. ' e P. 1

Foist Approved. O.2 L D. No. ZD&m12 ApprovalFspus 1G.31%.

U. S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE wx

E PA

PREMANUFACTURE °i""mm° "

NOTICE

FOR NEW CHEMICAL SUBSTANCES

DOCUMENT CONTROL OFFICER Sanitized OFFICE OF POLLUTION PREVENTION Company

AND TOXIC SUBSTANCES, 7407

U.S. EP.A.401 M STREET, SW

WASHINGTON, D.C.20460

Enter the total number of

in the Premanufacture Notice --

pages -~~ ~

-&

W

431

W I T I Z GENERAL INSTRUCTIONS TS- M11 O 11tJ • You mast provide aU rfoeaufloa eaqaested fa Nis form to

not have actual data

the eaRat that it is ltaows to or rsssoaabfy ascertainable by you. Maim fsssoaabfe sstlmats ifYOU do .

•

Substances Control

Before you complete thin

Ad

fota, you should mad tre'Iastncifoas Manual for ptsasafaeaw Notification" (the Instructions Manual is available fromthe Toxic

• If a

(TSCA) Information Service by calling 202- 551-140f,, or faring 20 2•6S4 56M

Resember,

user fee has bees remitted for tbis notice (40 CPR 700.45). indicate in the', -- aboee the TS-mw fss identification aober Pow have Staeeatsd.

P

your userfee ID number most also appear an your corresponding fee remittance, which is no to EPA, HQ Aetaaatlai Opaatro Branch RPd-ZK). .O. M0099M, PNtabwxiy PA 1 32S1-400, Atta. TSCA User Fee.

Part I - CENEILAL INFORMATION TEST DATA AND OTHER DATA

You mast providethe currently caned Chemical Abstracts (CA) Name of the You am required in submit allfastdata in you passessra or control sew chemical substance, ewa if you claim the Identity as osafideatiat. you may and to providea description of all otherdata known toor seasonably authorize another Pasco to submit chemical ideality iafoematloa for you, but aont+faabM by Yom.If tieas data can ntWd to the, ►oaltfa an d

your submission will so be omplett aid the review will sot begin until EPA ritosrsatal eefbs ofthe swEaetito, ptoasdaE, dyldbnlra receives this iatoematloa. A Istlsr in support ofyour submission should In mmmesee, se, ar dlspossl ofthe new chemical sabstsao. Sta.daad mfeteaoe your TS case fee ideatifiotloa number. You mum submit an original Ubsntate dfatrrway be wbmif6sd fordata in the open scientific

and twoespiesofthis notice including all two data . If you claimed any Wsralisra

iaforaatioa as confidential, a single saaitirad copy mast also be submitted f--- dmAL&ML

. mat JU You should

dtrdf idssifltP Mrbst~ tsst aata r aa Ne abstsaQ er oa a. aaslo5. Aiso, Pan II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE tYe dt~inl asxposrioa oE fletsrd ssaia[ sbsdd be dtaw dmised.

am examples efIM dataand other data. Datasboddbe

If then anseveral manufacture, ptoonsisj, or owopeotloas to be described is wbmftls/ amsdlaE to the mqdssmsab of STJt). 30 ofthePts:aaafsftte Put 11, sections A aad 1 of this codes, nptods or the soQfsss as needed. NoNBatlw Lis (!0 QI<Psst 71 01.

Put III - LISTOF ATTACH[ME NTS Test Data (deek telortr aq badsdd ia tiis aotloe)

Attack additional sbeetr if there is sot enough space to answers question fully. ❑

Label each continuation skeet with themneapoadr5 seRioa handles. In Part • Eav ihoameatal fate data Ys • Other data Ys III, list these attachments, any test data or otbe data and my optic "

Information included in the aotios. • Hea4b eHeerdata Ys ~~

OPTIONAL INFORMATION • Environmental offects data ~ Yes SboauN~" relationship

You may include any Information that you want EPA to consider is evaluating • Pbrsiol/pemiofProperties •® Ys Test data act in the romantics the now substance. On page 11 of this foem, spew has been provided for yo u to or central ofthe sabstitter describe pollution pweeatioa sad recycling iafosafioa you may have regardin g

the now ssbstastas. • physical an~ ~~ d properties~~is~

so the ~pap

So-called "binding* been ma Included throughout this foam for you to

yo u r willingness to be bound tocertain state meab iadieafe TYPE OF NOTICE (Check Oaly Os 4 4. .; yea make to this aoticR, such

as me, production volume, protective eqaipmeat . . . This optra is iateaded be

educe delays that routinely accompany the development

Significant New Use Rules. Except in the rase of of osssst ordeus or PMN ~tssaafa~ats Not1aN

77

binding on the

► EA, LVE, LOREXI

sabmitter when certain Information provided in such notification

when the Agency approves the exemption application

exemption applications (such as t 7

is Q, ❑ TEAbgpuTE PMN(submitled in sequence withfinal product ,

.

checkinga binding box to this notice does not by Itself prohibit the sabmitfer ~)

truce later deviating from the information (eiot:pt chemical ideatfq) reported in

the fotm 13 SNUN (Significant Now Unit Netlos )

❑ 11Y EA (Tat Madetla` Eaatoptlaa Application)

CONFIDENTIALITY CLAIMS

❑ LVE (Low Violence Exemptral0 10 CPi ?ALSO (dhtD

You may claim aay Information in this notice as osaf►dmtial. To assstta claim CJ

as the form, mark 00 The confidential box sect to the isforsutloa that you claim ❑ Loan Mew ReksoalLow, Exposure Exemption) 0 721.50(cll2)

ax confidential. To assert a claim in as attachment, drde or bracket the a

lafotmatba you claim as confidential. 11 va, -4-1- LVE Modffiratisa ❑ LOaE7( Modification,

attaG~{ti►. For additional instructions an claiming iafoematioa as mafideatial, read The Instructions Mescal. IS TEIIS A CONSOLIDATEa PMNT [:] Ys

®Mark (X) if any faformstioa I . this solicit is claimed as confidential #of

(Pteaottoe Comwasirattom 1 n qaicsd, eater 1 on page ])

EPA FORM 771 0-75 (Rev. 5-95)

Z-

~7 V ~~ / Replaces previous editions of EPA Form T11 d25 .
- • p.2

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

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

comments regarding the burden estimate or any other aspect of this collec tion of information, including suggestions for reducing this burden, to

Chief, Info rmation Policy Branch, PM-223, U .S . Environmental Pro tection Agency, 40 1 M .SL,S .W., Washington, D.C. 20460; and to the Office of

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

CERTIFICATION

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

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

purpose, other than in small quantities solely for research and development, the substance identified in Part 1, Section B.

