r1ritil 

# P-b(o-7aa

August 4, 2006 

## CONFIDENTIAL AS MARKED [ ] Overnight Mail Document Control Officer Office of Toxic Substances, TS-793 Document Processing Center U .S. Environmental Protection Agency EPA East Building 1201 Constitution Avenue Washington, DC20004-3302 

## Dear Sir/Madam

: Enclosed is one Premanufacture Notices (PMNs) for your review . The PMNis provided in two (2) forms: 

## 1 . Three originals with confidential portions so marked, and 2. Asanitized version for the public files. The PMN fee of $2,500.00 was sent to the HQAccounting Operations Board for these PMNidentified by the number [ ] . If you need any more information, please contact me. Sincerely,

-

, .j

C .".7

### SANITIZED n-2



### U.S . ENVIRONMENTAL PROTECTIONAGENCY 

# '~~ .FPA PREMANUFACTURE NOTICE r~

"' ""~ 'u"" "-- " F.S. i1rnthe Premanufacture Notice' I ~ 

### GENERAL INSTRUCTIONS 

# C Form Approved._ O

.M .B. No. 2070-0012. Approval Date of receipt

Jil Expires 10-31-96.

You must provide all information requested in this form to theextent that it is known to or reasonably ascertainable by you . Make reasonable estimates ifyou do not have actual data. Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available fromthe 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 (40CFR 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, HQAccounting Operations Branch (PM-226), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee. Part 1-GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name ofthe new chemical substance, even if you claimthe identity as confidential . You may authorize another person to submit chemical identity information for you, but your submission will not be complete and the review will not begin until EPAreceives this information. A letter in support of your submission should reference yourTS user fee identification number. You must submit an original and two copies ofthis notice including all test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part Il-HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part 11, sections Aand Bof this notice, reproduce the sections as needed. Part III-LIST OF ATTACHMENTS Attach additional sheets if there is not enough space to answer a question fully. Label each continuation sheetwith the corresponding section heading. In Part III, list these attachments, any test data or otherdata and any optional information included in the notice. OPTIONAL INFORMATION You may include any information that you want EPAto consider in evaluating the new substance. On page I I of this form, space has been provided for you to described pollution prevention and recycling information you may have regarding the new substance. So-called "binding" boxes are included throughout this form foryou 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 that routinely accompany the development ofconsent orders or Significant New Use Rules. Except in the case of exemption applications (such as TMEA, LVE, LOREX) where certain information provided in such notification is binding on the submitter when the Agency approves the exemption application, checking abindingbox in this notice does not by itself prohibit the submitter fromlater deviating from the information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claim as confidential . To assert a claimin an attachment, circle or bracket the information you claimas confidential . Ifyou claiminformation in the notices as confidential You must also provide a sanitized version of the notice. (including attachments) . For additional instructions on claiming information as confidential, read the Instructions Manual . ® Mark (x) if any information in this notice is claimed as confidential . TEST DATA AND OTHER DATA You are required to submit all test data in your possession or control and to provide a description ofall otherdata known to or reasonably ascertainable by you, if these data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, or disposal of the new chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English), not summaries ofdata. must be submitted if they do not aooear in the oven literature. You should clearly 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 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 720) . Test Data (Check Below any included in this notice) " Environmental fate data ~ Yes " Other data 0 Yes " Health effects data ~ Yes Risk assessments " Environmental effects data C] Yes Structure/activity relationships " Physical/Chemical Properties' ® Yes Test data not in the possession or control of the submitter ' Aphysical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One) ® 

# a a

0 

# a AGENCY USE ONLY

n t r--n 

# Company Sanitized

PMN(Premanufacture Notice) INTERMEDIATE PMN(submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (LowVolume Exemption) @ 40 CFR723.50(c)(1) LOREX (Low

Release/Low

Exposure Exemption) @ 40 CFR723.50(c)(2) LVE Modification IS THIS ACONSOLIDATED PMN? # of chemicals 

# 0

a LOREXModification Yes (Prenotice Communication # required, enter # on page 3) EPAFORM

7710-25 (Rev. 5-95) Replaces previous editions of EPA Form7710-25.

### 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 ofthis 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 ReductionAct (2070-0012), Washington, D .C . 20503. 

