Form 1265

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Previous editions are obsolete 

### 1 United States 

### ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060

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Expires: 8/31/2014



## SNAP INFORMATION NOTICE

For Significant New Alternatives Date of Receipt: Aug 6, 2014

Date 90 Day Review Begins:

Date Review Comple ted:

CBI Status: When completed send this form to:
Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA
U.S. EPA 1310 L STREET NW
1200 PENNSYLVANIA AVE NW 10 th FL OOR (MC 6205J) WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: 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

- depleting 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

.

PAPER SUBMISSIONS: All paper submissions mu st 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, which 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.

CD

- ROM SUBMISSIONS: The SNAP program also accepts submissions via CD

- ROM. If information is to be claimed as confidential, all confidential information mu st be excised from one of the files on the CD

- ROM, which will be placed in the public docket; the other file must include the confidential material. The file with the confidential material must include “contain s CBI” in
the file name.

STEP

- BY

- STEP INSTRU CTIONS: The Instructions for the SNAP Information Notice and TSCA/SNAP Addendum (“Instructions”)

are designed to assist applicants in completing this form. The Instructions provide step

- by

- step guidance on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sector

- specific data requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all info r mation requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailabl e.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________ 

## X

Petition: New alternative, Substance, or Formulation__________________________________________________________ 

# 

Petition: Revision of the Existing SNAP list

_________________________________________________________________ _ 

# 

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________ 

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### 2 Part I

- GENERAL INFORMATION

You must provide the identity of the alternative chemical o r 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 INFORMATION

Please indicate the sector(s) for which you are submitting information on the substitute by checking the appropriate

boxes:

• Refrigeration and Air Conditioning 

### X

• Foam Blowing 

### 

• Solvent Cleaning 

### 

• Fire Extinguishing
and Explosion Prevention 

### 

• Sterilization 

### 

• Aerosols 

### 

• Adhesives, Coatings, and Inks 

### 

• Tobacco Expansion 

### 

• Pesticides 

### 

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 r substitute is also subject to review under FIFRA, provide the FIFRA Registration Number:

_____________________________ Part III

- RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as ne cessary.

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 that 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 commerce, 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 summaries of data, 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

Instructions for a more complete list of data to be submitted.) Please indicate test data to be included in your submission notice by checking the appropriate boxes:

• Health Effects Data 

### X Yes  No

• Flammability Data 

### X Yes  No

• Environmental Effects

Data 

### X Yes  No

• Environmental Fate

Data  Yes 

### X No

• Risk Assessments  Yes 

### X No

• Test Data Not in the Possession/

Control of the Submitter 

### X Yes  No

• Other Data 

### X Yes  No

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at t his 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 th e time of submission may result in disclosure of information by the Agency without further no tice.

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 cl aimed as confidential, you must provide a “sanitized” version of this notice, including attachments, to EPA with y our submission. For additional information on claiming information as confidential, please see the Instructions Manual.

Information submitte d 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 development and implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within the EPA Office of the Atmospheric Program s 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 to 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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### 3 Part I

- GENERAL INFORMATION

Section A

- SUBMITTER IDENTIFICATION

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

Eric P. Youngdale

__________________ Global Marketing Manager, DuPont Stationary Refrigerants

Name of Authorized Official Title

DuPont Fluoroproducts

______________________ _______________________________________ Company/Organization

Chestnut Run Plaza P. O. Box 2915 974 Cen tre Road Wilmington, DE 19805 _ _(Office

- 302

- 999

- 5386)_(FAX

- 302

- 999

- 4925 ) Mailing Address Telephone & Fax Numbers

Eric.P.Youngdale@DuPont.com_

__ E- mail Address

(b) A gent (if applicable)

___________________________________________________________________________________________________________ _ Name of Authorized Official Title

___________________________________________________________________________________________________________ _ Company/Organization

_________________________________________________________________________________________________________ __ _ Mailing Address Telephone & Fax Numbers

____________________________________________________________________________________________________________ E- mail Address

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________ Name of Authorized Official Title

____________________________________________________________________________________________________________ Company/Organization

___________________________________________________________________________________________________________ _ Mailing Address Telephone & Fax Numbers

____________________________________________________________________________________________________________ E- mail Address

