Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 1 **United States** 

### ENVIRONMENT **AL PROTECTION A**  **GENCY**

**Washington, DC 20460 AG**  **ENCY USE ONLY** OMB Control No.: 2060 - 0226 Expires: 06/30 /201 1 

## SNA **P INFORMA**

**TION NOTICE For Significant New Alternatives**  Date of Receipt: Date 90 Day Review Begins: Date Review Compl eted: CBI Status: Wh en completed send this form to: Via US Postal Service: Via Overnight Delivery Service: SNAP DOCUMENT CONTROL OFFICER SNAP D OCUMENT CONTROL OFFICER OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA U.S. EPA 1310 L STREET N W 1200 PENNSYLVANIA AVE N W 10 th F LOOR (MC 6205J) WASHINGTON, DC 20460 WA SHINGTON, 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 o n 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 . All 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 incl ude the confidential material. If no claims of confidentiality are made for the submission, all copies must be identical. The attached “Guidance Manual for the SNAP Information Notice” is designed to assist applicants in completing this form. The manual provides instructions on submitting a SNAP not ice, 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 possibl e. Please provide all information requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailabl e. TYPE OF NOTICE (Check only one box) Select the appropriate box identifying the type of noti ce 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 06/2008)

Previous editions are obsolete 

### 2 You must provide the identity of the alte rnative chemical of 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 co mplete and review cannot begin until EPA receives this information. **Part II -**  **AL TERNA** 

**TIVE -**  **SPECIFIC INFORM AT**  **ION** Please indicate the sector(s) for which you are submitting information on the substitute by checking the appropriate boxes:

• Refrigeration and Air Conditioning 

###  • Foam Blowing 

###  • Solvent Cleaning 

###  • Fire Extinguishing

and Explosion Prevention 

### X • Sterilization 

###  • Aerosols 

###  • Ad hesives, 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 thes e sections as needed. If you substitute is also subject to review under FIFRA, provide the FIFRA Registration Number:

_____________________________ **Part III -**  **RELEA SE A**  **ND EXPOSURE DA TA**  Please reproduce additional copies of Part III as necessary. **Part IV**  **- LIST OF A** 

**TTA CHMENT**  **S** 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 a nd any test data, other data, or any optional information that you include in this notice. **TEST DA**

**TA A**  **ND OTHER DA**

**TA** 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 thes e 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 literatur e. 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 Guidance Manual 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  Yes  No  Flammability Data  Yes  No  Environmental Effects

Data  Yes  No  Environmental Fate

Data  Yes  No  Risk Assessments  Yes  No  Test Data Not in the Possession/

Control of the Submitter  Yes  No  Other Data  Yes  No 

### You must provide the identity of the alternative chemical of 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 identi ty for you, but your submission will not be complete and review cannot begin until EPA receives this information. **CONFIDENTIA LITY CL**  **AI MS**  Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which a re to be treated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information c laimed 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 bot tom of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as con fidential, you must provide a “sanitized” version of this notice, including attachments, to EPA with our submission. For addit ional 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) un der an EPA contract for the purpose of assisting EPA in the development and im plementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP progr am . These Authorized Representatives may have access t o any information received by the Stratospheric Protection Division within 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 affec t 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 co nfidential business information as implemented by 40 CFR 2.301(h).Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 3 **Part I -**  **GENERAL INFORMATION** Section A - SUBMITTER IDENTIFICATION **1. (a) Person Submitting Notice (in U.S.)**

__ Adam Richardson

_______________________________________________________ ________ President

___________

_______ __ Name of Authorized Official Title

__ N2Towers I

nc.

__________________________________________________________ ____________________________ ______ ___ Company/Organization 10 Forin Street Belleville, ON, Canada, K8N 2 H6

_________________ _________________

_ 613 - 962 - 2401

_ 613 - 968 - 3519

______ __ _ Mailing Address Telephone & Fax Numbers Email address Adam.Richardson@n2towers.com **(b) Agent (if applicable)**

___ George W Goetz

_____________________________________________________________ Consult ant

_________________

______ _ Name of Authorized Official Title

___________________________________________________________________________________ __________

___ ________ ___ _ Company/Organization

_ 16033 E. Primrose Drive #107, Fountain Hills, Az, 85268

______________________________ 480 - 836 - 8333

______________ ______ _ Mailing Address Telephone & Fax Numbers email address georgewgoetz@gmail.com **(c) Joint Submitter (if applicable)**

