U.S . ENVIRONMENTAL PROTECTION AGENCY 

A 

/ 

' N°b"° .34 

in the Premanufacture Notice 

. 

p. 1 

Form Approved . O.M.B. No. 2070-0012 . Approval Expires 10-31-96 . AGENCY USE ONLY 

Company Sanitized 

GENERAL INSTRUCTIONS 

C 

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

not have actual data . 

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

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

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

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

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

Part I -GENERAL INFORMATION 

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

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

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

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

letter in support of your submission should reference your TS user fee identification 

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

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

submitted. 

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

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

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

Part III- LIST OF ATTACHMENTS 

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

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

attachments, any test data or other data and any optional information included in the 

notice. 

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 EnQlish), not summaries of data, 

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

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

composition of the tested material should be characterized. Following are 

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

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

720) . 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes " Other data ® Yes 

" Health effects data ® Yes Risk assessments 

Environmental effects data 0 Yes Structure/activity relationships 

OPTIONAL INFORMATION 

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

substance . On page 1 I of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new 

substance. 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section, such as use, 

production volume, protective equipment . . This option is intended to reduce delays 

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

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

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

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

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

chemical identity) reported in the form . 

CONFIDENTIALITY CLAIMS 

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

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

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

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

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

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

® Mark (x) if any information in this notice is claimed as confidential . 

PhysicaVChemical Properties' ® Yes Test data not in the possession 

or control of the submitter 

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

TYPE OF NOTICE (Check Only One) 

® 

0 

0 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

LVE (Low Volume Exemption) (r~ 40 CFR 723 .50(c)(1) 

LOREX (Low Release! Low Exposure Exemption) (N, 40 CFR 723 .50(c)(2) 

LVE Modification 

IS THIS A CONSOLIDATED PMN? 

a 

0 

LOREX Modification 

Yes 

# ofchemicals 

(Prenotice Communication # required, enter # on page 3) 

5it~i7~ 

PREMANUFACTURE 

NOTICE 

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

Public reporting burden for this collection of information is estimated to average 1 10 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 infonnation, 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 of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C . 20503. 

CERTIFICATION 

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

1 . The company named in Part 1, section A, subsection 1 a of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, 

Section B. 

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

3. 1 am submitting with this notice all test data in my possession or control and a description of all other data known to or 

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

Additional Certification Statements: 

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

statement that applies: 

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

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

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

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

in accordance with 40 CFR 700.45(b) . 

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

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

statements : 

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

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

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

F1 The new chemical substance for which the notice is submitted meets all applicable exemption conditions . 

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

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

review period . 

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

described herein. An knowing and willful misinter p retation is subject to criminal penalty p ursuant to 18 USC 1001 . Confidential 

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

X 

Signature of agent -(if applicable) Date 

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

Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTI FICATION 

1 a. Person Name of authorized official Position 

Submitting 

Notice (in U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

b. Agent (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

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

Joi nt Submitter (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

2. Technical Name of authorized official Position 

Contact (in 

U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

3 . If you have had a prenotice communication (PC) concerning this notice 

and EPA assigned a PC Number to the notice, enter the number . Mark (X) - F-1 x if none 

4. If you previously submitted an exemption application for the chemical 

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

EPA. If you previously submitted a PMN for this substance enter the 

Mark (X) - F] x if none 

PMN number assigned by EPA (i.e . withdrawn or incomplete).--0 

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

for the chemical substance covered by this notice, enter the notice number Mark (X) - El X assigned by EPA . - if none 

1 . E] Manufacture 2. ~ Import 

6. Type of Notice - Mark (X) Only Only 3. ® Both 

Binding Option E] Binding Option 

Mark (X) Mark (X) 

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

Confidential 

EPA FORM 7710-25 (Rev . 5-95) Page 3 
p. 4 

Part I -- GENERAL INFORMATION -- Continued 

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

the ninth Collective Index (9CI) of CA nomenclature rules and conventions. 

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

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

If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right . ConfiIdentify the name, company, and address of that person in a continuation sheet. El dential 

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

a. Class of substance - Mark (X) 1 E] Class l or 2 0 Class 2 

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

For Class l substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must 

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

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

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

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

X 

CAS# 

X 

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 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 

diagram. as comnlete as can be known. if one can be reasonablv ascertained. 

