Final

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1 

# Significant New Alternatives Policy Program

Foam

- Blowing Sector

Risk Screen on Substitutes in Rigid Polyurethane Appliance Foam; Rigid Polyurethane and Polyisocyanurate Laminated Boardstock; Rigid Polyurethane Spray, Commercial Refrigeration
, and Sandwich Panels ; Rigid Polyurethane Slabstock and Other ; Flexible Polyurethane; Integral Skin Polyurethane; and Phenolic Insulation Board and Bunstock

Substitute: HFO

- 1336mzz(Z) (Formacel® 1100 )

This risk screen does not contain Clean Air Act (CAA) Confidential Business Information (CBI) and, therefore, may be disclosed to the public.



### 1. INTRODUCTION

Ozone

- depleting substances (ODS) are being phased out of production in response to a serie s of diplomatic and legislative efforts that have taken place over the past two decades, including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAAA). The U.S. Environmental Protection Agency (EPA), as authorized by Section 612 of the C AAA, administers the Significant New Alternatives Policy (SNAP) Program, which identifies acceptable and unacceptable substitutes for ODS in specific
end

- uses based on assessment of their health and environmental impacts.

EPA’s decision on the acceptabil ity of a substitute is based on the findings of a screening assessment of potential human health and environmental risks posed by the substitute in specific applications. EPA has already screened a large number of substitutes in many end

- uses within all o f the major ODS

- using sectors, including refrigeration and air conditioning, solvent cleaning, foam blowing, aerosols, fire suppression, adhesives, coatings and inks, and sterilization. The results of these risk screens are presented in a series of Backgro und Documents that are available in EPA's docket.

The purpose of this risk screen is to supplement EPA’s Background Document on the foam blowing sector (EPA 1994) (hereinafter referred to as the Background Document). This risk screen evaluates the potential use of HFO

- 1336mzz(Z) (also known as 2

- Butene, 1 ,1,1,4,4,4

- hexafluoro

- ,(2Z

- ) and hereinafter
referred to as Formacel® 1100 ) as a substitute in Rigid Polyurethane Appliance Foam; Rigid Polyurethane and Polyisocyanurate Laminated Boardstock; Rigid Polyurethane Spray, Commercial Refrigeration

, and Sandwich Panels; Rigid Polyurethane Slabstock and Other; Flexible Polyurethane; Integral Skin Polyurethane; and Phenolic Insulation Board and Bunstock . Table 1 presents information on the proposed substitute.Final

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2 Table 1 . Compositi on of Formacel® 1100

Constituent Chemical Formula CAS Number Percent of Total (by weight)

2

- Butene, 1,1,1,4,4,4

- hexafluoro

- ,(2Z

- ) (HFO

- 1336mzz(Z)) CF 3 CHCH CF 3 692

- 49

- 9 >99%

Potential Impurities (maximum concentration)

The potential risks associated with use of foam blowing agents have been examined at length in the Background Document. The reader is referred to this reference for a detailed discussion of the methodologies used to conduct this risk screen. This risk scr een addresses flammability risk and assesses the impact of potential releases of Formacel® 1100 on the atmosphere

, climate and other environmental impacts

. O ccupational exposure was modeled to ensure that manufacture and application of the proposed
substitute in the pr oposed foam blowing end

- uses does not pose unacceptable risk to workers. Lastly, general population exposure modeling was performed to ensure that the proposed substitute would not pose an unacceptable risk to the population at large.