_______________________________________________________________________________________________ _____ ______ __ Name of Authorized Official Title

_________________________________________________________________________________________________ ___ ______ __ Company/Organization

__ . Primrose Drive #107, Fountain Hills, Az, 85268_______________________________________480 - 836 - 8333_________

__ ______ _ Mailing Address Telephone & Fax Numbers email address georgewgoetz@gmail.com **2. Technical Contact (in U.S.)**

_ __George W Goetz_____________________________________________________________Consultant_______

___________________

___ ____ __ Name of Authorized Official Title

_____________________________________________________________________________________________________ _ ___ Company/Organization

_____________________________________________________________________________________________________ ____ _ Mailing Address Telephone & Fax Numbers **3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, ph one,**  **etc.) and the EPA staff person’s name:** Mark (X) if None _ email conferenc e call Nov 10, 2009 with Bella Maranion & Margaret Sheppard

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

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 4 **Part I -**  **GENERAL INFORMATION (continued)** Section B - ALTERNATIVE IDENTIFICATION 1. Commercial/Trade name (s) of alternative: N2 T owers, comes with N2 Generator Fire Suppression System which produces 100% clean nitrogen gas (N2) (an inert gas).
2. ( **a** ) Name of chemical(s) (preferably IUPAC nomenclature and/or process name. For blends, provide the percent composition of eac h con stituents. ( **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 consti tuents. ( **d** ) I f you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attachmen t. If you have submitted a patent application but have not been granted one yet, indicate the date submitted and the expected time frame for a response. **Answers a & b N2**  **Generator Estimated Room Toxicological Results**  **After Accidental Discharge** CAS # Measured ACGIH TLV's Ceiling Exposure 8Hr TWA STEL In flators which could have species Carbon Dioxide CO2 124 - 38 - 9 882 ppm 5000 30000 - 15min Augment Carbon Monoxide CO 630 - 08 - 0 8 0 ppm 50 OSHA 200 50/35/25 OSHA/NIOSH/ACGIH Particulates Total 1 - 16 - 8 3 1 Mg/M3 10 Mg/M3 15 - 30 min STEL was 30 Penn Health Laws STEL Canada 20 - 30 min Nitrogen & Air N2/O2 7727 - 37 - 9 & 132259 - 10 - 0 (Balance) (12% to 15%) 5 minutes maximum per NFPA 2001 Standard **Note** : Occupants located inside a space do not need any type of protective goggles, clothing and or respir ator equipment in which there has been an accidental N2 Generator discharge. ( **c** ) See attached Addendum A ( **d** ) See attached Addendum B

3. Generic chemical name (if chemical name of substitute is declared Confidential Business I nformation). Non a pplicableForm 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 5 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 substitut e refrigerant for centrifugal chillers). For a list of end uses, see Appendix A to the instructions, beginning on p. 19. ( **b** ) I dentify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ra tio). ( **a** ) N 2 Tower s (N2 Generators) are total flood nitrogen inert gas fire suppression system s whereby the oxygen inside a space is inerted down below 15% per volume. Combustion can not support a flame below 15% oxygen inside a space, thereby the fire i s extinguished. During actual N 2 Generator fire extinguishing tests at UTeC L abs in Ha llowell , Kansas during 2009 , it has been observed by N2 Towers Inc. that the actual nitrogen discharge vorticity (turbulence) created inside the test space, separates the flame from the fuel and extinguishes the test fire before the oxygen inside the test booth is inerted below 15% by volume . By then inerting the test space below 15% oxygen by volume the test fire does not reignite. **(b)** Filtered n itrogen gas is suppli ed without any Ozone Depletion or Global Warming effect.

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

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 6 **Part I -**  **GENERAL INFORMATION (continued)** Section B - ALTERNATIVE IDENTIFICATION (Continued) 5. (a) I dentify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial purposes. I f there are unidentified impurities, enter “unidentified.” (b) Provide the CAS Registry Number if available. (c) Estimate the m aximum weight percentage of each impurity. I f there are unidentified impurities, estimate their total weight percentages. Note: Please see Part I - GENERAL INFORMATION, Sections 2 a & b of this application.

