PMN Page 1 ; Page 1 of 18 p~ 1 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

My, Iae 

+t 

ES 

in the Premanufacture Notice 

PREMANUFACTURE 

NOTICE 

18 

GENERAL INSTRUCTIONS 

Form Approved O.M.B . No. 2070-0 012. Approval Expires 10-31-96. 

Date of-pt 

AGENCY USE ONLY 

~-+ 

Company Sanitized 

'rjpffllm r I 1 to .D~s~'+ 

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 data. 

Before you complete this form, you should read the "lrotructions Manual for Pretinanufacuue Notification" (the Insttivctiosts manual is available from the Toxic 

Substances Control Act (TSCA) lrd'ormation Service by calling 202-554-1404, or faxing 202-554-5603). 

If a user fee has been rernitted 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 rernittance, which is sent to EPA, Washington Financial Management Center (3303), P.O. 

360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee. 

Part I - GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name 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, 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 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 operafices to be described um Part Il, 

sections A and B of this notice, reproduce the sections as needed. 

Part III -- LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully. Label each 

continuation sheet with the corresponding section heading, In Part Fit, list these 

attachments, any test data or other dam and any optional information included in the notice . 

OPTIONAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance On page 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, L VF, 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 tile 

form, mark (X) the confidential box next to the information that you claim as confidential 

To assert a claim in an attachmerS, cirde or bracket the information you claim as 

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 

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

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 em+irormental effects on the 

manufacture, processing, distribution in commerce, use, or disposal of the new 

chemical substance. Standard literature citations may be submitted for data in the 

open scientific literature. Complete test data (written in Snglish), 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 Premarntfacture Notification Rule (40 CFR 

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 

uu u10 1 R-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) 

I NUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Applimtion) 

L VE (Low Volume Exemption) @ 40 CFR 723 .50(c)(1) 

LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.5Q(c)(2) 

1-1 

LVEModification ~ LOREX Modification 

IS THIS A CONSOLIDATED 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 of this 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 of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, 

Section B. 

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

3 . I am submitting with this notice all test data in my possession or control and a description of all other data known to or 

reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 

Additional Certification Statements : 

If you are submitting a MIN, Intermediate PMN, Consolidated PMN, or SNLJN, check the following user fee certification 

statement that applies: 

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

F1 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined (a~ 40 CFR 

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

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b) . 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(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 

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

0 If this application is for an LVE in accordance with 40 CFR 723.50(cXl ), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within I year of the date of the expiration of the 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. Any hnowin and widral misinte tation is subject to criminal pe na lty pursuant to 18 USC 1001. Confidential 

Signature and title of Aidhorized Official (Onginal Signadae Requited) Date 

EKI 

Sigtratise of agent -(if applicable) Date 

EPA FORM 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 ofl icial 

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 (number and street) 

City, state Postal Code c,u1 : t 

c. If you are submitting this notice as part of a joint 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 

if none Ej 

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) - 

number assigned by EPA (i .e . withdrawn or incomplete) if none F 

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 claim as 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 CA nomenclature rules and conventions . Mark the "Confidential" box next to an item you 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, company, and address of that on in a continuation sheet. 

dential 

1 . Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substan see the instructions Manual) 

a. Class of substance - Mark (X) Class 1 or Class 2 

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, 

- 

which ever is appropriate based on CA 9C I 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 from the CAS Inventory Expert Services must be 

submitted as an attachment to this 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 structure diagram. For a class 2 substance, provide a correct representative or 

partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained . Please see the F-PMN Instruction Manual for ~/ 

discussion of "native format" diagram software which can be helpful in reviewing your substance / 

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

EPA FORM 7710-25 (Rev . 5-95) Page 4 
PMN Page 4a ; Page 5 of 18 

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). 

e. (1) List the immediate precursor substances ivith their respective CAS Registry Numbers. ConfiName (CAS ~) dential 

F~ 

N/A 

e. (2) Describe the nature of the reaction 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 you attach a continuation sheet. 

