IIIIIIIIIIIIIIIIIIIIIIIIIIIIJIIIIIIIIIIIIIIIIIIIIIIIIII SANITIZED SUBMISSION 

PMN2010P1 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

PREMANUFACTURE 

NOTICE 

Date of receipt: 

FOR NEW CHEMICAL SUBSTANCES 51100000545 

Office of Pollution and Toxics 

Document Control Office (7407M) 

US EPA, 1200 Pennsylvania Ave NW 

WASHINGTON, D.C. 20460 

Submission rt Number 

1 i you. i 

• 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 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 JD number 

must also appear on your corresponding fee remittance. For mailing address information see the Help instructions in the e-PMN tool. 

Part I- GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) 

Name of the new chemical substance, even if you claim the 

identity as confidential. You may authorize another person to 

submit chemical identity information for you, but your submission 

will not be complete and the review will not begin until EPA 

receives this information. A letter in support of your submission 

should reference your TS user fee identification number. For all 

Section 5 Notice submissions (paper or electronic) you must 

submit an original notice including all test data; if you claimed any 

information as confidential, an original sanitized copy must also be 

submitted. 

Part II- HUMAN EXPOSURE AND ENVIRONMENTAL 

RELEASE 

If there are several manufacture, processing, or use operations to 

be described in Part II, sections A and B of this notice, reproduce 

the sections as needed. 

Part Ill- LIST OF ATTACHMENTS 

For paper submissions, attach additional sheets if there is not 

enough space to answer a question fully. Label each continuation 

sheet with the corresponding section heading. In Part Ill, list these 

attachments, any test data or other data and any optional 

information included in the notice. 

OPTIONAL INFORMATION 

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 pollution prevention and 

recycling information you may have regarding the new substance. 

"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, production volume, protective 

equipment ... The intention is to reduce delays that routinely 

accompany the development of consent orders or Significant New 

Use Rules. Checking a "binding" box in a PMN does not by itself 

prohibit the submitter from later deviating from the information 

(except chemical identity) reported in the form; however, in the 

case of exemption applications (such as TMEA, LVE, LOREX) 

certain information provided in such notifications is binding on the 

submitter when the Agency approves the exemption application, 

especially if the production volume "binding" box is chosen in a 

LVE. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To 

assert a claim on the form, mark (X) the confidential box next to 

the information that you claim as confidential. To assert a claim in 

an attachment, circle or bracket the information you claim as 

confidential. If you claim information in the notices as confidential. 

you must also provide a sanitized version of the notice. (including 

attachments). For additional instructions on claiming information 

as confidential, read the Instructions Manual. 

EPA FORM 7710-25 (Rev. 6-09) 

TESTDATAANDOTHERDATA; P-10-545 ... P-10·546 

You are required to submit all test data in your possession or-control and to provide a 

description of all other data known to or reasonably ascertainable by you, if these data are 

related to the health and environmental effects on the manufacture, processing, distribution in 

commerce, use, or disposal of the new chemical substance. Standard literature citations may 

be submitted for data in the open scientific literature. Complete test data (written in English). 

not summaries of data. must be submitted if they do not appear in the open literature. You 

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

chemical composition of the tested material should be characterized. Following are examples 

of test data and other data. Data should be submitted according to the requirements of 

§720.50 of the Premanufacture Notification Rule (40 CFR Part 720). 

D 

D 

D 

0 

D 

[] 

D 

D 

D 

D 

D 

D 

D 

D 

X 

2 

Test Data (Check Below any included in this notice). 

Environmental fate data D OtherData 

Health effects data D Risk Assessments 

Environmental effects data D Structure/activity relationships 

Physical/Chemical Properties (A physical and chemical properties worksheet is 

located on the last page of this form.) 

Test data not in the possession or control of the submitter 

TYPE OF NOTICE (Check Only One) 

PMN (Premanufacture Notice) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

LVE (Low Volume Exemption)@ 40 CFR 723.50(c)(1) 

LOREX (Low Release/Low Exposure Exemption)@ 40 CFR 723.M(c}(2) 

LVE Modification 

LOREX Modification 

Mock Submission 

Mark (X) if pending Letter of Support 

IS THIS A CONSOLIDATED PMN (YIN)? 

#of chemicals or polymers (Prenotice Communication# required, enter# on 

p. 3). 

Mark (X) if any information in this notice is claimed as confidential. 

Replaces previous editions of EPA Form 7710-25 

Page 1 

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PMN2010P2 PMN Page 2 

The public reporting and recordkeeping burden for this collection of information is estimated to average 93 hours per response. Send 

comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for 

minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies 

Division, U.S. Environmental Protection Agency (2822T}, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB 

control number in any correspondence. Do not send the completed EPA Form 7710-25 to this address. 

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

with CD or paper submission. 

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

1. The company named in Part I, section A, subsection 1a of this notice form intends to 

manufacture, import or process 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: 

D 

D 

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: 

D 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. 

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

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

D 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. Any knowing and willful 

misrepresentation is subject to criminal penalty pursuant to 18 USC 1 001. 

