Form 1265

- 07 (Revised 09/2011)

OMB Control No.: 2060

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Previous editions are obsolete 

### 1 United States 

### ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060

- 0226

Expires: 8/31 /2014



## SNAP INFORMATION NOTICE

For Significant New Alternatives Date of Receipt:

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 DO CUMENT 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 ma terial. 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 confidentiali ty 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_____________________________________________ 

# Form 1265

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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 subst itute 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 scient ific 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 t reated 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 f or 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 _____ X

_____ 

## Form 1265

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### 4 Part I

- GENERAL INFORMATION (continued)

Section B

- ALTERNATIVE IDENTIFICATION

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



### Opteon ® 

### XP10

2. (a) Name of chemical(s) (preferably IUPAC nomenclature ) and/or process n ame. 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 numb er and molecular formula. (c) For alternative processes and technologies d escribe the technology and p rovide 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 su bstitute, 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 Con fidential Business Information , provide a generic name

.

We note for information that this blend was previously denoted in several industry studies as

DuPont TM DR

- 11 or simply DR

- 11

.

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

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### 5

4. Specific End

- U se

(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)

. 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 refrigerant blend has been developed

as a lower global warming, non

- ozone depleting r eplacement for R

- 134a

. 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

• Comm ercial ice machines

• Heat transfer

• Household refrigerators, household freezers

• Ice skating rinks

• Industrial process refrigeration systems

• Industrial process air conditioning

• Refrigerated transport

• Retail food refrigeration

• Residential de

- humidifiers

• Resid ential 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 CFC

- 1 2. The replacement ratio for this blend is approximately 100% of CFC

- 1 2 , 1 lb per 1lb of CFC

- 12

.

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 reas onably be anticipated to be present in the chemical alternative as manufactured for commercial purposes. If there are unidentified impurities, enter “unidentified.”

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

percentages.

Part a) 

### Confidential

Part 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 byproduc ts/ 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 ca se of fire, etc.) and the amount

or rate at which it is formed.



### Part a) Confidential

Part b) Confidential

Part c) Confidential

Mark (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 108.4 2. Physical stat e at 20 o C lique fied gas

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

- 29.1 o C

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



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

8. Solubility in water @ temperature N/A o C

9. Partitio coefficient N/A Log K

ow 

### Log K 

10. Vapor pressure @ 20 o C 88.9 psi

(Also provide vapor pressure

- temperature curve for refrigerants.) 

### 11. Critical temperature

96 .5 o C 12. Critical Pressure

546 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. Volati lization from water N/A 18. Viscosity @ 20 o C N/A

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

N/A

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

Non

- flammable per ASTM E

- 681

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

### 8.9 5 Mj/kg

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

27. Other (specify)

28

. Fl ammability: 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 flamm able, 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 program 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 tested for flammability according to AST M

E 681

- 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 humidity for the WCFF.

Opteon ® 

### XP10 was fo und 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 Reference: Confidential

Mark (X) this box if thi s 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

t he source of this information and attach any supporting documentation.



### a) This blend contains no chlorine or bromine a nd is composed of a hydrofluoro carb on (HFC) and hydrofluoro

- olefin (HFO)

, each with zero ozone depletion potential (ODP).

b) Therefore , ODP= 0 (zero)

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

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 assessment 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 blend, 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 energ y efficiency relative to the substance it is replacing (e.g. +/

- X%) and results of any testing or modeling done (both theoretical and actual testing). Energy efficiency information is particularly useful for refrigerants and foams.

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



### P art a) and c)

Reference: AR4 IPCC Report Reference: CF3CFQCH2 and (Z)

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

– 13 Reference: AR5 IPCC Table 8a

Part b) Confidential

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

## 

Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section C

- OTHER STATUTES AND STANDARDSForm 1265

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### 11

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

such as t hose 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 Resou rce 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 o f 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 R ight 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 bui lding 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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### 12

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 refriger ant blend, Opte on ® 

### XP1 0, has been submitted to ASHRAE for safety classification per standard 34. Opte on ® 

### XP1 0 was granted refrigerant classification A1 (non

- flammable and low toxicity) and refrigerant nomenclature of

R

- 513A per ASHRAE standard 34

.

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

## Form 1265

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### 13 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 associated

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

.



### Cost: Confidential

.
New Equipment : DuPont TM 

### Opteon ® 

### XP1 0 can be used with exi sting equipment designed for R

- 134a , with minimal to no equipment costs associated to DuPont TM 

### Opteo n ® 

### XP1 0. However, in older systems, it may be beneficial to replace

elastomeric seals to minimize the risk of leaks and potentially adjust the thermal ex pansion valves (TXVs).

