DuPont Chemicals

& Fluoroproducts September

5, 2012 U.S. Environmental Protection Agency Office of Air and Radiation Stratospheric Protection Division Attention: Margaret Sheppard 1310 L Street NW, wth Floor (Room 1029) Washington, DC 20005 Dear Ms Sheppard:

DuPont Chemicals

& Fluoroproducts Chestnut Run Plaza 702 1276-E 4417 Lancaster Pike Wilmington,
DE 19805 USA 9Jj SE P - 7 2 012 Reference: DuPont SNAP Information Notice (Z)-1,1,1,4,4,4-hexafluoro-but-2-ene

(CAS RN 692-49-9) [

] [

] Please contact me if you have any questions about this submission
or need further clarification. Sincerely, [

] Via Federal Express Chestnut Run Plaza 702/1276-E, Wilmington,
DE 19805 E. I. du Pont de Nemours and CompanyAttachment1EPASNAPIncompletenessLetterUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 

### Ms. Helen Walter-Terrinoni



### N O V
- c ·' ·· : • Global Marketing Manager, Foam Expansion Agents DuPont Chemicals and Fluoroproducts CRP 702 Rm 1276-E 4417 Lancaster Pike Wilmington, DE 19805 Re: Incomplete SNAP Submission for FEA

- 11 00 Dear Ms. Walter- Terrinoni:

O F FICE OF A

I R AND RADIATION 

### Thank you for DuPont

' s submission

to the Environmental Protection Agency. The EPA established the Significant New Alternatives Policy program
to implement section 612 of the Clean Air Act. Your submission and the additional information received on September

9, 2011, have been reviewed for completeness

as part of the initial SNAP review. We have found the submission

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

: General Information 1. 

### Part I, Section 8, 

### Number 2(a) of the SNAP Information Notice

s tates that FEA-1100 may be used neat or in blends with other acceptable foam expansion agent alternatives. Please clarify whether or not FEA-1100

is antic

i pated for us e as a blen d . If yes, spe ci fy the substances

(e

. g. , HFC-245fa, HFC-365mfc, and C3-C 6 h y drocarbons) that may be blended with FEA-11 00, and the composition
of any anticipated blends (on a weight percent basis)

. Byproducts 

### 2. Please specify the catalyst used 

### in the manufacture
of foams when
u s ing FEA

- 1100 as th e blowing agent. 3. The additional data provided on September

9, 2011

, are helpful; however

, only preliminary stability data were provided

. Please provid

e the final stability testing report once it becomes available

. In addition, please provide th e follo w ing

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

at which anhydrous hydrochloric acid is formed as a byproduct ofFEA-1100, and the rate of formation
as a ratio to the production ofFEA-1100 (grams

: grams); b. Confirmation that the breakdown products of FEA-11 00 in polyurethane foam systems are fluorotrimethylsilane, HF0-1336mzz-T, HFC-245fa, HF0-1335, and Internet Address (URL)

• http :t lwww

. epa gov Recyc ledi1'l ecyclab

l e • P ri n ted wf th V egetable
O il Based

I nks o n 1 00 % Pos

t consumer

, Pro c ess Chlo

ri ne Free R ecyc led Paperpentane. Please verify ifHF0-1336mzz-T

is the same as HF0-1334mzz-2E

. Please further identify the structure(s) ofHF0-1335,

as public records of the structure associated with CAS Registry number 1186730-89-2 were not available and the structure ofHF0-1335

is not readily discernible. lfthere are other potential degradation products, please identify them; and c. Information was provided on breakdown products for polyether and polyester foam systems, but the proposed FEA-1100 end-uses are expected
in polyurethane, polyisocyanurate,
and phenolic foam systems. Please provide information
on the breakdown products from the use ofFEA-1100

in phenolic and polyisocyanurate foam systems, and the amount formed and their concentrations (percent by weight),
if there are different breakdown products expected.
If there is a specific rationale for providing the breakdown products for polyether and polyester systems (e.g., this is a standard protocol and substitutes for testing other systems), please explain and/or provide documentation. 4. If blends ofFEA-1100
are anticipated, we will require additional information
on degradation products that may result from decomposition

of the blends in rigid cell foams for residential uses, including:

1) identification
of the degradation products formed in rigid cell forms and their concentrations
(% values, by weight); and 2) information
on the catalyst and analysis of breakdown products under different conditions. Release and Exposure Data 5. In addition
to the data on instantaneous exposure concentration

at manufacture provided in Part III, Section
C (g) and Attachment
23 of the SNAP Information Notice, please provide the exposure concentration

as an 8-hour time-weighted average and as a 15- minuteTWA. 6. Part I, Section B, Number