2. Technical Contact (in U.S.)

Mary E. Koban

_______________________________________________________ Sr. Technical Enginee r Name of Authorized Official Title

DuPont Fluoroproducts

______________________________________________________________________________________ Company/Organization

Chestnut Run Plaza P. O. Box 2915 974 Centre Road Wilmington, DE 19805 ( Office

- 302

- 999

- 2692)_(FAX

- 302

- 999

- 2093 ) Mailing Address Telephone & Fax Numbers

Mary.E.Koban@DuPont.com__

________________ ________________ ________________________ E- mail Address

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, ph one, etc.) and the EPA staff person’s name:

Mark (X) if None ________________ 

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

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### 4 Part I - GENERAL INFORMATION (continued)

Section B

- ALTERNATIVE IDENTIFICATION

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



### Opteon® XP40

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

constituent. For powdered aerosols used in fire suppression, s ee page 11 of the Instructions for additional necessary composition information.

(b) Chemical Abstracts Service (CAS) registry number an d molecular formula. (c) For alternative processes and technologies describe the technology and and provide a diagram of the system. Also provide the information on any chemical constituents.

(d) If you have applied for or hold a patent on the sub stitute, provide the patent name

, number (if available), and information on the topics covered in the patent.



### Parts a), b), and c) are shown in table below:

Part d) Confidential

3. Generic name :
I f the name of the substitute is declared Confidential Business Information , provide a generic name

.

While we are not declaring this blend as CBI, we do note for information that this blend was previously denoted in several in dustry studies as

DuPont TM DR

- 33 or simply DR

- 33.

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### 5

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 su bstitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A

to the Instructions, beginning on p. 23

. If the alternative is a refrigerant, indicate whether it is a candidate for use in retrofits of existing equipment, for use in new equipment only, or both.

(b) Identify the ODS and the quantity of substitute needed to replace it for each end use in pounds ( i.e., the replacement ratio).



### Part a) This blend is a nonflammable chlorine

- free HFC/HFO refrigerant blend. This refriger ant blend has been developed
as a lower global warming, non

- ozone depleting replacement for R- 402A, R

- 402B, R- 404A , R

- 407A, R

- 407C, R

- 407F, and

R- 507A.

This blend can be used for both retrofit and new equipment applications for the refrigeration and air conditioning sectors of:

• Chillers

• Cold storage warehouses

• Commercial comfort air conditioning

• Commercial ice machines

• Heat transfer

• Household refrigerators, household freezers

• Ice skating rinks

• Industrial process refrigeration systems

• Industrial proces s air conditioning

• Refrigerated transport

• Retail food refrigeration

• Residential de

- humidifiers

• Residential and light commercial air conditioning and heat pumps

• Vending machines

• Water Coolers

Part b) 

### This substitute is a replacement for the ODS substance defined as HCFC

- 22. The replacement ratio for this blend is approximately 100% of HCFC

- 22 , 1 lb per 1lb of HCFC -2 2.

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

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### 6 Part I - GENERAL INFORMATION (continued)

Section B

- ALTERNATIVE IDENTIFICATION (Continued)

5. Impurities

(a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial purposes. If there are unidentified impurities, enter “uni dentified.”

(b) Provide the CAS Registry Number for each impurity if available. (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight

percentages.



### Part a) Confidential

P art b) Confidential

Part c) Confidential

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

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6. Byproducts:

(a) Describe any byproducts o r 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 products enter “unidentified.”

(b) Provide the CAS Registry Number for each byproduct or degradation product if available. (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, in case of fire, etc.) and the amount

or rate at which it is formed.



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Ma rk (X) this box if this page contains CBI __________ 

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### 8 Part II - ALTERNATIVE

- SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES

– See Appendix B to the I nstructions to see which properties apply

to which uses.



### 1. Molecular weight 87.2 2. Physical state at 20 oC lique fied gas

3. Melting point at 1 atm. pressure o C N/A 4. Boiling point at 1 atm. p ressure
- 46.0 oC

5. Specific gravity >1 g/ml @25C 6. Odor threshhold Not determined mg/m 3



### 7. Solubility using solvent N/A @ temperature o C g/L

8. Solubility in water @ temperature N/A oC

9. Partitio coefficient N/A Log K

ow 

### Log K 

10. Vapor pressure @ 20 o C 161.5 psi

(Also provide vapor pressure

- temperature curve for refrigerants.) 

### 11. Critical temperature

81.5 o C 12. Critical Pressure

645 psi a

13. Are spectra attached? No 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 oC N/A

19. pH@concentration N/A 20. Thermal conductivity (for foam blowing age nts)

N/A

21. Adsorption coefficient N/A 22. Flammability limits (LFL, UFL) % vol N/A

Non

- flammable per ASTM E

- 68 1

23. Flash point N/A 24. Heat of combustion 

### 7.65 Mj/kg

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

27. Other (specify)

28

. Flammability: Provide any information on flammability concerns. For example, if any 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. For flammable refrigerants, provide a fault tree analysis for each end use.

