Form 1265

- 93 (Revised 1/05)

Previous editions are obsolete

1 United States



## ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060

- 0226

Expires: 4/30/00



## SNAP INFORMATION NOTICE

For Significant New Alternatives Date of Receipt:

Date 90 Day Review Begins:

Date Review Com pleted:

CBI Status: When completed send this form to:



## M ELISSA FIFFER

SNAP DOCUMENT CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J

U.S. EPA

1 200 PENNSYLVANIA AVE, NW

WASHINGTON, DC 20460

Enter the total number of pages in your SNAP informa tion Notice: 2 4 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

- dep leting 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.

All 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, wh ich 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.

The attached “Guidance Manual for the SNAP Information Notice ” is designed to assist applicants in completing this form. The

manual provides instructions on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, secto r

specific data requirements, and submitting test data and supplem ental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all info rmation

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if act ual 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

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2 Part 1

- GENERAL INFORMATION

You must provide the identity of the alternative chemical of

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 INFORMAT ION

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

a nd Explosion Prevention 

Sterilization 

Aerosols 

Adhesives, Coatings, and Inks 

Tobacco Expansion

Pestici des 

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 you substitute is also subject to r eview 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 t hat 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 com

merce, 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 sum

maries of dat a, 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 Guidance Manual for a

more complete list of data to be submitted.) Please indicate

test data to be included in your submission notice by

checking the ap propriate boxes:



### Health Effects Data  Yes 

#  No

Flammability Data  Yes  No

Environmental Effects

D ata  Yes  No

Environmental Fate

D ata  Yes  No

Risk Assessments  Yes  No

Test Data Not in the Possession/

C ontrol of the Submitter  Yes  No

Other Data 

#  Yes  No

LIST OF TEST DATA IS SHOWN IN PART IV

- LIST OF

ATTACHMENTSForm 1265

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3 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). Sub stantiation 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 disclo sure 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 our 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 devel opment and

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP progr am.

These Authorized Representatives may have access to any information received by the Stratospheric Protection Divisi on within

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 t o 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 bu siness

information as implemented by 40 CFR 2.301(h)

.Form 1265

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4 

## Part I

- GENERAL INFORMATION

Section A

- SUBMITTER IDENTIFICATION

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

__________________________________________________________________________________________________ ____ Name of Authorized Official JOHN EDWARD POOLE Title MANAG ING DIRECTOR

______________________________________________________________________________________________________ Company/O rganization REFRIGERANT SOLUTIONS LIMITED

______________________________________________________________________________________________________ Mailing Address 8 MURIESTON ROAD, HALE, ALTRINCHAM Telephone & Fax Numbers

CHESHIRE WA 15 9ST , ENGLAND, UNITED KINGDOM 00 44 161 926 9876 FAX 9875

(b) Agent (if applicable)

____________________________________________________________ __________________________________________ Name of Authorized Official Title

____________________________________________________________________ __________________________________ Company/Organization

______________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

(c) Joint Submitter (if applicable)

______________________________________________________________________________________________________ Name of Authorized Official Title

______________________________________________________________________________________________________ Company/Organization

_________________________ _____________________________________________________________________________ Mailing Address Telephone & Fax Numbers

2. T echnical Contact (in U.S. MR RON STEVENSON

______________________________________________________________________________________________________ Name of Authorized Official MR DAVID STEVENSON Title

PRESIDENT

______________________________________________________________________________________________________ Company/Organization RESOURCE SEPARATIONS

______________________________________________________________________________________________________ Mailing Address Rt 16, BOX 308A, Telephone & Fax Numbers

LONGVIEW, TEXAS TX75603 TEL: 903 643 3125

FAX 903 643 3125

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication

(letter, phone, etc.) and th e EPA staff person’s name:

DAVID GOODWIN

E

- mail 21 July 20 11

______________ 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

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

- 5 0

R S

- 5 0 IS A LOW GLOBAL WARMING REPLACEMENT FOR 404A AND R507 AND A NON OZONE DEPLETING

REPLACMENT FOR R22 . RS

- 5 0 2 IS SUITABLE FOR USE IN EXISTING EQUIPMENT AND USE BY ORIGINAL EQUIPMENT

MANUFACTUERS.

RS

- 5 0 WAS ASSIGNED A DESIGNATED ASH RAE NUMBER OF R

- 4 42 A WITH A SAFTEY CLASSIFICATION OF A1 BY

ASHRAE STANDARD 34 COMMITTEE ON 2 8 June 20 11

2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process name. For blends, provide the percent composition

of each constituents.

(b) Chemical Abstracts Service (CAS) registry number and molecular formula.

(c) For alternative processes and technologies describe the technology an d and provide a diagram of the system. Also provid e

the information on any chemical constituents.

(d) If you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an

attachment. If you have submitted a patent application but have not been granted one yet, indicate the date submitted and th e

expec ted time frame for a response.

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information).

