Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

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United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 8/31/2014

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

 July 24, 2014 

Date 90 Day Review Begins:

Date Review Completed:

CBI Status:

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA

U.S. EPA 1310 L STREET NW

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J)

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control Number

INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of 

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are 

required to provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or 

processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting. 

PAPER SUBMISSIONS: All paper submissions must be provided in three complete copies. If information is to be claimed as 

confidential, all confidential information must be excised from one of the copies, which will be placed in the public docket; the 

other two copies must include the confidential material. If no claims of confidentiality are made for the submission, all copies 

must be identical.

CD-ROM SUBMISSIONS: The SNAP program also accepts submissions via CD-ROM. If information is to be claimed as 

confidential, all confidential information must be excised from one of the files on the CD-ROM, which will be placed in the public 

docket; the other file must include the confidential material. The file with the confidential material must include “contains CBI” in 

the file name.

STEP-BY-STEP INSTRUCTIONS: The Instructions for the SNAP Information Notice and TSCA/SNAP Addendum (“Instructions”)

are designed to assist applicants in completing this form. The Instructions provide step-by-step guidance on submitting a SNAP 

notice, asserting confidentiality claims, completing the notice form, sector-specific data requirements, and submitting test data 

and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________X

Petition: New alternative, Substance, or Formulation__________________________________________________________

Petition: Revision of the Existing SNAP list__________________________________________________________________

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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Part I - GENERAL INFORMATION

You must provide the identity of the alternative chemical or 

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim the 

identity as confidential. You may authorize another person 

to submit the identity for you, but your submission will not be 

complete and review cannot begin until EPA receives this 

information.

Part II - ALTERNATIVE-SPECIFIC INFORMATION

 

Please indicate the sector(s) for which you are submitting 

information on the substitute by checking the appropriate 

boxes:

• Refrigeration and Air Conditioning X 

• Foam Blowing 

• Solvent Cleaning  

• Fire Extinguishing 

 and Explosion Prevention 

• Sterilization 

• Aerosols 

• Adhesives, Coatings, and Inks 

• Tobacco Expansion 

• Pesticides 

You may need additional copies of Part II if there are several 

manufacturing, processing, or use operations that you will 

describe in this notice. Please reproduce these sections as 

needed.

If your substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number:

_____________________________

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information that you include in this notice.

TEST DATA AND OTHER DATA

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

control and to provide a description of all other data known to you if 

these data are related to the health and environmental effects of 

the manufacture, processing, distribution in commerce, use, or 

disposal of the alternative. Standard literature citations may be 

submitted if they do not appear in the open scientific literature. 

Complete test data (in English), not summaries of data, must be 

submitted if they do not appear in the open literature. The following 

are test data and other data that might be submitted (see the 

Instructions for a more complete list of data to be submitted.) 

Please indicate test data to be included in your submission notice 

by checking the appropriate boxes:

• Health Effects Data X Yes No

• Flammability Data X Yes No

• Environmental Effects 

Data X Yes No

• Environmental Fate 

Data Yes X No

• Risk Assessments Yes X No

• Test Data Not in the Possession/

Control of the Submitter X Yes No

• Other Data X Yes No

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice.

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with your submission. For additional information 

on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and 

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. 

These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within the 

EPA Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or 

activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that 

these companies can complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business 

information as implemented by 40 CFR 2.301(h).
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (in U.S.)

