**Continuati on Sheet for Part II, Section A** 

**Item 2(3) -**  **P rotective 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 hook
up 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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