RS

- 50

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).

RS

- 5 0 IS A LOW GLOBAL WARMING REPLACEMENT FOR R404A AND R507 AND A NON OZONE DEPLETING

REPLACEMENT FOR R22 IN THE FOLLOWING APPLICATIONS:

SUPERMARKET REFRIGERATION

INDUSTRIAL PROCESS REFRIGERATION SYSTEMS

ICE SKATING RINKS

COLD STORAGE WAREHOUSES

REFRIGERATED TRANSPORT

RETAIL FOOD REFRIGERATION

COMMERCIAL ICE MACHINES

THE SIZE OF THE RS

- 5 0 CHARGE CAN VARY SUBSTANTIALLY ACCORDING TO THE END USE FROM APPROXIMATELY 1

KG TO OVER 1000 KGS.

(b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacem ent

ratio).

RS

- 5 0 CAN BE USED IN RETROFIT OF EXISTING EQUIPMENT AND ALSO IN NEW EQUIPMENT. THE REPLACEMENT

RATIO FOR EACH END USE IS 0.9: I

, NAMELY 0.9 L B OF RS

- 52 TO 1 LB OF R 404A OR R 22

.

2Form 1265

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6 Mark (X) this box if this page contains CBI __________ 

# 

Part I

- GENERAL INFORMATION (continued)

Section B

- ALTERNATIVE IDENTIFICATION (Continued)

5. (a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured fo r

commercial purposes. If the re are unidentified impurities, enter “unidentified.”

(b) Provide the CAS Registry Number if available.

(c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weig ht

percentages.

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 produc ts

enter “unidentified.”

(b) Provide the CAS Registry Number if available.

(c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amoun t

or rate at which it is forme d.

(A) NO BYPRODUCTS OR DEGRADATION PRODUCTS RESULT FROM THE FORMULATION OF RS

- 5 0 BY THE BLENDING

OF THE F IVE COMMERCIALLY AVAILABLE HIGH PURITY STARTING MATERIALS.

(B) & (C) HF (HYDROGEN FLUORIDE) GAS, CAS NO 7664

- 39

- 3, WILL BE THE MAIN DEGRADATION PRODUCT

RESULTING FROM THE DISPOSAL BY INCINERATION OF RS

- 5 0

.

NB: RS

- 5 0 CAN BE RECOVERED, RECYCLED AND RECLAIMED PROVIDED THE REFRIGERANT HAS NOT BEEN MIXED

WITH OTHER REFRIGERANTS.

Mark (X) this box if this page contains CBI __________ 

# Form 1265

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7 

## Part II

- ALTERNATIVE

- SPECIFIC INFORMATION

Section A

– PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight 81.7 g/mol 2. Physical state at 20 ° C GAS AT 1 ATMOSPHERE

3. Melting point N/A 4. Boiling point at 1 atm. Pr essure

- 4 6.5 ° C (1)

5. Specific gravity 1. 21 *

g/ml 6. Odor threshhold N/A mg/m3

7. Solubility using solvent @ temperature ° C N/A

g/L

8. Solubility in water @ temperature LOW

SOLUBILITY

° C

9. Partition coefficients N/ A Log K

ow 

### Log K

∝

10 . Vapor pressure @ 20 ° C 1 92 (1) psi 11. Critical temperature

8 2.4 ° C 12 . Critical pressure

690 psi

13. Are spectra attached? N/ A 14. Disassociation constant N/A

15. Particle size distribution N/A 16. Volatilization from soil N/A

17. Volatilization from water N/A 18. Viscosity @ 20 ° C LIQUID 0.1 41 CENTIPOISE

VAPOUR 0.012 6 ( 2)

Cp

19. 

# pH@concentration N/A 19. Thermal conductivity LIQUID: W/Mk*

VAPOUR: W/mk(2)

21. Adsorption coefficient N/A 22. Flammability li mits (LFL, UFL) NONE % vol

23. Flash point NONE 24. Heat of combustion N/A

25. Maximum pressure rise N/A 26. Maximum rate of pressure rise N/A

27. Other (specify)

( 1) CAPACITY

(2) COEFFICIENTS OF PERFORMANCE

( 3 ) PRESSURE/TEMPERATUR E TABLE

( 4 ) THERMODYNAMIC TABLES

( 5 ) PRESSURE/ENTHALPY DIAGRAM

SEE PART IV

- LIST OF ATTACHMENTS 

## NB: (1) BUBBLE POINT

(2) 1 ATMOSPHEREForm 1265

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8

28. Provide any information on flammability concerns. For example, if a ny 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. (See Guidance Manua l for sector

- specific data requirements

for flammable substances).