Eric P. Youngdale__________________ Global Marketing Manager, DuPont Stationary Refrigerants

Name of Authorized Official Title

DuPont Fluoroproducts______________________ _______________________________________

Company/Organization

Chestnut Run Plaza P. O. Box 2915 974 Centre Road Wilmington, DE 19805_ _(Office- 302-999-5386)_(FAX- 302-999-4925) 

Mailing Address Telephone & Fax Numbers 

Eric.P.Youngdale@DuPont.com_ __

E-mail Address

(b) Agent (if applicable)

____________________________________________________________________________________________________________ 

Name of Authorized Official Title

____________________________________________________________________________________________________________ 

Company/Organization

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

____________________________________________________________________________________________________________

E-mail Address

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________

Name of Authorized Official Title

____________________________________________________________________________________________________________

Company/Organization

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

____________________________________________________________________________________________________________

E-mail Address

2. Technical Contact (in U.S.)

Mary E. Koban_______________________________________________________ Sr. Technical Engineer 

Name of Authorized Official Title

DuPont Fluoroproducts______________________________________________________________________________________

Company/Organization

Chestnut Run Plaza P. O. Box 2915 974 Centre Road Wilmington, DE 19805 (Office- 302-999-2692)_(FAX- 302-999-2093) 

Mailing Address Telephone & Fax Numbers 

Mary.E.Koban@DuPont.com__________________ ________________ ________________________

E-mail Address

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phone, 

etc.) and the EPA staff person’s name:

Mark (X) if None ________________ 

Mark (X) this box if this page contains CBI _____X_____
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative:

 Opteon® XP10

2. (a) Name of chemical(s) (preferably IUPAC nomenclature) and/or process name. For blends, provide the percent composition of each 

constituent. For powdered aerosols used in fire suppression, see page 11 of the Instructions for additional necessary composition information.

 (b) Chemical Abstracts Service (CAS) registry number and molecular formula.

 (c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information 

on any chemical constituents.

 (d) If you have applied for or hold a patent on the substitute, provide the patent name, number (if available), and information on the topics 

covered in the patent. 

Parts a), b), and c) are shown in table below:

 

Part d) Confidential

3. Generic name: 

If the name of the substitute is declared Confidential Business Information, provide a generic name. 

We note for information that this blend was previously denoted in several industry studies as

DuPont TM DR-11 or simply DR-11. 

Mark (X) this box if this page contains CBI ___ __
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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4. Specific End-Use

 (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g., terpene-based 

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A 

to the Instructions, beginning on p. 23. If the alternative is a refrigerant, indicate whether it is a candidate for use in retrofits of existing 

equipment, for use in new equipment only, or both.

 (b) Identify the ODS and the quantity of substitute needed to replace it for each end use in pounds (i.e., the replacement ratio).

Part a) This blend is a nonflammable chlorine-free HFC/HFO refrigerant blend. This refrigerant blend has been developed 

as a lower global warming, non-ozone depleting replacement for R-134a. 

This blend can be used for both retrofit and new equipment applications for the refrigeration and air conditioning sectors 

of:

• Chillers

• Cold storage warehouses

• Commercial comfort air conditioning 

• Commercial ice machines

• Heat transfer

• Household refrigerators, household freezers 

• Ice skating rinks

• Industrial process refrigeration systems

• Industrial process air conditioning

• Refrigerated transport

• Retail food refrigeration

• Residential de-humidifiers

• Residential and light commercial air conditioning and heat pumps

• Vending machines

• Water Coolers

Part b) This substitute is a replacement for the ODS substance defined as CFC-12. The replacement ratio for this blend is 

approximately 100% of CFC-12, 1 lb per 1lb of CFC-12.

Mark (X) this box if this page contains CBI ____ ____
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. Impurities

 (a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial 

purposes. If there are unidentified impurities, enter “unidentified.”

 (b) Provide the CAS Registry Number for each impurity if available.

 (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight 

percentages.

Part a) Confidential

Part b) Confidential

Part c) Confidential

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OMB Control No.: 2060-0226

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6. Byproducts:

 (a) Describe any byproducts or degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts/ degradation products enter “unidentified.” 

 (b) Provide the CAS Registry Number for each byproduct or degradation product if available.

 (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, in case of fire, etc.) and the amount 

or rate at which it is formed.