6. Byproducts: ( a) Describe any byproducts of degradation products resulting from the manufacturer, processing, use or disposal of the chemic al alternative or chemicals used in the new alternative. I f there are unidentified byproducts/ degradation products enter “unident ified.” (b) Provide the CAS Registry Number if available. (c) I ndicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amount o r rate at which it is formed. (a) Our N2 Generator propellant g rain undergoes the following chemical r eaction 4NaN3 + Fe2O3 - > 2Na2O.FeO + 6N2 during discharge . Clean nitrogen gas is delivered in to the space, which leaves a sinter (a solid at flame temperature) inside the generator ( 2Na2O.FeO ) a high temperature sta

ble mixed salt is treated as if it were Na2O (CAS # 

### 1313 - 59 - 3) or NaOH (CAS # 

### 95077 - 05 - 7 ) . This material is contained within the filter inside the N2 G enerator and is neutralized at the mill when the metal body of the inflator is smelted and recycled . (b) See above for CAS #. (c) See above in answer (a), during use in 100 millisecond discharge of a N2 Generator.

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

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 7 **Part II -**  **AL TERNA** 

**TIVE -**  **SPECIFIC INFORM AT**  **ION Section A**  **- PHYSICA**  **L A ND CHEMICA**  **L PROPERTIES for Nitrogen (N2)**  1. Molecular weight 28.0134 g/mol 2. Physical state at 20  C Gas 3. Melting point - 210  C 4. Boiling point at 1 atm. Pressure 

### - 195.9 °C 5. Specific gravity 

### 1 5 °C (59 °F)) : 1.185 g/ml 6. Odor threshhold No order mg/m3 7. Solubility using solvent non applicable @ temperature  C g/L 8. Solubility in water @ temperature 

### (1.013 bar and 0 °C (32 °F)) : 0.0234 vol/vol  C 9. Partition coefficient Log K ow 

### Log K  10. Vapor pressure @ 20  C non applicable 11. Critical temperature



### - 1 47 °C 12. Critical Pressure 492.9 psia psi 13. Are spectra attached? No 14. Disa ssociation constant 15. Particle size distribution non applicable 16. Volatilization from soil 17. Volatilization from water non applicable 18. Viscosity 

### 0 °C (32 °F)) : 0.0001657 Pois e 19. pH@concentration 7.0 @ any 20. Thermal conductivity 

### (1.013 bar and 0 °C (32 °F)) : 24 mW /(m .K) 21. Adsorption coefficient 22. Flammability limits (LFL, UFL) Nonflammable 23. Flash point Nonflammable 24. Heat of combustion Nonflammable 25. Maximum pressure rise Nonflammable 26. Maximum rate of pressure rise Nonflammable 27. Other (specify) 28 . 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. (See Instructions for sector - specific data requirements f or flammable substances). 

### Nonflammable

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## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 8 1. Ozone - depletion potential (ODP): (a) Provide the 100 year ODP of the alternative relative to CFC - 11, if known. I f the substitute is a blend, provide the ODPs of individual constituents. (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromin e loading potentials). Reference the source of this information and attach any supportin g documentation. (a) & (b) No Ozone - depletion potential (ODP): Nitrogen gas N2

2. Global Warming Characteristics: (a) Provide the alternative’s global warming potential (GWP) relative to carbon di oxide over 100 - and 500 - year t ime horizons, if known. I f the substitute is a blend, provide the GWPs of the individual constituents. (b) I f 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). (c) Provide source of GWP or any additional data on the GWP of the alternative, including the atmospheric lifetime, infrared absorption spectrum, and infrared absorption capacity. I f the alternative (e.g. CO 2 captured from a stream of waste gas as a by - product of fermentation). (a) & (b) & (c) Not a Global Warming gas. Nitrogen N2

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

## 

**Part II -**  **AL TERNA** 

**TIVE -**  **SPECIFIC INFORM AT**  **ION (Continued) Section B**  **- AT**  **MOSPHERIC INFORM AT**  **ION**Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 9 **Part II -**  **AL TERNA** 

**TIVE -**  **SPECI FIC INFORM**  **AT ION (continued)**  **Section C -**  **OTHER ST AT**  **UTES A ND ST**  **AND AR**  **DS** 1. Describe whether an d how the alternative is regulated under other environmental regulatory statutes, for example other t itles under the Clean Air Act (CAA), the Clean Water Act (CW A), the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act (RCA), the Federal I

nsecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Comprehen sive Environmental Response, Compensation and Li ability Act (CERCLA), the Emergency Planning and Community Right - to - Know Act (EPCRA, also known as SARA Title III), and state and local laws. List any concentration - based or other numerical standards to which the alternative is subject under the above sta ndards and regulations. Note; Our N2 Generator propellant grain s were previously manufactured by TRW in Mesa, Arizona and undergo the following chemical reaction 4NaN3 + Fe2O3 - > 2Na2O.FeO + 6N2 during our N2 Generator discharge. Clean nitrogen gas is de livered into the space, which leaves a sinter (a solid at flame temperature) inside the generator (2Na2O.FeO) a high temperature stable mixed salt is treat ed as if it were Na2O (CAS # 

### 1313 - 59 - 3) or NaOH (CAS # 

### 95077 - 05 - 7 ) . This material is contained withi n the filter inside the N2 Generator and is neutralized at the mill when the metal body of the inflator is smelted and recycled.

