• 

PREMANUFACTURE 

NOTICE 

ZO"G 1 u.- 0vl~ /1'' 2'· .._, 

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send tins 

hltlllll) 

FOR NEW CHEMICAL SUBSTANCES 

DOCUMENT CONTROL OFFICER 

_;ompany Sanitized 

Enter the total number of pages 

in the Premanufacture Notice 

OFFICE OF POLLUTION PREVENTION 

AND TOXIC SUBSTANCES, 7407 

U.S. E.P.A. 401 M STREET, SW 

WASHINGTON, D.C. 20460 

GENERAL INSTRUCTIONS 

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, Attn. 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 u.<>er 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 111-LISTOF ATTACHMENTS 

Attach additional sheel<> if there is not enough space to answer a question fully. Label 

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

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

notice. 

OPTIONAL INFORMATION 

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

substance. On page I 1 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 arc included throughout this fonn 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, L VE, 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 

~by itself prohibit the submitter from tater deviating from the information (except 

chemical identity) reported in the form. 

CONRDENTIALITY 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 VPu claim jnformation jn the notices as confidential yon must 

also provjde a sanitized version of the notice linc!udjng 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. 

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

TEST OAT A 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 dt~ta are 

related to the health and environmental effects on the manufacture, processing, 

distribution in commerce, use, or disposal of the new chemical substance. Stt~ndt~rd 

literature citations may be submitted for dt~t<~ in the open scientific litert~ture. ~ 

test data £written in English) not summaries of data must be submitted if they do not 

appear in the open literature. You should clearly identify whether te.~t 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 Premanuf<~cture Notifict~tion 

Rule ( 40 CFR Part 720). 

Test Data (Check Below any included in this notice) 

Environmental fate data 

Health effects data 

Environmental effects data 

PhysicaVChemical Properties• 

0 Yes 

0 Yes 

0 Yes 

0 Yes 

Other dat<~ 0 Yes 

Risk assessments 121 

Structure/activity relationships 0 

Test data not in the;po~scssion or 0 

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) 

(gJ PMN (Premanufacture Notice) 

D 

D 

D 

INTERMEDIATE PMN (submitted in sequence with final pro~~ct PMN) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

0 LYE (Low Volume Exemption)@ 40 CFR 723.50(c)(l) 

0 LOREX (Low Release/Low Exposure Exemption)@ 40 CFR 723.50(c)(2) 

D LYE Modification 

IS THIS A CONSOLIDATED PMN? 

# of chemicals 2 

D 

(gJ 

LOREX Modification 

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

Replaces previous editions of EPA Form 7710-25. 

;t/L#3.:<oo3j 
Public reporting burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions, 

searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send 

comments regardi'ng the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, 

lnformation 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: 

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

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

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

3. I am submitting with this notice 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 SNUN, check the following user fee certification 

statement that applies: 

[8J The Company named in Part I, Section A has remitted the fee of$2500 specified in 40 CFR 700.45(b), or 

D 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 

D 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)(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: 

0 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. 

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

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

D If this application is for an LVE in accordance with 40 CFR 723.50(c)(l), the manufacturer intends to commence manufacture 

of the exempted substance for commercial purposes within I year ofthe date of the expiration of the 30 day review period. 

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

described herein. Any knowin2-and willful misinterpretation is subJect to criminal penalty pursuant to 18 USC 1001. 

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

Signature of agent -(if applicable) Date 

EPA FORM 7710-25 (Rev. 5-95) Page2 

Confidential 

X 

X 
Person 

Submitting 

Notice (in U.S.) 

b. Agent (if 

applicable) 

Joint Submitter (if 

applicable) 

Contact (in 

U.S.) 

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

assigned by EPA. 

6. Type of Notice- Mark (X) 

I. 

D 

Manufacture 

Only 

2. 

D 

Import 

Only 

Mark (X) 

if none 

Mark (X) 

if none 

Binding Option 

3. D Both 
a. 

c. 

