n 1 

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

U.S . ENVIRONMENTAL PROTECTION AGENC Y AGENCY USE ONLY 

Date of receipt 

I 

PREMANUFACTiJRF ~~e-~ac,~e~,1 ~ , 

\ / 

I IIIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII I II IIIII II IIII 

, t, r , .. 

5 1 1 0 0 0 0 0 2 2 2 I S 1" : 

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U.S . E.P .A. 401 M STREET, SW COmpany Sanitized WASHINGTON, D.C . 20460 

nter the total number of pages 25 f42 

L 

PA case number 

in the Premanufacture Notice E P-1 ~~222 

GENERAL INSTRUCTIONS TS -u u u u u u 

" 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 Prem anufacture 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, Arm. 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 ascertainable by you, if these 

another person to submit chemical identity information for you, but your submission will data are related to the health and environmental effects on the manufacture, 

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 (written in English) not summaries of data, If you claimed any information as confidential, a single sanitized copy must also be . , 

must be submitted if they do not appear in the open literature . You should clearly submitted. identify whether test data is on the substance or on an analog . Also, the chemical 

composition of the tested material should be characterized . Following are 

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE examples oftest data and other 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 and 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 answer a question fully . Label " Environmental fate data El Yes " Other data 0 Yes 

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

attachments, any 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 control of the submitter 

You may include any information that you want EPA to consider in evaluating the new " A physical and chemical properties worksheet is located on the last page of this form . 

substance. On page 11 of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new TYPE OF NOTICE (Check Only One) 

substance. 

" " 

® PMN (Premanufacture Notice) 

So-called binding boxes are included throughout this form 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 ~ INTERMEDIATE PMN (submitted in sequence with final product PMN) 

that routinely accompany the development of consent orders or Significant New Use 

Rules . Except in the case of exemption applications (such as TMEA, LVE, LOREX) ~ SNUN (Significant New Use Notice) 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 

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) 

CONFIDENTIALITY CLAIMS 

LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723 .50(c)(2) 

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 ~ LVE Modification ~ LOREX Modification 

claim as confidential . If you claim information in the notices as confidential, you must 

also provide a sanitized version of the notice, (including attachments) . For additional IS THIS A CONSOLIDATED PMN? F-1 Yes 

instructions on claiming information as confidential, read the Instructions Manual . 

® 

M k if i f ti i thi i i l i d f d i l 

# of chemicals 

(Prenotice Communication # required enter # on page 3) ar (x) any n orma on n s not ce s c a me as con i ent a . , 

EPA FORM 7710-25 (Rev . 5-95) Replaces previous editions of EPA Form 7710-25. 

MR -3!2 44 93 
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 1 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 

0 The Company named in Part 1, 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. 

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

r-1 The new chemical substance for which the notice is submitted meets all applicable exemption conditions . 

0 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 prediction of the anticipated facts regarding the chemical substance 

described herein. An knowin g and willful misinterp retation is subject to criminal penal ty pursuant to 18 USC 1001 . Confidential 

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

Signature of agent -(if applicable) Date 

.2 

EPA FORM 7710-25 (Rev . 5-95) Page 2a 
p. 3 

Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTIFICATION 

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) 

Company 

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. 

Joi nt 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 

Company 

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) --i 

if none 

4 . If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by 

EPA If i l b i d f Mark (X) . you prev ous y su m tte a PMN or this substance enter the El X if none PMN number assigned by EPA (i .e . withdrawn or incomplete)- ---0 

5 . If you have submitted a notice of Bona fide intent to manufacture or import 

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

assi n d b EPA g e y . -~ 

Mark (X) -i El X if none 

6. 

I . ® Manufacture 

Type of Notice - Mark (X) 2 . ~ Import 

Only Only 3. ~ Both 

Binding Option 

1 

~ Binding Option 

Mark (X) Mark (X) 

Mark () the Confidential box next to an y subsection y ou claim as confidential 

Confidential 

EPA FORM 7710-25 (Rev. 5-95) Page 3a 
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 . 

