Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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:

7/27/13

Date 90 Day Review Begins: 

Date Review Completed:

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 10th FLOOR (MC 6205J)

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: 17 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 must be provided in three complete copies. If information is to be claimed as 

confidential, all confidential information must be excised from one of the copies, 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 must 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 “contains CBI” in 

the file name.

STEP-BY-STEP INSTRUCTIONS: 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 information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________☒

Petition: New alternative, Substance, or Formulation__________________________________________________________☐

Petition: Revision of the Existing SNAP list__________________________________________________________________☐

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

2

Part I - GENERAL INFORMATION

You must provide the identity of the alternative chemical or

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 ☒ 

• 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 your substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number:

Not subject to review under FIFRA___

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information 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 □ Yes ☒ No

• Flammability Data □ Yes ☒ No

• Environmental Effects 

Data □ Yes ☒ No

• Environmental Fate 

Data □ Yes ☒ No

• Risk Assessments □ Yes ☒ No

• Test Data Not in the Possession/

Control of the Submitter □ Yes ☒ No

• Other Data ☐ 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 this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice.

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with your submission. For additional information 

on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the 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 Programs for use in reviewing the need for possible control of any substance, practice, process or 

activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary 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 business 

information as implemented by 40 CFR 2.301(h).
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

3

Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

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

DAVID M. BERCHOWITZ_______________________________________________________CTO__________________________

Name of Authorized Official Title

GLOBAL COOLING INC.______________________________________________________________________________________

Company/Organization

6000 POSTON ROAD, ATHENS, OH45701__________________________________________740-274-7900 / 740-274-7901 ____

Mailing Address Telephone & Fax Numbers 

dberchowitz@globalcooling.com_________________________________________________________________________________

E-mail Address

(b) Agent (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.)

DAVID M. BERCHOWITZ_______________________________________________________CTO__________________________

Name of Authorized Official Title

GLOBAL COOLING INC.______________________________________________________________________________________

Company/Organization

6000 POSTON ROAD, ATHENS, OH45701__________________________________________740-274-7900 / 740-274-7901 ____

Mailing Address Telephone & Fax Numbers 

dberchowitz@globalcooling.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, phone, 

etc.) and the EPA staff person’s name:

Mark (X) if None _______X_______☒

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

4

Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

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

R-170 (ETHANE)

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, see page 11 of the Instructions for additional necessary composition information.

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

 (c) For alternative processes and technologies describe the technology 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 substitute, provide the patent name, number (if available), and information on the topics 

covered in the patent.

(a) ETHANE also referred to as R-170

(b) 74-84-0 C2H6 also known as CH3CH3

(c) Diagram shows a very low temperature freezer using a Stirling machine coupled to a thermosiphon to cool the interior space. 

ETHANE is proposed as a secondary heat transfer fluid in the thermosiphon. The thermosiphon is a hermetic copper tube and 

condenser attached to the Stirling machine’s cold head. The thermosiphon does not penetrate the Stirling machine.

(d) N/A

3. Generic name:

If the name of the substitute is declared Confidential Business Information, provide a generic name.

N/A

4. Specific End-Use

 (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g., terpene-based 

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). 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).

(a) Hydrocarbon substitute refrigerant for New Equipment - Very Low Temperature Refrigeration. This end-use is incorrectly 

defined in EPA website http://www.epa.gov/ozone/snap/refrigerants/index.html as “maintaining temperatures in the vicinity of -

80 degrees F (-62 degrees C) or lower.” Should be “maintaining temperatures in the vicinity of -80 degrees C (-176 degrees F) or 

lower.”

Used as a secondary heat transfer fluid at low temperatures - not in contact with moving parts. New Equipment – Non-Mechanical 

Heat Transfer Systems. Substitute is used in a thermosiphon that is part of a Very Low Temperature Refrigeration system.