2 . All information provided in this notice is complete and truthful as of the date of submission .

3 . I am submi tting 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 Ce rtification Statements:

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement

that applies:

❑ The Company named in Part I, Section A has remitt ed the fee of $2500 specified in 40 CFR700 .45 (b), or

❑ The Company named in Part 1, Section A has remitted the fee of $1000 for an Intermediate PMN (defined Q40CFR700.43) in

accordance with 40CFR700 .45.(b), or

❑ The Company named in Part I. Section A is a small business concern under 40CFR700 .43 and has remitted a fee of $1000 in

accordance with 40CFR700.45(b)

If you are submitting a low volume exemption (LVE) application in accordance with 40CFR723 .50(cx1) or a Low release and low

exposure exemption (LoREX) application in accordance with 40CFR723 .50(c)(2), check the following certification statements:

❑ The manufacturer submi tting this notice intends to manufacturer or impo rt the new chemical substance for comme rcial

purposes, other than in small quantities solely for research and development, under the terms of 40CFR723 .50.

❑ The manufacture is familiar with the terms of this section and will comply with those terms; and

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

❑ If this application is for an LVE in accordance with 40CFR723 .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 reg arding the

chemical substance desc ribed herein . Any knowing and wilful misinterpretation is subject to criminal penalty pursuant to 18 USC

1001 .

Confidential

Signature an e of AuthorizedrOiaV (Originrl Signatu Required) Dat e

.,p Lieu.;

~.~.

V. t5 i

Signature of agent - (ifapplicable) Date

/~,~ ~`~

wX.

~

///w

FnRn,r Faa '7-710_25 ( Rev .5-95) Page 2
p. 3

Part I - GENERAL INFORMATION

Section A - SUBNIITTER IDENTIFICATION Confidential

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

I a . Person Name of authorized official Position

Submitting Gary Grindrod Vice President, New Business Development

Notice Company

(in U.S .) Zeon Chemicals, Inc .

Mailing address (number and street)

4111 Bells Lane

City, State, ZIP Code

Louisville, KY 4021 1

b. Agent (if Name of authorized official Position

applicable) Ronald S. Slesinski, Ph.D.,DABT Senior Science Manager

Company

ENVIRON International Corporation

Mailing address (number and street)

4350 North Fairfax Drive, Suite 300

City, State, ZIP Code Telephone Area Number

Arlington, VA 22203-1619 Code

703 516-2322

c. If you are submitting this notice as part of a'oint submission, mark (x) this box .

Name of authorized official Posi tion

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Number

Code

2 . Technical Name of authorized official Position

Contact Ronald S. Slesinski, Ph.D.,DABT Senior Science Manager

(in U.S.) Company

ENVIRON Interna tional Corporation

Mailing address (number and street)

4350 North Fairfax Drive, Suite 30 0

City, State, ZIP Code Telephone Area Number

Arlington, VA 22203-1619 Code

703 516-2322

3 . If you have had a prenotice communication (PC) concerning this Mark (X)

notice and EPA assign a PC Number to the notice, enter the number . if none

4 . If you previously submitted an exemption application for the chemical Mark (X)

substance covered by this notice, enter the exemption number assigned if none []

by EPA. If you previously submitted a PMN for this substance enter the

PMN number assigned by EPA (i.e. withdrawn or incomplete)

5 . If you have submi tted a notice of Bona fide intent to manufacture or M ark (X)

impo rt for the chemical substance covered by this no ti ce, enter the no tice If none []

number assigned by EPA .

Manufacture [ X I Import Only

6 . Type of Notice - Mark (X) 1. Only 2. 3 . [] Both

Binding Option [ X I Binding Optio n

Mark (X) Mark (X)

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

Part I - GENERAL INFORMATION - Continued

Section B- CHEMICAL IDENTITY You must provide a currently correct Chemical Abstracts (CA) name of

INFORMATION

: the substance based on the ninth Collective Index (9CI) of CA

nomenclature rules and conventions.

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

Complete either item 1 (Ciass I or 2 substances) or 2(Potymers) as appropriate. Complete all other items.

If another person will submit chemical identity information for you, mark (x) the box at the right. [] ConfiIdentify the name, company and address of that person . dential

1 . Class i or 2 chemical substances (

for definitions of class 1 and class 2 substances, see the Instructions Manual )

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

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

similar substance . For Class I substance a CA Index Name must be p rovided. For Class 2 substances either a CA Index X

Name or CA Preferred Name must be provided, whichever is app ropriate based on CA 9C1 nomenclature rules and

conventions.).

c

. Please identify which method you used to develop or obtain the specified chemical identity information reported in this

notice : ( check one).

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

report obtained from the CAS Inventory Expert Service must be

submitted as an attachment to this notice)

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

X

F

e

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

immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of reaction or X

process. (3) Indicate the range of composition and the typical composition (where appropriate). (4) Provide a correct

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

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

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

Part I- GENERAL INFORMATION - Continued

Section B - CHEMICAL IDENTITY INFORMATION - Continue d

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

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

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

below 1,000 absolute molecular weight of that composition.

Describe the method of measurement or the basis for your estimates : GPC [] Other [] :(Specify

i) Lowest number molecular weight: °/.

ii) Maximum weight % below 500 molecular weight : %

iii) Maximum weight % below 1000 molecular weight: •/.

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

b . You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information .

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

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

manufacture of the polymer.

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

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

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

. description on the TSCA Chemical Substance Inventory.

(5) Mark (X) this column if entries in column (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.

Monomers or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maxim Confidential cornposition Mark (x) dential m dential

(2) (3) (4) (5) Residual (7)

(6)

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

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

Method 1(CAS Inventory Expert Service a copy of the Identification report obtained [] Method 2 (Other Source)

from the CAS Inventory Expert Service must be submitted as an attachment

to this notice)

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

polymers.

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

ascertained .

