u.s. ENVIRONMENTAL PROTECTION AGENCY 

Date of receipi 

PREMANUFACTURE 

NOTICE 03 NOV Ia M1r': rI 

ES Company Sanitized 

FormA 

AGENCY 

JnCI llle tUlQ.J lIU!lJUCl VI pd.!6.C~ 

in the Premanufacture Notice 

GENERAL INSTRUCTIONS 

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

not have actual data. 

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

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

• 	 If a user fee has been 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 User fee. 

Part I-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance. even if you claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you. but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in ,upport of your submission should reference your TS user fee identification 

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

If you claimed any information as confidential, a single sanitized copy must also be 

submitted. 

Part 11-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part It 

sections A and B of this notice. reproduce the sections as needed. 

Part III - LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully. Label 

each continuation sheet with the corresponding section heading. In Part 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 of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the 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 to reduce delays. 

that routinely accompany the development of consent orders or Significant New Use 

Rules. Except in the case of exemption applications (such as TMEA. LVE, LOREX) 

where cenain information provided in such notification is binding on the submitter when. 

the Agency approves the exemption application, checking a binding box in this notice 

does not by itself prohibit 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 a claim on the 

form, mark (X) the confidential box next to the information that you claim as 

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

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

also provide a sanitized version of the notice, (including attachments). For additional 

instructions on claiming information as confidential. read the Instructions Manual. 

TEST DATA AND OTHER DATA 

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

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

data are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

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

mQst be submitted if they do not appear in the open literature. You should clearly 

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

composition of tbe tested material should be characterized. Following are 

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

requirements of §720.50 of the Premanufacture Notification Rule (40 CFR Part 

720). 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes 	 Other data 0 Yes 

Health effects data 0 Yes 	 Risk assessments 

Environmental effects data 0 Yes 	 Structure/activity relationships 

Physical/Chemical Properties * 121 Yes 	 Test data not in the possession 

or control of the submitter 

A physical and Chemical properties worksheet is located on the last page of this 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) 

....:;;:;; o 	 LVE Modification o LOREX ModIfication

D 

IS THIS A CONSOLIDATED PMN? 	 o Yes

Mark (x) if any information in this notice is claimed as confident'"!. # of chemicals 


(Pre notice Communication # required. enter # on page 3) 


c 

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

1 ,;:rrei;;?j'3AFO=771~~' 0 
Public reporting burden for this collection of information is estimated to average 110 hours per response, including time for reviewing 

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

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

reducing this burden, to Chief. Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 40\ M. St., S,W" Washington, D.C. , 

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

CERTIFICATION 

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

I. 	 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 I, 

Section B, 

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

3. 	 I am submitting with this notice all test data in my possession or control and a description of all other data known to or 


reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 


Additional Certification Statements: 

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


statement that applies: 


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 $1 000 for an Intermediate PMN (defined @ 40 CFR 


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


o The Company named in Part I Section A is a small business concern under 40 CFR 700,43 and has remitted a fee of $100 

in accordance with 40 CFR 700,45(b). 

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

and low exposure exemption (LoRex) application in accordance with 40 CFR 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 of 40 CFR 723.50. 


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

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


o 
If this application is for an LVE in accordance with 40 PU-'B'~lGturuO'p¥e ma~ufactu~e of the exempted substance for commercial es 1 ear e date f th x r n 0 the 30 day 

review perIod. 

The accuracy of the statements you make in this notice should renect your hest prediction of the 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 of Authorized Official (Original Signature Required) Date 

Signature of agent - (if applicable) Date 

EPA FORM 7710-25 (Rev. 5·95) Page 2 

x 
X 

Confidential 

la. Person 

Submitting 

Notice (in U.S.) 

b. Agent (if Name of authorized official 

applicable) 

Company 

address (number and street) 

City, State, ZW 

Company 

Mailing address (number street) 

City, State. ZIP Code 

c. If you are submitting 

Joint Submitter (if Name of authorized 

applicable) 

2. Technical Name of authorized official 

Contact (in 

U.S.) 

Company 

Mailing address (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. If you 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 Binding Option 

Mark 

D X

D X

5. 	 Bona fide or import 

for the chemical substance covered by this notice, enter the notice number Mark (Xl II ~~~~. ~ D X if none 

I. Manufacture 	 , 6. Type of Notice - Mark (X) Only 	 :3 D Both

D Binding Option 

Mark (X) 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 3 
Section B·- CHEMICAL IDENTITY 

Complete 

lor class substances, see the Instructions Manual) 

a, Class of substance - 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. For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA 

Preferred Name must be provided. which ever is appropriate based on CA 9CI nomenclature rules and conventions). 

N/A 

c, Please' you used to develop or obtain 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 of the 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 of the reaction or process. 

(3) Indicate the range of composition and the typical composition (where appropriate), (4) Provide a correct representative or 

oartial chemical structure dial!ram. as comolete as can he known. if one can he reasonahlv ascertained, 

PUBLIC COpy 

attach a continuation sheet. 

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

below 1,000 absolute molecular weight of that composition, 

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

i) lowest number average molecular weight: 

ii} maximum weight % below 500 molecular weight: 

iii) maximum weight % below 1000 molecular weight: 

Mark (X) this box if attach a continuation sheet 

b, You must make separate confidentiality claims for monomer or 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 (if a number exists) of each monomer or other reactant used in the manufacture 

of the polymer, 

(2) Mark (Xl this column if entry in column (I) 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 (Xl this column if entries in columns (3) and (4) are confidential. 

(6) Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes, 

Mark this column if 

X 

X 

X 

X 

X 

Please identify which method you used to develop or obtain the 

U Method J (CAS Inventory Expert Service - a copy of the 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 polymer that is consistent 

e, a correct represe ve or partial chemical structure diagram, as as can be known, if one can be reasonably ascertained, 

PUBLIC COpy 

this box if you attach a continuation sheet. 