### RS

- 5 0 IS NON FL A MMABLE AT WORST CASE FORMULATION AND WORST CASE FRACTIONATION AS

PER ASHRAE STANDARD 34 ASTM 681

- 98 FLAMMABILITY TEST

FLAMMABILITY TEST DATA & WORST CASE FRACTIONATION TE ST DATA DURING LEAKAGE ARE

DETAILED IN ATTACH ED REPORT BY SAFET CONSULTING ENGINEERS INC. SEE PART IV

– LIST OF

ATTACHMENTS

Mark (X) this box if this page contains CBI __________Form 1265

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9 

## Part II

- ALTERNATIVE

- SPECIFIC INFORMAT ION (Continued)

Section B

- ATMOSPHERIC INFORMATION

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

individual constituents.

R134a R125 R32 R227ea R152a

ODP (100 YEARS CFC 11) ZERO ZERO ZERO ZERO ZERO

(b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromin e

loading potentials). Reference the source of this information and attach any supporting documentation.

ATMOSPHERIC LIFETIME ( YEARS ) 14 29 4.9 34.2 1.4

CHLORINE LOADING NIL NIL NIL NIL NIL

BROMINE LOADING NIL NIL NIL NIL NIL

SOURCE OF DATA:

INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, CLIMATE CHANGE 1997 AND US EPA,

2. Global Warming Characteristics:

(a ) Provide the alternative’s global warming potential (GWP) relative to carbon dioxide over 100

- , 500

- , and 1000

- year time

horizons, if known. If the substitute is a blend, provide the GWPs of the individual constituents.

(b) If known, provide the alt ernative’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).

(c) Provide source of GWP or any additional data on the GWP of t he alternative, including the atmospheric lifetime, infrared

absorption spectrum, and infrared absorption capacity. If the alternative (e.g. CO 2 captured from a stream of waste gas as a by

product of fermentation).

R134a R125 R32 R227ea R152a

(a) GWP (100 YEARS ITH) 1430 ((1) 3500 (1) 675 (1) 3220 (1) 124 (1)

(c) M ODEL CA LCULATIONS INDICATE A HIGHER ENERGY EFFICIENCY AND SIMILAR CAPACITY TO R404A

. SEE PART IV

– LIST OF ATTACHMENTS

(1) i INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, CLIMATE CHANGE 2007. SEE PART IV

– LIST OF

ATTACHMENTSForm 1265

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10 Mark (X) this box if this page contains CBI __________Form 1265

- 93 (Revised 1/05)

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11 

## Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section C

- OTHER STATUTES AND STANDARDS

1. Describe whether an d how the alternative is regulated under other environmental regulatory statutes, for example other t itle s under the Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation

and Recovery Act (RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act

(TSCA), the C omprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and

Community Right

- to

- Know Act (EPCRA, also known as SARA Title III), and state and local laws. List any concentration

- based or

other numerical standards to which the alternative is subject under the above standards and regulations.

REGULATION OF THIS HFC SUBSTITUTE BLEND UNDER OTHER ENVIRONMENTAL REGULATORY STATUTES WILL BE

COMPARABLE TO THOSE THAT APPLY TO OTHER HFC REFRIGERANTS, NAMELY:

U.S. CLEAN AI R ACT AMENDMENTS 1990

AND FOR APPLICATION AS A REPLACEMENT IN EXISTING EQUIPMENT, THE PROVISIONS OF:

U.S. CLEAN AIR ACT AMENDMENTS 1990 SECTION 608

APPLY TO THE REMOVAL, RECOVERY AND RECYCLING OF THE EXISTING HCFC AND/OR CFC CHARGE BEING

REPLACED.

ANY U. S. REGULATIONS IMPLEMENTING THE KYOTO PROTOCOL ON CLIMATE CHANGE , RELATED TO EMISSIONS OF

HFCs WILL APPLY TO THIS BLEND.

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as thos e

im plemented 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 alterna tive is subject under the above statutes and regulations. Also list any other standard

- setting organizations such

as the National Fire Prevention Association (NFPA) or the American Society of Heating, Refrigerating, and Air Conditioning

Engineers (ASHRAE) , by which the substitute is evaluated.

OTHER REGULATORY REQUIREMENTS FOR HANDLING AND TRANSPORTATION APPLY AS FOR LIQUEFIED

REFRIGERANT GASES UNDER PRESSURE.

OSHA EXPOSURE LIMITS AND EUROPEAN OCCUPATIONAL EXPOSURE LIMITES FOR THE COMPONENTS OF THE

RS

- 5 0 BLEND HAVE BEEN USED TO DETERMINE THE EXPOSURE LIMIT FOR THE BLEND.

MATERIAL SAFETY DATA SHEET ATTACHED.

NFPA 704 HAZARD SIGNALS ARE RECOMMENDED BY REFRIGERANT SOLUTION S LIMITED AS [H

- F

- R

- S] 2

- 0

- 0 [NO

SPECIAL HAZARD] BASED ON TOXICITY, FLAMMABILITY AN D REACTIVITY DATA FOR THE COMPONENTS AND THE

FORMULATED BLEND.

