# u.s. ENVIRONMENTAL PROTECTION AGENCY Date ofreceipi 

# PREMANUFACTURE NOTICE 03 NOV I

# a M1r': 

# rI ES 

# Company Sanitized FormA 

# AGENCY

JnCI llle tUlQ.J lIU!lJUCl VI**pd.!6.C~** in the Premanufacture Notice 

# GENERALINSTRUCTIONS
• You mustprovide all information requested in this form tothe extent that it is known to orrea_onably ascertainable by you. Make reasonable estimates ifyou do nothave actual data. • Before you complete this form. you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling202-554-1404. orfaxing 202-554-5603). • Ifa user fee has been remitted for this notice (40 CFR 700.45). indicate in the boxes above the TS-user fee identification number you have generated. Remember, your user fee 

### ID number must also appear on your corresponding fee remittance. which is sent to EPA, 

### HQ Accounting Operations Branch (PM-226), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA Userfee.
Part I-GENERAL INFORMATION You mustprovide the currently correct Chemical Abstracts (CA) Name ofthe new chemical substance. even ifyou 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 ,upport ofyour submission should reference your TS user fee identification number. You must submit an original and two copies ofthis notice including all testdata. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted.
Part 11-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture, processing, or use operations to be described in Part It sections Aand Bofthis notice. reproduce the sections as needed. Part III- LIST OF ATTACHMENTS Attach additional sheets ifthere is notenough space to answer aquestion fully. Label each continuation sheet with the corresponding section heading. In Part III. list these attachments. any test data Or other data and any optional information included in the notice
OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new SUbstance. On page I I ofthis form, space has been provided for you to described pollution prevention and recycling information you may have regardingthe new substance. So-called "binding" boxes are included throughout this form for you to indicate your willingness to be bound to certain statements you make in this section, such as use, production volume, protective equipment
... This option is intended toreduce delays. that routinely accompany the developmentofconsent orders or Significant New Use Rules. Except in the case ofexemption applications (such as TMEA. LVE, LOREX) where cenain information provided in such notification is binding on the submitter when. the Agency approves the exemption application, checkinga binding box in this notice does not by itselfprohibit the submitter from later deviating from the information (except chemical identity) reported in the form CONFIDENTIALITY CLAIMS You may claim any information in this notice as confidential. To assert aclaim on the form, mark (X) the confidential box next to the information that you claim as confidential. To assert aclaim in an attachment, circle or bracket the information you claim as confidential. Ifyou claiminformation in the notices as confidential, you must also provide a sanitized version ofthe notice, (including attachments). For additional instructions on claiming information as confidential. read the Instructions Manual. TEST DATA AND OTHER DATA You are required to submit 

### all test data in your possession orcontrol and to provide a description ofall otherdata known to or reasonably ascertainable by you, ifthese data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, or disposal ofthe new chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English), not summaries ofdata, mQst be submitted ifthey donot appearin the open literature. You shouldclearly identify whethertest data is on the substance oron an analog. Also, the chemical composition oftbe tested material should be characterized. Following are examples oftest data and otherdata. Data should be submitted according to the requirements of§720.50ofthe Premanufacture Notification Rule (40CFRPart 720).
Test Data (Check Below any included in this notice) Environmental fate data 

## 0 Yes Otherdata 

## 0 Yes Healtheffects data 

## 0 Yes Risk assessments Environmental effects data 

## 0 Yes Structure/activity relationships Physical/Chemical Properties

### * 

## 121 Yes Test data not in the possession orcontrol ofthe submitter Aphysical and Chemical properties worksheet is located on the last page ofthis form. TYPE OF NOTICE (Check Only One)