Section 2 of this re port summarizes the results of the risk screen for the proposed substitute. The remainder of the report is organized into the following sections:

• Section 3: Atmospheric Assessment

• Section 4: Volatile Organic Compound Assessment

• Section 5: Potential Health Effects

• Section 6: Flammability Assessment

• Section 7 : Occupational Exposure Assessment

• Section 8 : General Population Assessment

• Section 9 : Aquatic and Ecosystem Impact Assessment

• Section 10 : References



### 2. SUMMARY OF RESULTS

Formacel® 1100 is recommended for SNAP approval as a foam

- blowing agent in the following end

- uses: rigid polyurethane appliance foam; rigid polyurethane and polyisocyanurate laminated boardstock; rigid polyurethane spray, commercial refrigeration, and sandwich panels; ri gid polyurethane slabstock and other; flexible polyurethane; integral s kin p olyurethane; and phenolic i nsulation b oard and b unstock

.Final

— J uly 2, 2015
3 EPA's risk screen indicates that the use of the proposed substitute will be less harmful to the atmosphere
than the continu ed use of ODS and other commonly used blowing agents

. Formacel® 1100 is regulated as

a volatile organic compound ( VOC ) under the CAA (40 CFR 51.000) and emissions should be controlled through regulations and standard industry practices. In addition, based on the non

- flammable nature of the proposed substitute, Formacel® 1100 is not expected to present a significant flammability concern during
manufacture or end

- use (see Section 6 ).

Given that appropriate personal protective equipment (PPE) ( e.g., respirator y protection, goggles, impervious gloves, chemical

- resistant clothing and boots) consistent with Occupational Safety & Health Administration ( OSHA ) guidelines will be used during manufacture ; and proper procedures according to
the manufacturer’s Safety Data Sheet ( SDS ) (including provisions of engineering controls [e.g., exhaust ventilation, vapor

- in

- air detection systems]) will be used during manufacturing and application activities,

n o significant toxicity risks to workers or the general population are expected

.



### 3. ATMOSPHERIC ASSESSMENT
This section presents an assessment of the potential risks to atmospheric integrity posed by the use of
Formacel® 1100 in the foam blowing sector. The ozone depletion potential (ODP), global warming potential (GWP), a nd atmospheric lifetime (ALT) of the proposed substitute are presented in Table 2

. As compared to CFC

- 11 and HCFC

- 141b, CFC

- 113, and HCFC

- 22

, Formacel® 1100 is substantially less harmful to the ozone layer, has less climate impact, and a shorter ALT

. Formacel® 1100 has a non

- zero GWP, but at 8.9, this value is very small when considering continued use of HCFC

- 141b or HCFC

- 22. Further, Formacel® 1100 has a lower climate impact and a shorter ALT than those predicted for other
substitutes examined in the Background Document

. Thus, EPA believes that use of Formacel® 1100 would result in substantially less harm to the climate and ozone layer than the continued use of ODS and other commonly used blowing agents

.
Table 2 . Atmospheric Impacts of Formacel® 1100 Compared to Other Foam

- Blowing Agents Refrigerant ODP a GWP b ALT (years) b
Formacel® 1100 0 c 8. 9 c 22 days c
CFC

- 11 1.0 4, 750 45
CFC

- 113 0.85 6,130 85
HCFC

- 141b 0. 12 725 9.3

HCFC

- 22 0. 04 1,810 12
HFC

- 134a 0 1

, 430 14
HFC

- 245fa 0 1

, 030 7.6
HFC

- 365mfc 0 794 8.6

a WMO (2011)

b IPCC 4 th Assessment Report (Forster et al. 2007)

c DuPont (2011 c )



### 4. VOLATILE ORGANIC COMPOUND ASSESSMENT

Formacel® 1100 is regulated as a VOC under the CAA (40 CFR 51.000). Through regulations and standard industry practices, emissions of Formacel® 1100 should be controlled. The submitter has
indicated that a petition has been submitted to exempt this compound from the definition of VOC for purposes of regulations in state implementation plans for local air quality ; however, Formacel® 1100 continues to be regulated as a VOC for that purpose unless and until EPA is sues a final rule exempting it.

An assessment was performed to compare the annual VOC emissions from use of Formacel® 1100 in the foam blowing end

- uses in one year to other anthropogenic sources of VOC emissions. Assuming theFinal

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4 submitter’s maximum anticipated annual production of Formacel® 11 00 for all proposed foam blowing
end

- uses is entirely released (in the absence of controls)

, approximately [ ] MT of VOCs would be emitted. This is approximately equal to [ ] percent of all anthropogenic VOC emissions from 2013 in the
U nited S tates ; 1 however, the release of total production for all foam blowing end

- uses is extremely unlikely to occur. Thus, an additional analysis was performed to determine likely annual VOC emissions
from use of Formacel® 1100 in the foam blowing sector. Table 3 summa rizes leak estimates and market penetrations from the Vintaging Model for the proposed foam blowing end

- uses.