(b) Proposing to replace the following refrigerants with ETHANE (ODP = 0, GWP = 5.5). The quantity of ETHANE for each case is 

the same, 0.22lbs. Each of these refrigerants are usable as a secondary heat transfer fluid in the quantities cited:

R-13 (ODP = 1, GWP = 14,420) 0.48lbs. Replacement ratio 1:2.2

R-508B (ODP = 0, GWP = 13,396) 0.44lbs. Replacement ratio 1:2

R-503 (ODP = 0.599, GWP = 14,560) 0.69lbs. Replacement ratio 1:3.1

HFC-23 (ODP = 0, GWP = 14,760) 0.41lbs. Replacement ratio 1:1.9

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

5

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 “unidentified.”

 (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.

(a) Unidentified

(b) N/A

(c) N/A

6. Byproducts:

 (a) Describe any byproducts or degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts/ degradation 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.

(a) Carbon dioxide and water

(b) 124-38-9 and 7732-18-5

(c) In case of fire and release of substitute. 2C2H6 +7O2 -> 4CO2 + 6H2O. 0.22lbs of substitute becomes 0.70lbs CO2 and 0.44lbs 

water.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

6

Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES – See Appendix B to the Instructions to see which properties apply 

to which uses.

1. Molecular weight: 30.0690 2. Physical state at 20 oC: gas

3. Melting point at 1 atm. pressure: -172°C 4. Boiling point at 1 atm. pressure: -89 oC

5. Specific gravity N/A g/ml 6. Odor threshhold odorless mg/m3

7. Solubility using solvent @ temperature oC g/L N/A

8. Solubility in water @ temperature oC N/A

9. Partition coefficient: not known Log Kow Log K% not known

10. Vapor pressure @ 20o C 537psi 11. Critical temperature 

32.33oC

12. Critical Pressure 

706.5psi

13. Are spectra attached? No 14. Disassociation constant: not known

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

17. Volatilization from water: not known 18. Viscosity @ 20 oC: N/A

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

21. Adsorption coefficient: not known 22. Flammability limits (LFL, UFL): 3 to 12.5 % vol

23. Flash point: -135°C 24. Heat of combustion: HHV 51.9MJ/kg

25. Maximum pressure rise: Comparative data taken from: 

http://www.gexcon.com/handbook/gexhbchap5.htm Section 5.10, Fig 5.27

26. Maximum rate of pressure rise

Unknown

27. Other (specify) Energy Efficiency: Used as a secondary heat transport 

fluid in a two-phase thermosiphon attached to a Stirling cooling machine. 

28 cu. ft. freezer measured data at equivalent conditions: energy use is 11 

kWh/day for substitute system versus 20 kWh/day for cascade refrigeration 

equipment. There is no oil concern for the substitute since no oil is used.

References: http://www.caslab.com/Ethane_CAS_74-84-0/

http://encyclopedia.airliquide.com/Encyclopedia.asp?GasID=28#V

aporPressureGraph

Scientific Assessment of Ozone Depletion: 2006. Daniel J.S. and 

Velders G.J.M.
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

7

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 program that addresses flammability concerns specific to this 

substitute. (See Appendix B to Instructions for sector-specific data requirements for flammable substances).

The proposed substitute is safety classified A3. So it is important to apply strong safety measures. The substitute is filled into a copper tube (thermosiphon)

after it has been evacuated to hard vacuum. Filling is done on a mass basis. There is small (less than 0.02g) of substitute released during each filling 

process. The substitute is sealed within the copper tube by pinch-off technique and is therefore hermetic. The filling station is situated in a large wellventilated factory of 40,000sq.ft. with 20ft ceiling. Throughput is 20 units per day. No open flames are allowed in the vicinity of the filling station. Two 

valves are used on the filling line in order to avoid accidental release of gas. A capillary line in the charge tube ensures that flow rates are restricted under 

any circumstance. Written procedures with checklists are mandatory. We do not have a fault-tree analysis.