See Pages 4A and 4B 

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

EPA FORM 7710-25 (Rev . 5-95) Page 4 
Synthesis of PMN Substance 
Inventory Expert Service 

A division of the American Chemical Society Phone:800-631-1884, 614-447-3870 

Fax: 614-447-3747 

E-mail : answers@cas.org 

Web: www.cas .org/products/client/ 

INVENTORY EXPERT SERVICE REPORT 

Please print the above CA Index Name on the appropriate page of your PHN. 

If this box is checked, CAS has made correction(s) marked in red to 

your IES order . Please make the same correction(s) to your PNIIJ before 

submitting it to the EPA . 

Page 4R 
p. 7 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

2. Polymers (For a definition of polymer, see the Instructions Manual.) Confidential 

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below 1,000 absolute molecular weight of that composition . 

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

i) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight : 

iii) maximum weight % below 1000 molecular weight : 

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

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

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

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

the polymer. 

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

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

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

description on the TSCA Chemical Substance Inventory. 

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

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

commercial purposes . 

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

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential 

(1) (2) (3) 4) 5) (6) 7) 

% % 

% % 

% % 

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

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

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

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this notice) 

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

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

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

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

Part I -- GENERAL INFORMATION -- 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 . 

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

(b) - Estimate the maximum wei ght % of each impurity. If there are unidentified imp urities, estimate their total wei ght %. 

Provide the 

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(b) 

Confidential 

% X 

% 

% 

% 

% 

% 

% 

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

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

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

x 

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

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

X 

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

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

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

Vinylsilane ester 

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

7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

Number if available. 

Byproduct 

(1) 

CAS Registry Number 

(2) 

Confidential 

X 

X 

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

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

Part I -- GENERAL INFORMATION -- Continued 

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

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

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

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 k /yr, s pecify the volume and mark (x) in the bindin g box. If ranted, you are bound to this volume 

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

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

Mark (x) 

X 

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

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

you claim as confidential . 

a. (1) -- Describe each intended category of use of the new chemical substance by function and application . . 

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

(3) -- Indicate your willingness to have the information provided in column (1) binding . 

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

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

(6) -- Estimate the percent of the new substance as fonnulated 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 (CBI). 

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

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

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

Category of use (1) CBI Binding Produc- CBI % in CBI % of substance expected per use CBI Option tion % Form- (8) 

(by function and application i .e . a dispersive dye "tuk (x) ulation Site- Con-* Indus- Com- Binding 

forfinishing polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

X X X X 

o~ o~ 

% % 

o~ o~ 

o~ o~ 

o~ o~ 

o~ o~ 

% % 

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

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

substance loses its identity in the consumer product. 

E]Mark (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 Processing Additive Intermediate 

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

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

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

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

® Mark (X) this box if you attach hazard infonnation. 

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

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

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

claim as confidential 

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

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

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

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

Name X 

Site address (number and street) 

City, County, State, ZIP code 

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

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

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

sites as attachments . 

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

b. Type -- 

Mark (X) E:]Manufacturing ElProcessing E]Use 

c . Amount and Duration -- Complete t or 2 as appropriate 

Maximum kg/batch 0 oo^o ne<, cbemicai Hours/batch Batches/year 

substance) 

1 . Batch 

Maximum kg/batch (iooi new chemical Hours/batch Batches/year X 

substance) 

2 . Continuous 

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

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

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

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

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

used daily or per batch.) . , 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. See Page 8A 

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

EPA FORM 7710-25 (Rev. 5-95) Page 8 
C~ 

C 

. 

a~ 

u 0 

~, 

a 

. 

u 

c~~., 

C 

p. 11 

d 

ao 

en 

~a 

a 
p. 12 

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

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued 

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

number of works exposed, and duration of activity . Mark (X) the "Confidential" box next to any item you claim as confidential . (1) -- Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc . ) in which workers may be exposed to the substance. 

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

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

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

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

at the tune 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). 

(10) and (11) --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 (11) are confidential business information (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBt Maximu 

m 

duration CBI 

(i .e ., bag dumping, filling drums) Engineering Controls option and % new Option workers Hrs/day Days/yr 

Mark (x) substance Mark tx) Exposed 

(1) (2) (3) (4) (5) (6) (7) (8) (9) (l0) (11) (12) 

X gloves, goggles, X X X 

nrot . r;lothina . vPnt. 