2. Describe whether and how 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 Transport ation (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) or the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), by which the substitute is evaluated. **The following standards are being used** : **(a)** OSHA for our discharged N2 Generator Carbon Monoxide, Carbon Dioxide and particulate levels which are acceptable for occupied spaces. **(b)** DOT approval for non - hazardous shipping of our N2 Generators for air cargo, land and sea travel. **(c)** NFPA 2001 Standard for using our N2 Generators to displace oxygen inside a normally occupied space down to a 12 % oxygen leve l per volume with a required 5 minute m aximum egress time limit for the occupants from the space.Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

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

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 11

**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 c osts associated with the alternative. 

### Answer; Our N2 Generators can protect 1,000 cubic feet for a wholesale cost of approximate ly $2,000 US which is the approximate cost for existing UL Listed stored pressure cylinder, inert gas fire suppression systems or occupied spaces, sold in the USA today.

2. Provide information on production of the substitute. I nclude estimates on: (a) Year substitute will be available if not currently produced. **Answer** ; full scale production capable by June 2010 or sooner. (b) Total pounds production per year (current figure). **Answer;** 155,138 pounds of propellant in 2010, 1,000,000 poun ds in 2011. (c) Years to maximum market penetration **. Answer**  ; 2 to 4 years. (d) Maximum total production per year at market saturation. **Answer;** the USA will wholesale approximately $120,000,000 clean agent fire systems in 2010, this equates to appro ximately 60,000,000 stored pressure inert gas fire system bottles and an equivalent number of N2 Generators. . (e) Estimated percentage of market at market saturation **. Answer**  ; 80% of market for N2 Generator fire system for market saturation.Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 12 3 . Describe any new equipment and use profiles. I f 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 capita l costs associated with the substitute or alternative process. I nclude cost of equipment and/or any new materials, equipment lifetime, changes in labor and energy costs 

### . **Answer;** our N2 Tow er and N2 Generator fire suppression systems can be used for 100 % of all applications where clean agent fire suppression and explosion suppression systems are used in the fire system’s industry today. The w holesale cost of our N2 fire suppression systems is mentioned above in Section D

– 1. **Answer;** an existing halon, compressed chemical and or inert gas, total flood clean agent fire suppression system can be easily retrofitted with a N2 Tow er fire suppression system because our N2 Tow er fire sy stems require no discharge piping system. Also, our N2 Tow ers (c/w N2 Genera tors stacked inside the N2 Tow er ) total flood , inert gas fire suppression system can use existing detection and control equipment to be put into alarm and actuated (discharged).

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

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 13 **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 attached supporting informa tion) 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. I

nclude any data on impurities and degradation products if known. Also include information on any “A llowable Exposure Li mits” (AELs) that have been set for the substitute for use in the workplace. In addition, please attach a copy or facsimile of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person wh o is reasonably likely to be exposed. (See Guidance Manual for sector - specific data requirements). **Answer ;**  our N2 Tower (N2 Generator) total flood fire suppression systems discharge clean nitrog en gas into a normally occupied. The above questions are no n - application to our N2 Tower fire systems.



### Section B **- ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE**  For each manufacturing site: (a) I dentify all site locations (i.e. name and address) for each chemical manufacturing process . (b) I dentify all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitute s). (c) I dentify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) produc ts 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). **Answer;** this N2 Generator SNAP List application is for our N2 Generators which will be made from an existing stockpile of sodium azide propellant grains which were manufactured and are presently stored at TRW’s Mesa, Arizona facility.