4 of the SNAP Information Notice indicates that FEA-1100 would be used for spray foams. Please clarify that the expected uses are · industriaVcommercial spray foams, and that consumer applications are not intended.
If consumer use is expected, per Part III, Section
F, please also provide the following information regarding consumer exposure: a The type of application system. For example, the size of a consumer spray foam can (grams), and the amount of foam blowing agent contained therein. b. The anticipated average and maximum exposure concentrations

to the foam blowing agent during use of the spray foam in these consumer applications. 7. Part Ill, Section
B (d) of your submission indicated that quantities ofFEA-1100 will be released
to surface water after wastewater treatment. Please indicate the rate at which the compound will mobilize into the atmosphere (out of the surface water) after release (grams/second). Toxicity and HaZJird lnforllllltion Please provide EPA's SNAP program with
a complete report for the second 90-day inhalation toxicity study, once available.

## Claims of Confidentiality 

## In your response please include any claims of confidential business information,

if you wish to claim any of the information submitted
in response
to the above as CBI. Here is a summary of information concerning your submission

: Substitute name: FEA-1 100 Substance(s)
the substitute will replace: CFC-11, CFC-113, HCFC

- 141b Sectors: Foam Blowing End uses: • Rigid polyurethane and polyisocyanurate laminated boardstock • rigid polyurethane appliance • rigid polyurethane commercial spray and sandwich panel • rigid polyurethane slabstock • integral skin polyurethane • flexible polyurethane • phenolic insulation board Date received: August
3, 2011 Date most recent information received: October 14, 2011 Status of submission: incomplete Responses

to the above questions would be helpful for our review

. The information can be submitted via electronic mail or hard copy

. If you have questions about your submis

s ion

, please contact Melissa Fiffer

, the SNAP Coordinator,

at (202) 343

- 9464 or fiffer.melissa@epa.

g ov

. Sincerely, Margaret A. 

## Sheppard Alternatives and Emissions Reduction Branch Stratospheri

c Protection DivisionAttachment

2 Responses

to EPA SNAP Incompleteness LetterQuestion from the EPA SNAP office General Information 1 . Part

I, Section
B, Number 2(a) of the SNAP Information Notice states that FEA-1100 may be used neat or in blends with other acceptable foam expansion agent alternatives. Please clarify whether or not FEA-1100

is anticipated for use as a blend.

If yes, specify the substances (e.g., HFC-245fa, HFC-365mfc, and C3-C6 hydrocarbons) that may be blended with FEA-1100, and the composition

of any anticipated blends (on a weight percent basis). Question from the EPA SNAP office Byproducts

J 2. Please specify the catalyst used in the manufacture

of foams when using FEA-11 00 as the blowing agent Question from the EPA SNAP office 3. The additional data provided on September

9, 2011, are helpful; however, only preliminary stability data were provided. Please provide the final stability testing report once
it becomes available.

In addition, please provide the following: [

J Question from the EPA SNAP office a. Clarification

on the conditions under which and the point of manufacture

at which anhydrous hydrochloric acid is formed as a byproduct
of FEA-11 00, and the rate of formation
as a ratio to the production
of FEA-1100 (grams:grams);

1

]QuestionfromtheEPASNAPofficeb.ConfirmationthebreakdownproductsofFEA-1100inpolyurethanefoamsystemsarefluorotrimethylsilane,HF0-1336mzz:-T,HFC-245fa,HF0-1335,andpentane.PleaseverifyifHF0-1336mzz-TisthesameasHF0-1334mzz-2E.Pleasefurtheridentifythestructure(s)ofHF0-1335,aspublicrecordsofthestructureassociatedwithCASRegistrynumber1186730-89-2werenotavailableandthestructureofHF0-1335isnotreadilydiscernible.Ifthereareotherpotentialdegradationproducts,pleaseidentifythem;and]QuestionfromtheEPASNAPoffice4.lfblendsofFEA-1100areanticipated,wewillrequireadditionalinformationondegradationproductsthatmayresultfromdecompositionoftheblendsinrigidcellfoamsforresidentialuses,including:I)identificationofthedegradationproductsformedinrigidcellformsandtheirconcentrations(%values,byweight);and2)informationonthecatalystandanalysisofbreakdownproductsunderdifferentconditions.[QuestionfromtheEPASNAPofficeReleaseandExposureData15.InadditiontothedataoninstantaneousexposureconcentrationatmanufactureprovidedinPartIII,SectionC(g)andAttachment23oftheSNAPInformationNotice,pleaseprovidetheexposureconcentrationasan8-hourtime-weightedaverageandasa15-minuteTWA.2

