## GENERAL INSTRUCTIONS TS- 121 bJ kJ ILI Ed Lei

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

• Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603).

• If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to: EPA, HQ Accounting Operations Branch (PM-266), P.O. 360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User Fee.
Pa rt - GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even if you claim the 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 EPA receives this information. A letter in support of your submission should reference your TS user fee identification number. You must submit an original and two copies of this notice including all test data. If you claimed any information as confidential, a single sanitized copy must also be submitted. Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part II, sections A and B of this notice, reproduce the sections as needed.
Part HI - LIST OF ATTACHMENTS Attach additional sheets if there is not enough 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 TEST DATA AND OTHER DATA You are required to submit all test data in your possession or control and to provide a description of all other data known to or reasonably ascertainable by you, if these data are related to the health and environmental effects of 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 of data, must be submitted if they do not appear in the open 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 of test 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 0 Yes • Other data LI Yes

• Health effects data 

## ID Yes Risk assessments

• Environmental effects data 0 Yes Structure/activity relationships

• Physical/Chemical Properties* El Yes Test data not in the possession You may include any information that you want EPA to consider in evaluating the new substance. On page 11 of this form, space has been provided for you to describe pollution prevention and recycling 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 notice, such as use, production volume, protective equipment...This option is intended to reduce delays that routinely accompany the development of consent orders or Significant New Use Rules. Except in the case of exemption applications (such as TMEA, LW, 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 itself prohibit the submitter from later deviating from the information (except chemical identity) reported in the form. CONFIDENTIALITY CLAIMS You may claim any information in this notice as confidential. To assert a claim on the form, mark (X) the confidential box next to the information that you claim as confidential. To assert a claim in an attachment, circle or bracket the information you claim as confidential. If you claim information in the notice 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. 

# E Mark (x) if any information in this notice is claimed as confidential. or control of the submitter

• A physical and chemical properties worksheet is located on the last page of this form.

TYPE OF NOTICE (Check only one) 

## El PMN (Premanufacture Notice) El INTERMEDIATE PMN (Submitted in sequence with final product PMN) 

## El SNUN (Significant New Use Notice) 

## El TMEA (Test Marketing Exemption Application) 

## CI LW (Low Volume Exemption) @40 CFR 723.50 (c)(1) 

## LI LOREX (Low Release/Low Exposure Exemption) @ 723.50(c)(2) 0 LW Modification 

## 0 LOREX Modifications

IS THIS A CONSOLIDATED PMN? 

# D Yes # of chemicals (Prenotice Communication # required, enter # on page 3) When completed send this form to Enter the total number of pages in the Premanufacture 

### Notice 30 

# irote p A 

# II

- WASHINGTON. DC 20460 

### U.S. ENVIRONMENTAL PROTECTION AGENCY 

## PREMANUFACTURE

1VT/YrieL' 

# IIIIIIIIIIIIIIIIIIIII 11

5 1 1 0 0 0 0 0 0 5 8 /, 

# II Date of receipt


# Company Saniuzeci

I I AGENCY USE ONLY

OM I EP" tr8 

## p. 1

Form Approved. 0.M.B. No. 2070-0012 Approval Expires 10-31-96

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

- 25

### p. 2

Public reporting burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St, S.W., Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D. C. 20503. 

## CERTIFICATION

I 

### certify that to the best of my knowledge and belief: 1. The company named in Part I, section A, subsection la of this purpose, other than in small quantities solely for research and Part I, Section B. 2. All information provided in this notice is complete and truthful 3. I am submitting with this notice all test data in my possession or reasonably ascertainable by me as 

### required by §720.50 of

Additional Certification 

### Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, statement that applies: Paid with credit card — on Pay.gov 

### The Company named in Part I, Section A has remitted the fee notice form intends to manufacture or import development, the substance identified in

as of the date of submission. or control and a description of all other data known the Premanufacture Notification Rule.