Table 3. Foam Release Rates and Market Penetrations by End

- Use

Foam End

- Use Annual Leak
Rate First Year Loss a Disposal Loss Lifetime (yrs) Averag e Annual
Release Rate b Market
Share PU Rigid

– Commercial Refrigeration 0.25% 6 .0

% 90% 15 6 .0

% 1%

PU Rigid

– Slabstock 0.75% 3 8

% 51% 15 6 .0

% 1%
PU Rigid

– Spray 1.5% 15% 1.0% 56 0.3% 17 %
PU Rigid

– Appliance 0.25% 3. 8 % 40 % 14 3 .0

% 1 1 % PU Rigid

– Sandwich
Panels 0.50% 5.5% 70 % 50 2 .0

% 2 %

PU and PIR Rigid

– Boardstock 1 .0 % 6 .0

% 44% 50 1 .0 % 64 %

Flexible PU

- Slabstock 0 .0

% 100% 0 .0

% 1 100% 1%

Flexible PU

- Integral
Skin 2.5% 95% 0 .0

% 2 49% 0%

Phenolic Insulation Board and Bunstock 0.8 8

% 23% 49% 32 2 .0

% 2 %

Source: Vintaging Model (v4.4_ 10.13 .14).

a First year losses include losses at manufacture and other production steps that occur prior to end

- use.

b Calculated as (Leak Rate + First Year Loss + Disposal Loss)/Lifetime

Assuming the average annual release rates for each proposed foam blowing end

- use, and that use of
Formacel® 1100 is distributed according to existing market share for each proposed foam end

- use, 2 approximately [ ] MT o f VOCs would be expected to be release d into the atmosphere annually . This amount is approximately [ ] percent of all anthropogenic VOC emissions in the United States . In addition,
the end

- uses with the greatest annual release rate (e.g., integral skin and flexible polyurethane slabstock)

are reasonably expected to occur indoors in a manufacturing or disposal facility, which would have engineering controls in place (e.g., carbon adsorption systems or scrubbers) such that actual quantities of
Formacel® 1100 emissions would be less than the quant ity calculated in this assessment.

Although the VOC emissions for these foam blowing applications are several orders of magnitude l ower than other anthropogenic emissions , it is likely that the estimated VOC emissions estimat ed here can be
further reduced. Furthermore, there are acceptable foam blowing agents c urrently in use that are VOCs (e.g., hydrocarbons , formic acid ), and thus, use of Formacel® 1100 is not expected to increase VOC emissions relative to these other acceptable substitutes.

1 Based on the 2013 annual total VOC emissions for the U nited S tates (i.e., approximately 16.1x10 6 MT) as reported in the National Emissions Inventory (EPA 2014).

2 The distribution of proposed foam end

- uses is based on EPA’s Vintaging Model and may not necessarily represent the submitter’s intended market share for production of Formacel® 1100.Final

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5 Th erefore , us e of Formacel® 1100 would not result in greater impacts on local air quality than other
available options. In addition, Formacel® 1100 has a lower Maximum Incremental Reactivity (MIR) (i.e.,
0.0 4) relative to other commonly used blowing agents (i.e., ethane [MIR = 0.28], dichloroethylene [MIR = 1.70], and cyclopentane [MIR = 2.39]) (DuPont 2012a). Thus, Formacel® 1100 has a lower potential to produce ozone in the atmosphere compared to other commonly used blowing agents

. As the calculated
annual releas es of Formacel® 1100 from these analyses are several orders of magnitude smaller than other anthropogenic sources of VOC emissions, EPA believes that through the use of regulations and standard industry practices, the environmental impacts of these VOCs ar e not considered a significant

concern.