Part a) Confidential

 

Part b) Confidential

Part c) Confidential

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES – See Appendix B to the Instructions to see which properties apply 

to which uses.

1. Molecular weight 108.4 2. Physical state at 20 oC liquefied gas

3. Melting point at 1 atm. pressure o C N/A 4. Boiling point at 1 atm. pressure -29.1 oC

5. Specific gravity >1 g/ml @25C 6. Odor threshhold Not determined 

mg/m3

7. Solubility using solvent N/A @ temperature oC g/L

8. Solubility in water @ temperature N/A oC

9. Partitio coefficient N/A Log Kow Log K

10. Vapor pressure @ 20o C 88.9 psi

(Also provide vapor pressure-temperature curve for refrigerants.)

11. Critical temperature 

96.5o C

12. Critical Pressure 

546 psia

13. Are spectra attached? No 14. Disassociation constant N/A

15. Particle size distribution N/A 16. Volatilization from soil N/A

17. Volatilization from water N/A 18. Viscosity @ 20 oC N/A

19. pH@concentration N/A 20. Thermal conductivity (for foam blowing agents)

 N/A

21. Adsorption coefficient N/A 22. Flammability limits (LFL, UFL) % vol N/A 

 Non-flammable per ASTM E-681 

23. Flash point N/A 24. Heat of combustion 8.95 Mj/kg

25. Maximum pressure rise N/A 26. Maximum rate of pressure rise N/A

27. Other (specify)

28. Flammability: Provide any information on flammability concerns. For example, if any abatement techniques are being used to 

minimize the risks associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an 

assessment of overall risk in each end-use may be required. For flammable refrigerants, provide a fault tree analysis for each end use. 

For flammable foam blowing agents used in spray foam, provide a training program that addresses flammability concerns specific to this 

substitute. (See Appendix B to Instructions for sector-specific data requirements for flammable substances).

The worst case formulation (WCF) and worst case fractionated formulation (WCFF) were tested for flammability according to ASTM 

E681-2004 test procedure as required in ASHRAE Standard 34-2010 and described in Appendix B1 to ASHRAE Standard 34-2010. 

Test conditions were 60°C and 50% relative humidity for the WCF and 60° C and 50% relative humidity for the WCFF. 

Opteon® XP10 was found to be nonflammable at the WCF and WCFF when tested at 60oC. The tests were conducted in the DuPont 

Fluoroproducts analytical laboratory at Chestnut Run Plaza, Wilmington, DE. 

Reference: Confidential

Mark (X) this box if this page contains CBI _____ _____
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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1. Ozone-depletion potential (ODP):

 (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of the 

individual constituents. Reference the source for each ODP.

 (b) Provide any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading potentials). Reference 

the source of this information and attach any supporting documentation.

a) This blend contains no chlorine or bromine and is composed of a hydrofluorocarbon (HFC) and hydrofluoro-olefin (HFO), 

each with zero ozone depletion potential (ODP).

b) Therefore, ODP= 0 (zero)

Mark (X) this box if this page contains CBI __ _______

Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
Form 1265-07 (Revised 09/2011) 

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2. Global Warming Characteristics:

 (a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) relative to carbon dioxide over 100-year time 

horizon, and 20-year or 500-year time horizon, if known. Reference the most recent assessment report of the Intergovernmental Panel on

Climate Change (IPCC AR4). Alternate sources may include the 2010 World Meteorological Organization (WMO) Scientific Assessment of 

Ozone Depletion or the peer-reviewed literature. If the substitute is a blend, provide the GWPs of the individual constituents and an estimate 

of the blend at its nominal composition. 

 (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/- X%) and 

results of any testing or modeling done (both theoretical and actual testing). Energy efficiency information is particularly useful for 

refrigerants and foams.

 (c) For GWP values that do not come from AR4 or WMO 2010, provide any available additional data on the atmospheric lifetime and GWP 

of the alternative, including infrared absorption spectrum and infrared absorption capacity. Reference the source of this information. 