In the end-use product, a very low temperature freezer for use in bio-repositories or research establishments, the substitute filled thermosiphon tube is 

foamed into the steel-walled cabinet and connects thermally at its top end to the cold side of the Stirling machine. The evaporator part of the thermosiphon 

is located around the inner liner of the freezer. This inner liner is from steel and protects the thermosiphon. The tube is not subject to movement or potential

stresses that could cause rupture. The substitute refrigerant is at no point exposed to any moving parts as is the case with conventional refrigeration 

equipment. The total use of this hydrocarbon is less than that found to be “acceptable subject to use conditions” for isobutane, propane and R-441A for use 

in Retail Food Refrigerators and Freezers as published in the Federal Register Vol 76, No 244 (100g versus 150g). The thermosiphon material, copper does 

not react with the substitute and since the assembly is hermetic, isolated from user interaction, static and well protected from potential damage, we believe 

that it is in a secure and safe arrangement regarding the user.

If the very low temperature freezer requires service for which the substitute must be removed, it is fully recovered. Applying a special penetrating tool to 

the pinch-off fill-tube that allows the recovery equipment to access the substitute does this. If the thermosiphon is refilled, then it will be pinched off below 

the penetration point in order to re-hermetically seal the system.

Signs and notices will be placed permanently in 1⁄4 inch (or bigger) letters as follows:

(a) “DANGER—Risk of Fire or Explosion. Flammable Refrigerant Used. Do Not Drill or Puncture Inner Liner’’ Located on inner liner of freezer.

(b) ‘‘DANGER—Risk of Fire or Explosion. Flammable Refrigerant Used. To Be Repaired Only By Trained Service Personnel. Do Not Puncture 

Refrigerant Tubing.’’ Located in the mechanical compartment at the top of the freezer.

(c) ‘‘CAUTION—Risk of Fire or Explosion. Flammable Refrigerant Used. Consult Repair Manual/Owner’s Guide Before Attempting To Service This 

Product. All Safety Precautions Must be Followed.’’ Located in the mechanical compartment at the top of the freezer.

(d) ‘‘CAUTION—Risk of Fire or Explosion. Dispose of Properly In Accordance With Federal Or Local Regulations. Flammable Refrigerant Used.’’ 

Located on the exterior of the freezer.

(e) ‘‘CAUTION—Risk of Fire or Explosion Due To Puncture Of Refrigerant Tubing; Follow Handling Instructions Carefully. Flammable Refrigerant 

Used.’’ Located near the condenser section in the machine compartment.

The thermosiphon will be marked in red, Pantone® Matching System #185. There are no service ports or service aperture fittings. There is a fill-tube that is 

pinched-off after evacuation and filling of the substitute.

Spark-proof electronics are used throughout.

Leak rates and their likelihood from manufactured and / or repaired equipment are anticipated to be equivalent or less than that expected of refrigerator best 

practice. The procedures are identical but in our case there are fewer joints, no internal moving parts and no significant vibrations, even during transport. 

The machine compartment is positively ventilated during operation.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

8

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). Reference 

the source of this information and attach any supporting documentation.

(a) ODP = 0. Reference: Calm J.M., Wuebbles D.J. and Jain A.K. Impacts on Global Ozone and Climate From Use and Emission 

of 2,2-Dichloro-1,1,1-Trifluoroethane (HCFC-123), Climatic Change 42: 439-474, 1999. Cited on page 442 taken from IPCC 

1995 and 1996.

(b) Not known.

2. Global Warming Characteristics:

 (a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) relative to carbon dioxide 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 energy efficiency relative to the substance it is replacing (e.g. +/- X%) and results 

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

foams.

 (c) For GWP values that do not come from AR4 or WMO 2010, provide 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. 

