### U.S. ENVIRONMENTAL PROTECTIONAGENCY 

# EPA PREMANUFACTURE NOTICE 

# OPPT rBlC 

# 01 DEC -4 PH 3:05 FOR NEW CHEMICAL SUBSTANCES DOCUMENT CONTROL OFFICER OFFICE OFPOLLUTiv1-l PREVENTION AND TOXIC SUBSTANCES, 7407 U.S. E.P.A. 401 M STREET, SW W D.C. 

# Company Sanitized

You must provide all information requested in this form to the extent that it is known to orreasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. Before you completethis form, you should readthe "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from theToxic Substances Control Act (TSCA) Information Serviceby calling 202-554-1404, or faxing 202-554-5603). Ifa userfee has been remitted for this notice (40 CFR 700.45), indicate in theboxes abovethe TS-user fee identificationnumber you have generated. Remember, youruser 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, Attn. TSCA User fee.
Part I- GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name ofthe new chemical substance, even ifyou claimthe identity as confidential. You may authorize another person to submit chemical identity information for you, but your submission will not he complete and the review will not begin until EPA receives this information. A letter in support ofyour submission should reference your TS 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 he submitted.
Part II- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture, processing, or use operations to he described in Part II, sections A and Bofthis notice, reproduce the sections as needed.
Part III- LIST OFATTACHMENTS Attach additional sheets ifthere is notenough space to answer a question fully. Label 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 notice.

OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page II ofthis form, space has been provided for you to described pollution prevention andrecycling information you may have regarding the new substance. 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
... Tills option is intended to reduce delays that routinely accompany the development ofconsent orders or Significant New Use Rules. Except in the case ofexemption 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 a binding box in this notice does not by itselfprohibit the submitter from later 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 claim on the form, mark (X) the confidential box**n~**.., to the information that you cmim as confidential. To assert a claim in an attachment, circle or bracket the information you claim as confidential. Ifyou claiminformation in the notices as confidential you must also provide a sanitized version ofthe notice (including attachments). For additional instructions on claiming information as confidential, read the Instructions Manual. Mark (x) ifany information in this notice is claimed as confidential. TEST DATA AND OTHER DATA You are requiredto submit all test data in yourpossession or control andto provide a description ofall otherdata knownto orreasonably ascertainable by you, ifthese data are relatedto the health and environmental effects on the manufacture, processing, distribution in commerce, use, ordisposal ofthe new chemical substance. Standard literature citations maybe submitted for datain the open scientific literature. Complete test data (written in English). not summaries ofdata. mustbe submitted ifthey do not appearin the ooen literature. You should clearly identify whethertest datais on the substance oron an analog. Also, the chemical composition ofthe tested material shouldbe characterized. Following are examples oftest data and otherdata. Data shouldbe submitted according tothe requirements of §720.50 ofthe Premanufacture Notification Rule (40 CFR Part 720).

Test Data (Check Below any included in this notice) Environmental fate data 

### D Yes 

# . Other data 

### D Yes Health effects data 

### D Yes Risk assessments Environmental effects data 

### D Yes Structure/activityrelationships PhysicaUChemical Properties* 

### D Yes Test data not in the possession or control ofthe submitter Aphysical and chemical properties worksheet is located on the last page ofthis form. TYPE OFNOTICE (Check Only One) PMN (Premanufacture Notice) 

# [8J 

# D D D D 

# D 

# D INTERMEDIATE PMN (submitted in sequence with final pi'IJ{IuctPMN') '.

. \ SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LYE (Low Volume Exemption)@ 40 CFR 723.50(c)(l) ( ..] LOREX (Low Release/Low Exposure Exemption) @40 CFR

### n§~~c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? # ofchemicals 

# D D LOREX Modification Yes (Prenotice Communication#required, enter#on page 3) 

# 5"30

# 3.]

### Public reporting burden for this collection ofinformation is estimated to average 110 hours perresponse, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing andreviewing the collection of information. Send comments regarding the burden estimate or any other aspect ofthis collection ofinformation, 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 ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

# CERTIFICATION I certify that to the best ofmy knowledge and belief: 1. The company named in Part I, section A, subsection 1 a ofthis 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 ofthe date ofsubmission. 3. I am submitting with this notice all test data in my possession orcontrol and a description ofall other data known to or reasonably ascertainable by me as required by §720.50 ofthe Premanufacture Notification Rule.
Additional CertificationStatements: If

