UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF AIR AND RADIATION

Mr. Andy Garrett

President

Garrett Services, Inc.

P.O. Box 2233    

Gig Harbor, WA  98335

Dear Mr. Garrett:

Thank you for your letter of November 30, 2004 concerning the use of a
drilling fluid blend that contains n-propyl bromide (nPB).  You
specifically asked if use of this drilling fluid falls within the use
areas defined under the Significant New Alternatives Policy (SNAP)
program for nPB.  You also asked if the failure of nPB to receive SNAP
approval would cause the Garrett drilling fluid to be prohibited.

Based on the descriptions you provided to Margaret Sheppard and I in
your letter and in our conference call of November 19, 2004, we believe
that the Garrett drilling fluid you described does not fall within the
end uses defined under the SNAP program. The descriptions you hprovided
indicate that the Garrett drilling function serves as a combination
lubricant and heat transfer fluid for drilling. This fluid is not a
cleaning solvent used in industrial cleaning equipment, so it does not
fall under metal, electronics, or precision cleaning according to the
original SNAP regulation (March 18, 1994; 59 FR 13090).  The Garrett
drilling fluid is not applied through a pressurized spray can that
releases the solvents using a propellant, so it does not qualify as an
aerosol solvent.  The drilling fluid is not a decorative or durable
coating such as paint, wood stain, or aerospace coating, so this fluid
also falls outside the description of a coating under the SNAP Program
(59 FR 13118).  Thus, it does not appear that the Garrett drilling fluid
falls within the end uses regulated under the SNAP program.  Therefore,
even if use of nPB was found unacceptable in one or more end uses under
the SNAP program, use of the Garrett drilling fluid would be unaffected
by such a determination.

	Even though the Garrett drilling fluid, as described, would not be
regulated by any use restrictions under the SNAP Program, we encourage
you to take steps to ensure that it is used safely.  However, that legal
prohibition only makes it illegal to use unacceptable substitutes within
specific end uses.  For an application outside the SNAP end uses such as
the Garrett drilling fluid, the prohibition would not be a legal
requirement.  Thus, even if nPB were not found acceptable under the SNAP
program, the Garrett drilling fluid still could be used.

	If you have further questions in this matter, please contact me at
(202) 343-9464 or Margaret Sheppard at (202) 343-9163.

							Sincerely,

							Karen Thundiyil

							Environmental Protection Specialist

							Stratospheric Protection Division

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