## ~ PMN (Premanufacture Notice) 

# o INTERMEDIATE PMN (submitted in sequence With final product PMN) 

# r5I I

# B(tnifiICseNCOPY**~ (~**  g emp a ) 

# o LVE (Low Volume Exemption) @40CI;R 723.50(c)(I) C::-J 

# """ c:::> <.,..., 

# o LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.5Qi,Q1(2) ....:;;:;; LVE Modification LOREX ModIfication 

# o o D

IS THIS ACONSOLIDATED PMN? Yes 

# o Mark (x)ifany information in this notice is claimed as confident'"!. # ofchemicals (Prenotice Communica tion# required. enter# on page 3) 

## c EPA FORM 7710-25 (Rev. 5-95) 

# 1

# ,;:rrei;;?j'3AFO=771~~' 0

### Publicreporting burden for this collection ofinformation is estimated to average 110 hours per response, includingtime for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing andreviewing the collection of information. Send comments regarding the burden estimate or any other aspectofthis collection ofinformation, including suggestions for reducing this burden, to Chief. Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 40\ M. St., S,W" Washington, D.C. 

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

## CERTIFICATION 1certify that to the best ofmy knowledge and belief: I. The company named in Part I, section A, subsection I a ofthis notice form intends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B, 

### 2. All information provided in this notice is complete and truthful as ofthe date ofsubmission. 3. I am submitting with this notice all test data in my possession or control and a description ofall other data known to or reasonably ascertainable by me as required by §720.50 ofthe Premanufacture Notification Rule.
Additional Certification Statements: If

### you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following userfee certification statement that applies: 

# L8J The Company named in Part I, 

### Section A has remitted the fee of$2500 specified in 40 CFR 700,45(b), or 

# o The Company named in Part 1, 

### Section A has remitted the fee of$1000 for an Intermediate PMN (defined @ 

### 40CFR 700,43) in accordance with 40 CFR700,45(b), or 

# o The Company named in PartI Section A is a small business concern under 40 CFR 700,43 and has remitted a fee of$100 in accordance with 40CFR 700,45(b). If

### you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(l) or a Low release andlow exposure exemption (LoRex) application in accordance with40CFR 723.50(c)(2), check the following certification statements: 

# o 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 of40 CFR 723.50. 

# oThe manufacturer is familiar with the terms ofthis section and will comply with those terms; and 

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

# oIfthis application is for an LVE in accordance with 40

# PU-'**B'~lGturuO'** p¥e**ma~ufactu~e** 

### ofthe exempted substance for commercial es 1 ear e date fth x r n 0 

### the 30day review perIod.

The accuracy ofthe statements you make in this notice should renect your hest predictionofthe anticipated facts regarding the chemical substance described herein. Any knowing and willful misinterpretation is subiect to criminal nenaltv pursuant to 18 USC 1001. Confidential Signature and title ofAuthorized Official (Original Signature Required) Date
Signature ofagent
- (ifapplicable) Date



### EPA FORM 7710-25 (Rev. 5·95) 

### Page 2 

# x

## XConfidential la. Person Submitting Notice (in U.S.)

b. Agent (if Name ofauthorized official applicable) Company
address (number and street) City, State, ZW

Company Mailing address (number street) City, State. ZIP Code



### c. Ifyou are submitting Joint Submitter (if Name ofauthorized applicable)



### 2. Technical Name ofauthorized official Contact (in U.S.) Company Mailingaddress (number and street) City, State, Code

Company Mailing address (number and street) City, State, ZW Code

: 4. previously submitted an exemption application for the chemical substance covered by this notice. enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this substance enter the II

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

Telephone
Position

Telephone



### , 2. Import Only 

# D BindingOption Mark 

### X 

# D
X 

# D
5. Bona fide orimport for the chemical substance covered by this notice, enter the notice number Mark (Xl II 

### X 

# D**~~~~. ~**  ifnone 

### I. Manufacture 

# , 6. Type ofNotice

- Mark (X) Only Both 

# :3 

# D D Binding Option Mark (X) EPA FORM 7710-25 (Rev. 5-95) Page 3Section B·- CHEMICAL IDENTITY Complete

lor class substances, see the Instructions Manual) a, Class ofsubstance

- Mark (X) Class 

### I or 

### 2 

# D Class 

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

### I substances a CA Index Name must be provided. ForClass 

### 2 substances either a CA Index Name orCA Preferred Name must be provided. which ever is appropriate based on CA 9CI nomenclature rules and conventions). 