### you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, checkthe following userfee certification statement that applies:**~** 

### The Company named in PartI, Section A has remitted the fee of$2500 specified in 40 CFR 700.45(b), or 

# D The Company named in Part I, Section A has remitted the fee of$1000 for an Intermediate PMN (defined @ 

### 40CFR 700.43) in accordance with 40 CFR 700.45(b), or 

# D 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: 

# D 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 of40 CFR 723.50. 

# D The manufacturer is familiar with the terms ofthis section and will comply with those terms; and 

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

# D 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 ofthe date ofthe expiration ofthe 30 day review period. The accuracy ofthe statements you make in this notice should renectyour bestpredictionofthe anticipated facts regardingthe chemical substance described herei11. Any knowin2 and willful misinterpretationis subject to criminalpenalty pursuantto 18 USC 1001. Signature and title ofAuthorized Official (Original Signature Required) Date
Signature ofagent -(ifapplicable) Date

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

## XIa. Person Submitting Notice (in U.S.)

b. Agent (if applicable) Company Mailing address (number and street) City, State, ZIP Code
Name Company Mailing address (number and street) City, State, ZIP Code Telephone Area Code

c. Ifyou are submitting this notice as part ofajointsubmission, mark (X) this box.**----------------------~** Joint Submitter (if applicable) Name ofauthorized official

2.

4.

5.

6. Contact (in U.S.) Company
address (number and street) City, State,ZIPCode
Name of Company Mailing address (number and street) City, tate, ZIPCode

you a prenotice (PC) this notice and EPA assigned a PC Number to the notice, enter the number.
Ifyou submitted anexemption application for the chemical substance covered by this notice, enter the exemptionnumber assigned by EPA. Ifyou previously submitted a PMN for this substance enterthe PMN number assigned by EPA (i.e. withdrawn orincomplete).**~** Ifyou have submitted a Bona fide intent to manufacture or import for the chemical substance coveredby this notice, enter the notice number assigned by EPA. I.

Type ofNotice

- Mark (X) 

# D Manufacture Only Binding Option Mark

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

Telephone
Position

Telephone

2. 

# D

Page 3 Import Only Mark (X) ifnone Mark (X) ifnone Mark (X) ifnone
Binding Option Mark 3. Both Confidential 

## XSection B

--

Ifanotherperson will submit chemical identity information for you (for either Item 1or 2), mark (X) the box at the right. the and address ofthat in a continuation sheet. I. Class I or 2 chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class ofsubstance

- Mark (X) 

# D Class I or 2 

# D Class 2 b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name orCAPreferred 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 notice: (check one). 

# D Method I (CAS Inventory Expert Service- a copy ofthe Identification 

# D Method 2 (Other Source) report obtained from the CAS Inventory Expert Services must be 1--------.::.SU:::b::::nu=·tt.::e::::d:...:a::::s...::.a" attachment to this d. Molecular formula and CAS Registry Number (ifa number already exists for the substance)

CAS#

e. For a class I substance, provide a complete and correct structure diagram. For a class 2 substance

- (I)List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature ofthe reaction or process. (3) Indicate the range ofcomposition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical structure**dia~rram.** as comnlete as can he known. ifone can he reasonahlv ascertained.



#  This page intentionallyleftblank.** **

this box ifyou attach a continuation sheet.

EPA FORM 7710-25 (Rev. 5-95) Page4 Confidentiala. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymer you intend tomanufacture. Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500and below 1,000 absolute molecular weight ofthat composition. Describe the methods ofmeasurement or the basis for your estimates: GPC

# 0 Other 

# 0: (Specify) i) lowest number average molecular weight: ii) maximum weight % below 500 molecular weight: iii) maximum weight % below 1000 molecular weight: attach a continuation sheet. 

