## PMN Page 1 ; Page 1 of 18 U .S. ENVIRONMENTAL PROTECTIONAGENCY

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 claimthe 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. Ifyou 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 bedescribed in Part II, sections Aand Bofthis notice, reproduce the sections as needed. Part III-LIST OF ATTACHMENTS Attach additional sheets ifthere 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 EPAto consider in evaluating the new substance. On page 11 of this form, space has been provided for you to describe pollutionprevention and recycling information youmayhave regarding the new substance . So-called "binding" boxes are included throughout this formfor 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 ofexemption 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 fromlater deviating fromthe information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claim on the form, mark (X) the confidential box next to the information that yon claimas confidential . To assert a claimin an attachment, circle or bracket the information you claimas 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 ANDOTHER DATA You are required to submit all test data in your possession or control and to provide a description of all otherdata 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 onan analog. Also, the chemical composition of the tested material should becharacterized . Following are examples of test data and otherdata. Data should be submitted according to the requirements of §720 .50of the Premanufacture Notification Rule (40CFR Part 720) . Test Data (Check Belowany 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

® © ® ®

® 

# uuuuLOJ I I I

TS

0 

# 0 0 Yes Yes Yes Yes (Check Only One) " PMN (Premanufacture Notice) INTERMEDIATE PMN

(submitted in sequencewith final product PMN) SNUN (Significant New

Use Notice) TMEA (Pest Marketing Exemption Application) LVE (Low

Volta--a Exemption) Q 40 CFR723

.50(cxi) _ LOREX (Low

Release/LowExposure Exemption) @ 40 CFR723

.50(cx2) LVE Modification IS THIS A CONSOLIDATEDPMN? # ofchemicals or polymers ice Communication # Other data You must provide all information requested in this formto the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do not haveactual 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 CFR700 .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 EPAForm7710-25.

## 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 ^Qthe 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-- APrinted 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 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 of the date of submission. 3. I am submitting with this notice ail 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 user fee certification statement that applies

: .® The Company named in Part I, Section Ahas remitted the fee of $2500 specified in 40 CFR 700 .45(b), or 0The Company named in Part I, Section Ahas remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 700 .43) in accordance with 40 CFR 700 .45(b), or 0The Company named in Part I Section Ais a small business concern under 40 CFR 700 .43 and has remitted a fee of $100 in accordance with 40 CFR 700 .45(b) . Ifyou 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 40CFR 723.50(c)(2), check the following certification statements: 0The 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 ofthis 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] Ifthis application is for an LVE in accordance with 40 CFR723.50(c)(1), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year of the date of the expiration ofthe 30 day review period. The accuracy of thestatements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An knowing and willful misinter pretation is sub j ect to criminal nal pursuant to 18 USC 1001. Conridential Signature and title of Auttarized Official (Original Signature Required) Date r 1 \ © Signature of agent -(ifapplicable) 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 ofauthorized official Position Submitting Notice (in U

.S.) ~1 J Company 

### Mailing address (number and street) City, State Postal Code b. Agent (if Name of authorized official Position applicable) 

### Company

Mailing address (number andstreet) 

### City, State Postal Code ~ Telephone (include area code) c. If you aresubmitting this notice as part of a jointsubmission, 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 aptenotice 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. withdrawnor incomplete} -- if rtorte ILylJ`~JI 5 . If you have submitted a notice ofBona fide intent to manufacture or import for thechemical 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 currentlycorrectChemical Abstracts (CA) name ofthe substance basedon the ninth

Collective Index 9C ofCA nomenclature rules and conventions . Mark the "Confidential" box next to any item you claim

as confidential 

### Completeeither 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 ItemI or 2), mark (X) the box at the right . Confi- ~ Identi the name, com pany, and address of that p erson in a continuation sheet. dential 