X gloves, goggles, X X X 

nrot . dothinn_ vPnt. 

X gloves, goggles, X X X 

nrot . dothinn . vent. 

X gloves, goggles, X X X 

nrot . dothina . vent 

X gloves, goggles, X X X 

nrot . dothina . vent 

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

(1) -- Enter the number of each release point identified in the process description, part II, section A, subsection 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 kg/batch). 

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

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction 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 (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

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

Number released release 

(1) (2a) (26) e.g. s,aek nv Binding 

(3) (4) (Sa) Mark (x) (5b) (6) 

1 X X 

2 X X 

3 X X 

4 X X 

(7) Mark (X) the 

F POTW provide name(s) below: CBI 

~ Navigable ~ Other - Specify provide NPDES # CBI 

destination(s) of waterway X 

releases to water. 

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

EPA FORM 7710-25 (Rev . 5-95) Page 9 
p. 13 

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

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

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

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

section B for each type of processing, or use operation involving the new chemical substance. If the same operation is per-formed 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 information in this section as confidential, circle or bracket the specific information that you claim as confidential . 

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

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

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

products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points of release, 

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

these sites on a continuation sheet) : # of sites 

See Page 10,04 

® Mark (X) this box if you 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 of workers exposed for all sites combined . 

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

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

protect workers. 

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

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

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

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

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

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

(3), (5), (8), (11), (l3) and (15) -- Mark (X) this column if an of the proceeding entries are confidential business information (CBI). 

Letter # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI 

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

Act- Exposed Exposure Physical Form and % ulation Substance Technology 

ivit 

y new substance Released 

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (lOb) (II) (12) (13) 

A X X gloves, goggles, prot. 100 X 1 X X 

clothing, ventilation 

(14) -- Byproducts : (15) 

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

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

u 

C 

ees 

a 

+00 

.^., 

u 

u 

a 

u 

cu O 

C 

.~., 

D 

A 

p. 14 

d 0 

a oA 

a 

a 
p. 15 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in this section as confidential circle or bracket 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 

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 performance, a decrease in 

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

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

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

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

EPA FORM 7710-25 (Rev . 5-95) Page 1 l 
p. 16 

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 infonnation), 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 i n which you claim information as confidential . 

Attachment name Attachment 

page number(s) 

Confidential 

Material Safety Data Sheet (MSDS) 

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

A1--A8 

X 

X 

X 

X 

EPA FORM 7710-25 (Rev . 5-95) Page 12 
p. 17 

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 formulations 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 will simplify review and ensure that confidential 

information 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 Mark Page Value Measured o Confi- 

(X) if 

provided 

number Estimate dential 

Mark(X) 

(a) (b) (c) (M or E) (d) 

X A4 X 

Physical state of neat substance (s) (1)- (g) 

X A4 X 

Vapor pressure 

Temperature °C Torr 

X A4 X 

Density/relative density g/cm3 

X 

Solubility 

@ Temperature °C 

Solvent g/L 

X A4 X 

Solubility in water Temperature °C g/L 

X A4 X 

Melting temperature °C 

X A4 X 

Boiling / sublimation temperature torr pressure °C 

X X 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

X 

Volitalization from water 

Volitalization from soil 

X 

pH@ concentration 

X 

Flammability 

Explodability 

Adsorption / coefficient 

Other - Specify 

I 

EPA FORM 7710-25 (Rev . 5-95) Page 13 
p. 18 i MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

05/11/2005 

Page: 1 of 8 

1 . PRODUCT AND COMPANY IDENTIFICATION 

Product name: 

Chemical name: 

Supplier: 

Contact numbers: 

2 . COMPOSITION I INFORMATION ON INGREDIENTS 

COMPONENT CAS# CONCENTRATION 

I 

See Section 15 for chemicals appearing on Federal or State Right-To-Know lists. 

3. HAZARDS IDENTIFICATION 

EMERGENCY OVERVIEW 

WARNING! 

CAUSES EYE IRRITATION. 

MAY CAUSE SKIN IRRITATION . 

