***** DRAFT March 2 5 , 2016***** 1 

## S ignificant New Alternatives Policy Program F ire Extinguishing and Explosion Prevention Sector

R isk Screen on Substitutes for T otal Flooding Systems in Unoccupied Spaces

Substitute: 2

- bromo

- 3,3,3

- trifluoropropene (2

- BTP)

This risk screen does not contains Clean Air Act (CAA) Confidential Business Info rmation (CBI) and, therefore, may be disclosed to the public.



### 1. INTRODUCTION

Ozone

- depleting substances (ODS) are being phased out of production in response to a series of diplomatic and legislative efforts that have taken place over the past two decades, including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAA A). The U.S. Environmental Protection Agency (EPA), as authorized by Section 612 of the CAAA, administers the Significant New Alternatives Policy (SNAP) Program, which identifies acceptable and unacceptable substitutes for ODS in specific end

- uses based o n assessment of their health and environmental impacts. EPA’s decision on the acceptability of a substitute is based on the findings of a screening assessment of potential human health and environmental risks posed by the substitute in specific applications. EPA has already screened a large number of substitutes in many end

- use applications within all of the major ODS

using sectors including: refrigeration and air conditioning, solvent cleaning, foam blowing, aerosols, fire suppression, adhesive s, coatings and inks, and sterilization. The results of these risk screens are presented in a series of Background Documents that are available in EPA's docket. The purpose of this report is to supplement EPA’s Background Document on the fire extinguishing and explosion protection sector (hereinafter referred to as the Background Document , EPA 1994 a ). This risk screen discusses the potential human health and environmental risks posed by 2

- bromo

- 3,3,3

- trifluoropropene (hereinafter referred to as 2

- BTP) when used as a flooding agent in unoccupied spaces as a replacement for Halon 1301 . There are several aviation applications for this proposed substitute inc luding the protection of engine nacelles and auxiliary power units (APUs)

. Table 1 details the composition of the proposed substitute and its potential impurities prior to activation

.

Table 1 : Composition of 2

- BTP and Potential Impurities
Component Chemical Formula CAS Number Concentration (Weight Percent)

2

- bromo

- 3,3,3

- trifluoropropene CF 3 CBr=CH 2 1514

- 82

- 5 99 .5 % Potential Impurities (maximum concentration) 1,2

- dibromo

- 3,3,3

- trifluoropropane C 3 H 3 Br 2 F 3 431

- 21

- 0 ≤ 0.3% 3,3,3

- trifluoropropyne C 3 HF 3 661

- 54

- 1 ≤ 0.1% 3,3,3

- trifluoropropene C 3 H 3 F 3 677

- 21

- 4 ≤ 0.1%

Section 2 of this report summarizes the results of the risk screen for the proposed substitute for use in unoccupied spaces

. The remainder of the report is organiz ed into the following sections:***** FINAL March 25 , 2016***** 2  Section 3: Atmospheric Assessment

 Section 4: Volatile Organic Compound Assessment

 Section 5 : Potential Health Effects

 Section 6 : Occupational Exposure Assessment

 Section 7 : General Population Exposure Assessment

 Section 8 : References



### 2. SUMMARY OF RESULTS

EPA’s risk screen indicates that the use of the proposed substitute will be less harmful to the atmosphere than the continued use of ODS and substitutes used in this sector, such as HCFC Blend A, HFC

- 227ea

, and HFC

- 125

, as it is less harmful to the ozone layer, has lower climate impact, and a shorter atmospheric lifetime. 2

- BTP’s contributions to volatile organic compound (VOC) emissions are likely to be insignificant compared to VOC emissions from all other source s (i.e., b oth anthropogenic and biogenic). EPA’s risk screen indicates that the use of the proposed substitute is not expected to pose a significant toxicity risk to personnel or the general population , specifically w hen the substitute is used on engine nacelles and APUs on aircraft a nd when proper engineering controls are employed during manufacturing activities

. It is expected that procedures identified in the material data safety sheet ( MSDS ) for 2

- BTP and good manufacturing practices will be adhered to, and that the appropriate safety and personal protective equipment (PPE) (e.g., protective gloves, tightly sealed goggles, p rotective work clothing , and suitable respirato ry protection in case of acciden tal release or insufficient ventilation ) consistent with OSHA guidelines will be used , as applicable, during manufacture and disposal of 2

- BTP total flooding systems

.