If another person will submit chemical 

the 

information for you (for either Item I or 2), mark (X) the box at the right. 

name i 

For Class I substances Index Name must be For Class 2 substances either a CA Index Name orCA Preferred Name must 

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

0 Method I (CAS Inventory Expert Service- a copy of the Identification 

Obtained from the CAS Expert Services must be 

e. and 

precursor substances their CAS Registry Numbers. (2) 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 comolete as can be known. if one can be reasonablv ascertained. 

attach a continuation sheet. Refer to 

EPA FORM 7710-25 (Rev. 5-95) Page4 
a. 

c. 

For Class I substances a Index Name must be provided. For Class 2 substances either a CA Index 

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

used or obtain 

Method 1 (CAS Inventory Expert Service- a copy of the Identification 

report obtained from the CAS Inventory Expert Services must be 

substance) 

e. structure 

·-

For a substance - ( 1) 

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 comolete as can be known. if one can be reasonablv ascertained. 

111111111111111111111111111111111111111111111111111111111111111111111111111 5\0~0000447/S 

attach a continuation sheet. Refer to Continuation Sheet 

X 

X 

X 

X 
Continuation Sheet: Part I- General Information 

Section B- Chemical Identity Information 

Subsection B(l )(e) - Representative Structural Diagram 

I 

I 

Page 4(a)-l 
I. 

Section Bc. 

e. 

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. 

Manual) 

I name correct i 

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

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

precursor substances their CAS Registry Numbers. (2) 

-

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 comolete as can be known. if one can be reasonablY ascertained. 

X 

X 

X 
Continuation Sheet: Part I - General Information 

Section B- Chemical Identity Information 

Subsection B(l)(e)- Representative Structural Diagram 

I 

I 

• 
• 

Page 4(b)-l 
a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. 

d. 

e. 

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 D Other 0: (SpecifY) 

i) lowest number average molecular weight: 

ii) maximum weight% below 500 molecular weight: 

iii) maximum weight% below 1000 molecular weight: 

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

(I) 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 (I) 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. 

% 

0 Method 1 (CAS Inventory Expert Service - a copy of the identification report 

obtained from CAS Inventory Expert Service must be submitted as 

with Inventory listings 

a correct structure can 

attach a continuation sheet. 

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

maximum . . 

% 

% 

1 you must 

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

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

attach a continuation sheet. Refer to 

resulting from new chemical 

EPA FORM 7710-25 (Rev. 5-95) Page6 

Provide the 

I 

dential 
(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 · enter "unidentified." 

their total 

identified i subsection I or 2. 

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

name ~ you name your 

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. 

Sodium olefin sulfonate derivative 

use, or new 

6(a) 

dential 

% 

% 

X 
(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." 

i. 

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

5. trade names 

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

claim i i 1 i you must your 

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. 

Sodium olefin sulfonate derivative 

use, or 

X 
volume~~ Estimate maximum volume volume 

any consecutive 12~month period during the first three years of production. Estimates should be on I 00% 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 kglyr, specify the volume and mark (x) in the binding 

12-month (kg/yr) 

( 100% new chemical substance basis) dential 

X 

Binding 

Option 

Mark 

rz~~elnrc~l.rt~~1!c~must category, the formulation of the new 

s~e~p;ar~a"-te:Ccmi~mT.~ycr.ilinsfilr~<dOs<riPt;rn~flli~~~~~~~~erce.ltGJ~J.h~on~~~~Oiei>~;Ct~--i substance, and other use information. (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 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 formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial 

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

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

(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 

this 

X 

, enter a 

Processing aid 

hazard information. 

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

2. Continuous 

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

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

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

X 

(2) Provide the identity, the approximate weight (by kg/day or kg/batch on a I 00% 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. 

this box attach a continuation sheet. Refer to Continuation Sheets 

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

Continuation Sheet: Part II- Human Exposure and Environmental Release 

Section A- Industrial Sites Controlled by the Submitter 

Subsection A(l)(d)- Process Description 

Page 8(a) 
= 0 

·-.... 

