### PUBLIC COPY p. 

### 1 FormApproved. O.MB. No. 2.070-0012. Approval Expires 10-31-96. 

### U.S. ENVIRONMENTAL PROTECTION AGENCY

... _ 1111 

# PREMANUFACTURE NOTICE NEW CHEMICAL SUBSTANCES DOCUMENTCONTROLOFRCER OFFICE OF POLLUTION PREVENTION AND TOXIC SUBSTANCES, 7407 U.S. E.P.A. 401 M STREET, SW WASHINGTON, D.C. 20460 

### Enter the total number ofpages in

### the Premanufacture Notice 

# COMPANY 

# SANITIZED

•You must provide all information requested in this form to theexb!llt that it is known to orreuonably ascertainableby you. Make reasonable estimates ifyou do

not haveactual data. ' •Before you completethis form, you should read the "InstructionsManual for Premanufacture Notification" (the Instructions Manual is available from theToxic Substances Control Act (TSCA) Information Serviceby calling

**202~554-1404,** orfaxing 202-554-5603). •If a userfee hasbeen remitted for thisnotice (40 CFR 'ioo.45), indicate intheboxes above the TS-userfee identification numberyou have generated. Remember, youruserfee ID numbermust also appear on yourcorrespondingfee remittance, which is sentto: EPA, HQAccounting Operations Branch (PM-266), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA UserFee. Part I- GENERAL INFORMATION You must providethe currently correct Chemical Abstracts (CA) Name ofthe new chemical substance,even ifyou claim theidentity as confidentiaL You may authorize anotherpersonto submitchemical identity informationfor you,but your submissionwill notbecomplete andthereviewwill notbegin until EPA receives this information. A letter in supportofyoursubmission should reference yourTS userfee identification number. You must submit an original andtwo copies ofthis notice including alltest data. Ifyou claimed any information as confidential, a single sanitizedcopymust alsobe submitted. Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture,processing,oruse operationstobedescribed in Part II, sections A and Bofthis notice, reproduce the sections as needed. Part III- LIST OFATTACHMENTS Attach additional sheets ifthere is not enough space to answera question fully. Label each continuation sheetwiththecorresponding section heading. In Part III, listthese attachments, anytest data orotherdata and any optional information included inthe notice. OPTIONAL INFORMATION You may include any informationthatyou want EPA to considerin evaluating the new substance. On page 11 ofthis form, spacehasbeen provided for you to descn"be pollutionprevention and recyclinginformation you mayhave regarding the new substance. So-called "binding"boxes areincludedthroughoutthis form for you to indicate yourwillingness to beboundtocertain statementsyoumake inthis notic:e. such as use, production volume,protective equipment ••• Thisoption is intendedto reduce delays that routinely accompanythe development of consent orders or Significant New Use Rules. Except inthe case ofexemption applications

**~uch** as TMEA, LVE, LOREX) where certain information provided insuch notification is bindingon the submitterwhen the Agency approves the exemption application, checking a bindingbox in this
**notice~**byitselfprohibitthe submitter from laterdeviating from theinformation (except chemical identity) reported in the form. CONFIDENTIALITYCLAIMS You may claim any informationinthisnotice as confidential. To assert a claim onthe form. mark (X) the confidentialbox next to theinformationthatyou claim as confidential. To assert a claim in an attachment, circle orbracketthe information you claim asconfidential. Ifyou dajm information inthepolice u confidential. youmust also proyide a unitizes! vemiop ofthenotic;e. <ipc;ludin& attachments!. For additionalinstructions on claiminginformation as confidential, read the InstructionsManual.



### ~ Mark (X) ifanyinformation in this noticeis claimed as confidential. EPA FORM 7710-25 (Rev. 5-95) TEST DATA AND OTHER DATA You arerequiredto submit alltest data inyourpossession orcontrol andtoprovidea description ofall otkerdataknownto orreasonably ascertainable byyou, ifthesedataare related tothehealth and environmental effects ofthemanufacture,processing,distribution in commerce, use, ordisposal ofthenew chemical substance. Standard literature citations may besubmitted for data inthe open scientific literature. Complete

### test data <written in Eoslishl pot symmaries ofdab mgstbe submitted iftheydo not awevin the open literature, You should clearlyidentifywhethertest data isonthe substance oron an analog. Also, thechemical composition ofthetested material shouldbecharacterized. Followingare examples oftest data and otherdata. Data shouldbe submitted accordingtothe requirements of §720.50 ofthe Premanufacture Notification Rule (40 CFR Part 720). Test Data (Check Below any included inthis notice)

• Environmental fate data Yes • Otherdata 

# D Yes
• Health effects data Yes Riskassessments
• Environmental effects data Yes Structure/activityrelationships Test data not inthe possession orcontrol ofthe submitter • Physical/Chemical Properties •



### ~ Yes

•A physical and chemicalproperties worksheet is located onthe last page

ofthis form. TYPE OF NOTICE (Check Only One)



# D D 

# rn D D 

# D D PMN (Premanufacture Notice) INTERMEDIATE PMN (submittedin sequencewith final product PMN) SNUN (Significant NewUse Notice) TMEA (Test Marketing Exemption Application) 

### .:: ·:::J LVE (Low Volume Exemption) @ 40 CFR '723.50 (c)(1) 1 

### '"U

## i;2 c.r; 

## -o .., LOREX (Low Release/Low Exposure Exemption) @ 723.SO(c)(2T-I

# f;j h -...- 

# 0 LOREX Modificatkill 

### 2)"" LVE Modification '-0 _,..,.., •• ("") t::) IS THIS A CONSOLIDATED PMN? 

# 0 Yes f\.) I ofchemicals (Prenotice Communication I required, enterI on page 3) Replaces previous editions ofEPA Form 7710-25. 

# '

### p.2
Public reportingburden for this collection ofinformation is estimated to average 110 hoursper response, includingtime for reviewing instructiom, searchingexisting data sources, gathering and maintaining thedata needed, and completing and reviewing the collection ofinformation. Send comments regarding theburden estimate or any other aspect ofthis collection ofinformation, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental ProtectionAgency, 401 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 I certify that to thebest of myknowledge andbelief: 1. The companynamed in Part

### L section A, subsection 1a of

### this notice form intends to manufactureorimportfor a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part

### I, Section 

### B. 2. All information provided in this notice is complete and truthful as ofthe date of submission. 3. I 

### am submitting with this notice all test data in mypossession or control and a description ofall other data known to or reasonably ascertainable 

### by me as requiredby §720.50 ofthe Premanufacture Notification Rule. 

### Additional Certification Statements: If

### you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, 

### check the following userfee certification statement that applies: 

## [!] The Companynamed in Part

### I, Section A has remitted the fee 

### of $2500 specified in 

### 40 CFR 700.45 {b), 

### or 

# D The Companynamed inPart

### 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 

# D The Companynamed in Part

### I, Section A is a small business concern under

### 40 CFR 700.43 and hasremitted a fee of $100 in accordance with

### 40 CFR 700.45 (b). If

### you are submitting a lowvolume 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: 

# D D D The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercialpurposes, other than in small quantities solely for research and development, under the terms of

### 40 CFR 723.50. The manufacturer is familiar with the terms ofthis section and will complywith those terms; and The new chemical substance for which the notice is submitted meets all applicable exemption conditions. 

# D If

### this application is for an

### L VEin accordance with 

### 40 CFR 723.50 (c)(1}, the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year ofthe date ofthe expiration ofthe 30 dayreview period.

The accuracy ofthe statements you make in this notice should reflect yourbest predictioo ofthe anticipated facts regarding the 

### chemical

substance described herein. Any knowing and willful misinterpretation is subject 

### to criminal 

### penalty pursuant

### to 18 USC 1001. 

# Slgna-;r;;

**A;_~**

# Slgnatu
.. Requhed) 

### Date MANAGER, OCCUPATIONAL HEALTH 

### Signature of agent - (if 

### applicable) Date

FORM EPA m0-25 

### (Rev. 5-95) Page2 

### Confidential

## Part I-- GENERAL INFORMATION

la. Person Submitting Notice Name of authorized official 

## F. Mulherin Companv Position 

### Manager, Occupational Health Fluoroproducts (in U.S.) 

## E. I. duPont de Nemours 

## &Company, Inc.

b. Agent(if applicable) Mailin2 address (number and street) 

## 1007 Market Street City, State, ZIP Code 

## Wilmington, 

## DE 19898 Name ofauthorized official

City, State, ZIP Code Telephone

c. Hyou are submitting this notice as part ofa joint submission. mark (X) thisbox. ---------------• Joint Name of authorizedofficial J'no;iHnn Submitter (ifapplicable) Mailing address (number andstreet) City, State, 

### ZIP Code Telephone 

### 2. Technical Name Position Contact 

### F. Mulherin (in U.S.) 

### Manager, Occupational Health Fluoroproducts Company 

## E. I. du Pont de Nemours 

## & Company, Inc.

**Mallin~~;** address (number andstreet) 

## 1

007 Market Street City, State, 

### ZIP Code 

## Wilmington, 

## DE 19898 3. Hyou havehad a prenotice communication (PC) concerning thisnotice andEPA assigned a PC Number to the notice, enter the number. 4. Hyoupreviously submitted an exemption application for the chemical substance coveredby this notice, enter the exemptionnumber assigned by EPA. Hyoupreviously submitted a PMN for this substance enter the PMN number assignedby EPA (i.e. withdrawnorincomplete).



# --·~ Hyouhave submitted a notice of Bona fide intent to manufactureor import for the chemical substancecoveredby this notice, enter the notice number assignedby EPA :. Type ofNotice- Mark (X)
FORM EPA 7710-25 lRev. 5-95) 

# t.0 

# D Manufacture Only Option Page3 Telephone 1 I 

## 302 I 1 

## 774-2193 PC-1574

2. 

# D Import Only Mark (X) ifnone Mark (X) if none Mark (X) ifnone 

# D BindingOption Mark(x) 

# _ **___,.,..~** 

# D

3. 

# 0 Both

## Part I
-- GENERAL INFORMATION
- Continued Section B- CHEMICAL IDENTI'IY INFORMATION: **Youmutprovideacurre~tly** blued on the ninth Collective Mark (X} the "Confidential" box next to any item you claim as confidential. 

## .4

Abstracts ICA

**\~·-'~of** the substance nomenclature rules and conventions. Complete either item 1 (Clasa1 or 2 subsbnces) or 2 (Polymers) as appropriate. Complete all other items. Ifanother person will submit chemical identityinformation for you (for either item 1 or 2), mark (X) the box at the

**ri~t.** 

# D the and address ofthat in a continuation sheet. 

## >" 1. Class 1 or 2 chemical substances (for definitions ofclass 1 and class 2 substances, see the Instructions

**~nual)** a. Class ofsubstance- Mark (X) 1 

# [!] Oass 1 

### or 2 

# 0 Class 2 b. Chemical name (Currently correct ChemicalAbstracts (CA) Name that is consistent with TSCA Inventorylistingsfor similar substances. For Class 1 substances a CA Index Name mustbeprovided. For Class 2 substanceseither a CA IndexName orCA Preferred Name be provided, whichever is appropriatebasedonCA 9CI nomenclaturerules and conventions.).