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

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

Part I - GENERAL INFORMATION - Continued

Section B - CHEMICAL IDENTITY INFORMATION - Continued

3 . Impuriti es

(a) Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purposes.

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 impuriti es, estimate their total weight •/.

Impurity and CAS Registry Number Maximum Confi-

(a) percent dential

X

X

%°

%

%

%

%

[] Mark (X) this box if you attach a continuation shee t

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

X

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

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

X

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

6. Generic chemical name - Ifyou claim chemical Identity as eoafideatfal, you must provide a generic chemical name for your substance

that reveals the specific chemical Identity of the am chemical substance to the maximum extent possible. Refer to the TSCA chemical

Substance Inventory, 1985 edition., Appendix B for guidance on devdopiat generic aamea .

Alkyl Ether

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

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

substance. Provide the CAS Reastry Number if available.

Byproduct CASRegistry Number Co6 4

1 (2) destiat

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

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

Part I - GENERAL INFORMATION - Continue d

Section C - PRODUCTION IMPORT AND USE INFORMATION :

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

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

volume for any consecutive 12-month period during the first three yeas 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 10.000kg/yr.

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

Maximum first 12-month production (lt8/yr) Maximum 12-month production (kg/yr) Confidential Binding

(100'h new chemical substance basis) (100% new chemical substance basis) Option Mark

X

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

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

claim as confidential .

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

(2) Mark (X) this column if entry in 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 yews 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 mixtura, 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 en ies) in column (8) is (are) confidential business information (CBI).

Category of Use (I) CBI Binding Produc. CBI % in CBI % of substance expected per use (8) CBI

(by function and application (i .e. a (2) Option tion% (5) Form- (7) (9)

dispersive dye for finishing polyester fibers) Mark (x) (4) W~ Site- Colt Indus Com- Bindin g

(3) (6) limited ataner trial rtxteial Option

-- - -- -- X X X X

X X X X

I I L

% %

% %

% %

If you have identified a"constuner use", please provide on 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 you attach a continuation sheet

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

description cate . Read the Instructions Manual for examples of generic use descriptions.

Industrial Solvent

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

3 . Hazard Infortnation - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety deta sheet, or Binding

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 the safe handling, transport, use or disposal of the new substance . List in part III hazard information you include . Option

Mark (

Mark (X) this box if you attach hazard information

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

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER

Complete section A for each type of manufacture, processing, or use opera tion involving the new chemical substance at industrial sites you control .

Importers do not have to complete this sec tion 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 instruc tions manual .

1 . Operation description Confid

a. Identity-Enter the identity of the site at which the operation will occur. ential

Name

Site address

City, County, State, ZIP Code

If the same operation will occur at more than one site, enter the number of sites. Identify the additional sites on a continuation xof sites

sheet, and if any of the sites have signific antly different production rates or operations, include all the information requested

in this section for those sites as attachments.

Mark (X) if you attach a continuation sheet

b . Type -

Mark (x) ( ) Manufacturing Processing Use

c . Amount and Duration

1 . Batch Maximum kg/batch (100% new chemical substance) Hours/batch Batches/year

2. Continuous Maximum kg/batch ( 100°/. new chemical substance) Hours/botch Batches/year

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

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

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

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

materials and feedstocks (including reactants, solvents, and 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 .

No production, processing or use occurs at industrial sites controlled by the submitter .

[) Mark W this box if you attach a continuation sheet

Fnrtna FPA 7710-25 ( Rev .5-95) Page 8
p.9

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -Continued

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

2 . 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 (%) the "Confidential" box next to any item you claim as

confidential.

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

substance .

(2) Mark W 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 QC) this column if entry in column (5) is confidential business information (CBI) .

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

(9) Mark IX) this column if entry in column (5) is confidential business information (CBI) .

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

(12) Mark Q{) this column if entry in column (5) is confidential business information (CBI) .

Worker activity CBI Protective Equipment Binding Physical Binding CBI # of CBI Maximum Du CBI

(e .g . bag dumping, filling (2) /Engineering Controls Option form(s) Option (7) Workers (9) ration (12)

drums) (3) Mark (x) (5) Mark (x) Exposed x

(1) (4) (6) (8) Wday Days/yr

11M fill

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

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

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

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

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

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

(4) Identify the media of release i.e. stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration,

POTW, or other (please 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 (CB1).

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

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

business information (C]BQ.

Release Amount of new substance released CBI Media of Cont ro l technology and tency CBI

Number (2a) (2b) (3) release (Sa) Binding (5b) (6)

(1) (4) Markx

(7) Mark (X) the [] POTW provide name(s) below CBI [] Navigable [] Other - Provide NPDESN CBI

destination(s) of waterway specify

releases to water

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

page 9
p.10

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued

Section B - INDUSTRIAL SITES CONTROLLED BY OTHERS

Complete section B for typical processing or use operations involving 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 repo rt any processing or use acti viti es after import. See the Instructions

Manual . Complete a separate section B for each type of processing, or use operation involving the new chemical substance . If the same operation is

performed at more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet.

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

confidenti al.

(1) Diagram the major unit opera ti on steps and chemical conversions, including interim storage and transport containers (specify e.g. 5-gallon pails,

55-gallon drum, rail car, tank truck, etc .). On the diagram, identify by letter and bri efly describe each worker activity . (2) Pro vide the identity , the

appro ximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents,

and 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 . (4) Please enter the

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

# of Sites

See attachment Pages 20 -2 1

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

2. Worker ExposurefEavironmental Release

( 1) From the diagram above, p rovide the letter for each worker ac tivity . 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 protecti ve equipment and engineering contro ls used

to pro tect workers.

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

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

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

or kg/batch).

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

POWT, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the envi ronment.

(14) Identify by-products, which may result from the operati on.

3, (5), (8), (1 , 13 and (15) Mark this column if any of the roceedin entries are confidential business in tion (CBI).

Letter # of CBI Duration of CBI Protective EquipJ % in CBI Release Amount of New CBI Media of CBI

of Workers ( 3) Exposure (5) Engineering Controls/ Form- (8) Number Substance ( 11) Release & (13)

Act- Exposed Physical Form and % ulation (9) Released Control

ivity (2) (4s) (4b) new substance (7) (10a) (10b) Technology

(1) hours/ days/ kg/day (12)

day year

1 2 8 220 Vapor Respirator, 100% A 0.1kg Incinerloves and apron ation

2 2 4 50 100% B 10kg Incineration

C 50kg Incineration

(14)-By-products: (15)

Mark (X) this box if you attach a continuation sheet
p.11

OPTIONAL POLLUTION PREVENTION INFORMATIO N

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

substance. See the revised Instructions Manual that includes a Pollution Prevention manual for

guidance and examples.

