PMN Page 1 ; Page 1 of 18 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

nter ttte torat ntnnoof ot Pas~ 

in the Prerttanufacture Notice 

" 

" 

Form A 

Dae of receipt 

oved . O.M .B . No. 2070-0012. A 00 v^" 

AGENCY USE ONLY 

Company Sanitized 

GENERAL INSTRUCTIONS 

1 8 

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 informaboa A letter 

in support 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 II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

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

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

Part 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 wart EPA to consider in evaluating the new 

substance. On page 11 of this form, space has been provided for you to describe 

pollution prevention and recycling information you may have regarding the new substance. 

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 

certain 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 yon claim as confidential . 

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

confidential. 

a sanitized version of the notice . fincludin¢ attachments). For additional itnttuctlons on 

claimingjpformation as confidential, read the Instructions Manual . 

~ ~P.~tark (x) if any information in this notice is claimed as confidential. 

" 

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, must be submitted if they do not appear in the open litetature. You should 

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

chemical composition of the tested material should be characterized. Following 

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

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

Part 720). 

Test Data (Check Below any included m this notice) 

" Environmental fate data 

" Health effects data 

" Environmental effects data 

" Physical/Chemical Properties' 

P. 1 

Yes 

Risk assessments 

Structura/activity relationships[] 

Test data not in the possession 

or control of the submitter Q 

A physical and chemical properties worksheet is located on the last page of this form . 

TYPE OF NOTICE 

® 

© 

® 

® 

® 

TS uuuuLOJ I I I 

0 

0 

0 

Yes 

Yes 

Yes 

Yes 

(Check Only One) " 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

SNUN (Significant New Use Notice) 

TMEA (Pest Marketing Exemption Application) 

LVE (Low Volta--a Exemption) Q 40 CFR 723.50(cxi) _ 

LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(cx2) 

LVE Modification 

IS THIS A CONSOLIDATED PMN? 

# of chemicals or polymers 

ice Communication # 

Other data 

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

not have actual data . 

Before you complete this form, you should read the "Instructions Manual 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, Washington Financial Management Center (3303), P.O. 

360399M, Pittsburgh, PA 15251-6399, Atta . TSCA User fee. 

® 

a 

1 

enter # on 

LOREX Modification 

Yes 

A FORM 7710-25 (Rev. 5-95) Replaces previous editiotns of EPA Form 7710-25. 
p. 2 

" PMN Page 2 ; Page 2 of 18 

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 tnaintailn ^Q 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 Director, Collection Strategies Division (2822), U.S . Environmental Protection Agency, 1200 Pennsylvania Ave., N.W., I 

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

CERTIFICATION -- A Printed copy of this signature age, with original signature, must be submitted 

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

1 . The company named in Part I, section A, subsection 1 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 ail 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: 

.® The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

0 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

700.43) in accordance with 40 CFR 700.45(b), or 

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements: 

0 The manufacturer submitting this notice intends to manufacture or import the new chemical substance for cornmercial 

purposes, other than in small quantities solely for research and development, under te terms of 40 CFR 723.50. 

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

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

E] If this application is for an LVE in accordance with 40 CFR 723 .50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period. 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance 

described herein. An knowing and willful misinterpretation is subj ect to criminal nal pursuant to 18 USC 1001. Conridential 

Signature and title of Auttarized Official (Original Signature Required) Date r1 

\ 

Signature of agent - (i f applicable) Date 

© 

EPA FORM 7710-25 (Rev. 5-95) Page 2 
p. 3 

PMN Page 3 ; Page 3 of 18 

Section A - SUBMITTER IDENTIFICATION 

la Person Name of authorized official Position 

Submitting 

Notice (in U.S.) 

~1J Company 

Mailing address (number and street) 

City, State Postal Code 

b. Agent (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State Postal Code ~ Telephone (include area code) 

c. If you are submitting this notice as part of a joint submission, mark (X) this box. 

Joint Submitter (if Name ofauthorized official postttat 

applicable) 

Company 

Mailing address (number and street) City, state 

Province, Country Postal Code Telephone (include country or area code) 

2. Technical Name ofauthorized official Position 

Contact (in 

U.S.) 

company - 

Mailing address (number and street) 

City, State Postal Code Telephone (include area code) 

3. If you have had a ptenotice communication (PC) concetning this notice and 

EPA assigned a PC Number to the notice, enter the number. Mark (X) 

if none 

4 . If you 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 PMN Mark (X) ~--it 

number assigned by EPA (i .e. withdrawn or incomplete} -- 

if rtort e ILylJ`~JI 

5. If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical substance covered by this notice, ewer the notice number 

i d b EP Mark (X) ass gne y A. 