Part a) and c) 

Reference: AR4 IPCC Report

Reference: CF3CFQCH2 and (Z)-CF3CFQCHF : temperature dependent OH rate coefficients and GWP; Phys. Chem. 

Chem. Phys., 2007, 9, 1–13

Reference: AR5 IPCC Table 8a

Part b) Confidential

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory statutes

such as those listed below. List any concentration-based or other numerical standards to which the alternative is subject under the standards 

and regulations.

Titles of the Clean Air Act (CAA) other than Title VI Not applicable to this product_______________________________________

the Clean Water Act (CWA) Not applicable to this product____________________________________________________

the Safe Drinking Water Act (SDWA) Not applicable to this product _____________________________________________

the Resource Conservation and Recovery Act (RCRA) Not applicable to this product

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Not applicable to this product ______________________________

the Toxic Substances Control Act (TSCA) All components of the refrigerant blend are on the TSCA list____________ 

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) None of the components listed are regulated 

under CERCLA

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III) Not applicable to this product

State and local laws Confidential 

Other applicable environmental federal, state, and local laws not mentioned above _______________________________

Mark (X) this box if this page contains CBI _____ _____
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under health and safety 

related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health 

Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical 

standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such 

as the National Fire Prevention Association (NFPA) the American Society of Heating, Refrigerating, and Air Conditioning Engineers 

(ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitute from a health and safety perspective. 

Part a) Confidential

Part b) The refrigerant components and refrigerant blend will be transported and handled per the appropriate DOT 

regulations for flammable and non-flammable liquefied gas. 

Part c) The refrigerant blend, Opteon® XP10, has been submitted to ASHRAE for safety classification per standard 34.

Opteon® XP10 was granted refrigerant classification A1 (non-flammable and low toxicity) and refrigerant nomenclature of 

R-513A per ASHRAE standard 34. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated 

with the alternative. Please describe the information used as the basis for this cost estimate.

Cost: Confidential. 

New Equipment: DuPontTM Opteon® XP10 can be used with existing equipment designed for R-134a, with minimal to no 

equipment costs associated to DuPontTM Opteon® XP10. However, in older systems, it may be beneficial to replace 

elastomeric seals to minimize the risk of leaks and potentially adjust the thermal expansion valves (TXVs). 

Existing Equipment: Conversion costs are determined by servicing costs involving recovery of existing refrigerant, recharge 

with DuPontTM Opteon® XP10 and subsequent system optimization.

2. Provide information on production of the substitute. Include estimates on:

 (a) Year substitute will be available if not currently produced.

 (b) Total pounds production per year (current figure).

 (c) Years to maximum market penetration.

 (d) Maximum total production per year at market saturation.

 (e) Estimated percentage of market at market saturation.

Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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3. Describe any new equipment and use profiles that will be necessary in order to use the substitute. If retrofitting of existing equipment is 

required, detail changes in technologies needed to use the alternative and address any materials compatibility issues. Provide information on 

each end-use and capital costs associated with the substitute or alternative process. Include cost of equipment and/or any new materials, 

equipment lifetime, changes in labor and energy costs.

This substitute blend has been designed as a replacement for R-134a. It can be used in new equipment designed for R-134a, 

thus avoiding the need for system re-engineering or re-design. It can also be used for retrofit replacement of CFC-12 in 

existing equipment. This low GWP substitute blend will be used to replace R-134a in current stationary applications.

The blend is expected to be compatible with all materials commonly found in refrigeration systems.