## ' CERTIFICATION I certify that to the best of my knowledge and belief: 1 . The company named in Part 1, section A, subsection 1a of this notice formintends to manufactureor 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 ofthe 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$2500specified in 40 CFR 700 .45(b), or 0 The Company named in Part I, Section Ahas remitted the fee of $1000for an Intermediate PMN (defined @ 40 CFR 

### 700.43) in accordance with 40 CFR 700.45(b), or 0 The Company named in Part I Section A is a small business concern under 40 CFR700.43 and has remitted a fee of $100 in accordance with 40 CFR 700.45(b) . Ifyou 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: 

### F~ 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. F-j The manufacturer is familiar with the terms of this section and will comply with those terms; and 

### 0 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 ofthe exempted substance for commercial purposes within 1 year of the date of the expiration ofthe 30 day 

### reviewperiod. 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 knowing and willful misinter pretation is subject to criminal penal ty pursuant to IS USC1001 . Confidential Signature and title ofAuthorized Official (Original Signature Required) Date 

# X Signature of agent - (if applicable) Date

EPA FORM

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

### p. 4 Part I -- GENERAL INFORMATION Section A- SUBMITTERIDENTI FICATION l a. Person Name ofauthorized official Position Submitting Notice (in U.S.) 

# X

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. Ifyou are submitting this notice as part of ajoint 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 X U.S.) Company

Mailing address (number and street) City, State, ZIP Code Telephone ; AreaCode ; Number 3. Ifyou 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. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enterthe exemption number assigned by Mark (X) -It ® EPA . If you previously submitted a PMNfor this substance enter the if none PMN number assigned by EPA(i .e. withdrawn or incomplete)-------- - 5. Ifyou have submitted 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. -~ if none 6. Type of Notice - Mark (X) Mark the "Confidential" box next to an subsection ou claimas confidential

I . ® 

# a Manufacture Only Binding Option Mark (X) 

# a Import Only Binding Option Mark (X) ~ 3. i 0 Both Confidential

EPA FORM

7710-25 (Rev. 5-95) Page 3

### p. 5 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 9C of CA nomenclature rules and conventions. Mark (X the "Confidential" box next to any itemyou claimas confidential Complete either item I (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 ItemI or 2), mark (X) the box at the right . ConfiIdenti the name, com

p any, and address ofthat p erson 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 ofsubstance - Mark (X) 1 ~ Class 1 or 2 0 Class 2 

# X b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistentwith TSCA Inventory listings for similar substances. 

# X 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 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 ofthe Identification ~ Method 2 (Other Source) report obtained fromthe 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 ofthe 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 diaeram . as cnmnlete as can he known. if one can he reaaonahlv ascertained. I

II I

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

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

### p. 6 Part I -- GENERAL INFORMATION - Continued Section B-- CHEMICAL IDENTITY INFORMATION - Continued 2. Polymers (For a definition ofpolymer, see the Instructions Manual .) Confidential a. Indicate the number-average weight ofthe 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) below500 and below1,000 absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC F] Other [J : (Specify) i) lowest number average molecular weight : ii) maximumweight % below500 molecular weight : iii) maximumweight % below 1000 molecular weight : Mark (X) this box ifyou 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 itemyou claimas confidential (1) - Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeach monomer or other reactant used in the manufacture of

the polymer . (2) - Mark (X) this column ifentry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. (4) - Mark (X) the identity column ifyou want a monomer or other reactant used at two weight percent or less to be listed as part ofthe polymer

description on the TSCAChemical Substance Inventory. (5) - Mark (X) this column if entries in columns (3) and (4) are confidential . (6) - Indicate the maximumweight 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 ent ry in column (6 is confidential . Monomer or other reactant and CAS Registry Number (1) Confidential (2) Typical composition (3) Identity

Mark (X) (4 Confidential (5) Maximum

residual (6) Confidential (7)

0'0 % 0 0 Mark (X) this box ifyou 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) .

on Method I (CAS Inventory Expert Service - a copy ofthe identification report Method 2 (other source)

! obtained fromCAS 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. ained. e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, ifone can be reasonably ascert

Mark (X) this box ifyou attach a continutation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 5

## 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 ifavailable. If there are unidentified impurities, enter "unidentified." (b) - Estimate the maximumwei ght % of each im

puri ty. Ifthere are unidentified im purities, estimate their total wei ght % . Impurity and CAS Registry Number

a Maximum percent (b) Confidential 

# X X % 

# X

% 

# X

% 

# X

%

% Mark (X) this box ifyou attach a continuation sheet . 4. Synonyms - Enter any chemical synonyms for the newchemical identified in subsection I or 2. Confidential

Mark (X) this box ifyou attach a continuation sheet. 5 . Trade identification - List trade names for the newchemical substance identified in subsection 1 or 2 .