(a) GWP = 5.5 Reference: Table 2.15 in section 2.10.3.3 Non-methane Volatile Organic Compounds, IPCC Fourth Assessment 

Report: Climate Change 2007. http://www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-3-2.html

(b) Heat transfer testing against R-508B show slight improvements for substitute for measured temperature differentials. These 

differences are insufficient to result in a meaningful improvement in efficiencies. However, the system that we are introducing 

using a Stirling machine and the proposed substitute will improve the energy efficiency by 50% compared to existing equipment. 

We have tested an equivalent sized SANYO very low temperature freezer at identical conditions. The SANYO uses a compressor 

cascade system. Its power consumption is 24kWh/day versus our SU780U model (Stirling system with substitute filled 

thermosiphon) at 11.4 kWh/day.

(c) N/A

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

Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

9

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 those 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 _____________________________________________________

the Clean Water Act (CWA) _________________________________________________________________________

the Safe Drinking Water Act (SDWA) _________________________________________________________________

the Resource Conservation and Recovery Act (RCRA) ____________________________________________________

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) ____________________________________________

the Toxic Substances Control Act (TSCA) ______________________________________________________________

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) ________________________

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III) ________________________

State and local laws _________________________________________________________________________________

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

We anticipate that the alternative (substitute) will be subject to the same requirements under the Clean Air Act and SNAP ruling as the 

currently allowed hydrocarbons, i.e. “acceptable subject to narrowed use limits” (Federal Register Vol. 76, No 244). Maximum quantity 

would be limited to 150 grams (5.3 ounces) in very low temperature freezers. Our current use is 100 grams (3.5 ounces) per freezer. Full 

recovery techniques using appropriate equipment will be required for any repair and maintenance that involve discharging the thermosiphon 

(removal of substitute).

The alternative is not listed on the “original list of hazardous air pollutants” Reference: http://www.epa.gov/ttn/atw/188polls.html

The alternative has been determined by the EPA to have negligible photochemical reactivity. See US EPA Definitions of VOC (as of 

January 2009) 40 CFR Part 51 Section 51.100 Definitions.

Reporting under CERCLA. Reportable Quantity (RQ): None

Reporting under SARA, Title III, Section 313 not required.

40 CFR 68: ETHANE is listed as a regulated substance in quantities of 10,000lb or greater. Our maximum annual usage will be much 

smaller than this. We anticipate a maximum usage of 2,000lbs per year if all of our products used ETHANE and we achieved our maximum 

production goals.
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

10

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 Occupational Safety and Health 

Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical 

standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such 

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

(ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitute from a health and safety perspective.

OSHA requirements: 29 CFR part 1910, specifically 29 CFR 1010.94 (ventilation), 29 CFR 1910.106 (flammable and combustible liquids) 

and 29 CFR 1910.110 (storage and handling of liquefied petroleum gases). We think that 29 CFR 1910.1000 (toxic and hazardous 

substances) does not apply because the proposed substitute (ETHANE CAS No. 74-84-0) is not listed in Table Z-1 – LIMITS FOR AIR 

CONTAMINANTS and is also not listed on the “original list of hazardous air pollutants” at the EPA site 

http://www.epa.gov/ttn/atw/188polls.html.

We believe that transportation requirements of the end-use product (very low temperature freezer) would be regulated under 49 CFR 

173.174 (refrigerating machines). UN 3358 Class 2.1 REFRIGERATING MACHINES containing flammable, non-toxic, liquefied gas. The 

end product will also be controlled by IATA special provision A103 as follows: Flammable liquefied gases must be contained within 

refrigerating machine components. These components must be designed and tested to at least three times the working pressure of the 

machinery. The refrigerating machines must be designed and constructed to contain the liquefied gas and preclude the risk of bursting or 

cracking of the pressure retaining components during normal conditions of transport. Refrigerating machines and refrigerating machine 

components are considered not subject to these Regulations if containing less than 100 g of flammable, non-toxic, liquefied gas.

Threshold limit value time weighted average data from Guide to Occupational Exposure Values (ACGIH 2005) gives 1000 ppm 8 hours for 

the alternative.