### or SNUN, check the following user fee certification (see cover letter for tracking numbers) 

### of $2500 specified in 40 CFR 700.45 (b), or of $1000 for an Intermediate PMN (defined @

under 40 CFR 700.43 and has remitted
in accordance with 40 CFR 723.50 (c) (1) or a with 40 CFR 723.50 (c) (2), check the or import the new chemical substance for research and development, under the terms
will comply with those terms; and meets all applicable exemption conditions. (c)(1), the manufacturer intends to commence year of the date of the expiration of the

of the anticipated facts regarding the chemical criminal penalty pursuant to 18 USC 1001. 

### for a commercial

to

40 CFR 700.43) in



### Low following

manufacture ' The Company named in Part I, Section A has remitted the fee accordance with 40 CFR 700.45 (b), or The Company named in Part I, Section A is a small business concern a fee of $100 in accordance with 40 CFR 700.45 (b). If you are submitting a low volume exemption (LVE) application release and low exposure exemption (LoREX) application in accordance certification statements: The manufacturer submitting this notice intends to manufacture commercial purposes, other than in small quantities solely for of 40 CFR 723.50. 

# fl The manufacturer is familiar with the terms of this section and The new chemical substance for which the notice is submitted 

# fl If this application is for an LVE in accordance with 40 CFR 723.50 of the exempted substance for commercial purposes within 1 30 day review period.

The accuracy of the statements you make in this notice should reflect your best prediction substance described herein. Any knowing and willful misrepresentation is subject to Confidential Signature and title of Authorized Official (Original Signature Required) 

## [ 1 Date 

## November 11, 2009 X
Signature of agent - (if applicable) Date

EPA Form 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

1 a.

b.

c. Name of authorized official Person Submitting [ ] Position 

### Chemical Regulatory Consultant X
Notice Company (in U.S.)

..

[ Mailing Address (number and street) [ ] City, State, Zip Code [ Position Agent (if Name of authorized official applicable) Company

Mailing Address (number and street) City, State, Zip Code Telephone ' Area Code ' Number I I

, I I If you are submitting this notice as part of a joint submission, mark (X) this box. I , Joint Name of authorized official submitter (if applicable) Position

Company Mailing Address (number and street) City, State, Zip Code Telephone 1 Area Code 1 Number ! I

1 2. Technical Name contact (in U.S.) [ 

### 1 Position 

### Chemical Regulatory Consultant X

Company [ ] Mailing Address (number and street) [ ] City, State, Zip Code [ ] Telephone 1 Area Code

. Number l I
3. If you have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number. . X Mark (X) if none 4. If you previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA. If you previously submitted a PMN for this substance enter the PMN number assigned by EPA (i.e. withdrawn or incomplete). Mark (X) 

# • X if none

5. If you have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number assigned by EPA. 

# • X Mark (X) if none
6. Type of Notice—(X) 1.■ Manufacture I 2. I I 1 ' Import I

Only I Binding Opion 1 Mark (x) 1

. 1 

# I I Both Only Binding Opion Mark (x)
Form EPA 7710-25 (Rev. 5-95) Page 

### 3

### p. 4


## Part I - GENERAL 

## INFORMATION — Continued You must provide a currently correct Chemical Abstracts (CA) name of the substance Section B

— CHEMICAL IDENTITY INFORMATION: based on the ninth Collective Index (9CI) of CA nomenclature rules and conventions. Mark (X) the "Confidential" box next to any item you claim as confidential. Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. If another person will submit chemical identity information for you (for either item 1 or 2), mark 00 the box at the right. ConfiIdentify the name, company, and address of that person in a continuation sheet. ___,. dential 1. Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances, see the Instructions Manual)

a. Class of substance — Mark (x) 1 Class 1 or 2 D Class 2 X

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, whichever is appropriate based on CA 9CI nomenclature rules and conventions). x

[ ]

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

### 1 Method 1 (CAS Inventory Expert Service - a copy of the Identification Method 2 (Other Source) report obtained from the CAS Inventory Expert Service 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 1 substance, provide a complete and correct chemical structure diagram. For a class 2 substance — (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process (3) Indicate the range of composition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical structure diagam, as complete as can be known, if one can be reasonably ascertained. 

### X

--'.