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

_____ 

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 14 **Part III -**  **RELEASE AND EXPOSURE DATA Section C**  **- OCCUPATIONAL EXPOSURE AT MANUFACTURE**  For each manufacturing site (manufacturing of substitutes and/or products containing substitutes): (a) Describe the activities in which workers may be exposed to chemicals. (b) Describe any protective equipment and engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods) . (c) I ndicate 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) hour/day and (2) days/year. (f) Enter the contact pathway (e.g. ingestion, in halation, dermal). (g) Estimate the average and high - end exposure concentrations (separated by a /), being sure to provide units of measure. **Answer;** our existing stockpile of TRW sodium azide propellant gains will be shipped to UTeC Labs in Hallowell , Kansas and loaded into our N2 Generators using a down draft loading table inside the UTeC propellant grain loading facility , as permitted by the local health and safety authority having jurisdiction in this matter. Glove use is recommended when loading s odium azide propellant grains but no respirator is needed for the worker when using a down draft, propellant grain lading table. N2 Generator propellant grain loading can be pe rformed 24 hours per day and 365 days per year. Sodium azide is not to be ingest ed because it is a poison. Total number of workers allowed in the exposure area is per building code permitted allowances for that particular space. **Coated TRW**  **Grains :**  ACGIH OSHA Component CAS# Percent TLV PEL UNI TS Sodium Azide (S) 26628 - 22 - 8 50 - 70 0.3 (C) Not Est. mg/M3 Ferric Oxide 1309 - 37 - 1 20 - 35 5 (F) 10 (F)(T) mg/M3 Graphite 7782 - 42 - 5 2 - 7 2 (R) 15(T) 5(T) mg/M3 Bentonite 1. 1302 - 78 - 9 0 - 5 10(T) 3(R) 15(T) 5(T) mg/M3 So dium Nitrate 7631 - 9 - 4 0 - 5 Not Est. Not Est mg/M3 Potasium Perchlorate 7778 - 74 - 7 0 - 3 Not Est. Not Est. mg/M3 Amorphous Silica 112926 - 00 - 8 0 - 2 10(T) mg/M3 20(T) MPPCF **N2 Generator**  **Filter Pad Material inside the N2 Generator**  **(non -**  **carcinogeni c):**  Fibrox paper ACGIH OSHA Component CAS# Percent TLV PEL UNITS Mineral Wool 65997 - 17 - 3 90 - 95 10 15 mg/M3 total dust 5 mg/M3 respirable dust La tex 5 - 10 Not established (Baked out in manufacture) AC GIH TLVs are based on 2003 valvues OSHA PELs are based on 1970 values All values are 8 hour averages unless otherwise noted. S = Material can be absorbed throu gh intact skin C = Ceiling Exposure Limit F = Fume T = Total Particulate Matter R = Respirable Fraction of Particulate Matter 1. Exposure limits are for Particulates Not Otherwise Classified. No OSHA or ACGIH standards exist for this material.



### Section D **- ENVIRONMENTAL RELEASE AND DISPOSAL IN END**  **- USE** Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 15 For each end - use of a substitute: (a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous waste or wastewater effluent) at a site using the substitute (e.g. in products containing the substitute and processes using the substitute). (b) I dentify 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 releas es covered under RCRA? If so, identify the RCRA hazardous waste codes. (e) I dentify the appropriate number of sites expected to use the substitute. (f) Provide information on recycling of the substitute. Describe any associated costs and equipm ent. **Answers** ; **a)** This information is provided above in Part 1

– General I nformation

– section # 2 of this application. **b)** Again, this information is mentioned in Par 1

– General I nformation

– section # 2 of this application; this information and data of chemical release happens after discharge of our N2 Generator. **c)** We make a ceramic paper and steel wool filter roll/pad which is inserted inside the N2 Generator and the TRW propellant grain s are then placed inside the filter roll. When the pyrotec hnic squibs are actuated inside both end caps of the N2 Generator they ignite the propellant grains and the filter pad catches the particulate and clean nitrogen gas is discharged from the N2 Generator into the protect ed space. **d)** Our N2 Generator nitrog en release is not covered under RCRA. A fter discharge the sinter product left inside the discharged N2 Generator is considered as sodium hydroxide (re: commercially known as Drano), in an industrial setting sodium hydroxide is covered under RCRA. However N 2 Towers I

nc. will provide a “cradle to grave” program for our N2 Generator end users who can, if they wish, ship the dischar ged N2 Generators back to our recycling facility, which will smelt down and recycle our N2 Generator metal valve bodies. **e)** In al l potential clean agent applications across the USA. **f)** Answered above in (d). Mark (X) this box if this page contains CBI __________ 

## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 16 **Part III -**  **RELEASE AND EXPOSURE DATA (continued) Section E**  **- OCCUPATIONAL EXPOSURE AT END**  **- USE**  For all end - use scenarios of the substitute (end - uses utilizing the substitute in products and/or processes): (a) Describe the activities in which wo rkers may be exposed to chemicals. (b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). (c) I ndicate the physical form of chemicals at the time of handling/exposure (e.g. so lid, 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 pathwa y (e.g. ingestion, inhalation, dermal). (g) Estimate the average and high - end exposure concentrations (separated by a /), being sure to provide units. **Answer (a)**  **;** . **N2 Generator**  **Estimated Room Toxicological Results After Accidental Disch**  **arge** CAS # Measured ACGIH TLV's Ceiling Exposure 8Hr TWA STEL In flators which could have species Carbon Dioxide CO2 124 - 38 - 9 882 ppm 5000 30000 - 15min Augment Carbon Monoxide CO 630 - 08 - 0 8 0 ppm 50 OSHA 200 50/35/25 OSHA/NIOSH/ACGIH Particulates Total 1 - 16 - 8 3 1 mg/M3 10 Mg/M3 15 - 30 min STEL was 30 Penn Health Laws STEL Canada 20 - 30 min Nitrogen & Air N2 /O2 7727 - 37 - 9 & 132259 - 10 - 0 ( Balance ) (12% to 15%) 5 minutes maximum per NFPA 2001 Standard **Answer (b)** : Occupants located inside a space do not need to wear any type of protective goggles, gloves, chemical hoods, clothing , dust respirator equipment or self contained breathing apparatus in which there has been an accidental N2 Generator discharge . **Answer (c)** : The CO2, CO and nitrogen is discharged as a gas into a space by an N2 Generator the above noted particulate is a tiny solid . **Answer (d)** : Total number of occupants which are allowed inside a room afte r accidental N2 Generator discharge is as per the existing building occupancy permit for that particular room. **Answer (e):** After accidental discharge of an N2 Generator if the oxygen level inside the space is 12 % per volume then the occupants must vacat e the space within five minutes. **Answer (f)** : The contact pathway for the above mentioned gas and particulate levels are by way of inhalation. **Answer (g)** : The above noted N2 Generator gas and particulate amounts are the estimated high end levels after a N2 Generator discharge.



### Section F **- CONSUMER EXPOSURE** Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 17 For each end - use of a substitute: (a) I dentify the potentially exposed population (e.g. indoor residents). (b) I dentify the exposure medium (e.g. air). (c) Enter the cont act pathway (e.g. ingestion, inhalation, dermal). (d) Enter the exposure point of concentration. Provide (1) average and (2) high - end estimates. **Answer;** all of these above questions have been answered earlier in this N2 Generator SNAP List applicati on.

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##  **Part III -**  **RELEASE AND EXPOSURE DATA (continued) Section G**  **- GENERAL POPULATION EXPOSURE (optional)** Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 18 For manufacturing of substitutes and products containing substitutes: (a) I dentify and number potential exposure points. (b) For each exposu re point described in (a), identify the potentially exposed population (e.g. residents at the fenceline). (c) I dentify the contact pathway (e.g. ingestion, inhalation, dermal). (d) I dentify the exposure medium (e.g. air, water). (e) Enter th e exposure point concentration (mg/m 3 ). Provide (1) average and (2) high - end estimates. **Answer;** through the use of our stockpile of existing TRW sodium azide propellant grains our N2 Generator’s only expose the general pu blic to 100 % clean nitrogen gas , as it is discharged from an activated N2 Generator into a space and noted in various sections of this N2 Generator SNAP List application.

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## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 19 **Part I V**  **- LIST OF ATTACHMENTS**  Li st below any attachments that complete the responses to the questions on this form or that provide additional information t hat may assist EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide cita tion 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 sub mission. I f you have attached continuation pages, describe the Part, Section and question number being continued. Attach additional pages if necessary. Attachment Name Question # Number of Pages CBI 

## Part 1

– Addendum A

– N2 Generator Drawing # 2 (c) 1 No Part 1

– Addendum B - N2 Towers Inc. Patent List # 2 (d) 2 No Addendum C

– N2 Generator picture NA 1 No Addendum D

– N2 Diffuser NA 1 No Addendum E

– N2 Tower picture NA 1 No Addendum F

– TRW Toxicology report NA 1 No Addendum G

– N2 Toxicology Spreadsheet NA 1 No Addendum H

– TRW MSDS I nflator NA 1 No

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## Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 20Form 1265 - 07 (Revised 06/2008)

Previous editions are obsolete 

### 21