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

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

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

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

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

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

PMN substance is a new ether solvent which is used in chemical reaction for manufacturing of pharmaceuticals

or specialty Chemicals. It could replace some of universal solvents which are considered to be harmful, such

as tert-Butyl methyl ether, (MTB), Diisopropylether, Dioxane and Tetrahydrofuran (THF) .

The PMN substance has superior separation properties relative to some of the existing solvents and yields

a lower quantity of peroxide byproducts that reduces the amount of solvent needed in manufacturing

applications of this chemical.

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

Page 11
p.12

Part III -LIST OF ATTACHMENTS

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

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

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

numbers of each attachment.

Mark (x) the "Confidential" box next to any attachment name you claim as 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 .

Attachment name Attachment page Confinumber(s) dential

Physical and chemical propertiesworksheet 13

Material Safety Data Sheet (MSDS) 14 - 19

Continuation Sheet for Page 10 ; Part II. Section B. 1 . 20 - 21

CAS Inventory Expert Service Report 22 X

Spectra chart (IR, UV-vis, NMR) 23 - 28

GC analysis chart 29 - 30

Description for the physical and chemical properties test s

1 . Vapor pressure 31

2 . Density/relative density 31 - 32

3 . Solubility in water 32

4. Melting point 32

5 . Boiling point 32

6. Flammability / flash point 32

7. Explodability 32

Toxicology or Environmental Test s

1 . Rat acute oral toxicity study 33 - 51 X

2 . Rabbit acute skin irritation study 52 - 66 X

3 . Rabbit acute eye irritation study 67 - 81 X

4. Bacterial mutation study 82 -121 X

5. Mammalian cell cytogenetic study 122 -164 X

6. Mouse micronucleus study 165 -194 X

7. Readily biodegradation study 195 - 232 X

Partition coefficient study (n-octanoUwater) 233 - 252 X

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

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

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T

To assist EPA's review of physical and chemical prope rties data, please complete the following worksheet for data you p ro vided and include it in the

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

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

provided . These measured properties should be for the neat (100%) chemical substance . Properti es that are measured for mixtures or formulations

should be noted (% PMN substance in -). You are not required to submit this worksheet ; however, EPA strongly recommends that you do so, as it

will simplify review and ensure that con fidential information is properly protected. You should submit this worksheet as a supplement to your

submission of test data . Th is worksheet is not a substitute for submission of test data .

Property Mark (x) if Page Value Measured Confident

(a) provided number (c) or ial Mark

(b) Estimated (x)

MorE (d)

Physical state of neat substance X 16 Liquid

Vapor pressure " X 31 4.49kPa M.

@ temperature 25°C

Density / relative density X 31 0.86 g/cm3 M

at 20°C

Solubility in solvent M

@ temperature °C

Solubility in water X 32 l.lg/l00g M

@ temperature 23°C

Melting temperature X 32 <-140°C M

Boiling/sublimation temperature X 32 106°C M

_Torr pressure

Spectra (IR, UV-vis, NMR) X 23-30 Attached M

Dissociation constant

Particle size distribution

Octanol/water partition coefficient X 233 Log Po/w 1 .59 M

Henry's Law constant

Volatilization from water

Volatilization from soil

pH @ concentration

Flammability - Flash point -1°C

Explodability 32 Lower limit 1.1 vol%

Upper limit 9.9 vol%

Adsorption/coefficien t

Other - Specify

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

FORM EPA 7710-25 (Rev.5-95) Page 13
p.1 4

Material Safety Data Sheet

Form: 403

issue Date: 1 1/11ro2

Supersedes: Now

Zeon Chemicals L. P. MSDS Number. Z01902

Section 1 - PRODUCT AND COMPANY IDENTIFICATION

manufacturer / Importer. TelephoneNumber. ChemicalFamily:

Zeon Chemicals L.P. 1-800-735-3388

4111 Bells Lane (502)-775-2000

Louisville, Kentucky 40211 ~ 8 Z

Emergency Telephone Number. Uses:

1-800-776-2460 Ext 7650 solvent

(502) 7748126

The information contained in this MSDS applies to an experimental product that is not listed on the US EPA Toxic

Substances Control Act Chemical Substance Inventory. This product can only be used for R&D evaluation purposes

under the direct supervision of a technically qualified indiv[dnaL

C .~Z

Section 2- COMPOSITION I INFORMATION ON INGREDIENTS

Hazardous Ingredients C Amount Exposure Limits

OSHA PEL ACGIH TLV

>99 % None Established None Established

Other Ingredients CAS 01 Amount Notes

TWA . Time WeiS6oed Average TLV - Thessbold Limit Value

AL - Am= Level RD -Rapinbk Dust TD - Total Dust

STEL - S6at Term Exposure Lim ft Skin - Skin can= may be a

significant mm of expoau+e A2 - ACGIH Sotpected Human Carcinogen

A3 - ACGIH Animal Carcinogen A4 - ACGQi Not Classifiable as a

Human Carcino PNOC - Paroculaoa Not Otherwise Classified

4

C$1 I~

Pap I
p.15

Section 3 - HAZARDS IDENTIFICATIO N

Emergency Overview: This material is a clear, colorless liquid with a slight characte ristic odor . Flammable

liquid and vapors. Harmful if inhaled, ingested, or absorbed through skin. May

produce vapors or mists that can cause eye, skin, and respiratory tract irritation.

Prolonged or repeated exposure to vapors may cause drowsiness, nausea, dizziness,

or headaches. Toxic combustion Products may be released under fire conditions.

Potential Health Effects From Overexposure : Possible mutes of entry include skin & eye contact and process vapor or

mist inhalation.