Signature and title of 

Authorized Official (Original 

Signature Required) 

Date 

Confidential 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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PMN2010P3 PMN P ~ge 3 

l:lm•' ~(::1:~!,.1 l:~l'lr!111l•J 

Section A SUBMITTER IDENTIFICATION 

Mark (X) the ·'c..;onnaential" bl))( next tQ__§r1y_ subsection you claim as w•"•ucntial 

1a. Person Submittin J Notice.(in O,S.) ·:,· .. ·.·· ..••••. ' ;q· ..... ·:, .. ·.· .. : :. : Connuemla• 

Name of Authorized Official (first) XXX (last) XXX 

Position XXX 

Company XXX [X] 

Mailing Address (number & street) XXX 

City XXX I State I Postal Code XXX 

email XXX 

b. Agent (.ifApplicat le) ·.:·.·· · .. . .!':· ··.· /". ·' . , .. :· .·.:\ ... •: ............... /J.:. liOn IIUt::rltial .· 

Name of Authorized Official (first) XXX (last) XXX 

Position XXX 

Company XXX [X] 

Mailing Address (number & street) XXX 

City XXX I State I Postal Code XXX 

e-mail XXX ~~~~~~~~~ea code) XXX 

c. -Joint Submitter (ifapplicable) .·.·. ·,··.·· .. · ::·.·····. .. I \Confiut::lllli::ll 

If you are submitting this notice as part of a joint submission, mark (X) I [ J 

Name of Authorized Official (first) (last) 

Position 

Company D 

Mailing Address (number & street) 

City I State I Postal Code 

e-mail Telephone 

(include area code) 

T. Technical Contact (in U.S;) } . /:: . ·.· ... · .· .. , :, ... ;:.:.:~ .... · . :·•1>.· ... 'iii'' ••;,;:;r , d6i\fiuer•\ii;li 

Name of Authorized Official (first)xxx (last) XXX 

Position XXX 

Company XXX [X] 

Mailing Address (number & street) XXX 

City XXX I State I Postal Code XXX 

e-mail XXX ~~~~~~Z~~ea code) XXX 

If you have had a prenotice communication (PC) concerning XXX Mark (X) if none Cunfiut::ntial 

3. this notice and EPA assigned a PC Number to the notice, D [X] enter the number. 

If you previously submitted an "'""'"'fJuu•• lpplication for the . Mark (X) ifnorie. Confidential 

chemical substance covered by this notice, enter the 

4. exemption number assigned by EPA. If you previously 

submitted a PMN for this substance enter the PMN number [&] D 

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

If you have submitted a notice of Bona fide intent to ····· .. Mark (X) if none ·.Cu,;fil,,.,,;ti,al 

5. manufacture or import for the chemical substance covered 

by this notice, enter the notice number assigned by EPA. [&] D 

6. ......... ·Type of" ~=· · . .:..•Mark (X) : r:i:.;,;.,:,: '<.,.,. .....•. ,,,:.: . ·.i :; : .;.., .. , ... . 

D D . Manufacture Only I> Import Only 

1. [X] lr· 3 Both 

Binding Option D .:. Binding Option D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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(for either Item 1 or 2), mark (X) the box at the right. 

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 

D 

Class 2 

D 

CBI 

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

substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name orCA ~ Preferred N based current CA i I and 

XXX 

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

d. 

e. 

See Attachment 005 (unmodified structure sanitized. pdf) 

111111111111111111111111111111111111111111111111111111111111111111111111111 

511 00000545/S 

Enter Attachment filename for Part I, Section B, 1. e. unmodified structure sanitized.pdf 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 4 PtO., ~l..fs-
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PMN2010P4A PMN Page 4a 

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 composition and the typical composition (where appropriate). 

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

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (1) I e. (2) Describe the nature of the reaction or process. 

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (2) I PMN process description text sanitized.pdf 

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

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (3) I NCS1 elemental analysis sanitized.pdf 

Confidential 

D 

D 

D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 5 

"''"'. ,,, 

I 
lllllllllllllllllllllllllllllllllllllllllllllllllllllll 

PMN2010P5 

i num 

Indicate maximum weight percent of low molecula 

below 500 and below 1 ,000 absolute molecular 

SANITIZED SUBMISSION 

Describe the methods of measurement or the basis for your estimates: 

GPC D Other (Specify Below) D 

Specify Other: 

(i) lowest number average molecular 

weight: 

(ii) maximum weight % below 500 molecular 

weight: 

Enter Attachment filename for Part I, Section B, 2. a. 

(iii) maximum weight% below 1000 molecular 

weight: 

must separate co i 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) - 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 

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. 

- Mark this column if 

Monomer or other reactant specific chemical name 

(1) 

Mark (X) this box if the data continues on the next page. 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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PMN2010P5A PMN Page Sa c. Please· identify which method you used to develop or obtain the specified chemical identity information reported in this notice 

(check one). 

Method 1 (CAS Inventory Expert Service 

- a copy of the identification report obtained 

from CAS Inventory Expert Service must be 

submitted as an attachment to this notice) 

Enter Attachment filename for Part I, Section B, 2. c. 

D IES Order 

Number 

Method 2 

(other source) D 

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. 

Enter Attachment filename for Part I, Section B, 2. e. I 

CBI 

[ J 

D 

D 

D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 7 

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PMN2010P6 PMN Page 6 

Part I GENERAL INFORMATION Continued 

Section B --CHEMICAL IDENTITY INFORMATION-- Continued 

3

' ~~~)ri~iesldentify each i.mpurity 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) - Estim~ the ma)(j111_um weigblio of each impurity. If there are u ·•'"· impurities, ·••· their total weight %. 