### 1 . Class 1 or 2 chemical substances (fordefinitions ofclass 1 and class 2 substances see the Instructions Manual) r~ - a. Class of substance - Mark (X) 171 Class 1 or Class 2 ~tL X~~L b . Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCAInventory listings for similar substances For . Class I substances a CA Index Name must be provided ForClass 2substances either a CA Index Name or CA Preferred Name must be provided, I which ever is appropriatebased on CA 9CInomenclature 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 fromthe CAS Inventory Expert Services must ¬ .___1be 

### submitted as an attachment tothis 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 structurediagram . For aclass 2 substance, provide a correct representative or partial cihetnical structtue diagram, as complete as can be known, if ate can be reasonably ascertained . Please seethe E-PMNInstruction 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 2substance - (1) list the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate therange of composition and the typical composition (where appropriate) . e . (1) List the immediate precursorsubstances with their respective CAS Registry Numbers . Confi- Name (CAS #) 

## dential

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

e .(3) Indicate therange 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 ofthepolymer you intend to manufacture . Indicate maximum

weight percent of low

molecular weight species (not including residual monomers, reactants, w solvents) below

500and -

F' x '// below 1,000absolute molecular wei ght of that compo sition. Describe the methods of measurement or the basis foryour estimates : GPC U Other U : (Specify below) (i) lowest number average molecular weight: (ii) maximum

weight %

below 500molecular 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 claimas confidential (1) - Provide the specific chemical name and CAS Registry Number (ifa 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" fromdrop down menu if you want a monomer or other reactant used at twoweight 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 percentofeach monomer or otherreactant that may be present as a residual in thepolymer 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-11 

# °,° E:1



# _ 0- 

# °



# ,. F F-11 

# °,° _

E:1 

# . 1- 

# °,° 1 F11_1 

# °,. 1 11



# .1-1 

# --- °° - F~ - 

# °,° ~ % o °~ o o °,o - o °,° o °,° - o %o o °,° o °,° o °,. o °,° o % o %o Mark (}I) this box if y

ou attach a continuation sheet. 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 identi ty 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 fromCAS Inventory Expert Service must be submitted as an attachment FJto this notice) CBI

d. The currently correctChemical Abstracts (CA) name for the polymer that is consistent with TSCAInventory listings for similar polymers .

CAS Registry Number (ifa number already exists for the substance) e. Providea correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained . . Please see the E-PMNInstruction 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 wei ght %

of each im

pur it y. If there are unidentified im puriti es, 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 forthe new chemical identified in subsection 1 or 2 . Confi

### dential Mark (X) this box ifyou attach a continuation sheet. 5. Trade identification - List trade names for the new chemical substance identified insubsection 1 or 2 .

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

### 6. Generic chemical name - Ifyou claimchemical identify asconfidential, you must provide a generic name for your substance that reveals 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. 

# ~~~+~ rne~c, ~-~~ ~ Mark (X) this box ifyou attach a continuation sheet. 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number ifavailable. 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 itemy ou claim as confidential . 1 . Production volume - Estimate the maximumproduction 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 ofproduction. Estimates should be on 10046 new chemical II substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 

## 10,000 k r spec

i fy the volume and mark x inthe bindin box . Ifgranted, y

ou are bound to this volume i Maximum

first 12-month production (kg/yr) Maximum12-month production (kg/yr) rifi

## d Binding

O tion 

## (100%new

chemical substance basis) (100%new chemical substance basis) ential p Mark (X) 2 . Use Information --You must makeseparate 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 itemyou claim as confidential . j a. (1) -Describe each intended category of useof the new chemical substance by function andapplication . (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 thepercent of total roduction for thefirst 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 thenew substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured forcommercial purposes at sites under 

### our control associated with each category of use. (7) -Mark (X) this column ifentry in column (6) isconfidential business information (CBI) . (8) -Indicate % of roduct volumeexpected for the listed "use" secton. Mark more than one box ifappropriata Mark (X) to indicate yourwillingness tohave 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 peruse CBI dispersiva dye for finishing polyesterfibers) MRAt uccion % Formu

lation (8) ( :Cl (2) (3) (4) (5) (6) (7) sit, tmuted Camuska 6tdwodd Cammen6al Binding