MAY CAUSE IRRITATION OF THE RESPIRATORY TRACT. 

4. FIRST AID MEASURES 

Swallowing 

If patient is fully conscious, give two glasses of water. Induce vomiting. Obtain medical attention. 

Skin 

Remove contaminated clothing . Wash skin %ti ith soap and water. If irritation persists or if contact has been prolonged, 

obtain medical attention. 

Attachment Page A1 
P. 19 

MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

05/11/2005 

Page : 2 of 8 

Inhalation 

Remove to fresh air. Obtain medical attention if symptoms persist. 

Eye contact 

Immediately flush eyes with water and continue washing for several minutes. Obtain medical attention if discomfort 

persists . 

5. FIRE-FIGHTING MEASURES 

Flash point: 

Flammable limits 

Lower limit: Not available 

Upper limit: Not available 

Special protective equipment for firefighters 

Use self-contained breathing apparatus when fighting fires in enclosed areas. 

Extinguishing media 

Suitable : Large fires: 

- alcohol-type foam or universal-type foams 

Small fires : 

- C02 

- dry chemical 

Unusual fire and explosion hazards 

None 

6. ACCIDENTAL RELEASE MEASURES 

Personal precautions 

Wear suitable protective equipment. 

Environmental precautions 

Prevent runoff. 

Attachment 1'aQP A? 
p. 20 

MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

05/11/2005 

Page : 3 of 8 

Methods for cleaning up 

Cover with absorbent or contain. 

Collect for disposal . 

Observe government regulations. 

7. HANDLING AND STORAGE 

HANDLING 

Handling precautions 

Avoid contact with eyes, skin and clothing . Avoid breathing vapor. Wash thoroughly after handling . 

STORAGE 

Storage requirements 

Keep container closed . 

8. EXPOSURE CONTROLS I PERSONAL PROTECTION 

PERSONAL PROTECTION 

Respiratory protection 

Self-contained breathing apparatus in high vapor concentrations . 

Hand protection / protective gloves 

Recommended order of use: 

4H 

Butyl 

Neoprene 

Nitrile (NBR) 

PVC-coated 

Eye protection 

Monogoggles 

Other protective equipment 

Eye bath 

Safety shower 

ENGINEERING CONTROLS 

Ventilation 

General (mechanical) room ventilation is expected to be satisfactory where this product is stored and handled in 

closed equipment. 

Special, local %entilation is needed at points N% here %apors can be expected to escape to the workplace air. 

EXPOSURE LIMITS 

Attachment PraKa A3 
p. 21 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

05/11/2005 

Page: 4 of 8 

9 . PHYSICAL AND CHEMICAL PROPERTIES 

APPEARANCE 

Physical state 

Color 

Odor 

OTHER PROPERTIES 

Boiling point 

Melting point 

pH 

Specific gravity (H20=1) 

Vapor pressure 

Vapor density (sir=1) 

Solubility in water 

Evaporation rate (Butyl 

Acetate=1) 

Flash point 

Upper explosion limits 

Lower explosion limits 

Molecular weight 

10 . STABILITY AND REACTIVITY 

Stability : Stable . 

Stability - Conditions to avoid 

None known. 

Incompatible materials 

Acids. 

Bases. 

Strong oxidizing agents. 

Att,qchment Page A4 
p. 22 I MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

05/11/2005 

Page: 5 of 8 

Hazardous combustion products 

Burning can produce the following combustion products : 

Oxides of carbon. 

Oxides of silicon. 

Carbon monoxide is highly toxic if inhaled: carbon dioxide in sufficient concentrations can act as an asphyxiant. Acute overexposure to the products of combustion may result in irritation of the respiratory tract. 

Hazardous polymerization: Will not occur. 

Hazardous polymerization - Conditions to avoid 

None known. 

11 . TOXICOLOGICAL INFORMATION 

SWALLOWING 

Acute effects 

May cause the following effects: 

- dizziness, faintness, drowsiness, decreased awareness and responsiveness, euphoria, abdominal discomfort, nausea, vomiting, staggering gait, lack of coordination and coma 

Effects of repeated overexposure 

Long-term repeated oral_ may result in the development of progressive liver injury with fibrosis. 