----~ ifnone e I~'JV/Y-\/ 

Type of Notice - Mark (X) 

Part I - GENERAL INFORMATION 

Mark the "Confidential" box next to an subsection ou claim as confidential 

0 

Manufacture 

Only 

Binding Option 

Mark 7~{ 

i 2' 1:1 

Import I 

Only I 3 . 

I Binding Option 1 

i Mark (X) i 

Both 

Confidential 

EPA FORM 7710-25 (Rev. 5-95) Page 3 
PMN Page 4 ; Page 4 of 18 

Part I - GENERAL INFORMATION - Continued 

Section B - CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth 

Collective Index 9C of CA nomenclature rules and conventions . 

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

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

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. ~ Confi- Identi the name, company, and address of that person in a continuation sheet. dential 

1 . Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances see the Instructions Manual) r~ - 

a. Class of substance - Mark (X) 171 Class 1 or Class 2 ~tLX~~L 

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 , I 

which ever is appropriate based on CA 9CI nomenclature rules and conventions) . 

L 

X` 

c. Please identify which method you used to develop or obtain the specified chemical identi ntf , omtation reported in this notice: (check one) . 

® Method I (CAS Inventory Expert Service - a copy of the Identification F I Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must ¬.___1be 

submitted as an attachment to this notice) 

d . Molecular formula CBI CAS Registry Number 

(if a number already 

exists for the substance) 

e. For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance, provide a correct representative or partial cihetnical structtue diagram, as complete as can be known, if ate can be reasonably ascertained. Please see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 4 
PMN Page 4a ; Page 5 of 18 

t~or a class 2 substance - (1) list the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. 

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

e. (1) List the immediate precursor substances with their respective CAS Registry Numbers. Confi- Name (CAS #) 

dential 

e. (2) Describe the nature of the reaction or process. 

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

--^c 

U Maric this bax if u aitach a continuation sheei 

EPA FORM 7710-25 (Rev . 5-95) Page 4a 
PMN Page 5 ; Page 6 of 18 

Part I - GENERAL INFORMATION - Continued 

Section B - CHEMICAL IDENTITY INFORMATION - Continued 

2. Polymers (For a definition of polymer, seethe Instructions Manual .) C 

dential 

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, w solvents) below 500 an d 

- 

F' x '// 

below 1,000 absolute molecular weight of that composition. 

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

(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 you attach a continuation sheet. 

b . You must make separate confidentiality clairas for monomer or other reactant identity, composition information, and residual information. Mark (x) the 

"Confidential" box next to any item you claim as confidential 

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

the polymer. 

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

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

(4) - Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of 

description on the TSCA Chemical Substance Inventory. 

the polymer 

(5) - Mark (X) this column if entries in columns (3) and (4) are confidential. 

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

commercial purposes. 

(7) - Mark this column if en in column 6 is confidential . 

Monomer or other reactant and CAS Registry Number Confidential 

Typical 

composition 

Include in 

identity 

Confidential Maximum 

residual 

Confidential I 

1 2 3 

% 

4 5 

F1 

6 

% 

7 

I N 

% 

~ u % N/ I °,° 

7 

F~ l % 

, 

°.° 7 

F F-1 1 °,° 

E:1 

_ 0- 

° ,. 

F F-1 1 °,° _ 

E:1 

1- . 

°,° 

1 F1 1_1 

°,. 

1 11 

. 

1-1 

--- °° 

- 

F~ 

- °,° 

~ o % °,o - o o °~ °,° o 

o o °,° °,° - o o % °,° o 

o °,. o °,° 

Mark (}I) this box if you attach a continuation sheet. o % o % o 

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

PMN Page 5a ; Page 7 of 18 

c. Please identify which method you used to develop or obtain the snecified chemical identity information reported in this notice (check one). 

M 

Method 1 (CAS Inventory Expert Service - a copy of the identification report 1 I Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as an attachment FJto this notice) 

CBI 

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

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

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

see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance. 

' 

, 

I 

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

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

PMN Page 6 ; Page 8 of 18 

Part I -- GENERAL INFORMATION - Continued 

Section B - CHEMICAL IDENTITY INFORMATION - Continued 

3. Impurities 

(a) - Identify each impurity that maybe reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide 

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

) - Estimate the maximum weight % of each impurit y. If there are unidentified impurities, estimate their total we %. 

Impurity and CAS Registry Number Maximum Confipercent dential 

a (b 

% 

% 

O/° 

O/° 

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

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

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

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

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 that reveals 

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

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

~~ ~+~ rn e~c, ~-~ ~ ~ 

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 Registry 

Number if available. 