Mark (X) the "Confidential" box next to an y item you claim as confidential 

Complete either item 1 (Class 1 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 1 or 2), mark (X) the box at the right. Con& 

Identi the name, comp any, and address of that p erson in a continuation sheet . El dential 

I . Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. Class of substance - Mark (X) I [] Class 1 or 2 

0 

Class 2 X 

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 X 

be provided, which ever is appropriate based on CA 9CI 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) Sci-Finder 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d . Molecular formula and CAS Registry Number (if a number already exists for the substance) 

X 

CAS# 

X 

e. For a class I substance, provide a complete and correct chemical structure diagram . For a class 2 substance - (1) List the immediate 

precursor substances with their respective CAS Registry Numbers . (2) Describe the nature of the reaction or process . (3) Indicate the X 

range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure 

diagram, as complete as can be known, if one can be reasonably ascertained . 

f. 

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

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

Part I -- GENERAL INFORMATION - Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

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 

below 1,000 absolute molecular weight of that composition . 

Describe the methods of measurement or the basis for your estimates : GPC 0 Other Q: (Specify) 

i) lowest number average molecular weight : 

ii) maximum weight % below 500 molecular weight : 

iii) maximum weight % below 1000 molecular weight : 

0 Mark (X) this 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 confidential 

(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 

% % 

Mark (X) this 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 El Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

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 . 

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

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

EPA FORM 7710-25 (Rev. 5-95) Page 5a 
p. 6 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

3'. Impuiities 

(a) - Identify each impurity that maybe 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 ." 

(b) - Estimate the maximum wei ght % of each impurity. If there are unidentified imp urities, estimate their total wei ght %. 

Provide the 

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(b) 

Confidential 

% X 

% X 

% X 

% X 

% 

% 

% 

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

4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. Confidential 

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

X 

5 . Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

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

X 

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. 

Alkyltin halide 

Mark (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 

(1 

CAS Registry Number 

(2) 

Confidential 

X 

X 

X 

r9 __ 

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

EPA FORM 7710-25 (Rev . 5-95) Page 6a 
Part I -- GENERAL INFORMATION -- Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

Mark (X) the "Confidential" box next to any item you claim as confidential . 

1 . Pro auction 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 /yr, specify the volume and mark (x) in the binding box. If ranted, 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 entry(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 finishin g pol y ester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

% X °/u X 

0 0 

0 0 

0 0 

0 0 

0 0 

0 0 

* 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 . 

E]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 

Alkylating agent 

~ Mark (X) this 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 Ill hazard information you include . 

Mark (x) 

® Mark (X) this box if you attach hazard information. 

.7 

EPA FORM 7710-25 (Rev . 5-95) Page 7a 
p. 8 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

SectioqA -- 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 processin g or use operations after im port. You must describe these operations . See instructions manual 

1 . Operation description Confia . Identity -- Enter the identity of the site at which the operation will occur. dential 

Name 

Site address (number and street) 

i 

City, County, State, ZIP code 

If the same operation will occur at more than one site, enter the number of E 

sites . Identify the X 

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) this box if you attach a continuation sheet. b. Type -- 

Mark (X) E]Manufacturing aProcessing QUse 

c. Amount and Duration -- Complete 1 or 2 as appropriate 

Maximum kg/batch (1ooi new chemical Hours/batch Batches/year 

substance) X 

l . Batch 

Maximum kg/batch (iooi new chemical Hours/batch Batches/year 

substance) X 

2 . Continuous 

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

(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. 

CONFIDENTIAL INFORMATION 

REMOVED 

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

EPA FORM 7710-25 (Rev . 5-95) Page 8a 
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 separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, 

' numher Uf 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, cleaning, etc .) in which workers may be exposed to the substance . 

(2) --Mark (X) this column if entry in column (1) 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) . 

(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year . 