Mark (X) this box if this page contains CBI __________ 

# Form 1265

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12 

## Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section D

- COST AND AVAILABILITY OF T HE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installati on

costs associated with the alternative.

APPROXIMATE FORMULATION COST OF RS

- 5 0 IS US$ 7 PER LB.

IN NEW EQUIPMENT

, THE BLEND CAN BE USED TO REPLACE R404A, R507 AND R22 IN NEW EQUIPOMENT . IN THE

CASE OF R 22 NO RE

- NGINEERING OF THE EQUIPMENT IS NECESSARY. IN THE CASE OF R404A AND R507, THE

EX PANSIO N DEVICE WILL NEED TO BE REDUCED TO REFLECT THE LOWER MASS FLOW RATE, WH ICH IS SIMILAR TO

R22.

EXISTING EQUIPMENT “DROP

- IN”, CONVERSION INSTALLATION COSTS ARE MADE UP OF THE SERVICING COSTS,

INVOLVING RECOVERY OF EXISTING R22 AND/OR R 404A/R507 CHARGE AND RECHARGE WITH RS

- 5 0 AND

CONSEQUENT SYSTEM OPTIMISATION. TOTAL COST IS T HEREFORE COST OF REFRIGERANT CHARGE AND LABOUR

ONLY.

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.

I(d) Estimated percentage of market at market saturation.Form 1265

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13

3. Describe any new equipment an d use profiles. If retrofitting of existing equipment is required, detail changes in techn ologies

needed to use the altern ative 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 an d energy costs.

RS

- 5 0 IS A LOW GLOBAL WARMING REP LA CEMENT FOR R404A AND R507 AND A NON OZONE DEPLETING

REPALCEMENT FOR R22. RS

- 50 IS SUITABLE FOR USE IN NEW AND EXISTING EQUIPMENT

RS

- 52 CAN BE USED WITH NEW EQUIPMENT DESIGNED FOR R40 4A & R507 OR AS A RETR OFIT DROP

- IN

REPLACEMENT IN EXISTING R22 & R502 EQUIPMENT.

RS

- 5 0 DOES NOT REQUIRE THE REDESIGN OF EQUIPMENT. IN THE CASE OF R404A AND R507, THE EXPANSION

DEVICE WILL NEED TO BE REDUCED DUE TO THE LOWER MASS FLOW RATE, WHICH IS SIMILAR TO R22

NO SIGNIFICAN T CAPITAL COSTS ARE INVOLVED WHEN USING RS

- 5 0 AS A REPLACEMENT IN EITHER NEW OR

EXISTING EQUIPMENT.

R S

- 5 0 IS COMPATIBLE WITH ALL MATERIALS COMMONLY USED IN SYSTEMS DESIGNED AND CHARGED WITH R22

, R404A AND R507

.

INFORMATION ON REFRIGERATION PERFORMANCE AN D CAPACITY IS ATTACHED IN PART IV

- LIST OF

ATTACHMENTS. IT IS EXPECTED THAT RS

- 50 WILL SHOW A HIGHER ENERGY EFFICIENCY THAN R404A AND R507

WHILE HAVING A SIMIILAR CAPACITY.

Mark (X) this box if this page contains CBI _________ 

# 

_



## 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 attached supporting

information) the acute and chronic toxicity o f 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 “Allowable Ex posure Limits” (AELs) that have been set for the substitute. In addition, please attach a

copy or facsimile of any hazard warning statement, label, material safety data sheet, or other information which will be prov ided to

any person who is reasonably lik ely to be exposed. (See Guidance Manual for sector

- specific data requirements).

R134a ACUTE TOXICITY LC50: 4 HOUR (RAT)

- > 359,300 PPM (1)

CARDIAC SENSITISATION NOEL

- 250,000 PPM (1)

SUBCHRONIC &

CHRONIC TOXICITY TERATOGENIC NOEL (RAT)

– 40,000 PPM (1)

SUBCHRONIC INHALATION (RAT) NOEL

– 40 ,000 PPM (1)

R125 ACUTE TOXICITY LC50: 4 HOUR (RAT)

- >769,000 PPM (2)

CARDIAC SENSITISATIO N THRESHOLD (DOG)

– 75,000 PPM (1)

SUB

- CHRONIC &

CHRONIC TOXICITY TERATOGENIC NOEL (RAT & RABBIT)

– 50,000 PPM (1)

SUBCHRONIC INHALA TION (RAT) NOEL

– 50,000 PPM (1)

CHRONIC NOEL

– 10,000 PPM (1)

R32 ACUTE TOXICITY LC50: 4 HOUR (RAT) 760,,000 PPM (1)

R227ea ACUTE TOXICITY LC50: 4 HOUR (RAT) 788,696 OOM (1)

R152ea ACUTE TOXICITY LC50: 4 HOUR (RAT) 400,000 OOM (1)Form 1265

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14

THE FIVE CONSTITUENTS OF RS

- 50, WHICH ARE R134a, R125, R32, R 227ea AND R152a, ALL HAVE A VERY LOW ACUTE

TOXICITY BY INHALATION.