## X

You must make separate confidentiality claims for monomer orotherreactant identity, composition information, and information. Mark (X) the "Confidential" box next to any itemyou claim as confidential (I) Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeach monomer orotherreactant used in the manufacture of the polymer. (2) Mark (X) this column ifentryin column (I) is confidential. (3) Indicate the typical weightpercent ofeach monomer orotherreactant in the polymer. (4) Mark (X) the identity column ifyou want a monomer orotherreactant used at two weight percent orless tobe listed aspart ofthepolymer description on the TSCA Chemical Substance Inventory. (5) Mark (X) this column ifentries in columns (3) and (4) are confidential. (6) Indicate the maximum weight percent ofeach monomer orotherreactant that may be present as a residual in the polymer as manufactured for commercialpurposes. Mark · column if · confidential. Conti- Typical
% 

## X % 

## X 

## X % 

## X % % % %

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one). 

# 0 Method I (CAS Inventory Expert Service- a copy ofthe identification report 

# 0 Method 2 (other source) obtainedfrom CAS Inventory Expert Service mustbe submitted as as attachmenttothis d. The currently correct Chemical Abstracts (CA) name for the polymerthat is consistent with TSCA Inventory listings for similar polymers.

e. Provide a correctrepresentative orpartialchemical structure diagram, as complete as can be known, ifone can bereasonably ascertained.

attach a continutation sheet.

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

## X % 

## X % % % %

# Part I -- 

# GENERAL INFORMATION -- Continued Section B -- 

## c rFMI 'A.**U~N** L\TION

-- 3. Impurities (a)


### - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercialpurpose. Provide the CAS Registry Number ifavailable. Ifthere are unidentified impurities, enter "unidentified." (b)


### - Estimate the maximum weight % ofeachimpurity. [fthere are unidentified 

### ;lllpu,;u.:o>, estimate their total weight %. Impurity and CAS Registry Number Maximum Contipercent dential (a) (b) % 

## X
%
%
%
%
%
% 

# [ 

# ] Mark (X) this box ifyou attach a .sheet. 4. Synonyms

- Enter any chemical synonyms for the new chemical identified in subsection I or2. Contidential



## X 

# D Mark (X) this box ifyou attach a continuation sheet. 5. Trade identification

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

## X 

# D Mark (X) this box ifyou attach a continuation sheet. 

### 6. Generic chemicalname - Ifyou claimchemical identify as confidential, you mustprovide a generic name for your substance that reveals the specific chemical identityofthe new chemical substance to the maximumextent possible. Refertothe TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

## Polyalkyleneamine


# D Mark (X) this box if _2'(lll_attach a continuation sheet. 7. Byproducts

- Describe any byproducts resulting from the mannfa,tnrP processing, use, ordisposal ofthe new chemical substance. Provide the CAS Registry Number ifavailable. 

### uyp(O'U'-1 CAS Registry Number Conti- (2) dential 

# X



# l J Mark (X) this box ifyou attach a**;,.,n~et.**

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

# PartI

-- GENERAL INFORMATION

-- Continued Section C --PRODUCTION, IMPORT, AND USE INFORMATION: Mark (X) the "Confidential" box next to any item you claim as confidential. 

### 1. Productionvolume·· Estimate the maximumproduction volume during the first 12 months ofproduction. Also estimate the maximum production volume for any consecutive 12-monthperiod during the first three years ofproduction. Estimates shouldbe on 100% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lowerproduction volume than 10,000 kg/yr, specify the volume and mark (x) in the binding box. Ifgranted, you are bound to this volume Maximumfirst 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 ofthe category ofuse, the percent ofproduction volume devoted to each category, the formulation of the new substance, and otheruse information. Mark (X) 

### the "Confidential" Box next to any item you claim as confidential. a. (I)

-- Describe each intended category ofuse ofthe new chemical substance by function and application
.. (2)

-- Mark (X) 

### this column ifentry column (I) is confidential business information (CBI). (3)

-- 

### Indicate your willingness to have the information provided in column (I)binding. (4)

-- Estimate the percent oftotal production for the first three years devoted to each category ofuse. (5)

-- 

### Mark (X) 

### this column ifentry in column (4) is confidential business information (CBI). (6)

-- Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, orgels as manufactured for commercial purposes at sites under your control associated with each category ofuse. (7)

-- 

### Mark (X) 

### this column ifentry in column (6) is confidential business information (CBI). (8)

-- Indicate % ofproduct volume expected for the listed "use" sectors. Mark more than onebox ifappropriate. Mark (X) 

### to indicate your willingness to have the use type 

### provided in (8) binding. (9) -- 

### Mark (X) 

### this column ifentrv(ies) in column (8) is (are) confidential business information (CBI). Category ofuse (I) 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 polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercia! Option (9) 

## X X X X X % % 

## X X X X X % % % % % % % % % % % % 

## * Ifyou 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 ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumerproduct. 0Mark (X) this box ifyou attach a continuation sheet. 