EPA FORM 7710·25 (Rev, 5-95) PageS 
oued 

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

, CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

Estimate the maximum . % of If there are' estimate their total %. 

and CAS Registry 

Unknown 

identified in subsection 1 or 2. 

D 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. 

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

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

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

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

Acrylic Acid Ester 

Maximum 

percent 

Provide the 

dential 

resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

CAS Number Confidential 

EPA FORM 7710-25 (Rev. 5-95) Page 6 
Part I -­ GENERAL INFORMATION -- Continued 

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

Mark (X) 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 

producti~n voluml1 for any consecutive 12-month period during the first three years of production. Estimates should be on. 100% new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 

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

Maximum first 12-month production (kg/yr) Maximum l2-month production (kglyr) Confi- Binding 

000% new chemical substance basis) (100% new chemical substance basis) dential Option 

Mark (x) 

X 

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

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

you claim as confidential. 

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

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

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

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

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

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

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

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

Option tion% Form­ (8) 

(by function and application i.e. a dispersi ve 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 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products. 

In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product. 

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

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

use Instructions Manual for examples of generic use descriptions. .. - -. ~ .... 

description ---­

Open Non-Dispersive (Acrylate Resin) n IIIIIIII jr'\ l'~~. i\\/ - 'li ~1I ~,-,J rIiI.i l...1li ... I

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

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

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option 

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

[8J Mark (X) this box if you attach hazard information, 

EPA FORM 7710-25 (Rev. 5·95) Page 7 
box next to any tern you 

claim 

Complete section A for each type of manufacture. processing, or use 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. 

of the site at which the on will oceur. 

Site address (number and street) 

City, County. ZIP code 

If the same operation will occur at more than one site. enter the number of sites. Identify the 

additional sites on a continuation sheet, and if any of the sites have significantly different 

production rates or operations, include all the information requested in this sectton for those 

sites as attachments. 

I. Batch 

X 


X 


Maximum kglbatch (iIXiCk new cftemic, I I Hours/batch Batches/year 

);Ub.,lam:el I 

I 

2. Continuous I

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 transport containers (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 of all starting materials and 

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

used daily or per batch.). 

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

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. 	 Occupational Exposure·. You must make separate confidentiality claims for the description of ,:"orker activ~ty, physical form of the new chemical substance, 

number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any Item you claIm as 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 if entry in column (\) is confidential business infomJation (CB I). 

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

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

(5) __ Indieate the physical formes) of the new chemical substance (e.g .. solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) 

at the time of exposure. 

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

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

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

(\ 0) and (\ I) Estimate the maximum duration of the activity for any worker in hours per day and days per year. 

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

Worker activity eBJ Protective Equipment! I BIO(hng IPhYSIcal form,(s) I Blnumg em # of eBI Maximu duration eBI 

m 

(i.e., bag dumping, 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 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. 

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

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

(3) Mark (X) this column if entries 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 or off-site land or incineration, POTW, or other (specify» to 

which the new substance will be released from that release point. 

(5) -- a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet. for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). 

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

NPDES numbers of the POTW (Publici Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBf 

Number' released release 

(I) (2a) (2b) e.g. ~ta,,'kair Bmding I 

(4) 	 I Mark IX) (3) 	 (Sa) (5b) (6) 

X I 

I X I 

I 

" 

I 

I 

,... r-\ fIIIII~ ....
 .. 


I-' ~a ~~

'-I ... ..
 lu ~lJ IL~I
 , 

I 

, 

I 

I 

I 

I 

I 

(7) Mark (X) the D provide NPDES # CBI POTW provide name(s) below: CBI D Navigable o Other - Specify f-­ destination(s) of waterway 

releases to water. 

D Mark (X) this box if you 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 for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this 

section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate 

section B j(Jr each type ofprocessing. or lise operation involving the new chemical substance. If the 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, identify by 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), and entry point of all feedstocks (including reactants. solvents and catalysts. etc) and all 

products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- 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 

o Mark (X) this box if you 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 acti vity described. 

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

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

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

protect workers. 

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

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

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

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

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

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

(3), (5), (8), (II), (13) and (15) -- Mark (X) this column if any of the 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) 

% in 

Formulation 

(7) 

D 

CBI Release 

Number 

(8) (9) 

.' ... 

Amount of 

New 

Substance 

Released 

(lOa)' (lOb) 

CBI Media of Release 

& Control 

Technology 

(II) (12) 

DV 

I 

CBI 

(13) 

(14) 	 B yproducts: (15) 

o Mark (Xl this box if you attach a continuation sheet, 

EPA FORM 7710-25 (Rev. 5-95) Page 	 10 
OPTIONAL POLLUTION PREVENTION INFORMATION 


To claim 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 

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

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

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

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

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

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

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

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

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

of risks to other environmental media or 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 Instructions Manual and Pollution Prevention Guidance manual for guidance and 

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 of waste materials through recycling, source reduction or other means; (4) a 

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

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

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

substance that poses a greater overall risk to human health or the 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 if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page II 
Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form and test data and other data (including physicaUchemical properties and 

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

which it rel~tes, 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. 

Altachment name Attachment Confipage number(s) dential 

X I 

X 

X 

X 

X 

X 

I 

I 

I 

I 

I I 

.. 

r\ .... " fII\ ,., "'" "" ~~ , I I 1-1' I • r - - - I 

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

EPA FORM 7710-25 (Rev, 5-95) Page 12 
· . 


ATTACHMENTS 


PAGES 13-26 


PUBLIC COpy 

,~