## PMN Page 1 ; Page 1 of 18 p~ 1 U.S . ENVIRONMENTAL PROTECTIONAGENCY 

# My, Iae

+t 

## ES

in the Premanufacture Notice 

# PREMANUFACTURE NOTICE

18 GENERAL INSTRUCTIONS Form Approved O

.M .B. No. 2070-0012

. Approval Expires 10-31-96 . Date of -pt 

## AGENCY USE ONLY

~-+ 

# Company Sanitized 

# 'rjpffllm

rI1 to .D~s~'+

You must provide all information requested in this formto the extent that it is known to or reasonably ascertainable by you Make reasonable estimates if you do not have actual data. Before youcomplete this form, you should read the "lrotructions Manual forPretinanufacuueNotification" (the Insttivctiosts manual is available fromthe Toxic Substances Control Act (TSCA) lrd'ormation Servicebycalling202-554-1404, or faxing 202-554-5603) . If a user fee has been rernittedforthis notice (40CFR700 .45), indicate in the boxes above the TS-userfee identification number you have generated Remember, your user fee IDnumber must also appear on your corresponding fee rernittance, which is sent to EPA, Washington Financial Management Center (3303), P .O . 360399M, Pittsburgh, PA 15251-6399, Attn. TSCAUserfee . Part I - GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even if you claimthe identity as confidential . You may authorize another person to submit chemical identity information for you, bit your submission will riot be complete and the review will not begin until EPA receives this information A letter in support of your submission should reference your TSuser fee identification number. You must submit an original and twocopies of this notice including all test data Ifyou 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 operafices to be described um Part Il, sections A and B of this notice, reproduce thesections as needed. Part III -- LIST OF ATTACHMENTS Attach additional sheets if there is not enough space toanswer a question fully. Label each continuation sheet with the corresponding section heading, In Part Fit, list these attachments, any test data or other damand 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 1 l 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 statemetrts you make in this section, 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, LVF, 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 fromlater deviating fromthe information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claim on tile form, mark (X) the confidential box next tothe information that you claimas confidential To assert a claimin an attachmerS, cirde or bracket the information you claimas confidential . If you claim information "nn the notices as confidential- you must abo orovide a sanitized version of the notice, (including attachments) . For additional instructions on claiming information as corifidentiai, read the Instructions Manual ® Mark (x) if any information in this notice is claimed as; confidential

EPAFORM

7710-25 (Rev. 5-95) TEST DATA ANDOTHER DATA You are required to submit all test data inyour possession or control and to provide a description ofall otherdata known to or reasonably ascertainable by you, if these data arerelated to the health and em+irormental effects on the manufacture, processing, distribution in commerce, use, or disposal ofthe new chemical substance

. Standard literature citations may be submitted fordata in the open scientific literature. Complete test data (written in Snglish), notsummaries ofdata, must be submitted if they do not appear in the open literature. Youshould clearlyidentify 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 andother data. Data should be submitted according to the requirements of §720.50of the PremarntfactureNotification Rule (40CFR Part 720) . Test Data (Check Befow any icicluded in this notice) " Envirotunental fate data " Health effects data " Flwrromnerual effects data " Physical/Chemical Properties* 

# TS



# 0

# uuu101R-i u

Yes " Other data El Yes Yes Risk assessments Yes Structure/activity relationships 1 :1 Yes Test data not in the possession

or control of the submitter 0 " A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One) 

# lxl PMN (Premattufacture23otUce)

INTERMEDIATE PMN (submitted in sequence with final product PMN) NUN (Significant New Use Notice) I TMEA (Test Marketing Exemption Applimtion) L VE (Low

Volume Exemption) @ 40 CFR 723.50(c)(1) LOREX (LowRelease/LowExposure Exemption) @ 40 CFR 723

.5Q(c)(2) 1-1 LVEModification ~ LOREXModification IS THIS ACONSOLIDATED PMN? ~ Yes H of chemicals or polymers (Prenotice Communication # required, enter # on page 3) Replaces previous editions of EPA Form 7710-25. /' ` /