CAS Registry Maximum ConfiImpurity (a) Number % dential (a) (b) 

Mark (X) this box if the til data continues on the next page. D 

Enter Attachment filename for Part I, Section B, 3. I D 

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

D 

Enter Attachment filename for Part I, Section B, 4. I [ J 

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

XXX [X] 

Enter Attachment filename for Part I, Section B, 5. I NCS Tradename sterilized.pdf [ J 

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. 

modified lithium iron phosphate 

Enter Attachment filename for Part I, Section B, 6. I li!!Rl?'W;:,· ~rn'liliiJCf& 

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 (1) CAS Regi~!~ Number Conti-

(2). dential 

XXX XXX X 

XXX XXX X 

XXX XXX X 

XXX XXX X 

Mark (X) this box if the data continues on the next page. lliJ iiliilliiii:::i:l:;:;,,;:; JT~ 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 8 
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PMN2010P6-1 PMN Page 6 (1) 

Part I -- GENERAL INFORMATION -- Continued 

Section 8 --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 weiqht % of each impurity. If there are unidentified imjl_urities, estimate their total weight %. 

CAS Registry Maximum Confi- Impurity (a) Number Percent% dential _(~_ (b) 

Mark (X) this box if the data continues on the next page. D ~ Enter Attachment filename for Part I, Section B, 3. I D 

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

D 

Enter Attachment filename for Part I, Section B, 4. I D 

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

D 

Enter Attachment filename for Part I, Section B, 5. I D 

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. 

Enter Attachment filename for Part I, Section B, 6. I 1!: ;g;iUr·nrrrr!\!Rl!i 

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 (1) CAS Registry Number Confi-

(2f dential 

XXX XXX X 

Mark (X) this box if the data continues on the next page. D ~~~ ,. •. ! .. 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 9 
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I>< 

Complete either item1 (Class 1 or 2 substances) dr2 (Polymers) C!S 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. Identify 

the na and address of that 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 Class 2 

D D 

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

substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name orCA 

Preferred Name must and ""''"0 "'"'"" 

XXX 

Method 1 (CAS Inventory Expert Service -a copy of the 

Identification report obtained from the CAS Inventory Expert 

Enter Attachment filename for Part I, Section B, 1. c. 

d. 

e. 

See Attachment 005 (unmodified structure sanitized.pdf) 

Enter Attachment filename for Part I, Section B, 1. e. 

152943 

CAS name NCS2 sanitized. 

structure diagram. For a class 2 

can be known if one can be 

unmodified structure sanitized.pdf 

CBI 

D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 10 Pto, ~Lf(p 
SANITIZED SUBMISSION 

PMN2010P4AX1 PMN P age 4 a 

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 composition and the typical composition (where appropriate). Confidential 

e. (1) List the immediate precursor substance names with their respective CAS Registry Numbers. [X] 

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (1) I D e. (2) Describe the nature of the reaction or process. [X] 

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (2) I D e. (3) Indicate the range of composition and the typical composition (where appropriate). [X] 

XXX 

Enter Attachment filename for Part I, Section B, 1. e. (3) I NCS2 elemental analysis sanitized.pdf D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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PMN201 OP5X1 PMN P age 5 

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. D Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) 

below 500 and below 1 ,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: 

D I Other (Specify Below) D ... ,. 

~ . 

GPC :n••• 

Specify Other: 

(i) lowest number average molecular (ii) maximum weight % below 500 molecular (iii) maximum weight % below 1000 molecular 

weight: weight: weight: 

Enter Attachment filename for Part I, Section B, 2. a. I D 

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) - 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 

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 specific chemical name Typical Include in Max 

CBI composition identity CBI residual CBI (1) (2) (3) (4) (5) (6) (7) 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

Mark (X) this box if the data continues on the next page. D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 12 
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PMN2010P5AX1 PMN Page Sa 

Please identify which method you used to develop or obtain the :>IJ"'-''""u chemical identity i1 •v• "~"v' 

(check one). 

reported in this notice 

Method 2 

Method 1 (CAS Inventory Expert Service 

- a copy of the identification report obtained 

from CAS Inventory Expert Service must be 

submitted as an attachment to this notice) 

D IES Order 

Number (other source) D 

Enter Attachment filename for Part I, Section B, 2. c. 

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

I 

CBI 

[ J 

D 

";~·\: ... · ..... ~ 

CAS Registry Number (if a number already exists for the substance) lit1}'>::::1;,,1HHI"i>l'1'1''*' 

e. Provi.de a correct representative or partial chemical structure diagram, as ·Complete as can be known, if one can be , --~"'v' oav•y D 

ascertained. 

Enter Attachment filename for Part I, Section B, 2. e. I D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 13 
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PM N 2010P6 X 1 PMNP a_g_e 6 

_p~ ~§_RAL INFO_BM_A IIQ!+J ~ntiD_!Ie~ 

Section B --CHEMICAL IDENTITY INFORMATION-- Continued 

3

. (~)r~tiesldentify 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 unidentified impurities, estimate their total weight%. 