R

- 32, R

- 125, R

- 134A, R

- 152A, AND R

- 227EA HAVE CLASSIFIED AS A FOR TOXICITY BY ASHRAE 34. ACCORDINGLY, A

BLEND OF ONLY THESE COMPONENTS WARRANTS THE SAME CLASSIFICATION IN THE ABSENCE OF CO MPOUNDING

OR OTHER INTERACTIVE EFFECTS, NEITHER OF WHICH IS APPARENT. ANALYSIS OF THE WORST CASE OF

FRACTIONATION FOR TOXICITY IS NOT WARRANTED FOR R

- 32/125/134A/152A/227EA (31.0/31.0/30.0/3.0/5.0) SINCE THE

OEL CONCENTRATION CONSISTENT WITH A TLV

- TWA (AND ALSO CONSISTENT WITH A PEL) FOR EACH COMPONENT

IS 1,000 PPM. ACCORDINGLY, A FRACTIONATION ANALYSIS FOR THE BLEND ALSO WOULD RESULT IN A CALCULATED

VALUE OF 1000 PPM V/V CONSISTENT WITH A TLV

- TWA FOR ANY CASE OF FRACTIONATION. THEREFORE, THE

WORST CASE OF FRACTIONATION FOR TOXICITY OF R

- 32/125/134A/152A/227EA (31.0/31.0/30.0/3.0/5.0) THEREFORE

JUSTIFIES CLASSIFICATION AS CLASS A FOR TOXICITY

.

A TWA (8 HOURS) OF 1,000 PPM HAS BEEN PROPOSED FOR RS

- 50 WHICH IS BASED ON THE ABOVE DATA DUE TO,

THE RELATIVE NON

- TOXIC INHALATION PROPERTIES OF THE FIVE CONSTITUENTS IN THE FORMULATED BLEND.

PRODUCT SAFETY DATA SHEETS FOR RS

- 50, R134a, R125, R32, R227ea AND R152a ARE ATTACHED. SEE PART IV

– LIST OPF ATTACHMENTS.

RECOVERY

RS

- 50 CAN BE RECOVERED FROM REFRIGERATION EQUIPMENT USING APPROVED REFRIGERATION RECOVERY

PROCEDURES AND EQUIPMENT. REFRIGERANT SOLUTIONS LIMITED WILL PROVIDE A FULL RECLAMATION SERVICE

THROUGH ITS DISTRIBUTOR/S.

RECOVERY

RS

- 5 0 CAN BE RECOVERED FROM REFRIGERATION EQUIPMENT USING APPROVED REFRIG ERATION RECOVERY

PROCEDURES AND EQUIPMENT. REFRIGERANT SOLUTIONS LIMITED WILL PROVIDE A FULL RECLAMATION SERVICE

THROUGH ITS DISTRIBUTOR/S.

RECLAMATION

RS

- 5 0 CAN AND SHOULD BE RECLAIMED BY THE FOLLOWING:

(1) RECLAMATION THROUGH PROPRIETARY RECLAMATION EQUIP MENT (EG REFRIGERANT SERVICES INC).

THE BLEND CAN BE CLEANED AND DRIED THROUGH THIS TYPE OF EQUIPMENT ON A FULL BATCH PROCESSING

TRANSFER BASIS. THIS ENSURES THAT THE FULL BATCH COMPONENTS ARE COLLECTED TOGETHER. THE

BLEND IS THEN ANALYSED FOR COMPOSITIO N AND ANY DIVERGENCE FROM THE SALES SPECIFICATION WILL

BE CORRECTED BY THE ADDITION OF THE APPROPRIIATE COMPONENT. THE RECOVERED WASTE MATERIAL (IE

OI, WATER, PARTICULATES) WILL BE DISPOSED OF ACCORDING TO THE WASTE REGULATIONS APPLYING.

(2) RECLAMATION BY DI STILLATION

THE BLEND CAN BE RECLAIMED BY POT TO POT BATCH DISTILLATION. THIS ENSURES THAT THE TOTAL

COMPONENTS ARE RECOVERED FROM THE PROCESS AND THE DISTILLED BATCH CAN BE ANALYSED FOR

CONFORMANCE TO THE COMPOSITION SPECIFICATION. ANY DIVERGENCE WILL BE CORRECTED TO BRING THE

BLEND BACK TO SPECIFICATION.

(3) DISPOSAL

WHEN THE RS

- 5 0 BLEND MATERIAL IS NO LONGER REQUIRED, OR IS CONTAMINATED WITH OTHER GASES

THAN THE FOUR COMPONENTS, RENDERING IT UNSUITABLE FOR RECLAMATION BY EITHER OF THE ABOVE

METHODS, THE MA TERIAL WILL BE DESTROYED. DESTRUCTION WILL BE CARRIED OUT IN INCINERATORS,

APPROVED AND REGISTERED BY THE AUTHORITIES FOR THE DESTRUCTION OF FLUOROCARBON COMPOUNDS

IN LIGUEFIED FORM.

