UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DEC 17 201Z 

OFFICE OF 

AIR AND RADIATION 

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Re: Incomplete SNAP Submission for [ 

Dear [ ] 

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Thank you for [ ]submission to the Environmental Protection Agency. The EPA 

established the Significant New Alternatives Policy program to implement section 612 of the 

Clean Air Act. We have reviewed for completeness your submission that we received on July 2, 

2012 and additional information received on September 21,2012. We have found the 

information to be incomplete. To be able to review your SNAP submission review, EPA requires 

the following information: 

1. Clarification of blend compositions. The new substitute is proposed for use neat and in 

blends of as little as [ 

] 

The actual blend formulation has the potential to vary widely. Please specify, or at least 

narrow, the chemicals and percentage of the chemicals to be used in blends for the solvent 

cleaning (metal, electronic, and precision cleaning), aerosol (solvent), and adhesives, 

coatings, and inks uses. 

2. Conversion of exposure estimates. In your PowerPoint presentation, you provided estimates 

ofhuman exposure to the proposed substitute in units ofmg/kg/day. Please confirm or 

correct the conversion from mg/kg/day to ppm. 

Worker Inhalation Exposure Estimates 

Units ofMeasure [ ] [ [ ] [ ] [ [ ] ] 

mg/kg/day [ ] [ ] [ ] [ ] [ ] [ ] (provided) 

ppm calculation [ ] [ ] [ ] [ ] [ ] [ ] (to be confirmed) 

Internet Address (URL) • http.//www.epa.gov 

Recycled/Recyclable ·Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 

] 
We estimated these values based on the following equation: 

Exposure Estimate [ ')X 

72 [ ] 110 [ ] X 24.45 ( ] I [ ][ ] 

In addition, please clarify whether these exposure estimates are based on the neat 

substance only or on a [ ]. 

3. Additional toxicity information. Do you have any 28-day or 90-day inhalation toxicity 

studies completed for this compound that you could provide? If you have not performed 

such a study, we request that you perform at least a 28-day inhalation toxicity study. If you 

conduct additional testing, we recommend that the testing include a functional observation 

battery on neurological effects. As inhalation is the most probable route of exposure, a repeat 

dose inhalation study would be helpful in fully assessing health effects and reducing 

uncertainty. 

4. Confidential business information (CBI) claims. Claims of CBI, if you wish to claim any of 

the information above as CBI. 

Here is a summary of information concerning your submission: 

Substitute names: [ 

] 

Name for publication in Federal Register: To be determined 

Substance(s) the substitute will replace: CFC-113, methyl chloroform, HCFC-225ca!cb 

Sector: Solvent Cleaning 

End-uses: metals, electronics and precision cleaning 

Substance(s) the substitute will replace: CFC-113, HCFC-141b, HCFC-225ca/cb 

Sector: Aerosols 

End-use: solvents 

Substance(s) the substitute will replace: CFC-113, methyl chloroform 

Sector: Adhesives, Coatings and Inks 

End-use: coatings 

Substance(s) the substitute will replace: CFC-113 

Sector: Refrigeration and Air-Conditioning 

End-use: non-mechanical heat transfer 

Retrofit or new: retrofit and new equipment 
Date most recent information received: November 20, 2012 

Status of submission: incomplete 

Responses to these questions would be helpful for our review. The information can be submitted 

via electronic mail if not confidential or via hard copy and/or DVD if your responses contain 

confidential business information. If you have questions about your submission, please contact 

me at (202) 343-9464 or Fiffer.melissa@epa.gov. 

Sincerely, 

Me

~w lissa Fiffer 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division