• 	 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 if you do 

not have actual data. 

Before you complete this form, you shOUld read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554·5603). 

If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM·226), P.O. 

U.S. ENVIRONMENTAL PROTECTION AGENCY 


ft 

~EPA 

\\ I" II 

U11)11~kt,-d 

",--11...1 lhh 

I(lllll ill 

Enter the total number of pages 

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 of the new 

chemical substance, even ifyou claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A letter 

in support ofyour submission should reference your TS user fee identification number. 

You must submit an original and two copies of this 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 

If there are several manufacture, processing, or use operations to be described in Part II. 

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

Part 111- LIST OF ATTACHMENTS 

Attaeh additional sheets if there 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 of this form, space has been provided 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 of consent orders or Significant New Use Rules. 

Except in the case ofexemption applications (such as TMEA. LVE, LOREX) where 

certain information provided in such notification is binding on the submitter when the 

Agency approves the exemption application. checking a binding box in this notice ~ 

by itself prohibit 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. !fyou claim 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 

FOR NEW CHEMICAL SUBSTANCES 

DOCUMENT CONTROL OFFICER 


OFFICE OF POLLUTION PREVENTION 


AND TOXIC SUBSTANCES, 7407 


U.S. E.P.A. 401 M STREET, SW 


WASHINGTON D.C.2 60 


TEST OAT A AND OTHER DATA 

You are required to submit all test data in your possession or control and to 

provide a description of all other data known to or reasonably ascertainable by 

you, if these data are related to the health and environmental effects 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 

of data, must be submitted if they 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 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 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 of the submitter 

• A physical 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 of receipt 

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 A CONSOLIDATED PMN? o Yes

Mark (xl ifany infurmation in this notice is claimed as confidential. # ofchemicals 

Prenotice Communication # re uired, enter # on a 3 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 1 
Public reporting burden for this collection of infonnation is estimated to average 110 hours per response, including time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of 

infonnation. Send comments regarding the burden estimate or any other aspect ofthis collection of information, 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 of Management and Budget, Paperwork Reduction Act (2070-0012), Washington D.C. 20503. 

CERTIFICATION 

I certify that to the best of my knowledge and belief: 

1. The company named in Part I, section A, subsection la of this 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 knO\Vll to or 

reasonably ascertainable by me as required by §720.50 of the 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 Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700,45(b), or 

D The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (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 under 40 CFR 700,43 and has remitted a fee of $1 00 

in accordance with 40 CFR 700,45(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(l) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements: 

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

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50. 

D The manufacturer is familiar with the terms of this section and will comply with those terms; and 

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

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

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period. 

The accuracy of the statements you make in this notice should reflect your best prediction of the lIDticipated facts regarding the chemical substance 

described herein. Any knowllll and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001. Confidential 

Signature and title ofAuthorized Official (Original Signature Required) 

Toxicologist 

Date 

Signature of agent (ifappJicabJe) Date 

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

la. 	Person 

Submitting 

Notice (in U.S.) 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

Name of authorized official 

Company 

address (number and street) 

City, State, ZIP Code Telephone Area Code Number

c. If you are submitting this notice as part of a joint submission, mark (X) this box. _______________________ 

applicable) 

2. 	 Technical 

Contact (in 

U.S.) 

jJ,Jo~i:;;ntt&ib;:;;:;tt;;;(if-~Nr;;a~m~e;-;o;jf:-;a;;;u;tithi;;o:;;n:;;·z;ed~o;tffifilccii8all------------l Position 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

Name of authorized 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. 	 If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by 

EPA. If you previously submitted a PMN for this substance enter the PMN 

number assigned 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 of Notice - Mark (X) Only 	 Only 

Mark (X) 

if none 

Mark (X) 

if none 

Mark (X) 

if none 

3. D Both

D Binding Option D Binding Option 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 3 
substance based on 

Mark (X) the "Confidential" box next to any item you claim as confidential 


Complete either item I (Class I or 2 substances) or 2 (Polymers) as appmpriate. Complete all other items. 


If another person 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 of that person in a continuation sheet. o dential 

I. Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. Class of substance - 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. 


For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name mnst 


be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions). 


NA 

c. 	 Please identifY which method you used to develop or obtain 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 (Other Source) 


report obtained from the CAS Inventory Expert Services must be 


submitted as an attachment to this notice) 


d. 	 Molecular formula and CAS Registty Number (if a number already exists for the substance) 

NA CAS#

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 their respective CAS Registty Numbers. (2) Describe the nature ofthe reaction or process. (3) Indicate the 


range ofcomposition and the typical composition ( where appropriate). (4) Provide a correct representative or partial chemical structure 


diagram, as complete as can be known, ifone can be reasonably ascertained. 


NA 

attach a continuation sheet. 

EPA FORM nlO-25 (Rev. 5-95) 	 Page 4 
x X 

Confidential 

a. 	 Indicate the number-average weight of the lowest molecular weight composition ofthe 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: 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 or other 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 (if a nwnber exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

(2) 	 - Mark (X) this column if entry in column (I) is confidential. 

(3) 	 Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(4) 	 Mark (X) the identity colunm 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 colunm if entries in columns (3) and (4) are confidential. 

(6) 	 - Indicate the maximwn weight percent of each monomer or other reactant that may be present 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 if you attach a continuation sheet. 

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

rgJ 	 Method I (CAS Inventory Expert Service a copy of the 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 the polymer IS consistent with TSCA Inventory listings for similar polymers. 

e. Provide a correct representative or partial chemical structure as complete as can be known, if one can be reasonably 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 be present in the chemical substance as manufactured for commercial purpose, 

the CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

(b) 	 - Estimate the . I wei~ht % of each impurity. Ifthere are unidentified estimate their total 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 or 2, 

NONE 

0 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. 