CAS Registry Maximum ConfiImpurity (a) Number Percent% dential (a) (b) 

Mark (X) this box if the data continues on the next page. D 

Enter Attachment filename for Part I, Section B, 3. I D 

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

D 

Enter Attachment filename for Part I, Section B, 4. I [ ] 

5. Trade identification- List trade names for the new chemical substance identified in subsection 1 or 2. 

XXX [R] 

Enter Attachment filename for Part I, Section B, 5. I [ J 

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. 

modified lithium iron phosphate 

7. Byproducts 

Enter 

-

Attachment 

Describe any 

filename 

byproducts 

for Part 

resulting 

I, Section 

from 

B, 

the 

6. 

manufacture, processing, 

I 

use, or disposal of the new chemical substance. Provide 

~ the 

CAS Registry Number if available. 

Byproduct (1) CAS Regi~~; Number ;e n~f~1 XXX XXX X 

XXX XXX X 

XXX XXX X 

XXX XXX X 

Mark 

EPA 

(X) 

FORM 

this box 

7710-25 

if the data 

(Rev. 

continues 

6-09) 

on the next page. 

Replaces previous 

[X] 

editions of EPA Form 

~ 7710-25 

Page 14 
111111111111111111111111111111111111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN201 OP6X1-1 PMN~e 6 (1) 

Part I GENERAL INFORMATION Continued 

Section 8 -·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 weighf% of eact1JrT1purity.l~re are ·'"'· impuritie§, estimate their total wei~ht %. 

CAS Registry Maximum ContiImpurity (a) Number Percent% dential (a) (b) 

Mark (X) this box if the data continues on the next page. D 

Enter Attachment filename for Part I, Section B, 3. I D 

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

D 

Enter Attachment filename for Part I, Section B, 4. I [ J 

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

D 

Enter Attachment filename for Part I, Section B, 5. I [ J 

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. 

Enter Attachment filename for Part I, Section B, 6. I r,r:, 

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 (1) CAS Regis!ry Number Conti-

(2) dential 

XXX XXX X 

Mark 

EPA 

(X) 

FORM 

this box 

7710-25 

if the data 

(Rev. 

continues 

6-09) 

on the next page. 

Replaces previous 

[ J 

editions of EPA Form 

~ 7710-25 

Page 15 
lllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P7 PMN P age 7 

Part I-- GENERAL INFORMATION-- Continued 

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

The information on this page refers to consolidated chemical number(s): []1 lli]2 [ J 3 04 Os 06 

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

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

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

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

volume and mark (x) in the binding box. If granted, you are bound to this volume. 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confidential Binding Option 

(100% new chemical substance basis) (100% new chemical substance basis) Mark (X) 

XXX XXX [X] 0 

Enter Attachment filename for Part I, Section C, 1. I production estimate explanation sanitized.pdf CBI 0 

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 infdrmation. Mark (X) the "Confidential" Box next to any item you claim as 

confidential. 

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

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

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

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

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

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

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

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

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

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

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

Category of use (1) Binding Prod %in % of substance expected per use 

(by function and application i.e. a dispersive dye for CBI Option uction CBI Form- CBI (8) CBI 

finishing polyester fibers) Mark (X) % ulation Site- Con- Industrial Com- Binding 

(2) (3) (4) (5) (6) (7) limited sumer* mercia I Option (9) 

XXX X XXX X XXX X XXX XXX XXX XXX X 

• 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. 

Mark (X) this box if the data continues on the next page. 0 

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

description Read the Instruction Manual for examples of generic use descriptions. 

battery electrode component, contained use 

Enter Attachment filename for Part I, Section C, 2. b. I CBI 0 

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 Binding Option 

regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part Ill Mark (X) 

hazard information you include. 

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

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 16 

--·- .. --------~-~-.. -,~ 
lllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

Section A --INDU~tRI~LSIJES 

Complete section A for each type of manufacture, processing, or use operation the new 

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 

XXX 

manual 

of the site at which the ration will occur. 

Name XXX 

Site address (number and 

street) XXX 

City XXX County XXX 

State ZIP code XXX 

Mark (X) this box if the data continues on the next page. 

b. Type--

Mark (X) Manufacturing 0 Processing D Use D 

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

1. Batch 

2. Continuous 

d. Process description 

Maximum kg/batch 

(100% new chemical Hours/batch 

Hours/day 

XXX 

Mark (X) to indicate your ingness to 

have your process description binding. 

~ 

(1) Diagram the major unit operation steps and chemical conversions. Include m storage and 

pails, 55 gallon drum, rail car, tank truck, etc.). 

Batches/year 

Days/year 

XXX 

Confidential 

D 

(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 

releasin media at second 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 17 
llllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P8A PMN P age 8 a 

Confidential 

Diagram of the major unit operation steps. D 

See Attachment 010 (exposure flow 9-8-10 sanitized.pdf) 

Enter Attachment filename for Part II, Section A, 1. d. I exposure flow 9-8-10 sanitized.pdf D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 18 
111111111111111111111111111 II II SANITIZED SUBMISSION 

PMN2010P8-1 Continuation Sheet 

ml Field I Part II Section A 1 a (Additional Sites) ' ' .. 

