Company Sanitized 

06 JUL t~ M1 II: 04 

~rk-{j/r:) July 10, 2006 

CONFIDENTIAL AS MARKED [ ] 

Overnight Mail 

Document Control Officer 

Office ofToxic Substances, TS-793 

Document Processing Center 

U.S. Environmental Protection Agency 

EP A East Building 

1201 Constitution Avenue W 

c.J"l 

Washington, DC 20004-3302 

Dear Sir/Madam: 

Enclosed is one Premanufacture Notices (PMNs) for your review. The PMN is provided 

in two (2) forms: 

1. Three originals with confidential portions so marked, and 

2. A sanitized version for the public files. 

This is a re-submittal of a PMN that was previously submitted. A letter of support is 

being submitted separately by [ ] to provide [ 

] 

The PMN fee of $2,500.00 was sent to the HQ Accounting Operations Board for these 

PMN identified by the number [ ]. 

If you need any more information, please contact me. 

Sincerely, 
SANITIZED 

roved. O.M.B. No. 2070-0012. A

u.s. ENVIRONMENTAL PROTECTION AGENCY 

ft PREMANUFACTURE 

~EPA NOTICE

06 JUL 8 AM II : 0 It 

~ I

I 

in the Premanufacture Notice 

GENERAL INSTRUCTIONS 

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


not have actual data. 


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


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


If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS·user fee identification number you have generated. Remember, 


your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (P~·226), P.O. 


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

Part !-GENERAL !NFORMATION 

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

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

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

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

letter in support of your submission should reference your TS user ree identincation 

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

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

submitted. 

Part !I -HUMAN EXPOSURE AND ENV!RONMENTAL RELEASE 

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

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

Part I!l - LI ST OF ATTACHMENTS 

Attach additional sheets If there is not enough space to answer a question flllly. Label 

each continuation sheet with the corresponding section heading. In Part III, list these 

altachments, any test data or other data and any optional infonnation included in the 

notice. 

OPTIONAL INFORMATION 

You may include any infonnation that you want EPA to consider in evaluating the new 

substance. On page I I of this form, space has been provided for you to described 

pollution prevention and recycling information YOIl may have regarding the ncw 

substance. 

So·called "binding" boxes are included throughout this fonn for you to indicate your 

willinl,'11ess 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 notitication IS binding on the submitter when 

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

does not by itself prohibit the submitter from later deviatmg from the information (except 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To assert a claim on the 

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

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

claim as confidential. lfya\! claim information ill the notices as contidential you must 

ruso provide asanitized version or tile notice. (including attachments). For additional 

instructions on claiming information as contidential, read the Instructions Manual. 

TEST DATA AND OTHER DATA 

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

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

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

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

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

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

must be sybmitted if they do not appear in the open literature. You should clearly 

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

composition of the tested material should be characterized. Following are 

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

requirements of §72050 of the Premanufacture Notification Rule (40 CFR Part 

720) 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes Other data 0 Yos 

Health effects data 0 Yes Risk assessments 

Environmental effects data 0 Yes Structure/activity relationships 

Physical/Chemical Properties' ~ Yes Test data not in the possession 

or control of the submitter 

D 

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

TYPE OF NOTICE (Check Only One) 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with linal product PMN) 

D SNUN (Sih'11ificant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

D LVE (Low Volume Exemption) @ 40 CFR 723.50(c)(I) 

D LOREX (Low Release/Low Exposure Exemption) @40 CFR 723.50(e)(2) 

LVE Modification D LOREX Modification

IS THIS A CONSOLIDATED PMN? D Yes

# of chemicals 


Mark (Prenotice Communication # required, enter # on page 3)
 (x) if any information in this notice is claimed as confidential. 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 

29703'5 

Public reponir.-g burden for this collection of information is estimated to average 110 hours per response, including time for reviewing 

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

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

reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 

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

CERTIFICATION 

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

I. 	 The company named in Part I, section A, subsection la ofthis notice fonn 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 infonnation provided in this notice is complete and truthful as ofthe date of submission. 

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

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

Additional Certification Statements: 

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


statement that applies: 


16I The Company named in Part I, Section A has remitted the fee of$2500 specified in 40 CFR 700.45(b), or 


o The Company named in Part I, Section A has remitted the fee of$IOOO for an Intennediate PMN (defined @40 CFR 


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


o The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $1 00 

in accordance with 40 CFR 700.45(b). 