—)

Mark (X) this box if you attach a continuation sheet
Form EPA 7710-25 (Rev. 5-95) Page 

### 4

## 1 3 - 5
Part I - GENERAL INFORMATION — Continued Section B — CHEMICAL IDENTITY INFORMATION — Continued 2. Polymers (For a definition of polymer, see the Instructions Manual.) a. Indicate the number-average weight of the lowest molecular weight composition Indicate maximum weight percent of low molecular weight species (not including 500 and below 1,000 absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: (3PC i) lowest number average molecular weight: of the 

# E Other residual polymer you intend monomers, reactants, D : Specify) to manufacture.

or solvents) below Confidential

ii) maximum weight % below 500 molecular weight: iii) maximum weight % below 1000 molecular weight: Mark (X) this box if you attach a continuation sheet. b. 

### You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any item you claim as confidential. (1) — Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of the polymer. (2) — Mark (X) this column if entry in column (1) is confidential. (3) — Indicate the typical weight percent of each monomer or other reactant in the polymer. (4) — Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer description on the TSCA Chemical Substance Inventory. (5) — Mark (X) this column if entries in columns (3) and (4) are confidential. (6) — Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. (7) — Mark (X) this column if entry in column (6) is confidential. Monomer or other reactant and CAS Registry Number

( 1 ) Confidential (2) Typical composition ( 3 ) Identify

Mark (X) (4) Confidential ( 5 ) Maximum

residual (6) Confidential ( 7 ) % % % % % % % % % % % % % % Mark (X) this box if you attach a continuation sheet c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one). Method 1 (CAS Inventory Expert Service - a copy of the Identification report D Method 2 (other source)

obtained from the CAS Inventory Expert Service must be submitted as an attachment to this notice) d. The currently correct Chemical Abstracts (CA) name for the polymer that is 

### consistent with TSCA Inventory listings for similar polymers.

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

Mark (X) this box if you attach a continuation sheet
Form EPA 7710-25 (Rev. 5-95) 

### Page 

### 5

## p. 6 

## Part I - GENERAL INFORMATION — Continued Section B — CHEMICAL IDENTITY INFORMATION — Continued 3. Impurities (a) — Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purposes Provide the CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." (b) — Estimate the maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight %.
Impurity and CAS Registry Number

(a) Maximum Percent (b) Conlidential 

### Please see MSDS page 23 

### for composition of ' and also PMN page 14 for further description. %
% % % % % %
Mark (X) this box if you attach a continuation sheet 4. Synonyms — Enter any chemical synonyms for the new chemical substance identified in subsection 1 or 2.

]

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

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

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

6. Generic chemical name — If you claim chemical identity as confidential, you must provide a generic chemical name for your substance that reveals the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

### Partially fluorinated alcohol substituted glycol

Mark (X) this box if you attach a continuation sheet 7. Byproducts — Describe any byproducts resulting from the manufacture, processing use, or disposal of the new chemical substance. Provide the CAS

Registry Number if available. Byproduct (1) CAS Registry Number (2) Confidential

Mark (X) this box if you attach 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 item you claim as confidential. 1. Production 

### volume — Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% 

### new chemical substance basis. For a Low Volume Exemption application, i f you choose to have your notice reviewed at a lower production volume than 10,000 kglyr, speciA) the volume and mark (x) in the binding box. If granted, you are bound to this volume. 

### Maximum first 12-month production (kg/yr) (100% new chemical substance basis) Maximum 12-month production (kg/yr) (100% new chemical substance basis) Confidential Binding

Option Mark (x)
1 i 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 colunm (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 colunm 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 colunm (6) is confidential business information (CBI). (8)

— 

### Indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) — Mark(X) this column if entry(ies) in column 

### (8) is 

### (are) confidential business information (CBI). Category of use (1) (by function and application i.e. a dispersive dye for finishing polyester fibers) CBI
(2) Binding Option Mark (x) (3) Production % (4) CBI
( 5 ) % inFormulation (6) CBT
(7) % of substance expected per use (8) CBI
(9)Sitelimited Consurner Industrial Cornmercial Binding Option ] X X [ ] X X % % % % cy o % % % % % % % 

### *If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products. In addition, include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. Mark (X) this box if you attach a continuation sheet. b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that use category. Read the Instructions Manual for examples of generic use descriptions. description 

### Intermediate

Mark (X) this box if you attach a continuation sheet. 3. 