### N/A

c, Please' you used to develop orobtain the specified chemical identity information reported in this notice: (check one). 

# D Method 

### 1(CAS Inventory Expert Service 

### a 

# D Method 

### 2 (Other Source) copy ofthe Identification report obtained from the CAS Inventory Expert Services must 

### be ' d, 

### a number already exists for the substance)

CAS#

e. For a I substance, provide a complete and correct structure diagram, For a class 

### 2 substance
_(I) immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature ofthe reaction orprocess. (3) Indicate the range ofcomposition and the typical composition (where appropriate), (4) Provide 

### acorrect representative or oartial chemical structure dial!ram. as comolete as can heknown. ifone can he reasonahlv ascertained,


# PUBLIC COpy

attach a continuation sheet.
EPA FORM 7710-25 (Rev. 5-95) Page 4Confidential a, Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymer you intend to manufacture, Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500and 

# X below 1,000 absolute molecular weight ofthat composition, Describe the methods ofmeasurement orthebasis for your estimates: 

### GPC 

# D Other 

# D: (Specify) i) lowest numberaverage molecular weight: 

### ii} maximum weight 

### %below 500molecularweight: iii) maximum weight % below 1000 molecular weight: Mark (X) this box if attach a continuation sheet b, You must make separate confidentiality claims for monomeror composition information, and residual information, Mark (X) the "Confidential" box next to any item you claim as confidential (I) Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeach monomerorotherreactant used in the manufacture of the polymer, (2) Mark (Xl this column ifentry in column (I) is confidential. (3) Indicate the typical weight percent ofeach monomer orotherreactant in the polymer, (4) Mark (X) the identity column ifyou want a monomerorother reactant used at two weight percent orless to be listed as part ofthe polymer description on the TSCA Chemical Substance Inventory, (5)

- Mark (Xl this column ifentriesincolumns (3) and (4) are confidential. (6) Indicate the maximum weight percent ofeach monomerorother reactant that may be present as a residual in the polymer as manufactured for commercial purposes, Mark this column if 

# X X X X X

Please identify which method you used todevelop orobtain the 

# U Method J (CAS Inventory Expert Service

- 

### a copy ofthe identification report obtained from CAS Inventory Expert Service must be submitted as as attachment to this Identity Mark (X)(4) 

# X X X X X X X X X

d, The currently correct Chemical Abstracts (CA) name for the polymerthat is consistent

e, 

### a correct represe ve or partial chemical structure diagram, as as can be known, ifone can be reasonably ascertained, 

# PUBLIC COpy

this box ifyou attach 

### a continuation sheet.
EPA FORM 

### 7710·25 (Rev, 

### 5-95) PageS

# oued 3. Impurities
. (a) Identify each impurity that may be reasonably anticipated tobe present in the chemical substance as manufactured for commercial purpose.

, CAS Registry Number ifavailable. Ifthere are unidentified impurities, enter "unidentified."

Estimate the maximum
. % of Ifthere are' estimate their total %. and CAS Registry 

## Unknown

identified 

### in subsection 1or2. 

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

### 5. Trade identification

- List trade names for the new chemical substance identified in subsection 

### I or

### 2. 

# D Mark (X) this box ifyou attach 

### a continuation sheet. 

### 6. Generic chemical name ­ Ifyou claimchemical identify asconfidential, you must provide a generic name for your substance the specific chemical identity ofthe 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. 

## Acrylic Acid Ester Maximum percent Provide the

dential

resulting from the manufacture, processing, use, ordisposal ofthe new chemical substance. Provide the CAS Registry CAS Number Confidential

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

# PartI
-­ GENERAL INFORMATION

-- Continued Section 

## C·· PRODUCTION, IMPORT,AND USE INFORMATION: Mark (X) the "Confidential" box nextto any item you claim as confidential. 