## Pentane, 1, 1, 1,2,3,4,4,5,5,5- Decafluro

c. Please identify which method you used to develop or obtain the specified chemical indentityinformationreported in this notice:

(check one). DMethod 1 (CAS Inventory Expert Service- a copy ofthe Identification

**~ethod** 2 (OtherSource) report obtainedfrom the CAS Inventory

### Expert Service must be submitted as an attachment to this d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

## CF3CFHCFHCF2CF3 CAS I 

## 138495-42-8

e. For a class 1 substance,provide a complete and correct chemical structure diagram. For a class 2 substance- (1) List the immediate precursor substances with their respective CASRegistry Numbers. (2) Describe the

### nature ofthe reaction 

### or

### process. (3) Indicate the range ofcompositionandthe typical composition (where appropriate). (4) Provide a correctrepresentative or partial chemical structure

### diagram, ascomplete as canbeknown, ifonecanbereasonably ascertained.


### F F- C 

### F 

### F 

# c H 

### F 

# c H

Mark (X) thisboxifyou attach a continuation sheet. FORM EPA m0-25 (Rev.

**~95)** 

### F 

# c F 

### F C- F F

Page4 

## HFC-43-lOm.ee

### p.5 

## Part I --GENERAL INFORMATION
-- Continued

**~** 

### Section B - CHEMICAL IDENTITY INFORMATION
- Continued

2. Polymers (For a definition ofpolymer, see the Instructions Manual.) Confidential a. Indicate the number-average weight ofthe lowest molecular weight composition of thepolymer youintendtomanufacture. Indicate maximumweightpercent oflowmolecular weight species (not including residualmonomers, reactants, or solvents) below 500 andbelow 1,000 absolute molecular weightofthat composition. Describe the methods ofmeasurementor thebasis for vour estimates: GPC 0 Other0 : (Specify) i) lowest number average molecular weight ii) maximum weight% below500 molecular weight 

### NOT APPLICABLE iii) maximum weight%below 1000 molecular weight 

# 0 Mark(X) this box ify<>_u attach a continuation sheel

b. You must make separate confidentiality claims for monomer orotherreactantidentity, composition information, andresidualinformation. Mark (X) the "Confidential"boxnext to anyitem you claim as confidential. (1)
- Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeachmonomer orotherreactant used inthe manufacture of thepolymer. (2)
- Mark (X) this column ifentryin column (1) is confidential (3)
- Indicate the typical weight percent of each monomer or other reactant in the polymer. (4)
- Mark (X) the identitycolumn ifyou wanta monomer orotherreactant used attwo weightpercentorle• to be listed aspartofthe polymer description on the TSCA Chemical Substance Inventory. (5)
- Mark (X) this column ifentriesincolumns (3) and (4) are confidential. (6)
- Indicate the maximumweightpercent ofeach monomer orother reactant thatmaybepresent as a residual in the polymer as manufactured for commercial purposes. (7)
- Mark (X) this column ifentryincolumn (6) is confidential. Monomer or other reactant andCAS Registry Number Confi- Typical Identity Confi- Maximum Confidential

**r~;..ootinn** Mark (X) dential residual dential (1) (2) .(3) (4) (5) (6) (7) % 

### % % % % % % % % % % Of_ 

### % % 

# 0 Mark (X) thisbox ifyou attach a continuation sheet. c. Please identify whichmethod you used to develop orobtain the specified chemicalidentity informationreportedinthis notice. (check one). 

# 0 Method 1 (CAS Inventory Expert Service- a copy oftheidentification report 

# 0 Method 2 (other source) obtainedfrom CAS Inventory Expert Service mustbe submitted as an attachment to this notice)· d The currently correct Chemical Abstracts (CA) namefor the polymer that is consistent withTSCA Inventory listings for similarpolymers.

e. Provide a correct representative orpartial chemical structure diaJUam, as complete as canbeknown, ifone canbe reasonably ascertained.



# 0 Mark(X) thisbox ifyou attach a continuation sheet. FORM EPA 7710-25 ev. 5-95 (R PageS

### ,. 

### • p.G 

## Part I -GENERAL INFORMATION 

## --Continued



# ~ Section B- CHEMICAL IDENTITY INFORMATION
- Continued

3. Impurities

(a)
- Identify each impuritythat may be reasonably anticipated to be present in the ch-icalsubstance • manufactured for commercial purposes. Provide the CAS Registry Number if available. Ifthere are unidentified impurities,enter "unidentified." (b) -Estimate the muimum weight •;. of each impurity. Ifthere are unidentified impurities, estimate theirtotal weight •;.. Impurity and CAS Registry Number Maximum Confi- percent (a) (b) dential 

## 1,1,1,2,4,4,5,5,5 Nonafluoropentane 141993-32-Q <1 % 

## 1,1,1,3,4,4,5,5,5 Nonafluoropentane 141993-31-9 <1 % 

# ·- f-pentene-2 (CF 3

## CF=CFCF2

## CF

# j 72804-49-0 .05 % 

## . % % % % 

# 0 Mark_(X) this box ifyou attach a continuation sheet. 4. Synonyms-- Enter any chemical synonyms for the new chemical substance identified in subsection 1 or2.



# ~:=~~

HFC-43-10mee 

# 0 Mark (X) this box ifyou attach a continuation sheet. 5. Trade identification- List trade names for the new chemical substance identified insubsection 1 or2. 

## Hydrofluorocarbon 

# 0 Mark (X) this box ifyou attach a continuation sheet. 6. Generic chemical name- Ifyou claim chemical identity as confidential. you mustprovide a generic chemical namefor your substance that reveals thespecific chemicalidentity ofthe

### new chemical substance to the maximum extent possible. Refer to theTSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance ondeveloping generic names.


# 0 Mark (X) thisbox ifyou attach a continuation sheet. 7. Byproducts '"' anybyproducts resulting from themanufacture, processing, use, or 

### disposal ofthenew chemical substance. Provide the CAS Regu;try 1··;uu.....a ifavailable. Byproduct CAS Registry Number Confi- (1) (2) dential 

## HydrogenFluoride 7664-39-3 Sodium Fluoride 7681-49-4 

## Cf14



# - C 7 

## F13

## CC



# - D Mark (X) this box ifyou attach a continuation sheel FORM EPA 7710-25 (Rev. 5-95) Page6

### p. 7 

## Part I --GENERAL INFORMATION-- Continued

**~** 

### Section C- PRODUCTION, IMPORT, AND USE INFORMATION: Mark (X) the "Confidential"boxnext to any item you claim as confidential 1. Production volume -Estimate the maximum production volume during the first 12 months ofproduction. Also estimate the maximum productionvolume for any consecutive 12-month 

### period during the first three years ofproduction. Estimates should

### be on 100%new chemical substancebasis. 

### For a Low 

### Volume Exemption application, 

## if you choose to have yournotice reviewed

### atalower production volume t1um 10,000 

### kg!yr, specify the 

### volume and 11Ulrk (x) in the 

### binding box. 

## If granted, you are bound to this 

### volume
.. Maximum first 12-month

**~roduction** {kg/yr} Maximum 12-monthproduction (kg/yr} Confi- Bindittg dential Optioll (100% new chemical su stance basis) (100% new chemical substance basis) Muk(x) 

# x.·

2. Use Information

- You mustmake separate confidentiality claims for the description ofthe category ofuse, the percent ofproduction volume devoted to each category, the formulation ofthe new substance, and other useinformation. Mark (X) the "Confidential" Box next to any item you claim as confidential. a. (1) -Describe eachintended category ofuse ofthe new chemical substance byfunction and application. (2)

- Mark (X) this column ifentry in column (1) is confidentialbusinessinformation (CBI). (3) - Indicate your willingness to have the information provided in column (1) binding. (4) -Estimate thepercent oftotalproduction for the first three years devotedto each category ofuse. (5) -Mark (X) this column if entryincolumn (4) is confidentialbusiness information (CBI). (6) -Estimate the percent ofthenew substance asformulatedinmixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial

### purposes at sites under your control associated with each category ofuse. (7) -Mark (X) this column if entry in column (6) is confidentialbusinessinformation (CBI). (8)- Indicate %ofproductvolume expected for thelisted "use" sectors. Mark more than 

### one box ifappropriate. Mark (X) to indicate your willingness tohave the use typeprovided in (8) binding. (9)- Mark (X) this columnifentry(ies) incolumn (8) is (are) confidentialbusiness information (CBI). Category of use (1) CBI Binding Produc- CBI %in CBI %ofsubstance expected per use CBI (byfunction andapplicationi.e. a dispersive dyefor Optioll tion% Form- (8) Mark(x) ulation finishing polyester fibers) :site- {;on-
.. Indus- Com-

**~Jindins** (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) % % 

# X % % 

# X % % 

# l>( % % 

### % % % 

### % % % 

### •Ifyouhave identified a "consumer" use, pleaseprovide on a continuation sheet

### a detailed description of the use(s) of this chemical substance in consumerlroducts. 

### In addition include estimates of the concentration of the new chemical substance as expected in consumer products an describe the chemical reactions bywhich this substance loses its identity in the consumerproduct. 

# 0 Mark (X) thisboxifyou attach a continuation sheet. b. Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat use category. Read the InstructionsManual for examples ofgeneric 

### use descriptions. description 

## Contained process, heat transfer, and test media. 

# D Mark (X) thisboxifyou attach a continuation sheet. 3. Hazard Information

- Includeinthe notice a copy ofreasonable facsimile ofany hazard warning statement,label, material safety data sheet, Binding

or other information which willbeprovided to any person who isreasonably likely tobe exposed to this substance regardingprotective Option 

# 00 (uipmentor practices for the safe handling, 

### transport, use, ordisposal ofthe new substance. List in part

## mhazardinformationyou include. Mark(x) Mark ()() thisbox if_you attachhazardinformation. FORM EPA 7710-25 (Rev. 5-95) Page7

### p.8 

## Part II --HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE
Complete section A for each type ofmanufacture,

**proce~&ing,** or use operation involvingthe new chemical substance at industrial sitesyou control. Importers do nothave to complete this sectionfor operations outside the U.S.;however,you may still have reporting requirements ifthere are further industrial processing or use operations after import. You must dei!ICribe these operations. See instructions manual.
ofthe site at which the willocrur. Name

City, County, State, ZIP Code
Ifthe sameoperationwill ocrur atmorethan one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe siteshave significantly different ... productionrates or operations, include all the informationrequestedin this sectionfor those



### b. TypeMark (X) attach a continuation sheet 

# 0 Manufacturing

1. Batch 2. Continuous 

# D Processing Hours/batch Hours/dav 

# 0 Use Batches/vear

Days/year
d. Process description Mark (X} to indicate yourwillingnessto have yourprocess deKriptionbinding. (1) Diagramthemajor unit operationsteps and chemical conversions. Include interim storage andtransport containers (specify-e.g. 5 gallonpails, 55 gallondrum, rail car, tank truck, etc.). (2) Provide the identity, the approximateweight (by kg/day orkg/batch on an 100% new chemical substancebasis), andentrypointof all starting materials andfeedstocks (including reactants, solvents, and catalysts, etc.), andof all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch.). (3) Identifybynumber thepoints ofrelease, including small orintermittantreleases, to the environment ofthe new chemical substance.