### Hazard Information — Include in the notice a copy or other information which will be provided to any equipment or practices for the safe handling, transport, of reasonable facsimile of any hazard warning statement, label, material safety data sheet, person who is reasonably likely to be exposed to this substance regarding protective use, or disposal of the new substance. List in Part III hazard information you include. Binding Option Mark (x) 

### Continued on Pages 24-30 Mark (X) this box if you attach 

### hazard information.
Form EPA 7710-25 (Rev. 5-95) Page 

### 7

### p. 8 

## Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A — INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you claim as confidential. Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting requirements if there are further industrial processing or use operations after import. You must describe these operations. See instructions manual. I. Operation description a. Identity — Enter the identity of the site at which the operation will occur. Confidential Name [ ] X Site address (number and street) { ] City, County, State, ZIP Code [ ] If the same operation will occur additional sites on a continuation production rates or operations, sites as attachments. at more than one site, enter the number of sites. Identify the # of sites sheet, and if any of the sites have significantly different include all the information requested in the section for those Mark (X) this box if you attach a continuation sheet. b. Type — Mark (x) X ., Manufacturing Processing Use c. Amount and Duration - Complete 1 or 2 as appropriate

1. Batch i Maximum kg/batch (100% new chemical Hours/batch . Batches/year substance) 1 

## 1 1 [ ] 1 [ ] X

2. Continuous Maximum kg/day (100% new chemical Hours/day ! Days/year substance) I I 1 d. Process description 0 (1) Diagram the major unit gallon drum, rail car, tank (2) Provide the identity, the materials and feedstocks chemicals (note frequency (3) Identify by number the points

A, Mark (X) this box if you attach Mark (X) to indicate your willingness to have your process description binding. X operation steps and chemical conversions. Include interim storage and transport containers (specify-e.g. 5 gallon pails, 55 truck, etc.). approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting (including reactants, solvents, and catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning if not used daily or per batch). of release, including small or intermittent releases, to the environment of the new chemical substance.

a continuation sheet. Continued on Page 14.

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 SUBMITTER — 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 workers exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you claim as confidential. (1) — Describe the activities (e.g. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) — Mark (X) this column if entry in column (1) is confidential business information (CBI). 

### (3) — Describe any protective equipment and engineering controls used to protect workers. (4) — and (6) — Indicate your willingness to have the information provided in column (3) or (5) binding. (5) — Indicate the physical form(s) of the new chemical substance (e.g. solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) at the time of exposure. (7) — Mark (X) this column if entry in column (5) is confidential business information (CBI). (8) — Estimate the maximum number of workers involved in each activity for all sites combined. (9) — Mark (X) this column if entry in column (8) is confidential business information (CBI). (10) — and (11) — Estimate the maximum duration of the activity for any worker in hours per day and days per year. (12) — Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). CBI

(2) Worker activity (e.g. bag dumping, tilling drums) 

### (1) Protective Equipment/ Engineering Controls
(3) Binding

Option Mark (x) (4) Physical form(s) (e.g.solid:powder) and % new substance (5) Binding

Option Mark (x) (6) # of

Workers Exposed (8) Maximum

Hrs/day (1 0) duration

Days/yr CBI

(7) CBI



### (9) CBI
(12) X X X [ X

X X



### [E] Mark (X) this box if you attach a continuation sheet. Continued on Page 16. 3. Environmental Release and Disposal — You must make separate confidentiality claims for the release number and the amount of the new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (1) — Enter the number of each release point identified in the process description, part II, section A, subsection 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 column (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. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day). (6) — Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). (7) — Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). X X

Release Number CBI Media of Release Amount of new substance released Control technology and efficiency (you may wish to optionally attach efficiency data) CBI (1) (2a) (2b) 

### (3) e.g. stack air (4) 

### (5a) Binding Mark (x) (5b) (6) X X
X
X X

X X (7) Mark (X) the 

### A POTW provide name(s) below: destination(s) of releases to water. I 1 CBI Navigable 

### 1 Other-Specify Waterway [ ] provide NPDES # CBI X [ X 

### *No data available on efficiency of removal of PMN substance so no reduction assumed. [

- 1 Mark (X) this box if you attach a continuation sheet. Continued on Page 17.