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

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

statements: 

o The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 


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


o 	The manufacturer is familiar with the tenns ofthis section and will comply with those tenns; and 

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

o If this application is for an LVE in accordance with 40 CFR 723.50(c)(I), 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 the statements you make in this notice should renect your best prediction of the anticipated facts regarding the chemical substance 

described herein. AD:!, knowintr and willful misinterpretation is subiect to criminal penalty pursuant to 18 USC 1001. Confidential 

Signature and title of Authorized Official (Original Signature Required) Date 

x 

Si/:.>nature of agent - (if applicable) Date 

:PA FORM 7710-25 (Rev. 5-95) 

1 

Page 2 

I 
Submitting 

Notice (in U.S.) 

b. Agent (if 

applicable) 

Company 

Name 

Mailing street) 

Telephone 

c. If you are submitting this notice as part 

mark (X) this box. ___________________~ 

Joint Submitter (if 

applicable) 

ame of authonzed 

2. 

3. 

4. 

5. 

6. 

Contact (in 

U.S.) 

Mailing 

Company 

and street) 

Code 

you a prenotice 

and EPA assigned a PC Number to the notice, enter the number. 

you application 

substance covered by this notice, enter the exemption number assigned by 

EPA. lfyou previously submitted a PMN for this substance enter the 

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

I 

Type of Notice - Mark (X) 

Manufacture 

Only 

.. 

o Binding Option 

Mark 

PositIon 

o 

Import 

Only 

Mark (X) 

if none 

Mark (X) 

if none 

Mark (X) 

ifnone 

Binding Option 

Mark 

.. 

II 

.. 

o Both 

EPA FORM Page 3 7710-25 (Rev. 5-95) 
Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION; You must provide a currenlly correct Chemical Abstracts (CAl name of the substance based on the ninth Collective Index (9CI) of CA nomenclature rules and conventions, 

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

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

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. ContiIdentify the name, company, and address of that person in a continuation sheet. 0 dential 

l. 	 Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) • a. 	 Class ofsubstance - Mark (X) I D Class 1 or 2 D Class 2 X

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


For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Indcx Name or CA Preferred Name must 
 X 

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

c. Please' 

[8l 

d. (if a number already exists for the substance) 

c. a class I prov and correct chemical structure .ate 

precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the 

range of composition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical structure 

diaeram. a~ comnlete a~ can he known. if one can he reasonahlv a~certained. 

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

x 

x 

X 

EPA FORM 7710·25 (Rev. 5-95) 	 Page 4 
a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. 

Indicate maximum weight percent ofIow molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: apc 0 Other 0: (Specify) 

i) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight: 

iii) maximum weight % below 1000 molecular weight: 

attach a continuation shect. 

must make separate ality monomer or othcr rcactant . 

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

Confidential 

x 

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

the polymer. 

(2) Mark O() this column if entry in column (I) is confidential. 

(3) Indicate the typical weight percent ofeach monomer or other reactant in the polymer. 

(4) Mark eX) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

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

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

commercial purposes. 

Mark 

x 

obtained from CAS Inventory Expcrt Service must be submitted as 

polymer that is consistent . TSCA Inventory listings polymers. 

c. a correct re~lresem.all've or partial chemical structure diagram, as complete as can known, jf one can be reasonably ascertained. 

attach a continutation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 5 
Part I -- GENERAL INFORM A TION -- Continued 

Section B - CHEMICAL IDENTITY INFORMATION - Continued 

3. Impurities 

(a) - IdentifY each impurity that may be 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." 

(b) ­ Estimate the maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight %. 


Impurity and CAS Registry Number 
 Maximum I Confipercent I dential 

(a) (b) I I 

X I i 

I 

%! 

% I

J 

% 

i I %, 

in s I or 2. 

the new chemical substance 

you you must . . reveals 

the specific chemical idenllty ofthe new chemical substance to the maxImum extent pOSSIble Refe~ to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developmg genenc names. 

Surface modified magnesium hydroxide 

process 

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

x 

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

CAS Number 
I Part I -- GENERAL INFORMATION -- Continued 

I Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

Mark (X) the "Confidential" box next to any item you claim as confidential. 

1. Production volume Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum 

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

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

10,000 kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume 

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Confi- Binding 

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

Mark (x) 

X l 

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

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

you claim as confidential. 

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

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

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

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

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

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

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

(7) -­ Mark (X) this column if entry in column (6) is confidential business information (CST). 

(8) -­ Indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate 

your willingness to have the use type provided in (8) binding. 