# W Mark (X) thisbox ifyou attach a continuation sheet. FORM EPA 7710-25 (Rev. 5-95) Page

### SA

### p.9 

## Part II --HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Complete section A for each type ofmanufacture,proce11ing, or use operation involvingthe new chemical substance at industrial sites you control. Importers do nothave to complete this section for operations outside the U.S.;however, you may still have reporting requirements ifthere are further industrial processing oruse operations after import. You must describe these operations. See instructions manual.
ofthe site at which the will occur. Name Site address (number and street) City, County, State,

### ZIP Code
Ifthe same operationwill occur at more than one site, enter thenumber ofsites. Identify the additional sites ona continuation sheet, and ifany ofthe siteshavesignificantly different 

# > productionrates or operations,include all the information requestedin this section for those

b. TypeMark (X) attach a continuation sheet 

# 0 Manufacturing

1. Batch 2. Continuous 

# D Processing Hours/batch Hours/dav 

# 0 Use Batches/vear

Days/year
d. Process description Mark (X) to indicate yourwillingness to have yourprocess description binding. 

# X
(1) Diagramthe major unit operation steps and chemical conversions. Include interim storage andtransport containers (specify-e.g. 5 gallon pails, 55 gallon 

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

### (2) Provide theidentity, the approximate weight (by kg/day orkg/batch on an 

### 100% new chemical substance basis), and entrypoint ofall starting materials andfeedstocks (including reactants, solvents, and catalysts, etc.), and ofall products, recycle streams, andwastes. Include cleaning chemicals (note frequency ifnotused daily orper batch.). (3) Identify by number the points ofrelease, including small or intermittantreleases, to the environment ofthe new chemical substance.



# D Mark (X) thisbox ifyou attach a continuation sheet. FORM EPA 7710-25 (Rev. 5-95) PageS B

# \.iOntatns 

# Confidential Business Information p.10

# \Jontatns Confidential Business 

# Information

If p. 11

# ·0 c

# t. 2 5. 199 6 1 0

:3

4

AM 

# DUPONT No. 4342 Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE- Continued

**~** Section A - 

### INDUSTRIAL SITES CONTROLLED BY THE SUBMITrER- Continlled 1. 

### Occupational Exposure- You

**m~t** 

### make separate

**con.lid~ty** claims

**for~ de:scripli_~,ofworker**  

### activity, physical

**~rm** ofthe 

### new .chemical



### . substance, number ofworkers 

### exposed. and duration of

### actiVlty. Mark (X) the 

### Confidential box I\I!Xt to 

### any 1tem. you claim as confidential.

(1)- 

### Describe the activities (e.g. bag 

### dl.lDlping, tote 

### .lilliiig, unloading drums, 

### sampling, clearUI\g. etc.) inwhich

### workers may 

### be expasecl. 

### to the 

### substance. (2) 

### -Mark (X) 

### this column if

### entry in

### colWNI (1) is 

### confidential busiJI.ess 

### infonnation (CBI). (3)
- 

### Describe any protective equipment 

### a.nd engiMering controls used 

### to protect 

### workets. (4) and (6)
- Indicate 

### you williJ1glles& to

### have the 

### infomla.tionprovided

### in colwm (3) 

### or (5) binding. (5) 

### -Indicate the physical farm(s) of

### the rtew chemical 

### substance (e.g. solid: crystal granule, powder, or dust) 

### and% 

### new chemical substance (ifpart 

### of a mixture) at the time 

### of exposUJ"e.

**~7)** - 

### Mark (X) this 

### colwnn ilentry

### in column (5) is confidential 

### business intonnation (CBI). 8)
- Estimate the maximW"n number 

### ofworkers involved in each

### activity ford sites combined. (9) 

### -Mark (X) 

### thiscolwnnilenltyin col\ID\I\ (8) is conlidential 

### buslnessi.nlonnati.on (CBI). (10) and (11)
- 

### Estimate the maximum 

### dUJ"ation ofthe activity for any 

### worker inhoiUS 

### per day and

### days

### per year. (12)
- Mark (X) 

### this column if entries 

### incolUDIJIS (10) and (11} are 

### con5dential business 

### infonnation (CBl). 

### Worker activity CBI ProtectiYe 

### E<talpaeatf. llidins: l'ftysJc.al

**tonnt~J**



# ~· CBI tof CBI Mmmum duration CBI (e.g. bag dumping. fillitlg drums) bgiaccriaiJCoatrols Optloa 

### (4!.g.solid:powdar)



# ~be) Worken

**~(x)** m4%new 

### Exposed Hr.;/ day 

### Day-5/yr 

## m 12) (3) (4) **11Ub5~CI!** (..;t {7\ "(6} {9) 

### 110> n1) lnl) 

# X Impervious Gloves. 

## X 

# X 1 70 Respiratory Protection 

# - X· 1 1mpotv1ous

**~lOVes,** 

### Respiratory Protection 

# X X 8 

## 10 

# X Impervious Gloves 

# X X 

## 4 10

. 

# 0 Mark (X) thisbox if

### you attach a 

### continuationsheet. 3. 

### En•ironmental Releaee a11d 

### Dilpotal
- You U\USt make 

### separate cOIIfidentiality cWm5 

### for the release 

### nUD\be:r aadthe 

### amount ofthe

### n.ew chemical

su.bsbu\ce 

### released.and·otherrelease and disposal infonnation. Mar.k (X) the 

### "Conficlential" box next to eachitem

### you claimas 

### confidential. (1)
- Enter thenumber 

### ofeach 

### release pointidenli.6ed in the proce55 descriptio:n,. part 

### II,. sectionA. 

### subsection ld(3). · .

**~2)** - 

### Estimate the 

### amounr ofthe new substance 

### released (a) directly 

### to the

### enviroNIW\t or (b) 

### into contr:ol technology (in kg/

### day or kg/batch).
. 3)
- Mark (X) this 

### c:olUDIX\ ifentries in

### colWMS (1) and (2) are 

### confidential 

### business infonnation (CBI). (4)
- Identify the mediaofrelease 

### i.e. stack air, 

### fugitive air (optional-see InstructionManual), 

### surface water, on-site 

### or off-site land 

### oritldnerati.o.a, PO'lW, or 

### othe:f (please specify) 

### to which the 

### new substance will. be 

### releasedlrom that release point · (5)
- a. 

### Desaibecontrol technology, ifany, ,and 

### contrDl efficiencythat will be

### useclto limit the release 

### ofthe

### new subsllmce to the en..;rpnment. For 

### releases disposed 

### ofon

### land, characterize the disposal methodancl state 

### whether itis 

### approved for disposal ofRCRA 

### hazwdous waste.
· On a

### continuation sheet , for each site

**de~>cribe** any 

### additional 

### cl.i5poAl methods that will

**~** usecl anci 

### whether the waste is subject 

### to secon<Wy or tertiary on-si.te treatment. b. Estimate

**~e** 

### amountreleased 

### to the enviroraneat after 

### control 

### techrlology (m kg/

### day).

**~6)** - Mark (X) this col\lJM ifentries in

### colwn.ns (4) mel(5) are conficlenMJ business i.nformation (CBl}. . . · . . 7) - Identily the 

### destixlation(s) 

### of. releases to 

### water.· Please

**~pply** 

### NPDES (National

**Poll~tant** Discharge ElimiNtion

### system) numbers 

### for direct di.schargeJS 

### or 

### NPDES numbers ofthe 

### PO'IW (Publicly 

### OwnedTxeatment Works). Mark (X) ifthe 

### PO'TW name or NPDES t# i:> confidential business 

### information (CBI). . Release Amountof-new

**subsW~Ce** CBI 

### 1Medl.aof Control technology and efficiency (you may wi&h to 

### optioDally attach effic:iii\Cy data) 

### CBl Number

**I'Q)~wl** releilse

**I~**

(1) (2a) (2b) e.JA>Ckair (3) (4) .:. (SOl) : M.uk l'<l
. (Sb) (6) 

## X Water 

### Neutralization System I 

### <.001 k!Jiday 

# ·- 1 I I 

## 2 

## X Air 

### Incineration I <0.0001 

### kgfday



## - 

# .. I I I I I I ' I I I (7) Mark (X) 

### the 

# D P01W

### pr:ovide l.'lall\e(s) below: CBI 

# C Navigable 

# 0 OOIIr. Specify provi.de NPDES it CBI destiauliOn(s) 

### of f--

**-~y** 

## X 

# X releases 

# J water. 

# 'fl}Mark (X) thisbox if

### you attach a continuation sheet FORM EPA 7710-25 

### (Rev. 5-95) 

### Page9 A



### OCT-25-1996 10:36 3027748416 

## J...7 96% 

### P.02

# l

-0 c

# t. 

# 2 5. 199 6 I 0:3 4 AM 

# DUPONT No. 

# 4342
..


# . Part 11-- HUMAN 

## EXPOSURE AND 

## ENVIRONMENTAL RELEASE- Continued



## ~ Section A- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTF.R ··Continued 2.. Occupational Exp05un -You must INIIte separate con.fidentialiay claims for ahe description ofworker .l(tiv\ty, physical form Clf

### the new chetnical

**~~bs~nce. ni.UI"'b~r**  ofworker;

**~'<p<'Sed.** and dunlion ofactivity. Mark (X) thl! 'Cilniidtmaal"

**bo~t nt:~<t**  w any item y011 c1ailn as conJiclential. (1)
-

**De,;~nbo!** rho! .l(tivities (t.g.

**b:~g** dumping. late filling. unloacling drums. sampling, cleaning. etc.) in which 

### workers maybe exposed to the substance. (2)
- Mark (X) this coli.U\"'n 1fenuy incol\UN\ (1) is confidmti.3.1 business information (CBl). (3)- Describe any protective equipmetlt

**and~** controls used co protect workers. (-l) and (6)- (ndieate you willitlgnts.s to 1\:lve the mformation provided in column {3) or (S) binditls- (S)- Indicate the physical form(s) of lhe new chemical substance (e.g. solid: crystal, grarwle. powder, ordust) and 0k new chemical 

### substance {ifpa-tof a mixture) at the time of exposure. · (7)
- Mark (X) this column iientry in colUINI (5) isconfidential business information (CBI). (8)
- Esamate the maxi.lnwn number ofworlc.ers involved. irl each activity for all sites combined. (9) -Mark (X) this colWN\ ifentry ir1 colwnn (8) is confidential business information (CBI). 

