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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

AIR AND RADIATION 

Ms. Helen Walter-Terrinoni N0ti! 

Global Marketing Manager, 

Foam Expansion Agents 

DuPont Chemicals and Fluoroproducts 

CRP 702 Rm 1276-E 

4417 Lancaster Pike 

Wilmington, DE 19805 

Re: Incomplete SNAP Submission for FEA-1100 

Dear Ms. Walter-Terrinoni: 

Thank you for DuPont's submission to the Environmental Protection Agency. The EPA 

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

Clean Air Act. Your submission and the additional information received on September 9, 2011, 

have been reviewed for completeness as part of the initial SNAP review. We have found the 

submission to be incomplete. To be able to complete the SNAP submission review, EPA requires 

the following information: 

General Information 

1. Part I, Section B, Number 2(a) of the SNAP Information Notice states that FEA-1100 

may be used neat or in blends with other acceptable foam expansion agent alternatives. 

Please clarify whether or not FEA-1100 is anticipated for use as a blend. If yes, specify 

the substances (e.g., HFC-245fa, HFC-365mfc, and C3-C6 hydrocarbons) that may be 

blended with FEA-1100, and the composition of any anticipated blends (on a weight 

percent basis). 

Byproducts 

2. Please specify the catalyst used in the manufacture of foams when using FEA-1100 as the 

blowing agent. 

3. The additional data provided on September 9, 2011, are helpful; however, only 

preliminary stability data were provided. Please provide the final stability testing report 

once it becomes available. In addition, please provide the following: 

a. Clarification on the conditions under which and the point of manufacture at which 

anhydrous hydrochloric acid is formed as a byproduct of FEA-1100, and the rate 

of formation as a ratio to the production of FEA-1100 (grams:grams); 

b. Confirmation that the breakdown products of FEA-1100 in polyurethane foam 

systems are fluorotrimethylsilane, HFO-1336mzz-T, HFC-245fa, HFO-1335, and 

Intemet Address (URL) • http://www.epa.gov 

Recycled/Recyclable o Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
pentane. Please verify if HFO-1336mzz-T is the same as HFO-1334mzz-2E. 

Please further identify the structure(s) of HFO-1335, as public records of the 

structure associated with CAS Registry number 1186730-89-2 were not available 

and the structure of HFO-1335 is not readily discernible. If there are other 

potential degradation products, please identify them; and 

Information was provided on breakdown products for polyether and polyester 

foam systems, but the proposed FEA-1100 end-uses are expected in polyurethane, 

polyisocyanurate, and phenolic foam systems. Please provide information on the 

breakdown products from the use of FEA-1100 in phenolic and polyisocyanurate 

foam systems, and the amount formed and their concentrations (percent by 

weight), if there are different breakdown products expected. If there is a specific 

rationale for providing the breakdown products for polyether and polyester 

systems (e.g., this is a standard protocol and substitutes for testing other systems), 

please explain and/or provide documentation. 

4. If blends of FEA-1100 are anticipated, we will require additional information on 

degradation products that may result from decornposition of the blends in rigid cell foams 

for residential uses, including: 1) identification of the degradation products formed in 

rigid cell forms and their concentrations (% values, by weight); and 2) information on the 

catalyst and analysis of breakdown products under different conditions. 

Re[ease and Exposure Data 

5. In addition to the data on instantaneous exposure concentration at manufacture provided 

in Part III, Section C(g) and Attachment 23 of the SNAP Information Notice, please 

provide the exposure concentration as an 8-hour time-weighted average and as a 15- 

minute TWA. 

6. Part I, Section B, Number 4 of the SNAP Information Notice indicates that FEA-1100 

would be used for spray foams. Please clarify that the expected uses are 

industrial/commercial spray foams, and that consumer applications are not intended. If 

consumer use is expected, per Part III, Section F, please also provide the following 

information regarding consumer exposure: 

a. The type of application system. For example, the size of a consumer spray foarn 

can (grams), and the amount of foam blowing agent contained therein. 

b. The anticipated average and maximum exposure concentrations to the foam 

blowing agent during use of the spray foam in these consumer applications. 

7. Part III, Section B(d) of your submission indicated that quantities of FEA-1100 will be 

released to surface water after wastewater treatment. Please indicate the rate at which the 

compound will mobilize into the atmosphere (out of the surface water) after release 

(grams/second). 

Toxicity and Hazard Information 

Please provide EPA's SNAP program with a complete report for the second 90-day inhalation 

toxicity study, once available. 
Claims of Confidentiality 

In your response please include any claims of confidential business information, if you wish to 

claim any of the information submitted in response to the above as CBI. 

Here is a summary of information concerning your submission: 

Substitute name: FEA-1100 

Substance(s) the substitute will replace: CFC-11, CFC-113, HCFC-141b 

Sectors: Foam Blowing 

End uses: 

• Rigid polyurethane and polyisocyanurate laminated boardstock 

• rigid polyurethane appliance 

• rigid polyurethane commercial spray and sandwich panel 

• rigid polyurethane slabstock 

• integral skin polyurethane 

• flexible polyurethane 

• phenolic insulation board 

Date received: August 3, 2011 

Date most recent information received: Uctober 14, 2011 

Status of submission: incomplete 

Responses to the above questions would be helpful for our review. The information can be 

submitted via electronic mail or hard copy. If you have questions about your submission, please 

contact Melissa Fiffer, the SNAP Coordinator, at (202) 343-9464 or fiffer.melissa@epa.gov . 

Sincerely, 

Margaret A. Sheppard 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division