REFRIGERANT SOLUTIONS LIMITED WILL TAKE ALL STEPS NECESSARY TO ENSURE TH AT ANY RECLAMATION OR

DESTRUCTION IS CARRIED OUT IN ACCORDANCE WITH THE ABOVE AND IIN CONFORMANCE WITH APPROPRIATE

STATE AND FEDERAL LAWS.Form 1265

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15



## Section B

- ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

(a) Ide ntify 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 substitute s).

(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.

ind oor air, outdoor air, water, land).

(a) REFRIGERANT SOLUTIONS LIMITED

8 MURIESTON RAOD

HALE

ALTRINCHAM

CHESHIRE WA15 9ST

ENGLAND

UNITED KINGDOM

RESOURCE SEPARATIONS

Rt 16

BOX 308QA

LONGVIEW

TEXAS 7X 75603

USA

REFRIGERANT SERVICES INC

1 5 WILLIAMS AVENUE

DART MOUTH

HALIFAX

NOVA SCOTIA B3 3 1 X3

CANADA

(b) NO SITE LOCATIONS AT PRESENT FOR MANUFACTURE OF PRODUCTS USING RS

- 5 0

. THIS NEW REFRIGERANT

WILL BE USED AT MANY SERVICE SITES.

Mark (X) this box if this page contains CBI __________



## Part III

- RELEASE AND EXPOSURE DATA

Section C

- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products con taining substitutes):

(a) Describe the activities in which workers may be exposed to chemicals.

(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 o f (1) hour/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) THE FORMUATION AND PA CKAGING FACILITIES FOR THE PRODUCTION OF RS

- 5 0 ARE DESIGNED AND

CONSTRUCTED TO ENSURE NEGLIGIBLE EMISSIONS. THE FACILITIES COMPLY WITH UK REQUIREMENTS FOR

EMISSIONS AND SAFETY AND CONSEQUENTLY WORKERS ARE NOT EXPOSED TO EITHER RS

- 5 0 OR ITS

CONSTITUENTS.

(b) P ERSONAL PROTECTIVE EQUIPMENT ACCORDING TO THE RS

- 5 0 PRODUCT SAFETY DATA SHEET IS WORN

DURING MANUFACTURE OF RS

- 52 , IE EYE PROTECTION AND IMPERVIOUS GLOVES. ALL EQUIPMENT IS

EARTHED.Form 1265

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16

(c) ALL THE COMPONENTS OF RS

- 5 0 ARE LIQUEFIED GASES UNDER PRESSURE

(d) THE AVERAG E NUMBER OF WORKERS EMPLOYED IN THE MANUFACTURE OF RS

- 5 0 IS TWO. THE MAXIMUM

NUMBER OF WORKERS IS FOUR.

(e) THE WORKERS OPERATE A ROTATION SYSTEM WORKING A MAXIMUM 8 HOUSRS/DAY AND APPROXIMATELY 100

DAYS/YEAR.

(f) THE CONTACT PATHWAY WOULD BE INHALATION SHOULD A NY RELEASE OCCUR.

(g) UNDER NORMAL CONDITIONS OF FORMULATION AND PACKAGING, THE ESTIMATED EXPOSURE

CONCENTRATION IS NEGLIGIBLE. THE RECOMMENDED OCCUPATIONAL LEVEL (TWA) FOR RS

- 5 0 IS 1000 PPM AS

QUOTED IN THE PRODUCT SAFETY DATA SHEET.



## Section D

- ENVIRONMENTAL RELEASE AND DISPOSAL IN END

- USEForm 1265

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17

For each end

- use of a substitute:

(a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous

waste or

Waste water effluent) 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 poin t.

(c) De scribe 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 dispos al.

(d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes.

(e) Identify the appropriate number of sites expected to use the substitute.

(f) Provide information on recycling of the substitute. Describ e any associated costs and equipment.

(a) RS

- 5 0 IS A REPLACEMENT FOR R22 , R 404A AND R507 FOR USE IN LEAK

- FREE REFRIGERATION AND AIR

CONDITIONING SYSTEMS. RS

- 5 0 CAN BE RECOVERED AND RECYCLED. RESTRICTIONS ON VENTING TO

ATMOSPHERE SHOULD BE OBSERVED, AND RELEAS ES DURING CHARGING AND MAINTENANCE WILL BE

MINIMAL.

(b) ANY ACCIDENTIAL RELEASE WILL BE EITHER INDOOR AIR OR OUTDOOR AIR DEPENDING ON THE LOCATION OF

THE EQUIPMENT AND POSITION OF THE LEAK.