## PMN Page 2 ; Page 2 of 18 

## p. 2

Public reporting burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions, searching eristing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect ofthis collection of information, including suggestions for reducing this burden, to Director, Collection Strategies Division (2822), U .S. Environmental Protection Agency, 1200 Pennsylvania Ave., N .W ., Washington, D.C. 20460 ; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. CERTIFICATION - A Printed copy of this signature page, with original signature, must be submitted 

## I certify that to the best of my knowledge and belief: I. The company named in Part I, section A, subsection 1 a ofthis notice formintends 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 of submission. 3. I am submitting with this notice all test data in my possession or control and a description ofall other data known to or reasonably ascertainable by me as required by §720 .50 of the Premanufacture Notification Rule. Additional Certification Statements : Ifyouare submitting a MIN, Intermediate PMN, Consolidated PMN, or SNLJN, check the following user fee certification statement that applies: n The Company named in Part I, Section Ahas remitted the fee of $2500 specified in 40CFR 700 .45(b), or F1 The Company named in Part I, Section Ahas remitted the fee of $1000 for an Intermediate PMN (defined (a~ 40CFR 700 .43) in accordance with 40 CFR 700 .45(b), or 0The Company named in Part I Section Ais a small business concern under 40CFR 700 .43 and has remitted a fee of $100 in accordance with 40 CFR 700 .45(b) . Ifyou are submitting a low volume exemption (LVE) application in accordance with 40CFR723.50(cx 1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(cx2), check the following certification statements: [) The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50 . E] The manufacturer is familiar with the terms of this section and will comply with those terms; and 

## 0The new

chemical substance for which the notice is submitted meets all applicable exemption conditions. 0Ifthis application is for an LVE in accordance with 40CFR 723.50(cXl ), the manufacturer intends to commence manufacture of the exempted substance for commercial purposes within I year ofthe date ofthe expiration ofthe 30 day review period. The accuracy of the statements you make r this notice should rened your best prediction or the anticipated facts regarding the chemical substance described herein. An

y hnowin and widral misinte tation is sub j ect to criminal pe na lty pursuant to 18USC 1001 . Confidential Signature and title of Aidhorized Official (Onginal Signadae Requited) Date 

# EKI Sigtratise of agent -(if applicable) Date

EPAFORM

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

## p. 3 PMN Page 3 ; Page 3 of 18 Part I- GENERAL INFORMATION Section A - sL'1ni1T'1'ER IDE11'fI bICAfKIN I a. Person Mane of authorized oflicial Submitting Position Pres ;deaL Notice (in U

.S.) Company Mailing address (number and street) CA-.% Slate Postal Code b. Agent (if Name of authorized official Position applicable) N/A Company Mailing address (numberand street) City, state Postal Code c,u1 : t c . If you are submitting this notice as part of ajoint submission. mark (?C) this box. Joint Submitter(if Name of authorized official Position applicable) N/A Company A9aiiing address (number and strcLt) CitY. State Province, ('ountrv Postal Code I

_ . . . ~ . . . . ,-, ~ . . _ . . s.r ~ : . ~ t, . . , 2. Technical Name of authorized ollicial Contact (in Position U .S.) :' : . : :pn

\tailing address (number and street) 544 Beacon Knoll lane City, State Postal Code -- 3. If you ha : e had a prenouce communication (PO concerning tlus nonce and EPA assigned a PC Nrnnber to the notice, enter the mrmber. Alatic (\) ~1 Ej if none 4. If you prev iously iutxnitte<i an e .\empthexi applicaLcar for tlee chemical sutxstarwe covered by tlus notice, enter die exemption number assigned by EPA. If you previously submitted a P\Lti for this substance enter the PAIN Mark (X) - 

# F if none number assigned by EPA (i .e. withdrawn or incomplete) 5. If you have submitted a notice of Bona fide intent to mamil'acture or impcxt - for the chemical substance covered by this notice, enter the notice number assigned by EPA

. ----0 Mark (Y) ifnone 6 . Type of Notice -Mati : (X) klark the "Ccmtidcn1ial" bos ne-ct to anm subsection Non claimas conlidcntial