Provide 

Confi­

. dential 

Confidential 

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

6. 	 Generic chemical name - Ifyou 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 


Unsaturated polyester 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 
 M

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

7. Byproducts Describe any byproducts resulting from the manufacture, processing, use, or disposal ofthe new chemical substance. Provide the CAS Registry 

Number if available. 


UYP(O"'v, CAS Regis~ Number 
 Confi­

(2) dential 

X 

[ ] Mark (X) this box if you 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 maximum production volume during the first 12 months of production. Also estimate the maximum 

production volume for any consecutive l2-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 kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume 

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Conti- Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dential Option 

Mark (xl 

X 

2. Use Information -- You must make separate confidentiality claims for the description of the category ofuse, the percent ofproduction 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. (I) -­ Describe each intended category of use of the new chemical substance by function and application.. 

(2) -­ Mark (X) this column ifentry column (I) is confidential business information (CBI). 

(3) -­ Indicate your willingness to have the information provided in column (I) binding. 

(4) -­ Estimate the percent of total production 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) -­ Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category ofuse. 

(7) Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) -­ Indicate % of product volume expected for the listed ''use'' sectors. Mark more than one box ifappropriate. Mark (X) to indicate 

your willingness to have the use type provided in (8) binding. 

(9) -­ Mark (X) this column if entry(ies) in column (8) is are) confidential business information (CBI). 

Category of use ( I ) CBI Binding Produc- CBI %in 1: % of substance expected per use 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 

% % 

% % 

% % 

% % 

% % 

% % 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consuroer products. 

In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which 

this substance loses its identity in the consumer product. 

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

b. Generic Ilfy:.~~~~~:y category of use description in subsection 2a as confidential, enter a generic description of that 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 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 likely to be exposed to this substance regarding protective equipment or practices Option 

for the safe handing, transport, use, or disposal ofthe new substance. List in part ill hazard information you include. Mark (x) 

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

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

Part 11-­

Complete section A for each type ofmanufacture, 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 

use after You must describe these See instructions manual 

of the 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, 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 infonnation requested in this section for those 

X 

Use 

X 

substance) 

2. Continuous 

d. Process description Mark (X) to indicate your willingness to have your process description binding. X 

(I) 	 Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails,S 5 gallon 

drum, rail car, tank truck, etc.). 

(2) 	 Provide the identity, the approximate weight (by kg/day or kglbatch 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 ofrelease, including small or intermittent releases, to the environment of the 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 of worker activity, physical fonn 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. 

(I) Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. 

(2) -- Mark (X) this column if entry 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) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart of a 

mixture) at the time of exposure. 

(7) -- Mark (X) this column if entry in column (5) is confidential business information (CBI). 

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined. 

(9) -- Mark (X) this column if entry in column (8) is confidential business information (CBl). 

(10) and (II ) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year. 

(12) -­ Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). 

Worker activity 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 if you attach a continuation sheet. 

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. 

(I) -" 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 kglbatch). 

(3) -- Mark (X) this column if entries 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 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 (CBl). 

(7) -- Identify the destination( s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publici Owned Treatment Works). Mark (X) ifthe POTW name or NPDES # is confidential business information (CBl). 

Release Amount of new 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 provide NPDES # CBI 

- destination(s) of waterway 

releases to water. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing 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 ofprocessing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typical operation common to these sites. Identify additional sites on a continuation sheet. 

1. Operation Description -- To claim information in this section as confidential, circle or bracket 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 letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight 

(by kg/day or kgibatch, on 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. 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. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet). 

1-10 

# of sites 

See attachment 

I:8J Mark (X) this box if you 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 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 kgibatch). 

(12) -- Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other 

(specify) and control technology, if any, that will be used to limit the release of the new substance to the environment. 

(14) -- Identify byproducts which may result from the operation. 

(3), (5), (8), 11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI). 

Letter 

of 

Activity 

(I) 

# of 

Workers 

Exposed 

(2) 

CBI 

(3) 

Duration 

of 

Exposure 

CBI 

(5) 

Protective Equip. / 

Engineering Controls/ 

Physical Form and % 

new substance 

(6) 

%in 

Fonnulation 

(7) 

CBr 

(8) 

Release 

Number 

(9) 

Amount of 

New 

Substance 

Released 

CBI 

(11) 

Media of Release 

& Control 

Technology 

(12) 

CBI 

(4a) (4b) (lOa) (lOb) (13)

X X X X 

X X X X 

X X X X 

14) -- Byproducts: (15) 

D Mark (X) this box if you 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 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 

ofthe 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 ofuseful 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 

ofrisks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics ofthe 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 Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (I) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured; (3) a reduction in the generation ofwaste materials through recycling, source reduction or other means; (4) a 

reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in 

the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical 

substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing 

substance that poses a greater overall risk to human health or. the environment. 

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 of the form and test data and other data (including physical/chemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section ofthe form to 

which it relates, if appropriate. Number consecutively the pages of the attachments. In the column below, enter the inclusive page 

numbers of each attachment. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidentiaL You must include with the sanitized copy of the notice form a sanitized 

version of any attachment in which vou claim information as confidentiaL 

Attachment name Attachment 

na!!e number(s) 

Confidential 

X 

X 

X 

X 

X 

D 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 
PAGES 13-32 


CONFIDENTIAL 


BUSINESS 


INFORMATION 


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