### 1. 

### Production volume •• Estimate the 

### maximum production volume during the first 12 months ofproduction. Also estimate the maximum**producti~n** 

### voluml1 for any consecutive 12-month period during the first three years ofproduction. Estimates should be on.100% 

### new chemical substance basis. For a Low Volume Exemption application, ifyou 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. Ifgranted, you are bound to this volume Maximum first 12-monthproduction (kg/yr) Maximum l2-month production (kglyr) Confi- Binding 000% 

### new chemical substance basis) (100% 

### newchemical substance basis) dential Option Mark (x) 

# X 2. Use Information•• You must make separate confidentiality claims for the description ofthe category ofuse, the percent ofproduction volume devoted to each category. the formulation of the new substance, and otheruse information. Mark (X) 

### the "Confidential" Box next to any item you claim as confidential. 

### a. (l) -­ 

### Describe each intended category ofuse ofthe new chemical substance by function and application" (2)

-­ Mark (X) 

### this column ifentry column (I) is confidential business information (CBI). 

## (3) Indicate your willingness to have the information provided in column (I) binding. (4)

-­ Estimate the percent oftotal production for the first three years devoted to each category ofuse. (5) -­ 

### Mark (X) 

### this column ifentry in column (4) is confidential business information (CBI). (6)

-­ 

### Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, orgels as manufactured for commercial purposes at sites under your control associated with each category ofuse. (7) -­ 

### Mark (X) 

### this column ifentry in column (6) is confidential business intormation (CBI). (8) Indicate %

### ofproduct volume expected for the listed "use" sectors. Mark more than onebox ifappropriate. Mark (X) 

### to indicate your willingness to have the use type provided in (8) binding. (9) -­ 

### Mark (X) 

### this column ifemr (ies) in column (8) is (are) confidential business information (CBI). Category ofuse (I) CBI Binding 

### Produc- CBI %in CBI %ofsubstance expected per use CBI Option 

### tion% Form­ (8) 

### (by function and application i.e. adispersive dye Mark (x) 

### ulation Site- Con-* Indus- Com- Binding for finishing polyester fibers) (2) [J) (4) 

### (5) (6) (7) 

### limited sumer trial mercial Option (9) 

# X X X X



# I

* Ifyou have identified a "consumer" use, please provide on acontinuation sheet adetailed description ofthe use(s) ofthis chemical substance in consumerproducts.

In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. DMark (X)

### this box ifyou attach acontinuation sheet. b. Generic Ifyou claimany category ofuse description in subsection 2a as confidential. enterageneric description ofthatcategory. Read the use Instructions Manual forexamples ofgeneric use descriptions.


### .. - -.**~** .... 

### description 

### ---­ 

### Open Non-Dispersive (Acrylate Resin) 

# n IIIIIIII 

# jr'\

# l'~~. 

# i\\/ 

# - 'li**~1I ~,-,J**  r

# I IiI.i 

## l...1li 

# ... D Mark (X)

### this box ifyou attach acontinuation sheet. 3. HazardInformation

-­ Include in the notice acopy ofreasonable facsimile ofany hazard warning statement, label, material safety data sheet, orother Binding



### information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipmentorpractices Option 

### for the safe handing, transport, use, ordisposal ofthe new substance. List in part III hazard information you include. Mark (X) 

# [8J Mark (X) 

### this box ifyou attach hazard information,
EPA FORM 7710-25 (Rev. 5·95) Page 7box next to any tern you claim 

### Complete section A for each type ofmanufacture. processing, oruse operation involving the new chemical substance at industrial sites you Importers do not have to complete this section for operations outside the U.S.: however, you may still have reporting requirements if See instructions manual**~n~** dential



# X control. there are futther industrial or use after You must describe these 1. ofthe site at which the on will oceur.

Site address (number and street) City, County. ZIPcode 

### Ifthe same operation will occur at more than one site. enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates oroperations, include all the information requested in this sectton for those sites as attachments.