The physical and toxicologi cal proper ties of this experimental product have not been thoroughly evaluated Contact with

liquid, vapors, or mists may cause irritation to the eyes, skin, nose, throat, and respiratory tract. Inhalation of high vapor or

mist concentrations may produce narcotic effects. Accidental ingestion may cause gastrointestinal irritation with nausea,

vomiting, and diarrhea- Repeated or prolonged overexposure may cause central nervous system effects. Processing under

conditions of inadequate ventilation may produce symptoms of nausea, dizziness, tearing, coughing, or headaches. Typically

these effects are reversible upon removal from exposure and no lasting effects are eapected. Most importantly, the potential

for irritation will depend on the effectiveness of exhaust ventilation provided to the process area .

Appropriate precautions should be taken to minimize potential exposure to accidental ingestion, inhalation of process vapors

or mists, and skin contact .

Overexposure to decomposition or combustion products may cause irritation of the eyes, skin, and respiratory tract.

Symptoms such as coughing, tearing, and irritation should be regarded as potentially hazardous and measures taken to avoid

exposure. See Section 10 for information on combustion products.

Section 4- FIRST AID MEASURES

If irritation occurs or persists from any mute of eupostiue, remove the affected individual from the area and seek medical

assistance .

Ingestion: If swallowed, induce vomiting only if directed to do so by medical personnel. Never give anything by mouth to an

unconscious person . Seek medical assistance immediately.

Eye Contact: Flush eyes with running water for at least 15 minutes while holding eyelids open. Consult a physician if

irritation persists.

Sldn Contact: Remove contaminated clothing. Wash skin with soap and water. Seek medical attention ifirritation / allergic

skin reaction develops. Launder contaminated clothing before reuse.

Vapor Inhalation (processing vapors or decomposition Products) : Remove the affected individual to fresh air . If not

breathing, give artificial respiration. If breathing is difficult, give oxygen. Seek medical assistance immediately.

Section S- FIRE FIGHTING MEASURE S

Extinguishing Media: Carbon dioxide, dry chemical, water fog or alcohol resistant foam is recommended for sma ll fires.

For large fires use aqueous foam or water fog . Use water spray or fog to cool fire exposed containers .

Special Firefighting Procedures: Wear positive pressure self-contained breathing apparatus (SCBA) during the attack

phase of firefighting operations and during cleanup in enclosed or poorly ventilated areas immediately a fter a fire . Personnel

not having suitable respiratory protection must leave the area to prevent significant exposure to toxic combustion gases from

any source.

Unusual Fire and Explosion Hazards: Flammable liquid and vapors. Vapor can flow along surfaces to distant ignition

sources and flash back . Closed containers may rupture due to pressure buildup under fire conditions. Toxic gases may be

formed upon combustion and represents a hazard to firefighters. See Section 10 for additional information on combustion

products.

I1IIIIIII1I1)C8I PW = 00 00 1 5

_ l~
p. 16

Section 6- ACCIDENTAL RELEASE MEASURES

Wear respiratory protection and protective clothing, ventilate area, remove all ignition sources, and use non-sparking tools

and equipment to contain spill and recover as much as possible . Absorb remaining residue with inert material and place into

closed containers to await disposal . Wash spill area with soap and water. Do not allowproduct to enter municipal sewers or

waterways. Spills or releases to the environment may be reportable to the National Response Center (800) 4248802 and to

state and / or local agencies.

Section 7 - HANDLING AND STORAG E

Use only in well ventilated areas. Avoid contact with eyes, skin, and clothing . Store in a dark, dry, cool, we ll ventilated

location away from heat, sparks, flame, and direct sunlight. Keep container closed when not in use. Recommend purging

opened containers with nitrogen to limit peroxide formation. Store in stainless steel, lined steel, glass, or polyethylene

containers. Do not at, smoke, or drink where the product is handled, processed, or staed. Wash hands thoroughly before

eating or smoking. Evaluate transfer operations for potential static charge buildup and ground and bond accordingly . Use

non-sparking tools and equipment. Empty containers may retain product residue (liquid and ! or vapor) and can be dangerous .

Do not pressurize, cut, weld, braze, solder, drill, grind, or expose empty containers to heat, sparks, open flames, or

incompatible materials.

Section d- EXPOSURE CONTROLS/PERSONAL PROTECTION

Ventilation: Enclose operations and / or provide local exhaust ventilation to draw fumes, vapors, or mists away from

workers. Ventilation must be adequate to maintain the ambient workplace atmosphere below the limits listed in Section 2 .

Respiratory Protection: For protection against process vapors or mists, wear a NIOSH approved respirator suitable for the

anticipated airborne concentration. Wear a positive pressure air-supplied respirator in situations where time may be potential

for elevated airborne exposure.

Protective Equipment: -During processing operations, splash proof goggles or safety glasses with face shield suitable for

keeping liquid material out of the eyes should be worn when potential exists for eye concact. Rubber gloves and apron should

be worn when skin contact is anticipated. Provide an eye wash facility and safety shower.

Section 9- PHYSICAL AND CHEMICAL PROPERTIES

Specific Gravity (H20s1): 0.88 (a3 200C Solubility in Water. l .ig/l00g '/e Volatile by Weight: 100

Flash Point: 30°F (-l°C) Vapor Pressure: 4.49 kPa @ 2S°C Vapor Density : 3 .45

Boiling Point: 223°F (106°C) Melting Point•. 4220°F (<-140°C) Evaporation Rate: No Data

Lower Explosion Limit: 1.1 Upper Explosion Limit-- 9 .9 Autoignition Temp : 356°F (180°C)

Appearance and Odor. Clear, colorless liquid with a slight characteristic odor .

Section 10 - STABILITY AND REACTMTY

Stability: Stable Hazardous Polymerization: Will not occur

Conditions to Avoid: Overheating, open flames, sparks, and contact with ignition sources . May form explosive peroxides

when exposed to light or air.

Materials to Avoid: Oxidizing agents, reducing agents, strong acids. 000016

Hazardous Decomposition Products: Fumes produced when heated to decomposition temperatures may contain carbon

monoxide and carbon dioxide . Combustion products must be considered toxic.

cIIIc6T Page 3 N

O

• -
p. 17

Section 11 - TOXICOLOGICAL INFORMATION

Oral I.Dso (rat): >1000mg/kg and < 2000 mg/lcg

Skin Irritation (rabbit): Moderate, P11 3 .7. Reversible after 14 days.

Eye Irritation (rabbit): Irritation of conjunc tiva; reversible after 14 days

Mutagenicity: Negative in Ames test

Mouse Micronucleus Test : Negative

Mammalian Chromosome Aberration Test (in vitro): Negative

Section 12 - ECOLOGICAL INFORMATION

Not readily biodegradable.