### 5. POTENTIAL HEALTH EFFECTS
To assess potential health risks from exposure to this proposed substitute, DuPont developed a workplace environmental exposure level (WE EL) of 5 00 ppm for Formacel® 1100 ( DuPont 2014 ). The WEEL represents the maximum 8

- hour time weighted average (TWA) at which a worker can be exposed regularly without adverse effects.

According to the SDS, exposure to Formacel® 1100 may be harmful by ocular or dermal absorption, inhalation, or ingestion. Regardless of the route of exposure, the SDS recommends that a physician be
contacted in the case of any exposure . Specifically, i n case of ocular exposure, the SDS for Formacel®
1100 recommends that person(s) sh ould immediately flush the eyes with water for at least 15 minutes

. Exposures of Formacel® 1100 to the skin should also immediately be flushed with water f or at least 15 minutes; should frostbite occur, it should be treated by gently warming the affected area

. A ll contaminated clothing should be re moved and washed before re

- use

. Inhalation may cause cardiac effects
such as irregular h eartbeat accompanied by atypical chest sensations, heart thumping, apprehension, fainting, dizziness, or weakness. In addition, Formacel® 1100 vapors are heavier than air and in high
concentrations cause suffocation and asphyxiation by reducing oxygen available for breathing . If
Formacel® 1100 is inhaled, person(s) should be immediately moved to fresh air. The SDS further recommends that person( s) be kept lying and warm, and provided oxygen and/or artificial respiration if necessary. In situations of emergency life support, physicians should use catecholamine drugs with particular caution because of possible cardiac rhythm disturbances. I n case o f ingestion, the SDS
recommends having the person(s) drink one to two cup s of water, if fully conscious

. If the person vomits while lying on his/her back, the person should be repositioned. D o not induce vomiting without medical
advice. EPA’s review of the human health impacts of this proposed substitute is contained in the public
docket for this decision. These risks and procedures after exposure are similar for other common blowing agents.
The potential health effects of Formacel® 1100 are unlikely to occ ur when following good industrial hygiene practices and the PPE and engineering control (e.g., ventilation) recommendations outlined in the
SDS for Formacel® 1100 and Sections 7 and 8 of this risk screen.



### 6. FLAMMABILITY ASSESSMENT

Formacel® 1100 is not flammable [ ] ; t hus, the proposed substitute is not considered to pose a flammability risk.



### 7. OCCUPATIONAL EXPOSURE ASSESSMENT
This section presents an assessment of potential occupational exposures to Formacel® 1100 , which is anticipated to occ ur during manufacture of blown foam. Based on this assessment, Formacel® 1100 was found not to present a significant risk to workers

.Final

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6 7.1 Occupational Exposure at Manufacture Limited data are available regarding employee exposures to blowing agents for the proposed foam types
at manufacture . The submitter, however, was able to provide results of a laboratory test to measure the

worst

- case occupational exposures [ ]

. Although exposure data were not avai lable for the manufacture of most foam blowing end

- u ses, such as integral skin foam and slabstock foam, which are estimated to have the greatest first year losses (see
Table 3 ), the majority of losses are anticipated to occur after manufacture, during processing (Jeffs 2012).
For slabstock foam and flexible polyurethane foam , this would include cutting of the foam, and for integral skin, this would include removing the foam from its molds. However, the resulting occupational exposure during these activities is not anticipated to present a significant concern (Jeffs 2012). Further, since the monitoring data indicates that the 8

- hour time

- weighted average exposure concentration ( [ ] ppm) during [ ] foam manufactur ing under a conservative scenario are significantly l ower than the 8

- hour
WEEL for Formacel® 1100 ( 500 ppm), it is unlikely that exposure during manufacture and processing of the other proposed foam end

- uses would result in concentrations beyond the acceptab le occupational exposure limit.