I. Batch 

# X X
Maximumkglbatch (iIXiCk new cftemic,I I Hours/batch Batches/year );Ub.,lam:el I I I 2. Continuous d. Process description Mark (X) to indicate your willingness to have your process description binding. 

# X (I) Diagram the major unit operation steps and chemical conversions. Include interim storage and transportcontainers (specify- e.g. 5 gallon pails, 55 drum, rail car, tank truck, etc.). (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents. catalysts. etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency 

### ifnot used daily orper batch.). (3) Identify by numberthe points ofrelease, including small or intermittent releases. to the environment ofthe new chemical substance. 

### See Attached. 

# PUBLIC COpy

Mark (X) this box if attach a continuation sheet.
EPA FORM 7710-25 (Rev. 5-95) Page 8

# Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A.. INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER .. Continued 2. OccupationalExposure·. You must make separate confidentiality claims for the description of ,:"orker

### activ~ty, physical form ofthe new chemical substance, numberofworks exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any Item you claIm as confidenlla1. (I) 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 colunm ifentry in column (\) isconfidential business infomJation (CBI). (3) -- Describe any protective equipment and engineering eontrols used toprotect workers. (4) and (6) Indicate your willingness to have the information provided in column (3) or (5) binding. (5)
__ Indieate the physical formes) ofthe new chemical substance (e.g
.. solid: crystal, granule, powder, ordust) and % new chemical substance (ifpart of

### a mixture) at the time ofexposure. (7)

-- Mark (X) this column 

### ifentry in column (5) isconfidential businessinformation (CBI). (8)

-- Estimate the maximum number ofworkers involved in each activity for all .,ites combined. (9) -- Mark (X) this column ifentry in column (8) is confidential business information (CBI). (\0) and (\ I) Estimate the maximum duration ofthe activity for any worker in hours perday and days per year. (12)

-- Mark (X) this column ifentries in columns (10)and (II) are confidential business information (CBI). 

# I BIO(hng 

# IPhYSIcal form,(s) 

# I Blnumg Worker activity eBJ ProtectiveEquipment! em # of eBI Maximu duration eBI m (i.e., bagdumping, filling drums) Engineering Controls Option Mark IX) and % new substance Option Mark (X) Workers Exposed Hrs/day Days/yr (I) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12) 

# x 

# x x x

I

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

### 3. Environmental ReleaseandDisposal You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (I) -- Enter the number ofeach release point identified in the process description, part II, section A, subsection Id(3). (2) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kglbatch). (3) Mark (X) this column ifentries in columns (I)and (2)are confidential business information (CBI). (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual). surface water, on-site oroff-site land or incineration, POTW, orother (specify» to which the new substance will be released from that release point. (5)

-- a. Describe control technology, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. For releases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA 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 ifentries in columns (4) and (5) are confidential business information (CBI). (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant DischargeElimination System)numbers for direct discharges or NPDES numbers ofthe POTW (Publici Owned Treatment Works). Mark (X) ifthe POTW name or NPDES 

### # is confidentialbusiness information (CBI). Release Amount ofnew substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBf Number' released release e.g.**~ta,,'kair** Bmding (I) (2a) (2b) I (4) I Mark IX) (3) (Sa) (5b) (6) 

# X I I 

# X I I 

# " I I 

# ,...**fIIIII~** 

# .... r-\ 

# .. I-'**~~**

# ~a 

# lu**~lJ IL~**  

# I
... 

# .. '-I 

# , I 

# , I
I I I I (7) Mark (X) the provide NPDES# CBI 

# D POTW provide name(s) below: CBI 

# D Navigable 

# o Other

- Specify f-­ destination(s) of waterway releases to water. 