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

Name 

XXX 

Site address 

(number and street) XXX [X] 

City XXX County XXX 

State ZIP code XXX 

Name XXX 

Site address 

(number and street) XXX [&] 

City XXX County XXX 

State ZIP code XXX 

Name 

XXX 

Site address 

(number and street) XXX [X] 

City XXX County XXX 

State ZIP code XXX 

Name XXX 

Site address 

(number and street) XXX [&] 

City XXX County XXX 

State ZIP code XXX 

Name XXX 

Site address 

(number and street) XXX [&] 

City XXX County XXX 

State ZIP code XXX 

Name XXX 

Site address 

(number and street) XXX [g] 

City XXX County XXX 

State ZIP code XXX 

Name XXX 

Site address 

(number and street) XXX [29 

City XXX County XXX 

State ZIP code XXX 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 19 
lllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P8-2 Continuation Sheet 

ml Field I Part II, Section A, 1.a. (Additional Sites) 

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

Name XXX 

Site address 

(number and street) XXX [X] 

City XXX County XXX 

State ZIP code XXX 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

Name 

Si.te address D (number and street) 

City County 

State ZIP code 

Name 

Site address D (number and street) 

City County 

State ZIP code 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

Name 

Site address 

(number and street) D 

City County 

State ZIP code 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 20 
1111111111111111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2010P9 PMN P age 9 

Part 11-- HUMAN EXPOSURE AND EN~IRONMENTAL~EC.I;~SE •-.. Qor:itintied ; .·<:·· 

Section A-- INDUSTRIAL SITES CONTROLLED BYTHE SUBMITIER •• Contin~ed .:. . 

The information on pages 9 and 9a refer to consolidated chemical number(s): 01 ~2 03 04 Os Os 

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

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

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

substance. 

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

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

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

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

part of a mixture) at the time of exposure. 

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

(1 0) 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). 

Physical 

.. ·:.\ ' ····;··· 

Worker activity Protective Equipment/ Bindillg: form(s) Binding·, ;,.,.#of !, >i:M~)(imumPur~tiilrl ·· •·" ; CBI (i.e., bag dumping, filling CBI Optiqn . .; &%new . · Option ,fBI, Workers "CBI '-"'- ,.,: .. ·) 

drums) Engineering Controls Mark;(X) . ~~[~)[~li, '' Exposed ,::,'J:;',;::'i:c:' !:lj;H(li/Day o~ys/Yr'' ·(12) (1) (2) (3) ... < ''(4) substanc~ "(?). I· .. (8):· (9)>> ' (5) <'''''"'"'! I·"· ·•·· (10). :' '' !.(11) 

see attachments see attachments see 

attachments 

Mark (X) this box if the data continues on the next page. [ J 

Enter Attachment filename for Part II, Section A on the bottom of page 9a. Worker activity table sanitized.pdf 0 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 21 
·111111111111111111111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2010P9A PMN P age 9 a 

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 1d(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 Medium.of release · .. ·. ,Control technqlogy and eff.iciehcy(youi~nay wish to 

Number Substance Released CBI e.g, Stack air ,./ · , optionally attach ~fficiency ~~ta) .. .. CBI 

Binding 

(1) (2a) (2b) (3) .·• (4) 

.•.: •••••• 

(Sa) Mark'• •••• 1 :··:.· (5b) .·· ... (6) 

; ........ · ..·:::txl·· . I··• ····· XXX XXX XXX X XXX XXX X 

XXX XXX XXX X XXX XXX X 

XXX XXX XXX X XXX XXX X 

Mark (X) this box if the data continues on the next page. D 

(7j_ Mark (X) the destination(s of releases to water. NPDES# CBI 

D POTW--provide D name(s) 

D Navigable waterway- D -provide name(s) 

D Other--Specify D 

Enter Attachment filename for Part II, Section A. I Worker activity table sanitized.pdf ~ 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 22 
11111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2010P1o PMN Page 10 

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

·• The information on pages 10 and 10a refer to consolidated chemical number(s): [X] 1 [2$] 2 D 3 D 4 D 5 D 6 

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 8 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 (a). Operation Description-- To claim information in this section as confidential, bracket (e.g.{}) 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) -- Either in the diagram or in the text field 1 (b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new 

chemical substance basis), and entry point 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): 

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

Enter Attachment filename for Part II, Section B on the bottom of page 1 Oa. I D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 23 
lllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P10A PMN Page 10a 

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. 

(1 0) -- 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 any of the proceeding entries are confidential business information (CBI). 

Letter #of , """ ,',', , , <> ''"' :" , ,, '• 

%new 1 ' <'"loin 

of Workers CBI Duration of CBI Protective Equip./Engineeririg Control,s/Physical CBI 

Activity Exposed Exposure Form 

,;>',;,' 

substance Formulation ,' 

(1) (2) (3) (4a) (4b) (5) (6) ', (6) El (8) 

Release Amount of New Substance R,eleased CBl',,'',,' '''"' ,,,,,; ',, ,' , , ,,~. ,,'' ,,",;t;;j, • :" l•"c"BI 

Number > ~edia of Rei~~~~ ,&Contrbt:%rv''""'';,.,;:> ;,' 

(9) (10a) (10b) ··: (11) ,;;' 

' , ''" > (12) , ,' 

,,, ' ,, (13) 

(14) Byproducts: 

Mark (X) this 

I 

box if the data continues on the next page. 

