Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

1

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:

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: 16 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___________________________________________!

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

Previous editions are obsolete

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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 ! 

• 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 ! 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

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

Previous editions are obsolete

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Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

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

Luca Costantini Founder & CEO

_____________________________________________________________________________________________________________

Name of Authorized Official Title

Blupura USA, Inc.

____________________________________________________________________________________________________________

Company/Organization

1200 Brickell Avenue, Suite 1950, 33131 Miami , FL – USA + 1 305 777 3591

____________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

luca@blupura.com

____________________________________________________________________________________________________________

E-mail Address

(b) Agent (if applicable)

Marc Chasserot Managing Director

____________________________________________________________________________________________________________

Name of Authorized Official Title

shecco America, Inc.

____________________________________________________________________________________________________________

Company/Organization

570 Seventh Avenue, 18th Floor, New York,NY 10018 - USA 

____________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

marc.chasserot@shecco.com

____________________________________________________________________________________________________________

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.)

Gianni Grottini

__________________________________________________________________________________________________________

Name of Authorized Official Title

Blupura USA, Inc.

_________________________________________________________________________________________________________

Company/Organization

1200 Brickell Avenue, Suite 1950, FL 33134 - USA + 1 305 777 3591

__________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

blupurausa@blupura.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:

• June 2015: email, conference call - Rebecca von dem Hagen, Margaret Sheppard

• 25-26 June 2015: personal communication at ATMOsphere America 2015, Atlanta, GA - Gerald Wozniak

• September 2015: personal communication at FMI Connect 2015 in San Diego

Mark (X) if None ________________☐

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 I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

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

Propane

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.

R290 - propane

Chemical formula: C3H3

CAS # 74-98-6

3. Generic name:

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

Propane

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).

(a) Substitute refrigerant for water coolers in new equipment

(b) Replacement for R22 and R134. The replacement gas propane has 0 ODP and charge is less than 150 g. Propane requires less than 60% 

of the total mass of the HFC chemicals. 

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 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.

a) Propylene (propene) and Isobutane (2 methyl propane)

b) Propene - CAS 115-07-1, Isobutane - CAS 75-28-5

c) Total impurities are less than 0.5%

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.

Unidentified

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

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

to which uses.

1. Molecular weight 44.11 g/mol 2. Physical state at 20 oC gas

3. Melting point at 1 atm. pressure -187.6 o C 4. Boiling point at 1 atm. pressure -42.1 oC

5. Specific gravity g/ml 6. Odor threshhold mg/m3

7. Solubility using solvent @ temperature oC g/L

8. Solubility in water @ temperature oC

9. Partition coefficient Log Kow Log K%

10. Vapor pressure @ 20o C 840 kPa / 121.8317 psi

http://encyclopedia.airliquide.com/images_encyclopedie/VaporPressureGraph/Propa

ne_Vapor_Pressure.GIF

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

11. Critical temperature 

96.81oC

12. Critical Pressure 

618 psi

13. Are spectra attached? 14. Disassociation constant

15. Particle size distribution 16. Volatilization from soil

17. Volatilization from water 18. Viscosity @ 20 oC

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

21. Adsorption coefficient 22. Flammability limits (LFL, UFL) LFL - 2.2 % vol; 

UFL - 9.5 % vol

23. Flash point -104°C 24. Heat of combustion (constant vol) 528.4 cal; (constant 

pressure) 553.5 cal

25. Maximum pressure rise 601psi 26. Maximum rate of pressure rise unknown

27. Other (specify)
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

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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).

Propane (R290) is classified as A3 refrigerant by ASHRAE Standard 34-2010. Propane is flammable when its concentration in air is in 

the range of 2.1% and 9.5% by volume (21,000 ppm to 95,000 ppm).

Flammability risks and occupational exposures to hydrocarbons are adequately regulated by OSHA and building and fire codes at a local 

and national level. All propane storage and transport equipment should be installed with safety devices that minimize the likelihood of 

releases. For example, NFPA 58 Liquefied Petroleum Gas Code (NFPA 2014) for liquefied propane requires the use of overfill protection 

devices (OPD) on cylinders to minimize the likelihood of leaks. The NPFA 58 Code also contains propane storage and transportation

requirements/guidelines. It is expected that refrigerants be properly stored and caution used within manufacturing facilities to minimize 

explosion risk and that workers adhere to the requirements set by OSHA under 29 CFR 1910. OSHA requirements include proper 

ventilation and storage practices within manufacturing facilities to prevent fire and explosion. Good manufacturing practices should be 

adhered to during the manufacture of equipment containing propane.

R290 water coolers were tested by the independent laboratory INTERTEK in 2009 following the AINSI / UL 399. You can find the test on 

REFRIGERANT LEAK SIMULATION attached to this submission. The findings of the test point out that “this appliance has been 

identified as complying with the definition of clause 22.107 of EN 60335-2-24 for "Compression-type appliances with protected cooling 

system which uses flammable refrigerant" in this case Propane”.

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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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) Propane has zero ozone depleting potential (ODP = 0)

(b) Atmospheric lifetime in years (ALT): 0,03 (WMO 2010 Scientific Assessment Report (2011))

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. 

(a) GWP (100 years) = 3.3

(b) R290 natural refrigerant gas has excellent thermodynamics properties leading to high energy efficiency.

In BLUPURA drinking water coolers R290 is between 15 and 20% more energy efficient than R22 or R134a, depending on the 

model, and therefore type and brand of compressors used, as well as type of heat exchangers, etc.