It is not clear if UL471 applies to the end-use category of Very Low Temperature Freezers. We have not found a UL standard that would 

apply to this alternative for the application proposed. We are in process of obtaining UL certification for the end product, i.e. the Very Low 

Temperature Freezer.

NFPA 497: Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations 

for Electrical Installations in Chemical Process Areas, 2012 Edition.

ASHRAE recognizes the alternative as a ‘natural refrigerant’, i.e. naturally occurring in nature. Because it is flammable, ASHRAE standard 

15 applies with exceptions such as laboratories with 100 sq.ft. space per person or where local authorities have jurisdiction.

The use the substitute will be subject to all Federal, State and Local laws regarding the storage and use of flammable gases. These include 

Ohio Administrative Code 1301:7-7-35 (flammable gases), 4101:1-3-01 (use and occupancy classification), 1301:7-7-30 (compressed 

gases).

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

11

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 of substitute (R-170, ETHANE) is about $9.50/lb. (cost fluctuates, this is from our last purchase order). Installation costs are very small, 

basically labor for about 5 minutes per fill.

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

 (a) Year substitute will be available if not currently produced.

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

 (c) Years to maximum market penetration.

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

 (e) Estimated percentage of market at market saturation.

(a) The substitute is currently produced.

(b) Not known. Current VLT use of R-170 is zero.

(c) We believe that we could achieve maximum market penetration in five years.

(d) Maximum VLT use of R-170 at market saturation. Market size for this application is 25,000 VLT freezer units per year. We believe that 

this technology has the potential to displace 20% of the VLT freezer market after 5 years. That would be 500kg (about 1,100lbs) of R-170 per 

year.

(e) We estimate that the substitute could displace 20% of the market in five years. About 5,000 units per year.

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 issues. Provide information on 

each end-use and capital costs associated with the substitute or alternative process. Include cost of equipment and/or any new materials, 

equipment lifetime, changes in labor and energy costs.

Hydrocarbon refrigerant recovery equipment will be needed for repair and maintenance service groups. The Caresaver Universal refrigerant 

recovery unit is an example of such equipment and costs about $1,400 FOB. Equipment lifetime is not known.

We anticipate costs of labor and other activities associated with manufacture and repair to be almost equivalent to current practice.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

12

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 information on) the 

acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, 

and plants), if available. Include any data on impurities and degradation products if known. Also include information on any 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).

Threshold limit value time weighted average data from Guide to Occupational Exposure Values (ACGIH 2005) gives 1000 ppm at 8 hours for 

the alternative.

The alternative is defined as a simple asphyxiant. Threshold limit value time weighted average data from Guide to Occupational Exposure 

Values (ACGIH 2005) gives 1000 ppm 8 hours for the alternative. Reference http://www.orcbs.msu.edu/msds/LINDE_MSDS/pdf/024.pdf

The alternative is not listed by OSHA as a Toxic and Hazardous Substance. No PEL listed.

NFPA Hazard classification: Health Hazard (blue): 1, Flammability (Red): 4, Instability (Yellow): 0.

Symptoms Following Exposure: In high vapor concentrations, can act as asphyxiant. Liquid causes severe frostbite. Treatment of Exposure: 

Remove from exposure; support respiration. Vapors are nonirritating to the eyes and throat. Odor Threshold: 899 ppm

Airgas material safety data sheet (MSDS): http://www.ebsinfo.com/Tech-pdf-files/MSDS-Ethane.pdf

Praxair material safety data sheet (MSDS): http://www.prest-o-sales.com/other_links/gases/pdf/msds/ethane_p4592e.pdf

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

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 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 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).

Product containing substitute:

(a) Substitute is purchased. We do not manufacture the substitute. We have no chemical manufacturing processes.

(b) The very low temperature freezers are manufactured by Global Cooling Inc. at 6000 Poston Rd., Athens, OH 45701.