Section 13 - DISPOSAL CONSIDERATIONS

Waste resulting from this product as supplied may be classified as hazardous because of ignitability per the current listings and

characteristics contained in 40 CFR Part 261, and its Appendices. It is the generator's responsibility to determine, per the

regulation, the applicability of the Resource Conservation and Recovery Act (RCRA), as well as all state, local, or other

governmental agency waste disposal regulations, to the particular waste materials prior to treatment or disposal. Disposal of

liquid wastes and solids containing free liquids by land filling is prohibited in mostjurisdictions. Incinerate or use biological

treatment in accordance with federal, state, and local regulations. Containers of this product may be hazardous when emptied.

Empty containers may retain product liquid and vapors.

Section 14 - TRANSPORTATION INFORMATION

For domestic transportation purposes, this product is defined or designated as a hazardous material by the U.S. Department of

Transportation under Title 49 of the Code of Federal Regulations.

CL~Z

DOT Hazard Class 3

DOT Proper Shipping Name Flammable liquid, N.O.S 3, UN 1993, PG II

DOT Label Class 3

UN/NA Hazard No. UN 1993

Section 1 5 - REGULATORY INFORMATION

TSCA Inventory Status: This product is not currently listed on the US EPA Toxic Substances Control Act Chemical

Substance Inventory. It can only be used for R&D evaluation purposes under the direct supervision of a technically qualified

individual - 40 CFR 720.36.

TSCA 12(b) Export Notification Status: This product does not contain any components subject to expo rt notification

requirements.

SARA 313 Status: This product does not contain any components exceeding the de nrinunis amount subject to reporting

under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 and of 40 CFR 372.

O 0001 7

Page 4
p. 18

Additional Right-to-Know Information on Components:

Cotnponent CAS # Key (See below)

7,13 •

Key Description Key Description

1 . Reserved S. MA Extraordinary Hazardous Substance above 1 ppm

2. CA Listed Carcinogen 9. MA Toxic or Hazardous Substance above 1%

3 . CA Listed ReproductiveToxin 10. NJ Hazardous Substance above 1 %

4. PA Special Hazardous Substance above 0.01% 11 . NJ Special Health Hazard Substance above 0.1 %

5 . PA Hazardous Substance above 1% 12. NJ Environmental Hazardous Substance above 1%

6. PA Non-Hazardous Substance above 3% 13. NJNon-Hazardous Substance above 1%

7. PA Non-Hazardous Substance above 5% 14. Canadian WHIvIIS Ingredient Disclosure List

Substance

Section 16 - ADDITIONAL INFORMATION

Hazard Rating System Classifications:

NFPA HMIS Key: 0-least; l•alight; 2-moderate; 3-high; 4-extreme

Health 2 2 National Fire Protection Association razing identifies hazards during a fire

Flammability 4 4 Hazardous Materials Identification System rating applies to products as

Reactivity 0 0

It may be possible under certain processing and handling conditions, e .g. processes that create vapors, mists, or dust, to

release unreacted monomers and other substances in airborne concentrations in excess of their established exposure limits or

guidelines. Customers and processors should do sufficient in-house industrial hygiene monitoring to assure compliance of

their operations.

Reason for (Re)inne: New

Q 0 t1 018

C 617

popS 12

. . . .
P. 19

User's Responsibility

This bull etin cannot cover all possible situations which the user may experience during processing. Each aspect of your

operation must be examined to determine if, or where, additional precautions may be necessary . All health and safety

information contained in this bulletin must be provided to your employees or customers. It is your responsibility to use this

information to develop appropriate work practice guidelines and employee instructional programs for your operation.

Disclaimer of Liability

As the conditions or methods of use are beyond our control, we do not assume any responsibility and expressly disclaim any

liability for any use of this material . Information contained herein is believed to be true and accurate but an statements or

suggestions are made without warranty, expressed or implied, regarding accuracy of the information, the hazards connected

with the use of the material or the resultsto be obtained from the use themof. Compliance with all applicable federal, state,

and local laws and regulations remains the responsibility of the user.

CST

Cij(1M 9

Pop 6
p. 20

Continuation Sheet for Page 10 ; Part H. Section B. 1.

Zeon Corporation, PMN Substance : Solvent in Chemical Reaction

<Simplified process description>

Supply Residue in empty containers (Release A)

♦ (Worker Ac tivity 1 )

Monitoring the automated production

Loading to holding line, connecting the joints of pipe lines,

tank etc.

Reaction for

10 Cleaning (Release B; Worker Activity 2)

chemical production

Separation 01 Final product - Intended chemical substanc e

free from PMN substance

Distillation Recycled PMN substance (to be re-used)

Reaction residue ( to be disposed of by incineration) (Release C)

<Supply>

The PMN substance is synthesized in Japan. The PMN substance is liquid and transported in stainless-steel containers of

varying sizes that typically hold about 1,000 kg to 10,000 kg of PMN substance .

<At use>

PMN substance is an industrial solvent that is used in chemical reactions. The main market is pharmaceutical industry an d

there is some potential market in specialty chemicals industry. At sites of use, PMN substance is loaded into holding tanks

using automatic pump or pipelines.

Typical size of chemical reaction is 0.1 M' - IOM' and the typical amount of PMN substance used in one batch is

approximately 100 to 900 kg. The chemical reaction may involve heating reaction at up to 100 degrees Celsius (below

boiling point of PMN substance, ca .106 degree C). The reaction process typica lly takes place one to two days .

The reactor and equipments are closed system and has a standard designed to prevent release of volatile compounds into the

working environment, but usually 100% containment cannot be achieved . The operation is automated process and is

monitored by one or two workers who wear standard protective equipment such as glove, vapor mask, goggles and

protective clothing. The operation sites are equipped with local air ventilation system . Worker exposure to PMN substanc e

at operation site is at a negligible level .

f~0oar0
~ • p.21

Continuation Sheet for Page 10 ; Part II. Section B. 1 .

<Separation / Distillation>

After chemical reaction to obtain intended substance, PMN substance which is not incorporated to the resulting substances

is separated out and purified for re-use. The purification process yields a waste residue and unusable PMN substance which

is disposed of by incinera tion. The loss of PMN substance at one reac tion is about 10% to the total amount used.