### 3. ATMOSPHERIC ASSESSMENT This section presents an assessment of the potential risks to atmospheric integrity posed by the use of 2

- BTP as a total flooding fire extinguishing agent in unoccupied spaces

. The proposed substitute is substantially less harmful to the ozone layer, has a lower climate impact and a shorter atmospheric lifetime compared to ODS (e.g., h alon 1301 ) . In addition, 2

- BTP has a lower climate impact and shorter atmospheric lifetime than those predicted for other substitutes examined in the Background Document, as

w ell as a commonly utilized substitute s

. Thus, EPA believes that use of 2

- BTP would result in substantially less harm to the climate and ozone layer than the continued use of ODS and commonly used ODS substitutes.

Table 2 : Atmospher ic Impacts of 2

- BTP Compared to Other Flooding Agents Chemical ODP GWP (100

- year) ALT (y ears ) Proposed Substitute 2

- BTP 0 .0028 a 0.23

– 0.26 b 7 days a Other Flooding Agents Halon 1301 15.9 c 7,140 d 65 d HCFC Blend A e 0.035 c 1,546 d NA f HFC

- 227ea 0 3,220 d 34.2 d HFC

- 125 0 3,500 d 29 d

a Patten et al. 2012
b GWP range represents GWPs for 30 ° N to 60 ° N and 60 ° S to 60 ° N emissions scenarios for a 100

- year time horizon. A tropospherically well

mixed approximation of the GWP is equal to 0.59. ( Patten et al. 2012)

c WMO (2010)
d IPCC 4 th Assessment Report (Forster et al. 2007)

e HCFC Blend A is a blend consisting of HCFC

- 123 (4.75%), HCFC

- 22 (82%), HCFC

- 124 (9.5%), and D

- limonene (3.75%).
f Atmospheric lifetimes are not given for blends because the components separate in the atmosphere. The ALT for HCFC

- 123 is 1.3 years, HCFC

- 22 is 12 years, HCFC

- 124 is 5.8 years, and D

- limonene ranges from less than a minute to a few hours (IPCC 4 th Assessment Report [Forster et al. 2007] and WHO 1998).***** FINAL March 25 , 2016***** 3 

### 4. VOLATILE ORGANIC COMPOUND (VOC) ANALYSIS

2

- BTP is regulated as a VOC under CAA (40 CFR 51.100(s)). Through regulations and standard industry practices, emissions of 2

- BTP should be controlled.

The submitter intends to manufacture 2

- BTP as a total flooding agent in unoccupied spaces as a replacement for Halon 1301. An assessment was performed to compare the annual VOC emissions from the use of 2

- BTP as total flooding agent to other anthropogenic sources of VOC emissions. Assuming the submitter’s maximum anticipated a nnual production of 2

- BTP for all proposed fire suppression end

- uses is entirely released (in the absence of controls), approximately [ ] of VOCs would be emitted. This is approximately equal to [ ] percent of all anthropogenic VOC emissions in the U.S. in 201 4 ; 1 however, the release of total production for all proposed end

- uses of 2

- BTP is extremely unlikely to occur , as this would imply that all installed total flooding systems would be completely discharged in the same year

. A n additional analysis was performed to determine more realistic annual VOC emissions from the use of 2

- BTP in total flooding applications. Assuming the average annual release rate for total flooding applications of 2.5 % is applied to the entire intended U. S. annual production of 2