For flammable foam blowing agents used in spray foam, provide a training progr am that addresses flammability concerns specific to this

substitute. (See Appendix B to I nstructions for sector

- specific data requirements for flammable substances).

The worst case formulation (WCF) and worst case fractionated formulation (WCFF) were test ed for flammability according to ASTM

E681

- 2004 test procedure as required in ASHRAE Standard 34

- 2010 and described in Appendix B1 to ASHRAE Standard 34

- 2010.

Test conditions were 60 ° C and 50% relative humidity for the WCF and 60 ° C and 50% relative humid ity for the WCFF.

Opteon ® 

### XP40 was found to be nonflammable at the WCF and WCFF when tested at 60oC. The tests were conducted in the DuPont Fluoroproducts analytical laboratory at Chestnut Run Plaza, Wilmington, DE.

Reference: Confidential

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

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### 9

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 the

individual constituents. Reference the source for each ODP. (b) Provide any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading potentials). Refer ence the source of this information and attach any supporting documentation.



### a) This blend contains no chlorine or bromine and is composed of three fluorina ted hydrocarbons (HFC’s) and a fluoro

- olefin

(HFO) , each with zero ozone depletion potential (ODP).

b) Therefore, ODP= 0 (zero)

2. Global Warming Characteristics:

(a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) relative to carbon di oxide over 100

- year time horizon, and 20

- year or 500

- year time horizon, if known. Reference the most recent as sessment report of the Intergovernmental Panel on Climate Change (IPCC AR4) . Alternate sources may include the 2010 World Meteorological Organization (WMO) Scientific Assessment of Ozone Depletion or the peer

- reviewed literature

. If the substitute is a b lend, provide the GWPs of the individual constituents and an estimate of the blend at its nominal composition

.

(b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/

- X%) and

resu lts of any testing or modeling done (both theoretical and actual testing). Energy efficiency information is particularly useful for refrigerants and foams.

(c) For GWP values that do not come from AR4 or WMO 2010, p rovide any available additional dat a on the atmospheric lifetime and GWP of the alternative, including infrared absorption spectrum and infrared absorption capacity. Reference the source of this information.



### Part a)

Reference: IPCC Fourth Assessment Report, Table 2.14 Reference: CF 3CFQCH2 and (Z)

- CF3CFQCHF : temperature dependent OH rate coefficients and GWP; Phys. Chem. Chem. Phys., 2007, 9, 1

– 13 Reference: IPCC Fifth Assessment Report, Table 8a



### Part b) Confidential

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

##  Part II - ALTERNATIVE

- SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATIONForm 1265

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### 10

Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section C

- OTHER STATUTES AND STANDARDS

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory statutes

such as th ose listed below. List any concentration

- based or other numerical standards to which the alternative is subject under the standards and regulations.

Titles of the Clean Air Act (CAA) other than Title VI Not applicable to this produc t

_______________________________________

the Clean Water Act (CWA) Not applicable to this produc t

____________________________________________________

the Safe Drinking Water Act (SDWA) Not applicable to this product

_____________________________________________

the Resour ce Conservation and Recovery Act (RCRA) Not applicable to this product

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Not applicable to this product

______________________________

the Toxic Substances Control Act (TSCA) All components of the refrigerant blend are on the TSCA list

____________

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) None of the components listed are regulated

under CERCLA

the Emergency Planning and Community Ri ght to Know Act (EPCRA or SARA Title III) Not applicable to this product

S tate and local laws This product is not flammable, therefore, it is not expected to have any special regulations beyond those already governing safe use of refrigerants (local build ing codes, etc. )

________________________

Other applicable environmental federal, state, and local laws not mentioned above

_______________________________

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

_____ 

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### 11

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under health and safety related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupati onal 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 alternative is subject under the above statutes and regulations. Also l ist any other standard

- setting organizations such as the National Fire Prevention Association (NFPA) the American Society of Heating, Refrigerating, and Air Conditioning Engi neers (ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitu te from a health and safety perspective

.