In some cases, water is used to separate out the intended chemical product from the reaction mass. In the water layer

resulting from this process contains PMN substance at its water solubility level (ca.l g/L). The resulting water is put through

the distillation process and the most of the dissolved components are separated out before the water is released to water

treatment system of the industrial sites . The resulting residue is disposed of by incineration.

<Cleaning of equipment>

At completion of reaction process, the equipment is cleaned typically using water . The resulting water is treated in the same

way as described above .

<Simplified process description, Polymer solvent>

The PMN substance may be used in polymer processing, although this is not major target field at this stage . This usage may

involve a process to dissolve a polymer with the PMN substance and apply the solution to various articles. One of the

possible processes in which the PMN substance may be used is semiconductor produc tion. A polymer dissolved with the

PMN substance may be coated on the surface of semiconductor parts. The PMN substance may be evaporated to leave a

polymer layer on the surface . Most of the time, this type of process is performed in closed and automated systems that do

not allow release of the solvents into working environment and does not involve manipula tion by workers.

The risk of worker exposure and environmental release is therefore low and estimated to be similar for the usage of Process

solvent and Polymer solvent.

ar ot?002i
p.22

Inventory Expert Service

A division of the American Chemical Society PhonwK 800-631-1884. 614-447-3600 (ext. 2308)

F»c 614447-3747

E-maik msvMes@as.cxg

INVENTORY EXPERT SERVICE REPORT

IES-ORDER NUMBER : 69862

REGISTRY NUMBER : c1t ~

CA INDEX NAME

Please print the above CA Index Nams on the appropriate page of your PMR.

If this box is checked, GS has made correction(s) marked in red to

0 your IES order . Please make the sasis correction(s) to your P M before

suhmittinQ it to the ZpA.

000022

az
• p. 23

2) Infrared spectrum (obligato ry):

The spectrum should be recorded over the range 4004 600 cm" . with an instrument resolution of at

least 4 cm" .

Please provide the following Use this space to provide the information or tick space as

information> a cbecktist

Type of spectrometer used JASCO FI'/IR 5300

Purity of sample >"'S%

Any references or background Not used

corrections used

Solvent and concentration of Neat

sample

Method of prepawtioa or The KBr disc

sample (liquid film, KBr disc etc)

Cell (pathkagtb and material)

Waveanmbers and assignments 3000"2E00' 1450, 990 cm

of major absorbances

A clear spectrum, labelled with- The compound aame ' hc Lot

the compound name No. is 020618, the date o aea ysts is July 31, zuuu.

batch number u sed

the sample number

date of analysis

2

000023
p. 24

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• p. 25

Regulatory Affairs - EU Industrial Chemical Notification s

Spectra

1) Uftraviolet/visible spectrum (obligatory) :

The spectrum should be recorded over the range 200- 750 nm. with a wavelength accuracy of t 0.5nm.

It is recommended that a 102 molar solution is used. which is diluted to concentrations o[ 1d . 104.

and 10'5 molar . ,

if the substance is soluble in water or methanol. additional spectra are required in acidic and basic

medium. The acidic medium should have a pH of less than 2. and the basic mdium Should he at least

pH 10.

Please provide The following Use this space to provide The information or lick space as

information), a checklist

Type of spectrometer used (ea Shimadzu UV 265FS

single beam, double beam)

Parity of sample (puriticabn "S%

procedure if applicable)

Composition and path length or 20 mm/em

cells used

Any references or background Not used

corrections used

Solvent and concentration of Neat

sample

pH ofsolution used Not used

Operating temperature 24 'C

Wavelength and molar extioctioo 2031 am

~ Cg=

coefficient or any transitions

A clear spectrum, labelled with : The compound name the Lot

the compound name No. is 020618, the date o~aoarJune 2 .

batch number used

the sample number

date of analysis

r

0u-0-C125
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. i1H1t - - .- i

p. 2 '

• , ,

, , _i i i , i;

~ ;-`--?-----~- .---

.-i- ~ - ---- - --- --- . •

~-~ --- , -:- - .-- . . . .

, ---- --; -. - .

;- - - -

- --~ -• -

~- - - co - -- - - - - - -

-•~ ---- - - - - -

~-:-~- -- -- - - -_. _

. .

.---- --- _ . .

.-- -- -

,- ' .

-----=---------------._ ._ . . --- ~ -- -

~-~ r - - -

., o --- --- • - . - - - -

-- - - 0

~_ . . .

.- -• --- -- -

~ - -- --- • -- • - - -- - ~J -. . :

4121 iJ,0

-- -- t------. ,-,----'- -' ----. ..

. -- - - -- - - ----

____ . .-- --_-_1.

.

. _ ._.~~_~_.-------'--'- - --- ~-- . ._-.-- --' -- ~- -- - - ---- - - .

?lill

. -

_ ._ .---~'--------- - ---'-'----- -

c5~::t•1t4 .'._i _

2i►3 214M 1 . _~~_ -- - -~_~ ! _! • ''

---•-

~ - -- l.i!iut -- -

. -- - -- -- - - - - - ~ L
• p. 27

3) Nuclear Mapwic Resonance (obligatory):

The quality of the NMR spectrum must permit the interpetation of the spectrum . Complex groups of

peaks which are relatively weak in the first run should be suitably expanded and/or increased and a

second integration should he appended. Th e solvent used should not obscure important substance

related peaks.

At least one high resolution NMR spectrum should be p rovided if the substance is an organic

compound. If the molecule has a mobile hyd ro gen atom that undergoes isotopic exchange. an

additional spectrum in the presence of DO should be run. For `'C NMR spectra . "C - 'H splitting

should be suppressed . cg by decoupling .

The spectra should contain all of the peaks attributable to the substance . and cover at least the range :

'H 0 - 10 ppm (reference TMS).

"C 0 - 250 ppm (reference TMS) .

"F or ''P NMR spectra should be given where applicable .

Please provide the following Use this space to provide the information or tick space as

informations a checb4ig

Instrument used JEOL EX 400

Sample purity (purification >~S~D

procedure if applicable)

NMR-active nuckus eg'H, uC 'H NMR (400MHz)

and frequency in MHz Chemical shifts are given in ppm.