·-a.. 

<:.1 

"' ~ 

~ ~ 

"' ..Q 

~ 

00 

" "" .. 

0.. 

"' ~ 

<:.1 

0 

a.. 

~ 

= 

·-a.. 

.... = <:.1 

~ 

= = ~ 

~ 
. Part 11-- HU!VIAN 1!..!\.YU~URE AND 1!.1'1 v lKUl'llVll!.l'l l'AL RF.I .F.ASF.- C'ontinnPtl 

A-- >I .KIAL SITES LU!' lKULLED BY THE :>UD!Vlll 1M{- CnntinnPrl 

I 2. < -• ·You must make separate · v claims for the' 'or worm activity. phys~c;'~ '"'~'~ v• new chemical 

"" number of works exposed, and duration of activity. Mark t·~!.~e __ - box next to any item you claim as confidential. 

(I)-- Describe the activities (i.e. bag dumping, tote filling, I 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 (CBI). 

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

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

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

at the time of exposure. 

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

~f~~ ~~~) -- Estimate the maximum duration ofth~ :~vg~) for any worker in hours per day and~~~~:~~~ year. •· :(X) thiscolumn ifetr(ries in colu~ (I 0) and i) are , · business 

Worke~~,~~lii~g' CBI ~;~~~g , Physi~;;f;:J:~) ~;~~nng CBI #of CBI CBI 

(e.g. bag dumping, I drums) Equipment/Engineering (e.g. solid, Workers Maximum Duration 

Controls Mark (X) and %new Mark(X) Exposed 

substance 

(I) (2) (4) (5) (6) (7) (8) (9) H~~)ay Dmt (12) 

~ X X I X I • X 

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

3. 

released and other release an~~::;~:~' i~f~::::a~~~t ':,~~~~)~~' i · ·;!, ~~~~!:~;ot~:~~~~~~ ~~:~~i:!t~ .. ~~~~i~ffthe • 

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

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

(3) --Mark (X) this column if entries in columns (I) 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) -- [dentify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct or 

NPDES nh. ,r.h,, POTW 1 'Owned t ·works). Mark (X) if the POTW name or NPDES # is I business . I(CEI). 

Release Amount o~ new : CBI Merna of Control I (you! ••y n;,,Jto 1 attach' 1 data) 1 em 