# D Mark (X) this box 

### ifyou attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 9

# Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section B..INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B fortypical processing oruse operationsinvolving the new chemical substance at sites you donot control. Importers do not have to complete this section for operations outside the U.S.; however, you must report any processing or use activitiesafter import. See the Instructions Manual. Complete a separate section Bj(Jreach type of processing. orlise operation involving the newchemical substance. Ifthe same operation is performed at more than one site describe the typical operanon commCfn to these sites. Identify additional sites on a continuation sheet. 

### 1. Operation Description To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. (l) 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, identifyby letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kglbatch, on an 100% new chemical substance basis), andentry point ofall feedstocks (including reactants. solvents andcatalysts. etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch). (3)

-- Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enterthe # ofsites (rememberto identify the locations of these sites on 

### a continuation sheet): 

### # ofsites



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

### 2. Worker ExposurelEnvironrnental Release (I) From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2)

-- Estimate the number ofworkers exposed for all sites combined. (4)

-- Estimate the typical duration ofexposure per worker in (a) hours perday and (b) days per year. (6)

- Describe physical form ofexposure and 

### % new chemical substance (ifin mixture). and any protective equipment and engineering controls. ifany, used to protect workers. (7)

--Estimate the percent ofthe new substance as formulated when packaged orused as a final product. (9) From the process diagram above, enterthe number ofeach release point. Complete 9-13 for each release point identified. (10)

-- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day orkg/batch). (12) Descnbe media ofrelease i.e. stack air, fugitive air(optional-see Instructions Manual), surface water. on-site oroff-site land orincineration. POTW, or other (specify) and control technology, ifany, that will be used to limit the release ofthe new substance to the environment. (14)

-- Identify byproducts which may result from the operation.

(3), 

### (5), (8), (II), (13) and 

### (15)

-- Mark (X) this column ifany ofthe proceeding entries are confidential business information (CBI). Letter # of

of Workers Act- Exposed ivity (I) (2) CBI

(3) Duration of Exposure (4a) I (4b) CBl

(5) Protective Equip. I Engineering Controls! Physical Form and % new substance (6) % inFormulation

(7) 

# D CBI Release Number (8) (9)



# .'

# ... Amount of New Substance Released (lOa)' (lOb) CBI Media ofRelease & Control Technology (II) (12) 

# DV I CBI

(13)

(14) Byproducts: (15)



# o Mark (Xl this box ifyou attach a continuation sheet,

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

# OPTIONAL POLLUTIONPREVENTION INFORMATION Toclaim information in this section as confidential circle or bracket the specific information that vou 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 ofthe PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and saferprocesses orproducts available due to the new chemical substance. Source reduction includes the reduction in the amount ortoxicity ofchemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recyclingrefers to the reclamation ofuseful chemical components from wastes that would otherwise be treated orreleased as air emissions or water discharges, orland disposal. Descriptions ofpollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be eitherquantitative orqualitative. TheEPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks to otherenvironmental mediaor non-environmental areas (e.g., occupational orconsumerexposure). In addition, information on the relative costorperformancecharacteristics ofthe PMN substance to potential alternatives may be provided. 

# All information provided in this section will be taken into consideration during the review ofthis substance. See InstructionsManual and Pollution Prevention Guidancemanual for guidanceand examples. Describe the expected net benefits, such as (I) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation ofwaste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance. a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a greater overall risk to human health orthe environment.


## • PMN substance will be imported in 55 gal. Drums • Drum residue will be incinerated on site, drums are then crushed & recycled 

# PUBLIC COpy

D Mark (X) this box ifyou attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page II

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe form and test data and otherdata (including physicaUchemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section ofthe form to which it**rel~tes,** 

### ifappropriate. Number consecutively the pages ofthe attachments. 

### In the column below, enter the inclusive page numbers ofeach 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 ofthe notice form a sanitized version ofany attachment in which you claim information as confidential. Altachment name Attachment Confipage number(s) dential 

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### you attach acontinuation sheet. Enterthe attachmentname and number.

EPA FORM 7710-25 (Rev, 5-95) 

### Page 12

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ATTACHMENTS PAGES 13-26



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