### 1 SANITIZED COPY P . Form Approved . O .M .B . No . 2070-0012 . Approval Expires 10-31-96 . U .S . ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONL Y Date of receipt 

# PREMANUFACTUR E NOTICE ` 

# V EPA Es Company Sanitized 

# IIIII li~li II'i II'~ii I ►Ili II!''' ~I''~' i~',~ ~I I i i~'~'~I il' I'I' ;I~ ,

0 4 U 14 c ber in the Prem an ufacture Notice 

### Pr GENERAL INSTRUCTIONS TS _ 0 1141 E C 11 A • You must provide all information requested in th is 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 th e "Instructions M an ual for Prem an ufacture Noti fication" ( the Instructions Manual is available from the Toxic Subst ances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603) . • If a user fee has been remi tted for th is notice (40 CFR 700 .45), indicate in the boxes above the TS-user fee identifi cation number you have generated . Remember, your user fee ID number must also appear on your corresponding fee remi ttan ce, which is sent to EPA, HQ Accounting Operations Br anch (PM-226), P .O . 360399M, Pittsburgh, PA 15251-6399, Attn . TSCA User fee . Part I - GENERAL INFORMATION TEST DATA AND OTHER DATA You must provide the currently correct Chemical Abstracts (CA) Name of the new You are required to submit all test data in your possession or control and to provide chemical substance, even if you claim the identity as confidential . You may authorize a description of all other data known to or reasonably asce rtainable by you, if these an other person to submit chemical identity information for you, but your submission will data are related to the heal th an d environmental effects on the m an ufacture , not be complete and the review will not begin until EPA receives this information . A processing, distribution in commerce, use, or disposal of the new chemical letter in support of your submission should reference your TS user fee identification substance . Standard literature citations may be submi tted for data in the open number . You must submit an original an d two copies of this notice including all test data . scientific literature . Complete test data ( w ritten in English), not summa ri es of data . If you claimed any information as confidential, a single s an itized copy must also b e submitt ed . must be submi tt ed if they do not appear in the open literature . You should clearly identify whether test data is on th e subst ance or on an analog . Also, the chemical composition of th e tested material should be characterized . Following ar e Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE examples of test data and o th er data . Data should be submi tted according to the requirements of §720 .50 of the Prem anufacture Notification Rule (40 CFR Part If there are several manufacture, processing, or use operations to be described in Part II, 720) . sections A an d B of this notice, reproduce the sections as needed . Part III - LIST OF ATTACHMENTS Test Data ( Check Below any included in this notice ) Attach additional sheets if there is not enough space to an swer a question fully . Label • Environmental fate data ❑ Yes • Other data ❑ Yes each continuation sheet with the corresponding section heading . In Part 111, list thes e attachments, an y test data or other data and any optional information included in the • Health effects data ❑ Yes Risk assessments notice . • Environmental effects data ❑ Yes Structure/activity relationships • Physical/Chemical Properties* ® Yes Test data not in the possession OPTIONAL INFORMATION or con trol of the submitter You may include an y information that you want EPA to consider in evaluating the new • A physical an d chemical prope rt ies worksheet is located on the last page of this form . substance . On page 11 of this form, space has been provided for you to desc ribed pollution prevention an d recycling information you may have reg arding the new TYPE OF NOTICE (Check Only One) subst an ce . P . .? So-called "binding" boxes are included throughout this form for you to indicate your PMN ( Prem an ufacture Notice) C-" willingness to be bound to ce rt ain statements you make in this section, such as use, ` production volume, protective equipment . . This option is intended to reduce delays ❑ INTERMEDIATE PMN (submi tted in sequence with final product kTJ ) that routinely accompany the development of consent orders or Significant New Use T t t~ Rules . Except in the case of exemption applications (such as TMEA, LVE, LOREX) ❑ SNUN ( Significant New Use Notice ) where ce rt ain information provided in such notification is binding on the submi tter when the Agency approves the exemption application, checking a binding box in this notic e does not by itself prohibit the submi tter from later deviating from the information ( except ❑ TMEA ( Test Marketing Exemption Application) -+ chemical identity) repo rted in the form . ❑ LVE (Low Volume Exemption) @ 40 CFR 723 .50(c)(1) l'`) CONFIDENTIALITY CLAIMS ~ • ❑ You may claim an y information in this notice as confidential . To asse rt a claim on the LOREX ( Low Release/Low Exposure Exemption) @ 40 CFR 723 .?8(y)(2) form, mark (X) the con fi dential box next to the information that you claim a s con fi dential . To assert a claim in an attachment, circle or bracket the information you ❑ LVE Modification ❑ LOREX Modification claim as confidential . If you claim information in the notices as confidential, you mus t also provide a s anitized version of the notice, ( including attachments) . For additional IS THIS A CONSOLIDATED PMN? ❑ Yes instructions on claiming information as confidential, read the Instructions M an ual . # of chemical s (Prenotice Communication # required, enter # on page 3) EPA FORM 7710-25 (Rev . 5-95) Page 1 