REFERENCE: AHRI Test Report #7-System Drop-In Tests of R-134a Alternative Refrigerants (ARM-42a, N-13a, N-13b, 

R-1234ze(E), and OpteonTM XP10) in a 230-RT Water-Cooled Water Chiller

REFERENCE: AHRI Test Report #8- System Drop-In Tests of R-134a, R-1234yf, OpteonTM XP10, R-1234ze(E), and N13a 

in a Commercial Bottle Cooler/Freezer

Mark (X) this box if this page contains CBI __________

Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attach supporting information on) the 

acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, 

and plants), if available. Include any data on impurities and degradation products if known. Also include information on any permissible 

exposure limits (PELs), occupational exposure limits (OELs), or Acceptable Exposure Limits (AELs) that have been set for the substitute for 

use in the workplace. In addition, please attach a copy of any hazard warning statement, label, material safety data sheet, or other information 

which will be provided to any person who is reasonably likely to be exposed. (See Pgs. 16-17 of the Instructions for sector-specific 

requirements for toxicity testing).

Toxicity information: Confidential

The recommended blend 8-hr TWA workplace exposure standard is 653 ppm. This is based on additive formula using WEEL 

values of 1000 ppm for R-134a and WEEL value of 500 ppm for R-1234yf

Reference: Confidential

Reference: Confidential

Mark (X) this box if this page contains CBI __________

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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For each manufacturing site (for manufacturing of substitutes and/or products containing substitutes): 

 (a) Identify all site locations (i.e., name and address) for each chemical manufacturing process.

 (b) Identify all site locations for manufacturing of products using substitutes (e.g., refrigerators containing the substitutes).

 (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing the substitutes.

 (d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e.g., indoor air, 

outdoor air, water, land).

Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

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Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE
Form 1265-07 (Revised 09/2011) 

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For each manufacturing site (manufacturing of substitutes and/or products containing substitutes):

 (a) Describe the activities in which workers may be exposed to chemicals at the manufacturing facility. Answer items (b) through (g) for 

each activity.

 (b) Describe any protective equipment and engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

 (f) Enter the contact pathway (e.g., ingestion, inhalation, dermal).

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure.

Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

Part f) Confidential

Part g) Confidential

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE
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For each end-use of a substitute (end-uses using the substitute in products and/or processes): 

 (a) Provide the estimated amount (in kg/day) of each chemical released to the environment (e.g., as a solid waste or wastewater effluent) at

the point of, or subsequent to, the end-use at a site using the substitute (e.g., in products containing the substitute and processes using the 

substitute).

 (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point.

 (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control technology in 

place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal.

 (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes.

 (e) Identify the approximate number of sites expected to use the substitute.

 (f) Provide information on recycling of the substitute. Describe any associated costs and equipment.

Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Releases not covered under RCRA. 

Part e) Confidential 

Part f) Standard HFC recycle equipment and procedures are used for DuPontTM Opteon® XP10 EPA-approved recovery 

equipment and recovery cylinders rated for CFC-12 may be used to recover DuPontTM Opteon® XP10. 

Mark (X) this box if this page contains CBI __________

Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE
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For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes):

 (a) Describe the activities in which workers may be exposed to chemicals at the end-use (i.e., during installation, maintenance, inspection, 

servicing, or use). Answer items (b) through (g) for each activity.

 (b) Describe any protective equipment or engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

 (f) Enter the contact pathway (e.g,. ingestion, inhalation, dermal).

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units. Personal monitoring data 

may be required for some end uses (see pgs. 17-18 of Instructions).

Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

Part f) Confidential

Part g) Confidential

Reference: Gjolstad et al., J Environ Monit. 2003 Apr;5(2):236-40

Section F - CONSUMER EXPOSURE
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

19

For each end-use of a substitute (end-uses where a consumer might be exposed): 

 (a) Identify the potentially exposed consumer population (e.g,. indoor residents).

 (b) Identify the exposure medium (e.g., air).

 (c) Enter the contact pathway (e.g,. ingestion, inhalation, dermal).

 (d) Describe the exposure point of concentration. Provide (1) average and (2) high-end concentration estimates, including units of measure. 