'on (y) % . % X , % % % 5b - - ---

_ - 1 

### 1 1111 % % 

# l - - ----- - 

# E I %

# []I %

# F11 --- ---- 

# F11 I 3'0 % _ -- 

# u 

# u _ 

# 1E111 " If you have identified a "consumei" use, please provideon a continuation sheet a detaib;d description of the use(s) of this chemical substancein consumer products . Inaddition include estimates of the concentration of the new chemical substanceas expected in commumer products anddescribe thechemical reactions by whichthis substanceloses its identity in the consumer product (X) this box ifyou attach a continuation sheet b . Genericuse If you claimanycategory of use description in subsection 2a as confidential, enter a generic description of that category. Read the Instruction description Manual forexamples of generic use descriptions.



# U4eU Mark (X) this box if you attach a continuation sheet 3 . Hazard Information - Includein the notice a copy of reasonable facsimile of any hazard warningstatement, label, material safety data sheet, or other ~s Option information which will be provided to any person whois reasonably likely to be exposed to this substance regarding protective equipment or practices for thesafe handing, transport, use, or disposal of thenew substance

. List in part III hazard information you include . Merk (X) this box if you attach hazard information. EPAFORM

7710-25 (Rev. 5-95) Page 7

## p. 10 PMN Page 8 ; Page 10 of 18 

# Part II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE Section A- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the"Confidential" box next to any itemyou claim as confidential 

### Complete section Afor each type of manufacture, processing, or use operation involving the newchemical 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 p rocessing or use o

perations after im

port. You must describe these ope rations. See instructions manual 

### 1 . Operation description Confia. Identi ty -- Enter the identi ty of the site at which the operation will occur. dential Name Site address (number andstreet) City, County, State, ZIP code 

### If the same operation will occur at more than one site, enter the number ofsites. 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 Use I` ~~~( ~l c. Amount and Duration --Com plete 1 or 2 as appropriate Maximum

kg/batch poo9s new

chemiesi sabsiance) Hours/batch Batches/year 1 . Batch Maximumkg/day(iooxnawctnnicad Hours/day Days/year suesmnce) 2 . Continuous d. Process description u Mark (X) to indicate yourwillingness to have your process description binding . (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage and transportcontainers (specify- e .g. 5gallon 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 perbatch

.) . (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 releasenumber 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 ANDENVIRONMENTAL RELEASE - Continued Section A - INDUSTRIAL SITES CONTROLLED BY THE SUMMER- Continued 2. Occupational Exposure - You must make separate confidentiality claims for the descriptionofworker activity, physical formof the new chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou claim as confidential . (1) --Describe the activities (i .e. bag dumping, tote filling, unloadingdrums, sampling, cleaning, etc .) in which workers may be exposed tothesubstance . (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 thephysical form(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart 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 ofworkers 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 areconfidential business'nformation (CBI) . Workeractivity 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

Exposed (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 itemyou claimas confidential . (1) --Enter the number of each releasepoint identified in the process description, part II, section A, subsection ld(3) . (2) -- Estimate the amount ofthe new substancereleased (a) directly to the environmentor (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 whichthe new

substance will be released fromthat release point . (5) --a . Describe controltechnology, if any, and control efficiency that will be used to limit the release of the new substanceto the environment. For releases disposed of on land, characterize the disposal method and state whether it is approved fordisposal of RCRA hazardous waste. On a continuation sheet, for I each site describe anyadditional 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 entriesin 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 ofthe POTW blicl Owned TreatmentWorks ). Mark ifthe POTW name or NPDES# is confidential business information CBI' . Release Number (1) Amount of new

substance released (2a) (2b) CBI Mediumof 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) ' 

