• You must provide an information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. Before you complete this form, you shOUld read the "Instructions Manual for PremanufactureNotification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554·5603). Ifa 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·226), P.O. 

## U.S. ENVIRONMENTAL PROTECTION AGENCY 

# ft

# ~EPA

\\ I" II**U11)11~kt,-d** ",--11...1 lhh I(lllll ill Enterthe total numberofpages in the Premanufacture Notice

360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee. Part 1- GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name ofthe new chemical substance, even ifyou claim the identity as confidential. You may authorize anotherperson 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 ofyour submission should reference your TS user fee identification number. You must submit an original and two copies ofthis notice inclnding all test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Ifthere are several manufacture, processing, or use operations to be described in Part II. sections A and Bofthis notice, reproduce the seetions as needed. Part 111- LIST OFATTACHMENTS Attaeh additional sheets ifthere is not enough space to answer a question fully. Label each continuation sheet with the corresponding section heading. In Part Ill, lis! these attachments, any test data or other data and any optional information included in the notice.
OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page II ofthis form, space has beenprovided for you to described 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 section. such as use, production volume, protective equipment. .. This option is intended to reduce delays that routinely accompany the development ofconsentorders or Significant New Use Rules. Except in the case ofexemption applications (such as TMEA. L VE, LOREX) where certain information provided in such notification is binding on the submitterwhen the Agency approves the exemption application. checking a binding box in this notice**~** by itselfprohibit the submitter from later deviating from the information (except chemical identity) reported in the form. CONFlDENTIALl1Y CLAIMS You may claim any infurmation in this notice as confidential. To assert a claim on the form, mark (Xl 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. !fyouclaim infOnnatjon in !he notices as confidential you must also provide a sanitized version of!he notice (jnc!udjng attachments). For additional instructions on 

# SANITIZED 

# PREMANUFACTURE NOTICE FORNEW CHEMICAL SUBSTANCES DOCUMENTCONTROL OFFICER OFFICE OF POLLUTION PREVENTION ANDTOXIC SUBSTANCES, 7407 U.S. E.P.A. 401 M STREET, SW WASHINGTON D.C.2 60

TEST OATA AND OTHER DATA You are required to submit all test data in your possession or control and to provide a description ofall otherdata known to or reasonably ascertainable by you, ifthese data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, or disposal ofthe new chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English), not summaries ofdata, must be submitted ifthey do not appear in the open literature. You should clearly identitY whether test data is on the substance or on an analog. Also, the chemical composition ofthe tested material should be characterized. Following are examples oftest data and other data. Data should be submitted according to the requirements of§720.50 ofthe Premanufacture Notification Rule (40 CFR Part 720). Test Data (Check Below any included in this notice) Environmental fate data DYes • Other data 

### I:lSI Yes Health effects data DYes Risk assessments Environmental effects data DYes Structure/activity relationships Physical/Chemical Properties· DYes Test data not in the possession or control ofthe submitter • Aphysical and chemical properties worksheet is located On the last page ofthis fOrm. 1YPE OF NOTICE (Check Only One) 

# r8l 

# o o o o 

# o o FormA 

# AGENCY USE ONLY Date ofreceipt 

# 25 

# r**~** 

# G: I? "**~** I..... 

# Company Sanitized

PMN (Premanufacture Notice) lNTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (Low Volume Exemption)@40CFR 723.50(c)(l) Co.) 

## o LOREX (Low Releaseil,ow Exposure Exemption) @40 C;§..**723.~** 

## :::c _rrl LVE Modification 

# o WREX

## Modifi~n (J 

### CI claiming information as confidential, read the Instructions Manual. IS THIS ACONSOLIDATED PMN? Yes 

# o Mark (xl ifany infurmation in this notice is claimed as confidential. # ofchemicals Prenotice Communica tion # re uired, enter # on a 3
EPA FORM 7710-25 (Rev. 5-95) Page 1

### Publicreporting burden for this collection ofinfonnation is estimated to average 110 hours perresponse, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of infonnation. Send comments regarding the burden estimate orany other aspect ofthis collection ofinformation, including suggestions for reducing this burden, to Chief, Infonnation Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 20460' and to the Office ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington D.C. 20503. 

