5111VI 1 l Z-E

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Form Approved. O.M.B. No. 2070-0072. Approval

U. S. ENVIRONMENTAL PROTECTION AGENCY A-GENCY UgE.

PS`iElNykl VCi~~~~TURE

Date of receto 71

EPA NOTIC ''~~E~

FOR NEW CHEMICAI_. SUBSTANCES

Company Sanitized

Ei.

in the Preulanufac'ture Notice ~ ~~ ~ ~ .► ~

GENERAL FNSTTUME3NS L `Lk) F3 +

• You must provide all information requested in this form to the extent that it is known to or neasonably ascertainable by you . Make reasonable estimates if you do not have actual data.

• Before you complete this fo rm, you should read the "Instructions Manual for Premanufacture Notificati on" (the instructions Manual is available from the Toxic

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or taxing 202-554-5603)

user fee has been remitted for this notice . • If a (40 C.~'E 700.45), indicate in the boxes above the TS-user fee identifi cation numbervou have generated . Remembec, your user fee ID number must also appear on your corresponding fee remittance, which is sent to : EPA, HQ Accounting OperationsBranch (PM-266),

P.O. 360399Ma, Pittsburgh, PA 15251-63%, Attn . TSCA User Fee.

Part :

- GENERAL INFORMATION TEST DATA AND OTHER DATA

You must provide the currently coned Chemical } Abstracts (CA) Name of the You are re quired to submit all test data in yonrpossession or contro l

new chemical substance, even if you claim the identity as confidential . You may and to provide a description of all other data known to or neasonabiy

autho rize another person to submit chemical identity information for you, but ascertainable by you, if these data are related to the health and

your submission will not be complete and the review will not begin until EPA environmental effects of the manufacture, processing, distribution

re ceives this information_ A letterin support of your submission should in commerce, use, or disposal of the new chemical substance Standard

referen ce your TS user fee identi fi cati on number. You must submit an original literature citations may be submitted for data in the open scientifi c

and two copies of this notice inctuding all test data . If you claimed any literatute. C mpiete test data (written in .nglishl, not summaries of d~ = ini:ormation as confidential, a single sanitized copymust also be submitted . must be submitted if they do not ~ea_r in the oven literatu re. You should

clearly identify whether test data is on the substance or on an analog . Also,

Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE the chemical composition of the tested material should be characterized .

Following are examples of test data and other data. Data should b e

If there are several manufacture, processing, or use operati ons to be described in submitted according to the requirements of §720.50 of the Premanufadure Part 11, sections A and B of this notice, rep roduce the sections as needed . Notifi cation Rule (40 CFR Part 720).

Part III - LIST OF ATTACHMENTS Test Data (Check below any included in this noti ce)

Attach additi onal sheets if there is not enough space to answer a auestion fuliy.

Label each continuation sheet with the corresponding section heading. In Part Enviro nmental fate data ~ Yes • Other data Yes

III, list these attachments, any test data or other data and any optional

information included in the notice. • Health effects data L Yes Risk assessments

OPTIONAL INFORMATION • Environmental effects data f ¢ Yes SiruQure/acfivityreiafionshiios

You may include any information that you want EPA to consider in evaluating • Physical/Chemical P ro perties L11 Yes Test data not in the possessidn the new substance . On page 11 ofthis form, space has been provided for you to orcontrol of the submitter describe pollution prevention and rxcycling information you may have regarding

the new substance 'A physical and chemical pro perties worksheet is located on.V last page

of this form.

So-called "binding" boxes are included throughout this form foryou to indicate

your willingness to be bound to ce rtain statements you make in this notice, suc TYPE OF NOTICE (Check Only One) C'_' L~ h

as use, production volume, protective equipment . . . This option is intended to C-) °'- ~rq

reduce delays that routineiy accompany the development of consent orders or

Significant New Use Ruies. Except in the case of exemption applications (suc.