Form EPA 

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

### 9

### p. 10



## Part II - HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE — Continued Section B — INDUSTRIAL SITES CONTROLLED BY OTHERS Complete Section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. 

### Complete a separate section B for each ive 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 (1) — Diagram the major unit operation steps and chemical conversions, including interim storage 55 gallon drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), solvents and catalysts, etc) and of all products, recycle streams, and wastes. Include clearing batch). (3) — Identify by number the points of release, including small or intermittent releases, (4) Please enter the # of sites (remember to identify the locations of these sites on a continuation



# fl Mark (X) this box if you attach a continuation sheet. the specific information and transport containers each worker activity. and entry point of all feedstocks chemicals (note frequency to the environment of the sheet): that you claim as confidential.

(specify— e.g. 5 gallon pails, (2) — Provide the identity, (including reactants, if not used daily or per new chemical substance.

# of sites

2. Worker Exposure/Environmental Release. (1) — From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) — Estimate the number of workers exposed for all sites combined. (4) — Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. (6) — Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls used to protect workers. (7) — Estimate the percent of the new substance as formulated when packaged or used as a final product. (9) — From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified. (10) — Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). (12) — Describe media of release i.e., stack air, fugitive air (optional—See Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the environment. (14) — Identify byproducts which may result from the operation. (3), (5), (8), (11), (13) and (15) - Mark (x) this column if any of the proceeding entries are confidential business information (CBI). Letter ofActivity ( 1 ) # of Workers Exposed (2) CRT

(3) Duration

of Exposure CBI

(5) Protective Equip./ Engineering Controls/ Physical form and % new substance (6) % in

Formulation (7) CBI

(8) Release Number
(9) Amount of New Substance Released CBT

(1 1) Media of Release

& Control Technology (12) CRT

(13) (4a) (41)) (10a) (10b)

(14) — By products ( 15 ) Mark (X) this box if you attach a continuation sheet.
Form EPA 7710-25 (Rev. 5-95) Page 10

### p. 11


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

## In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the reclamation of useful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal. Description 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 reduction 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 the revised Instructions 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 or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in similar 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.

Mark (X) this box if you attach a continuation sheet.
Form EPA 7710-25 (Rev. 5

- 95) Page 11

### p. 12 

## Part III — LIST OF ATTACHMENTS
Attach continuation sheets for sections of the form and test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to which it relates, if appropriate. Number consecutively the pages of the attachments. In the column below, enter the inclusive page numbers of each attachment. Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on how to claim any information in an attachment as confidential. You must include with the sanitized copy of the notice form a sanitized version of any attachment in which you claim information as confidential.
Attachment name Attachment page number(s) Confidenti al 

### Part 2, Section A, ld, Manufacturing Process Description of PMN Substance 

### 14 X Part 2, Section A, ld, Block Diagram of Manufacturing Process of PMN Substance 15 X Part 2, Section A, 2, Occupational Exposure of Manufacturing Process of PMN Substance 

### 16 X Part 2, Section A, 3, Environmental release 

### and Disposal of Manufacturing 

### Process of PMN Substance 17 

### X GC and GC/MS Analysis of [ ] 18-21 X 

### Impurity Profile of [ ] 22 X 

### Material Safety Data Sheet (MSDS) 23-29 X 

### CAS Inventory Expert Service letter for PMN Substance 30 X

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

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

### 12

### p. 13



## PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET To assist EPA's review of physical and chemical properties data, please complete the following worlsheet for data you provide and include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property, the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential. The physical state of the neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (% PMN substance in _). You are not required to submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should suhnit this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission of test data.