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

# X

6. Generic chemical name - If you claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the newchemical substance to the maximum extent possible. Refer to the TSCAChemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names. Substituted aliphatic amine

Mark (X) this box ifyou attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number ifavailable. Byproduct (1 CAS Registry Number (2 Confidential

_ 

# X

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

7710-25 (Rev. 5-95) Page 6

### p. 8 

## Part I -- GENERAL INFORMATION -- Continued Section C-- PRODUCTION, IMPORT, AND USE INFORMATION:

Mark (X) the "Confidential" box next to an itemyou claimas confidential . 1 . Production volume - Estimate the maximum production volume during thefirst 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during thefirst three years ofproduction. Estimates should be on 100%new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10,000 k r, sp

eci fy the volume and mark (x in the binding box. Ifgranted, y ou are bound to this volume Maximum

first 12-month production (kg/yr) _ Maximum12-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 ofthe category of use, the percent ofproduction 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 claimas confidential . a . (1) -- Describe each intended category of use of the new chemical substance by function andapplication. . (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 ifappropriate. 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 % ofsubstance 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 pol yester fibers) (2 (3) (4 (5 (6) (7 Limited sumer trial mercial O 

## ption (9 

## X X X X

% % o/ . o/n o~ o~ o/ 14 . % a/ . % % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consumer products. In addition include estimates of the concentration of the newchemical 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 ifyou attach a continuation sheet . b. Generic Ifyou claimany category of use description in subsection 2a as confidential, enter a generic description ofthat category. Read the use Instructions Manual for examples of generic use descriptions. description Destructive Use

El Mark (X) this box ifyou 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 Mark (x) for the safe handing, transport, use, or disposal ofthe newsubstance. List in part III hazard information you include. ® Mark (X) this box if you attach hazard information. EPA FORM

7710-25 (Rev. 5-95) Page 7

### p. 9 

## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section Afor each type ofmanufacture, 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 maystill have reporting requirements if there are further industrial processingor use op erations after im

port. You must describe these op erations. See instructions manual 1 . Operation description Confi

### a . Identi ty - Enter the identi ty ofthe site at which the o peration will occur. dential Name 

# X Site address (number and street) City, County, State, ZIP code 

### Ifthe same operation will occur at more than onesite, enter the number ofsites. Identify the ' additional sites on a continuation sheet, and ifany 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 ifyou attach a continuation sheet . 

### b. Type -- Mark (X) DManufacturing aProcessing ~Use c. Amount and Duration -- Com plete 1 or 2 as approp

riate Maximum

kg/batch (loo°i new

chemical 1 Hours/batch 1 Batches/year substance) ~

i 1 . Batch ' '

Maximum

kg/batch (loo^i newchemical ~ Hours/batch ; Batches/year

substance) i i 2. Continuous d. Process description 11 Mark (X) to indicate your willingness to have your process description binding. (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage 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%newchemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment ofthe new chemical substance.

Mark (X) this box ifyou attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 8

### p. 10



## 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 ofworker activity, physical formofthe new chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou claimas 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 ifentry 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) ofthe newchemical substance (e.g., solid: crystal, granule, powder, or dust) and %newchemical substance (if part of a mixture) at the time of exposure. (7) -- Mark (X) this column ifentry in column (5) is confidential business infortnation (CBI) . (8) -- Estimate the maximumnumber of workers involved in each activity for all sites combined. (9) -- Mark (X) this column ifentry in column (8) is confidential business information (CBI) . (10) and (11) -- Estimate the maximumduration ofthe activity for any worker in hours per day and days per year . (12) -- Mark (X this column ifentries in columns (10 and (11) are confidential business inforrnation 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 Mark and % new Option Workers Hrs/day Dayslyr (X) substance Mark (x) Exposed (1 (2) (3 (4) (5) (6) (7) (8 (9) (I0) (II)