- BTP
, approximately [ ] of VOCs would be emitted, which is approximately equal to [ ] percent of all anthropogenic VOC emissions in the U nited States. Although the VOC emissions for these fire suppression applications are several orders of magnitude l ower than other anthropogenic emissions , it is likely that the estimated VOC emissions estimated here can be further reduced. T here are acceptable fire suppression agents currently in use that are VOCs (e.g., perfluoroketones), and thu s, use of 2

- BTP is not expected to increase VOC emissions relative to these other acceptable substitutes. Furthermore, most releases of 2

- BTP are expected to be at altitude, not in the lower troposphere, and would contribute less to the VOC burden

. As the calculated annual releases of 2

- BTP from these analyses are several orders of magnitude smaller than other anthropogenic sources of VOC emissions and because 2

- BTP would not result in greater impacts on local air quality than other available options , EPA believes that through the use of regulations and standard industry practices, the environmental impacts of these VOCs are not considered a significant

concern

.



### 5. POTENTIAL HEALTH EFFECTS As required for a new chemical, the manufacturer of this agent s ubmitted a Toxic Substance Control Act (TSCA) Premanufacture Notice (PMN) for review by EPA. The PMN, designated as P

- 14

- 260, has completed EPA review and the manufacturer is presently subject to requirements contained in a TSCA section 5(e) Consent Order. Other future manufacturers and processors will be subject to a TSCA section 5(a)(2) Significant New Use Rule (SNUR) that is expected to be promulgated in 2016. The requirements of the consent order apply to all commercial manufacturing, processing, distri bution in commerce, use and disposal of 2

- BTP, unless exempted ; the SNUR would have similar or identical requirements to the consent order . The consent order require s use of 2

- BTP for aircraft either 1) as a total flooding agent in engine nacelles and APUs on aircraft or 2) as a streaming agent in handheld extinguishers in aircraft. In addition, a manufacturer for this agent is required to maintain workplace airborne concentrations of 2

- BTP at or below a specified New Chemical Exposure Limit (“NCEL”) of 1 p art per million (ppm), verified by exposure monitoring data ; otherwise PPE (e.g., respirators) must be provided to workers to prevent inhalation exposure. EPA developed the NCEL for 2

- BTP based on review of available toxicity studies (U.S. EPA, 2015b) . The NC EL i s the maximum 8

- hour time we ighted average (TWA) at which

1 Based on the 2014 annual total VOC emissions for the United States (i.e., approximately 17.13x10 6 MT) as reported in the National Emissions Inventory (EPA 2015a).***** FINAL March 25 , 2016***** 4 personnel in an occupational environment can be exposed regu larly without adverse effects. The basis of the NCEL is long

- term health effects ( decreased postnatal survival and increased gestation length ), and is not relevant to the acute exposure expected at end

- use of the fire suppressant. According to the MSDS, exposure to 2

- BTP through ocular or dermal absorption is unlikely to cause irritation, and ingestion is not li kely to occur in industrial use . However, t he most likely pathway of exposure is through inhalation. Overexposure via inhalation to the proposed substitute may cause central nervous system effects, such as dizziness, confusion, physical incoordination, drowsiness, anesthe sia, or unconsciousness. At concentrations of 1.0 percent or higher, the proposed substitute may cause increased sensitivity of the heart to adrenaline which might cause irregular heartbeats and possibly ventricular fibrillation or death. In the case that 2

- BTP is inhaled, person(s) should be immediately removed and exposed to fresh air. The MSDS recommends that if breathing is difficult, person(s) should seek medical attention. Short ocular, dermal, or ingestion exposures are not expected to pose a hazard. However, i n case of ocular exposure, the MSDS for 2

- BTP recommends that person(s) s Hastings7 hould immediately flush the eyes, including under the eyeli ds, with fresh water and move to a non

- contaminated area. Medical attention should be sought if irritati on develops or persists. In the case of dermal exposure to 2

- BTP, the MSDS recommends that person(s) should immediately wash the affected area with large amounts of water and remove all contaminated clothing and footwear to avoid irritation. If water is no t available, cover the affected area with a clean, soft cloth. Medical attention should be sought if irritation develops or persists. 2

- BTP is not likely to be hazardous by ingestion; however, in case of ingestion, th e MSDS recommends the person(s) to cons ult a physician immediately

. Do not induce vomiting without medical advice.