# MR • 27G ~ 27

### p . 2

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 regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U .S . Environmental Protection Agency, 401 M . St ., S .W ., Washington, D .C . 20460 ; and to the Office 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 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 : ® 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 ❑ 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 . ❑ The manufacturer is familiar with the terms of this section and will comply with those terms ; and ❑ The new chemical substance for which the notice is submitted meets all applicable exemption conditions . ❑ 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 predic ti on of the anticipated facts regarding the chemical substanc e desc 

### ri bed herein . 

### Any knowing and willful 

### misinterpretation is 

### subject to c 

### ri minal 

### penalty pursuant to 18 USC 1001 . 

### Confidential Signature a

### n d title of Authorized Official (Original Signature Required) Date X Signature of agent - (if applicable) Date X

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

### p . 3 Part I -- GENERAL INFORMATIO N Section A -- SUBMITTER IDENTIFICATION ConfiM ark O the "Confidential" box next to any subsection you claim as confidential dential la . Person Name of authorized official Positio n 

### Submitting Notice (in U .S .) Company

Mailing address (number and street) City, State, ZIP Cod e b . Agent (if Name of authorized official Position applicable) X

Compan y Mailing address (number and street) City, State, ZIP Code Telephone Area Code Numbe r
c . If you are submitting this notice as part of a joint submission, mark (X) this box . ❑ Joint Submitter (if Name of authorized official Positio n applicable) Company

Mailing address (number and street ) City, State, ZIP Code Telephone Area Code Number 2 . Technical Name of authorized official Positio n Contact (in U .S ) X

Compan y Mailing address (number and street ) City, State, ZIP Code Telephone Area Code Number 3 . If you have had a prenotice communication (PC) concerning this notic e and EPA assigned a PC Number to the notice, enter the number . Mark (X) - ♦ ® if non e 4 . If you previously submitted an exemption application for the chemica l substance covered by this notice, enter the exemption number assigned by Mark (X) -~ ® EPA . If you previously submitted a PMN for this substance enter the if non e PMN number assigned by EPA (i .e . withdrawn or 

### incomplete) . No 5 . If you have submi 

### tt ed a notice of Bona fide intent to manufacture or impo 

### rt for the chemical substance covered by this notice, enter the notice number Mark (X) assigned by EPA . 10 if non e I . ❑ Manufacture 2 . ® Import 6 . Type of Notice - Mark (X) Only Only 3 . ❑ Both ❑ Binding Option ❑ Binding Optio n Mark (X) M ark (X) EPA FORM 7710-25 (Rev . 5-95) Page 3