Part a) DuPontTM Opteon® XP10 blend is used in air conditioning and refrigeration equipment from which any emission 

would only occur as a result of equipment failure since the systems are sealed units. It is expected that exposure levels to

which the general consumers would be exposed, under these conditions would be minimal and additionally would be expected 

to occur only once in a consumers’ lifetime. Additionally, any leakage would normally be expected in the parts of the system 

which tend to be remote and/or away from the public.

Part b) System failures could potentially release the product. As the product is a liquefied gas, even if the product is leaked in 

the liquid form, it will quickly vaporize and partition into the air. Therefore, potential exposures to the general public are via 

the air.

Part c) Normally, the potential exposure pathway would be inhalation. 

Part d) Confidential

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

20

Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

 (a) Identify and number potential general population exposure points.

 (b) For each exposure point described in (a), identify the potentially exposed population (e.g., residents at the fenceline to the 

manufacturing facility).

 (c) Identify the contact pathway (e.g., ingestion, inhalation, dermal).

 (d) Identify the exposure medium (e.g., air, water).

 (e) Enter the exposure point concentration (mg/m3 or ppb). Provide (1) average and (2) high-end estimates.

Parts a) and b) It is not expected that the general population would come into contact with the application equipment and any

emission due to equipment failure or leakage would be initially confined to a small area in close proximity to the equipment, 

then readily dispersed. This would put the exposure of the general population close to zero.

Parts c) and d) Inhalation through the air

Part e) Confidential

Mark (X) this box if this page contains CBI _________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

21

Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citations for information already submitted to EPA as 

part of past regulatory and information activities, as well as for other information that could not be included with this submission. If you have 

attached continuation pages, describe the Part, Section and question number being continued. Attach additional pages if necessary. Mark (X) 

in the CBI box next to any attachment that contains information you claim as confidential.

Attachment Name Question # Number of Pages CBI

ASHRAE Section 9.7 – Flammability Information Part II A 14 X 

IPCC Fourth Assessment Report Part II B.2

CF3CFQCH2 and (Z)-CF3CFQCHF : temperature 

dependent OH rate coefficients and GWP; Phys. Chem. 

Chem. Phys., 2007, 9, 1–13

Part II B.2 15 

IPCC Fifth Assessment Report, Table 8a Part II B.2 8 

AHRI Report #7 Part II D.3 27 

AHRI Report #8 Part II D.3 18

ASHRAE Section 9.6 – Toxicity Information Part III A.1 31 X 

DuPont TM Opteon ® XP10 SDS Part III A.1 11 X 

R-1234yf SDS Part III A.1 10 X 

R-134a SDS Part III A.1 10 X 

Gjolstad et al., J Environ Monit. 2003 Apr;5(2):236-40 Part III E 5 

 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

22

Part V – CERTIFICATION

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

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

2. 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.

3. If this is a submission of a new alternative, the company named in Part I, Question 1a of this notice:

 (a) intends to manufacture, formulate, import, market, or use a new alternative to a Class I or Class II ozone-depleting 

substance which is identified in Part I, Section B, Question 2.

 (b) seeks an acceptability determination on a new alternative(s) to a Class I or Class II ozone-depleting substance, which is 

identified in Part I, Section B, Question 2.

4. The accuracy of the statements made in this notice reflects my best prediction of the anticipated facts regarding the 

alternative described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to section 113(c) 

of the Clean Air Act and 18 U.S.C.§1001.

Signature and Title of Authorized Official (Original Signature Required): Date 7/24/2014

 

Signature of Agent (Where Applicable): Date

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 171 hours per year. For 

persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 36 hours her year. Burden 

means that total time, or financial resources expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. This includes the time needed to review instruction; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information; adjust the existing ways to comply with any previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number.

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any 

suggested methods for minimizing respondent burden, including through the use of automated collection techniques 

to the Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency,1200 Pennsylvania 

Ave NW, Washington, DC 20460. Include the OMB control number in any correspondence. Do not send the 

completed form to this address.