# CERTIFICATION I certify that to the best ofmy knowledge and belief: 1. The company named in Part I, section A, subsection la ofthis notice form intends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in PartI, Section B. 

### 2. All information provided in this notice is complete and truthful as ofthe date ofsubmission. 3. I am submitting with this notice all test data in mypossession or control and a description ofall other data knO\Vll to or reasonably ascertainable byme as requiredby §720.50 ofthe Premanufacture Notification Rule. Additional Certification Statements: Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: 

# IZI The Company named in PartI, Section A 

## has remitted the fee of$2500 specified in 40 CFR 700,45(b), or 

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

### 40 CFR 700.43) in accordance with 40 CFR 700,45(b), or 

# D The Company named in Part I Section A is a small business concern under40 CFR 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 40 CFR 723.50(c)(l) or a Low release and low exposure exemption (LoRex) application 

### in accordance with40 CFR 723.50(c)(2), check the following certification statements: 

# D The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other 

## than in small quantities solely for research and development, under the terms of40 CFR 723.50. 

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

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

# D Ifthis application is for anLVE 

### in accordance with 40 CFR 723.50(c)(I), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year ofthe date ofthe expiration ofthe 30 day reviewperiod.

The accuracy ofthe statements you make in this notice should reflect your best prediction ofthe lIDticipated facts regarding the chemical substance described herein. Any knowllll and willful misinterpretation is subject to criminal penalty pursuantto 18 USC 1001. Confidential Signature and title ofAuthorized Official (Original Signature Required) 

### Toxicologist Date Signature ofagent (ifappJicabJe) Date

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

### SUBMITTER la. Person Submitting Notice (in U.S.) Company Mailing address (numberand street) City, State, ZIP Code Name ofauthorized official Company address (number and street) Telephone Area Code Number City, State, ZIP Code

c. Ifyou are submitting this notice as part ofajoint submission, mark(X) this box.

_______________________ applicable)

2. Technical Contact (in U.S.)

## r;;a~m~e;-;o;jf:-;a;;;u;tithi;;o:;;n:;;·z;ed~o;tffifilccii8all------------l**jJ,Jo~i:;;ntt &ib;:;;:;tt;;;(if-~N**  Position Company Mailing address (numberand street) City, State, ZIP Code Telephone 

### Area Code Number Name ofauthorized official

Mailing address (number and street) City, State, ZIP Code Telephone 

### Area Code Number
3. Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number. 4. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this substance enter the PMN number assigned EPA (i.e. withdrawn or' 5. have Bona intent to manufacture or import for the chemical substance covered by this notice, enter the notice number assigned by EPA. I. Manufacture 2. Import 6. Type ofNotice
- Mark (X) Only Only Mark(X) ifnone Mark (X) ifnone Mark(X) ifnone 3. Both 

# D D Binding Option 

# D Binding Option

EPA FORM 7710-25 (Rev. 5-95) Page 3substance based on Mark (X) the "Confidential" box next to any item you claim as confidential Complete either item I (Class I or2 substances) or2 (Polymers) as appmpriate. Complete all otheritems. Ifanotherperson will submit chemical identity information for you (for either Item 

### I or

### 2), mark (X) the box at the right. ConfiIdentifY the name, company, and address ofthat person in a continuation sheet. 

# o dential I. Class I or2 chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class ofsubstance
- Mark (X) I 

# 0 Class I or 2 

# 0 Class 2 b. Chemical name (Currently correct Chemical Abstracts (CAl Name that is consistent with TSCA Inventory listings for similar substances. ForClass I substances a CA Index Name must beprovided. ForClass 2 substances eithera CA Index Name orCA Preferred Name mnst beprovided, which everis appropriate based on CA 9CInomenclature rules and conventions). 