2

- BTP vapors are heavier than air and cause suffocation by reducing oxygen available for breathing, causing asphyx iation in high concentrations. Such vapors pose a potential hazard if large volumes are trapped in enclosed or low places. If person(s) are exposed to high concentrations, the person(s) will likely not realize that he/she is suffocating, but may experience central nervous system effects, such as drowsiness and dizziness. EPA’s review of the human health impacts of this proposed substitute is contained in the public docket for this decision. These risks and procedures after exposure are similar for other common fire suppressants. T he potential health effects of 2

- BTP are u nlikely to occur w hen following good industrial hygiene practices and the PPE and engineering control (e.g., ventilation) recommendations outlined in the MSDS for 2

- BTP
, Sections 6 and 7 of this risk screen , and above

. 

### 6. OCCUPATIONAL EXPOSURE ASSESSMENT The potential for personnel exposure to 2

- BTP during manufacturing , installa tion and servicing are examined in this section. EPA has evaluated the risks associated with potential exposures to 2

- BTP during production operations and t he filling of fire extin guishers as well as i n the case of an inadvertent discharge of the system during maintenance activities on the fire extinguishing system

. 2

- BTP is not expected to pose a risk to workers when the engineering controls and PPE recommendations referenced in th e MSDS for this proposed substitute are followed. For operations requiring handling of the substitute, e ngi neering controls should include adequate ventilation systems and enclosed or confine d operations to ensure exposure levels to the proposed substitute are below the NCEL

. I n general, use of appropriate PPE is recommended , specifically respirators during activities in which exposure to the proposed substitute cannot be controlled through other means

. I f the proposed substitute is handled in enclosed spac es where exposure l imits might be exceeded, a s elf

- contained breathing a pparatus (SCBA) should be used. When handling a leak in a storage container, p rotective clothing is recommended as well

as vapor

- in air detection systems . If the presence of the propos ed substitute is detected in the workplace atmosphere, there may be a need to purge the gas from the confined space (e.g., with air, water, or an inert gas followed by air), following by additional testing of the space to ensure the proposed substitute has***** FINAL March 25 , 2016***** 5 been removed completely from the atmosphere. Furthermore, gloves ( i.e., neoprene, polyvinyl chloride [ PVC ] , or polyvinyl alcohol [PVA]) should be worn when handling equipment containing the proposed substitute for prolonged periods. The combination of appropriate engineering controls and the use of PPE will ensure exposure levels to the proposed substitute are below the NCEL

.

6.1. Occupational Exposure during Manufacture As described by the submitter, there is limited exposure to the product during manufact uring. Personnel monitoring data were collected during the process of filling a fire extinguisher inside a filling booth equipped with local exhaust ventilation of 13.2 ACH. Air sampling data taken at the extinguisher filling area resulted in a TWA exposur e of 5.9 ppm (American Pacific 2015). This value takes into account measured exposures inside the fill booth and in the filling area (outside the booth). The fill booth was measured to have an approximate volume of 2 m 3 (70 ft 3 ). The table below summarizes the air sampling results provided by the submitter.

Table 3 . Occupational Exposure Assessment during Manufacturing

Proposed Substitute Ventilation

Rate (ACH) TWA Exposure (ppm) a NC EL (ppm) Inside the Booth Filling Area

(Outside Booth) Total Exposure

2

- BTP [ ] [ ] [ ] [ ] 1

a The operator has exposure inside the booth for 7 percent of the time and 93 percent of the time in the surrounding area.