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)

OMB Control No.: 2060-0226

Previous editions are obsolete

9

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

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 : Propane is regulated as a VOC under the Clean Air Acts. It is observed by [112(r)] 

as an Accidental Release Prevention Substance

the Clean Water Act (CWA) _________________________________________________________________________

the Safe Drinking Water Act (SDWA) _________________________________________________________________

the Resource Conservation and Recovery Act (RCRA) ____________________________________________________

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) ____________________________________________

the Toxic Substances Control Act (TSCA): Propane is TSCA substance for Chemical Inventories (10,000 pounds).

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) ________________________

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): Propane is a EPCRA substance for Chemical 

Inventories (10,000 pounds)

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

Propane is on state list a Hazardous Substance in Delaware, Massachusetts, Minnesota, New Jersey (RTK List), Pennsylvania, and in 

Washington with Permissible Exposure Limits for air contaminates.

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.

Analysis performed for the previous SNAP rules (March 17, 1994, at 59 FR 13044; December 20, 2011, at 76 FR 38832; April 10, 2015, at 

40 CFR Part 82, respectively) indicate that existing regulatory requirements and industry practices designed to limit and control these 

substances adequately control the emission of propane.

Propane is a NIOSH Hazardous Chemical [OSHA TWA 1000 ppm, NIOSH TWA of 1000 ppm (1800 mg/m3), ACGIH 1000 ppm]

Propane is a NFPA Hazardous Material LEL 2.1%, UEL 9.5% in air.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

10

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.

R290 costs Blupura around 15 US$ per pound (considering the quantities and the type of containers we buy today)

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.

Propane is commercially available in North America and other regions. It is already used in other applications in the USA, such as light 

commercial refrigeration and vending machines

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.

A water cooler uses a refrigeration circuit with a compressor, copper coils with refrigerants, as well as a heat exchangers (static or ventilated 

condenser). It is very similar to a domestic fridge.

With the R290 natural refrigerant gas we need to use a compressor designed to be used with this type of refrigerant, which does not make any 

sparkles. Compressors in 110 Volts , to be used with R290 , are already available for the US market , as the R290 is already approved to be 

used in domestic refrigerators and in vending machines.

The compressor for R290 is only slightly more expensive (approximately 5% more) than a compressor for R134 or R22.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

11

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).

Propane: 1,000 ppm PEL on 8-hr TWA; 6,900 ppm AEGL-1 over 30 minutes

Propane is not considered to be poisonous by OSHA

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

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).

Blupura will not be manufacturing propane, but will use it in new water coolers, which are manufactured in Italy (VIA ERIDEO 

MARINUCCI, 2/4, ZONA INDUSTRIALE SQUARTABUE, 62019 RECANATI (MC) - ITALY). R290 units will be imported to the USA from 

Italy.

Blupura does not currently have plans to manufacture these units in the USA.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

12

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 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.

(a) Release of or exposure to propane is possible at the change and sealing of a water cooler unit

(b) Workers are required to wear protective clothing, including mechanically-resistance gloves and safety goggles. Manufacturing equipment 

is designed to minimize potential emissions while engineering controls at the manufacturing facility include warning alarms for propane 

leakage and ventilation systems. Maintenance manuals describe procedures to reduce leakage and safety training is required for all personnel 

who work on the production line.

(c) Propane is in gaseous and liquid state during the manufacturing process

(d) In Autumn 2015: around 20 workers

(e) Each water cooler requires around one hour to be assembled and packed (depending on the type of model)

(f) The most common contact pathway is dermal exposure

(g) 10/50 ppm in the air

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

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.

(a) Less than 0.5kg / day due to connecting and disconnecting of units during charging

(b) Indoor air mostly

(c) VOC detection to find leaks at less than 25% of the LEL - an automatic shut-off valve will turn off the supply in case this level is recorded

(d) Under RCRA it is D001 Flammable material, recovery of this material once leaked is not likely

(e) There are currently no manufacturing sites for water coolers using propane in the USA

(f) The substitute is reclaimed.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

13

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 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).

(a) It is expected that the servicing of propane water coolers would happen rarely, since the equipment is hermetically sealed. In any case, 

servicing personnel should be adequately trained and follow the procedures outlined in maintenance manual.

(b) Protective goggles and safety glasses

(c) Liquid or gas

(d) One

(e) 2-3h/ year

(f) The most common path of contact is dermal, the most dangerous is inhalation of gas

(g) 10 / 50 ppm in air could be expected if a leak occurs 

Section F - CONSUMER EXPOSURE

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.

Units are hermetically sealed, no exposure is expected. In case of a leak, exposure should be less than 8 hour time weighted average for 

propane and the time for the gas (in room air) to dissipate would be less than one minute.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

14

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.

Potential exposure is minimal and would not pose a risk to general population. Each water cooler unit will contain less than 150g of propane.

Exposure to propane is not expected to pose a significant toxicity risk to the general population.

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

OMB Control No.: 2060-0226

Previous editions are obsolete

15

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

1. Propane MSDSs (Linde, Airgas) Part I - 1-6

Part II - 1-25

21

2. Intertek - Refrigerant Leak Simulation Tests Part II- 28 9

3. Application Guideline: Practical application of refrigerants R600a and 

R290 in small hermetic compressors

Part II - III 16

4. Propane as R22-Replacement in Commercial Appliances Part II - III 4

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

OMB Control No.: 2060-0226

Previous editions are obsolete

16

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

 

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.