1 . Manufacture ~ 2 . Only I Binding Option I Mark (X) I 0 0 Import

Only Binding Option Mark (?C) t I 3. t I Both Confidential

EPA FORM

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

## p. 4 PMN Page 4 ; Page 4 of 18 ' Part I - GENERAL INFORMATION- Continued Section B-- CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth Collective Index 9CI of CAnomenclature rules and conventions . Mark the "Confidential" boxnext to an itemy ou claim as confidential Complete either item I (Class 1 or 2 substances) or 2(Polymers) as appropriate . Complete all other items . ~ If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right . Confi- I ~ Ident the name, com

pany, and address of that on in a continuation sheet. dential 1 . Class 1 or 2chemical substances (for definitions of class 1 and class 2substan see the instructions Manual) a . Class of substance - Mark (X) Class 1 or Class 2 b . Chemical name (Currently correct Chemical Abstracts (CA) Namethat is consistent with TSCA Inventory listings for similar substances . For Class 1 substances a CA Index Name must be provided ForClass 2substances either a CA Index Name or CA Preferred Name must be provided, - which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

I

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one) . FKI Method I (CAS Inventory Expert Service - a copy of the Identification Q Method 2 (Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment tothis notice) d . Molecular formula CBI CAS Registry Number (if a number already exists for the substance) e . For a class 1 substance, provide a complete and correct chemical structurediagram . For a class 2substance, provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. Please seethe F-PMNInstruction Manual for ~/ / discussion of "native format" diagram software which canbe helpful in reviewing your substance

Mark (X) this box ifyou attach a commutation sheet . EPAFORM

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

## PMN Page 4a ; Page 5 of 18

Fora class 2substance - (1)List theimmediate precursor substances with their respective CAS Registry Numbers. (2)Describe the nature of the reaction or process. (3) Indicate the range of composition andthetypical composition (where appropriate) . e . (1) List the immediate precursor substances ivith theirrespective CAS Registry Numbers. Confi

## Name (CAS ~) dential 

# F~ N/A

e. (2) Describe the nature of thereaction or process.

N/A

e . (3) indicate the range of composition and the typical composition (uhere appropriate) 

### Ei

N/A

Mark (Ji) this box if y

ou attach a continuation sheet. EPAFORM

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

## p. 6 PMN Page 5 ; Page 6 of 18 Part I - GENERAL INFORMATION - Continued Section B- CHEMICAL IDENTITY INFORMATION- Continued 2 . Polymers (For a definition of polymer, seethe Instructions Manual .) Confidential a. Indicate the number-averageweight of the lowest molecularweight composition of the polymer you intend to manufacture. Indicate maximum

weight percent of low

molecular weight species (not including residual monomers, reactants, or solvents) below 500and below 1,000absolute molecular wei ght of that com pos ition. Describe the methods of measurement or thebasis for your estimates : C,PC U Other U : (Specify below) (i) lowest number average molecular weight: (ii) maximum

weight °l°below

500molecular weight (iii) maximum

weight %

below1000 molecular weight: Mark (X)this box ifyou attach a continuation sheet . b . You must make separate confidentiality claims for monomer or otherreactant identity, composition information, and residual information. Mark (X)the "Confidential" box next toany item you claimas confidential (1) - Provide the specific chemical name and CAS Registry Number (ifa number exists) of each monomeror other reactant used in the man ufacture of thepolymer. (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate thetypical weight percent of each monomeror other reactant m the polymer. (4) - Choose "yes" fromdrop down menu if you want a monomer or other reactant used at twoweight percent or less to be listed as part of the polymer

description on the TSCAChemical 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 otherreactant that may be present as a residual m thepolymeras manufactured for commercial purposes . (7) - Mark (X) this column if en in column (6) is confidential . Monomeror other reactant and CAS Registry Number Confi- Typical Include in Confi- Maximum Confi1 dcntial 2 composition