# NA

c. Please identifY which method you used to develop orobtain the specified chemical identity information reported in this notice: (check one). 

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

# 0 Method 2 (OtherSource) report obtained from the CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula and CAS Registty Number(ifa number already exists for the substance) CAS# 

# NA

e. For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance
- (I) List the immediate precursor substances with theirrespective CAS Registty Numbers. (2) Describe the nature ofthereaction orprocess. (3) Indicate the range ofcomposition and the typical composition (where appropriate). (4) Provide a correct representative orpartial chemical structure diagram, as complete as can beknown, ifonecan bereasonably ascertained. 

# NA

attach a continuation sheet.
EPA FORM 

### nlO-25 (Rev. 5-95) Page 4

## x XConfidential a. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymeryou intend to manufacture. Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500 and below 1,000 absolute molecularweight ofthat composition. Describe the methods ofmeasurement orthe basis for your estimates: GPC

# D Other 

# D: (Specify) i) lowest number average molecular weight: ii) maximwn weight % below 500 molecular weight: iii) maximwn weight % below 1000 molecular weight: attach a continuation sheet. b. You must make separate confidentiality claims for monomer orother reactant identity, composition information, and residual information. Mark(X) the "Confidential" box next to any item you claim as confidential (I)
- Provide the specific chemical name and CAS Registry Number (ifa nwnberexists) ofeach monomer orotherreactant used in themanufactureof the polymer. (2)
- Mark (X) this column ifentry in column (I) is confidential. (3) Indicate thetypical weight percent ofeach monomer orotherreactant in thepolymer. (4) Mark(X) the identity colunm ifyou want a monomeror other reactant used attwo weight percent orless to be listed as part ofthe polymer description onthe TSCA Chemical Substance Inventory. (5)
- Mark(X) this colunm ifentries in columns (3) and (4) are confidential. (6)
- Indicate the maximwn weightpercent ofeach monomerorotherreactant that may bepresent as a residual in the polymer as manufactured for commercial purposes.



## X X X 

## X X X 

## X X X 

## X X X % % % Mark (X) this box ifyou attach a continuation sheet. c. Please identify which method you used to develop orobtain the specified chemical identity information reported in this notice (check one). 

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

# D Method 2 (other source) obtained from CAS Inventory Expert Service must be submitted as d. The currently correct Chemical Abstracts (CA) name for thepolymer IS consistent with TSCA Inventory listings for similar polymers.
e. Provide a correct representative orpartial chemical structure as complete as can beknown, ifonecan bereasonably ascertained

attach a continutation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 5

## Part I -- 

# GENERAl" INtUKMA'I1UN --**Continu~d** Section 

### B- 'AI, 111M'! II Y 

### IATION _. 3. Impurities (a) 

# - Identify each impurity that may be reasonably anticipated to bepresent inthe chemical substance as manufactured for commercial purpose, the CAS Registry Numberifavailable. Ifthere are unidentified impurities, enter "unidentified." (b)
- Estimate the . I**wei~ht** 

### % ofeach impurity. Ifthereare unidentified estimate theirtotal weight 

### %. Impurity and CAS Registry Number Maximum percent (a) (b) 

### % 

## NONE % % % % % % 

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

### 4. Synonyms Enter any chemical synonyms for the new chemical identified in subsection I or2, 

## NONE 

# 0 Mark (X) this box ifyou attach a continuation sheet. 5, Trade identification
- List trade names for the new chemical substance identified in subsection I or2. Provide Confi­

. dential

Confidential



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

### 6. Generic chemical name - Ifyou claim chemicalidentify as confidential, you must providea generic name for your substance that reveals the specific chemical identity ofthenew chemical substance to themaximum extent possible. Referto the TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