### Part a) Confidential

Part b) The refrigerant components and refrigerant blend will be transported and handled per the appropriate DOT regulations for flammable and non

- flammable liquefied gas

. Part c) The refrige rant blend, Opteon ® 

### XP40, was been submitted to ASHRAE for safety classification per standard 34.

ASHRAE number R- 449A was assigned to this blend. Additionally, the refrigerant blend will be submitted to UL for

confirmation that the blend is non

- flammabl e per the listed nominal composition and WCFF.

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

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### 12 Part II - ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs asso ciated

with the alternative. Please describe the information used as the basis for this cost estimate

.



### Cost: Confidential

New Eq uipment : DuPont TM 

### Opteon® XP40 can be used with existing R- 402A. R

- 402B. R- 404A

, R- 407C, R- 407A, R

- 407F

and R

- 507A designs . (Please note that designing new equipment to HCFC

- 22 is no longer possible due to current regulations.)

Existing Equipment: Conve rsion costs are determined by servicing costs involving recovery of existing refrigerant, recharge

with DuPont TM 

### Opteon ® 

### XP40 and subsequent system optimization. However, in older systems, it may be beneficial to replace elastomeric seals to minimize the risk of leaks and potentially adjust the thermal expansion valves (TXVs), it may also require lubricant (oil) changes

.

2. Provide information on production of the substitute. Include estimates on:

(a) Year substitute will be available if no t currently produced.

(b) Total pounds production per year (current figure).

(c) Years to maximum market penetration.

(d) Maximum total production per year at market saturation.

(e) Estimated percentage of market at market saturation.



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

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

_____ 

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### 13

3. Describe any new equipment and use profiles that will be necessary in order to use the substitute . If retrofitting of existing equipment is required, detail changes in technologies needed to use the alternative and address any materials compatibil ity 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 materi als, equipment lifetime, changes in labor and energy costs

.



### This substitute blend has been designed as a replacement for HCFC

- 22

, R- 402A. R

- 402B, R- 404A, R

- 407A, R- 407C, R- 407F,

and R

- 507A

. It can be used in new equipment designed for R- 402A. R

- 402B. R- 404A, R

- 407A, R- 407C, R- 407F, and R50A, thus avoiding the need for system re

- engineer ing or re

- design. It can also be used for retrofit replacement of HCFC

- 22

, R- 402A, R

- 402B, R- 404A, R

- 407A, R- 407C, R- 407F, and R

- 507A in existing equipment.

No significant costs are involved in the use of this blend in new or existing equipment. Howev er, in older systems, it may be
beneficial to replace elastomeric seals to minimize the risk of leaks, change the TXV settings and potentially change the

lubricant.

The blend is expected to be compatible with all materials commonly found in refrigeration systems.

Reference: Confidential

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, summ arize below (and attach supporting information on) the acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammal s, fish, wildlife, and plants), if available. Include any data on impurities and degradation products if known. Also include information on any permissible exposure limits (PELs), occupational exposure limits (OELs), or Acceptable Exposure Limits (AELs) that have been set for the substitute for use in the workplace. In addition , please attach a copy of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonably likely to be exposed. (See Pgs. 16

- 17 of the Instructions for sector

- specific requireme nts for toxicity testing).



### Toxicity information : Confidential

The SDS for the components and DuPont TM 

### Opteon ® 

### XP40 are attached. The recommended blend 8

- hr TWA wo rkplace
exposure standard is 830 ppm

. This is based on additive formula using WEEL values of 1000 ppm for R

- 32, R125 and R

134a and WEEL value of 500 ppm for R

- 1234yf

Reference: Confidential

Reference: Confidential

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

___ 

## 

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTUREForm 1265

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### 14

For ea ch manufacturing site ( for manufacturing of substitutes and/or products containing substitutes) :

(a) Identify 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 substitutes). (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products contain ing the substitutes. (d) Provide informat ion on the magnitude of release if available, along with the media to which the substitute is released (e.g.

, indoor air, outdoor air, water, land).



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

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



### Part III - RELEASE AND EXPOSURE DATA

Section C - OCCUPATIONAL EXPOSURE AT MANUFACTUREForm 1265

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### 15

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

(a) Describe the activities in which workers may be exposed to chemicals at the manufacturing facility

. Answer items (b) through (g) for each activity. (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 f or any worker, in terms of (1) hour s /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 meas ure.



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

Part f) Confidential

Part g) Confidential



### Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END

- USEForm 1265

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### 16

For each end

- use of a substitute (en d- uses u s ing the substitute in products and/or processes) :

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

, as a solid waste or wastewater effluent) at the point of, or subsequent to, the end

- use at a s ite 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 point. (c) Describe 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 disposal. (d) Are release s covered under RCRA? If so, identify the RCRA hazardous waste codes. (e) Identify the approximate number of sites expected to use the substitute. (f) Provide information on recycling of the substitute. Describe any associated costs and equipme nt.



