September 9, 2014 

Bradford Colton 

Research Engineer 

Halotron Division 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Americao Pacific Corporation 

3883 Howard Hughes Parkway, Suite 700 

Las Vegas, NV 89169 

OFFICE OF 

AIR AND RADIATION 

Re: Incomplete SNAP Submission for 2-Bromo-3,3,3-trifluoroprop-1-ene (BTP) in Fire 

Suppression 

Dear Mr. Colton: 

Thank you for Americao Pacific Corporation's submission to the Environmental Protection 

Agency (EPA). EPA established the Significaot New Alternatives Policy (SNAP) program to 

implement section 612 of the Cleao Air Act. Your application received on December 3, 2013, 

aod the additional toxicity studies received on March 21 aod June 17, 2014 have been reviewed 

for completeness as part of the initial SNAP review. We have found the submission to be 

incomplete. The following information is necessary in order to allow the Agency to continue the 

review of Americao Pacific's submission for BTP in fire suppression as primarily a streaming 

agent aod also as a total flooding agent. 

1. Applications. Americao Pacific has submitted BTP to the SNAP program for 

consideration under several fire suppression applications. In addition to broad civil 

aviation applications, the TSCA/SNAP Addendum form aod TSCA PMN form list 

applications that tend to overlap although are not inclusive of all possible applications. 

We understand aod propose to move forward in our review for the use ofBTP for the 

following applications: 

engine nacelles, 

auxiliary power units (APUs), 

baggage/cargo compartment, 

haodheld extinguishers onboard aircraft, 

haodheld extinguishers in protection of electronics, 

haodheld extinguishers for use in server rooms, 

haodheld extinguishers for use in industrial applications, 

haodheld extinguishers for use in aoy area that may contain expensive assets or 

for which contamination is ao issue, aod 

niche systems (normally unoccupied spaces). 
a) For each of the above applications, we request the following information: 

1) Extinguisher System 

Design concentration expressed volumetrically on a percent basis (e.g. 5% 

v/v) 

The charge size of a BTP fire extinguisher (grams) 

Release rate of a BTP fire extinguisher (g/sec) 

2) End-Use Exposure 

The minimum and typical dimensions (meters) and effective volume (i.e., 

excluding cargo, passengers, etc.) (m3

) of the space that BTP is proposed for 

use within 

The minimum and typical rate of airflow in the space that BTP is proposed 

for use within (air changes per hour) 

b) On the other specified uses in your submission forms, we request further 

clarification on whether or not use by consumers is anticipated. 

2. Disposal. Please provide the procedures and/or guidelines for proper clean-up and 

disposal of discharged BTP. 

3. CBI Claims for Additional Information. If you wish to claim any of the information 

submitted in response to the requests above as CBI, please provide two copies of your 

response, one containing CBI and one with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: BTP 

Substance(s) the substitute will replace: Halon 1211 and Halon 1301 

Sector: Fire Suppression 

End-uses: Streaming and Total Flooding (Normally Unoccupied Spaces) 

Date received: December 3, 2013 

Date most recent information received: June 17, 2014 

Status of submission: Incomplete 

Responses to these questions are necessary for us to begin our review. The information can be 

submitted via electronic mail or hard copy. If you have questions about your submission, please 

contact me at (202) 343-9749 or maranion.bell(@epa.gov. 

Sincerely, 

Bella Maranion 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division