Property (a) Mark (X) if provided Page

number (b) Value (c) Measured or Estimate (M or E) Confidential Mark (X) (d) Physical state of neat substance I ] M 

### X Vapor pressure @ Temperature °C Torr Density/Relative density g/cm3 Solubility @ Temperature °C g/L Solvent Solubility in water @ Temperature °C °C Melting Temperature °C Boiling/sublimation temperature @ torr pressure Spectra
Dissociation constant
Particle size distribution Octanol/water partition coefficient Henry's Law constant
Volitalization from water
Vol ital ization from soil p H @ concentration
Flammability Explodability Adsorption/coefficient Other - Specify

EPA 

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

### 13

## Continuation Page For Part II — Section A-ld - 

## Description of Manufacturing Process from page 8 p. 14



## 1 are isolated during a [ ]. The [ ] will take place in [ heated [ ]. During the [ ]. A [ determine the [ ]. When the appropriate [

] is complete. The [ ]. The [ ] will be ], which will be [ ] will be [ ] will be taken to ] has been achieved, the

] will be packed out into drums. Approximately [ ]. The [ ] can then be either disposed of [ 

## ] would then be rinsed ]. The
]. The material in would be analyzed for [ 

## The drums used to transfer and store the [

For clarification,

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

### 14

## Continuation Page For Part II — Section A-ld — Diagram of Manufacturing Process from page 8 p. 15

(Rev. 5-95) Page 

### 15 Form EPA 7710-25

### p. 16



## Continuation page of Part II 

## — Section A 

## — 2 Occupational Exposure of Manufacturing Process from page 9
2. substance, Occupational Exposure - You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical number of workers exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you claim as confidential. (1) - Describe the activities (e.g. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) - Mark (X) this column if entry in column (1) is confidential business information (CBI). (3) - Describe any protective equipment and engineering controls used to protect workers. (4) - and (6) - Indicate your willingness to have the information provided in column (3) or (5) binding. (6) - Indicate the physical form(s) of the new chemical substance (e.g. solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) at the time of exposure. (7) - Mark (X) this column if entry in column (5) is confidential business information (CBI). (8) - Estimate the maximum number of workers involved in each activity for all sites combined. (9) - Mark (X) this column if entry in column (8) is confidential business information (CBI). (10) - and (11) - Estimate the maximum duration of the activity for any worker in hours per day and days per year. (12) - Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). Worker activity (e.g. bag dumping, filling drums) (1) CBI

(2) Protective Equipment/ Engineering Controls
( 3 ) Binding

Option Mark (x) (4) Physical form(s) (e.g.solid:powder) and % new substance (5) Binding

ption o- Mark (x) (6) CBI

( 7 ) # of Workers Exposed (8) CBI

( 9 ) Maximum duration CBI

(12) Hrs/day (10) Days/yr

(11) J X [ ] X [ 1 X 1 ] X

1X [ i X X X

[XX X X

[ i1X

1X X X

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

Form EPA 7710

- 25 (Rev. 5-95) Page 

### 16

### p. 17



## Continuationpage of Part II — Section A — 3 Environmental Release and Disposal of Manufacturing Process from page 9

3. Environmental Release and Disposal

— You must make separate confidentiality claims for the release number and the amount of the new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (1) — Enter the number of each release point identified in the process description, part II, section A, subsection 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 column (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. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day). (6) — Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). (7) — Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). Release Number (1) Amount of new substance

released CBI

( 3 ) Media of Release e.g. stack air (4) Control technology and efficiency (you may wish to optionally attach efficiency data) CBI
(6) Binding (5a) Mark (x) (5b) (2a) (2b)

[ ] X ] [ ] [ ] X (7) Mark (X) the destination(s) of releases to .. POTW provide name(s) below:



## I 1 CBI Navigable Other-Specify Waterway 

# ] provide NPDES # CBI 

# [ ] x x
water. * 

### No data available on efficiency of



### removal of PMN substance so no 

### reduction assumed. [ 1 Mark (X) this box if you attach a continuation sheet.

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

### 17

### p. 18

Page 18

### p. 19



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### p. 23

The MSDS format adheres to the standards and regulatory requirements of the United States and may not meet regulatory requirements in other countries. Page 1 Material Safety Data Sheet

Revised 05-Nov-2009

CHEMICAL PRODUCT/COMPANY IDENTIFICATION Company Identification MANUFACTURER/DISTRIBUTOR

PHONE NUMBERS

COMPOSITION/INFORMATION ON INGREDIENTS # Components Material 1 1 I 1 Unknown CAS Number % 1 I I 1 I I I I I