3 -_ % identity

4 dential

5 residual

6 % dential

7

----- --

~ °/u 1-1 F] %

# F-1

%

# R1-11 %

# F-1

% 

# 0 %

# 0 11 

# 0 % F ~ °,° 

# 1-11 °.o 

# ELI1F] % 

# o % o °%o o % o %o o ° .° o %o o % o %o

° .° ~ °.o 

# o °~ o %o

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

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

## p. 7 PMN Page 5a ; Page 7 of 18 c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) . ~ Method I (CAS InventoryExpert Service - a copy of the identification report 1L 1 Method 2 (other source) obtained fromCAS Inventory Expert Service must be submitted as an attachment to this notice) CBI

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCAInventory listings for similar polymers. N/A

CAS Registry Number (if a number already exists for the substance) e . Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained . . Please see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing yoursubstance.

[]Mark (X) this bo

x ifyou attach a continuation sheet. EPAFORM

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

## p. 8 PMN Page 6 ; Page 8 of 18 

# 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 a4 manufactured for commercial purpose . Provide the CAS Registry Number if available. If there are unidentified impurities, enter"unidentificd ." _) - Estimate the maximum wei ght %

of each im

puri ty. If there are unidentified im p urities, estimate their total wei g ht °/n Impurity andCAS Registry Number Maximum Confipercent dential a % I~J

_ °io

--__ %

- . %

%

- _ %

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

_ ~ ,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 . ® Mark (X) this box if you attach acontinuation sheet. 6 . Genericchemical name - Ifyou claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the new chemical substance tothe maximum extent possible . Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names.

_ . . . 2, ___-~

.__ .: .-_

Mark (X) this box ifyou attach a continuation sheet. 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the new chemical substance

. Provide theCAS Registry Numher if available. Byproduct CAS Registry Number Confi1 2) dential

.

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

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

## P. 9 

# Part I - GENERAL INFORMATION-- Continued Section C- PRODUCTION, IMPORT, ANDUSE INFORMATION : Mark X the "Confidential" box next to an itemyou claimas confidential . 1 . Production volume - Estimate the maximumproduction 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, ifyou choose to have your notice reviewed at a lower production volume than 10,000 k r, speci fy the volume and mark x in the bindin box. If ranted, you are bound to this volume 

## Maximum

first 12-month production (kg/yr) Maximum 12-month production (kg/yr) c°nf- Binding °n i

### al ~ k (100%new

chemical substance basis) (100%new chemical substance basis) dent 

## --- a

]a] 2. Use Information -- You must make separate confidentialityclaims 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 itemyou claimas confidential . a . (1) --Describe each intended category of use of the new chemical substance by function and application. (2) -Mark (X) this column if entry column (1) is onfrdential business information (CBI) . (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total roduction for the first three years devoted to each category of use . (5) --Mark (X) this column if entry in column (4) is confidential business information (CBI) . (6) -- ,stimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under our control associated with each category of use . (7) --Mark (X) this column if entry in column (6) is confidential business information (CBI) . (8) --Indicate % of roduct volume expected for the listed "use" sectors. Mark more than onebox if appropriate . Mark (X)to indicate your willingness to have the use type provided in (8) indin . 9 --Mark X this column if en ies in column 8 is are confidential business infomwtion CBI . Category of use (1) (by function and application i .e. a CBI Bi"du* Pro- CBI % in CBI %

ofsubstance expected peruse CBI dispersive dye for finishingpolyesterfibers) oMP° x~ I uction % . Formu

latton (8) (2) (3) (4) (5) (6) (7) site- C~- Indos- Com- Binding (9) limited imWc trial mercial 

## Op tion Acid Dye for Coloring Anodized % u Aluminum X 100 

## [] 0-5% 1f10% 

# 1111 % 

# 11 q% 

# E_ 1111 %

# ll ---

# % ][11

. 

# 111111 %

# 11 % 

# 11111 % 

# 1 Ll c%

% %

# P 1 1 1 

# 1A E Ifyou 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 bywhich this substance loses its identity in the consumer product . rk (X) this box ifyou attach a continuation sheet. b . Generic use Ifyou claim any category of use description in subsection 2a as confidential, enter a generic descriptionof that category. Read the Instruction description Manual forexamples of generic use descriptions .

