I ~ 11II1I1111I1 jlliljllil ~I~ llill ~lllllli tlilljillJII ~III JIII~ IIIII 

VI 1'1'- 1: VI' rVLLU IIUN PREVENTION 

AND TOXIC SUBSTANCES, 7407 

US EPA. 401 M STREET, SW 

WASH 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

ft Er. 

I

;'"': '"- ; !."! 1'"' F") 

D,C. 20460 

14 

GENERAL INSTRUCTIONS 

Sanitized 

You must provide all information requested in this form to the extent that il 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 trom thc 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. 

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

Part 1-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name oftile new 

chemical substance, even if you claim the identity as confidentiaL You may authorize 

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

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

letter in support of your submission should reference your TS user fee identification 

number. You must submit an original and two copies of this notice including all test data. 

[f you claimed any information as confidential, a single sanitized copy must also be 

submitted. 

Part II HUMAK EXPOSURE AND ENVIRONMENTAL RELEASE 

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

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

Part III LIST OF ATTACHMEI\TS 

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 Ill, list these 

attachments. any test data or other data and any optional infomiation included in the 

notice. 

OPTIONAL INFORMATION 

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

substance. On page I I ofthis fonn, space has been provided for you to described 

pollution prevention and recycling infomllltion you may have regarding the new 

substance, 

So-called "binding" boxes are included throughom this form lor 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 of exemption applications (such as TMEA, LYE, LOREX) 

where certain infomlation provided in such notification is binding 011 the submitter when 

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

d.ocs 110t 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 assen a claim On the 

fornI, mark (X) the confidential box next to the infannalion that you claim as 

confidential. To assert a claim in an attachment, circle or bracket the information vou 

claim as confidential. !LYQu claim information in the nOllces as qmfidentlai, yot) ;nust 

~9 provide a sanitized version orthe oo!!ce, (includn)gJill,,!,hmell!;;l For additional 

instructions on claiming information as confidentit.tI. read the Instruchons t\·lanuaJ, 

TEST DAT A A;>lD 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, ifthese data are 

related to the health and environmental effects on the manufacture, processing, flio.rih,..!innl 

in commerce, use, or disposal of the new chemical substance. Standard literature citations 

may be submitted for data in the open scientific literature. Complete test data (written in 

English), not summaries ofdata, must be submitted if theytlo not appear in the open 

literature. You should clearly identif'y 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 

the requirements of ~72050 ofthe Premanufacture Notification Rule (40 CFR Part 720) 

Test Data (Cheek Below any included in this notice) 

Environmental fate data DYes 	 Otherdala 0 Yes 

Health efTects data DYes 	 Risk assessments 

Environmental efTects data o Yes 	 Structure/activity relationships 

,.,..." 

Physical;Chemical Properties· o Yes 	 Test da~t in the possession 

or cOlltrCiiif the submitter 

""T1 ..... A phvsical and chemical properties worksheet is located all thftil;t page·iJIt £Ii!iJ form 

CO -:)~ 

TYPE OF ;';OTlCE (Check Only One) 	 - -=~ --1-'rn 


PM;'; (Premanufacture Notice) : t·' ';, 

o !:vrERMEDIATE PMN (submitted in sequence witl~1 productrlvfN) ... ; 

o o SNC'J (Significant New Use Notice) Ul 

o TMEA (Test Marketing Exemption Application) 

o LVE (Low Volume Exemption) i.'§ 40 CFR 723.50(c)(l) 

o lOREX (Low Release/Low Exposure Exemption) !~I' 40 CFR 723,50(c)(2) 

o I\,E \1 odi fication o LOREX Modification 

IS THIS A CONSOLIDATED PMN'! Yes 

t; of chemicals __ ______~ 

Mark (x) ifany infomlatioll in this notice" claimed as confidential. (Prellotice Communication # required, enter # on page 3) 

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

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

information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for 

reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 

20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

CERTIFICATION 

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

1. 	 The company named in Part I, section A, subsection 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 ofsubmission. 