During manufacture and use of Formacel® 1100 , engineering control s should be in place, such as vapor

in air detection systems. Adequate ventilation should always be established during any use, handling, or storage of Formacel® 1100 . In addition, an eye wash and safety shower should be near the manufacturing facility and ready for use. In general, use of PPE is recommended, such as NIOSH

- approved respiratory protection, chemical splash goggles or face shield, impervious gloves, and chemical

- resistant boots and clothing consistent with OSHA guidelines ( DuPont 2011 c , OSHA 1 994).

EPA believes that because proper handling guidelines are followed in accordance with good industrial hygiene and manufacturing practices and the SDS for Formacel® 1100 , as described above, manufacture
of Formacel® 1100 foam does not present a significant risk to workers.

7.2 Occupational Exposure at Spray Foam Application In addition to occupational exposure during manufacture of blown foam, there is also potential for occupational exposure to Formacel ® 1100 during rigid polyurethane spray foaming operations, which typically occurs on the site of installation, outside of a manufacturing facility. Monitoring data for
Formacel® 1100 in this application was not available. The submitter did , however, provid e the maximum occupational exposures recorded during HFC

- 245fa spray foam application for comparison. T he HFC

245fa data was used as a surrogate to model exposure concentrations of Formacel® 1100 during spray foam application and ensure that it does not pr esent a risk to workers. Due to the lower vapor pressure and higher boiling point of Formacel® 1100 (see Table 4 ) , EPA believes that using HFC

- 245fa as a surrogate provides a reasonable estimate of potential air concentrations of Formacel® 1100.

Table 4

. Physical Properties of Formacel® 1100 and HFC

- 245fa Analog

Parameter Formacel® 1100 HFC

- 245fa Analog Boiling Point ( ° F ) 92.1 62.4 Vapor Pressure (PSIA at 68 ° C) 8.7 18 Molecular Weight (g/mol) 164 134

Using the HFC

- 245fa surrogate data provided, the maximum exposure for employees involved in the use
of Formacel® 1100 for spray foam was calculated to be [ ] ppm , which is less than the WEEL of 5 00

ppm. In addition , the submitter has indicated that Formace l® 1100 will only be used in industrial or commercial spray foam applications (DuPont 2012) , and thus is anticipated to be used by trainedFinal

— J uly 2, 2015
7 personnel where blowing agent losses are minimized and adequate ventilation is in place. As indicated by
the submitte r, the PPE required for spray foam application would typically eliminate the occupational exposure or reduce exposure to concentrations below the 500 ppm WEEL (DuPont 2011). EPA believes that because proper handling guidelines are followed in accordance wi th good industrial hygiene and

m anufacturing practices and the SDS for Formacel® 1100, use of Formacel® 1100 for the spray foam
end

- use does not present a significant risk to workers.



### 8. GENERAL POPULATION EXPOSURE ASSESSMENT
This section screens potential risks to the general population from exposures to releases of Formacel®
1100 , specifically acute exposures when used in spray foam, and chronic exposures during the lifetime of the foam, because these agents can slowly leak from the foam over time

. Because the proper safety precautions, as listed in the remainder of this section, are followed, Formacel® 1100 is not expected to cause a significant impact on human health in the general population when used for foam end

- uses.

8.1 Acute Exposure at Spr ay Foam Application There is potential for general population exposure to Formacel® 1100 during rigid polyurethane spray foaming operations when performed in buildings with occupants. To ensure that these instances do not present a risk to the general popu lation, EPA recommends that the contractors consult the building management prior to com mencing foam blowing activities. The building management should also ensure that building occ upants are made aware that foam blowing is about to occur and should sugges t the occupant s leave the premises until foam blowing is complete.

8.2 Chronic Exposure during Lifetime Foam

- Blowing Agent Releases There is the potential for chronic general population exposures to foam

- blowing agents during the lifetime
of the foam in which they are used, because these agents can slowly leak from the foam over time

. As a result, in locations where persons are regularly present for extended periods, such as a home or apartment,
the persons could be exposed to very low levels of Formacel ® 1100 over time. Based on the foam blowing end

- uses proposed for Formacel® 1100 , the maximum annual operating leak rate of Formacel®
1100 during the lifetime of the foam (i.e., after manufacture and before disposal) is anticipated to be 1 .5% (see Table 3 ) , resulting in very minimal exposure concentrations well below the WEEL of 500 ppm

. Due to the low toxicity of Formacel® 1100 and minimal expected release, EPA believes that such exposures do not pose a significant toxicity risk, and thus, Formacel® 1100 i s not expected to cause a significant impact on human health in the general population when used as a foam blowing agent in the proposed
end

- uses.



