Form 1265

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Previous editions are obsolete 

### 1 United States 

### ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060

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Expires: 8/31 /2014



## SNAP INFORMATION NOTICE

For Significant New Alternatives Date of Receipt:

Date 90 Day Review Begins:

Date Review Comple ted:

CBI Status: When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DO CUMENT CONTROL OFFICER
OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA

U.S. EPA 1310 L STREET NW

1200 PENNSYLVANIA AVE NW 10 th FL OOR (MC 6205J)
WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: 1 6 Document Control Number



### INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to subm it 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 “contain s CBI” in

the file name.

STEP

- BY

- STEP INS TRUCTIONS: 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 confidenti ality 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 in formation 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 notice submitted:

Manufactur er Submission: New alternative, Substance, or Formulation___________________________________________ ! Petition: New alternative, Substance, or Formulation__________________________________________________________ ☐
Petition: Revision of the Existing SNAP l ist_________________________________________________________________

_ ☐
Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________ ☐Form 1265

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### 2 Part I

- GENERAL INFORMATION

You must provide the identity of the alternative chemical o r 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 n ot 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 su bstitute 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. Ple ase reproduce these sections as

needed.

If you r 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 k nown 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 s cientific 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 lis t 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 t reated as Confidential Business Information (CBI). Substantiation of this claim must also be provid ed 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 th e time of submission may result in disclosure of information by the Agency without fur ther 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 informatio n is claimed as confidential, you must provide a “sanitized” version of this notice, including attachments, to EPA with y our submission. For additional information on claiming information as confidential, please see the Instructions Manual.

Information s ubmitted 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 regula tions 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 comple te 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 bu siness information as implemented by 40 CFR 2.301(h).Form 1265

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### 3 Part I

- GENERAL INFORMATION

Sec tion A

- SUBMITTER IDENTIFICATION

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

Luca Co stantini Founder & CEO

____________________________________________________________________________________________________ _______ __ Name of Authorized Official Title Blupura USA, Inc.

___________________________________________________________________________________________________ ______ ___ Company/Organization

12 00 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 app licable)

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@b lupura.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 communicat ion at FMI Connect 2015 in San Diego

Mark (X) if None ___________

_____ ☐

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

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### 4 Part I

- GENERAL INFORMATION (continued)

Section B

- ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternativ e:

P ropane

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, s ee 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 informatio n 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: C 3 H

3

CAS # 74

- 98

- 6

3. Generic name :
I f 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 I nstructions, beginning on p. 23

. If the altern ative 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. P ropane requires less than 60% of the total mass of the HFC chemica ls.

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

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### 5 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

pur poses. 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 the ir total weight

percentages.

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

- CAS 115

- 07

- 1, Isobutane

- CAS 75

- 28

- 5 c) T otal impurit ies are less than 0.5 %

6. Byproducts:

(a) Describe any byproducts o r degr adation 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 R egistry 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.

Unidenti fied

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

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### 6 Part II

- ALTERNATIVE

- SPECIFIC INFORMATION

Section A

- PHYSICAL AND CHEMICAL PROPERTIES

– See Appendix B to the I nstructions to see which properties apply

to which uses.



### 1. Molecular weight 44. 11 g/mol 2. Physical state at 20 o C gas

3. Melting point at 1 atm. pressure

- 187.6 o C 4. Boiling point at 1 atm. p ressure

- 42.1 o C

5. Specific gravity g/ml 6. Odo r threshhold mg/m 3



### 7. Solubility using solvent @ temperature o C g/L

8. Solubility in water @ temperature o C

9. Partition coefficient Log K

ow 

### Log K %

10. Vapor pressure @ 20 o 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

96.81 o C 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 o C

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

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### 7 28

. Flammability: Provide any information on flammability concerns. For example, if any abatement techniques are bein g used to minimize the risks associated with flammable substances or mixtures, detail those techniques below. If a substitute is flamm able, an

assessment of overall risk in each end

- use may be required. For flammable refrigerants, provide a fault tree an alysis 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 I nstructions 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).

F

lammability risks and occupational exposur es 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 5 8 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/guidelin es. 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 INTERTE K 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 60 335

- 2

- 24 for "Compression

- type appliances with protected cooling system which uses flammable refrigerant" in this case Propane”.

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### 8

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). Refer ence the source of this information and attach any supporting documentation.



### (a) Propane has zero ozone dep leting 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 di oxide 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 W orld 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 particul arly useful for refrigerants and

foams.

(c) For GWP values that do not come from AR4 or WMO 2010, p rovide any available additional data on the atmospheric lifetime and GWP of the alternative, including infrared absorption spectrum and infrared absorpti on 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 ene rgy efficient than R22 or R 134a , 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 INFORMATIONForm 1265

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### 9

Part II

- ALTERNATIVE

- S PECIFIC 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 c oncentration

- 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) _________________________________________________________________

t he Resource Conservation and Recovery Act (RCRA) ____________________________________________________

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

the Toxic Substances Control Act (TSCA) : Pr opane 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, Massachu setts, 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 heal th and safety related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupational Safety a nd Health Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentr ation

- 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 Heat ing, 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 ; Decembe r 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 NIOS H Hazardous Chemical [OSHA TWA 1000 ppm, NIOSH TWA of 1000 ppm (1800 mg/m 3 ), 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

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### 10 Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section D

- COST AND AVAILABILITY OF THE ALTERNATIVE

1. Esti mate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associat ed

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 productio n 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 ye ar at market saturation.

(e) Estimated percentage of market at market saturation.

Propane is commercially available in N orth America and other regions. It is already used in other applications in the USA, such as light commercial refrigeration and ven ding 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 material s 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 materi als, 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 th e R290 natural refrigerant gas we need to use a compressor desig ned 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 ex pensive (approximately 5% more) than a compressor for R134 or R22

.

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### 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 informati on 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 an y permissible

exposu re limits (PELs), occupational exposure limits (OELs), or A cceptable 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 shee t, 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 3 0 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 ) Ident ify 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.
, in door 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.

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### 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) h our s /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 th e 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 product ion line. (c) Propane is in gaseous and liquid state during the manufacturing process (d) In Autumn 2015 : around 20 workers (e) Each water cooler require s around one hour to be assembled and packed (depending on the type of model) (f) The most common conta ct 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 u s ing 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 c ontrol 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 a ir 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.

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### 13 Part III

- RELEASE AND EXPOSURE DATA (continued)

Section E

- OCCUPA TIONAL 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 installati on, 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 phys ical 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 r equired for some end uses (see pg s. 17

- 18 of Instructions).

(a) It is expected that the servicing of propane water coolers would happen rarely, since the equipment is hermetically sealed. I n any case, servicing personnel should be adequately trained and follow the procedures outlined in maintenance manual. (b) P rotective goggles and safety glasses (c) L iquid or gas (d) O ne (e) 2

- 3h/ year (f) T he 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) De s cribe 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 averag e for propane and the time for the gas (in room air) to dissipate would be less than one minute.

Mark (X) thi s 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 e xposure medium (e.g.

, air, water). (e) Enter the exposure point concentration (mg/m 3 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.

E

xposure 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 t hat may assist EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citation s 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. 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 Commerc ial 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 b elief 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 o r reasonably a scertainable by me.

3. If this is a submission of a new alternative, the company name d 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

su bstance 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 1 13(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 da ta 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.