### (10) and (11)
- Estunate the maxunum duration ofthe activity for anyworker inhours 

### per day anddays 

### per yev. 02) -Mark (X) this column iientries incol\liX\IIS (10) and (11) are confidl!l\tial businesS infonnation (CBI). Worker activity 

### CBI l'lotcdivc£q11ip111oellll 

### !Jiactiq 

### 1'1\ys,caa

**torm~J**

**~illclias** CBI I of CBl

**MalliDJ~** 

### duration 

### CBI pptloa (e.g.solid:powder)



# ~:c, Worken (e.g. bag dumping. fill.lllg drwns) Eapnec1iR3 Coatrols

**~(ll)** ancl %new Hrs/lky 

### Days/yr Exposed 

## m (2) 

### J3l (4\
**subs~e** ({,\ 17\ "<8) (9\ (l()) n1\ il12)

. 'oj 

## X Impervious Glo11es, 

## X X 1 

## 230 Respiratory Protection 

## X

**~mpeiVIOUS** '!JOV8S, 

### RespiraiOiy Proteetion 

## X X 8 40 

## X Impervious Gloves 

## X X 4 

## 50

**~** 

# 0 Mark (X) this bo:t ifyou attach a continuationsheel. 3. Environmental Reiease 

### a.nd DiJpoAI- You must make separate coa&denl:iality daimsfor the release nwnber mel theamount oflhe

### new chemica!

substance released andocher relea5e and disposalinfonMiion. Mark (X) the "Confidential" box next to

**eachitem~tl** claim ascon&lentW. (1) - 

### Enter the ni.QI\ber ofeach release point

**idez~tified** il\ the process desaiptiort. pvt

### 11.. sectionA. subseclion 1 (3). (2)
- E.5timate the amow:ttofthe newsubstaJu:e released (a) 

### directly to lhe enviroxunent or (b) into control tKhrlology ("m kg/ 

### day or kg/batc:h). (3)
- 

### Mule: (X) 

### this colUDlll ifentries incol\UNIS (1) and (2) are confidential busine5s inforxnation (CBI). (4)
- lclent# themedia ofrelease i.e. stack air, fugitive air (optional-see 

### InstructionManual), SUJface 

### water, 

## on-«1e or off-site larld ori..nanent3on. POTW, or other (please specily) to which 

### the newS\ll7stance willbereleased &om 

### that release point. (5)
- a. Describe coatrol technology. il

### any, ,aridcontrol 

### elficiency that will be used to lilllit INrelease of

### th@ new substarv:e to th@ environment. For releases 

### dispo.5ed ofon

### land. characterize the disposal method and stalewhether itis approved for 

### disposal ofRCR.A hazardous 

### waste. On acontint&ation sheet , for each site describ@ any additional disposal. methods that will be used and wtll!ther IN waste is subject 10 seconclary or tertiary

**o~site** 

### treatment. b. Eslimate the 

### amount released to the environment 

### after CCMtrOltedulology (inkg!day). (6)
- Mark (X) this colwnn 

### i.l

**en~5** incolumns (4) and (5) are

**conlidez~tial** businessinformalion (CBI). . . (7)
- Identity the destination(s) ofreleases to watet. Please 

### Sl.lpply NPOES (National Pollutant Discharge

### EWNnation System) nuJDbets for clirect dischargers or NPDES munbers ofthe POTW (Publidy OwnedTtealma\tWorlcs). 

### Mark (X) il

### the POIW t'allltorNPDES tis con6denlial 'bus.iness i.n.fonnation (CBI). Release Amount ofMW sW5tal\ce 

### CBI Medilof Control 

### technology and elficiency 

### (you may wish to 

### optionaD.y attacheffidmcy data) 

### CBI Number releued 

### release I llir.dq

(1) (la) (2b) ...libel<

**~lr** (3) (4) (Sa) :



### Muk~ (Sb) (6)



# - 

# - 1 

## X Water

**Nat~tralizalion** System 

# . I <.001 kgfday (:>99% 

### Efficiency) I



# - I 

## 2 

## X Air JncineraliOf\ I <0.0001 kgday (:>99% 

### Elficianc:y) I L I I 1 I I I I I (7) Mark (X) the 

# 0 l'OTW provid.e I\IUU!(s) below: CBI []Navigable 

# 0 Od\er
- Specify provide 

### NPDES It CBl ciestina!ion(s) of 1-- waterway releases to water. 

# X X 

# 0 Mark (X) thisbox iJ yo1.1 .lttacha



### COC\tinW~tion sheet.



# - - Page9 B 

### OCT-25-1996 10:37 3027748416

**/~** 96% 

### P.03

### p.14 

## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE-- Continued

**~** 

### Section B
- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete sectionB for typical processing or use operations involving the new chemical substance at sites you do not control.Importers do not have to complete this sectionfor operations outside the U.S.; however, youmustreport any processing or use activities after import. See the Instructions Manual. Complete a separate section B

### fureach type of processing, or use oper11tion involving the new chemiall substance. Hthe same operationisperformed at more thanone site describe the typical operation common to these sites. Identify additional sites on a continuationsheet. 1. Operation Description
- To claim informationinthis section as confidential, circle orbracket the specific information that you claim as confidential. (1)
- Diagram the major unit operation steps and chemical conversions, includinginterim storage and transport containers (specify- e.g. 5 gallonpails, 55gallondrums, rail cars, tank trucks, etc). Onthe diagram, identifyby letter andbriefly describe each worker activity. (2)- Provide the identity, the approximate weight (bykg/day orkg/batch, onan 100% new chemical substancebasis), and entrypoint of all feedstocks (includingreactants,

solvents and catalysts, etc) and ofallproducts, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch). (3)
-- Identifybynumber the points ofrelease, including small orintermittentreleases, to the environment of the new chemical substance. (4) PI-"""'the•

# of""" (

**-~** 

### ro Hiontify the l=tiDn>

# of"""' •itos



### ~ • 

### <~tinua•~"""'~ 

# .,.,.--...,

-- #ofSltes



## L--- 

# - 0 Mark (X) thisbox ifyou attach a continuation sheet. 2. Worker Exposure/Environmental Release (1)- Fromthe diagram above, provide the letter for eachworker activity. Complete 2-8 for each worker activity described. (2)- Estimate the number ofworkers exposedfor all sites combined. (4)- Estimate the typical duration of exposureper worker in (a) hours per day and (b) days per year. (6)- Describe physical form ofexposure and% new chemical substance (ifinmixture), and any protective equipment and engineering controls used to protect workers. (7)
- Estimate the percent ofthe new substance asformulated whenpackaged or used as a final product. (9)
-- From theprocess diagram above, enter the number ofeachrelease point. Complete 9-13 for eachrelease pointidentified. (10)- Estimate the amount ofthe new substancereleased (a) directly to the environment or (b) into control technology to the environment (inkg/day orkg/batch). (12)- Describe media ofrelease 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, ifany, that will beused to limit the release ofthe new substance to the environment. (14)- Identify byproducts whichmayresult from the operation. (3), (5), (8), (11), (13) and (15)- Mark (X) this column if any ofthe proceeding entries are confidentialbusinessinformation (CBI). Letter #of CBI Duration CBI Protective Equip. 

### I '7oin CBI Release Amount of CBI Control CBI

of Workers of Engineering Controls/ Form- Number New Technology Act- Exposed Exposure Physical Form and % ulation Substance ivity new substance Released I (lOa) : (lOb) (1) (2) (3) (4a) I (4b) (5) (6) (7) (8) (9) (11 (12) (13) I I 

# 'I I 

# K X I 

# y 

# f<" I I I 

# y· I 

# 'X I I 

# [>< I 

# IX \ 

# v I I / 

### I' --' I I I I I I I I I I I I (14)- Byproducts: (15)



## ~Mark (X) this box ifyou attach a continuationsheet. FORM EPA 7710-25 (Rev. 5-95) Page10 A

### p.15 

## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE-- Continued

**~** 

### Section B
- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfor typical processing oruse 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 mustreport any processing or use activities after import. See the Instructions Manual. Camplete aseparate section B for each type of processing, or use operation involving the 

### new chemical substance. lfthe same operationis performed at more than one site describe the typical operation commonto these sites. Identify additional sites on a continuation sheet. 1. Operation Description

- To claim informationinthis section as confidential, circle orbracket 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, 55gallon 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 orkg/batch, onan 100% new chemical substance basis), and entry point of all feedstocks (includingreactants, solvents and catalysts, etc) and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per OOI<h). (3) -ldontifybymnnbo< tho,-.,

## of,..,.,., lncludmg ....U

**~ mtenn!ttent.-el~~.**  to lho

**~~** oh..U<ol '"""""' ( 4) Please enter the # ofsites ( remember to identify the locations of these sites ona continuation sheet) :

**~** 

# r- #otstt



# 0onta1ns Confidential Business Information l..---' "'-... 

# 0 Mark (X) thisbox ifyou attach a continuation sheet. 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 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)
-- Describephysical form ofexposure and% new chemical substance (ifinmixture), andany protective equipment and engineering controls used to protect workers. (7)
- Estimate the percent ofthe new substance as formulated whenpackaged or used as a final product. (9)
- From the process diagram above, enter thenumber ofeachrelease point. Complete 9-13 for eachrelease pointidentified. (10)- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day orkg/batch). (12)- Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land orincineration, POTW, or other (specify) and control technology, ifany, that will beused to limit the release of the new substance to the environment. (14)- Identifybyproducts whichmayresult from the operation (3), (5), (8), (11), (13) and (15)- Mark (X) this column if any ofthe proceeding entries are confidential business information (CBI). Letter #of CBI Duration CBI Protective Equip. 