(c) The point of release or exposure is during filling of the thermosiphon. This occurs at the final stage of manufacture of the 

freezer.

(d) The magnitude of the release is about 0.02g per filling. It is released to the indoor air. We expect to manufacture 10 units per 

day.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

13

Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

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 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 of measure.

For each manufacturing site, the product containing the substitute:

(a) Exposure occurs during filling the thermosiphon. Final stage of manufacture.

(b) Protective equipment: goggles and gloves. Engineering controls: flow restrictor and two manual valves must be opened for 

filling process. A Schrader-type valve is attached to the fill tube (removed after pinch-off) so that the delivery line is sealed and 

opened only on connection to the fill tube. 

(c) Gas.

(d) One worker.

(e) Less than five minutes to fill and pinch-off the filling tube. Ten units per day so total fill process time 50 minutes/day. Total fill 

process time per year is about 9 days.

(f) Inhalation.

(g) Not known. A very small fraction of the released substitute.

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute (end-uses using 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 technology 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 information on recycling of the substitute. Describe any associated costs and equipment.

For end-use using the substitute in product:

(a) Product lifetime is estimated at 10 yrs. The substitute refrigerant must be recovered at end-of-use. In recovery we anticipate a 

loss of refrigerant of 0.02g.

(b) Outdoor air.

(c) Refrigerant recovery machines must be used. Release is anticipated to be 0.02g per recovery. Disposal is by return of gas 

cylinder to gas supplier with proper identification and labeling, with any valve outlet plugs or caps secured and valve protection 

cap in place.

(d) We do not believe that releases are covered under RCRA. End-use recovery must be carried out in accordance with proper 

practice and therefore the release is insignificant.

(e) The end-product will be sold to bio-repositories, universities and research establishments. Total current installed base of very 

low temperature freezers is about 500,000 units. Current total annual sales for all manufacturers is about 30,000/yr. We are 

anticipating up to 2,600 very low temperature freezers per year.

(f) Recycling of the substitute will be a decision taken by the gas supply companies who have to take the recovered substitute. 

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

14

Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes):

 (a) Describe the activities in which 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, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms 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 pgs. 17-18 of Instructions).

End-uses utilizing the substitute in a very low temperature freezer.

(a) Workers may be exposed during servicing only. This will be during replacement of the cooling machine.

(b) Protective equipment: goggles and gloves. Engineering controls: flow restrictor and two valves must be opened for filling 

process. Recovery of substitute by hydrocarbon refrigerant recovery equipment.

(c) Gas

(d) One to two workers.

(e) Total time to replace a cooling machine would be one hour. Extracting the substitute will take 10 minutes. Replacing the 

substitute after the cooling machine has been replaced, will take 5 minutes.

(f) Inhalation.

(g) Exposure to the substitute will be when the charging valve is disconnected. This releases about 0.02g of substitute. Exposure 

concentration is not known but will be a small fraction of the released substitute.

Section F - CONSUMER EXPOSURE

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) Describe the exposure point of concentration. Provide (1) average and (2) high-end concentration estimates, including units of measure.

End-uses where a consumer might be exposed: This product is not intended for consumer use.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

15

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 exposure 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/m3 or ppb). Provide (1) average and (2) high-end estimates.

For products containing substitutes: There will be negligible exposure of the general population to the product containing the substitute.

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

16

Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citations 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, 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

All citations are live links within the answers to the questions.

General reference on ETHANE: http://cameochemicals.noaa.gov/chris/ETH.pdf

Mark (X) this box if this page contains CBI __________☐
Form 1265-07 (Revised 09/2011)

OMB Control No.: 2060-0226

Previous editions are obsolete

17

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 named 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 regarding the 

alternative described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to section 113(c) 

of the Clean Air Act and 18 U.S.C.§1001.

Signature and Title of Authorized Official (Original Signature Required): Date

 

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 otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number.

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any 

suggested methods for minimizing respondent burden, including through the use of automated collection techniques 

to the 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.