torr © cm3 Densi ty/relative densi ty Solubility @ Temperature °C 

# F E :1 Solvent '' ° 

# F-1 1L C Solubili ty in water Tem p erature 

# 9 El oc Melting tem

perature El o Boiling / sublimation tem erature torr pressure 

# l c

FTIR ® Sp ectra 

## Dissociation constant Particle size distribution Octanol / water p

artition coefficient 's Law constant Hen ry Volatilization from

water Volatilization fromsoil H concentration ® M EE Flammabili Ex lodabili Adsorption / coefficient Other - Speci fy NCS TGA & DSC, Refractive Index © Other-Specify Viscosity, Aaake, 5 RPMc/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, TGATrace

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 E xpert Service Adivision of theAmerican Chemical Society

INVMPBORY KKMT SERVlCB RgpORT

IBS-ORDSR NIJNIER" 94269 R80ISTRY NU1~ER: 903876-45-9 4 Ch INDBX MM 

### 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 .

3S40OhwW

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 30of 30