1

SANITIZED COPY P

.

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

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY

Date of receipt

PREMANUFACTURE

`V EPA NOTICE

Es Company Sanitized

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

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in the Preman ufacture Notice

14 c ber

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 Man ual for Prem an ufacture Noti fication" (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 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 Branch (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 and 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 submitted for data in the open number . You must submit an original and 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 san itized copy must also be

submitt ed . must be submitt ed ifthey do not appear in the open literature. You should clearly

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

composition of th e tested material should be characterized . Following are

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE examples of test data and oth er data . Data should be submitted according to the

requirements of §720 .50 of the Premanufacture 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 and chemical propert 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 regarding the new TYPE OF NOTICE (Check Only One)

substan ce .

P..?

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

Preman ufacture Notice) C-"

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 ❑ INTERMEDIATE PMN (submitted in sequence with final product kTJ)

that routinely accompany the development of consent orders or Significant

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

New Use T t t~

where ce rt ain ❑ SNUN (Significant New Use Notice)

information provided in such notification is binding on the submitter when

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

does not by itself prohibit the submitter from later deviating from the information (except ❑ TMEA (Test Marketing Exemption Application) -+

chemical identity) reported in the form.

❑ LVE (Low Volume Exemption) @ 40 CFR 723 .50(c)(1) l'`)

CONFIDENTIALITY CLAIMS ~ •

❑

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

LOREX ( Low Release/Low Exposure Exemption) @ 40 CFR 723 .?8(y)(2)

form, mark (X) the confidential 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 must

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 Man 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 an 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 INFORMATION

Section A --SUBMITTER IDENTIFICATION ConfiMark O the "Confidential" box next to any subsection you claim as confidential dential

la. 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)

X

Compan y

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 . ❑

Joint 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) 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 notice

and EPA assigned a PC Number to the notice, enter the number. Mark (X) -♦ ®

if none

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

PMN number assigned by EPA (i e .e . withdrawn or incomplete). No

5 . If you have submi tt ed a notice of Bona fide intent to manufacture or import

for the chemical substance covered by this notice, enter the notice number Mark (X)

assigned by EPA .

10 if none

I . ❑ Manufacture 2. ® Impor . Type of Notice - Mark (X)

Only Only 3

t 6

. ❑ Both

❑ Binding Option ❑ Binding Optio n

Mark (X) Mark (X)

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 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 - Mark (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

% %

% %

❑ Mark (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 -- 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 . 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

%

❑ Mark (X) this box if you att 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 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 CAS Registry Number Confi-

(1) (2) dential

None Known

❑ M ark (X) this box if you attach 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 fidential" 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 r, specify the volume an d mark (x) in the binding box . Ifgranted, 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 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- Binding

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

Trifunctional acrylic ester used in 100 °i° 2-15 100

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 Manual for examples of generic use descriptions .

description

~ Mark (X) th is 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 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 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 processing or use operations after import. You must describe these operations. See instructions manual

1 . Operation description Confia . Identity -- Enter the

Name v

identity of the site at which the operation will occur. dential

Site address (number and street) J~

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) th is box if you att ach a continuation sheet.

b. Type --

Mark (X) ❑Manufacturing 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/year

substance)

2 . Continuou s

d . Process description

(1) Diagram the major unit operation steps and chemical conversions

❑ Mark (X) to indicate your willingness to have your process description binding

. Include interim storage and transport containers (specify- e

. X

.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 -- Continued

2. Occupational Exposure -- You must make sep arate confidentiali ty claims for the description of worker activity, physical form ofth e new chemical substan ce,

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, clean 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 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 th e physical form(s) of the new chemical substan ce (e .g., solid : cry stal, granule, 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 entry in column (5) is con fidential 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 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 activity CBl Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI

in

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

Mark ( x) substance Mark (x) Exposed

(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

❑ Mark (X) th is box if you att ach a continuation sheet.

3. Environmental Release and Disposal -- You must make sep ar ate con fi dentiality claims for the release number an d th e amount ofthe new chemical subst ance

released and oth er release and disposal information . 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 l d(3).

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

( 3) --Mark ( X) th is column if entries in columns ( 1) and (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 and or incineration, POTW, or other (specify)) to

which the new substan ce 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 subst ance to th e environment. For releases

disposed of on l and, characterize th e disposal meth 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 control technology ( in kg/day).

( 6) --Mark ( X) this column if entries in columns ( 4) and (5) are con fidential business information (CBl).

(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 th e POTW ublicly Owned Treatment Works) . Mark (X) ifthe POTW name or NPDES # is confidential business information (CBI) .

Release Amount of new subst ance CBI Media of Control technology and efficiency (you may wish to optionally att ach efficiency data) CB1

Number released release

(1) (2a) (2b) eg.stack - Binding

(3) (4) (5a) Mark (X)

R1 0 2.4 Liquid (5b) (6)

Incineration (off-site) 0

kg/batch Waste

(7) Mark ( X) the ❑ POTW provide name(s) below : CBI ❑ Navigable ❑ Other - Specify provide NPDES # CBI

destination(s) of waterway

releases 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 of-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 & Control

Act- Exposed Exposure Physical Form and % ulation Substance Technology

ivity Released new substance

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (10b) (11) (12) (13)

1

14) -- Byproducts :

. I LT_

(15)

❑ Mark (X) th is box if you att ach a continuation sheet,

EPA FORM 7710-25 (Rev . 5-95) Page 10
P. 11

OPTIONAL POLLUTION PREVENTION INFORMATION

To claim information in this section as confidential circle or bracket the specific information that you claim as con fidential.

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

substance 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 attach a continuation sheet.

EPA FORM 7710-25 (Rev . 5-95) Page I 1
p. 12

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 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 confidential.

Attachment name Attachment Confipage number(s) dential

X

X

X

x

X

X

X

❑ 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
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

Physicalstate of neat substance (s) X(1) _)

E

Vapor pressure

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 Determined

Dissociation constant

Not Determined

Particle size distribution

Not Determined

Octanol / water partition coefficient

Not Determined

Henry's Law constant

Volitalization fr

om water Not Determined

Not Determined

Volitalization from soil

6.8-7.2 M

pH@ concentration

Flashpoint > 110°C E

Flammability

Not Determined

Ex lodabili

Not Determined

Adsorption / coefficient

Not Determined Other - Specify

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