SKIN ABSORPTION 

Acute effects 

No evidence of harmful effects from available information. 

INHALATION 

Acute effects 

May cause irritation of the respiratory tract. 

SKIN CONTACT 

Acute effects 

May cause irritation . 

EYECONTACT 

Acute effects 

May cause discomfort . 

May cause the tiollowing effects: 

- mild conjunctivitis 

- slight excess redness of the conjunctivae 

- tear production 

Injury to the cornea is not expected. 

Medical conditions aggravated by overexposure 

Repeated exposure ggravate liver injury produced from other causes . 

Other effects of overexposure 

Repratcd Iii - -- - ~ has hcen ,hru n to ailNer~ek aftei t the central ncn ~~u.; ,%,tem Of tile lC" tll, . (irt~tluClnk ct ii~IIC~tli~n ~~fctlclt, %%hlLh together c,in,htutl'1 - ~ ~- ~~~-I I I7C,C Itklllile 

Attachment PnKe A5 
p. 23 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

05/11/2005 

Page: 6 of 8 

mental and physical retardation, disturbances of learning, motor and language deficiencies, behavioral disorders, and small size head. 

12. ECOLOGICAL INFORMATION 

All available ecological data have been taken into account for the development of the hazard and precautionary information contained in this Safety Data Sheet. 

13. DISPOSAL CONSIDERATIONS 

General: Incinerate in a furnace where permitted under appropriate Federal, State, and local regulations. 

14. TRANSPORT INFORMATION 

DOT Classification 

This product is not regulated by DOT. 

Freight description road: CHEMICALS, NOIBN 

IMDG Classification 

This product is not regulated by IMDG . 

ICAO Classification 

This product is not regulated by ICAO. 

15. REGULATORY INFORMATION 

Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) requires notification of the National Response Center of release of quantities of hazardous substances equal to or greater than the reportable quantities (RQ's) in 40CFR302.4 . 

Components 

**** 

present in this product at a level which could require reporting under the statute are: NONE   

Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III requires emergency planning based on Threshold Planning Quantities (TPQ's) and release reporting based on Reportable Quantities (RQ's) in 40CFR355 (used for SARA 302 and 304). 

Components 

** ** 

present in this product at a level which could require reporting under the statute are: N O NE   

tiuperfund .krnendments and Reauthorizatinn %rt of 1986 ( .S ~R .~) litle III requires submission of annual 

SIGNIFICANT DATA WITH POSSIBLE RELEVANCE TO HUMAN HEALTH 

Attachment Page Ah 
p. 24 

MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

05/11/2005 

Page: 7 of 8 

reports of release of toxic chemicals that appear in 40CFR372 (for SARA 313). This information must be 

included in MSDS's that are copied and distributed for this material. 

Components present in this product at a level which could require reporting under the statute are: 

** ** NONE   

Ntassachusetts Right-To-Know Substance List (MSL)--Hazardous Substances and Extraordinarily Hazardous 

Substances on the MSL must be identified when present in products . 

Components present in this product at a level which could require reporting under the statute are: 

** ** NONE   

Pennsylvania Right-To-Know Hazardous Substance List--Hazardous Substances and Special Hazardous 

Substances on the list must be identified when present in products. 

Components present in this product at a level which could require reporting under the statute are: 

** ** NONE   

EPA Hazard Categories (SARA 311, 312): Immediate Health Hazard 

California Proposition 65 

This product contains no levels of listed substances, which the State of California has found to cause cancer, birth 

defects or other reproductive harm, which would require a warning under the statute. 

California SCAQMD Rule 443.1 VOC's 

Volatile Organic Components (VOC's) = Substances with vapor pressure of => 0.5 mmHg at 104'C (219.2'F). 

** **NOT DETERMINED**** 

CHEMICAL INVENTORY 

United States : This is a new chemical substance that is not currently on the TSCA Inventory. Under 

TSCA regulations, 40 CFR Section 720.36, experimental products such as these can only 

be used for research and development purposes either directly by, or under the supervision 

of a technically qualified person. The law further stipulates that an evaluator may test and 

evaluate samples such as these but, with few exceptions, the sample or products derived 

from it may not be used for commercial purposes until the new substance is added to the 

TSCA Inventory via Premanufacture Notification . 