## X X X X X X X X X X X X

~ Mark (X) this box ifyou attach a continuation sheet . 3 . Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) -- Enter the number ofeach release point identified in the process description, part II, section A, subsection 1d(3) . (2) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . I (3) --Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBn. , (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 fromthat release point . (5) -- a. Describe control technology, ifany, and control efficiency that will be used to limit the release of the newsubstance to the environment. For releases ' disposed ofon 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) ofreleases to water . Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or ' NPDES numbers ofthe POTWPublicl Owned Treatment Works) . Mark X if the POTW name or NPDES # is confidential business information (CB0. Release Amount of newsubstance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) Number released release (1) (2a) (2b) e.s.stackeir ~ Binding (3) (4) (Sa) ~ Mark (X) (Sb) (6

! I 

### ; X 

## ; X ! ' (7) Mark (X) the El POTW provide name(s) below

: CBI Navigable Other - Specify provide NPDES # CBI destination(s) of X waterway X I releases to water. Mark (X) this box ifyou attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 9

### p. 11



## 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 Bfor each type ofprocessing, or use operation involving the new chemicalsubstance. If the same operation is performed at more than one site describe the typical operation common to these sites. Identi fy additional sites on a continuation sheet. -- - I . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagram

the major unit operation steps and chemical conversions, including interimstorage 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 ofall 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 ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enter the # of sites (remember to identify the locations of these sites on a continuation sheet) : # ofsites

a Mark (X) this box ifyou attach a continuation sheet . 2. Worker Exposure/Environmental Release (1) --Fromthe diagramabove, 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 formofexposure and % newchemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect workers. (7) -- Estimate the percent ofthe new substance as formulated when packaged or used as a final product . (9) -- From

the process diagramabove, enter the number ofeach release point. Complete 9-13 for each release point identified. (10) -- Estimate the amount ofthe 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, ifany, that will be used to limit the release of the newsubstance to the environment. (14) -- Identify byproducts which may result fromthe operation. (3), (5) , (8

) , (11 ), (13 and (15) -- Mark ( this column ifan 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/ Formulation Number New Substance & Control Technology Act- Exposed Exposure Physical Formand % Released 'v'ty new substance (1) (2) (3) (4a) ~ (4b) (5) 6 

### _ (7) (8) (9) (l0a) ~ (1ob) (Il) (12) (13)



### X ~ X X ~ ' 

### X X X ~ X X ~ ' 

### X X X ~ X X ~ ' X X X ~ X X ~ X X

---- X T

I 

### X X ' (14) -- Byproducts: (15)



### _X_ Mark (X) this box ifyou attach a continuation sheet, EPA FORM

7710-25 (Rev. 5-95) Page 10

### p. 12



# OPTIONAL POLLUTION PREVENTION INFORMATION To claim information in this section as confidential circle or bracket the specific information that you claimas confidential . 

## In this section you may provide information not reported elsewhere in this formregarding 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 exam ples. 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 ofwaste 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 ofproduction and/or improved operation efficiency ofthe 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 p

oses a eater overall risk to human health or the environment .

[:] Mark (X) this box ifyou attach a continuation sheet . EPAFORM

7710-25 (Rev. 5-95) Page i l

### p. 13 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand 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 ofthe formto which it relates, if appropriate. Number consecutively the pages ofthe attachments. In the column below, enter the inclusive page numbers ofeach attachment . Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice forma sanitized version of any attachment in which you claiminformation as confidential . Attachment name

0-Mark (X) this box ifyou attach a continuation sheet. Enter the attachment name and number. Attachment page number(s) Confidential 

### X X X X X X

EPA FORM

7710-25 (Rev. 5-95) Page 12

### p. 14 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 ofthe 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 ofthe 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 (%PMNsubstance in _J . 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 oftest data. This worksheet is not a substitute for submission oftest data. Property (a) Mark (X) if provided Page

number (b) Value (c) M easured o Estimate or E Confidentiai Mark(x) (d) 