Number released release 

(I) (2a) (2b) e.g. $taCk. air 

~~~,(~, (3) (4) (Sa) (Sb) I (6) 

(7) Mark (X) the lXI POTW provide name(s) below: CBI D Navigable 0 Other • Specicy Prov1de NPDES # CBI 

destination(s) of Waterway 

releases to water. X X 

:1:8J Mark IX) this box if you attach ' ' sheet. Refer to 1 Sheets Page 9(a) 

EPA FORM 7710-25 (Rev. 5-95) Page 9 
Continuation Sheet: Part II- Human Exposure and Environmental Release 

Section A- Industrial Sites Controlled by the Submitter 

Subsection A(2) - Occupational Exposure 

Subsection A(3)- Environmental Release and Disposal 

Page 9(a) 
not 

processing or use activities after import. See the Instructions Manual. Complete a separate 

new chemical substance. If the same operation is performed at more than one site describe the 

a continuation sheet. 

or bracket the specific information that you as confidential. 

(I -- Diagram the major unit operation steps and chemical conversions, including storage and transport containers (specifY- e.g. S 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 a 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 

(I) --From 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. 

(I 0) -- 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 

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

Identify l>)'l'lrO<iucts which result from the operation. 

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

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

EPA FORM 7710·25 (Rev. 5·95) Page II 
< 

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 Confipage number(s) dential 

Material Safety Data Sheets Attachment I X 

Inventory Expert Service (IES) Reports Attachment 2 X 

Preliminary Risk Assessment for PMN Substances Attachment 3 X 

Attachment 3a X 

Attachment 3b X 

Attachment 3c X 

Attachment 3d X 

Attachment 3e X 

Attachment 3f X 

Attachment 3g X 

Attachment 3h X 

Attachment 3i X 

Attachment 3i X 

Attachment 3k X 

0 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 
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 (X) Page Value Measured or Conti· 

if provided number Estimate dential 

(a) (b) (c) (MorE) Mark(X) 

(d) 

P~_?ical state of neat substance (s) (I) (g) 

Vapor pressure • (al Temperature •c Torr 

Density/relative density glcm3 

Solubility 

@Temperature •c 

Solvent giL 

Solubility in water@ Temperature •c giL 

Melting temperature •c 

Boiling I sublimation temperature(a'l_ torr pressure •c 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol/ water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

pH @l concentration 

Flammability 

Explodability 

Adsorption I coefficient 

Other - Specify 

Refer to paees 13(a) and 13(b) 

Page 13 
f'tll 'A. I, AND CHF.MIC'A.I lliESWORI ,I 

To assist EPA's rev1ew o~ p~y~~~~land chemical properties dat" P!~:"e_ :the following t for data you p~ovide and 

include it in the notice. ·~ 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 

; for · · 1 of test data. 

Property Mark(X) Page Value 

if provided number j M~~i:~~eor ;e~~~j (a) (b) (c) (MorE) 

ldl 

Physical state of neat substance lm -(g) X 

Vapor p@~ure 

_•c Torr 

I 'density 11/cm3 

Solubility 

@Temperature •c 

Solvent elL 

in water@ Temperature 21 oc X 

Melting· •c 

Boiling/ tnrr pressure 'C 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol/ waler partition ' 

Henry's Law constant 

from water 

1 from soil 

pH @J 

" 

i' 

I coefficient 

Other- Specify 

X 

EPA FORM 7710-25 (Rev, 5-95) Page 13(a) 
' t'H Y ~ICAL AND , uCAL m,T 

:~1~~~ ~t 7: ~; ~~~i~; ~ pn:I;c~l a;r~~:~~~~~~~~;;: 'ili! :=~~ ~;~~ee notice on' !~~ch the p;;P;;;;;;~;:~r~ata ~ou ~f th~ 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 

p "' . You should submit this worksheet as a supplement to your submission of test data. This worksheet is not a 

i 1 of test data. 

Property ~hlk <;<>, Page Value Contl: • e· number Estimate dential 

(a) (b) (c) (MorE) 

M"[,~ <l'l 

~~si~~state of neat substance ~s) -(1) -(g) X 

Vapor pressure 

'C Torr .@! 

:density wcm3 

Solubility 

@Temperature 'C 

Solvent g/L 

in water@ Temperature 21°C X 

Melting 1 'C 

Boiling! torr pressure 'C 

Spectra 

i 1 constant 

Octanol I 

Henry's' 

1 from water 

from soil 

pH @' i 

I coefficient 

Other - SpecifY 

X 

oPA FORM 7710-25 (Rev. 5-95) Page 13(b) 
Attachment 1 

Material Safety Data Sheets 

4 Pages Each - TSCA CBI 
Attachment 2 

Inventory Expert Service (IES) Reports 

2 pages - TSCA CBI 
Attachment 3 

Preliminary Risk Assessment for PMN Substances 

10 Pages- TSCA CBI 
Attachment 3a 

77 Pages - TSCA CBI 
Attachment 3b 

20 Pages- TSCA CBI 
Attachment 3c 

38 Pages - TSCA CBI 
Attachment 3d 

44 Pages - TSCA CBI 
Attachment 3e 

18 Pages - TSCA CBI 
t 

Attachment 3f 

22 Pages - TSCA CBI 
Attachment 3g 

21 Pages- TSCA CBI 
'· 

Attachment 3h 

EPA Reassessment of One Exemption from the 

Requirement of a Tolerance 

11 Pages - TSCA CBI 
Attachment 3i 

10 Pages- TSCA CBI 
Attachment 3j 

7 Pages - TSCA CBI 
Attachment 3k 

7 Pages - TSCA CBI