16. OTHER INFORMATION 

HNIIS RATING 

Health : I Flammability I Reactivity I PPI : X 

LEGEND 

STP Standard temperature and pressure 

W'W Wei hGWei ht 

0 (HMIS) Minimal hazard 

I (HMIS) Slight hazard 

2 (HMIS) Moderate hazard 

3 (HMIS) Serious hazard 

-I (HMIS) Severe hazard 

L X 11IMISt Personal protection rating to he supplied by user depending tin use conditions 

Attachment Page A7 
p. 25 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

05/11/2005 

Page: 8 of 8 

The opinions expressed herein are those of qualified experts withi e believe that the information 

contained herein is current as of the date of this Safety Data Sheet. Since the se of this _information and of these 

opinions and the conditions of use of this product are not within the control o L----- J it is the user's obligation 

to determine the conditions of safe use of the products . 

Attachment PnQe AH 
HEALTH EF TA TEMENT 

a very low order of acute toxicity by swallowing or skin penetration. liberated has 

in acidic stomach fluids may cause additional toxic effects in man following ingestion . is 

slightly toxic following the acute inhalation of vapors generated at ambient temperatures is 

a slight skin and mild eye irritant. Repeat dose studies identify the kidney and urinary tract as 

primary target organs following inhalation of vapor. Repeated inhalation exposure to an aerosol of 

a solution of hydrol ecis not expected to cause any adverse health effects. is a mild 

skin sensitizer. was negative for mutagenicity in two in vitro assays . Similar findings are 

anticipated for 

~~ can torm additional k ~upon contact with body fluids, particularly in the stomach 

because`of the low stomach pH. Therefore, the potential for toxicity due to 

visual disturbances, digestive tract irritation, CNS depression, repro uctive and fetal 

toxicity, and liver kidney and heart muscle damage) to result from accidental in 6es I t' ion o f 1 arge 

quantitie ot=should be recognized . Since dermal and inhalation ex os re would produce 

lessno contact with acidic media) the concern for toxicity fromis much lower 

by these routes . 

Attachment Page A9 0 
Acute Oral Toxicity 

Whe as administered by oral gavage to rats, the acute oral LDS0 was detennined to be 

>5000 mg/kg, indicating a very low order of toxicity in the rat by this route. 

Acute Dermal Toxicity 

In order to determine the potential for systemic toxicity by absorption across the skin, 

(undiluted) was applied to the clipped dorsal skin of rats and maintained in contact for 24 hours 

under a semi-occlusive dressing. The acute percutaneous LDSO was determined to be >2000 mg/kg, 

indicating a very low order of toxicity in the rat by this route. 

Acute Inhalation Exposure 

When rats were exposed for 4 hours to dynamically generated vapors ok--i poor coordination, 

tremors, anesthesia, and death were reported. The 4-hour LC5o value was estimated to be 4500 

ppm, indicating slight toxicity in the rat by this route. 

Repeat Dose Studies 

In a subchronic (90-day) vapor inhalation study o 

hours/day, 5 days/week) resulted in no consistent evidence for toxic effects, indicating a noobserved-adverse-effect-level (NOAEL) of greater than 50 ppm with this treatment protocol. The 

results from these repeated inhalation studies identify the kidney and urinary tract as the primary 

target organs following re eated inhalation exposure to concentrations less than 100 ppm but 

greater than 50 ppm ofas a vapor. 

Repeat Dose Studies on HydrolyZ 

Male rats were exposed to a res irable aerosol of a hydrolyzate o which is primarily the 

( ~derived from the land not the same~ hemical structure~ 

`tTie unhydrolyzed -~ generate at room temperature from a 2% aqueous dispersion o ~ 

for 6 hours/day, 5 days/week, for a total of 19 exposures. The aerosol concentratio n 

determined to be 145 mg/m3. There were no deaths, clinical signs of toxicity, or gross or 

microscopic pathology chan n the kidneys or respiratory tract associated with exposure to an 

aerosol of a hydrolyzate o~under these conditions. 

Primarv Skin Irritation 

To determine the primary dermal irritation potential o= 0.5-ml neat liquid was applied to 

the clipped, intact skin of male and female New Zealand White rabbits and maintained under a 

semi-occlusive cover for 4 hours . A primary irritation index of 1 .3 was calculated from the 

results, consistent with a slight skin irritation potential for= in the rabbit . 