# I

I

3Question from the EPA SNAP office 6. Part I, Section B, Number

4 of the SNAP Information Notice indicates that FEA-11 00 would be used for spray foams. Please clarify that the expected uses are industrial/commercial spray foams, and that consumer applications are not intended.
If consumer use is expected, per Part Ill, Section
F, please also provide the following information regarding consumer exposure: a. The type of application system. For example, the size of a consumer spray foams can (grams), and the amount of foam blowing agent contained therein. b. The anticipated average and maximum exposure concentrations

to the foam blowing agent during use of the spray foam in these consumer applications. Question from the EPA SNAP office 7. Part III, Section B(d) ofyour submission indicated that quantities ofFEA-1100 will be released
to surface water after wastewater treatment. Please indicate the rate at which the compound will mobilize into the atmosphere (out of the surface water) after release (grams/second).

] Question from the EPA SNAP office Toxicity and Hazard Information Please provide EPA's SNAP program with
a complete report for the second 90-day inhalation toxicity study, once available. ]

6

# Attachment

3 [



# ]Part 1- GENERAL INFORMATION (continued) Section B- ALTERNATIVE IDENTIFI

C ATION I . C ommcr

c ial f rmdc name (s) of alternative

: FEA

- 1100, Formaccl
® 1100, Fom1acel
® FEA

- 1100 2 . (a) Name of chcmical(s) (pr e ferably IUPA C n o menclature
an d/o r pr oc e ss n a me

. For blends, provide the percent compo

s iti o n of each const

i tuents. 2-Butenc, 1,1,1,4,4,4-hcxatluoro

- , (2Z

- ) [ A Index Name obtained from C AS Inventory Expert Service; chemical name submilled

w PMN] (Z)
- 1,1,1,4,4,4

- hexatluoro

- but
- 2-ene (IUPAC) Also known as HF0-1336mzz

- Z (Fiuorochemical

n o menclature) (b) Chemical Abstracts Service

( C AS) re g i s try number and molecular fornmla

. CAS RN 692-49-9; CF3HFHFCF3 (c) For alternat

i ve processes

a nd technolo

g ies describe the technolo

g y and provide

a diagram oft he syste m
. Also prov

i de the

i nfom1ation on any chemical const

i tuents. No change to foaming process (d) If you hold
a patent on the substitute

, provide the patent name and number and include

a copy oft he patent as an allachmenl.

If you have submillcd

a patent application but have not been granted one yet,

i ndicate the date submilled and the expected time frame for a response. Patent Summary allached 3. Generic chemical name (if chemical name of substitute

is declared Confidential Business Information)

. The chemical name is not CBI. 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 sem

i - aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifu

g al chillers). For a list of end uses, see Appendix

A to the instructions,

be g innin g on p . 19
. I . CFC-11, HCFC-141

b, HFC

- 245 fa foam expansion agent for Polyurethane and Polyisocyanurate, Rigid Laminated Boardstock 2. CFC-11, HCFC-141

b, HFC-245fa foam expansion agent for Polyurethane, Rigid Appliance 3. CFC-11, HCFC-141b, HFC-245fa foam expansion agent for Polyurethane, Rigid Spray, Commercial Refrigeration Foams, Spray Foams and Sandwich Panel Foams 4. CFC

- 11, HCFC-141b, HFC-245fa foam expansion agent for Polyurethane, Rigid Slabstock and Other 5. CFC

- 11, CFC-113, HCFC-14lb, HFC-245fa foam expansion agent for Phenolic, Insulation Board 6. CFC-11, HCFC-14lb, foam expansion agent for Polyurethane, Flexible 7. CFC-11, HCFC-14lb, foam expansion agent for Polyurethane, Integral Skin (b) IdentifY the ODS

a n d the quantity of subst

i tute (if appl

i cable) needed to replace

i t for e a ch end use

i n pounds (replacement ratio)

. The ODSs bein g replaced are CFC-11 and HCFC-141b. The ODS of HF0-1336mzz-Z

is zero. HF0-1336mzz-Z contains no chlorine or bromine. Foams would require approximately

an cquimolar

to equal weight repla
c ement. On a mass basis,

I to 1 . 2 pounds of the alternative (HF0

- 1336mzz-Z) will replace

I lb of the ODS. The replacement ratios range from I: I to 1.2: I. CFC-11

is CAS RN 75-69-4 HCFC-14lbCAS

RN 1716-00-6 HFC-245fa CAS RN 460-73-1 Form 1265-07 (Rev

i sed 06/2008) Previous editions are obsolete

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