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

with DuPont TM 

### Opteon ® 

### XP1 0 and subsequent system optimization.

2. Provide information on product ion 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.

(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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### 14

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 compatibility iss ues. 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 d esigned as a replacement for R

- 134a

. It can be used in new equipment designed for R

- 134a

, thus avoiding the need for system re

- engineering or re

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

- 12 in

existing equipment. This low GWP substitute blend will be used to replace R

- 134a in current stationary applications.

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

REFERENCE : AHRI Test Report #7

- System Drop

- In Tests of R

- 134a Alternative Refrig erants (ARM

- 42a, N

- 13a, N

- 13b,

R

- 1234ze(E), and OpteonTM XP10) in a 230

- RT Water

- Cooled Water Chiller

REFERENCE: AHRI Test Report #8

- System Drop

- In Tests of R

- 134a, R

- 1234yf, OpteonTM XP10, R

- 1234ze(E), and N13a

in a Commercial Bottle Cooler/Freezer

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 attach supporting informati on on) the acute and chronic toxicity of the s ubstitute 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 an y 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 requirements for toxicity testing).



### Toxicity informatio n : Confidential

The recommended blend 8

- hr TWA wo rkplace exposure standard is 653 ppm

. This is based on additive formula using WEEL

values of 1000 ppm for 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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### 15

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

(a) Identify all site locations (i.e.

, name and address) for each chem ical 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 su bstitute 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.

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



### Part a) Confidential

Pa rt 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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### 16

For each manufacturing site (manufacturing of subs titutes 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 e ngineering 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 invo lved in each activity. (e) Estimate average and maximum duration of activity for 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 measure.



### 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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### 17

For each end

- use of a substitute (end

- 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 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 point. (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control t echnology in place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal. (d) Are releases 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 inf ormation on recycling of the substitute. Describe any associated costs and equipment.



### 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 a nd procedures are used for DuPont TM 

### Opteon ® 

### XP10 EPA

- approved recovery equipment and recovery cylinders rated for CFC

- 12 may be used to recover DuPont TM 

### Opteon ® 

### XP10

.

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



### Part III

- RELEASE AND EXPOS URE DATA (continued)

Section E

- OCCUPATIONAL EXPOSURE AT END

- USEForm 1265

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### 18

For all end

- use 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, or 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, che mical 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 o f 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 u nits. 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

Refere nce: Gjolstad et al., J Environ Monit

. 2003 Apr;5(2):236

- 40



### Section F

- CONSUMER EXPOSUREForm 1265

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### 19

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 point of concentration. Provide (1) average and (2) high

- end concentration estimates , including units of measure

.



### Part a) DuPontTM 

### Opteon ® 

### XP10 blend is used in air condition ing and refrigeration equipment from which any emission would only occur as a result 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 b e expected to occur only once in a consumers’ l ifetime . 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 are via

the air.

Part c) Norma lly, the potential exposure pathway would be inhalation

.

Part d) Confidential

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

## Form 1265

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### 20 Part III

- RELEASE AND EXPOSURE DATA (continued)

Section G

- GENERAL POPULATION EX POSURE (optional)

For manufacturing of substitutes and products containing substitutes:

(a) Identify and number potential general population exposure points. (b) For each exposure point described in (a), identify the potentially exposed populat ion (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 con fined 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.

Parts c) and d) Inhalation through the air

Part e) Confidential

Mark (X) this bo x 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 assist

EPA’s review of the alternative under Sectio n 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 sub mission. If you have

attached con tinuation pages, describe the Part, Section 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



### ASHRAE Section 9.7

– Flammability Information Part II A 14 X

Opteon® XP10 Pressure Temperature Data Part II A 4 X

IPCC Fourth Assessment Report Part II B.2



## CF3CFQCH2 and (Z)

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

– 13 Part II B.2 15

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

AHRI Report #7 Part II D.3 27

AHRI Report #8 Part II D.3 18

ASHRAE Section 9.6

– Toxicity Information Part III A.1 31 X

DuPont TM Opteon ® 

### XP10 SDS Part III A.1 11 X

R

- 1234yf SDS Part III A.1 10 X

R

- 134a SDS Part III A.1 10 X

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 __________ 

## 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 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 or 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, marke t, 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, w hich 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 regarding the alternative described herein. Any knowing and willful misinterpretation is subj ect 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 Signature Required): Date 7/24/2014

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, t he 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 n eeded 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 requirement s; 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 r espondent 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.