I I I 1 I 1 I I I 8.5

HAZARDS IDENTIFICATION Potential Health Effects Skin contact may cause skin irritation with discomfort or rash. Eye contact may cause eye irritation with discomfort, tearing, or blurring of vision. Based on animal experiments on a similar product, gross overexposure may cause abnormal liver or kidney function as detected by laboratory tests. Based on related products, inhalation of spray or mist may cause nasal, throat, or lung irritation. Inhalation of large amounts of respirable particles may be toxic to the lungs. Symptoms may be modest initially, followed in hours by severe shortness of breath requiring prompt medical attention.



## Page 23

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Page 2 , Material Safety Data Sheet (HAZARDS IDENTIFICATION - Continued)

Carcinogenicity Information The following components are listed by IARC, NTP, OSHA or ACGIH as carcinogens. Material IARC NTP OSHA ACGIH T 2B X A3

FIRST AID MEASURES First Aid INHALATION If inhaled, immediately remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Call a physician. SKIN CONTACT Flush skin with water after contact. Wash contaminated clothing before reuse. EYE CONTACT In case of contact, immediately flush eyes with plenty of water for at least 15 minutes. Call a physician. INGESTION If swallowed, do not induce vomiting. Immediately give 2 glasses of water. Never give anything by mouth to an unconscious person. Call a physician.
Notes to Physicians Activated charcoal mixture may be administered. To prepare activated charcoal mixture, suspend 50 grams activated charcoal in 400 mL water and mix thoroughly. Administer 5 mL/kg, or 350 mL for an average adult.



## Page 24

### p. 25
i Page 3 Material Safety Data Sheet

FIRE FIGHTING MEASURES Flammable Properties Flash Point : Does not ignite Method : Pensky-Martens Closed Cup - PMCC. Noncombustible. Hazardous decomposition products including carbon dioxide, carbon monoxide, hydrogen fluoride, toxic gases or particles may be formed during combustion. These products may cause severe eye, nose, throat, and lung irritation or toxic effects. Extinguishing Media Use media appropriate for surrounding material.
Fire Fighting Instructions Evacuate personnel to a safe area. Wear self-contained breathing apparatus. Avoid breathing decomposition products.

ACCIDENTAL RELEASE MEASURES Safeguards (Personnel) NOTE: Review FIRE FIGHTING MEASURES and HANDLING (PERSONNEL) sections before proceeding with clean-up. Use appropriate PERSONAL PROTECTIVE EQUIPMENT during clean-up. Evacuate personnel, thoroughly ventilate area, use self-contained breathing apparatus. Ventilate spill area. Initial Containment Dike spill. Spill Clean Up Soak up with sawdust, sand, oil dry or other absorbent material.

HANDLING AND STORAGE Handling (Personnel) Avoid contact with eyes, skin or clothing. Wash thoroughly after handling. Do not store or consume food, drink, or tobacco in areas where they may become contaminated with this material. Avoid circumstances that produce respirable particles unless suitable ventilation and respirator are used.



## Page 25

### p. 26 Page 4 Material Safety Data Sheet (HANDLING AND STORAGE - Continued)
Handling (Physical Aspects) Close container after each use. Storage Keep container tightly closed. Keep away from open flames and heated surfaces above 200 degrees C (392 deg F).

EXPOSURE CONTROLS/PERSONAL PROTECTION Engineering Controls Keep container tightly closed. Use only with adequate ventilation. Do not aerosolize. Keep away from open flames and heated surfaces above 200 degC (392 degF). Personal Protective Equipment EYE/FACE PROTECTION Wear safety glasses. Where splash potential exists, wear chemical splash goggles. RESPIRATORS Wear NIOSH approved respiratory protection, as appropriate. PROTECTIVE CLOTHING
Where there is potential for skin contact have available and wear as appropriate impervious gloves, apron, pants and jacket. Exposure Guidelines Applicable Exposure Limits PEL (OSHA) : 100 ppm, 360 mg/m3, 8 Hr. TWA, Skin TLV (ACGIH) : 20 ppm, 8 Hr. TWA, Skin, A3 : 25 ppm, 8 & 12 Hr. TWA, Skin

