Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

1

United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

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.

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 include 

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 notice, asserting confidentiality claims, completing the notice form, sectorspecific 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_____________________________________________
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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 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  

• Foam Blowing 

• Solvent Cleaning  

• Fire Extinguishing 

and Explosion Prevention X

• 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 you 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 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 identity for you, but your submission will not 

be complete and review cannot begin until EPA receives 

this information.

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 our 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 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).
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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 Inc._______________________________________________________________________________________________

Company/Organization

10 Forin Street Belleville, ON, Canada, K8N 2H6___________________________________613-962-2401_ 613-968-3519_________

Mailing Address Telephone & Fax Numbers 

Email address Adam.Richardson@n2towers.com

(b) Agent (if applicable)

___George W Goetz_____________________________________________________________Consultant________________________

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, phone, 

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

Mark (X) if None _email conference call Nov 10, 2009 with Bella Maranion & Margaret Sheppard______

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: N2 Towers, 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 each 

constituents.

 (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 hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attachment. 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 Inflators which could have species

Carbon Dioxide CO2 124-38-9 882 ppm 5000 30000-15min Augment

Carbon Monoxide CO 630-08-0 80 ppm 50 OSHA 200 50/35/25 OSHA/NIOSH/ACGIH

Particulates Total 1-16-8 31 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 respirator 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 Information).

Non applicable
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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. terpenebased 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. 19.

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

(a) N2 Towers (N2 Generators) are total flood nitrogen inert gas fire suppression systems 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 is extinguished. 

During actual N2 Generator fire extinguishing tests at UTeC Labs in Hallowell, 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 nitrogen gas is supplied without any Ozone Depletion or Global Warming effect.

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. (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 if available.

 (c) Estimate the maximum weight percentage of each impurity. If 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 chemical alternative 

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

 (b) Provide the CAS Registry Number if available.

 (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amount or rate at which 

it is formed.

(a) Our N2 Generator propellant grain undergoes the following chemical reaction 4NaN3 + Fe2O3 -> 2Na2O.FeO + 6N2 during discharge. 

Clean nitrogen gas is delivered into the space, which leaves a sinter (a solid at flame temperature) inside the generator (2Na2O.FeO) a high 

temperature stable 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 Generator 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.

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Form 1265-07 (Revised 06/2008)

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Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL 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 15 °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 Kow Log K

10. Vapor pressure @ 20 C non applicable 11. Critical temperature 

-147 °C 

12. Critical Pressure 

492.9 psia 

psi

13. Are spectra attached? No 14. Disassociation 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 Poise

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 for flammable substances).

Nonflammable

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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 individual 

constituents.

 (b) Provide source of ODP or 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) & (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 dioxide over 100- and 500-year time horizons, if known. If 

the substitute is a blend, provide the GWPs of the individual constituents.

 (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).

 (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. If the alternative (e.g. CO2 captured from a stream of waste gas as a by-product of fermentation).

(a) & (b) & (c) Not a Global Warming gas. Nitrogen N2

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether an d how the alternative is regulated under other environmental regulatory statutes, for example other titles under the 

Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act 

(RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Comprehensive 

Environmental Response, Compensation and Liability 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 standards and regulations.

Note; Our N2 Generator propellant grains 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 delivered into the space, which 

leaves a sinter (a solid at flame temperature) inside the generator (2Na2O.FeO) a high temperature stable 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 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 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) 

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 level per 

volume with a required 5 minute maximum egress time limit for the occupants from the space. 
Form 1265-07 (Revised 06/2008)

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Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008)

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. 

Answer; Our N2 Generators can protect 1,000 cubic feet for a wholesale cost of approximately $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. Include 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 pounds 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 approximately 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. 
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3. Describe any new equipment and use profiles. 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.

Answer; our N2 Tower 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 wholesale 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 Tower fire suppression system because our N2 Tower fire systems require no 

discharge piping system. Also, our N2 Towers (c/w N2 Generators stacked inside the N2 Tower) total flood, inert 

gas fire suppression system can use existing detection and control equipment to be put into alarm and actuated 

(discharged). 

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Form 1265-07 (Revised 06/2008)

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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 information) 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 “Allowable 

Exposure Limits” (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 who 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 nitrogen gas into a normally occupied. The above 

questions are non-application to our N2 Tower fire systems. 

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

 (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).

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. 

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Form 1265-07 (Revised 06/2008)

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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) 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) hour/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.

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 sodium 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 performed 24 

hours per day and 365 days per year. Sodium azide is not to be ingested 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 UNITS

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 

Sodium 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-carcinogenic): 

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

Latex 5-10 Not established (Baked out in manufacture)

ACGIH 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 through 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
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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) 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 appropriate number of sites expected to use the substitute.

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

Answers; 

a) This information is provided above in Part 1 – General Information – section # 2 of this application. 

b) Again, this information is mentioned in Par 1 – General Information – 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 grains are then 

placed inside the filter roll. When the pyrotechnic 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 protected space. 

d) Our N2 Generator nitrogen release is not covered under RCRA. After 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 N2 Towers Inc. will provide a “cradle to grave” program for our N2 Generator end users who can, if they wish, ship the discharged 

N2 Generators back to our recycling facility, which will smelt down and recycle our N2 Generator metal valve bodies. 

e) In all potential clean agent applications across the USA. 

f) Answered above in (d). 

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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 workers may be exposed to chemicals.

 (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.

Answer (a);. 

 N2 Generator Estimated Room Toxicological Results After Accidental Discharge

CAS # Measured ACGIH TLV's Ceiling

 Exposure 8Hr TWA STEL Inflators which could have species

Carbon Dioxide CO2 124-38-9 882 ppm 5000 30000-15min Augment

Carbon Monoxide CO 630-08-0 80 ppm 50 OSHA 200 50/35/25 OSHA/NIOSH/ACGIH

Particulates Total 1-16-8 31 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 after 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

vacate 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) Identify the potentially exposed population (e.g. indoor residents).

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

 (c) Enter the contact 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 application. 

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

Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)
Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

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For manufacturing of substitutes and products containing substitutes:

 (a) Identify and number potential exposure points.

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

 (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). 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 public 

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. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

19

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 citation 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.

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 Inflator NA 1 No 

Mark (X) this box if this page contains CBI __________
Form 1265

-07 (Revised 06/2008)

Previous editions are obsolete

20
Form 1265

-07 (Revised 06/2008)

Previous editions are obsolete

21