-- ;_r ._a z i, . For _ "

---- . . . .-r~ . ._u .-_ - ., . . ~yL _

, i~_ ~`f. TG~ .~~_,_- '''K _- .- .i . , .c, .. , ~7- . . . .~~ JE ._. .,c . .CE: : . z~- w a~_c,d?~ i ,. .,_ a - a re __na ~ ;a. .~ ~c: ._d ~t=~ - v_ . . . :C ., . ._i

_ .~C .t_~ 

## '_-he _ - - _ - k- - - -~ . .- . : _C3~ . :I :3 y . '- : : .^- -- _- "

. . . a . ~ oa=ir _ ~~ ~=~_=d c_ . part . Mark (X) this box ifyou attach a continuation sheet 3. Hazard Information - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding - information which will be provided to anyperson whois reasonably Rely to beexposed to this substance regarding protective equipmentor practices for ~ x) Mark the safe handing, transport, ~e, a disposal of the new substance. List in part III hazard informationyou include . Mark (X) this box ifyou attach hazard information. 

## PMN Page 7 ; Page 9 of 18

EPAFORM

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

## p. 10 PMN Page 8 ; Page 10 of 18 

# Part II-- HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE Section A- INDUSTRIAL SITES CONTROLLED BY THE SUBMII'TER Mark (X) the "Confidential" box next to any itemyou claim as confidential 

### Complete section A for each type of manufacture, processing, or use operation involving the newchemical 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 im po rt . You must describe these operations. See instructions manual I . Operation description 

### Confia. Identi ty -- Enter the identi ty ofthe site at which the operation will occur. dential Name Diversified Products Inc . Site address (number and street) 1140 Memorial Park Road Ci ty, County

, State, ZIPcode Lancaster Lancaster SC 29721 

### 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 or operations, include all the information requested in this section for those sites as attachments. Mark (X) this box ifyou attach a continuation sheet. 

### b . Type Mark (X) x Manufacturing Processing Use c. Amount and Duration -- Com plete 1 or 2 as a ro riate Maximumkg/batch(ioownewct~ .cat Hours/batch Batches/year subsmnoe) 50 1 50 1 . Batch Maximum kg/day(tao%

mw ckmmcal Hours/day Days/year 2. Continuous d . Process description U Mark (X) to indicate your willingness to have your process description binding . (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage and transport containers (specify- e .g. 5gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Providethe identity, the approximate weight (by kg/day or kg/batch on a 100%new chemical substance basis), and entry point of all starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes . Include cleaning chemicals (notefrequency if not used dailyor per batch.). (3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance

. If releasing to two media at the same step, assign a second release number for the second medium . Product will be received in 5 lb sealed puncture resistant bags that will be packaged in sealed 

### containers . Most of the product will be reshipped as received without repackaging . Some product will be repackaged in smaller containers weighing from 5 - 40 lbs . This activity is expected to last 1 hour for 50 days in the year . One employee will be exposed to the bags when performing this activity .

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

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

## P. 11 PMN Page 8a ; Page 11 of 18

EPA FORM

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

## PMN Page 9 ; Page 12 of 18 Part II- HUMANEXPOSURE AND EN VIRONMENTAL RELEASE -- Continued Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER- Continued 2 . Occupational Exposure - You must make separate confidentiality claims for the description ofworker activity, physical formof the new chemical substance, number of works exposed, andduration of activity. Mark (X) the "Confidential" box next to any itemyou claim as confidential . (1) --Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance . (2) -Mark (X) this column if entry in column (1) is confidential business information (CBI). (3) -Describe any protective equipment and engineering controls used to protect workers . (4) and (6) - Indicate your willingness to have the information provided in column (3) or (5) binding . (5) -Indicate the physical form(s) of thenew 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 (?C) this column if entry 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 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 perday and days peryew . (12) --Mark this column if entries in columns 10 and 11 are confidential business' formation (CBI)

. Worker activity CBI Protective Equipment/ Birdnis Physical Bmding CBI # of CB1 Maximunm duration CB1 i b d i s e ( .e., ag ump ng, filling drums)

1 (Z) En g ineerin g Controls 3 option M-k(x) (4) and %

n w sub3tance (5) ~n

Mark (x) (6) (7) Workers

Exposed (9) Hrs/day 10 Dsyslyr 8 )

( (11) (12) Repackaging of 

### sealed bags Gloves, Safety Glasses, 

### Apron & Face Mask Powder I

o ld I U .