X PMN (Premanufadure Notice) O

: as

TMEA, LVE, LOREX) where certain information provided in such notification is a -

binding an the submitter wh en. the Agency approves the exemption application, INT ERIvEDIATE PMN (submitted in seauence witR'thtal "01C

checking a binding box in this notice Qotg nnt, by itself p ro hibit the submitter PMN) (TI

from later deviating from the information iexcept chemical

the form . SNUN (Significant New Use Notice)

identity) reported in fV «~

•

TASE .4 (Test Marketine Exemption Application)

CONFIf7ENTIALT"iYC:..AIMS

, LVE (Low Volume Exemption) 6 40 C'FR 72'. .50 (c)(1)

You may claim any information in this notice as confidential. To assert a claim P"Z on the form, mark (X) the confidential box next to the information that you Calm ~- : LOREX flaw Reiease/Low Exposure Exemption) 0 723.50(c)L?)

as confidential . To asse rta claim in an attachment, circle or bracket the

information you claim as confidential. If you claim information in the notice as ~ L~ M~tiic~tioa iOREX Modification Lonfiden{iat . vou must ?)an provide a~_itiaed ver:ion of thr nnti . (in i•~d ;n4

For additional instructions on claiming information as

confidential, read the instructions Manuai. IS THIS A CONSOLIDATED PMN7 77 Y~

Mark (X) if any information in this notice is claimed as confidential . 6 of chemical

s (Prenotice Communication # required, enter & on page 3 )

EPA FORM 7710-25 (Rev

. 5-95) Replaces previous editions of EPA Form 77IL2. 5 n_a i

/ 9
p. 2

Public reporting burden for this collection of information is estimated to average 1 10 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 l, Section B .

2 . All information provided in this notice is complete and truthful as of the date of submission .

3 . 1 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:

❑X The company named in Part 1, Section A has remitted the fee of $2500 specified in 40 CFR 700 .45(b), or

0 The company named in Part l, 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), o r

E The company named in Part 1, 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 40CFR 723 .50(c)(2), check the following

certification statement.

El The manufacturer submitting this notice intends to manufacture or import the new chemical substance for

commercial purposes, other than in small quantity solely for research and development, under the terms

of 40 CFR 723 .50 .

F-1 The manufacturer is familiar with the terms of this section and will comply with those tenns ; an d

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

F-~ 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. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001 .

Confidential

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

X

Signature of agent - (if applicable) Date

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

Part I -- GENERAL INFORMATION

Section A -- SUBMITTER IDENTIFICATION ConfiMark (X) the "Confidential" box next to any subsection you claim as confidential . dential

I a . Person Name of authorized official Position

Submitting President X

Notice Company

(in U .S .)

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 Area Code Number

Telephone

c . If you are submitting this notice as part of a joint submission, mark (X) this box. -------------->

Joint Name of authorized official Position

Submitter

(if applicable) Company

Mailing Address (number and street)

City, State, ZIP Code Area Code Number

Telephone

2 . Technical Name of authorized official Positio

Contact X

n

(in U .S.) Company

Mailing Address (number and street )

City, State, ZIP Code Area Code Number

Telephone

3 . If you have had a prenotice communication(PC) concerning this notic e

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

if non e

4 . If you previously submitted an exemption application for the chemica l

substance covered by this notice, enter the exemption number assigned Mark (X) ---->

7X

by EPA . if you previously submitted a PMN for this substance enter if none

the PMN number assigned by EPA (i .e .withdrawn or incomplete) ---->

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 Mark (X) ---->

notice number assigned by EPA . ----> if none

6 . Type of Notice - Mark (X) 1. Manufacture Only 2. FX Import Only 3. F] Both

FI Binding Option Binding Option

Mark (X) Mark (X)

FORM EPA 7710-25 (Rev . 5-95) Page 3
p. 4

Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITY INFORMATIQ'ou must provide a currently correct Chemical Abstracts(CA) names of the substance

based on the ninth Collective Index(9CI) of CA nomenclature rules and conventions .

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

Complete either item 1(Class 1 or 2 substances) or 2(Pol,ymers) as appropriate . Complete all other items.

