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~ O 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 Paperpentane. 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