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: 

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 Company 
Attachment 1 

EPA SNAP Incompleteness Letter 
Ms. Helen Walter-Terrinoni NOV - 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: 

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 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-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 using FEA-1100 as the 

blowing agent. 

3. The additional data provided on September 9, 2011 , are helpful; however, only 

preliminary stability data were provided. Please provide the final stability testing report 

once it becomes available. In addition, please provide the following: 

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

anhydrous hydrochloric acid is formed as a byproduct 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:tlwww.epa gov 

Recycledi1'lecyclable • Printed wfth Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
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. 
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 submission, please 

contact Melissa Fiffer, the SNAP Coordinator, at (202) 343-9464 or fiffer.melissa@epa.gov. 

Sincerely, 

Margaret A. Sheppard 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division 

Attachment 2 

Responses to EPA SNAP Incompleteness Letter 
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 
p

g

p

, p

y 

; 

] 

Question from the EPA SNAP office 

4. lfblends 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: I) identification ofthe 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. 

[ 

Question from the EPA SNAP office 

Release and Exposure Data 

1 

5. In addition to the data on instantaneous exposure concentration at manufacture 

provided in Part III, Section C (g) and Attachment 23 of the SNAP Information Notice, 

please provide the exposure concentration as an 8-hour time-weighted average and as a 

15- minute TWA. 

2 
I I 

3 


(g

)

g 

g

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 

[ ] 
Z (Fiuorochemical nomenclature) 

(b) Chemical Abstracts Service (CAS) registry number and molecular fornmla. CAS RN 692-49-9; CF3HFHFCF3 

on 

(c) 

any 

For 

chemical 

alternative processes and technologies describe the technology and provide a diagram oft he system. Also provide the infom1ation constituents. 

No change to foaming process 

have 

(d) 

submillcd 

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 

Patent Summary 

a patent application but have not been granted one yet, indicate the date submilled and the expected time frame for a response. 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 

sem

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

to the 

i-aqueous 

instructions, 

solvent 

beg

cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A inning on p. 19. 

2. 

I. 

CFC-11, 

CFC-11, 

HCFC-141 

HCFC-141 b, HFC-245 fa foam expansion agent for Polyurethane and Polyisocyanurate, Rigid Laminated Boardstock b, HFC-245fa foam expansion agent for Polyurethane, Rigid Appliance 

and 

3. CFC-11, 

Sandwich 

HCFC-141b, 

Panel 

HFC-245fa foam expansion agent for Polyurethane, Rigid Spray, Commercial Refrigeration Foams, Spray Foams 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 and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ratio). The ODSs being replaced are CFC-11 and HCFC-141b. 

The ODS of HF0-1336mzz-Z is zero. HF0-1336mzz-Z contains no chlorine or bromine. 

Foams 

1336mzz-Z) 

would 

will 

require approximately an cquimolar to equal weight replacement. On a mass basis, I to 1.2 pounds of the alternative (HF0- 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 (Revised 06/2008) Previous editions are obsolete 

Mark (X) this box if this page contains CBI 0 

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