If another person will submit chemical identity information for you (for either I or 2), mark (X) the box at the right. ConfiIdentify the name, company, and 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 Instruction Manual )

a . Class of substance -- Mark (X) 1 [_X1 Class 1 or 2 F_~ Class 2

b. Chemical name (Currently correct Chemical Abstracts(CA) Name that is consistent with TSCA Inventory listings for simila r

substances. For Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA X

Preferred Name must be provided, whichever 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).

X Method I (CAS Inventory Expert Service - a copy of the Identification E7 Method 2 (Other Source)

report obtained fron the CAS Inventory Expert Service must b e

submitt ed 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 immediat e

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

the range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partia l

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

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

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

Part I -- GENERAL INFORMA .TI O?4T - Continued

~► Section B- Oi^.

.MICAL IDENrI'= LNFORMATION - Continued

2 Polymers (-r or a definition of poiymer, see the instructions ManuaL) Contidential

a. Indicate the number-avera ge weight of the lowest molecular weight coatmsihon of the polymer you intend to manufacture- ,

Indd®te m:rimvat wei z tt percent of low molecular weight speoes (not mciuatng reszcua; monomers, reactants, or soivents) below

5D0 and below 1,D00 absolute molecular weight of that composition

Describe the methods of ineasnrement or the basis fo r your estimates: GPG ❑ :xi,c❑ :(Spedfy)

i) )owut tttsmbe' average awi• c+,1 a* wciFftt

ti) max=rsm weuz}tt % beiow 50o molecular we Lght

lLt7 ma=um waYitt 4. ixiow 1QDG moiecuiar weight

❑ Mark ()4 this box if vou attach a continuation shee t.

b. Youmust ataice separate o7ttacentiality clasms for monomer or other reaaant idennry , comvc efitvort uiiormation, and resiaual

Mark (X) the "Confidential" box next to any iteae you claim as mnfidentiaL

(1) - Provide the specific cneatiral name and CAS Registry Number (if a number exr.st9) of each monomer or other reactant used in the

atarnwaure of the floivmer .

(73 - Mark DO this miumn if entry in column t1) is wnfidentiaL

(3) - Indicate the tyaiaE wogttt peraatt of each monomer or other reactant in the voiva =.

(4) - Mark tJb the identity miuma if vou want a monomer or othc aacnnt used at two weight percent or less to be listed as mn of the

polymerdescription cc the TSCA Chemical Substance Invenm:v .

(5) - Mark 00 this column if entries in columns (3) and (4) are confidenba L

(6) - Indicate the maximum weight percatt of each monomer or other rracta$t that maybe presmt as a residual in th epolymer as

mannfa mtred for rnntaterdal purooee,.

C7) - Mark 00 this column if entry in column (6) is confidential

Monomer or other reactant and CAS Registry Number Confi- i ypicai Identity Const- Ma~affi Confiden tial composition Mark M dential nemduai dential

(1) ~ (2) C3) (4) I5) (6) (7)

% I

I 4

e g° ~n

% I ( I ~

` ❑ Mark kXi this box if you attach a mntinuation sheet.

c Pleas= idartift widc'r, method vtu used to develop or obtain the spedned ateau cal ioentity information reported in this nonce- (cie e= one). Method 1(iA5 Inventory Expert Service - a coy of the identification report = Method 2 (otile- sotuce )

obtained aam CAS inventory Expert Service must be submitted as

an attachment to the notice)

d. The currently tsztea Chemical A'tntratc ts (CA) name for the polvme* that is consistent with TSZA inventory listsut p for smvia' poiymn

e . Provide a®rc=represgttanve or partial eheaticai structure aiagta lr,, as compiete as c2m be known, i one can ve rezsonabiy ascm- a ;*+ ~.

{

I II

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

:OFlt- ~"~. 771 G~ fke . ~4~ ra~te: ~ •-
p. 6

Part I -- GENERAL INFORMATION -- Continued

Section B - CHEMICAL IDENTITY INFORMATION --Continued

3 . Impuritie s

(a)-- Identify each impu rity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial

purposes. Provide the AS Registry Number if available . If there are unidentified impurities, enter "unidentified" .