Solvent ea D=O, CDC13 and CDC13

concentration ofsample CPME Concentration: 596

Internal or external references TMS as internal standard.

Operating temperature 24 T

C$S

A clear spectrum, labelled with : The compound same is the Lot

the compound name No. is 020618, the date o ana srs

is

Ma~J, 2001 .

hatch number used

sample number

date of analysis

Frequency and structural a 3 .80(IH), 3 .26(3H),1.67-1 .52(8H)

assignmentsof major peaks

3

0 U0(12 f
• p. 28

:_ o!= :

:s3I: =

+i~ ■ ~~~~ ~i~ w s'.

T33~ 3 $ i

f-------------------------:-----------_.__. .---------- -- ~F

OD

I N

o

0

ooo•e c ~; . ~ r►

► ~ .

zTO•s `n

r ~

55s • o ----. `

r

CL

! U ~o Ir ,`

W

-- --- - - ----- -- -- - ----- - -r---~

.~ ~

060028
p. 29

2 .2 GC (Gas chromatography)

Please provide the following Use this space to provide the information or tick space as

iaformatioo> a checklist

Type of analysis (e .g. identity, Pu rity and impurity

parity, impurities)

Instrument

Hitachi GC 390

Column stationary phase and GL Sciences Neutraboed Capillary Column 60•1D

dimensions 0.2Sd•(1Sμ mdQ

Carrier gas 1 N2

Flow rate 10 ml/min

Inlet system - type and 200 T

temperature

Column temperature 50'C(10 min), 100'C t0 300'C (20'C/mim)

programme

Detector type temperature and 300-C+ FID

mode (if applicable)

Auxilia ry gas flow rates N2: 20mUmin; H2: 35m11mim ; Air. 250mUmin

Sample injection volume 1

Sample concentratio n

Retention time in minutes 30 min

A clear chromatogram, labelled The compound aame ' )tbe Lot

w~ith : the compound name No. is 020618, the date o a ;

batch number used

sample number

date of analysis

Also label The peaks ofinterest.

6

Gvtli129
p. 30

GLC Chart

C~Z Lot

. 020618 Page 1 of 1

Sample ID : N2F Lot 02061 8

Acquired : Aug 07. 2002 15 :51 :03

Printed : Aug 09. 2002 10 :44 :47

User : System

cW917000 Chr F N A

0 .2 0 0.20

0 .10 0., G

0.10

0.1 9

O 1 ,y Q,

4

v v

a, ~ ✓ a1z

0.10 °

i

0.0 0

0.00 0 .05

G.

y ♦

f O O g O.Ga

0. 02 ~ 8 g R

g O O p

0. 02

'4 N N

0.00 y 0.00

O s 10 te 20 23 00

MnuMs

Channel A Result s

Peak Time Hight Hight% Area Area %

----- ---------- ---------- ---------- ---------- ----------

1 5.84 5 0.003 37 0.004

2 10.72 189762 99 .994 975669 99.992

3 20.08 1 0.001 16 0.002

4 21.55 3 0.002 14 0.001

5 29.21 2 0.001 13 0.001

Totals

189773 100. 000 975749 100. 000

G~ 0n~p
p.31

Description for the physical and chemical properties tests

1 . Vapor pressure

The measurement was conducted by Isoteniscope at 259C and Dynamic method at other temperature .

Results ;

Temperature Vaporpressuref(kPa)

Q°'C)

Measured value Estimated value

25.00 4.49 4.48

31 .28 6.13 6.14

43.05 10.67 10.66

57.95 20.00 20.03

71 .30 33.33 33.35

84.79 53.33 53.35

97.47 79.99 79.98

105.39 101.33 101.35

108.90 112.19 112.16

looo

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ._ . . .

. . . . : . . . . . . . . . . 1 o ~~it ; . . . . . . ; . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . .. . . . . . . . : _ rrs . .

. . . . . . . . . . . . . . . .

100 '

. . : . .

. . : . . . . . . . ; . . . . . . . . . . . . . . . : . . . .

: .

:

? : . . . . . . . . : . . . . . . . . : . . . . . . . . : . . . . . . . .

. . . . . . .i . . . .

. . . .

: . . . . . . . : .

10

.

. . . . . .

. . . . . . . . .

Zp ~p ~p ep ~p 7 L -L 0 so s0 100 110 lt0

f( c)

2. Density/relative density

The measurement was conducted using a Pyknometer (capacity 5cm3) at 25+/-0 .04°C.

Results ; density = 0.8596g/cm3

000031

2 1
p.32

3. Solubility in water

The measurement was conducted by GC-FID analyzing samples after shaking test substance and water ( 1 :10) and leaving

for 48 hours.

Results ; water solubility (room temperature 23.4C) = 1 .1 (g/1 00g)

4. Boiling point

The measurement was conducted using Differential Scanning Calorimet ry.

Results ; boiling point = 1069C

5. Melting point

The measurement was conducted using Differential Scanning Calorimet ry.

Results ; melting point = -87°C

6. Flash point

The measurement was conducted using a Closed Tester at 24 .09C, humidity 73% and vapor pressure 1014hpa.

Results ; flash point was confirmed as -1 .09C

7. Explodability

No. Date Sample Conc. Temp Pressure Reaction Reaction Explodability

(S) (%) (`jC) (kgf/cm2) (°C) (kgf/cm2)

1 12/5 0.1365 2.0 120.6 1038 103.0 Positive

2 12/5 0.1020 1 .5 117.1 1038 83.9 2.13 Positive

3 12/5 0.0683 1 .0 120.4 1038 - - Negative

4 12/5 0.0685 1 .0 121.9 1040 - - Negative

5 12/5 0.0676 1 .0 121.9 1040 -

- Negative

6 12/5 0.5429 8.0 119.3 1029 122.3 1.99 Positive

7 12/5 0.6117 9.0 121.0 1040 64.7 0.41 Positive

8 12/6 0.6780 10.0 120.5 1033 - - Negative

9 12/6 0.6795 10.0 120.1 1033 - - Negative

10 12/6 0.6795 10.0 120.7 1033 - - Negative

Results ; Under normal pressure, lower explodability limit concentra tion was 1.1- 1.5% and upper explodability limit

concentration was 9.0 - 9.9%.

000032
p. 33

PAGES 33 TO 252

CONFIDENTIAL BUSINESS INFORMATION

000033 TO 000252 CBI