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

Category of use (1) CBII Binding Produc- CBI % in ,CBI % of substance expected per usc I CBI 

Option tion % Form­ (8) 

(by function and application i.e. a dispersive dye ! Mark (x) ulation Site· , Con-" Indus- Com· I Binding 

for finishing polvester fibers) (2) (3) (4) (5) (6) I (7) Limited ; sumer trial mercial Option (9) 

X X X X I 

% % 

°In ' % 

% % 

! 

% % 

! 

% % 

% % 

" lfyou have identified a "consumer" usc, please provide on a continuation sheet a detailed description of the users) of this chemical subst~ce in co~sumer pro.ducts .. In addition include estimates of the concentration ofthe new chemical substance as expected in consumer products and descnbe the chemIcal reactions by whIch thIS 

substance loses its identity in the consumer product. 

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

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

use Instructions Manual for examples of generic use descriptions. 

description Destructive Use 

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

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

Option

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

for the safe handing, transport, usc, or disposal of the new substance. List in part III hazard information you include. 

D Mark (X) this box if you attach hazard information 

I 

- . HA fORM 7710-25 (Rev. )-9)) Page 7 
CUUO'U~L'lC lC:CC r~ ~IUemdrle ~OrpOrallOn ll"J~~'/U40 3/3 

SANITIZED 


Part I -­ GENERAL INFORMATION -­ Continued 

Se~tion C -- PRODUCTION, IMPORT, Aj~D USE ll'fFORMATlON: 

Mark eX) the "Confidential" box next to any item you claim a!l confidential. 

L l'roductioll volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum 

production volume fO!' any c(lJlsecutive 12-monlh period duling the til'st three ye<'lrS of prodllction. Estimates should he on 100% new chemic.al 

substallce ha..~is. For u Low Volum.: Exemption application, i(you choose to hllve your nolice reviewed at a lower pl'oduction volume thun 

lO,O()O kg/yr, specify the vr)lumc and mark ex) in the binding box. If granted, you arc bound to this volull1e 

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Conti· Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dCll!ial OJ.lti()11 

Mark (x) 

X 

2. Usc: Inform:ltion·- You must makE separate contidenrio.lity claims for the description oflhc category of use, the percent of pl'oduction volume 

devoted to caeh category, the formulation of the new subslance, and other usc information. Mark (X) the "Confidential" Box neXllo any item 

you claim as confidential.. 

a. (\) -­ Dc!;cribe each intended C<l.tegary oruse oCthe ne,;' chemical subshmcc by function and application.. 

(2) -- Mnrk (X) this column if eniry column (1) is confidcntial bu~ine~~ information (cn I). 

(3) ­ Indicate your wil1inglle.~s to have the information provided in column (I) binding. 

(4) -­ E~imate tile percent oftotnl production for the tirst three ycHrS devoted (0 each category ofusc. 

(S) -- Mllrk (X) Ihi3 column if entry in column (4) is confidential bu.~inc,!;s information (em). 

(6) ­ E~timate the percent of the new ruhstance 3.~ fonnulatNl in mixrures, suspensions, emulsions, solutions, or gels all manufac·tllrc::d for 

commercia.l purposes at sites under your c<lntrol nssocioted with ~Ich cll[l;gory of nse. 

(7)- MArk (X) this column if entry in COhlnlO (6) is confidential business information (CBI). 

(11) - Indicate % of produet volume expected for the listed. "use" sectOrs. !'vfuJ'k more thnn olle box ifnpproprinte. Mark (X) lO indic.'ll:e 

your willingness LO have the II~e type provided in (8) binding. 

(9) -­ Mark (X) this column ifentty(ics) in column (&) is (a.rc) ccmtidential business information (CBI). 

ClIlcgory ohlc (1 ) C'BI llin~inl; ProduCo eEl ~~ in CRT % of SUb5tlUlCI: expeclcd per u~c CEf 

OPtiOIl lion % Fonn­ (8) 

(by r.,mctioll dJld <Ippliciltioll i.e. d dj'per~i ...e dye MI\J1( (xl IJIOlioll Sile- Con·~ IndlJs· Com· Binding 

for finishing polyester fibers) (2) (:I) (4) (5) (6) (J) Limited smner tl'ia! mercia I °Etioll (9) 

Compatibilizer for Flame Retardant X X X 

for Plastics 

r~...]. 

,,' o,~ (,,-'c 

.,

-- .......1 _. % ~I,. 

.... :i ' I 

- ~/" % . 

.'-' , 

.,­ ..• -­ -.~ "" 

% 0;', J -", -."' 