### p . 4 Pa rt I -- GENERAL INFORMATION -- Continue d Section B -- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth Collective Index 9CI of CA nomenclature rules and conventions . M ark (X) the "Con fi dential" box next to any item you claim as con fidential Complete either item 1(Class I or 2 substances) or 2 (Polymers) as appropriate . Complete all other items . If another person will submit chemical identity information for you (for either Item l or 2), mark (X) the box at the right . ConfiIdenti the name, company, an d address of that person in a continuation sheet . ❑ dential 1 . Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual ) a . Class of subst ance - M ark (X) I ❑ Class l or 2 ❑ Class 2 b . Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances
. For Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9C1 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 1(CAS Inventory Expert Service - a copy of the Identification ❑ Method 2 (Other Source ) report obtained from the CAS Inventory Expert Services must be submitt ed as an attachment to th is notice ) d . Molecular formula and CAS Registry Number (if a number already exists for the substance) CAS#

e . For a class 1 substance, provide a complete and correct chemical structure diagram . For a class 2 substance -(1) List the immediat e precursor substances with their respective CAS Registry Numbers . (2) Describe the nature of the reaction or process . (3) Indicate the range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diaeram . as comolete as can be known, if one can be reasonably ascertained .



# This page does not apply .

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

### p . 5 Part I -- GENERAL INFORMATION -- Continue d Section B-- CHEMICAL IDENTITY INFORMATION -- Continue d 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 X below 1,000 absolute molecular weight of that composition . Describe the methods of measurement or the basis for your estimates : GPC ❑ Other ❑ : (Specify)

i) lowest number average molecular weight : ii) maximum weight % below 500 molecular weight : % iii) maximum weight % below 1000 molecular weight : % ❑ Mark (X) th is 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 confidentia l (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 ) X % X X % X X % X X % X % % % % ❑ M

### ark (X) 

### th is 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) X obtained from CAS Inventory Expert Service must be submitted a s 

### 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 . X

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

. 

### X

❑ Mark (X) this box if you attach a continutation sheet . EPA FORM 7710-25 (Rev . 5-95) Page 5

### p . 6 Part I -- GENERAL INFORMATION -- Continue d Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 3 . Impuritie s (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose . Provide the

CAS Registry Number if available . If there are unidentified impurities, enter "unidentified . " (b) -' Estimate`the maximum weight % of each impurity . If there are unidentified impurities, estimate th eir total weight % .Impurity and CAS Registry Number Maximum Confipercent dential (a) (b) % X % X % X % X

% ❑ M ark (X) this box if you a tt ach a continuation sheet . 4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2 . Confidential X ❑ Mark (X) this box if you attach a continuation sheet . 5 . Trade identification - List trade names for the new chemical substance identified in subsection I or 2 . 

### X ❑ Mark (X) this box if you attach a continuation sheet . 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 . Trifunctional acrylic este r

❑ M ark (X) this box if you a ttach 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 CAS Registry Number Confi- (1) (2) dential None Know n

❑ M ark (X) this box if you a ttach a continuation sheet . EPA FORM 7710-25 (Rev . 5-95) Page 6

### p . 7 Part I -- GENERAL INFORMATION -- Continue d Section C -- PRODUCTION, IMPORT, AND USE INFORMATION :

Mark (X) the "Con fi dential" box next to any item you claim as con fi dential . 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 r, specify the volume an d mark (x) in the binding box . If granted, 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 M ark (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 formulation of the new substance, and other use information . 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 formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under your control associated with each category of use . (7) -- Mark (X) this column if entry in column (6) is confidential business information (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 ent (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 Mark (x) ulation Site- Con-* Indus- Com- Bindin g 

### for finishing polyester fibers) 2) (3) (4) (5 (6) (7 limited sumer trial mercial Option (9) Trifunctional acrylic ester used in 100 °i° 2-15 10 0 

## lacquer / dry film manufacture % % % % % % % * 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 . ❑ 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 M anual for examples of generic use descriptions . description

~ M ark (X) th is box if you a ttach 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 Option for the safe handing, transport, use, or disposal of the new substance . List in part III hazard information you include . Mark (x) Mark (X) this box if you attach hazard information . EPA FORM 7710-25 (Rev . 5-95) Page 7

### p . 8 Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEAS E 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 processing or use operations after import . You must describe these operations . See instructions m anual 1 . Operation description Confia . Identity -- Enter the identity of the site at which the operation will occur . dential