### b. Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat category. Read the 

### use Instructions Manual for examples ofgeneric use descriptions. 

### description 

### Emulsifier


# 0 Mark (X) this box ifyou attach a continuation sheet. 3. HazardInformation·· Include in the notice a copy ofreasonable facsimile ofany 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 ofthe new substance. List in part III hazard information you include. Mark (x) 

# C8J Mark (X) this box ifyou attach hazard information.

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

# Part 11-- 

# 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 ofmanufacture, processing, oruse operation involving the new chemical substance at industrial sites you control. Importers do nothave to complete this section for operations outside the U.S.; however, you may still have reporting requirements if there are further industrial after · You must describe these See instructions manual l.

Site address (number and street) City, County, State, ZIPcode 

### If

### the same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates oroperations. include all the information requested in this section for those sites as attachments.

b.

I. Batch

2. Continuous substance) Maximum kg/batch (100% new chemical Hours/batch substance) 

### Use Batches/year
Batches/year 

### Confidential



# X

X 

# X

d. Process description Mark (X) to indicate your willingness to have your process description binding. (I) Diagramthe major unit operation steps andchemicalconversions. 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 substancebasis), 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 orperbatch.). (3) Identify by numberthe points ofrelease, including small orintermittentreleases, to the environment ofthe new chemical substance.

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

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

# Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE-- Continued Section A

-- INDUSTRIAL SITES CONTROLLEDBY THESUBMITTER

-- Continued 2. OccupationalExposure-- You must make separate confidentiality claims for the description ofworker activity, physical form ofthe new chemical substance, number ofworks exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any item you claim as confidential. (I)-- 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 (I) is confidentialbusiness information (CBI). (3) --Describe any protective eauipment 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) --Indicatethe physical form(s) ofthe new chemical substance (e.g., solid: crystal, granule, powder, or dust) and% new chemical substance (ifpart ofa mixture) at the time ofexposure. (7) --Mark (X) this column ifentry in column (5) is confidential business information (CBI). (8) --Estimatethe maximum number ofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI). (10) and (II)-- Estimate the maximum duration ofthe activity for any worker in hours per day and days per year. (12)

-- Mark (X) this column ifentries in columns (I0) and (II) are confidential business information (CBI). Worker activity CBI Protective Equipment! Binding Physical forms(s) Binding CBI #of CBI Maximu duration CBI m (i.e., bag dumping, filling drums) Engineering Controls Option and %new Option Worker Hrs/day Days/yr Mark (•) substance Mark (x) s (1) (2) (3) (4) (5) (6) (7) Expose (9) (10) (11) (12) d (8) 

## X X X X X X X X



# D 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 otherrelease and rusposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (I) --Enterthe number ofeachrelease point identified in the process description, part II, section A, subsection ld(3). (2) --Estimate the amount ofthe new substance released (a) directly to the environmentor (b) into control technology (in kg/day or kg/batch). (3) --Mark (X) this column ifentries in columns (I) and (2) are confidentialbusiness information (CBI). (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land orincineration, POTW, or other (specify)) to which the new substance will bereleased from that release point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. For releases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA 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 ifentries in columns (4) and (5) are confidentialbusiness information (CBI). (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for directdischarges or NPDES numbers ofthe POTW (Publici OwnedTreatmentWorks). Mark (X) ifthe POTW name or NPDES #is confidentialbusiness information (CBI). Release Amount ofnew substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Number released release

(I) (2a) (2b) e.g stack ru.r Binding (3) (4) (Sa) Mark(X) (5b) (6) 

### 1 

## X X 2 

## X X 3 

## X X

(7) Mark (X) the 

# D POTW provide name(s) below: CBI 

# D Navigable 

# D Other

- Specify provide NPDES # CBI 1--- destination(s) of waterway releases to water. 