### 9. AQUATIC AND ECOSYSTEM IMPACT ASSESSMENT
To assess potential environmental risks from releases of the proposed substitute to water and aquatic life

, EPA reviewed studies evaluating the ecotox ic ity of Formacel® 1100. Notably, the studies indicated that the chemical has high volatility and would very likely not remain in surface water at concentrations high enough to be considered toxic to the environment. Mitsubishi (2011) indicated that Formacel® 1100 could be toxic to fish. However, the study authors had to continually replenish the Formacel® 1100 in the samples in order to try to maintain the test concent rations of 100 m g/L and observe these effects. The submitter has indicated that releases of the proposed substitute to surface water are expected to be less
than [ ] grams/h ou r, in accordance with facility permit limits. Because releases are expected to be minimal and highly volatile, toxic concentrations of Formacel® 1100 are not likely to occur under normal manufacture and use of the proposed substitute. Based on these considerations, EPA believes that
Formacel® 1100 will not pose significant environmenta l risks through contact with aquatic life

.Final

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8 

### 10. REFERENCES

DuPont Chemicals and Fluoroproducts. 2014. Letter from Toxicology Excellence for Risk Assessment on the Workplace Environmental Exposure Level (WEEL) developed by the Occupational Alliance for Ris k Science for Formacel® 1100. September 12, 2014

DuPont Chemicals and Fluoroproducts. 2012a. Performance Update on Formacel® 1100

– a Zero ODP and Low GWP Foam Expansion Agent. May 8

- 9, 2012. Available at:

< http://www2.dupont.com/Formacel/en_US/assets/do wnloads/20120508_FEA

1100_Performance_Update_charts.pdf >

DuPont Chemicals and Fluoroproducts. 2012 b

. Response to Incomplete SNAP Submission for
Formacel® 1100

. September 5, 2012.

DuPont Chemicals and Fluoroproducts. 2011a. Formacel® 1100 Foam Stability Testing

. September 9,
2011.

DuPont Chemicals and Fluoroproducts. 2011 b

. Response to Incomplete SNAP Submission for
Formacel® 1100

. August 15, 2011

.
DuPont Chemicals and Fluoroproducts . 2011 c . SNAP Submission to EPA for Formacel® 1100

. Aug ust 3,
2011

.

EPA

. 1994. Significant New Alternatives Policy Technical Background Document: Risk Screen on the
Use of Substitutes for Class I Ozone

- depleting Substances: Foam Blowing Agents . Stratospheric Protection Division. March, 1994.

EPA

. 2011. Na tional Emissions Inventory Air Pollutant Emissions Trends Data. Accessed 23 December 2011. Updated October 2011. Available at: <http://www.epa.gov/ttn/chief/trends/index.html#tables>

Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen , R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007. Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate Change 2007:The Physical Science Basis. Contribut ion of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United King dom and New York, NY, USA.

Jeffs, Mike. Personal communication between ICF International and Mike Jeffs. April 24

- 26, 2012.

Mitsubishi Chemical Medience Corporation. 2011. Acute Toxicity Test of 1100 with Medaka (Oryzias latipes). Study Number A100566. Submitted to DuPont

- Mitsui Fluorochemicals, Co., Ltd. August 26,
2011.

OSHA. 1994. General description and discussion of the levels of protection and prote ctive gear. 1910.120 App B. Last updated August 22, 1994. Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9767

WMO (World Meteorological Organization)

. 2011. Scientific Assessment of Ozone Depletion: 2010

, Global Ozone Research and Monitoring Project

— Report No. 52, 516 pp., Geneva, Switzerland, 2011.