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 ofthe Premanufacture Notification Rule. 


Additional Certification Statements: 

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


statement that applies: 


D 	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 $1 000 for an Intermediate PMN (defined @ 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 (L VEl application in accordance with 40 CFR 723 .50{c)(1 ) 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 of40 CFR 723.50. 


D 	The manufacturer is familiar with the terms ofthis 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 L VE in accordance with 40 CFR 723.50( c)( 1), the manufacturer intends to commence 

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

review period. 

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

described herein. Anv knowing and willful misinterpretation i$ subject to criminal penaltv pursuant to 18 lise 1001. Confidential 

Signature and title of Authorized Official (Original Signature Required) Date 

x 

Signature of agent (if applicable) Date 

x 

EPA FORM 77)0-25 (Rev. 5-95) 	 Page 2 
x 

Confidential 

la. Person 

Submitting 

Notice (in U.S.) 

b. Agent (if 

applicable) 

Company 

Mailing address (number and street) 

City, ZIP Code 

Name of 

Company 

Mailing address and street) 

City, State, ZIP Code Telephone 

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

Joint Submitter (if 

applicable) 

Name of authorized official 

Company 

Mailing address (number and street) 

2. Technical 

Contact (in 

U.S.) 

City, State, ZIP Code 

Name of authorized official 

Mailing address (number and street) 

City, State, ZIP Code 

3. If you commun 

and EPA assigned a PC Number to the notice. enter the number. 

: 4 !f you previously submitted all exemption application for the chemical 

sOOstance covered by this notice. enter the exemption number assigned by 

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

PMN number assigned by EPA (i.e. withdrawn or incomplete). ~ 

5. If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical suhstance covered by this notice. enter the notice number 

assigned by EPA. ~ 

I. 

6. Type of Notice Mark (X) 

D 

Manufacture 

Only 

Binding Option 

Mark 

Position 

Telephone 

Position 

Telephone 

Mark (X) 

ifnone 

Mark (X) 

ifnone 

Mark (X) • 

ifnone 

2. Import 3. Both 

Only 

0 Binding Option 

Mark (X) 

0 X 

0 X 

0 X 

EPA FORM 7710-25 (Rev. 5-95) Page J 
Complete ei 

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right Confithe and address of that in a continuation sheet dential 

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

a, 	 Class of substance - Mark (X) I Class I or 2 Class 2 

b. 	 Chemical name (Currently correct Chemical Abstracts (CA) 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 C A Index Name or CA Preferred Name must 
 x 

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

c, 	 Please reported in notice: (check one). 

D Method 1 (CAS Inventory Expert Service - a copy of the Identification Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

as an attachment to this 

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

x 

CAS# 

x 

e. 	 a class 1 substance, a complete and correct structure diagram For a class 2 immediate 


precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the 
 x 

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

diagram, as complete as can be known, if one can be reasonably ascertained. 

This page is not applicable. 

Mark (X) this box ifyOll attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 4 
x 

Confidential 

a. 	 Indicate the number-average weight of the lowest molecular weight composition of the polymer you 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 molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC 0 Other 0: (Specify) ___ 

i) lowest number average molecular wcight: 

ii) 	 maximum weight % below 500 molecular weight: 

iii) 	 maximum .weight % below 1000 molecular weight: 

attach a continuation sheet. 

must separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark the 

"Confidential" box next to any item you claim as confidential 

(I) 	 Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

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

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

(4) 	 Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) 	 Mark (X) this column if entries in columns (3) and (4) are confidentiaL 

(6) 	 Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes. 

Mark this column if en 

x x 

x x 

x x 

x x 

x x 

x x 

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 0 Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this 

x 

x 

x 

x 

x 

x 

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers. 