Byproduct CAS Registry Number Confi1 (2 dential 

® 

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

EPA FORM 7710-25 (Rev . 5-95) Page 6 
P. 9 

PMN Page 7 ; Page 9 of 18 

Part I -- GENERAL INFORMATION -- Continued 

Section C - PRODUCTION , 51PORT, AND USE INFORMATION: 

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

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

production volume for any consecutive 12-month period during the first three years of production . Estimates should be on 10046 new chemical I I 

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

10,000 k r speci fy the volume and mark x in the bindin box. If granted, you are bound to this volume i 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) rifid 

Binding 

O tion (100% new chemical substance basis) (100% new chemical substance basis) ential p 

Mark (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 . j 

a. (1) -Describe each intended category of use of the new chemical substance by function and application. (2) -Mark (X) this column if entry column (1) is 

onfidential business information (CBI). (3) -Indicate your willingness to have the infomtation provided in column (1) binding. (4) -Estimate the percent of total 

roduction for the first three years devoted to each category of use. (5) --Mark- (X) this column if entry in column (4) is confidential business information (CBI). (6) - 

timate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under 

our control associated with each category of use . (7) -Mark (X) this column if entry in column (6) is confidential business information (CBI). (8) -Indicate % of 

roduct volume expected for the listed "use" secton. Mark more than one box if appropriata Mark (X) to indicate your willingness to have the use type provided in (8) 

utdin . 9) -Marl: this column if ie.s) in column (8 is are confidential business infomution (CBI) . 

Category of use (1) (by function and application i .e. a CBI Binding Prod- CBI %in CBI % of substance expected per use CBI 

dispersiva dye for finishing polyester fibers) MRAt 

uccion 

% 

Formu 

lation 

(8) 

(:Cl 

(2) (3) (4) (5) (6) (7) sit, 

tmuted 

Camuska 6tdwodd Cammen6al Binding 

'on 

(y) 

% . % 

X, 

% % 

% 5b - - --- 

_ - 

11 111 1 % 

% 

l 

- - ----- - 

E I % 

[] I 

% 

F1 1 

--- ---- 

F1 1 I 

3'0 % _ -- 

u 

u 

_ 

1 E1 11 

" If you have identified a "consumei" use, please provide on a continuation sheet a detaib;d 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 commumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product 

(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 category. Read the Instruction 

description Manual for examples of generic use descriptions. 

U4eU 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 ~s Option 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 handing, transport, use, or disposal of the new substance. List in part III hazard information you include. 

Merk (X) this box if you attach hazard information. 

EPA FORM 7710-25 (Rev . 5-95) Page 7 
p. 10 

PMN Page 8 ; Page 10 of 18 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you 

claim as confidential 

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

control . Importers do not have to complete this section for operations outside the U.S . ; however, you may still have reporting requirements if 

there are further industrial processin g or use operations after import. You must describe these ope rations. See instructions manual 

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

Name 

Site address (number and street) 

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 sheet, and if any of the sites have significantly different 

production rates or operations, include all the information reque .;u:d in this section for those 

sites as attachments. 

Mark (X) this box if you attach a continuation sheet. b. Type -- ~-->1 

Mark (X) Manufacturing Processing Us e I` ~~~( ~l 

c . Amount and Duration --Complete 1 or 2 as appro priate 

Maximum kg/batch poo9s new chemiesi 

sabsiance) 

Hours/batch Batches/year 

1 . Batch 

Maximum kg/day(iooxnawctnnicad Hours/day Days/year 

suesmnce) 

2. Continuous 

d. Process description u 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 a 100% new chemical substance basis), and entry point of all starting materials and 

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

used daily or per batch.). 

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

at the same step, assign a second release number for the second medium. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 8 
PMN Page 8a ; Page 11 of 18 

EPA FORM 7710-25 (Rev. 5-95) Page 8a 
PMN Page 9 ; Page 12 of 18 

Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUMMER - Continued 

2Occupational . Exposure - You must make separate confidentiality claims for the description of worker activity, 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 confidential. 

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

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

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

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

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

time of exposure. 

(7) --Mark (X) this column if entry in column (5) is confidential business information (CB4. 

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

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

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

12 -- Mark ) this column if entries in columns 10 and 11 are confidential business' nformation (CBI) . 

Worker activity CBl Protective Equipment/ Bid4 s Physical aumling CBI # of CBI Maximum duration CBI 

fonns(s) 

(i .e., bag dumping, filling drums) 

1 (Z) 

Engineering Controls 

3 

~ 

W 

(4) 

and 

(5) 

Option 

(6) (7) 

Workers 

Ex 

posed 

(9) 

Hrs/day 

(1~) 

Daystyr 

(11) (12) 

t 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9 
PMN Page ga ; Page 13 of 18 

3. Environmental Release and Disposal -- You must make separate confidentiality claim 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 l 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 kg/batch). 