EPA FORM 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-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates : C,PC U Other U : (Specify below) 

(i) lowest number average molecular weight: 

(ii) maximum weight °l° 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 man ufacture 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 m the polymer. 

(4) - Choose "yes" from drop down menu 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 m the polymer as manufactured for 

commercial purposes . 

(7) - Mark (X) this column if en in column (6) is confidential. 

Monomer or 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 

% R 1-1 1 

% 

F-1 % 

0 % 0 1 1 0 % 

F ~ 

°,° 

1-1 1 

°.o 

ELI 

1F] % 

o o % % o o °% % o o o o 

°

% °

.° 

.° 

o o % % o o ~ 

°.o 

Mark (X) this box if you attach a continuation sheet. o °~ o % o 

EPA FORM 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 Inventory Expert Service - a copy of the identification report 

1L 

1 Method 2 (other source) 

obtained from CAS 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 TSCA Inventory 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 your substance. 

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

EPA FORM 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 weight % of each im purity. If there are unidentified impurities, estimate their total weight °/n 

Impurity and CAS Registry Number Maximum Confipercent dential 

a 

% 

I~J 

_ 

°io 

--__ % 

-. 

% 

% 

- _ 

% 

-- % 

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

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

~ _ ,d~~~~ 

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

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic 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. 

_

. . . 2, ___-~.__ .: .-_ 

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 

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, AND USE INFORMATION: 

Mark X the "Confidential" box next to an 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, if you 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 

i al ~ k °n 

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

--- 

a ]a] 

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 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 one box 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 % of substance expected per use CBI 

dispersive dye for finishing polyester fibers) oMP° 

x~ 

I 

uction 

%. 

Formu 

latton 

(8) 

(2) (3) (4) (5) (6) (7) site- C~- Indos- Com- Binding (9) 

limited imWc trial mercial Option 

Acid Dye for Coloring Anodized % u 

Aluminum X 100 

[] 

0-5% 1f10% 

111 1 

% 

11 

q% 

E_ 

111 1 

% 

ll 

--- % 

. ] [11 

11 111 1 

% 

11 

% 

11 111 

% 

1 Ll 

c% 

% % 

1 1 1 1 A P E 

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. 

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

b. Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the Instruction 

description Manual for examples of generic use descriptions . 

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

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

, i~_ ~`f. TG~ .~~_,_- '''K _-

.-.i . , .c, .. , ~7- . . . .~~ JE ._ . .,c..CE: : . a~_c,d?~ z~-w i ,. .,_ a 

- v_ .. . :C ., . ._i _ .~C .t_~ - a re __na ~c: ~;a. .~ ._d ~t=~ '_-he _ 

- - _ - k- - - -~ ..- . : _C3~ .:I :3 . y '- :: .^- _- -- " oa=ir _ ~~ ~=~_=d ~ c_ . . . a. . 

part . 

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

3. Hazard Information - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding 

- 

information which will be provided to any person who is reasonably Rely to be exposed to this substance regarding protective equipment or practices for ~ x) Mark 

the safe handing, transport, ~e, a disposal of the new substance. List in part III hazard information you include. 

Mark (X) this box if you attach hazard information. 

PMN Page 7 ; Page 9 of 18 

EPA FORM 7710-25 (Rev . 5-95) Page 7 
p. 10 

PMN Page 8 ; Page 10 of 18 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

Section A - INDUSTRIAL SITES CONTROLLED BY THE SUBMII'TER 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 ope rations after import . You must describe these operations . See instructions manual 

I . Operation description Confia . Identi ty -- Enter the identity of the site at which the operation will occur. dential 

Name 

Diversified Products Inc . 

Site address (number and street) 

1140 Memorial Park Road 

City, County, State, ZIP code 

Lancaster Lancaster SC 29721 

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

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

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

sites as attachments. 

