Continuation Sheet for Part II, Section A

Item 2(3)- Protective Equipment/Engineering Controls

All activities associated with the manufacturing and processing (e.g. quality control) of 

the new substance are carried out in well ventilated areas. All workers are provided 

with and required to wear uniforms and adequate personal protection equipment as part 

of an organized worker safety and industrial health program. As part of this program, 

every raw material undergoes a complete hazard evaluation and appropriate personal 

protective equipment is required where necessary when possible exposure exists.

The procedure for cleaning all equipment, and the charging of the new substance to 

reactors and filtration tanks, is essentially a closed system. Thus the potential for 

worker exposure is low and any contact that does occur is purely incidental. Also, the 

time involved for potential exposure is small since it largely occurs only during the hookup of pumps and valves. The reported times are thus estimates of potential exposure 

and do not include the time during which the liquid containing the PMN substance is 

physically moving through the equipment.

The number of workers reported in Part II, Section A, Item 8, as involved in each 

manufacturing and processing activity, represents the number of workers performing 

the activity. Allowing for possible shift changes and break relief, the actual number of 

workers performing some part of the activity may be two or three times the listed 

number depending on the number of operating shifts.

Item 3(5a) – Environmental Release and Disposal- Control Technology

Our company utilizes wash-water and solvent-wash recovery systems in an effort to 

reduce any amount of waste generated in the manufacturing and processing of 

materials. Any cleaning material used to rinse equipment clean (e.g. pipes, reactors, 

etc.), as the material is transferred from one vessel to the next, becomes part of the 

batch of produced substance.

As the material is filled, the final cleaning wash is recycled through a cleaning wash 

recovery system. Dirty wash material is treated to remove any contaminants or 

impurities before being reclassified as clean wash material. The sludge that 

accumulates throughout this process is incinerated, and ash that remains is disposed of 

in RCRA approved landfills.

The amounts reported in Part II, Section A, Item 3(2b), are approximations based on 

the total solids of the PMN substance as applied to standard process loss calculations. 

These numbers should not be interpreted as amounts for direct loss or discharge of the 

PMN substance.

Our company maintains a “zero-discharge” policy for hazardous waste. Thus, no 

amount of PMN substance will be released to any POTW.
Our company operates a hazardous waste Energy Recovery Unit at { }

location. This rotary kiln unit has been designed to treat, through incineration and energy 

recovery, the majority of our company’s hazardous waste. Thus, waste is reduced to a 

small fraction of its original volume and the energy value of the waste is recovered in the 

form of steam to help meet the total energy requirements of the manufacturing plant. 

Wastes handled at the Energy Recovery Unit are generated from the manufacture and 

processing of our products. These include: process equipment cleaning residues, 

reaction byproducts, unusable products or raw materials, organic wastes consisting 

primarily of solvents, still sludges, paints, or resins, and aqueous wastes consisting 

primarily of organically contaminated water, caustic wash solutions or waterbase paints 

and resins. Solid wastes are primarily trash, empty raw material containers, filter 

material, raw materials or solidified paints and resins.

Drums: Our { } facility uses a drum reconditioner that processes all drums 

received (regardless of previous contents) in a furnace to burn out any residue and burn

off all labels. The oxidized drums are then reconditioned by physical means and 

painted. The ash from the furnace is landfilled.

Our { } facilities use drum reconditioners that process drums based on 

whether they are open-head (lid bolted into place with a gasketed ring) or closed-head 

(bung opening in the lid), regardless of the material that the drums previously held. 

Open-head drums are first oxidized in a furnace to burn out any residue and burn off all 

labels, and then are reconditioned by physical means and painted. The ash from the 

furnace is landfilled. Closed-head drums are caustic washed, reconditioned by physical 

means, and then painted. The spent caustic washwater and sludge are sent to a 

commercial treatment facility where the combined caustic liquid and sludge are 

stabilized and chemically fixed. The resulting solidified material is shipped to a secure, 

non-hazardous landfill.

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