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Releases not covered under RCRA.

Part e) Confidential

Part f) Standard HFC recycle equipment and procedures are used for DuPont TM 

### Opteon ® 

### XP40 EPA

- approved recovery equipment and recovery cylinders rated for HCFC

- 22 may be used to recover DuPont TM 

### Opteon ® 

### XP40.

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



### Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END

- USEForm 1265

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### 17

For all end -u se scenarios of the substitute (end

- uses utilizing the substitute in products and/or processes):

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

- use (i.e., during installation, maintenance, inspection, servicing, o r use)

. Answer items (b) through (g) for each activity. (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 han dling/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 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. Personal monitoring data may be required for some end uses (see pg s. 17

- 18 of Instructions).



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Part d) Confidential

Part e) Confidential

Part f) Confidential

Part g) Confidential

Reference: Gjolstad et al., J Environ Monit

. 2003 Apr;5(2):236

- 40



### Section F - CONSUMER EXPOSUREForm 1265

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### 18

For each end

- use of a substitute (end

- uses where a consumer might be exposed) :

(a) Identify the potentially exposed consumer population (e.g

, . indoor residents). (b) Identify the exposure medium (e.g.

, air). (c) Enter the contact pathway (e.g

, . ingestion, inhalation, dermal). (d) De s cribe the exposure p oint of concentration. Provide (1) average and (2) high

- end concentration estimates , including units of measure

.



### Part a) DuPontTM 

### Opteon ® 

### XP40 blend is used in air conditioning and refrigeration equipment from which any emission would only occur as a re sult of equipment failure since the systems are sealed units. It is expected that exposure levels to which the general consumers would be exposed, under these conditions would be minimal and additionally would be expected to occur only once in a consumers ’ lifetime. Additionally, any l eakage would normally b e expected in the parts of the sy stem
which tend to be remote and/or awa y from the public.

Part b) System failures could potentially release the product. As the product is a liquefied gas, even if the product is leaked in the liquid form, it will quickly vaporize and partition into the air. Therefore, potential exposures to the general public a re via

the air.

Part c) Normally, the potential exposure pathway would be inhalation

.

Part d) Exposure point conce ntration is expected to be extremely low. Exposure is estimated to be 0

- 100 ppm depending on the surrounding environment

.

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

## Form 1265

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### 19 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 general population exposur e points. (b) For each exposure point described in (a), identify the potentially exposed population (e.g.

, residents at the fenceline to the manufacturing facility ). (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 or ppb). Provide (1) average and (2) high

- end estimates.



### Parts a) and b) It is not expected that the general population would come into contact with the application equipment and any
emission due to equipment failure or leakage would be initially confined to a small area in close proximity to the equipment,
then readily dispersed. This would put the exposure of the general population close to zero.

P arts c) and d) Inhalation through the air

Part e) Confidential

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

## Form 1265

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### 20 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 assist EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citation s for information already submitted to EPA as part of past regulatory and information activities, as well as for other information that could not be included with this submission. If you have attached continuation pages, describe the Part, S ection and question number being continued. Attach additional pages if necessary. Mark (X) in the CBI box next to any attachment that contains information you claim as confidential.

Attachment Name Question # Number of Pages CBI



### IPCC Fourth Assessment Report, Table 2.14 Part II B. 2 1

CF3CFQCH2 and (Z)

- CF3CFQCHF : temperature dependent OH

rate coefficients and global warming potentials Part II B.2 15

IPCC Fifth Assessment Report, Table 8a Part II B.2 8

Gjolstad et al., J Environ Monit

. 2003 Apr;5(2):236

- 40 Part III E 5

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

____ 

## 

Part V

– CERTIFICATIONForm 1265

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

1. All information provided in this notice is complete and truthful 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 o r reasonably ascertainable by me.

3. If this is a submission of a new alternative, the company name d 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 an 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 anticipated facts regardi ng the alternative described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to section 1 13(c) of the Clean Air Act and 18 U.S.C.§1001.



### Signature and Title of Authorized Official (Original Signature Required): Date 8/6/2014

Signature of Agent (Where Applicable): Date

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 171 hours per year. For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 36 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 existing 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 otherwis e 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 Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency,1200 Pennsylvania Ave NW, Washington, DC 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.