### I !%in CBI Release Amount of CBI Control CBI

of Workers of Engineering Controls/ Form- Number New Technology Act- Exposed Exposure Physical Form and % ulation Substance ivity new substance Released I (lOa) : (lOb) (1) (2) (3) (4a) I (4b) (5) (6) (7) (8) (9) (11 (12) (13) I I 

# y I



# ~ 

# x I 

# x k I I I I I I I I I I I I I I I I I I I I I (14)
- Byproducts: (15)



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

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



## /~

### p.16 

## Part II
-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE --Continued

**~** 

### Section B - INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfor typical processing oruse operations involving the new chemical substance at sites you do not controlImporters do not have to complete this sectionfor operations outside the U.S.; however, youmustreport any processing or use activities after import. See the Instructions Manual. Ccnnplete aseparate section B for each type of processing, or use operation involving the new chemical substance. Hthe same operationis performed at more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet. 1. Operation Description

- To claim informationinthis section as confidential, circle orbracket 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 gallonpails, 55gallon drums, rail cars, tank trucks, etc). Onthe diagram, identifyby letter andbriefly describe eachworker activity. (2)- Provide the identity, the approximate weight (by kg/day orkg/batch, onan 100% new chemical substancebasis), and entrypoint of all feedstocks (including reactants, solvents and catalysts, etc) and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch). (3) -- Identifyby number the points ofrelease, including small or intermittentreleases, to the

**environmen~** the new chemical substance. (4) Please enter the# of sites (remember to identify the locations ofthese sites on a continuation sheet) : 

### 71 ol sttes



# -~



# vonta1ns Confidential 

# L--- Business 

# Information "-- 

# 0 Mark (X) this box ifyou attach a continuation sheet. 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 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 form ofexposure and% new chemical substance (ifinmixture), and any protective equipment and engineering controls used to protect workers. (7)
-- Estimate the percent ofthe new substance as formulated whenpackaged or used as a final product. (9)
- From the process diagram above, enter the number ofeachrelease point. Complete 9-13 for eachrelease pointidentified (10)- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (inkg/day orkg/batch). (12)- Describe media ofrelease i.e. stack air, fugitive air (optional-see InstructionsManual), surface water, on-site or off-site land or incineration, POTW, or other (specify) and control technology, if any, that will beused to limit the release ofthe 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 any ofthe proceeding entries are confidentialbusiness information (CBI). Letter #of CBI Duration CBI Protective Equip. 

### I %in CBI Release Amount of CBI Control CBI

of Workers of Engineering Controls/ Form- Number New Technology Act- Exposed Exposure Physical Form and % ulation Substance ivity new substance Released I (lOa) : (lOb) (1) (2) (3) (4a) I (4b) (5) (6} (7) (8) (9) (11 (12) (13) I I 

# v I 

# IX' I 

# )< 

# >< I 

# [><. I I I I I I I I I I I I I I I I I I I I (14)
- Byproducts: (15) 

# 0 Mark (X) this box ifyou attach a continuation sheet. FORM EPA 7710-25 (Rev. 5-95) Page 10 C 

# 16

### p.17 

## OPTIONAL POLLUTION PREVENTION INFORMATION To claim information in this section as confidential circle orbracket the specific information that you claim as confidential. 

## In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal ofthe PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and 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 ofuseful chemical components from wastes thatwould otherwise be treated or released as air emissions or water discharges, or land disposal. Descriptions ofpollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and canbe either quantitative or qualitative. The EPA is interested in this information to assess overall net reductions intoxicity 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 onthe relative cost or performance characteristics of the PMN substance to potential alternatives maybe provided. All information provided in this section will be taken into consideration during the review of this substance. See the revised Instructions Manual thatincludes a Pollution Prevention manual for guidance and examples.



# \Jon;.~~--- De=ibe 

### the expected netbenefit>,

# •uch., (1) <m 

### ovenill <edu<tion in 

### risk to

### human h 

# Jl.,~tion in 

### the volume manufactured; {3) a reduction in the generation ofwaste materials through recycling, so . er means; (4) a reduction in potential toxicity orhuman exposure and/or environmental release; (5) an increase in pro performance, a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar applications; 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. The PMN chemical, HFC-43-10mee, is a replacement for environmental undesirable solvents CFC-113, perfluorocarbons and Methychloroform in many cleaning and solvent applications. The ODP (Ozone Depletion Potential) of HFC-43-1 Omee is zero and GWP (Global Worming

**Potentia~** is less than 1/5 that of CFC-113. The atmospheric life ot lhe PMN chemical is about 20 years compare to that of Perfluorocarbons of 2D00-3000 years. Also, the PMN chemicals atmospheric life is such that is should not contrl>ute to atmospheric pollution by decomposing In lower stratosphere and therefor should be exempted from VOC regulations. Thus, the PMN chemical should significantly enhance global environmental quality.



# - The PMN

**ch~mi~l H~C-43-1**  Omee is made from fairly expensive raw materials and fairly proprietary process. We, therefore expect to

**sell~** [ range for a fa1rly h1gh-1n-value 

# y

uses. The cleaning equipment to be used with this material are expected to be upgraded to minimize losses from the equipment. Also, the boiling point of this material is about 

### rc higherthan 

### CFC-113 which will further enhance containment of this material in the equipment to be used with this chemical.

Due to 10dvances in process and equipment

**technol~,** and the high cost of raw materials and final product, the manufacturing and cleaning processes will be

**h~hly** controlled, thereby reducing the

**probab1l~1es** and magnrtudes of losses from spills a fugrtive emissions. The best current available technology wHI be used to minimize these losses and maximtze recycling and containment.


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

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

# 17

### p.18 

## Part III-- LIST OF ATTACHMENTS
Attach continuation sheets for sections ofthe form and test data and other data (including physical/chemical properties and structure/activity information), and optional informationafter this page. Clearly identify the attachment and the section ofthe form to whichitrelates, ifappropriate. Number consecutively the pages ofthe attachments. In the columnbelow, enter the inclusive page numbers of each attachment. Mark (X) the "Confidential" boxnext to any attachment name you claim as confidential. Read the Instructions Manual for guidance onhow to claim any informationin anattachment as confidential. You must include with the sanitized copy of the notice form a sanitized version ofany attachment in which you claim informationas confidential. Attachment name Attachment Confipage number(s) dential



### ~. 

## Material Safety Data Sheet (MSDS)

2. Physical and Chemical Properties 3. 

# X 4. 

## Toxicology Assessment 5. Environmental Effect Data 

# Co, 

# /o'>/1

**c_c.(o~~ .s~**  

# '- D(E 

### S 

# S.' 

# ,. eyV) tJ

- '- E.E 

## L

**r;~.** 

# p.::_

**v~~-** 

# <.r3 'C 

# ( f>u lt7 

# h. t- 

### ~.,~ {..)



# ...



# D Mark (X) this box ifyou attach a continuation sheet. Enter the attachment name and number. FORM EPA 7710-25 (Rev. 5-95) Page 12 

# If

### /~• l 1'. ' .. 

## t : , . '-...... :\. .... , i'r 

## DuPont Material Safety Data Sheet p.19 

## Page 1



# ---------------------------------------------------------------------- 05570733 HFC-43-10MEE Revised 4-AUG-1995 CHEMICAL PRODUCT/COMPANY IDENTIFICATION Material Identification Corporate MSDS Number CAS Number Formula Molecular Weight : DU008057 138495-42-8 CF3CHFCHFCF2CF3 252 Printed 7-0CT-1996

CAS Name : Pentane, 1,1,1,2,3,4,4,5,5,5-decafluoro 

## Tradenames and Synonyms 2,3-DIHYDROPERFLUOROPENTANE 43-10MEE Company Identification MANUFACTURER/DISTRIBUTOR DuPont
PHONE NUMBERS 1007 Market Street Wilmington, DE 19898 Product Information Transport Emergency Medical Emergency : 1-800-441-9442 : CHEMTREC: 1-800-424-9300 : 1-800-441-3637 COMPOSITION/INFORMATION ON INGREDIENTS Components Material 1,1,1,2,3,4,4,5,5,5-DECAFLUOROPENTANE HAZARDS IDENTIFICATION Potential Health Effects INHALATION CAS Number 138495-42-8 % 

## 99

Gross overexposure may cause: Suffocation, if air is displaced by vapors. Based on animal data, repeated or excessive overexposure may cause the following effects: Central nervous system stimulation with increased activity or sleeplessness. Tremors. Convulsions. These effects may be 

## followed by: Central nervous system depression with dizziness, confusion, incoordination, drowsiness or unconsciousness. Potential effects based on data from OTHER FLUOROCARBONS: 

# ;;g /'I

## 05570733 DuPont**p.~ge** 

## Material Safety Data Sheet (HAZARDS IDENTIFICATION

- Continued) Gross overexposure may cause: Irregular heart beat with a strange sensation in the chest, "heart thumping", apprehension, lightheadedness, feeling of fainting, dizziness, weakness, sometimes progressing to loss of consciousness and death. It is unlikely that concentrations sufficient to produce irregular heartbeat would be achieved from 1,1,1,2,3,4,4,5,5,5-DECAFLUOROPENTANE without first producing other signs of toxicity. SKIN CONTACT Immediate effects of overexposure may include: Slight irritation with itching, redness or swelling. Repeated and/or prolonged exposure may cause: Defatting of the skin with itching, redness or rash. Data to evaluate the skin permeation hazard of this compound are insufficient. There are no reports of human sensitization. EYE CONTACT Immediate effects of overexposure may include: Eye irritation with tearing, pain or blurred vision. INGESTION The major ingestion hazard is aspiration (liquid entering the lungs during ingestion or vomiting) which may result in "chemical pneumonia". Symptoms include coughing, gasping, choking, shortness of breath, bluish discoloration of the skin, rapid breathing and heart rate, and fever. Pulmonary edema or bleeding, drowsiness, confusion, coma and seizures may occur in more serious cases. Symptoms may develop immediately or as late as 24 hours after exposure, depending on how much chemical entered the lungs. ADDITIONAL HEALTH EFFECTS Increased susceptibility to the effects of this material may be observed in persons with pre-existing disease of the: central nervous system, cardiovascular system. Carcinogenicity Information None of the components present in this material at concentrations equal to or greater than 0.1% are listed by IARC, NTP, OSHA or ACGIH as a carcinogen.


# ltf 2

## 05570733 DuPont p. 

## mage 3 Material Safety Data Sheet



# ---------------------------------------------------------------------- FIRST AID MEASURES



# ---------------------------------------------------------------------- First Aid INHALATION If inhaled, immediately remove to fresh air. Keep person calm. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Call a physician. SKIN CONTACT Flush skin with water after contact. Wash contaminated clothing before reuse. EYE CONTACT In case of contact, immediately flush eyes with plenty of water for at least 15 minutes. Call a physician. INGESTION If swallowed, do not induce vomiting. Immediately give 2 glasses of water. Never give anything by mouth to an unconscious person. Call a physician. Notes to Physicians Activated charcoal mixture may be 

## administered. To prepare activated charcoal mixture, suspend 50 grams activated charcoal in 400 mL water and mix thoroughly. Administer 5 mLfkg, or 350 mL 

## for an average adult. Because of a possible increased risk of eliciting cardiac dysrhythmias, catecholamine drugs, such as epinephrine, should be used with special caution in situations of emergency life support. Because of the danger of aspiration, emesis or gastric lavage should not be employed unless the risk is justified by the presence of additional toxic substances. Activated charcoal may induce vomiting, but may be given after emesis or lavage to absorb toxic additives. Steroid therapy in mild to moderate cases does not improve outcome. Bacterial pneumonia often occurs after exposure, but prophylactic antibiotics are not indicated and should be reserved for documented bacterial pneumonia.