( b)-- estimate the maximum weight % of each impu rity . If there are unidentified impurities, estimate their total weight % .

Impurity and CAS Registrv Number Maximum Confi-

(a) Percent dential

(b)

Unidentified 3

Mark this box if you attach a continuation sheet.

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

~ Mark this box if you attach a continuation sheet.

5 . Trade identifi cation -- List trade names for the new chemical substance identified in subsection I or 2 .

X

Mark this box if you att ach a continuation sheet.

6 . Generic Chemical Name - If you claim chemical identity as confidential, you must provide a generi c chemical name for your

substance that reveals the specifi c chemical identity of the new chemical subst an ce to the maximu m

extent possible . Refer to the TSCA Chemical Substance Invento ry , 1985 Edition, Appendix B for guidance

on developing generic names.

Alkylamide derivative

=

Mark this box if you a ttach a continuation sheet.

7 . Byproducts - Desc ri be any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance .

Provide the CAS Registry Number if available .

Byproducts CAS Registry Number Confi-

(1) (2) dential

None

Mark this box if you a ttach a continuation sheet.

FORM EPA 7710-25 (Rev . 5-95) Page 6
p. 7

Part I -- GENERAL INFORMATION -- Continued

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

Mark (X) the "Confidential" box next to any subsection 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 . Estimate 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 granted, you are bound to this volume . Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confi- Binding

(100% New chemical substance basis) (100° 0' New chemical substance basis) dential

I

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 in 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 (I) CBI Binding Produc- CBI °/o in CBI % of substance expected per use CBI

(by function and application i .e . a dispersive dye Option tion °o Formfor finishing polyester fibers) Mark (x) ulation Site- Con-* Indus- Com- Bindin g

(2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9)

X X

*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

.

F-] 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

use category. Read the Instructions Manuals for examples of gene ri c use descriptions.

description

Raw material for manufacturing of photosensitive material

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

3 . Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, Binding

material safety datasheet, or other information which will be provided to any person who is reasonably likely to be exposed to Option

to this substance regarding protective equipment or practices for the safe handling, transport, use . or disposal of the new Mark(X)

substance. List in part III hazard information you include .

~ Mark(X) this box if you attach a continuation sheet . MSDS Pages 17 and 18

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

Part II -- HUMAN EXPOSURE AND ENVIRONMENTAL RELEAS E

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER

Mark ( X) the "Con fidential" box next to any subsection you claim as confidential .

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at

industri al site you control . Import ers do not have to complete this section for operations outside the US ; however, you

may still have reporting requirements if there are furt her industrial processing for use operations after impo rt. You must

desc ri be these operations. See instructions manual .

1 . Operation desc

a . Identity --

ri

ption ConfiName

Enter the identitv of the site at which the operation will occur . dential

X

Site Address (number and street)

City, County, State, ZIP Code

If the same operation will occur at more than one site, enter the number of sites, Identify the # of sites

additional sites on a continuation sheet, and if any of the sites have significantly differen t

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

sites as att achment .

1:1 Mark(X) this box if you att ach a continuation sheet .

b . TypeMark(X) ElManufacturing Processing Use X

c . Amount and Duration -- Complete a or 2 as appropriat e

Maximum kg/batch Hours/batch Batches/year

(100% new chemical substance )

1 . Batch X

Maximum kg/day Hours/day Days/year

(100% new chemical substance)

2 . Continuous

d . Process desc ription F~ Mark(X) to

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

indicate your willingness to have your process description binding

. Include interim storage and transpo rt container

. X

s

(specify -- e .g . 5 gallon pails, 55 gallon drum, rail car, tank truck, etc . I.

(2) Provide the identity, the app ropriate weight ( by kg/day or kg/batch )on an 100 1/6 new substance basis), and entry point of all starting

materials and feedstocks ( including reactant, solvents, and 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 intermi ttent releases, to the environment of the new chemical substances) .

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

FORM EPA 7710-25 ( Rev . 5-95) Page 8
p. 9

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

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBNHTTER -- Continued

2 . Occupational exposure -

- You must make separate confidentiality claims for the description of worker activity, physical form of the new

chemical substance, number of worker exposed, and duration of activity . Mark(x) the "Confidential" box next to any item you claim confidential .