(15) 

[ 

CBI 

J ~ 

D 

Enter Attachment filename for Part II, Section B. [ J 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 24 
llllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P11 PMN Page 11 

OPTIONAL POLLUTION PREVENTION INFORMATION 

" To claim information in the following section as confidential, bracket (e.g.{}) 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, and/or raw materials substitution. 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. Quantitative or qualitative 

descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing 

regulatory requirements. 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 media (e.g., air to water) or nonenvironmental areas (e.g., occupational or consumer exposure). To the 

extent known, information about the technology being replaced will assist EPA in its relative risk determination. In addition, information on the 

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

Describe the expected net benefits, such as 

(1) an overall reduction in risk to human health or the environment; 

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

(3) a reduction in the use of hazardous starting materials, reagents, or feedstocks; 

( 4) a reduction in potential toxicity, human exposure and/or environmental release; or 

(5) 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. 

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. 

Enter Attachment filename for Pollution Prevention Page 11. I environmental benefit sanitized.pdf D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 25 
llllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION . PMN2010P12 PMNP age 12 

Part Ill --LIST OF ATTACHMENTS 

c Attach continuation sheets for sections of the form, 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 Number of Pages column 

below, enter the inclusive page numbers of each attachment for paper submissions or enter the total number of pages for each 

attachment for electronic submissions. Electronic attachments can be identified by filename. 

Mark (X) the "Confidential" box next to any attachment name or filename 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 any attachment in which you claim information as confidential. 

Number Associated 

# Attachment Name Attachment Filename of Pages PMN Section CBI 

Number 

001 CAS name 1 Pt.l, Sec.B, 1 c. 

002 elemental analysis 1 Pt.l, Sec. B, 1 e(3 ). 

003 CAS name 1 Pt.l, Sec.B, 1c. (Chern 2) 

004 elemental analysis 1 Pt.l, Sec.B, 1e(3). (Chern 2) 

005 structure 1 Pt.l, Sec.B, 1 e. 1 Pt.l, Sec.B, 1 e. 

(Chern 2) 

006 production estimate 1 Pt.l, Sec.C, 1. 

007 environmental benefit 4 Pollution Prevention 

008 worker info 2 Pt.2, Sec.A, End 

009 process description 2 Pt.l, Sec.B, 1 e(2). 

010 exposure info 2 Pt.2, Sec.A, 1d. 

011 MSDS 3 

012 trade name 5 Pt.l, Sec.B, 5. 

013 physical data 1 

014 physical data 1 

015 physical data 1 

Mark (X) this box if the data continues on the next page. D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

Page 26 
llllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN2010P13 PMN P age 13 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

" The information on this page refers to chemical number(s): l AJ 1 02 03 04 Os Os 

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 value of the property, the units in which the property is measured (as necessary), and whether or not the 

property is claimed as confidential. Give the attachment number (found on page 12) in column (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 the review and ensure that confidential information is properly protected. You should submit this worksheet as a 

supplement to your submission of test data. This worksheet is not a substitute for submission of test data. 

Property .'~ :: : , 

<" 

··I~~ U Nu e (a) .•.,.· ... · ··'· .· I• ·•· .· E) • 

Physical state of neat substance 0 . _rsj 0 q~ )_:.1~ 0 ~ X 

Vapor Pressure @ XXX ·c 0 XXX Torr X 

Temperature 

D XXX X 

Density/relative density g/cm3 

Solubility 

@ Temperature ·c 0 g/L 

Solvent l;,':li . ;:;:;;1 

Solubility in Water @ XXX 0 XXX X 

Temperature 

·c g/L 

Melting Temperature 0 XXX 

•c 

X 

Boiling I Sublimation XXX 0 XXX X 

temperature @ 

Torr ·c 

0 XXX X Spectra XXX 

0 XXX X Dissociation constant 

0 XXX X Octanol/ water partition coefficient 

Henry's Law constant 0 XXX X 

0 XXX X Volatilization from water 

Volatilization from soil 0 XXX X 

pH@ concentration 

XXX 0 XXX X 

0 XXX X Flammability 

0 XXX X Explodability 

Adsorption I Coefficient 0 

Particle Size Distribution ~ X Measured 

Other- Specify XXX 0 XXX 

X 

Page 27 
llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll SANITIZED SUBMISSION 

PMN201 OP13X1 PMN P age 13 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

c The information on this page refers to chemical number(s): L11 [1_2 03 04 Os Os 

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 value of the property, the units in which the property is measured (as necessary), and whether or not the 

property is claimed as confidential. Give the attachment number (found on page 12) in column (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 the review and ensure that confidential information is properly protected. You should submit this worksheet as a 

supplement to your submission of test data. This worksheet is not a substitute for submission of test data. 

I Uni~ I Mark X if Attachment ,., ... ···· \'. 

ME!a~i.lred :.· .CB! Property Number 'Value, or Estimate Ma\k(X) (a) Pro~ided (b) .· . .,:• (?) •• ;·· ..·. ··' I •• (M C?i·E) ,· .. (d)" ... 