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

b. Type 

Mark (X) Manufacturing x Proce ssing Use 

c . Amount and Duration -- Complete 1 or 2 as a ro riate 

Maximumkg/batch(i oownewct~.cat Hours/batch Batches/year 

subsmnoe) 

1 . Batch 50 1 50 

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 interim storage and transport containers (specify- e.g . 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). 

(2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical 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 (note frequency if not used daily or 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 if you 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- 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 works exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you 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 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 (?C) 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 yew. (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 gineering 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 if you 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 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 I d(3). 

(2) -Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). (3) -Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI). 

(4) - Identify the media (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 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 (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 (Publicly 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 

efficiency data 

(1) (2a) (2b) Bi di 

(3) (4) (Sa) 

n ng 

Mar` (5b) (6) 

N.`A 

E l 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 if you attach a continuation sheet. 

EPA FOKM 7710=25 (Re:" . 5-95) P3g-_ 93 
PMN Page 10 ; Page 14 of 18 

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 type of 

processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the typical operation common to these 

sites. Identify additional sites on a continuation sheet. 

1(a). Operation Description - To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. 

(1) - Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g . 5 gallon pails, 55 gallon drums, rail 

cars, tank trucks, etc). On the diagram, identify by low and briefly describe each worker activity. (2) - Either in the diagram or in the text field l (b) below, provide the 

identity, the approximate weight (by kg/day or kg/batch, at an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and 

catalysts, etc) and all products, recycle streams, and wastes . Includo cleaning chemicals (note frequency if not used daily or per batch) . (3) - Either in the diagram or in the 

text field i (b) below, identify by number the points of release, including small or intermittent releases. to the environment of the new chemical substance . (4) Please enter 

the # of sites (remember to identify the locations of these sites an a continuation sheet) ; Z5 ~ 

!I CBI of sites 

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, 5 or 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) --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, 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 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 an of the proceeding entries are confidential business information (031 ) ette 

of 

4 of 

Workers 

CBI Duration Of CBI . 

Protective Equip. /Engineering Controls/Physical Form and/ % new substance ~ m CBI 

Activ iTy, 

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) 

F1 1 I F1 1 

_ 

a o 

- 

a 

Rele a se 0 mou 0 o 

Number 

A nt of 

New 

C7B1 Media of Release & Control Technology I CB1 

Substance 

Released 

9 108 106 11 12 13 

POTW 

14) -- Byproducts : 

None (15) 

a Mark (X) this box if you 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 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 . Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or non- environmental areas (e .g ., occupational or consumer exposure) . In addition, information on the relative cost or performance characteristics of the PMN substance to potential alternatives may be provided . 

All information provided in this section will be taken into consideration during the review of this substance. See PMN Instructions Manual and Pollution Prevention Guidance manual for guidance and examples. 

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 em iromnent. 

CB1 

O 

E P:\ PORA 17710-25 (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 form and test data and other data (including physical/chemical properties and 

sttucture/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 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 claim any 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 you claim information as confidential . 

# Attachment name Attachment Filename Attachment 

e num s 

Confidential 

2 

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

EPA FORM 7710-25 (Rev. 5-95) Page 12 
p. 18 

PMN Page 13 ; Page 18 of 18 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice . Identify the property measured, the page 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 measured for mixtures or 

formulations should be so noted (% PMN substance in .__) . You are not required to submit this worksheet; however, EPA strongly 

cecommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should submit 

this worksheet as a supplement to 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) 

Physical state of neat substance El 0 -(s ) 1 ~ 

Vapor pressure N/A ° C Q N/A Temperature Torr 

Density/relative density ~ NK cm3 E:1 

Solubility 

_ 

Temperature °C 

Solvent N/A 9/1- 

Solubility in water Temperature 20 °C F-1 I

SO 9/1- 

0 NK Melting temperature ° C 

Boiling / sublimation tem rature @torr pressure F~ N/A °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 Adsorp tion / coefficient 

Other - Spe cify 

Other - Specify 

ro 

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

ATTACHMENT 

PAGE 13