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OFFICE OF 

## JUL 0 12014 AIR AND RADIATION

Chris Martin Holland Applied Technologies 7050 High Grove Blvd. Burr Ridge, Illinois 60527 Re: Incomplete SNAP Submission for Methylal in Foam Blowing

Dear Mr. Martin: Thank you for Holland Applied Technologies' submission to the Environmental Protection Agency (EPA). EPA established the Significant New Alternatives Policy (SNAP) program to implement section 612 of the Clean Air Act. Your application submitted on April 18, 2014 has been reviewed for completeness as part of the initial SNAP review. We have found the submission to be incomplete. The following information is necessary in order to allow the Agency to continue the review of Holland Applied Technologies' submission for methylal in foam blowing applications. 1. Application. Your submission indicated that methylal will be used in [ applications. Please confirm that this compound is not intended to be sold to consumers for use in foam blowing (e.g., is not intended for do-it-yourself cans of [ ]). If consumer use is expected, then please provide the following information:
a. Please describe the application system for consumer [ ] use- for example, application using an aerosol can. Please provide the amount of the container contents intended for consumer use in grams and the amount of foam blowing agent, in grams or percentage of total contents, in such a container. b. What are the anticipated average and maximum inhalation concentrations in ppm of the foam blowing agent to which a consumer would be exposed to during use? 2. Blends of Foam Blowing Agents. Please provide further information on blends of methylal with other acceptable substitutes. Below is a table as an option for providing this information.
a. Please identify whether any applications will use methylal as the sole blowing agent in the formulation. b. What are the acceptable foam blowing agents that you expect would be blended with methylal, and what is the percentage range of composition of

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### blends expected in [ ] (such as, 10-20% blowing agent A and the remainder methylal).
c. What percentage composition of other, non-flammable foam blowing agents (e.g., HFC-245fa, or blends of HFC-365mfc/HFC-227ea) is needed to render the blends nonflammable? Please identify this separately for each blend. d. Please provide information on the identity and concentration of decomposition products found in foam cells for each blend of foam blowing agents expected to be used in [

]. See table below.

Percentage Concentration of Expected Co-Blowing Range of Co-Blowing Agent Concentration of Intended Agent Methylal at which Blend is Decomposition Application(s) Non-flammable Products HFC-245fa HFC-365mfc Commercialblends of HFC365mfc/HFC227ea Polyol Isocyanate n-Pentane Cyclopentane and Isopentane Other: please identify

3. 

### Exposure Data. Please provide further information characterizing exposure during

use as a foam blowing agent.
a. Specifically, please clarify the processes and end-uses that resulted in the exposure values found in [ ] of your submission. For example, are specific measured exposures available for [ ] applications? b. In addition, EPA uses the following default assumptions for the maximum annual emission rates for blowing agent leaks from different foam applications during the foam's lifetime (i.e., after manufacturing and before disposal). These are percentages of the original total amount of blowing agent used to produce the foam, not the percentage of agent enclosed in the cells after manufacturing. i. [ ]:1% ii. [ ]:0.25%iii. [ ]:1.5% iv. [ ]:0.25% V. [ ]:0.75% vi. [ ]:2.5% Please confirm whether the above annual emission rates are reasonable for methylal; if not, please provide the anticipated maximum methylal annual emission rates by foam application. 

### 4. CBI Claims. If you wish to claim any of the information submitted in response to the requests above as confidential business information (CBI) under the Clean Air Act and its Amendments, please provide two copies of your response, one containing CBI and one with CBI removed.

Here is a summary of information concerning your submission: Substitute name: Methylal Substance(s) the substitute will replace: HCFC-141b Sector: Foam Blowing End-uses: [

Date received: April 18, 2014 Status of submission: Incomplete Responses to these questions is necessary for us to begin our review. The information can be submitted via electronic mail or hard copy. If you have questions about your submission, please contact Gerald Wozniak at (202) 343-9624 or 

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. Sincerely,

Gerald Wozniak Alternatives and Emissions Reduction Branch Stratospheric Protection Division

Cc: Ms. Angelina Duggan Exponent, Inc 1150 Connecticut Ave, NW Suite 1100 Washington, DC 20036