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

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

EPA FORM 7710-25 (Rev. 5-95) 	 Page 5 
Part I -- GENERAL INFORMATION -- Continued 

Secti~!IH -- CHEMICAlIDEN'nIY IN .. ' IwMA.TION Continued 

3. Impurities 

(a) 	 - Identify each impurity that may be reasonably anticipated to be present In the chemical substance as manufactured for commercial purpose. Provide the 

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

(b) 	 - Estimate the maximum weight % of each impurity. If there are unidentitled,,,f'u, ;';"" estimate their total weight %. 


Impurity and CAS Registry Number 
 Confipercent Maximum 

dential 

(a) (b)

X 

X 

X 

X 

X 

X 

X 

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

Confidential 

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

X 

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

5. Trade 'U"""""QUV" - List trade names for the new chemical substance identified in ",h",ctinn I or 2. 

X 

D 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 

TSC A Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

Alkyl ethoxylate 

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

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

Number if available. 


Bypr?duct 
 CAS Regis!ry Number 

(I) (2) ~e~~~~ 

X 

X 

X 

X 

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

EPA FORM 7710-25 (Rev. 5-95) 	 Page 6 
Part I -- GENERAL INFORMATION -- Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

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

1­ Production volume ­ Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for 

any consecutive 12-month period during the first three years of production. EstImates should be on 100% new chemical substance basis. For a Low Volume 

Exemption application, 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 (kg/JT) Maximum l2-month production (kg/yr) Confi- Binding 

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

Mark (x) 

X 

2_ Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production volume devoted to each 

category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next 10 any item you claim as confidential. 

a. (I) Describe each intended category of usc of the new chemical substance by function and application .. 

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

(3) Indicate your willingness to have the information provided in colunm (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 colunm (4) is confidential business information (CBI). 

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

purposes at sites under your control associated with each category of use. 

(7)­ Mark (X) this colunm if entry in colunm (6) is confidential business information (CBJ). 

(8) -­ Indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to 

have the use type provided in (8) binding. 

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

Category of use (l) Binding Produc­ %in % of substance expected per use 

CBI Option tion% CBI Form­ eBJ (8) CBI 

(by function and application i.e. a dispersive dye Mark (x) ulation Site- Con-* Indus- Com- Binding 

for finishing polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

X X X X 

X X X X 

X X X X 

X X X X 

X X X X 

X X X X 

X X X X 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the users) 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. 

OMark (X) this box iryou attach a continuation sheet. 

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

description Instructions Manual for examples of generic use descriptions. 

Surfactant 

0 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 likely to be exposed to this substance regarding protective equipment or practices Option 

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

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

EPA FORM 7710-25 (Rev 5-(5) Page 7 
each type 

use You must describe these 

I. 

attach a continuation sheet. 

Processing 

Part 11-­

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you 

claim as confidential 

processing, or use operation involving the new chemical substance at industrial sites you control. Importers do 

this section for operations outside the U.S.; however, YOll may still have reporting requirements if there are further industrial processing or 

See instructions 

Confiof the site at which the will occur. dential 

x 

Site address (number and street) 

City, County, State, ZIP code 

Ifthe same operation wi 11 occur at more than one site, enter the number ofsites. 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. 

b. 

Batches/year 

x 

I. 	 Batch 


Maximum kg/day (100% new 
 Hours/day Days/year 

chemical substance) x 

2. Continuous 

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

(I) 	 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 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 ifnot 

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. 

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

EPA FORM 77\o~25 (Rev 5-95) 	 Page 8 
r----. 

Part 11-- 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 contidential. 

(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 (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 formes) of the new chemical substance (e.g .• solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) 

at the ti me of exposure 

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

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

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

(10) and (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 (II) are confidential business information (CBI). 

Physical 

Worker activity CBI Protective Equipment! Binding forms (s) Binding CBI # of CBI Maximum Duration CBI 

(i.e., bag dumping, filling drums) Engineering Controls Option and % new Option Workers Hrs/day Days/yr 

Mark (x) substance Mark (x) Exposed 

(I) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12) 

X X X X 

X X X X 

X X X X 

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 Il, 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 (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, ifany, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). 