# D Mark (X) this box ifyou attach a continuation sheet.
EPA FORM 7710-25 (Rev. 5-95) Page 9

# Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE-- Continued Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B for typical processing oruse 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 mustreport any processing oruse activities after import. See the Instructions Manual. Complete a separate section B for each type of processing, oruse operation involving the new chemicalsubstance. Ifthe 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 orbracket the specific information that you claim as confidential. (I)-- Diagramthe 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 orkg/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 ifnot used daily orperbatch). (3)

-- Identify by number the points ofrelease, including small orintermittentreleases, to the environment ofthe new chemical substance. ( 4) Please enterthe#ofsites (remember to identify the locations of these sites on a continuation sheet): [#ofsites 

# l

...._ 

# ' 7

/


# - - D Mark (X) this box ifyou attach a continuation sheet. 

### 2. Worker Exposure/Environmental Release (I)-- From the diagramabove, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) --Estimatethe number ofworkers exposed for all sites combined. (4) --Estimate the typical duration ofexposure per worker in (a) hours per day and (b) days per year. (6) --Describephysical form ofexposure and% new chemical substance (ifin mixture), and any protective equipmentand engineering controls, ifany, usedto protect workers. (7)

-- Estimate the percent ofthe new substance as formulated when packaged orused as a final product. (9) --Fromthe process diagram above, enterthe 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 ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land orincineration, POTW, or other (specify) and control teclnnJlogy, ifany, that will be used to limit the release ofthe 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 ifanv ofthe proceeding entries are confidential business information (CBI). Letter #of CBI Duration CBI Protective Equip./ %in CBI Release Amount of CBI Media ofRelease CBI

of Workers of Engineering Controls/ Form- Number New & Control Act- Exposed Exposure Physical Form and % ulation Substance Technology ivity new substance Released (I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (II) (12) (13)

14)

-- Byproducts: (15) 

# D Mark (X) this box ifyou attach a continuation sheet,

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

# OPTIONAL POLLUTIONPREVENTION 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 orminimize potential ri"ks associated witr activities surrounding manufacturing, processing, use and disposal ofthe PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and saferprocesses orproducts available due to the new chemical substance. Source reduction includes the reduction in the amount ortoxicity ofchemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the reclamation ofuseful chemical components from wastes that would otherwise be treated orreleased as air emissions or water discharges, orland disposal. Descriptions ofpollution prevention, source reduction and recycling shouldemphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be eitherquantitative orqualitative. The EPA is interested in the information to assess overall net reductions in toxicity orenvironmental releases and exposures, not the shifting ofrisks to otherenvironmental media ornon-environmental areas (e.g., occupational orconsumerexposure). In addition, information on the relative cost orperformance characteristics ofthe PMN substance to potential alternatives may be provided. 

## All information provided in this section will be taken into consideration during the review ofthis 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 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 poses a greater overall risk to human health or the environment.



# J } Mark (X) this box ifyou attach a continuation sheet.

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

### Page 11

# Part III-- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe 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 ofthe form to which it relates, ifappropriate. 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 claim any information in an attachment as confidential. You must include with the sanitized copy ofthe notice form a sanitized version ofany attachment in which you claiminformation as confidential. Attachment name Attachment Contioage number(s) dential 

### 14-19 

## MaterialSafetv DataSheet <MSDS) 2. General Comments 20 

## X 3. Inventory Expert Servir1s Report 21 

## X 4. Manufacturing Location 23 

## X 5. Gel Permeation Chromatography 24-29 

## X 6. UV Spectrum 30-32 

## X 7. Infrared Spectrum 33-35 

## X 8. NMR Analyses 36-39 

## X 9. Confidentiality Statement 40-49 

## X



# D Mark (X) this box ifyou attach a continuation sheet. Enter the attachmentname and number.

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

### PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET Toassist EPA's review ofphysical 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 ofthe 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 subst 1ce shouldbe provided. T.:ese 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 submitthis worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should submitthis worksheet as a supplement to your submission oftest data. This worksheet is not a substitute for submission oftestdata. Property Mark Page Value**~easured** o Contidential (X) if (a) provided 