(12) -- Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximum duration CBI 

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

Mark (x) substance Mark (x) 

Exposed 

(1) (2) (3) (4) (5) (6) (7) (8) (9) (ID) (II) (l2) 

X X X X 

X X X X 

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

3 . Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other 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 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 (1) 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) -- Identify the destination(s) of releases to water . Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CBI) . 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

Number released release 

(1) (2a) (2b) ~.g. 4) au (3) ( Binding 

(56) (6) 

X 

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

destination(s) of waterway 

releases to water. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9a 
p. 10 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

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 suhstance. If the same operation is performed at more than one site describe the 

typ ical o peration common to these sites . Identify additional 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 Release 

(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), (11), (13) and (15) -- Mark (X) this column if an of the p roceeding entries are confidential business information (CBI) . 

Letter # of CBI Duration CBI Protective Equip. / % in CBI Release Amount of CBI Media of Release CB1 of Workers of Engineering Controls/ Form- Number New & Control Act- Exposed Exposure Physical Form and % ulation Substance Technology ivity 

new substance Released 

(1) (2) (3) (4a) (46) (5) (6) (7) (8) (9) (l0a) (lOb) (11) (12) (13) 

(14) -- Byproducts : (15) 

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

EPA FORM 7710-25 (Rev . 5-95) Page 10a 
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 (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 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 eater overall risk to human health or the environment. 

CONFIDENTIAL INFORMATION 

REMOVED 

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

n 11 

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

a e number(s) 

Confidential 

14 X 

15 X 

Part I, Section C.3 - Material Safety Data Sheet 16-20 

21-22 X 

23-24 X 

25 X 

a Mark (X) this box if you attach a continuation sheet . Enter the attachment name and number. 

EPA FORM 7710-25 (Rev . 5-95) Page 12a 
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 

(a) 

Mark 

(x) if 

provided 

Page 

number 

(b) 

Value 

c) 

Measured o 

Estimate 

M or E 

consdential 

Mark (X) I Physical state of neat substance X MsDs (s) X-0) _(g) M 

Vapor pressure 

Temperature °C 

X 

Torr 

E X ' 

' 

Dens i /relative density M MSDS 1 .86 cm3 M 

Solubility 

@ Temperature °C 

Solvent g/L 

Solubility in water Temperature °C X E X 

Meltin g temperature X tvtSDS < 0 °C M 

Boiling / sublimation temperature torr pressure X °C E X 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient X E X 

Henry's Law constant °C 

Volatilization from water 

Volatilization from soil 

H concentration 

Flammability X MSDS > 110 °C M 

Ex lodability 

Adsorption / coefficient X E X 

Other - Specify 

.13 

ATTACHMENT 

PAGE 13 
p. 14 

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 processin g or use operations after im port. You must describe these operations . See instructions manual 

1 . Operation description Confia . Identity -- Enter the identity of the site at which the operation will occur . dential 

Name X 

I 

Site address (number and street) 

0 

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 X X 

production rates or operations, include all the information requested in this section for those 

sites as attachments . 

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

b. Type -- 

Mark (X) El Manufacturing E]Processing E]Use 

c . Amount and Duration -- Complete 1 or 2 as appropriate 

Maximum kg/batch (loor new chemical Hours/batch Batches/year X 

substance) 

1 . Batch 

Maximum kg/batch (iooi new chemical Hours/batch Batches/year X 

substance) 

2 . Continuous 

d . Process description F-1 Mark (X) to indicate your willingness to have your process description binding . 

(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 . CONFIDENTIAL INFORMATION 

REMOVED 

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

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

Iq 
Premanufacture Notice Continuation Sheet 

Continued-From: 

Continuation Title: 

CONFIDENTIAL INFORMATION 

REMOVED 

p. 15 

Confidential 

X 

Page 15 of 25 
Premanufacture Notice Continuation Sheet 

Continued-From : Part 1, Section C3 

Continuation Title: Material Safety Data Sheet 

MATERIAL SAFETY DATA SHEET 

Version : 1 . 