# J~

### 05570733 

## DuPont 4 

## Material Safety Data Sheet 

# ---------------------------------------------------------------------- FIRE FIGHTING MEASURES 

# ---------------------------------------------------------------------- Flammable Properties Flash Point Method None Tag Open Cup
- TOC. Fire and Explosion Hazards: Use water spray or fog to cool containers. Drums may rupture under fire conditions. Decomposition may occur. Extinguishing Media As appropriate for combustibles in area. Fire Fighting Instructions Self-contained breathing apparatus (SCBA) is required if drums rupture and contents are spilled under fire conditions. 

# ---------------------------------------------------------------------- ACCIDENTAL RELEASE MEASURES **----~-----------------------------------------------------------------** 

## Safeguards (Personnel) NOTE: Review FIRE FIGHTING MEASURES and HANDLING (PERSONNEL) sections before proceeding with clean-up. Use appropriate PERSONAL PROTECTIVE EQUIPMENT during clean-up. Evacuate personnel, thoroughly ventilate area, use self-contained breathing apparatus. Spill Clean Up Soak up with sawdust, sand, oil dry or other absorbent material. HANDLING AND STORAGE Handling (Personnel) Avoid breathing vapors or mist. Avoid contact with eyes, skin, or clothing. Wash thoroughly after handling. Material should not be dispensed from its container by pouring, except for small sample containers where fume hoods or where other ventilation is used to manage the exposure limits. The use of a drum pump is recommended for dispensing from shipping containers.0 

## 05570733 DuPont Material Safety Data Sheet **p.~atge** 

## (HANDLING AND STORAGE
- Continued) Storage Store in clean, dry area. Do not heat above 52 deg 

# c (125 deg F) as excessive pressure may cause container to leak or rupture. 5



# ---------------------------------------------------------------------- EXPOSURE CONTROLS/PERSONAL PROTECTION 

# ---------------------------------------------------------------------- Engineering Controls Normal ventilation for standard manufacturing procedures is generally adequate. Local exhaust should be used when large amounts are released. Mechanical ventilation should be used in low or enclosed places. Personal Protective Equipment Impervious gloves and chemical splash goggles should be used when handling liquid. Under normal manufacturing conditions, no respiratory protection is required when using this product. Self-contained breathing apparatus (SCBA) is required if a large release occurs. # 

## Exposure Guidelines Exposure Limits HFC-43-lOMEE PEL (OSHA) TLV (ACGIH) AEL 

# * (DuPont) : None Established None Established : 200 ppm, 8 

# & 12 Hr. TWA 400 ppm, Ceiling 

# * AEL is DuPont's Acceptable Exposure Limit. Where governmentally imposed occupational exposure limits which are lower than the AEL are in effect, such limits shall take precedence. 

# ---------------------------------------------------------------------- PHYSICAL AND CHEMICAL PROPERTIES Physical Data Boiling Point Vapor Pressure Solubility in Water pH Form Color Density 55 C (131 F) 226 mm Hg @ 

## 25 C (77 F) : Insoluble : Neutral : Liquid Clear, colorless 1.58 gjcm3 @ 

## 25 

# c (77 F) 13.2 lb/gal

## 05570733 DuPont p.P4lge 6 

## Material Safety Data Sheet 

# ---------------------------------------------------------------------- STABILITY AND REACTIVITY 

# ---------------------------------------------------------------------- Incompatibility with Other Materials Incompatible with alkali or alkaline earth metals
- powdered Al, Zn, Be, etc. Decomposition Decomposition:
Polymerization Decomposition products are hazardous. HFC-43-10mee can be decomposed by high temperatures (open flames, glowing metal surfaces, etc.) forming, hydrofluoric acid and possibly carbonyl fluoride. Polymerization will not occur. TOXICOLOGICAL INFORMATION Animal Data EYE: Animal testing indicates this material is a mild eye irritant. SKIN: LD50: No information found. Animal testing indicates this material is a slight skin irritant, but not a skin sensitizer. INGESTION: No information found. INHALATION: 4 hour, ALC, rat: 10,000 ppm (Very low toxicity). 1,1,1,2,3,4,4,5,5,5-DECAFLUOROPENTANE 5,000 ppm. Single exposure caused: Tremors. No cardiac sensitization was observed. 1,900
- 3,500 ppm Single and repeated exposure caused: the following temporary effects
- Tremors or convulsions. Behavioral effects. Altered clinical chemistry. No-observed-Adverse-Effect-Level (NOAEL): 500 ppm CARCINOGENIC, DEVELOPMENTAL, REPRODUCTIVE, MUTAGENIC EFFECTS:

### 05570733 

## DuPont Material Safety Data Sheet p. 

## fSige (TOXICOLOGICAL INFORMATION
- Continued) Animal data show developmental effects only at exposure levels producing other toxic effects in the adult animal. No animal data are available to define the following effects of this material: carcinogenicity, reproductive toxicity. Tests have shown that this material does not cause genetic damage in bacterial or mammalian cell cultures. It has not produced genetic damage in tests on animals. 7



### -------------------------------------------------~-------------------- 

## DISPOSAL CONSIDERATIONS 

# ---------------------------------------------------------------------- Waste Disposal Reclaim by distillation or remove to a permitted waste disposal facility. Comply with Federal, State and local regulations.


# ---------------------------------------------------------------------- TRANSPORTATION INFORMATION 

# ---------------------------------------------------------------------- Shipping Information DOT/IMO Proper Shipping Name : NOT REGULATED BY DOT OR IMO


# ---------------------------------------------------------------------- REGULATORY INFORMATION 

# ---------------------------------------------------------------------- u.s. Federal Regulations TSCA Inventory Status : Listed. TITLE III HAZARD CLASSIFICATIONS SECTIONS 311, 312 Acute 

# . Yes 

# . Chronic 

# . No 

# . Fire 

# . No 

# . Reactivity No Pressure 

# . No 

# . LISTS: SARA Extremely Hazardous Substance
- No CERCLA Hazardous Substance
- No SARA Toxic Chemicals
- No



# /df 

# J5

### 05570733 

## DuPont 8 

## Material Safety Data Sheet 

# ---------------------------------------------------------------------- OTHER INFORMATION NFPA, NPCA-HMIS NPCA-HMIS Rating Health Flammability Reactivity 1 0 

### 1 

## Personal Protection rating to be supplied by user depending on use conditions.
The data in this Material Safety Data Sheet relates only to the specific material designated herein and does not relate to use in combination with any other material or in any process. Responsibility for MSDS Address > 

## > 

## Telephone DuPont Chemicals Engineering 

# & Product Safety : P.O. Box 80709, Chestnut Run Wilmington, DE 19880-0709 (302) 999-4946 # 

## Indicates updated section.End of MSDS

# I ., '

**~** 

### ;

**~c.** 

### ...... ,/""'\ ·:::"- _,-

**~** 

### ______________ ...:._ _ __;_______ __::.____________ ----tp:r..1!2T-7---- ['dYSlCAL

**A:'~D** CHE:\UCAL PROPERTIES WORKSHEET 

## r.J t·;:;,;t EPA'; revte'"' of

**ph:1~1Clllllnd** chem•c.ll prop<!!rties

**J.>t~. plel~**  complete the followillg worksheet fur J,ltJ you ?rovide

**~c...!** "'dude •t •n the nonce. Identify the property me.uured, the

**po~ge** of the notice on wluch the property

**.appea~.** the v.alue ,)f the propeny. the units in which the proper1y is me.asured (as necessary)• .and whether or not the property is claimed as confidential. You are not re<1uired to submit this worksheet; however. EP. .S.. strongly recommends tl1.at you do so. u it will simplify

**re·11·~·.v** .1nd ensure :h.at confidential information is properly protected. You should submit this worksheet .lS a supplement to your ;ubmission of test d.lt.J. This worksheet is not a substitute for submo.SSion of test do11.1.

**?rope~/** Mark {X) if ?.lge Value provided number {a) (b) {c) Vapor"pressure 

## 25 

# ·c X 

## 22, @Temperature Torr DensityI relative density 

## 25°C X 

## 1.56 g/an3 Solubility 

## RT 

## -c X 

## Fully miscible

@Temperature Solvent 

## Alcohols, H;tdrocarbons g/L Solubility in water 0 Tempentuft 

## 29-c X 

## 170 ppm g/1. Melting temperature 

### X 

## -· -80 

## -c Boiling/sublimation temperature 

### fl 

## 760 torr pressure 

### X 

## 54°C Spectra 

## Infrared X



# . Dissociation constant 

## Color

**1'mtde"S'ia"ttts~lt"** 

### X 

## Clear, colorless Octanol/water partition coefficient Henry's Law constant Volitalization from 

### water Volitalization from soU pH @ concentration Flammability 

### X 

## Nonflanunable Coniidential Mark (X)

(d)

**~abtlity-** 

## Form X 

## Liquid at 

## R.T. Adsorption/coefficient Other- Specify 

### X 

## Critical Temperature X 

## l80.6l°C Critical Pressure X 

## 331.9 psia Critical Volt.!me X 

## 0.433 liter/mol Critical

**Com~ressibility** 

### X 

## 0.263 

# l ·;

I ' I I I ; ,

### ~ont 

# · Bus.atnsConfidential 

# lnessInformat· 

# ton p.28

# T..0."\.1 CObQGY
**ASSESS~IENT** 

# OF HFC-431Omce DuPont

**ur:publish~d** 

### toxicity studies for HFC-B 

## lOmee are reviewed below, and copies of the originJ.l reports are 

### included 

## in Appendi.""< A. 

## STJM1,1ARY Overall, HFC-4310mee has low toxicity. The compound was only a slight skin p.29



## and eye irritant. and had low inhalation toxicity. Signs indicative ofneurotoxicity were evident in rats during the 90-day inhalation study at exposure concentrations of2000 and 3500 ppm; no effects were evident at 500 ppm, the lowest concentration tested. Slight decreases in motor activity were evident the day following exposure at 3500 ppm only. Slight developmental toxicity was observed in rats at an exposure concentration of3500 ppm, and was observed 

# as a decrease in fetal body weights. Maternal effects, body weight decreases and convulsions, were also observed at 3500 and 2000 ppm. HFC-4310mee was notmutagenic 

## in an Ames assay. and was not clastogenic 

## in an 

## in vivo micronucleus study. No cardiac sensitization response was observed in experimental screening studies with dogs at 5000 ppm. The occurrence ofconvulsions at 10,000 ppm. however. precluded further cardiac sensitization studies. Based on these studies, DuPont established an internal occupation exposure limit (Acceptable Exposure Limit. AEL) of 200 ppm. 8- and 12-hourTWA. and a 15-minute Short-tenn Exposure Limit of400 ppm. ACUTE TOXICOLOGY S1UD1ES
HFC-4310mee was evaluated for eye irritation potential 

## in three New Zealand white rabbitsO). Approximately 0.1 mL ofthe material was placed into the conjunctiVal sac of each test anima4 and the conjunctiva. 