### Physical state ofneat substance Vapor pressure @Temperature 

# oc Density/relative density Solubility @ Temperature 

# oc

Solvent Solubility in water @Temperature 25 

# oc Melting temperature Boiling I 

### sublimation temperature@ torr pressure Spectra X 

### Dissociation constant Particle size distribution Octanol I 

### water partition coefficient Hemy'sLaw constant Volitalization from water Volitalization from soil pH@ concentration Flammability Explodability Adsorption I 

### coeffic
..;nt Other

- Specify number (b) (c) 

### (s) X (I) (g)


### Torr 0.9 g/cm3

g/l 

### Insoluble giL 

# oc oc 30-39 UV, IR and NMR spectra Estimate Mark (X) (MorE) (d)



### M

E

E

M X



### ATTACHMENT PAr.!= 1-:l

## Material Safety Data Sheet [ 

# J Page 1

# of6

Material Safety Data Sheet 

# [ J

1 ChemicalProductand Company Identification 

# [ 1

This material is to be used for research purposes only under the supervision ofa technically qualified individual. The toxicological properties may have notbeen completely characterized. Todetermine your responsibilities under the Toxic Substances Control Act (TSCA), please see the**R~ulatory** 

### Information Section. ProductTradeName [ 

# j CAS Number Confidential. Synonyms Confidential. Generic ChemicalName ProductType Preparation!Revisio:._Date TransportationEmergency Phone No. Polyolefin amide Not applicable. 06 Nc.1ember 2001 (CHEMTREC) 1-800-424-9300. MSDSNo. 5001530-6922047-9385074


## 2 Composition/Information onIngredients HazardousIngredients This material has no known hazards under applicable laws. !HazardsIdentification PrincipalHazards • Thismaterialhas no known hazards. See Section 11for complete health hazard information. 

# I FirstAid Measures Oral DO NOT INDUCE VOMITING. If

### conscious, give 2 glasses ofwater. Get immediate medical attention. Eyes Skin Inhalation AdditionalInformation Flush with water at least 15 minutes. Get medical attention ifeye irritation develops or persists. Wash with soap and water. Get medical attention ifirritation develops. Launder contaminated clothingbeforereuse. Remove exposedperson to fresh air ifadverse effects are observed. Note to physician: Treat symptomatically. 

# Is I Fire FightingMeasures


## http://msds/1941/1941.asp

# I~ 11121101

## Material Safety Data Sheet

# -L 

# J Page 2 of6

FlashPoint ExtinguishingMedia Firefighting Procedures Unusual Fire & 

## Explosion Hazards
SpillProcedures

Loading Temperature Maximum Handling Temperature Handling Procedures Maximum Storage Temperature StorageProcedures 8 

## Ventilation Procedures Gloves Procedures Eye Protection Respiratory Protection Clothing Recommendation

FlashPoint UpperFlammableLimit Lower FlammableLimit Autoignition Point Explosion Data Vapor Pressure pH Specific Gravity WaterSolubility PercentVolatile PercentVOC Vapor Density Evaporation Rate Odor 

## > 100Deg C, 212 DegF PMCC (Minimum) C02, dry chemical, orfoam. Water can be used to cool and protectexposed material. Recommend wearing self-contained breathing apparatus. Watermay cause splattering. Material will float on water. Toxic fumes, gases or vapors may evolve onburning.


## !AccidentalRelease Measures Personal ProtectiveEquipment must be worn, seePersonal Protection Sectionfor PPE recommendations. Ventilate area ifspilled in confined space or otherpoorly ventilated areas. Prevententry into sewers and waterways. Pick up free liquid for recycle and/or disposal. Residual liquid can be absorbed on inert material. Check under Transportation and Labeling (DOT/CERCLA) and OtherRegulatory Information Section (SARA) for hazardous substances to determineregulatory reporting requirements for spills. 

# I Handling a;;d Storage Not determined. Not determined. Keep containers closed when not in use. Wash thoroughly after handling. Empty container contains productresidue which may exhibithazards ofproduct. Not determined. No special storage precautions required. 

## Exposure Controls/PersonalProtection Use with adequate ventilation. Use nitrile or neoprene gloves. Safety Glasses. Under normal use conditions, respirator is not usually required. Long sleeve shirt is recommended. 