Date : 

1217~ 2009 0 

1 . PRODUCT AND COMPANY IDENTIFICATION 

Experimental 20881-19 

Product Information: Experimental 20881-19 

Company Identification : 

Milliken Chemical 

P.O. Box 1926 

Spartanburg, SC, 29303 USA 

1-864-472-9041 

msds@milliken.com 

Emergency Telephone Number: 

Chemtrec : 

1-800-424-9300 (Chemtrec- US) 

1-703-527-3887 (International) 

2 HAZARDS IDENTIFICATION 

Emergency Overview 

HFRP Rating 

Health 3 

Flammability 2 

Reactivity 2 

Personal protection D 

?A 'W 

wnc+~enM I LLIKENW 

Eye Causes eye irritation . 

Inhalation May cause irritation to the respiratory system . 

Skin May be harmful if absorbed through skin . 

Ingestion May be harmful if swallowed 

Remarks For research and development purposes only. 

Material : 1286 1 of 5 

Page 16 of 25 
Premanufacture Notice Continuation Sheet 

Continued-From: Part 1, Section C3 

Continuation Title: Material Safety Data Sheet 

MATERIAL SAFETY DATA SHEET 

Version: 1 . 

Date : 

1217i2009 0 

3. COMPOSITION! INFORMATION ON INGREDIENTS 

Product name CAS Number Amount 

Proprietary Product Proprietary 100.0% 

4. FIRST AID MEASURES 

2" cm ive~e - 

Eye Flush thoroughly with water. If irritation occurs, get medical assistance . 

Inhalation Move the exposed person to fresh air at once . Get medical attention it 

symptoms persist. 

Skin Wash the skin immediately with soap and water. Get medical attention it 

irritation develops or persists . 

Ingestion If swallowed, rinse mouth with water (only if the person is conscious) . Do not 

induce vomiting . Get medical attention if symptoms occur. 

5. FIRE-FIGHTING MEASURES 

Flarnrnable Properties 

Flash Point > 110 'C 

Fire Fighting Media Extinguish with alcohol-resistant foam, carbon dioxide or dry powder . 

Fire Fighting Instructions Firefighters must use standard protective equipment including flame retardant 

coat, helmet with face shield, gloves, rubber boots, and in enclosed spaces, 

SCBA. 

Unusual Fire 8 Explosion Decomposition may produce fumes, smoke. oxides of carbon and 

Hazards hydrocarbons . 

6. ACCIDENTAL RELEASE MEASURES 

Safety AtJYlce Wear appropriate personal protective equipment. ELIMINATE all ignition 

sources (no smoking, flares . sparks or flames in immediate area). 

Material : 1286 2 of 5 

Page 17 of 25 
Premanufacture Notice Continuation Sheet 

Continued-From : Part 1, Section C3 

Continuation Title: Material Safety Data Sheet 

MATERIAL SAFETY DATA SHEET 

Version : 1 . 

Date : 

12.-'17!2009 

on~rwW 0 

a.o.ot, . .a 

Spill Cleanup Methods Prevent runoff from entering drains, sewers, or streams. Dam and absorb 

spillages with sand, earth or other non-combustible material . Ensure that . 

waste and contaminated materials are collected and removed from the work 

area as soon as possible in a suitably labeled container. All waste materials 

should be packaged, labeled and transported in accordance with all national, 

staterprovincial, and local requirements . 

7. HANDLING AND STORAGE 

Handling Wash promptly with soap and water if skin becomes contaminated . Provide 

adequate ventilation if fumes or vapors are generated. Avoid inhalation of 

vapors and spray mist and contact with skin and eyes . Eliminate all sources 

of ignition . Keep away from heat. sparks and open flame. 

Handling / Physical Hazards Do not store near heat sources or expose to high temperatures . 

Storage Precautions Store away from heat and light . Store in a cool, dry place with adequate 

ventilation. Keep away from incompatible materials, open flames, and high 

temperatures. 