## iris and cornea subsequently scored for irritation at 1. 24. 48 and 72 hours post-treatment. The eyes remained unwashed during the study. Slightconjunctival redness was 

## observed at 1 and 24 hours postexposure, but 

## allirritation had resolved by 48 hours after treatment. 

## In a dennal irritation study. 0.5 mL ofthe test material was applied under an occlusive patch to the clipped, intact skin ofthree 

## New Zealand white rabbits for 4 hours(2). Dennal irritation was scored at 1, 24, 48, and 72 hours after the end of the exposure period. Slight, transient dennal irritation was observed in one rabbit at 24hours after exposure. No irritation was observed in the other animals. Seven groups ofmale Crl:CD®BR rats (n=6/group) were exposed nose-only for 4 hours to several vapor concentrations ofHFC-431Omee(3). Afterexposure, the animals were observed for 14 days. Mortality occurred 

## in rats exposed to 10,000 ppm and greater within one day ofexposure (Table 1). Slight to severe body weight losses were observed in surviving rats one day 

## after exposure. but all 

## animals gained weightduring the recovery period. Based on mortality, the approximate lethal 

## concentration 

## CALC) for 

## HFC4310mee was 10.000 ppm. 1

## TABLE l

**~!ORTALITY** 

## IN RATS EXPOSED 4 HOURS TO 

## HFC-43l0mee


## 5200 7900 10,1001 

## 10,200 10.500 1 

## 19,400 67,800 

# 0/6 0/6 3/6 4/6 216 

# 6/6 516 p.30



## A group of six beagle dogs was exposed via a face mask to HFC-4310mee concentrations of 1000. 5000 or 10.000 ppm(4). About 5 minutes after initiation of exposure. the dogs were injected intravenously with a challenge dose of

**epin~phrine** 

## to 

## assess the potential for HFC-4310mee to induce a cardiac sensitization response. No cardiac sensitization response was observed at either 1000 or 5000 ppm. At 10.000 ppm, severe convulsions were observed in one dog which precluded a determination of a cardiac sensitization response. The other test dogs and higher exposure concentrations were not tested because ofthe conwlsive response. The conwlsions observed 

## in this study were not unexpected based on previous subchronic and rangefmding studies (see below). SUBCHRONIC TOXICOLOGY STUDIES Four groups of 10 male Crl:co®BR rats were exposed nose-only to HFC4310mee concentrations of0, 500, 1000 or 4000 ppm 6 hours/day. 5 days/week over 12 days(5). A functional observation battery (FOB) was performed prior to and 

## immediately following the third 

## and eighth exposure. After the ninth exposure urine and blood samples were collected for clinical pathological evaluations. Following the last exposure the animals were sacrificed for gross and microscopic examinations. All animals 

## survived the study duration. Significantly lower body weights were observed in rats in the 500 and 4000 ppm groups. However, 

## in the absence of a doserelated effect. these 

## body weight changes were not considered toxicologically significant Furthermore. a decrease 

## in body weights ofanimals placed 

## in restraining devices 

## is not an unexpected outcome. No compound-related clinical observations were detected, and no compound-related effects 

## in the FOB were observed. No compound-related organ weight changes or gross or microscopic observations were detected 

## in the animals. Therefore,

1 

### Two samples ofEFC-4310mee were used in 

### this ALC study, and the composition of the samples differed slightly. For these samples (footnoted as 1) 

### the composition was 98.6% pure with 1.3% ofa HFC-4310mee isomer. The sample used to 

### ge:-:erate the remainder of these data 

### had a purity of95.6% with 4.2% ofa HFC-4310mee isomer. 

### 2

## untkr tl:e

**~uditior".s ~:"·t.'1is**  

## study. the **no-obser~~ble-ldverse-effect** 

## level (NOAEL) for this nosl.!-only

**2-w~;;:k** 

## study was

**~000** 

## ppm. p.31



## In 

## preparation to initiate the 90-day inhalation study, a series of inhalation rangefmding studies(6) were conducted to select concentrations for the 90-day inhalation study. During these range-finding studies, clinical signs of neurotoxicity were observed that occurred when a certain chamber concentration was reached (>3500 ppm). However, the clinical signs were transient, and were no longer observed approximately 2 hours (depending on concentration) after their fli'St occurrence even though the animals continued to be exposed to 

## the test material. Following termination of the exposure, some animals were evaluated with an abbreviated FOB. However, clinical signs ofneurotoxicity were not observed after the conclusion of the exposure or prior to a subsequent exposure. On subsequent exposure days, the same pattern ofclinical signs was repeated with exposure to HFC-4310mee. In 

## the rangefmding study. 

## 5 male and 

## 5 female rats per concentration were exposed four times for 6 hours to nominal concentrations of4000 or7000 ppm ofthe test

## material. The study was conducted in stainless steel chambers with a glass window for gbserving the animals. However, because ofchamber construction not 

## all ofthe animals were visible at any given time. During exposure, the animals were observed for clinical signs of toxicity. After exposure, an abbreviated FOB was conducted. The test material provided contained a different concentration of a low boiling diastereomer ofHFC-431Omee designated as Isomer A and a higherboiling HFC4310mee diastereomer designated as IsomerB. The fU"St batch of test material used for the rangefmding study contained 8.9% ofisomer A and 90.8% ofisomerB. However, because oflimited 

## test material, a second batch of material, containing 6.5% ofIsomer A and 93.3% ofIsomer B, was used in the 

## three subsequent exposures. The results of

## this rangefinding study for each exposure are presented below.
• Exposure #1 (Test Material- 8.95% Isomer A /90.84% Isomer B): Two groups ofrats were exposed to target concentrations of4100 and 7000 ppm, respectively. Within 20-30 minutes after initiation ofexposure to 

## 4100 ppm, animals 

## exhibited clinical signs of jwnping, flipping and had nasal discharge. Within 45 minutes after initiation of the exposure, the animals that were visible through the chamber window did not respond to a sound stimUlus. However, approximately 3 hours after the beginning ofthe exposure, the 

## animals responded normally to a sound stimulus. At the conclusion ofthe exposure, the results ofthe abbreviated FOB were similar to pre-exposure. Animals exposed to a target concentration of7000 ppm were inadvertently overexposed to a concentration ofapproximately 11.00) ppm. Clinical signs included jumping, convUlsions, gasping, labored breathing and flipping. Mortality occurred 

# :n 50% of the animals within 40 minutes. Tne remainder ofthe exposure

**~rcceeded** 

## with chamber concentrations ranging between 5000 and 

## 3

## 10.000 ppi..**Th~** 

## :lnim:.1Is which survived**lh~ ~xp~c** **.w~re** 

## :i:.lcrificed 

## without**pltholog:.:~ ~v:llu:1tion**  

## or a FOB ev:lluation.
• Exposure ;f2 

## i_T;!st M:uerial- 6.5% 

## Isomer A I 

## 93.3% Isomer B): Prior to the start of the second exposure, the animals previously were evaluated by an abbreviated FOB. There were no abnormal clinical signs observed. About 30 minutes after vapor generation was initiated (at a chamber concentration of approximately 4000 ppm). clinical signs of tremors. shaking, flips. and convulsions were observed. Within 1 hour after vapor generation was initiated, the animals responded normally to a sound stimulus. For the remainder ofthe exposure period (approximately 3 hours due to a power failure), the chamber concentntion ranged between 4000-5000 ppm. A group ofpreviously unexposed males and females (5/sex) were exposed to 

## a target concentration of7000 ppm. Approximately 15 minutes after initiation of exposure, clinical signs oftremors, abnormal gait, twitching, convulsions, and low posture were observed when the chamber concentration was app["')x.imately 4200-5300 ppm. The exposure continued approximately 4 hours and clinical signs were observed throughout the exposure period at concentrations ranging from 5000-7300 ppm. • Exposure #3 (Test Material

- 6.5% Isomer A /93.3% Isomer B): p.32



## Prior to the start ofvapor generation, there were no abnormalities detected 

## in the abbreviated 

## FOB conducted on animals receiving two previous exposures to · 4000-5000 ppm. Within 20 minutes after initiation ofvapor generation (at a chamber concentration ofapproximately 3500 ppm), clinical signs of convulsions.jerky movements, involuntary muscular reflexes, and discharge from the mouth were observed. Approximately 1 hour after initiation ofvapor generation, the animals responded to a sound stimulus, but were lethargic (at chamber concentration ofapproximately 4,600 ppm). Approximately 2 hours after initiation, the animals responded normally to 

## sound, and there were no additional clinical signs for the remainder ofthe exposure (at chamber concentrations ranging up to 

## approximately 5,900 ppm). After the conclusion of the exposcre, there were no abnormalities detected in an abbreviated 

## FOB. Prior to the start ofvapor generation, there were no abnormalities detected 

## in an abbreviated 

## FOB in animals previously exposed to approximately 7,000 ppm. Within 20 minutes after initiation ofvapor generation (at a chamber concentration of approximately 4,500 ppm) convulsions and seizure-like clinical signs were noted. Approximately 1 hour after exposure initiation, the animals respondee**~** 

## a sound stimulus. but were lethargic (chamber concentration was**approxim:1~ly** 

## 5,800 ppm). Approximately 2.5 hours after exposure initiation, the anirn:Ls responded normally to sound, and there were no additional clinical signs fer :.':e remainder of the exposure (at chamber concentrations ranging up to 4

## appro:tirr...l:.ely 7 .lOO ppm). 

## After the conclusion of 

## the exposure. several animals were noted to have discharge from the nose and mouth.
•**Exposure~** 

## CTest Material- 6.5% Isomer A I 

## 93.3% Isomer B): p.33



## Prior to the start 

## of vapor generation, no abnormalities were detected in the FOB conducted on 

## animals which had three previous exposures to HFC-4310mee. Within 1 hour after initiation of vapor generation (at a chamber concentration of approximately 4,900 ppm), seizure-like clinical signs were observed. Within 2.5 hours after vapor initiation (at a chamber concentration of approximately 4,900 ppm), the animals responded normally to sound and there were no additional signs for the remainder of the exposure. After the conclusion of the exposure, there were**~o** 

## abnonnalities detected in the FOB. 

## In a FOB conducted prior to the start of vapor generation on animab which received two previous exposures to approximately 7,000 ppm, several animals exhibited labored 

## breathing. Within one hour after initiation ofvapor generation (at a chamber concentration of approximately 5,500 ppm), seizure-like clinical signs were observed. Within 2.5 hours after vapor initiation (at a chamber concentration of approximately 6,500-7,000 ppm), the animals responded normally to 

## sound and there were no additional clinical signs for the remaind.er of the exposure. After the conclusion ofthe exposure, 1 animal was found dead, and several animals were noted to have labored breathing.