# I Physical and ChemicalProperties
> 100Deg C, 212 DegF PMCC (Minimum) Not determined. Not determined. Not determined. Material does not have explosive properties. Not determined. Not determined. 0.85 (15.6 Deg C) 

### Insoluble. Unknown. Not determined. Not determined. Not determined. Aromatic hydrocarbon 

## http://msds/1941/1941.asp 

# ·IS 11/21101

## Material Safety Data Sheet

-

# L J Page 3 of6
Viscosity OdorThreshold Boiling Point PourPointTemperature FreezingPoint MolecularWeight Octanol!WaterPartition Coefficient 

# lw Stability Unknown. Unknown. Not determined. Not determined. Not determined. Not determined. Not determined.


## The above data aretypical values anddo notconstitutea specification. 

# I Stability and Reactivity Material is normally stable at moderately elevated temperatures and pressures. DecompositionTemperature Not determined. Incompatibility None known, avoid contact with reactive chemicals. Polymerization Will not occur. ThermalDecomposition Smoke, carbon monoxide, carbon dioxide, aldehydes and otherproducts ofincomplete combustion. Under combustion conditions, oxides ofthe following elements will be formed: nitrogen. 

# In I Toxicological Information

OralToxicity Eye Irritation SkinIrritation DermalToxicity InhalationToxicity Respiratory Irritation DermalSensitization Inhalation Sensitization

ChronicToxicity Carcinogenicity Mutagenicity Reproductive Toxicitv Teratogenicity



## http://msds/1941/1941.asp -- ACUTEEXPOSURE-- The LD50 in rats is between 2000 mg/kg and 5000 mg/kg. Based on data from similar materials. Insufficient data oncomponents and similarmaterials to determine potential for eye irritation. Insufficient data oncomponents and similar materials to determine potential for skin irritation. The LD50 in rabbits is 

## > 2000 mg/Kg. Based on other data ordata on similarmaterials. No data available to indicate product or components may be a toxic inhalation hazard. No data available to indicate product orcomponents may causerespiratory irritation under normal workplace conditions and good industrial hygiene practices. No data available to indicate product orcomponents may be a skin sensitizer. No data available to indicate product orcomponents may berespiratory sensitizers.

-- CHRONIC EXPOSURE-- No data available to indicate product orcomponents present at greater than 1% are chronic health hazards. No data available to indicate any components present at greater than 0.1% maypresent a carcinogenic hazard. No data available to indicate product or any components present at greater than 0.1% are mutagenic or genotoxic. No data available to indicate eitherproduct or components present at greater than 0.1% that may cause reproductive toxicity. No data available to indicate product or any components contained at greater than 0.1% may cause birth defects.



## 11/21/01

## Material Safety Data Sheet

# L 

# J Page 4 of6

Other ExposureLimits

Freshwater FishToxicity FreshwaterInvertebrates Toxicity Algal Inhibition SaltwaterFishToxicity SaltwaterInvertebrr**~es** 

### Toxicity BacteriaToxicity Miscellaneous Toxicity

Biodegradation Bioaccumulation Soil Mobility

WasteDisposal

ICAO/IATA IMDG (Ambient) IMDG (Elevated) IMDGEMS IMDGMFAG IMOMarine Bulk USCG Compatibility U.S. DOT Bulk (Ambient) U.S. DOT Bulk (Elevated) U.S. DOT Non-Bulk DOTNAERG TDG Bulk (Ambient) TDGBulk (Elevated) TDG Non-Bulk Mexico ADRIRID (Ambient) ADRIRID (Elevated) ADG (Ambient) --ADDITIONALINFORMATION-- No otherhealth hazards known. See Hazardous Ingredients Section for any applicable exposure limits for components. 

# I EcologicalInformation --ENVIRONMENTAL TOXICITY-- Not determined. Not determined. Not determined. Not determined. Not determi::ed. Not determined. Not determined. --ENVIRONMENTAL FATE-- Not determined. Not determined. Not determined. 

# I Disposal Consideration This material, ifdiscarded, is not a hazardous waste under RCRA Regulation 40 CFR 261. 

# I TransportInformation Not regulated. Not regulated. Not determined. Not applicable. Not applicable. Not determined. Not determined. Not regulated. Not determined. Not regulated. Not applicable. Notregulated. Not determined. Not regulated. Not regulated. Not regulated. Not determined. Not regulated. 

## http://msds/1941/1941.asp 

# 1'1 11/21/01

## Material Safety Data Sheet -[ 

# J Page 5 of6

ADG (Elevated) Not determined. 