- .:: ;'. ,1 

% OJ.. ~.:'-

% % =: ~ (r you hRYC identilied 11 "~nsumer" use, ple~$e provide on a. CllI1\inu~lion sheet a detailed description ofthe u~e(l) oflhis chcmic~1 substMcc in consumcr products. 

In addiliLln include e.\timQle~ ofille collcelllration oflhe new chemicallubstanco as expected ill consumcr products lind describe the chcmic~1 rcnctiol1s by which lhis 

sub~tance loses its identily in the eonsuluer pJodlJcr.

DMark (X) ll1is box ifyolJ attach ~ continuation shceT. 

b. Generic If you claim allY C3tCg01Y ot·u~o description in SlIb~cction2n lIS c<lnfidcntial. cnlcr 11 S~'11cric d~scripLion oClhuL Cl1l~g()ry. Rend Ole 

use Insu'IIctioM Manu...1lor examples of generic usc descriptions. 

dcscription 

D M~rk (X) lhis box if YrJU RltHCh II c<lntinulllion sheet. 

3. H:1z:1rd Information .. Include in the notice ncopy ofrelL~on~hlc r~csimile "C uny h!l:l.ord wurning slatemenl, I~bel. material s.-uelY data ~hcet, or otllel" llin:'iing 

informlilion which \~i" be prnvided 10 My pe~iln whl'l is re!i.~onably likely to be exposed to lhis sllbstance regarding pro\er.live c'luipmcnt or prnC!TcC5 r>VI\r,n 

Cor Lhe ~~re hJlldin~, l1:u1sport, IJIC. or disposal ofthe new znbsllIncc. List ill part 1\I hazilrd infonnation you include. M,,~ (~) 

[ZJ Mark (X) lhis box if YOIl artRch hnz.,rd infonnlltion. 

- EPA FORM 7710-25 (Re,'.5-05) Page 7
 \ZEU COMPAN'f SAN\l 111111111111111111111111111111111111111111111111111111111111111111111111111


500 7 0 0 0 0 3 1 8 I S 


AfflOlD P-oh h {d­
p 

you 

lete section A for each type of manufacture, processing, or use operation new 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 or use after You must describe these s. See instructions manual 

1. 

the site at which the "n••r~'·;An will 

City, code 

the same operation wIll occur at more than one site, enter number of sites. Identify the 

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

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

attachments. 

kglbatch (100% new chemical I 

substance) 1 

----------------~~~ , 

Use 

X 

d. Process description Mark (X) to indicate your willingness to have your process description binding. X 

(I) Diagram the m<uor unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon 

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

(2) Provide the identity, the approximate weight (by kg/day or kglbatch on a 100% new chemical substance basis), and entry point of all starting materials and 

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

used daily or per batch.). 

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

attach a continuation sheet. 

EPA FORM 7710·25 (Rev.5-95) Page 8 
Part II HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE C d -­ ontinue 

Section A --INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Continued 

2. Occupational Exposure You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, 

number of works exposed, and duratIon of activIty. Mark (X) the "Confidential" box next to any item you claim as confidential. 

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

(2) -- Mark (X) thiS column If entry In column (I) is confidential business information (CBl). 

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

(4) and (6) -­ Indicate ~our willingncss to have the information provided in column (3) or (5) binding. 

(5) -- IndIcate the physIcal formes) oftlle new chemical substance (e.g., solid: crystal, granulc, powder, or dust) and % new chemical substance (if part of a mixture) 

at the time of exposure. 

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

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

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

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

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

Worker activity eBI Protective Equipment! Binding Physical fonns(s) Binding CBI # of Icm Maximum duration eBr 

(i.e., bag dumping, filling drums) Engineering Controls Option Mark and % new Option Workers Hrslday Dayslyr (x) substance Mark (x) Exposed i 

(I) (2) (3) (4) (5) (6) (7) (~ 1 (9) (10) (11) (12) 

X X 1 

X X 

L I I 

! , 

I I 

I 

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

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. 

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

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

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

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify» to 

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

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

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

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

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

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

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

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

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

Number released release 

(I) (2a) I (2b) e.;. stm:k!lir I Binding 

i (3) I (4) (Sa) I Mark (X) I (5b) (6)

i XI I 

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(7) Mark (X) the o POTW provide name(s) below: ~' 0 Navigable D Other· Specify I provide NPDES # CBI I 

destination(s) of waterway 

releases to water. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

I Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this 

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

section B jar each type ojprocessing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typical operation common to these sites. ldentify additional sites on a continuation sheet. 