# M
Unsaturated polyester 

# 0 Mark (X) this box ifyou attach a continuation sheet. 7. Byproducts Describe any byproducts resulting from the manufacture, processing, use, ordisposal ofthe new chemical substance. Providethe CAS Registry Number 

### ifavailable. CAS**Regis~** Number Confi­ 

# UYP(O"'v, (2) dential 

# X



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

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

## X

# 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 maximumproduction volume during the first 12 months ofproduction. Also estimatethe maximum production volume for any consecutive l2-month periodduring thefirst three years ofproduction. Estimates should beon 100% new chemical substancebasis. For a Low Volume Exemption application, ifyou choose to haveyournoticereviewed at a lower production volume than 10,000kg/yr, specify the volume and mark (x) in thebinding box. Ifgranted, you arebound to this volume Maximum

### first 12-monthproduction (kglyr) Maximum 12-monthproduction (kglyr) Conti- Binding 

### (100% new chemical substance basis) 

### (100% new chemical substance basis) dential Option Mark (xl 

## X 2. Use Information
-- Youmustmake separate confidentiality claimsfor the description ofthe category ofuse, the percent ofproduction volume devoted to each category, the formulation of the new substance, and otheruseinformation. Mark (X) the "Confidential" Box nextto any item you claim as confidential. a. 

### (I) -­ Describe each intended category ofuse ofthe new chemical substance by function and application.. (2)
-­ Mark (X) this column ifentry column (I) is confidential business information (CBI). 

### (3)
-­ Indicate your willingness to havethe information provided in column (I) binding. (4)
-­ Estimate thepercent oftotal production for the first three years devoted to each category ofuse. 

### (5)
-­ Mark 

### (X) this column ifentryin column (4) is confidential business information (CBI). (6)
-­ Estimate thepercent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, orgels as manufactured for commercial purposes at sites under your control associated with each category ofuse. 

### (7) Mark 

### (X) this column ifentry in column (6) is confidential business information (CBI). (8)
-­ Indicate % ofproduct volume expected for the listed ''use'' sectors. Mark more than onebox ifappropriate. Mark 

### (X) to indicate your willingness to havetheusetype provided in (8) binding. (9)
-­ 

### Mark (X) this column ifentry(ies) in column (8) is are) confidential business information (CBI). Category ofuse ( I ) CBI Binding 

### Produc- CBI %in 

# 1: % ofsubstance expected peruse CBI Option 

### tion % Form­ (8) 

### (by function and application i.e. a dispersive Mark (x) 

### ulation Site- Con-* Indus- Com- Binding dye for finishing polyester fibers) (2) (3) 

### (4) (5) (6) 

### limited sumer trial merciaI OPtion (9) 

## X 0/0 

## X X X % % % % % % % % % % % % * Ifyou have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consuroerproducts.

In addition include estimates ofthe concentration ofthe new chemical substance 

### as expected in consumerproducts and describe the chemical reactions bywhich this substance loses its identity in the consumerproduct. 

# o Mark (X) 

### this box ifyou attach a continuation sheet. b. Generic Ilf**y:.~~~~~:y** 

### category ofuse description in subsection 2a 

### as confidential, enter ageneric description ofthat category. Read the use Manual for examples ofgeneric use descriptions. description 

# Open, dispersive - used in molding operations 

# o Mark (X) 

### this box ifyou attach a continuation sheet. 3. Hazard Information
­ Include in the notice a copy ofreasonable facsimile ofany hazard warning statement, label, material safety data sheet, or other Binding



### information which will be 

### provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment orpractices Option 

### for the safe handing, transport, use, ordisposal ofthe new substance. List inpart illhazard 

### informationyou include. Mark (x)



### Mark (X)

### this box ifyou attach hazard information.

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

### Page?

# x Part 11-­ Complete section A for each type ofmanufacture, processing, oruse 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 havereporting requirements if use after You must describe these Seeinstructions manual ofthe site at which the will occur. box next to any item you



### Confidential
Site address (number and street) City, County. State, ZIP code 

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

## X Use 

## X substance) 2. Continuous d. Process description Mark (X) to indicateyourwillingness to have yourprocess description binding. 