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

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Mantral), 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 I 

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 j 

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

(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 NPDE : (,National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES rnmtbers of the POTW blicl Owned Treatment Works). Mark ifthe POTW name or NPDES # is confidential business information CBI' . 

Release 

Number 

(1) 

Amount of new 

substance released 

(2a) (2b) 

CBI Medium o f 

release 

~g _k. : 

~ 

Control technology and efficiency (you may wish to optionally attach 

efficiency data 

Bvd'v~g 

CBI ' 

i 

) (4) (Sa) M

X) 

(5b) (6) ' 

IK I 

rl 

L/N 

1E 1 [] 1 11 

I 

0 1 

E 

:1 1 El 

(7) Mar k (X) the d 

. 

estination(s) of releases to water. NPDES # CBI 

POTW--provide 

name(s) 

Navigable waterway-- 

provide name(s) 

Other--Specify 

Pun 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9a 
PMN Page 10 ; Page 14 of 18 

Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section B - INDUSTRIAL _SITES CONTROLLED BY OTLLRS 

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 for each type of 

processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the typical operation common to these 

sites. identify additional sites on a continuation sheet. 

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

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

cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity. (2) - Either in the diagram or in the text field 1(b) below, provide the 

identity, the approximate weight (by kg/day or 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) - Either in the diagram or in the 

text field 1(b) below, identify by number the points of release, including small or intermittent releases. to the environment of the new chemical substance. (4) Please enter 

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

# of sites CBI 

Diagram the major unit operation steps and chemical conversions. . . 

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

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

EPA FORM 7710-25 (Rev. 5-95) Page 10 
p. 15 

PMN Page 10a ; Page 15 of 18 

2. Worker Exposure/Environmental Release 

(1) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

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

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

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

workers. 

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

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

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

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

(3) (5), (8), (11), (13) and (15) -- Mark (X) this column if an of the proceeding entries are confidential business information (CBI). 

e # of CBI Duration Of C~ Protective Equip. /Engineering Controls/Physical Form and/ a/o new substance °i° in 

FormCBI 

of 

tiWorkers 

Exposed 

Exposure ulation 

vity 

(1) (2) (3) (4a 4b (5) 6 (7) (8) 

------ 

- -- 

o a o 

Release 11 , 0 . 0 

Number 

Amount of 

New 

CBI Media of Release & Control Technology CBI 

Substance 

Released 

(9) 10a) (lOb) 11 (12 (13) 

-- ----- 

_-_ _ F-1 a 

_ 

a o 

o F] El 11 

14) -- Byproducts : (15) 

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

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in the follo 

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 nonenvironmental 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 PMN Instructions 

Manual and Pollution Prevention Guidance manual for guidance and examples. 

EPA FORM 7710-25 (Rev. 5-95) Page 10a 
p. 16 

. PMN Page 11 ;Page 16 of 18 

Optional Pollution Prevention Information (Continued) Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation 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 substa .ce that poses a greater overall risk to human health or the environment. 

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

EPA FORM 7710-25 (Rev . 5-95) Page 11 
p. 17 

PMN Page 12 ; Page 17 of 18 

Part III -- LIST OF ATTACHMENTS 

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

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

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

numbers of each attachment. Electronic attachments can be identified by filename . 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on 

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 an attachment in which you claim information as confidential. 

# Attachment name Attachment Filename Attachment 

e number(s ) 

Confidential 

EL 

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 
p. 18 

PMN Page 13 ; Page 18 of 18 

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

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice. Identify the property measured, the page of the notice at which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . If the attachments 

are electronic, give the attachment number (found on page 12) at (b). The physical state of the neat substance should be provided. 

These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

formulations should be so noted (% PMN substance in -J. You are not required to submit this worksheet; however, EPA strongly 

recommends that you do so, as it will simplify review and ensure that confidential information is property protected. You should submit 

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

Property k (X 

if 

Page 

number 

Value easured o 

Estimate 

cont;- 

dentist 

(a) provide d ib) (c) or E 

Mark (X) 

(d) 

Physical state of neat substance D (s) (1 

Vapor pressure 

Temperature ° C ~ Torr 

Density/relative density g/cm3 

Solubility 

@ Temperature )1a °C 

t J Solvent C I6 /~ 7~I~tr~.( (2lc¢u'f, ~ I , ~ 

Solubility in water Temperature -C °C ® ,~ da ,~, L 

Melting temperature 0C Q 

Boiling / sublimation tem rature torr pressure El 0C 

Spectra F-1 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volatilization from water 

Volatilization from soil E:1 0 

H concentration 

Flammability 

Ex lodabilit 

Adsorp tion / coefficient 

Other - Specify F-1 0 

Other - Specify 

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

ATTACHMENT 

PAGE 13