Primary Eye Irritation 

To determine the primary eye irritation potential of= 0 .1-ml neat liquid was instilled into 

the eyes of male and female New Zealand White rabbits. A maximum average score of 4.0 was 

calculated at the 1-hour time point, indicating___Iwas mildly irritating to the rabbit eye under 

the conditions of this test . 

Attachment Pn9P AI0 

exposure of rats to 5, 15, or 50 ppm (6 
Skin Sensitization Potential 

The potential for cat( produce dermal contact sensitization was assessed in a guinea pig 

sensitization maximization test . The design of the study consisted of an intradermal induction 

phase, followed by a topical induction phase and subsequent topical challenge. Irritation (degree of 

erythema and edema) was graded using a 0 to 3 severity scale after induction and challenge phases . 

Positive skin reactions were observed at the topical challenge sites in 20% of the animals. The 

severity of irritation scores was 0.5 at 24 and 48 hours. The sensitization rate and severity of 

response indicate thatf----I is a mild skin sensitizer . 

Genotoxici Studies 

The potential mutagenicity oq= was evaluated in the Salmonella typhimurium assay (Ames 

test) and in the mouse lymphoma mutagenesis test in the presence and absence of metabolic 

activation=was not mutagenic in either of these tests. 

Attac}imPnt Page All 

C 
Preliminary Risk Assessment of Intermediate PMN Substance 

Worker Exposure Assessment and End-Use 

_ ll s produced exclusively at one o _ --

plarit( The synthesis 04 _ ill take place in a closed 

reactor and distillation system located within a manufacturing area, partly outdoors, and 

partly i oors, serviced by local exhaust ventilation. Operators will obtain samples of 

using a self-contained and vented sampling system. QC laboratory personnel 

will use exhaust hoods when preparing samples and will follow analytical methods that 

have been developed to maximize safety and minimize exposure. 

J involved with the manufacture of are trained and 

experienced in handling hazardous materials, such as the various 

intermediates, and products These processes 

by vacuum distillations. Therefore, the process is typical for the specified 

manufacturing department. The operating personnel are required to use personal 

protective equipment (PPE) and are trained to follow all safety recommendations as 

specified in the MSDS and within the Operating Instructions . The personnel protective 

equipment includes safety hard hat, steel-toed shoes, chemical resistant gloves, and 

goggles. The has moderate volatility. The PPE worn by workers will 

effectively eliminate the potential for dermal or inhalation exposure. The workers are 

trained in emergency procedures in the event of an unexpected exposure, accidental 

release, spill or fire . 

The i-~ will b e[:=-----

intermediate of this process, which involve _ - 

molecule. T is next intermediate is known as and is described in the 

intermediat The ~ but 

long te The same training, PPE, and procedures described 

above are used downstream for the~-lurocess. 

Attachment Page AI? 
Environmental Release Assessment 

At th _ the potential for releases o into the 

environment will be minimized. Based on the intended process, it is anticipated that 

there will be three potential releases of the intermediate PMN substance to the 

environment (see Pages 8A and 9). The potential releases will be associated with 

disposing of waste QA samples, filter bag disposal, and waste clean-up solvent which 

will contain low levels of intermediate PMN substance. 

Waste QA sample bottles containing the intermediate PMN substance will be collected 

with other wastef- --- ---Isamples in a RCRA collection site and transferred to an 

on-site, RCRA approved rotary kiln, permitted b 

The efficienc of the incineration process in destroying buckets of sample bottles 

including, is estimated to be beyond 99.99%. Likewise, waste clean-up solvent 

be collected in a waste solvents tank and transferred by dedicated pipeline 

to the kiln for incineration . Consequently, there will be effectively no releases of 

L-7associated with the incineration of waste sample bottles or equipment clean-up 

solvent. Used filter media such as bag filters ar collected for on-site disposal in the 

RCRA-a roved landfill . The contained will underg to an[_ 

__)amorphous polyme 

At rnchmPnt PakP A13 
GC OF INTERMEDIATE PMN SUBSTANCE 

Attachment Page Al4 
Attachment Page A15