These estimated exposure values are greater than the NCEL of 1 ppm. T o effectively mitigate potential occupational exposure and maintain average exposure levels below the NCEL , the manufacturing space should be equipped with specialized engineering controls and well ventilated with a local exhaust system and low

- lying source ventilation. The sampling data provided by the submitter demonstrates that local exhaust ventilation greatly reduces exposure concentration inside the fill both and in the filling area (American Pacific 2015) and as such, additional mechanical ventilation above the values tested [ ] can further control exposure levels to achieve a value of 1 ppm or lower. Testing and monitoring of the workplace atmosphere should be conducted regularly to ensure it has not been contaminated with the proposed substitute or a ny other airborne workplace hazards. Additionally, an eye wash fountain and quick drench facilities must be close to the production area. Employees responsible for chemical processing should wear the appropriate PPE, such as protective gloves, tightly seal ed goggles, p rotective work clothing , and suitable respirato ry protection in case of accidental release or insufficient ventilation

. EPA believes if these engineering controls are employed

, the appropriate occupational safety guidelines are adhered to, and appropriate PPE is used, significant occupational exposure during manufacture of 2

- BTP is not expected to occur

.

6.2. Occupational E xpos ure d uring Inst allation and Servicing Exposure to 2

- BTP is not likely during ins tallation or servicing of 2

- BTP total flooding systems for engines and APUs

. As indicated by the submitter, the risk of accidental activation of the fire extinguishing system wh ile personnel are present near the protected space is highly unlikely if p roper procedures are followed. Proper instructions on system installation and servicing included in manuals for the 2

- BTP systems should be adhered to.

The locations of the 2

- BTP bo ttles in the engine and APU compartments will vary by air plane model. The engine bottles could be installed inside or outside the pressurized volume, but they are connected through piping to the engines. APU bottles are typically installed forward of the APU firewall, outside of the pressurized volume of the plane. The bottles are hermeticall y sealed and the piping system is pressure tested, mitigating the potential for any leak of 2

- BTP from the system

. In the case of an inadvertent discharge of the system d uring maintenance activities on the fire extinguishing system or surrounding***** FINAL March 25 , 2016***** 6 equipment , the cowl doors that would be open to allow access to the area will allow personnel to immediately egress and avoid exposure (American Pacific 2014b )

. P rotective g loves and tightly sealed goggles should be worn for installation and servicing activities , t o protect workers in any event of potential discharge of the proposed substitute, accidental or otherwise

. F illing or servicing operations should be perform ed in well

- ventilated area s . If handling the material in poorly ventilated areas, use proper respiratory protection. Furthermore, maintenance procedures that provide specific instruction to prevent accidental discharge of 2

- BTP systems can be found in the Boeing Aircraft Maintenance Manual (AMM) (American Pacific 2014b)

.



### 7. GENERAL POPULATION EXPOS URE

2

- BTP is not expected to cause a significant risk to human health in the general population when used as a total flooding fire extinguishing agent

. The only general population exposure to 2

- BTP anticipated will be during discharge of the total flooding system. Should releases during manufacturing operations occur, engineering controls should be used (e.g.

, carbon absorption scrubbers) to collect and prevent the release of the proposed substitute to the atmosphere. 2

- BTP is not listed as a priority pollu tant or toxic pollutant under the Clean Water Act. Disposal of 2

- BTP total flooding systems is subject to local, state, and federal regulations, which ensure that releases of 2

- BTP and water contaminated with 2

- BTP are not be dumped into sewers, on the gro und, or into any body of water , but rather taken to a wastewater treatment facility or disposed of properly. 2

- BTP is not considered to be hazardous waste under EPA regulations implementing the Resource Conservation and Recovery Act. Disposal procedures as outlined in the proposed substitute’s MSDS and local, state, and federal regulations should be followed. EPA believes that by using proper engineering controls and by following disposal and containment recommendations outlined in the proposed substitute’s MSDS, exposure to 2

- BTP is not expected to pose a significant toxicity risk to the general population.



### 8. REFERENCES ACGIH. 2004. The Documentation of the Threshold Limit Values and Biological Exposure Indices. American Conference of Governmental Industrial Hygienists. Available at: www.acgih.org.