# E d 0

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

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

## PMN Page 9a ; Page 13 of 18

3. Enviromnental 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 anddisposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) -Enter the number of each release point identified in the process description, part II, section A, subsection Id(3) . (2) -Estimatethe amount of the new substancereleased (a) directly to the environmentor (b) into control technology (in kg/day or kg/batch) . (3) -Mark (X) this column if entries in columns (1) and (2)are confidential business information (CBI) . (4) -Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off -site land or incineration, POTW, or other(specify)) to which the new

substance will be released fromthat release point. (5) -- a . Describe control technology, if any, and control efficiency that will be used tolimittherelease of thenew substance tothe 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 sitedescribe 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 (CB1) . (7) - klentify the destination(s) of releases to water . Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDFS numbers of the POTW (Pu blicly Owned Treatment Works ). Madc if the POTW name or NPDES# is confidential business information CB . Release Number Amount of new

substance released CBI Medi= of release Control technology and efficiency (you may wish to optionally attach

efficienc y data (1) (2a) (2b) Bi di (3) (4) (Sa) n ng Mar` (5b) (6) N .`A 

# El I ]i

El 11 (7) Mark (X) the destination(s) of releases to water. NPDES# CBI POTW--provide name(s) Navigable waterway-- provide name(s)

a Other--Specify

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

7710=25 (Re

:" . 5-95) P3g-_ 93

## PMN Page 10; Page 14 of 18 Part II- HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE - C ontinued Section B- INDUSTRIAL SITES CONTROLLEDBY OTHERS Completesection Bfor typical processing or useoperations involving the new chemical substance at sites you donot control . Importers donot have to completethis section for operations outsidethe U .S.; however, you must report any processing or use activities after import . See the Instructions Manual . Complete a separate section B for each type of processing, or use operation involving the new chemical substance

. If thesame operation is performed at more than one site describe the typical operation common to these 

### sites. Identi fy additional sites on acontinuation sheet. 1(a) . Operation Description - To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) - Diagramthe major unit operation steps and chemical conversions, including interimstorage and transportcontainers (specify -e.g. 5 gallonpails, 55 gallon drums, rail cars,tank trucks, etc) . Onthe diagram, identify by low and briefly describeeach workeractivity. (2) - Either in the diagramor in the text field l(b) below, provide the identity, the approximate weight (by kg/day or kg/batch, atan 100%new chemical substance basis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Includo cleaning chemicals (notefrequency if not used daily or per batch) . (3) - Either in the diagramor in the text field i (b) below, ide

## n

tify by number the points ofrelease, includingsmall or intermittent releases. to the environment ofthe new chemical substance. (4) Please enter the# ofsites (remember to identify the locations ofthese sites an a continuation sheet) ; 

## Z5 ~ !I 

## CBI ofsites 

# u

PARTS FROM 

## ANODIZING TANK

Process Imported to Distribution Metal Tank Rinse Seal Tank Finished the US in Center Finisher 5 g/Itr . Water Dye is Part 

## 2, 5or 10 dissolved locked in shipped to lb. bags in water coating customer

i (b) . (Optional) This space is for a text description to clarify the diagram above.