(c) GOOD HOUSEKEEPING AND FREQUENT INSPECTION WILL LIMIT RELEASES. REFRI GERANT SOLUTION S LIMITED

IN THE UK, RESOURCE SEPARATIONS IN THE USA AND REFRIGERANT SERVICES INC IN CANADA WILL TAKE

BACK RECOVERED RS

- 5 0 FOR RECYCLING AND RECLAMATION. IF RS

- 5 0 IS MIXED WITH OTHER REFRIGERANTS

THEN THE MIXTURE CAN BE DESTROYED BY HIGH TEM PERATURE INCINERATION IN AN APPROVED FACILITY

CAPABLE OF ABSORBING AND NEUTRALISING THE BY

- PRODUCTS.

(d) RS

- 5 0 IS NOT A HAZARDOUS WASTE.

(e) FEW MANUFACTURING SITES ARE EXPECTED TO USE RS

- 5 0 . HOWEVER, MANY REFRIGERATION SERVICE

SITES ARE EXPECTED TO USE RS

- 5 0

.

(f) RS

- 5 0 CAN BE RECOVERED, RECYCLED AND RECLAIMED USING STANDARD REFRIGERATION EQUIPMENT IN A

SIMILAR MANNER AND AT A SIMILAR COST TO A SINGLE FLUID REFRIGERANT.

Mark (X) this box if this page contains CBI __________Form 1265

- 93 (Revised 1/05)

Previous editions are obsolete

18 

## 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 worke rs may be exposed to chemicals.

(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) Es timate 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.

(a) RS

- 5 0 IS A REFRIGERANT TO REPLACE R22, R404 AND R507 AND WILL BE HANDLED AND USED IN THE SAME

MANNER AS OTHER REFRIGERANTS. GOOD HOUSEKEEPING, SAFE PRACTICES AND OBSERVATION OF

REGULATIONS ON VENTING TO ATMOSPHERE WILL AVOID END

- USERS BEING EXPOSED TO RS

- 5 0 AND ITS

CONSTITUENTS.

(b) INFORMATION ON PERSONAL PROTECTIVE EQUIPMENT HANDLING AND THE RECOMMENDED EXPOSURE LEVEL

(TWA) OF 1000 PPM IS GIVEN IN THE PRODUCT S AFETY DATA SHEET. HOWEVER, LOCAL CONCENTRATIONS

DURING CHARGING AND SERVICING OF EQUIPMENT WILL BE CONSIDERABLY BELOW THE TWA.

(c) RS

- 5 0 IS HANDLED AS A LIQUEFIED GAS UNDER PRESSURE.

(d) SITE SERVICE WORK INVOLVING RS

- 5 0 IS NORMALLY UNDERTAKEN BY INDIVIDUAL REFR IGERATION AND AIR

CONDITIONING ENGINEERS.

(e) THE DURATION FOR HANDLING RS

- 5 0 BY WORKERS INVOLVED IN EQUIPMENT MANUFACTURE OR SERVICE

WORK IS LIMITED TO THE RELATIVELY SHORT TIME OF CHARGING THE NEW REFRIGERANT.

(f) THE CONTACT PATHWAY WOULD BE INHALATION SHOULD ANY RELEASE OCCUR.

(g) UNDER NORMAL CONDITIONS OF END

- USE, THE EXPECTED EXPOSURE CONCENTRATION IS NEGLIGIBLE.Form 1265

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19



## Section F

- CONSUMER EXPOSURE

For each end

- use of a substitute:

(a) Identify the potentially exposed population (e .g. indoor residents).

(b) Identify the exposure medium (e.g. air).

(c) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

(d) Enter the exposure point of concentration. Provide (1) average and (2) high

- end estimates.

(a) RS

- 5 0 IS A REPLACEMENT REFRIGERANT FOR USE IN LEAK

- FREE REFRIGERATION AND AIR CONDITIONING

SYSTEMS. HENCE, EXPOSURE TO THE GENERAL CONSUMER IS EXTREMELY REMOTE. SHOULD EMISSIONS

OCCUR, THEY WOULD MOST LIKELY BE THE RESULT OF EQUIPMENT LEAKAGE, PARTICULARLY AT THE HIGH

PRESSURE SIDE OF THE EQUIPMENT. AS LEAKS TEND TO DEVELOP GRADUALLY AND THE HIGH PRESSURE

SIDE OF LARGER EQUIPMENT IS USUALLY REMOTE FROM GENERAL CONSUMERS AND THE PUBLIC AND

LOCATED IN WELL VENTILATED AREAS, THE LIKELY POPULATION TO BE EXPOSED IS EXTR EMELY SMALL.

(b) THE EXPOSURE MEDIUM WOULD BE AIR.

(c) THE CONTACT PATHWAY WOULD BE INHALATION SHOULD EXPOSURE OCCUR.

(d) THE CONCENTRATION AT THE EXPOSURE POINT IS EXPECTED TO BE EXTREMELY LOW AND VERY

INFREQUENT, IF AT ALL.