## X (I) Diagram the majorunit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails,S5 gallon drum, rail car, tank truck, etc.). (2) Provide the identity, the approximate weight (by kg/day orkglbatch on a 100% new chemical substancebasis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch.). (3) Identify by number the points ofrelease, including small orintermittent releases, to the environment ofthe new chemical substance.

attach a continuation sheet. 

### sites

Hourslbatch
(100% new chemical Hourslbatch Batches/year Batches/year

EPA FORM 

### n1O-25 (Rev. 5-95) 

### Page 8

## Part 

# 11-- HUMAN EXPOSURE AND 

# ENVIRONMENTAL RELEASE
-- Continued Section A - INDUSTRIAL SITES CONTROLLED BY 

## THE SUBMITTER
-- Continued 

# I 2. Occupational Exposure
- You must make separate confidentiality claims for the description ofworker activity, physical fonn ofthe new chemical substance, number ofworks exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any item you claim as confidential. (I) 

### Describethe activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2)
-- Mark (X) this column ifentry in column (I) is confidential business information (CBl). (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 fonn(s) ofthe new chemical substance (e.g., solid: crystal, granule, powder, ordust) and % 

### new chemical substance (ifpart ofa mixture) at the time ofexposure. (7)
--

### Mark (X) this column ifentry in column (5) is confidential business information (CBI). (8)
-- Estimate the maximum numberofworkers involved in each activity for all sites combined. (9)
-- Mark (X) this column ifentry in column (8) is confidential business information (CBl). (10) and (II)
-- Estimatethe maximum duration ofthe activity for any worker in hours perday and days peryear. (12)
-­ Mark (X) this column ifentries in columns (10) and (11) are confidential business information (CBI). Worker activity CBI 

### Protective Equipment! Binding Physical fonns(s) Binding CBI 

### #of CBI Maximum duration 

### cm (i.e., bag dumping, filling drums) Engineering Controls Option and % new Option 

### Workers Hrsiday Daysiyr Mark (x) substance Mark (x) 

### Expose (I) (2) 

### (3) (4) (5) 

### (6) (7) 

### d (9) (10) (1\) (12) (8) 

## X X X X X X X X


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

### 3. Environmental Release and Disposal
-- You must make separate confidentiality claims for the release number and the amount ofthenew chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claim as confidential. (I) -"Enter the numberofeach release point identified in the process description, part II, section 

### A. subsection Id(3). (2) Estimatethe amount ofthe new substance released (a) directly to the environment or(b) into control technology (in kg/day orkglbatch). (3)
-- Mark (X) this column ifentries in columns (I) and (2) are confidential business information (CBl). (4)
-- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site oroff-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, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. Forreleases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whetherthe waste is subject to secondary ortertiary on-site treatment. b. Estimate the amount released to the environment aftercontrol technology (in kg/day). (6)
--Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBl). (7)
-- Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publici Owned Treatment Works). Mark (X) ifthe POTW name orNPDES # 

### is confidential business information (CBl). Release Amount ofnew substance CBI Media of 

### Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

### Number released release

(I) 

### (2a) (2b) e.g, stack air Binding (3) 

### (4) (Sa) Mark (X) 

### (5b) (6) 

## X X X X

(7) Mark (X) the 

# D POTW provide name(s) below: CBI 

# D Navigable 

# D Other
- Specify provideNPDES # CBI



# - destination(s) of waterway releases to water. 

# D Mark (X) this box if

### you attach a continuation sheet.

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

### Page 9

# Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE
-- Continued Section B
-- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B for typical processing 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 chemicalsubstance. Ifthe same operation is performed at more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet. 1. Operation Description
-- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. (1)
-- Diagram the majorunit operation steps and chemical conversions, including interim storage and transport containers (specify
- e.g. 5 gallon pails, 55 gallon drums, rail cars, tanktrucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2)
-- Provide the identity, the approximate weight (by kg/day orkgibatch, on an 100% new chemical substancebasis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch). (3)
-- Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enter the # ofsites (rememberto identify the locations of these sites on a continuation sheet). 