(1)-- Descri be the activities ( e .g . bag dutnping, tote filling, unloading drums, sampling, cleaning, etc .) in which workers may be exposed to the

substance .

(2)-- Mark ( X) this column if entrv 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 activitv 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 entry in column ( 10) and ( 11) are confidential business information (CBI).

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

(e .g . bag dumping, filling drums) Engineering Cont ro ls Option ( e .g .solid:powder) Option Workers Duration

Mark(x) and °b new Mark(x) Exposed Hrs/day Days/yr

(1) (2) (3) (4)

X X X X

substance (5) (6) (7) (8) (9) (10) (11) (12)

X X X X

X X X X

X X X X

~ Mark(X) this box ifyou a ttach 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 desc ri ption, part 11, section A, subsection ld(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 of release i .e . stack air, fugitive air(optional-see Instruction Manual), surface water, on-site or off-site land or incineration,

POTW, or other ( please specify) to which the new substance will be released from that release point .

(5)-- a. Desc ri be 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 entri es 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

dischargers or NPDES numbers of the POTW(Publicly 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 with to optionall y attach efficiency data) CBI

Number released Release Bindin

g

(1) (2a) (2b) e.g . stack air Removal Mark(X)

kg/day kg/dav (

X X

3) (4) (5a) Efficiencv (5b) (6)

x

" X

X X

.

X

r--,

(7) Mark(X) the `n' POTW provide name(s) below CBI F7 Navigable =Other-Specify pro vide NPDES # CBI

destination of waterway

release to

Marx(X) this box if you

water. X

attach a continuation sheet.

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

Part II - HLTMAN E XPOSURE AND ENVIRONMENTAL RELEASE - Continued

Section B - INDUSTRIAL SITES CO'_NTTROLLED 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{or 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 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 transporn 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 a 100% new chemical substance basis) and entry point of all feedstocks (including reactants, solvents, and 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 ofrelease,

including small or intermittent releases, to the environment of the new chemical substance . (4). Please enter the number 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/'~trnvironmental 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 oio new chemical substance (if in mixture), and any protective equipment and engineering controls 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 Le. stack air, fugitive air (optional - see instructions M an uai). surface water, on-site or on-siie land or iucrnerauon, Pv I`Jr', or oth~

(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 any of the preceding entries are confidential business information (CBI i .

Letter of ~ of CBI Duration of CBI Protective Equip .! oro in CBI Release Amount of New CBI Control Technology CBI

Activity Workers Exposure Engineering Controls/ Form- Number Substance Release d

Exposed Physical Form and oio uiation

new substanc e

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l 0a) (10b) (11) (12) ~(13)

I I ~ I

I ~ I

(14) - Byproducts (15)

D

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

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

OPTIONAL POLLUTION PREVENTION INFORMATIO N

To claim information in this section as confidential circle or bracket the specific information that you claim as 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 of 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

this information to assess overall net reductions in toxicit~, of 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 the revised Instruc tions Manual that includes a Pollution Prevention 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 of human exposure and/or environmental release ; (5) an increase in product performance, a decease in the cost of production and/or

improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in similar applications ; 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. ~

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

FORM EPA 7710-25 (Ret>. 5 .95) Page 11
p. 12

Part III -- LIST OF ATTACHMENTS

Attach continuation sheets for selections 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 approp ri ate. Number consecutively the pages of the a ttachments. In the columns below . enter the inclusive page

numbers of each attachments.

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instruction Manual for

guidance on how to claim any information in an a ttachment 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 confi dential.

Attachment ConfiAttachment name page number(s) dential

Material SafetyData Sheet (MSDS) 17 & 18 X

HPLC 14 X

CA Index Name Verification 13 X

NMR Data 15 X

IR Data 16 X

Acute Oral Toxicity Study 19-45 X

Ames Test 57-60 X

Skin Prima Irritation Study 46-56 X

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

Page 12
p. 13

~~~~~~~N77 IAL

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