0 .... (~glid) ''I '(liq~id);;;:;;i+····~Jg~ Physical state of neat substance ::ii'\'>::,/1~ 

X 0 0 0 

Vapor Pressure @ XXX 

I •c 0 XXX Torr X 

Temperature 

0 XXX X 

Density/relative density g/cm3 

Solubility 

@Temperature ·c 0 g/L 

Solvent 

Solubility in Water @ XXX 0 XXX X 

Temperature 

·c g/L 

0 XXX X 

Melting Temperature •c 

Boiling I Sublimation XXX 

I 0 XXX X 

temperature@ Torr ·c 

0 XXX X Spectra XXX 

0 XXX X Dissociation constant 

0 XXX 

Octanoll X water partition coefficient 

0 XXX 

Henry's X Law constant 

0 XXX 

Volatilization X from water 

D XXX 

Volatilization X from soil 

pH@ concentration 

XXX 0 XXX X 

0 XXX 

Flammability X 

Explodability 0 XXX X 

Adsorption I Coefficient 0 

Particle Size Distribution 0 X Measured 

Other - Specify XXX 0 XXX 

X 

Page 28 
--~--- .. -~~~ 

ATTACHMENT HEADER SHEET 

Attachment Number 001 

Attachment Name 

CAS name 

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4D 
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environmental benefit 

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POLLUTION PREVENTION OF 

material reduces pollution in a number of ways: 

1. Product substitution 

Rather than using metal oxide cathode materials, such as cobalt oxide or nickel-based 

oxides, 

and has a lower impact on the environment than cobalt or nickel-based cathodes, which 

are currently used in the lithium ion battery industry. 

2. Enhanced product life or durability 

the cycle life of a typical lithium ion 

battery cathode materials. For example, a typical lithium cobalt oxide cell, such as that 

used for a cell phone or laptop, might be expected to last 500 cycles. 

or more cycles for the same charging/discharging profile. 

Longer cycle life means that a smaller battery or fewer cells can be used and meet the 

same life requirement. This reduces pollution by using less materials and energy in the 

production of the battery and results in less waste disposal because the cell lasts longer. 

3. Energy savings 

material saves energy, which in turn reduces pollution. The 

areas of greatest energy savings are in the transportation and grid areas. Additional 

information is provided below regarding the energy savings and life cycle emissions. 

EMISSIONS AND POLLUTION OVER ENTIRE LIFE CYCLE- PUBLISHED STUDIES IN TRANSPORTATION 

It is well-known that electric drive vehicles (HEV, PHEV, EV) lower tailpipe emissions. It is also 

true that these vehicles lower total life cycle emissions. Life cycle assessment (LCA) quantifies 

the environmental impacts of a product's manufacture, use, and end-of-life. One recent study 

from Carnegie Mellon University assessed life cycle GHG emissions from PHEVs, including 

energy use and GHG emissions from battery production. They analyzed how changes in the 

electricity mix, vehicle efficiencies, battery characteristics, and biofuel use affect the life cycle 

GHGs. These researchers found that PHEVs reduce GHG emissions by 32% compared to 

conventional vehicles. They also estimated that GHGs associated with lithium-ion battery 

materials and production account for 2-5% of life cycle emissions from PHEVs. Even with the 

average U.S. carbon intensity for electricity generation, PHEVs have a lower life cycle GHG than 

HEVs. However, with cleaner electricity generation, the GHG savings become greater. The 

three figures from the paper are reproduced here.1 

1 Samaras, C. and Mesterling, K: "Life Cycle Assessment of Greenhouse Gas Emissions from Plug-in Hybrid Vehicles: Implications 

for Policy" Environ. Sci. Techno/. 2008,42, 3170-3176. 

42 
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300 I 250 

e 

.... ""' 200 

' 

8 15() 

.E! 

.. 

~ 10() 

G 

.91 

~ 50 

~ -' () 

cv HEV f'H€\130 f'HEV 610 PHE.V 00 

FIGURE 2 lif$ cycle GHG emissions (g COz-eq/km) of conven· 

tional vehicles (CVst hybrid electric vehicles (HEVsl. and plug-in 

hybrids (PHEVs) widl all·electric ranges of :11, ro, or 00 km. Life cycle 

GHG intensity of electricity is 670 g COz-eqik:Wb (186 giMJ; U.S. 

average scenario). Uncertainty bars represent changes in total 

emh~sions under the carbon-intensive {950 g COz·llUJ/kWh) or 

low-carbon (:l.OO g C~Wit} electricity scenarios. 

3()0 

~ 200 

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300 

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0 200 400 600 BOO 1000 

l.lfe cyete electricity GHG Intensity [g CO:req/kWhJ 

RGURE ;3 Lite cycle GHG emissions from vehicles shown as a function ot the life cycle GHG intensity of electricity genera· 

tion. Electricity is used during production of the vehicles, and 

the slight slope of the CV and HEV lines reflect GHG intensity 

of electricity used during production. The chart indicates which 

generation options correspond to various GHG intensities to 

provide so01e insight into generation mixes. The low-carbon 

portfolio could cornprise nuclear, wind, coal with carbon 

catrtnre and sequestmtion, and other low•carbon electricity 

generation technologies (see Table S6). The vertical line at 

670 g C02-eq/kWh indicates the U.S. average life cycle GHG 

intensity. 