Based on the results of

## this study. it was apparent that the neurotoxicity induced by HFC-4310mee was an acute phenomenon and that cumulative toxicity was notevident The convulsive response was clearly observed at concentrations of 3500 ppm and greater. Because this response was an acute response to the test material, a series ofsingle exposure studies were conducted to better define a possible "threshold" for 

## this response to ensure adequate dose selection for the 90-day study. Furthermore, the concentrations ofisomers A and B were modified to determine ifthe toxicity ofthe test material also changed with the composition.
• Single Exposure (1.03% isomer A /98.8% isomer B): Four male rats per concentration were exposed to nominal concentrations of approximately 2,000, 3,000, or 4,000 ppm. Seizure-like behavior occurred at a chamber concentration of 3,759 ppm (actual). Clinical signs oftoxicity were not observed during exposures to nominal concentrations of 3,000 ppm or below.
• Single Exposure (44.85% Isomer 

## N 53.11% Isomer B): Four male rats per concentration were exposed to nominal concentrations.of approximately 500

- 5,000 ppm. Seizure-like behavior occurred at a chamber concent.'"ation of 4,538 ppm (actual)and above. Clinical signs of toxicity were not obse::·ved during exposures to concentrations of4,200 ppm (actual)or below.


## 5 

# :1.::1

## • Single Exposure (3.95% isomer A /90.84% isomer B): Four male nts 

## were exposed to a nominal concentration of 4,000 ppm. Seizurelike behavior occurred at a chamber concentration of 4,385 ppm (actual). p.34



## Based on the results of the rangefinding studies, the 90-day inhalation study was conducted at concentrations afO, 500,2000 and 3500 ppm(7). Exposures were conducted whole-body for 6 hours/day, 

## 5 days/week for 13 weeks. A FOB and an assessment of motor activity (MA) 

## were conducted on 10 rats/group prior to initiation of the study, and at weeks 4, 8 and 13. The FOB and MA were conducted on non-exposure days about 16 hours following the preceding exposure. Clinical pathology and pathology measurements were also conducted. No compound-related mortalities were observed. Rats exposed to 2000 and 3500 ppm exhibitedjerking behavior and convulsions during exposure. These Behaviors were observed within about 1 hour ofexposure initiation. Within about 2 hours ofachieving the chamber concentration. the animals appeared to adapt and these clinical signs were infrequently observed. No changes 

## in FOB orMA were observed at 2000 or 500 ppm. At 3500 ppm, a decrease in MA was observed. A compound-related decrease in serum albumin and urine osmolality and an increase 

## in urine volume were evident in male or female rats exposed to 3500 ppm. The biological significance of these fmdings are uncertain since correlative changes 

## in other clinical pathology orpathology measures were not evidenl An 

## increase 

## in urinary fluoride was observed 

## in rats exposed to 2000 and 3500 ppm. 

## This latter fmding was not considered to be 

## adverse, but reflects the possible metabolism ofthe test material. Also, a dose-related decrease in



## ~-oxidation activity towards 14c-palmitoy1 CoA. a measure of peroxisome proliferation. was observed. However. 

## in the absence ofchanges in otherfat metabolism parameters, e.g.• cholesterol. triglycerides, this fmding was not considered 

## to be adverse. No compound-related gross or microscopic changes were noted in 

## any ofthe treated rats. 

## DEVELOPMENTALTOXICOLOGY In a pilot developmental toxicity study conducted in 

## conjunction with the 2-week subchronic study (see above), four groups of time-pregnant rats (n=6/group) were exposed, nose-only, to HFC-4310mee concentrations of 0, 500, 1000 or 4000 ppm 6 hours/day during gestation days 7-16(8). No evidence ofmaternal toxicity was observed throughout the study. Also, no changes in pregnancy rate, fetal viability, resorptions or nidation were observed. Fmally, no fetal toxicity was observed in any of the exposure groups. In 

## the main developmental toxicity study, groups of 25 rats were exposed, wholebody, on days 7-16 of gestation to concentrations of0, 500, 2000 or 3500 ppm(9). A dose-related dec:ease in maternal body weight g3.ins and food consumption were observed at 200) and 

## 35C{) ppm. Also, 

## as in the 90-day study, convulsions were evident in rats 6

### p.35 

## exposed to 2000 l.."':d 350<) 

## ppm. No evidence of m:.1tem:ll toxicity was observed at 500 

## ppm. Signifi.can:.!y reduced fet:ll body weights were observed at 

## 3500 ppm, and were indicative of d!!velopmental toxicity. No other developmental toxicity was evident in the off-spring. Under the conditions of this study. the NOAEL for maternal effects was 

## 500 ppm, and NOAEL for fetal effects was 2000 ppm. GENOTOXICITY HFC-4310mee was evaluated for mutagenicity 

## in 

## S. typhimurium strains T AlOO, TA1535, 

## TA97 and 

## TA98, and in E. 

## coli strain WP2uvrA(pKm101) with and without metabolic activationClO). The maximum concentration tested was 5000 J.lg/mL. No evidence of mutagenicity was observed in any ofthe tester strains. An 

## inhalation micronucleus test was conducted with rats to determine 

## ifHFC43l0mee was a potential clastogen01). Rats were exposed, whole-body: on 

## 2 consecutive days to 

## concentrations of0. 2000. 3500 or7000 ppm for 

## 6 hours/day. Bone marrow smears were prepared approximately at 

## 24 and 

## 48 hours after the second exposure, and 2000 

## cells per animal evaluated. No significant changes in the number of m.icronucleated polychromatic cells were observed at any of the tested concentrations. Therefore, HFC-4310mee was not considered to 

## be clastogenic. 

## In summary. HFC-4310mee has low acute toxicity potential. During exposure, however, clinical signs suggestive ofneurotoxicity are 

## observed, and consist of convulsions, tremors,jerking behavior. etc. 

## These clinical signs 

## are transient, and there appears to 

## be an adaptive response to 

## the exposure, Le., after about 1-2 hours of exposure, no clinical signs ofneurotoxicity 

# are observed. About 

## 16 hours after exposure, reduced motor activity is observed, but only at higherconcentrations (3500 ppm). The convulsive response observed to HFC-4310mee appears to 

## be 

# an acute response. 

# No convulsions are 

## observed after termination ofexposure. but on subsequent exposure 

# days, the same pattern ofclinical signs was 

## repeated during exposure to HFC-4310mee. The no-observed-effect level from the subchronic inhalation studies was 500 ppm. The material produces slight fetal effects (reduced fetal body weights) but does not induce structural changes 

## in offspring. Also, HFC-4310mee was not genotox.ic. Based on these studies, DuPont established an internal occupation exposure limit (Acceptable Exposure Limit, AEL) of 200 ppm, 8- and 12-hour TV{ 

## A. and a 15-minute Short-term Exposure Limit (STEL) of400 ppm. ADDffiONAL STUDIES Additional studies are currently planned for HFC-4310mee and include.
•**Derm~** 

## sensitization in guinea pigs • In vitro chromosomal aberration study with hwnan lymphocytes The re.sults of these studies will be provided when concluded. 

## 7

### p.36



## An additional series of acute and repeated exposure studies are being conducted with the test material to 

## better define the threshold for convulsive effects. During the 90- 

## day study, an accurate incidence ofconvulsions at 2000 

## ppm and above could not be determined because.not 

## all ofthe animals were visible 

## in the chamber at 

## any given time. In this additional study, the animals are being exposed 

## in a Plexiglas chamber such that all of

## the animals 

## are**visib~** 

## Also, during exposure. 

## a modified FOB 

## is being conducted. 

## The results ofthese studies are 

## expected in 

## early 1995.



## 8

### p.37 

# REFERENCES
l. 

## DuPont Company, unpublished data, HLR 

## 386-93, 1993. 2. DuPont Company, unpublished data, HLR 

## 385-93. 1993. 3. DuPont Company, unpublished data, ID...R 

## 77-93, 1993. 4. Huntingdon Research Centre. unpublished data, OPT

## 304/942241, 1993 

## 5. DuPont Company, unpublished data, HLR 

## 819-91. 1991. 

## 6. EPATSCA 8(e) Submission. 

## 7. DuPontCompany. unpublished data, HLR

## 24-94, 1994. 

## 8. DuPont Company, unpublished data, 

## MR. 9146 9. DuPontCompany. unpublished data, HLR 

## 255-94, 1994. 10. DuPont Company, unpublished data, HLR 

## 189-94, 1994. 11. DuPont Company, unpublished data, 

## HLR 

## 53-94, 1994.



## 9 

# :37

## ENVIORNMENTAL EFFECT DATA FOR HFC-43-lOMEE

OZONE DEPLETION POTENTAIL ZERO ATMOSPHERIC LIFE 20.8 YEARS GLOBAL WARMING POTENTIAL 1100 ( 100 YEARS) ( COMPARED TO CARBON DIOXIDE) 375 ( 500 YEARS) VOLATILE ORGANIC CARBON EXEMPTION TO BE FILED (VOC ) p.38

# jJ-r:r~CH}AG~( (c

- 

# -- 

# ·-------

. - 

## Study Title 

## Acute Dermal Irritation/Corrosion Study with HFC-43-1Omee 

# in Rabbits Study Title 

# Primary Eye Irritation Study with HFC-43-1Omee 

# in Rabbits Study Title Mutagenicity Testing ofH-20255 in the Salmonella Typhimurium and Escherichia Coli Plate Incorporation 

# Assay Study Title**~** 

## Rat Bone Marrow Micronucleus Assay ofH-20255 

# By Inhalation Study Title p.39



## Inhalation Approximate Lethal Concentration 

# (ALC) ofH-18780/H-18891 

# inRats

,,, ... ' 

# ..

...,_ t
. 

## HFC-43-1

# O:MEE Assessment ofCardiac Sensitisation Potential 

# in Dogs Study Title 

# Two-Week Inhalation Toxicity Study with HFC-43-1Omee 

# in Male Rats Study Title Developmental Toxicity Study ofH-20255 

# in Rats 

## Study Title Subchronic Inhalation Toxicity: 90 Day Study with H-20255 Inhalation Study 

# in Rates (Volumes 1, 2, 

# & 3)