0 Mark (X) this box ii' you attach a continuation sheet . 13PA FORM

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

## PMN Page 10a ; Page 15 of 18 

## p. 15

2. Worker Exposure/Environmental Release (1) --Fromthe diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) - Estimate the number ofworkers 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 formof exposure and % new chemical substance (ifin mixture), and any protective equipmentand engineering controls, if any, used to protect workers . (7) -Estimate the percent of the new substance as formulated when packaged or used as a final product . (9) --From the process diagram above, enter the number of each release point . Complete 9-13 for each release point identified. (10) -Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology tothe 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 fromthe operation. (3 ) , (5), (8 , (11) , 13 and 15 -- Mark X this column if an of thep roceeding entries are confidential business information (031 ) 

### ette of 

### 4 of Workers 

### CBI Duration Of CBI . Protective Equip. /Engineering Controls/Physical Formand/ % new substance 

### ~ m CBIActiviTy, Exposed Exposure Formulation (1) (2) (3) 2C C a 4a

?,vt ; 4b

_Jt_ ;a (5)

~ 6 Safety glasses/pH monitoring/Powder dissolved in water/O .Sg (7) 0 .5% (g) 

# F11 I F11



# _ a o 

# - a

Rele a 

# 0

mou 

# 0 o

se Number A nt of New C7B1 

## Media of Release &Control Technology I 

## CB1 Substance Released 9 108 106 11 12 13 POTW

14) -- Byproducts : (15) None a Mark (X) this box ifyou attach a continuation sheet,



# OPTIONAL POLLUTION PREVENTION INFORMATION To claim

information in the following section as confidential circle or bracket the specific information that you claimas confidential In this section you may provide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMNsubstance. 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 ofchemical 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 fromwastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or non- environmental areas (e.g., occupational or consumer exposure) . In addition, information on the relative cost or performance characteristics of the PMN substance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the reviewof this substance. See PMNInstructions Manual and Pollution Prevention Guidance manual for guidance and exa mples. EPA FORM

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

## p. 16 PMN Page 11 ; Page 16 of 18 Optional Pollution Prevention Information (Continued) Describe the expected net benefits, such as (1) an overall reduction in risk to human health or die environment ; (2) a reduction in the Volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other ntcans: (-l) a reduction in potential toxicity or human exposure and/or enviromnental release; (5) an increase in product perfonnance, 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 simi!ar 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 emiromnent. CB1 

# O

EP :\ PORA17710-25 (Rev. 5-95) P3ze 11

## p. 17 PMN Page 12 ; Page 17 of 18 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand test data and other data (including physical/chemical properties and sttucture/activity information), and optional information afterthis page. Clearly identify the attachment and the section of the form to which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the column below, enter the inclusive page numbers of each attachment . Electronic attachments can be identified by filename. Mark (X)the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized version of an attachment in which y ou claiminformation as confidential . # Attachment name Attachment Filename Attachment e num s Confidential

2

( uMark (X) this box if you attach a continuation sheet Enterthe attachment name and number . EPA FORM

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

## p. 18 PMN Page 13 ; Page 18 of 18 PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property, the units in which the property is measured (as necessaryX and whether or not the property is claimed as confidential . Ifthe attachments are electronic, give the attachment number (found on page 12) at (b). 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 measuredformixtures or formulations should be so noted (% PMNsubstance in .__) . You are not required to submit this worksheet; however, EPA strongly cecommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected. You should submit this worksheet as a supplement to our submission of test data. This worloheet is not a substitute for submission of test data . property k (X it Page number Value Measured E.gtimate (a) ~Y (b) (e) M or E Mark (X)

(d) 

### El ~

0 Ph ysical state of neat substance 

# -( s

# ) 1 

## Vapor pressure N/A ° Q N/A C Tem perature Torr

~ NK E :1 Densi ty/relative density cm3 Solubility 

# _

Temperature °C Solvent N/A 9/1- 

## Solubili ty in water Tem p erature 20 °C F-1 

# I SO 

# 9/1- 0 NK ° Melting tem

p erature C F~ N/A Boili ng / sublimation tem rature @torr p ressure °C Spectra



## ~ NK Dissociation constant E] NK Particle size distribution F-1 NK Oetanol / Water partition coefficient Henry 's Law

constant F-1 NK Volatilization from water E] None F-1 NK Volatilization from soil pH ( d . ) - 5 .5 6 .0 Flammability ~ Not Flammable Ex lodabilit a Not Explodable 

### F-1 NK Adso rption / coefficient 

## Other - S pecif y Other - Specify

ro Mark (X) this boxif you attach a continuation sheet Enterthe attachment name end number 

## ATTACHMENT PAGE 13