### Physical state ofneat substance s~ (1) _W X Vapor pressure Tem p erature °C Torr Densi ty/relative densi ty cc 

### Solubility @ Temperature °C Solvent Solubili ty in water Tem p erature °C X 

### Melting tem

perature oc Boiling / sublimation temerature torr p ressure °C X 

### Spectra X Dissociation constant Particle size distribution 

### Octanol / water partition coefficient Henry's Law

constant Volatilization fromwater Volatilization fromsoil H concentration Flammabili ty Ex lodabili Adsorption / coefficient Other - Sp

ecify



### ATTACHMENT PAGE 13

### KATERZAL SA!'ETT DATA SWMT RBSEhRCH AND DMMOP ("` . 1 L Emergency Pnoneg : Sample identification : SI?-10 S1=10K I Physical and Chemical Properties - Compiled by : ~=- 

### Molecul .a.r Weiqht : 33$ .6 Density (g/rp-Tj) Not established Mi-'t Point Not am>~cgble . Boiling Point : >35C/95F Vapor Pressure : Not established Flashpoint : >=93C Sta'b: 1 r.y : Stable incompatibility: None establisb?,d nazdrdous Decomposition Products : None establi_shed . _ r' : :y szcal DLsct: iption : Clear liauidLamine_qdor - - ,~r~t :~c~e in :>tructions : 

### SECTI¢,K II Toxicity - Review bY ; -, Ef facts

_ of Qge_reM2sure : The hazards of this material have not been thoroughly investigated . Based on analogy it is expected to cause irritation to the eyes, skin and respiratory tract . May be harmful if ingested . 11xercise ordinary care while handling . 

### Emergency/First Aid Procedures : INHALATION: Remove to fresh air . If not breathing, give artificial respiration, prefer-ably mouth-to-mouth . If breathing is difficult, give oxygen . Get raedical attention. EYE CONTACT: hcued.iately flush with plenty of water for at least IS minutes . Got medical attention.

EPA FORM

7710-25 (Rev. 5-95) Page 14

# -2-

SKIN CONTACT : Immediately flush skin with plenty of water for at least 15 M4Zrates wbile removing contaminated clothing and shoes . Get medical attention. INGESTIONT Do not induce vomiting . Get medical attention. 

## SECTION 11 '_J?sposal/ .';~pi11 Procedures : Ventilate area . Contain any spills with dikes or absorbents to prevent migration and entry into sewers or strealoo . Take up small spills w-Ith dry chemical absorbent . Large spills may be taken up With pump or vacuum and finished off with dry Chemical absorbent . E3'tsder the CERCLA/RCRA regulations currently in effect, this material is not regulated as a hazardous waste or material . Therefore, it nay he disposed of in a facility in compliance with EP3l and/or other applicable local, state, and federal regulations . It should be handled in a manner acceptable to good waste managemmmt practice . p0 MDT RELEASE TO WATER. Rinse containers with organic before disposal or recycle . SECTION_ ,IV 

### Industrial Hygiene - Reviewed byThreshold Limit V&lues Not established- -- far Ventilation : At source of vaoors . , _thi $ itla .rE?t'1 .ai . 

### Mechanical Ventilation : _ Recorttrnendcd . ____ Personal Protective Equipment : EYE PROTECTION: Chem ical aocQ1r,-q PROTECTIVE GLOVES : 

### or safety glasses . Resistant to chemical Rer.etrs? on . 

### RESPIRATORY PROTECTIQNr Full faceoiece OTHERt if skin contact ~ or c nLami .na on oro ctive clothing should be-- worn . Regulatory Reviewed by : 

# 7 ~, . 1 i ke3 .v ,_-

IT IS INTENDED FOR RESEARCH AND DEVRLOPMNi' ( R&D ) PURPOSES ONLY! information Reviewed by : . ,r... Date Issued : 01/a4/2006 

### NTOSH approver, respi Xa to y of clothing

EPA FORM

7710-25 (Rev. 5-95) Page 15p. 17

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pleaao $riat tha above CA Itedlex :um on ra4o Iwtppz+opriato page of your P3Hsf .

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. alaaps make the s=w corraatioa(s) to your PW before sa2oLitting it to tLo EPA.

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7710-25 (Rev. 5-95) Page 16EPAFORM 7710-25 (Rev. 5-95) Page 17

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EPA FORM

7710-25 (Rev. 5-95) Page 18EPA FORM

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