# 1-10 # ofsites 

# See attachment



# I:8J Mark (X) this box ifyou attach a continuation sheet. 2. Worker Exposure/Environmental Release (I)
-- From the 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 ofexposure perworker in (a) hours per day and (b) days per year. (6)
-- Describe physical form ofexposure and % new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7)
-- Estimate the percent ofthe new substance as formulated when packaged orused as a final product. (9)
-- From the process diagram above, enterthe number ofeach release point. Complete 9-13 for each release point identified. (10)
-- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day orkgibatch). (12)
-- Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site oroff-site land or incineration, POTW, orother (specify) and control technology, ifany, that will be used to limit the release ofthe new substance to the environment. (14)
-- Identify byproducts which may result from the operation.

(3), (5), (8), 11), (13) and (15)
-- Mark (X) this column ifany ofthe proceeding entries are confidential business information (CBI). Letter

ofActivity (I) # of Workers Exposed

(2) CBI
(3) Duration of Exposure CBI
(5) Protective Equip. / Engineering Controls/ Physical Form and % new substance (6) %inFonnulation

(7) CBr
(8) Release Number

(9) Amount of New Substance Released CBI
(11) Media ofRelease & Control Technology (12) CBI
(13) (4a) (4b) (lOa) (lOb) 

## X X X X X X X X X X X X

14)
-- Byproducts: (15) 

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

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

# 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 mayprovide information not reported elsewhere in this form regarding your efforts to reduce orminimize potential risks associated with activities surroundingmanufacturing, processing, use and disposal ofthe PMN substance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and safer processes orproducts available due to the new chemical substance. Source reduction includes the reduction in the amount ortoxicity ofchemical wastes bytechnological modification, process and proceduremodification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to thereclamation ofuseful chemical components from wastes that would otherwisebetreated orreleased as air emissions orwater discharges, orland disposal. Descriptions ofpollution prevention, source reduction and recycling should emphasizepotential risk reduction subsequent to compliance with existing regulatoryrequirements and can be eitherquantitative orqualitative. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks to other environmental media ornon-environmental areas (e.g., occupational or consumer exposure). In 

## addition, information on the relative cost orperformance characteristics ofthe PMN substance to potential alternatives maybeprovided. 

# All information provided in this section will be taken into consideration duringthe review ofthis substance. See Instructions Manual and Pollution Prevention Guidance manualfor guidance and examples. Describe the expected net benefits, such as (I) anoverall reduction in riskto human health or the environment; (2) a reduction inthe volume manufactured; (3) a reduction inthe generation ofwaste materials through recycling, source reduction or other means; (4) a reduction inpotential toxicity orhuman exposure and/or environmental release; (5) an increase inproduct performance, a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance maybe a substitute for an existing substance that poses a greater overall riskto humanhealth or. the environment.



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

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

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe form and test data and other

### data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section oftheform to which it relates, ifappropriate. Number consecutively thepages ofthe attachments. In the column below, enterthe inclusivepage numbers ofeach attachment. Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on how to claim any information in an attachment as confidentiaL You must include 

### with the sanitized copy ofthe notice form a sanitized version ofany attachment in which vou claim information as confidentiaL Attachment name Attachment na!!e number(s) 

### Confidential



## X X X X X



# D Mark (X) 

### this box ifyou attach a continuation sheet. Enterthe attachment name and number.

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

# PAGES 13-32 CONFIDENTIAL BUSINESS INFORMATION

EPA 

### FORM 7710-25 (Rev. 5-95) Page 13