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

NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance Media of release 

Number released CBI e.g. stack air Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

(I) (2a) (2b) (3) (4) (5a) Binding (5b) (6) 

Mark (X) 

X X 

X X 

X X 

X X 

X X 

(7) Mark (X) the D POTW provide name(s) below: CBI D Navigable D Other ­ provide NPDES # CBr 

destination (s) of releases - waterway Specify 

to water --­ X X 

D Mark (X) this box i i' you attach a continuation sheet. 

EPA FORM 7710-25 (Rev 5-95) Page l) 
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 a/processing. or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

t}'!)ical 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. 

(I) -- 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 kglbatch, 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 ifnot 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): 

--­

# of sites 

Confidential Business Information has been removed. 

D 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- I 3 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 kglbatch). 

(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), (II), (13) and (15) -­ Mark (X) this column ifany of the proceeding entries are confidential business information (CBI). 

Protective Equip. / Amount of 

Letter # of Duration Engineering Controls/ %in New Media of Release 

of Workers of Physical Foml and % Foml- Release Substance & Control 

Activity Exposed CEI Ex,osure CBI new substance uIation CBI Number Released CBI Technology CEI 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (II) (12) ( 13) 

X X X X X 

X X X X X 

X X X X X 

X X X X X 

(14) -- Byproducts: (15) 

X 

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

EPA FORM 7710-25 (Rcv. 5-95) Page 10 
OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim infonnation in this section as confidential circle or bracket the specific information that you claim as confidential. 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce 

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal 

of the PMN substance. Please include new information pertinent to pollution prevention, including source 

reduction, recycling activities and safer processes or products available due to the new chemical substance. 

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological 

modification, process and procedure modification, product reformulation, raw materials substitution, andlor 

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 

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 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 Mannal and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the 

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

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

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

substances used in similar 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. 

Confidential Business Information has been removed . 

• D Mark (X) thIS box if you 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 of the form to 


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


numbers of each attachment. 


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


how to claim any information in an attachment as confidential. You must include with the sanitized copy ofthe notice form a sanitized 


version of any attachment in which you claim information as confidential. 


Attachment name 
 Attachment Contipage number(s) dential 

Physical and Chemical Properties Worksheet 13 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


X 


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X 


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X 


D Mark (Xl this box if you attach a contmllation sheet. l:nter the attachment name and number. 

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

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA '5 review of physical and chemical properties data. please complete the followmg 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 necessary), and whether or not the property is claimed as confidential. The physical state of the 

neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are 

measured for mixtures or fonnulations should be so noted (% PMN substance in You are not reqUired to submit this worksheet; 

however. EPA strongly recommends that you do so, as it will simplify review ensure that confidential infonnation is properly 

protected. You should submit this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for 

submission of test data. 

Property Mark Page Value Measured Confi­

(X) if number or dential 

provided Estimate Mark (X) 

(a) (b) (c) (M or E) (d) 

Physical state of neat substance (s) (I) (g) X 

Vapor pressure X 

@ Temperature °C Ton 

Density/relative density g/cm3 X 

Solubility 

@ Temperature ---°C X 

Solvent gil 

Solubility in water @ Temperature °C giL X 

Melting temperature O( X 

Boiling / sublimation temperature@ torr pressure °C 

Spectra X 

Dissociation constant X 

Particle size distribution X 

Octanoll water partition coefficient X 

Henry's Law constant X 

Volitalization from water X 

Volitalization from soil X 

pH @ concentration X 

Flammability X 

Explodability X 

Adsorption I coefficient X 

Other Specify X 

X 

X 

EPA FORM 7710-25 (Rev 5-95) Page I:} Replaces previous editions of EPA Form 7710-25 
Confidential Business Information 

Pages 14 through 37 have been removed as confidential business information. 

EPA FORM 7710-25 (Rev. 5-95) Page 14