8. EXPOSURE CONTROLS I PERSONAL PROTECTION 

Engineering Controls Provide adequate ventilation. Observe Occupational Exposure Limits and 

minimize the risk of inhalation of vapors . 

Eye protection Where contact with this material is likely, chemical goggles are 

recommended . 

Skin and Body Protection Wash promptly with soap and water if skin becomes contaminated . Wear 

protective gloves to minimize skin contamination . When prolonged or 

frequently repeated contact could occur, use protective clothing impervious to 

this material . 

Personal protection Always observe good personal hygiene measures . such as washing after 

handling the material and before eating, drinking, and'or smoking. Routinely 

wash work clothing and protective equipment to remove contaminants . 

Respiratory Protection If engineering controls do not maintain airborne concentrations below 

recommended exposure limits (where applicable) or to an acceptable level (in 

countries where exposure limits have not been established), an approved 

respirator must be worn . 

Material : 1286 3 of 5 

Page 18 of 25 
Premanufacture Notice Continuation Sheet 

Continued~From : Part I, Section C3 

Continuation Title: Material Safety Data Sheet 

MATERIAL SAFETY DATA SHEET 

Version : 1 . 

Date : 

1217'2009 0 

9. PHYSICAL AND CHEMICAL PROPERTIES 

Appearance Liquid 

Flash Point > 110 'G 

Density 1 .86 gcm3 

Melting/ Freezing Point < 0 "C 

10. STABILITY AND REACTIVITY 

Conditions to Avoid Keep away from heat, sparks and open flame. 

Hazardous Polymerization Polymerization may occur at elevated temperatures 

Hazardous decomposition Decomposition may produce fumes, smoke, oxides of carbon and 

products hydrocarbons . 

11 . TOXICOLOGICAL INFORMATION 

No data available. 

12 ECOLOGICAL INFORMATION 

No data available. 

13. DISPOSAL CONSIDERATIONS 

?A cm 

c,wcawwa~a 

Disposal Recommendations Dispose of waste at an appropriate treatment and disposal facility in 

accordance with applicable laws and regulations, and product characteristics 

at time of disposal . 

Material : 1286 4 of 5 

Page 19 of 25 
Premanufacture Notice Continuation Sheet 

Continued-From : Part I, Section C3 

Continuation Title : Material Safety Data Sheet 

MATERIAL SAFETY DATA SHEET 

Version : 1 . 

Date : 

12'17 2009 0 

14. TRANSPORT INFORMATION 

rrrwCM 

.NO ,. - 

Transport classifications may vary by container volume and may be influenced by regional or country variations in 

regulations. 

15. REGULATORY INFORMATION 

Regulatory Lists Searched Component 

Additional information is available by request. 

16. OTHER INFORMATION 

The information contained in this Material Safety Data Sheet is furnished without warranty . expressed or implied, 

except that it is accurate to the best knowledge of Milliken Chemical . 

Material : 1286 5 of 5 

Page 20 of 25 
Premanufacture Notice Continuation Sheet 

Continued From: 

Continuation Title: ECOSAR Model 

CONFIDENTIAL INFORMATION 

REMOVED 

p. 21 

Confidential 

X 

Page 21 of 25 
Premanufacture Notice Continuation Sheet 

Continued From: 

Continuation Title: ECOSAR Model 

CONFIDENTIAL INFORMATION 

REMOVED 

p. 22 

Confidential 

X 

Page 22 of 25 
p. 23 

Premanufacture Notice Continuation Sheet 

Continued-From: 

Continuation Title: EpiWin Model 

Confidential 

X 

CONFIDENTIAL INFORMATION 

REMOVED 

Page 23 of 25 
p. 24 

Premanufacture Notice Continuation Sheet 

Continu6d From: 

Continuation Title: EpiWin Model 

Confidential 

X 

CONFIDENTIAL INFORMATION 

REMOVED 

Page 24 of 25 
Premanufacture Notice Continuation Sheet 

Continued From: 

Continuation Title: PBT Profiler 

p. 25 

Confidential 

X 

Page 25 of 25