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) 

### inFire Suppression

Dear Mr. Colton:

Thankyou for Americao Pacific Corporation's submission to the Environmental Protection Agency (EPA). EPA established the SignificaotNewAlternatives Policy (SNAP) program to implement section 612 ofthe Cleao Air Act. Your application received on December 3, 2013, aod the additional toxicity studies received on March 21 aod June 17, 2014 have beenreviewed for completeness as part ofthe initial SNAP review. We have found the submission to be incomplete. The following information is necessary inorder to allowthe Agency to continue the review ofAmericao Pacific's submission for BTP 

### infire suppression as primarily a streaming agent aod also as a total flooding agent.

1. Applications. AmericaoPacific has submitted BTP to the SNAP program for consideration under several fire suppression applications. In addition to broadcivil aviation applications, the TSCA/SNAP Addendum form aod TSCA PMN form list applications thattend to overlap although are not inclusive ofall 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 ofelectronics, haodheld extinguishers for use in server rooms, haodheld extinguishers for use in industrial applications, haodheld extinguishers for use in aoy areathat may contain expensive assets or for which contamination is ao issue, aod niche systems (normally unoccupied spaces).a) Foreach ofthe 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 ofa BTP fire extinguisher (grams) Release rate ofa 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) ofthe space that BTP is proposed for
use within The minimum andtypical rate ofairflow inthe space that BTP is proposed for use within (air changes perhour)
b) Onthe other specified uses inyour submission forms, we request further clarification onwhether or not use by consumers is anticipated.

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

3. CBIClaims forAdditionalInformation. Ifyou wishto claim any ofthe information submitted in response tothe requests above as CBI, please provide two copies ofyour response, one containing CBI and one with CBI removed.

Here is a summary ofinformation 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 (NormallyUnoccupied Spaces) Date received: December 3, 2013 Date most recent information received: June 17, 2014 Status ofsubmission: Incomplete Responses to these questions are necessary for us to begin our review. The information can be submitted viaelectronic mail orhard copy. Ifyou have questions aboutyour submission, please contact me at (202) 343-9749 or maranion.bell(@epa.gov.

Sincerely,

Bella Maranion Alternatives and Emissions Reduction Branch Stratospheric Protection Division