Name v Site address (number and street) J~ City, County, State, ZIP cod e 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 . ❑ M ark (X) th is box if you att ach a continuation sheet . b . Type -- 

### Mark (X) ❑ M anufacturing Processing MUse c . Amount an d Duration -- Complete 1 or 2 as appropriat e Maximum kg/batch (1000% new chemical Hours/batch Batches/year substance ) 1 . Batch Maximum kg/batch (1000% new chemical Hours/batch Batches/ye 

### ar substance ) 2 . Continuou s d . Process description ❑ Mark (X) to indicate your willingness to have your process description binding . X (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 .

❑ Mark (X) this box if you attach a continuation sheet . EPA FORM 7710-25 (Rev . 5-95) Page 8

### p . 9

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continue d 2 . Occupational Exposure -- You must make sep arate confidentiali ty claims for the description of worker activi ty , physical form of th e new chemical subst an ce, number of works exposed, an d 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, cle an ing, etc .) in which workers may be exposed to th e subst ance . ( 2) -- Mark (X) this column if entry in column ( 1) is confidential business information (CBl) . ( 3) --Describe an y protective equipment an d 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 th e physical form(s) of the new chemical subst an ce (e .g ., solid : cry stal, gr anule, powder, or dust) and % new chemical subst an ce ( if part of a mixture) at the time of exposure . ( 7) -- M ark (X) this column if ent ry in column (5) is con fidential business information (CBI) . ( 8) -- Estimate the maximum number of workers involved in each activi ty for all sites combined . ( 9) -- Mark ( X) this column if ent ry in column (8) is confidential business information (CBI) . ( 10) an d (11) -- Estimate the maximum duration of th e activity for an y worker in hours per day and days per year . (12) -- Mark (X) th is column if entries in columns (10) and (11) are con fi dential business information (CBI) . Worker activi ty CBl Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI in ( i .e ., bag dumping, fi lling drums) Engineering Controls Option and % new option Workers Hrs/day Days/y r Mark ( x) substance M ar k (x) Expose d (1) (2) (3) (4) (5) ( 6) ( 7) (8) (9) ( 10) (11) (1 2 ) X gloves, goggles, local % X 1 1 .5 186 exhaust, workwea r X gloves, goggles, local % X 1 1 .0 186 exhaust, workwea r X gloves, goggles, local % X 2 2 .0 186 exhaust, workwea r X gloves, goggles, local % X 2 1 .0 186 exhaust, workwea r X gloves, goggles, local % X 2 2 .0 186 exhaust, workwea r X gloves, goggles, local % X 2 2 .0 186 exhaust, workwea r ❑ M ark ( X) th is box if you att ach a continuation sheet. 3 . Environmental Release and Disposal -- You must make sep ar ate con fi dentiali ty claims for the release number an d th e amount of the new chemical subst ance rele as ed and oth er release an d disposal information . M ark (X) the "Confidential" box next to each item you claim as confidential . ( 1) --Enter th e number of each release point identi fied in the process description, part II, section A, subsection l d(3) . ( 2) -- Estimate the amount of the new subst an ce released (a) directly to the environment or (b) into con trol technology ( in kg/day or kg/batch) . ( 3) --Mark ( X) th is column if entries in columns ( 1) an d (2) are con fi dential business information (CBI) . (4) --Identify the media (stack air, fugitive air (optional-see Instruction M anual), surface water, on-site or off-site l an d or incineration, POTW, or other (specify)) to which the new subst an ce will be released from that release point . (5) -- a . Describe control technology, if any, an d control efficiency that will be used to limit the release of the new subst ance to th e environment . For releases disposed of on l and, characterize th e disposal me th od and state whether it is approved for disposal of RCRA haz ardous waste . On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to seconda ry or te rt iary on-site treatment . b . Estimate the amount released to th e environment after con trol technology ( in kg/day) . ( 6) --Mark ( X) this column if entries in columns ( 4) an d (5) are con fidential business information (CBl) . (7) -- Identify the destination(s) of releases to water . Please supply NPDES (National Pollut ant Discharge Elimination System) numbers for direct discharges or NPDES numbers of th e POTW ublicly Owned Treatment Works) . Mark ( X) if the POTW name or NPDES # is confidential business information (CBI) . Release Amount of new subst ance CBI Media of Control technology an d efficiency (you may wish to optionally att ach efficiency data) CB1 Number released releas e (1) (2a) (2b) eg .stack - Binding ( 3) (4) (5a) Mark (X ) 