Exposure Guideline Comments



## Page 26

### p. 27

Page 5 Material Safety Data Sheet (Applicable Exposure Limits - Continued)

PHYSICAL AND CHEMICAL PROPERTIES Physical Data Boiling Point 1 Freezing Point : Liquid at room temperature Vapor Pressure : 0.2 torr @ 25 C (77 F) Solubility in Water : Negligible Odor : None Form : Liquid Color : Colorless to Pale Yellow Density

STABILITY AND REACTIVITY Chemical Stability Stable at normal temperatures and storage conditions. Incompatibility with Other Materials None reasonably foreseeable. Decomposition Decomposes with heat. Hazardous decomposition products including carbon dioxide, carbon monoxide, hydrogen fluoride, toxic gases or particles may be formed during combustion. These products may cause severe eye, nose, throat, and lung irritation or toxic effects. Polymerization Polymerization will not occur.



## Page 27

### p. 28 Page 6 Material Safety Data Sheet

TOXICOLOGICAL INFORMATION Animal Data was evaluated for acute, genetic, subchronic, reproductive, developmental, and aquatic toxicity. was slightly toxic by the oral and dermal routes with an oral LD 50 of 1750 mg/kg and a dermal LD 50 of greater than 5000 mg/kg in rats. , did not produce a dermal sensitization response in mice. By the inhalation route, was slightly toxic with a 4-hour LC 50 in rats greater than 5.2 mg/L and less than 9.9 mg/L. was not mutagenic in the bacterial reverse mutation test or in the mouse lymphoma assay and was not clastogenic in a chromosome aberration assay in human lymphocytes. In subchronic, one-generation reproductive, and developmental toxicity studies, was administered to rats by oral gavage. Liver effects were observed in the subchronic study at 25 mg/kg/day and higher. In the developmental and reproductive studies, toxicity was only observed in the offspring at doses that were also maternally toxic. Therefore, this material is not considered to be a selective reproductive or developmental toxicant. These data indicate 25 mg/kg/day is the NOAEL for

1 in the developmental and reproductive studies; the NOEL in the subchronic study is 5 mg/kg/day. Ecotox The 96-hour LC 50 in fathead minnows was 4.8 mg/L, 48-hour EC 50 in Daphnia magna was 7.8 mg/L The 72-hour EC 50 in the green algae, Pseudokirchneriella subcapitata, was 4.5 mg/L.

DISPOSAL CONSIDERATIONS Waste Disposal Treatment, storage, transportation, and disposal must be in accordance with applicable Federal, State/Provincial, and Local regulations.

TRANSPORTATION INFORMATION Shipping Information Not Regulated as a hazardous material by DOT, IMO, or IATA.

REGULATORY INFORMATION U.S. Federal Regulations TSCA Inventory Status : Not Listed. One or more components are not listed on EPA's Toxic Substances Control Act (TSCA) Chemical Inventory. TITLE III HAZARD CLASSIFICATIONS SECTIONS 311, 312 Acute : Yes Chronic : No Fire : No Reactivity : No Pressure : No



## Page 28

### p. 29

Material Safety Data Sheet Page 7

OTHER INFORMATION NFPA, NPCA-HMIS NPCA-HMIS Rating Health : 2 Flammability : 0 Reactivity : 0 Personal Protection rating to be supplied by user depending on use conditions.
The data in this Material Safety Data Sheet relates only to the specific material designated herein and does not relate to use in combination with any other material or in any process. Responsible for MSDS : MSDS Coordinator Address Telephone
This information is based upon technical information believed to be reliable. It is subject to revision as additional knowledge and experience is gained.

End of MSDS



## Page 29

# inventory 

# Expert Service

A division of the American Chemical Society Phone: 800-631-1884, 614-447-3870 Fax: 614-447-3747 E-mail: answers@cas.org Web: wwwcas.org/products/client/



### INVENTORY EXPERT SERVICE REPORT



### IES-ORDER NUMBER:

CA INDEX NAME

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

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.

CAS 2540 Olentangy River Road RO. Box 3343 Columbus, Ohio 43210-0334 • USA Page 30