ACGIH. 2005. Guide to Occupational Exposure Values. American Conference of Governmental Industrial Hygienists.

ACGIH. 2006. Threshold Limit Values for Chemical Substances (TLV®

- CS). Dennis Casserly

, TLV®

- CS Committee

, University of Houston at Clear Lake

. American Conference of Governmental Industrial Hygienists

. Available online at : http://www.acgih.org/tlv/03_TLV

- CS

- Update_AIHce06.pdf

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- BTP for Use as a Fire Suppression Agent

. Significant New Alternatives Policy Program Submission to the U.S. Environment al Protection Agenc y. December 2013

. American Pacific Corporation. 2014a. Response to Incompleteness Letter for 2

- BTP for Use as a Fire Suppression Agent SNAP Submission. September 25, 2014

. American Pacific Corporation. 2014b. Response to Incompleteness Letter for 2

- BTP for Use as a Fire Suppression Agent SNAP Submission. November 10, 2014

. American Pacific Corporation. 2015. Industrial Hygiene Assessment Report. Prepared by Ferguson Risk Management, LLC for American Pacific Corporation. July 20 and August 11, 2015.***** FINAL March 25 , 2016***** 7 CDC. 1997. Respiratory Protection Program Manual. Office of Health and Safety, Centers for D isease Control and Prevention. January 1997.

Folland, C.K., T.R. Karl, J.R. Christy, R.A. Clarke, G.V. Gruza, J. Jouzel, M.E. Mann, J. Oerlemans, M.J. Salinger and S.

- W. Wang, 2001: Observed Climate Variability and Change. In: Climate Change 2001: The Scientific Basis. Contribution of Working Group I to the Third Assessment Report of the Intergovernmental Panel on Climate Change [Houghton, J.T., Y. Ding, D.J. Griggs, M . Noguer, P.J. van der Linden, X. Dai, K. Maskell, and C.A. Johnson (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Available online at: ht tp://www.grida.no/climate/ipcc_tar/wg1/pdf/wg1_tar

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Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. (2007)

. Errata. In : Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Available online at: http://www.ipcc.ch/pdf/assessment

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National Academy of Sciences (NAS). 2007. Acute Exposure Guideline Levels for Sel ected Airborne Chemicals: Volume 6. Committee on Acute Exposure Guideline Levels, Committee on Toxicology, National Research Council. Available online at: http://www.nap.edu/catalog/12018.html

.

NFPA. 2010

. NFPA 2010. Standard for Fixed Aerosol Fire Extingu ishing Systems. National Fire Protection Association

. Orkin, V. L. 2004. Photochemical Properties of 2

- bromo

- 3,3,3

- trfluoropropene and semi

- empirical kinetic estimates of its Global Impacts on the Atmosphere. Prepared by the National Institute of Stan dards and Technology Physical and Chemical Properties Division for American Pacific Corporation. July 2004.

OSHA. 2009. Fire Protection and Prevention. Occupational Safety & Health Administration . Available online at: https://www.osha.gov/dte/grant_materials/fy09/sh

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. Patten, K. O., V. G. Khamaganov, V. L. Orkin, S. L. Baughcum, and D. J. Wuebbles. 2012. Correction to “OH reaction rate constant, IR absorption spectrum, ozone depletion potentials and global warming potentials of 2

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- trifluoropropene,” J. Geophys. Res., 117, D22301.

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. 201 5 a . National Emissions Inventory (NEI) Air Pollutant Emissions Trends Data. Accessed 1 2 March 201 5 . Updated March 2015 . Available at: http://www.epa.gov/ttnchie1/trends/

.

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### EPA Re s pon se to Comment s Received from the Submitter of TSCA Pr e man ufactur e Not ice (PMN) P

- 14

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- 14

- 2 6 0. April 20, 2015.

U.S. EPA. 2012. Acute Exposure Guidelines (AEGLs) Definitions. Available online at: http://www.epa.gov/oppt/aegl/pubs/define.htm

.***** FINAL March 25 , 2016***** 8 U.S. EPA

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