Mark (X) this box if this page conta ins CBI __________ 

# Form 1265

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20 

## 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 expos ure points.

(b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline).

(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/m 3 ). Provide (1) average and (2) high

- end estimates.

THE GUIDANCE DOCUMENT STATES: “ YOU DO NOT NEED TO PROVIDE THE INFORMATION REQUESTED IN THIS

SECTION UNLESS YOU CHOOSE TO DO SO.”

(a)&(b) IT IS NOT ANTICIPATED THAT THE GENERAL PUBLIC WOULD COME INTO DIRECT CONTACT WITH PARTS

CONTAINING RS

- 5 0 . EMISSIONS FROM EQUIPMENT LEAKAGE, OR EVEN FAILURE, WOULD BE CONFINED TO THE

RELATIVELY SMALL AREA AROUND THE EQUIPMENT. HENCE, EXPOSURE TO TH E GENERAL PUBLIC WOULD BE

EXPECTED TO BE NEGLIGIBLE AND VIRTUALLY ZERO.

(a) THE CONTACT PATHWAY WOULD BE INHALATION SHOULD EXPOSURE OCCUR.

(b) THE EXPOSURE MEDIUM WOULD BE AIR.

(c) THE CONCENTRATION AT THE EXPOSURE POINT IS EXPECTED TO BE VIRTUALLY ZERO.

Mark (X) this box if this page contains CBI __________ 

# Form 1265

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21 

## 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 assi st EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citation for information already

submitted to EPA as part of past regulatory and information activities, as well as for other information that could not be in cluded

w ith this submission. If you have attached continuation pages, describe the Part, Section and question number being continued

. Attach additional pages if necessary.

Attachment Name Question # Number of

Pages CBI

RS

- 5 0 PRESSURE & TEMPERATURE TABLES APPENDIX 2 PTII SECTION A

Q27 4

RS

- 5 0

- THERMODYNAMIC TABLES APPENDIX 3 PTII SECTION A

Q27 2 1

RS

- 5 0 PRESSURE ENTHALPY DIAGRAM APPENDIX 4 PT II SEC TION A

Q27 1

IPCC 2007 GLOBAL WARMING POTENTIALS APPENDIX 7 PTII SECTION B Q2 1

RS

- 50 RETROFIT PROCEDURE FOR R404A & R507 APPENDIX 8 PTII SECTION D Q3 3

RS

- 50 RETROFIT PROCEDURE FOR R22 APPENDIX 9 PTII SECTION D Q3 2

RS

- 50 CAPACITY APPENDIX 10 PTII SECTION A

Q27 1

RS

- 50 COEFFICIENT OF PERFORMANCE APPENDIX 11 PTII SECTION A

Q27 1

RS

- 50 PHYSICAL PROPERTIES APPENDIX 13 PTII SECTION D Q3 1

RS

- 50 PRODUCT SAFETY DATA SHEET APPENDIX 14 PTIII SECTION A

8

HFC134a MATERIAL SAFETY DATA SHEET APPENDIX 15 PTIII SECTION A 9

HFC125 MATERIA L SAFETY DATA SHEET APPENDIX 16 PTIII SECTION A 7

R227ea MATERIAL SAFETY DATA SHEET APPENDIX 17 PTIII SECTION A 5

R32 MATERIAL SAFETY DATA SHEET APPENDIX 18 PTIII SECTION A 7

R152a MATERIAL SAFETY DATA SHEET APPENDIX 19 PTIII SECTION A 9

PRODUCT STEWARDHSIP APPENDIX 20 PTIII SECTION A 1

PAFT HFC125 TOXICITY SUMMARY APPENDIX 21 PTIII SECTION A 1

PAFT HFC134a TOXICITY SUMMARY APPENDXI 22 PTIII SECTION A 2

PAFT HFC32 TOXICITY SUMMARY APPENDIX 23 PTIII SECTION A 1

PAFT HFC227ea TOXICITY SUMMARY APPENDIX 24 PTIII SECTION A 2

Mark (X) this box if this page contains CBI __________Form 1265

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22 

## Part V

– CERTIFICATION

I certify to the best of my knowledge and belief that:

1. All information provided in this notice is complete and trut hful 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 co mpany name 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 a n 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 antic ipated 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 Si gnature Required):

Da te :

Signature of Agent (Where Applicable): Date

For persons filing a SNAP Information Notice, the reporting burden is estimate d to average 150 hours

per year. For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 46

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 existin g 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 U.S.Environmental Protection Agency, Attn: Director, Collection

Strategies Division, Office of Information Collection, 1200 Pennsylvania Avenue, NW, Mail Code

2822T, Washington, DC 20460. Please i nclude the EPA Docket ID Number OAR

- 2004

- 0077 and OMB

Control Number 2060

- 0226 in nay correspondence. Do not send the completed form to this address. 

# Managing DirectorForm 1265

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23