Current u.s. 

electricity mlK 

Low-carbon 

electricity 

Carllon.JflklnGivo 

electricity 

Current u.s. L.ow'""bon 

etectrtclty mix electrtclty 

GASOLINE E8S CEI.LUL.OSIC 

FIGURE 4 Life cycle GHG etnissions sensitivity of CVs, HEVs, and PHEVs with 30 and 00 all-electric km ranges und1n different fuel 

and electricity carhon intensities. Lite cycle carhon intensity of electricity assumed to be 670, ZOO, and 950 g C02·eq/kWh for U.S. 

average, low·corhon, and carbon·intensive scenarios, respectively. ·ess· is a li11uid fuel with 85% cellulosic ethanol {volume basis}, 

and the remainder gasoline. Life cycle carbon intensity of gasoline and E85 are 86 and 21 g CO:·eq/MJ, respectively. 

--~-~ -. .., ---.,.---~-~~--_,.,.,---~~--
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The graphs above can be used to estimate the environmental benefits of using lithium ion 

batteries in automotive applications. Clearly, the environmental benefits are greater when 

electricity comes from low-carbon sources, such as wind, solar, hydroelectric, and nuclear. 

Another study reported that the energy intensity of NiMH battery production is nearly double 

that of Li-ion per kWh of capacity.2 Thus, in comparison to the baseline NiMH battery 

technology currently being used in HEV, lithium ion batteries will have lower life cycle 

greenhouse gas emissions. 

ENERGY STORAGE FOR GRID APPLICATIONS 

also manufactures grid-scale energy storage systems which hybridize power plants to 

increase efficiency, improve grid stability and facilitate the seamless integration of renewable 

energy sources. The efficiency of existing fuel-burning plants can be improved, reducing the 

fuel used and resulting emissions. To date, · - - has delivered more than 20MW of grid energy 

storage systems to customers worldwide, making the company the largest producer of lithium 

ion batteries for ancillary services for the power grid. 

In addition, energy storage systems can be used to help mitigate the intermittency of 

renewable, such as wind and solar. Thus, technology can reduce emissions, by 

increasing the use of clean technologies and reducing the use of fuel-burning generators. 

2 Rydh, C. J.; Sanden, B. A. Energy analysis of batteries in photovoltaic systems. Part 1: Performance and energy requirements. 

Energy Convers. Manage. 2005, 46 (11-12), 1957-1979. 

44 
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I 

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-

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Controls %New Substance 

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Exposure Worker Activity That May Result in 

ID Exposure 

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MATERIAL SAFETY DATA SHEET 

Section 1 - Product Identification 

Product N arne : 

Chemical Formula: 

CAS Number: 

Supplier: 

Section 2 - Composition/Information on Ingredients 

Ingredients : 

Section 3 - Hazards Identification 

Complete Data not yet available 

May be harmful if swallowed or inhaled. May cause irritation to skin, eyes and respiratory tract. 

Section 4 - First -Aid Measures 

INHALATION Move to fresh air. If breathing becomes difficult 

Seek medical attention. 

Induce vomiting immediately as directed by 

INGESTION medical personnel. 

Seek medical attention. 

Flush with soap and water for 15 minutes. 

SKIN CONTACT Remove contaminated shoes and clothing. 

Wash before reuse. 

Seek medical attention if irritation develops: 

Immediately flush eyes with plenty of water 

EYE CONTACT for at least 15 minutes, lifting upper and lower 

eyelids occasionally. 

Seek medical attention if irritation persists. 

Page 1 of3 
'' \..,VlVlrJ-\.1'11 ~J-\.l'llllLDl.J '' 

MATERIAL SAFETY DATA SHEET 

Section 5- Fire Fighting Measures 

• Extinguishing media : 

Water spray, carbon dioxide, dry chemical powder or appropriate foam. 

• Special fire fighting procedures : 

Wear self-contained breathing apparatus and protective clothing to prevent contact with skin and eyes. 

Use extinguishing media appropriate to surrounding fire conditions. 

Section 6 - Accidental Realease Measures 

• Place in appropriate container; 

• Wash spill site with soap solution; 

• Flush spill area with copious amount of water. 

Section 7 - Handling and Storage 

Store in a dry location at normal room temperature 

Section 8 - Exposure Controls/Personal Protection 

• Wear suitable gloves; 

• Wear chemical safety goggles; 

• Keep container tightly closed; 

• Use only in well ventilated areas. 

Section 9 - Physical and Chemical Properties 

APPEARANCE 

ODOR 

SOLUBILITY 

SPECIFIC GRAVITY 

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.,..,. CUlVlYAN Y :SANlllL.I::UJ .,..,. 

MATERIAL SAFETY DATA SHEET 

Section 10- Stability and Reactivity 

Stability 

Hazardous Decomposition Products 

Hazardous Polymerisation 

Incompatibilities 

Section 11 -Toxicological Information 

See SECTION 3 

The toxicological properties have not been thoroughly investigated. 

Section 12 - Ecological Information 

Data not yet available 

Section 13 - Disposal Considerations 

• Contact a licensed professional waste disposal service to dispose of this material. 

• Observe all federal, state and local environmental regulations. 

Section 14 -Transport Information 

Not regulated. 

Section 15 - Regulatory Information 

Data not yet available 

Section 16- Other information 

THE ABOVE INFORMATION IS BELIEVED TO BE CORRECT BUT DOES NOT PURPORT TO BE 

ALL INCLUSIVE AND SHALL BE USED ONLY AS A GUIDE. 

SHALL NOT BE HELD LIABLE FOR ANY DAMAGE RESULTING 

FROM HANDLING OR FROM CONTACT WITH THE ABOVE PRODUCT. 

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