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

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

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) ­ Provide the identity, the approximate weight 

(by kg/day or kglbatch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all 

products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch). (3) --Identify by number the points of release, 

including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet): 

[ ] 

# of sites 

r--­ -

'---­ ~ 

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

2, Worker ExposureJEnvironmental Release . . . . (\) __ From the diagram above, provide the letter for each worker actiVIty. Complete 2-8 for each worker actiVIty descnbed. 

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

(4) __ Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per ycar... ., . (6) __ Describe physical form of exposure and % new chemical substance (if in mixture), and any protective eqUipment and engmeerlng controls, If any, used to 

protect workers. 

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

(9) __ From the process diagram above, enter the number of each release point. Complete 9-13 for each release pomt Identified. . . (10) .. Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the envlron~cnt (10 kg/day or kglbatch). 

(12) -­ Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-stt~ or off-site land or mcmeratlOn, 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 any of the proceedmg enmes are confidential bus mess mformatlon (CBI). 

Letter # of eBI Duration eEl Protective Equip.! % in eBI Release Amount of ICEI Media of Release eBI 

of Workers of Engineering Controls! Form- Number New & Control 

A Ed' - d % ulation Substance Technolob'Y . ct· xpose Exposure PhYSical Form an 0 Released . 

IVlty new substance i • 

I (5) (6) (7) (8) (9) (lOa) I (lOb) (II) • (12) (13) (I) (2) (3) (4a) (4b) 

X , X X i , X X I I 

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

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

To claim il1fonnation in this section as confidential circle or bracket the specific infonnation 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 

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

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

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

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

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

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

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

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

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

of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics of the PMN substance to potential 

alternatives may be provided. 

All information provided in this section will be taken into consideration during the review of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (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 perfonnance, a decrease in 

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

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

substance that poses a greater overall risk to human health or the environment. 

NA 

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

EPA FORM 7710-25 (Rev. 5-95) Page 11 
Part III -- LIST OF ATTACHMENTS 

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

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

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

numbers of each attachment. 

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

how to claim any information in an attachment as confidential. You must include with the sanitized copy of the notice form a sanitized 

version of any attachment in which you claim information as confidential. 

Attachment name Attachment Contipage number(s) dential 

X 

I X 

X 

X 

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

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

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PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

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

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

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

state of the neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. 

Properties that are measured for mixtures or fonnulations should be so noted (% PMN substance in You are not required to 

submit this worksheet; however, EPA strongly recommends that you do so, as it wiB simplify review and ensure that confidential 

infonnation is properly protected. You should submit this worksheet as a supplement to your submission of test data. This worksheet 

is not a substitute for submission of test data. 

Property I Mark 

I (X) if 

(a) provided 

Physical state of neat substance 

Vapor pressure 

@ Temperature °C 

Density/relative density 

Solubility 

@ Temperature °C 

Solvent I 

Solubility in water @ Temp_erature °C ; 

I 

Melting temperature 

Boiling / sublimation temperature(a), torr pressure 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volatilization from water 

Volatilization from soil 

pH@ concentration 

Flammability 

Exp!odability 

Adsorption I coefficient 

Other - Specify 

I 

Page Value 

number 

(b) (c) 

is) (\) (g) 

Torr 

glee 

giL 

I °C 

I °C 

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IMeasured 0 ConfiEstimate dentin! 

Mark {Xl 

! (MorEl (d) 

X 

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ATTACHMENT 


PAGE 13 

EPA FORM 7710-25 (Rev. 5-95) Page 14 
EPA FORM 7710-25 (Rev. 5-95) Page 15 
06/0]/2006 10.31 FAX 614 4~7 3747 CAS CS 

@003/003 

Inventory Expert Service 

A diVisIon of the Ameliom ChM'lical SOciety F'fIoM:. 800-631 ~1S84,. 614447.03810 

Fax: 614-447-37-if7 

E-rnall: ~@=.crg 

Internee http://www.=.otgl'SupporrJdient.hlml 

!NV'S!I!'I'ORY EXPER'l' SERVIC:E: REPORT 

rES-ORDER lx'UMBER: ( J 

CA r..-;mEX NN-IE 

\ 

'­ J

o :If thia box i;, chucked, CAB ha.!1 :made cO%rG<::titnl (B) lILIttked in red to 

your lES o:rde=. P:iealie, lIll!ke .t11e Iil.UIU3 con::octiOi:l{S) to your PMN' ~tQ;re 

sul::at:.l.tf:bg it to the lWA. 

p.Oo Box ll-4J 

ATTACHMENT 

PAGE 16