# I Regulatory Information U.S. TSCA Inventory Requires notification in the U.S. Commercial shipments from[ Ju.S. location must be exported :o non U.S. customers only. Research and development quantities must bear special labels and shipping papers. Samplerecipients must comply with the requirements for an R&D exemption under TSCA. None known. OtherTSCA Reg. SARA ExL Haz. Subst. This product does not contain greater than 1.0% ofany chemical substance on the SARA Extremely Hazardous Substances list. SARA Section 313 This product does not contain greater than 1.0% (greater than 0.1% for carcinogenic substance) ofany chemical substances listed under SARA Section 313. TDG Regulated Limits CERLA Hazardous Substances None known. None known. Cal. Prop. 65 This product does not intentionally contain any chemicals known by the State ofCalifornia to cause cancer and/or birth defects. Moreover,[ }oesnotroutinely analyze its U.S. FuelRegistration U.S. DeptofAgriculture products for impurities which may be such chemicals. Not applicable. This product has not been filed with the USDA to support H2 approvals. U.S. TariffHeadingNumber Not determined. Schedule BNumber Not determined. FDA Approval Not applicable. EEC EINECS May require notification under EC Seventh Amendment Directive 92/32/EEC. FinnishRegistration Number Sweden Registration Number Norway Registration Number NotRegistered Not Registered Not Registered Danish Registration Number Not Registered Switzerland BagT Not Registered RegistrationNumber JapanMETI May require notification in Japan. Australia Canada Switzerland Korea Korean Registration Number Philippines May require notification before sale under Australian regulations. May require notification before sale under Canadian regulations. May require notification before sale in Switzerland. May require notification before sale in Korea. NotRegistered May require notification before sale under Philippines Republic Act 6969. China This product may require notification in China. ChinaRegistration Number Not Registered New Zealand Registration Not Registered Number MaltaRegistration Limber Not Registe
..!d Ukraine Registration Not Registered Number 

# I otherInformation 

## http:/ /msds/1941/1941.asp 11/21/01

## Material Safety Data Sheet -[ 

# J

US NFPA Codes

HMIS Codes

Precautionary Labels Revision Indicators Health Fire Reactivity Special 1 1 0 

### N/E



### Health Fire Reactivity 0



### • Thismaterialhas no known hazards. Section: 1GENERIC/CHEMICAL NAME Changed: 06 November 2001 Section: 1PRODUCT TRADE NAME Changed: 06 November 2001 

## Page 6 of6

The information

# prese~edherein has been ckpiledfromsources cojideredto be dependable andis 

### accurate to the bestofr· nowledge; however,
. makes no warranty whatsoever, expressedorimplie;/-of MERCHANTABILIT**O~ITNESS** 

### FOR EP4jlTICULARPURPOSE, regarding the accuracy of such data 

### orthe results to be obtained from use thereof**J~ssumes** 

### no responsibilityfor injury to recipient orto thirdpersons or for any damage to anyproperty a recipientassumes allsuch risks.



## http://msds/194111941.asp 

# 1'1 11/21101

# Attachment 2 General Comments

# ern InventoryExpert 

# Service

A division ofthe American Chemical Society Phone: 800-631-1884, 614-447-3870



## INVENTORY EXPERT SERVICE REPORT Fax: 614-447-3747 E-mail: answers@cas.org Internet: http://www.cas.org/Supportlclient.html



## IES-ORDER NUMBER:

# ~ REGISTRY

# NUMBER:~ 

# 1]

CA INDEX NAME 

# [

Please print the above CA Index Name on the appropriate page of your PMN. 

# 0 If this box is checked, CAS has made correction(s} marked in red to your IES order. Please make the same correction(s} to your PMN before submitting it to the EPA.

2540 Olentangy River Road P.O. Box 3343/ • 

# _, Columbus. Ohio 43210-0334

## ATTACHMENT 4 

# Manufacturing Location

## ATTACHMENT 5 

# Gel Permeation Chromatography

## ATTACHMENT 6 UV Spectrum

## ATTACHMENT 7 

# Infrared Spectrum

# ATTACHMENT 8 NMR Analyses

## ATTACHMENT 9 

# Confidentiality Statement