### R1 0 2 .4 Liquid ( 5b) (6) Incineration ( off-site) 0 kg/batch Wast e

(7) Mark ( X) the ❑ POTW provide name(s) below : CBI ❑ Navigable ❑ Other - Specify provide NPDES # CBI destination(s) of waterwa y rele as es to water . N/A N/A N/A ❑ Mark ( X) this box if you attach a continuation sheet . EPA FORM 7710-25 ( Rev . 5-95) Page 9

### P . 10

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section B -- INDUSTRIAL SITES CONTROLLED BY OTHER S 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 o f-processing, or use operation involving the new chemical substance . If the same operation is performed at more than one site describe the typical operation common to these sites . Identify addition al 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

❑ Mark (X) this box if you attach a continuation sheet . 2 . Worker Exposure/Environmental Releas e (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), (l 1,(13 an d (15) -- Mark (X) this column if an ofthe 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 & Contro l Act- Exposed Exposure Physical Form and % ulation Substance Technology ivity Released new substanc e (1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (10b) (11) (12) (13 )



### 1 . I 

# LT_ 14) -- Byproducts : (15) ❑ Mark (X) th is box if you a tt ach a continuation sheet , EPA FORM 7710-25 (Rev . 5-95) Page 10

### P . 11



# OPTIONAL POLLUTION PREVENTION INFORMATIO N To claim information in this section as confidential circle or bracket the specific information that you claim as con fi dential . 

## 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 chemica l substances used in similar application ; or (6) the extent to which the new chemical substance may be a substitute for an existing subst an ce that poses a greater overall risk to human health or the environment . 

## No information is available at this time .

❑ Mark (X) this box if you att ach a continuation sheet . EPA FORM 7710-25 (Rev . 5-95) Page I 1

### p . 12 

# Part III -- LIST OF ATTACHMENT S 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 attaoltment . 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 con fi dential .

### Attachment name Attachment Confipage number(s) dential

X X X 

# x X X X

❑ Mark (X) this box if you a

### ttach a continuation sheet . Enter the a

### ttachment name and number. EPA FORM 7710-25 (Rev . 5-95) Page 12

### p . 13 PHYSICAL AND CHEMICAL PROPERTIES WORKSHEE T 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 easured o cons- (X) if number Estimate dential (a) provided (b) (c) Mark (X ) M or E (d) White M 

### Physical state of neat substance (s) X(1) _) E Vapor pressur e Temperature 20-25 °C < 0 .01 mmHg Torr M Density/relative density 1 .09 g/cm3 25° C Solubility @ Temperature ° C Solvent Not determined Solubility in water Temperature °C Not determined Melting temperature (Glass transition temperature) Not determined E Boiling / sublimation tem erature 760 torr pressure >110° C Spectra X Not Determine d Dissociation constant Not Determined Particle size distribution Not Determined Octanol / water partition coefficient Not Determined Henry's Law constan t Volitalization fr om water Not Determined Not Determined Volitalization fr om soil 6 .8-7 .2 M pH@ concentration Flashpoint > 110°C E Flammability Not Determined Ex lodabili Not Determined Adsorption / coef

fi cient Not Determined Other - Specif

y Viscosity 60-90 cP @ 25°C M

r- I I I i Ll

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

### p . 14



# Pages Al through A10 have been Omitted from this Sanitize d Copy as the Information is Considered Confidential Business Information .

14