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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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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 

Commercial 

blends 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 Wozniak.gerald c~epa.gov . 

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