# IKI rl 

# L/N 1E1 []1 11

I 

# 0

1 E :11 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- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE - Continued SITES CONTROLLED BY OTLLRS Section B- INDUSTRIAL _ Completesection Bfortypical processing or use operations involving the new chemical substance at sites you donot control . Importers do not have to completethis section for operations outside the U .S . ; however, you must report anyprocessing or use activities after import. See the Instructions Manual . Complete a separate section B for each type of processing, or useoperation involving the new chemical substance

. If the same operation is performed at more than one site describe thetypical operation common to these sites . identi fy additional sites on acontinuation sheet. 1(a) . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claim as confidential . (1) - Diagram

the majorunit operation steps and chemical conversions, including interimstorage andtransport containers (specify - e .g. 5gallon pails, 55 gallon drums, rail 

### cars, tank trucks, etc) . On the diagram, identify byletter and brieflydescribeeach worker activity. (2) - Either inthe diagram or in the text field 1(b) below, provide the identity, the approximate weight (bykg/day or kglbatch, on an 100%new chemical substance basis), and entrypoint 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 perbatch) . (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 (rememberto identify the locations of these sites on a continuation sheet) : CBI 

### # of sites



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

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

Mark (X) this box ifyou 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) -- Fromthediagram above, provide the letter foreach worker activity. Complete 2-8 for each worker activity described. (2) -Estimatethe number ofworkers 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 formof exposure and % new chemical substance (ifin mixture), and any protective equipment and engineering controls, if any, used to protect workers. (7) -Estimate the percent of the new substance as formulatedwhen packaged or used as a final product. (9) --Frorn the process diagram above, enter thenumber of each release point . Complete 9-13 foreach release point identified. (10) - Estimate the amount of the new substancereleased (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 p roceeding entries are confidential business information (CBI) . e # of CBI Duration Of 

## C~ Protective Equip. /Engineering Controls/Physical Formand/ a/o new substance °i°inForm

## CBI oftiWorkers Exposed Exposure ulation vity (1) (2) (3) (4a 4b (5) 6 (7) (8)

------

- -- 

# o a o 11, 

# 0

. 

# 0 Release 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 claiminformation in the follo In this section you may provide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMNsubstance . 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 fromwastes 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 PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the reviewof this substance . See PMNInstructions Manual and Pollution Prevention Gui dance 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 ifyou 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 formand 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 claimas confidential . Read the Instructions Manual for guidance on howto claimany information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized version ofan attachment in which you claiminformation as confidential . # Attachment name Attachment Filename Attachment e number (s) Confidential

EL

Mark (X) this boxif you attach a continuation sheet. Enterthe 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 youprovide and 

### include it in the notice. Identify the property measured, the page of the notice at which the property appears, the valueofthe property, the unitsin which the property is measured (asnecessary), and whether or notthe property is claimed as confidential . If the attachments are electronic, give the attachment number (found on page 12) at (b) . The physical state of theneat substance should be provided. Thesemeasured properties should be for the neat (100% pure) chemical substance . Properties that are measured for mixtures or formulations should be so noted (%PMNsubstance in -J . You are not required to submit this worksheet; however, EPAstrongly 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 y our 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) provided ib) (c) or E Mark (X) (d) 

## D Ph ysical state of neat substance (s) (1 Vapor pressure ° 

## ~ C Tem perature Torr Densi ty/relative density g /cm3 Solubility @ Temperature )1a °C 

# t J 

# Solvent C I6 /~ 7~I~tr~.( (2lc¢u'f, ~ 

# I

, ~ Solubility in water Tem p erature -C °C ® ,~ da ,~, L Q Melting tem

perature 0C El Boiling / sublimation tem rature torr p ressure 0C

F-1 S pectra Dissociation constant Particle size distribution Octanol / water p

artition coefficient Henry's Law

constant Volatilization fromwater Volatilization fromsoil E :1 0 H concentration Flammability Ex lodabilit Adsorption / coefficient Other - S pecif y 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