United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460	AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives	Date of Receipt:

Date 90 Day Review Begins:

Date Review Completed:

CBI Status:



When completed send this form to:

Via US Postal Service:                                                  
                                 Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER                       SNAP DOCUMENT
CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J                      U.S. EPA

U.S. EPA                                                                
         1310 L STREET NW

1200 PENNSYLVANIA AVE NW                                     10th FLOOR
(MC 6205J)

WASHINGTON, DC 20460                                     WASHINGTON, DC
20005



	Enter the total number of pages in your SNAP information Notice:
Document Control Number



INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit information under the Significant New
Alternatives Policy (SNAP) program for the review of alternatives to
class I and class II ozone-depleting substances (ODS) under section 612
of the Clean Air Act.  Submitters are required to provide this
information on new substitutes to assist the Agency in assessing the
acceptability of chemicals or processes that are considered alternatives
for ODSs.  A separate notice must be filed for each alternative you are
submitting.

All submissions must be provided in three complete copies.  If
information is to be claimed as confidential, all confidential
information must be excised from one of the copies, which will be placed
in the public docket; the other two copies must include the confidential
material.  If no claims of confidentiality are made for the submission,
all copies must be identical.

The attached “Guidance Manual for the SNAP Information Notice” is
designed to assist applicants in completing this form.  The manual
provides instructions on submitting a SNAP notice, asserting
confidentiality claims, completing the notice form, sector-specific data
requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled
out as completely as possible.  Please provide all information requested
to the extent that it is known or reasonably ascertainable.  Make
reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission:  New alternative, Substance, or
Formulation________________________________________X__

Petition: New alternative, Substance, or
Formulation__________________________________________________________

Petition: Revision of the Existing SNAP
list__________________________________________________________________

 Petition: Request to Grandfather Use of An Unacceptable
Substitute_____________________________________________





You must provide the identity of the alternative chemical of processes
and the identity and percentages of all components in a blend and/or
process, even if you claim the identity as confidential.  You may
authorize another person to submit the identity for you, but your
submission will not be complete and review cannot begin until EPA
receives this information.

Part II - ALTERNATIVE-SPECIFIC INFORMATION

                                                       

Please indicate the sector(s) for which you are submitting information
on the substitute by checking the appropriate boxes:

Refrigeration and Air Conditioning 	          

Foam Blowing    			     

Solvent Cleaning      	  	       

Fire Extinguishing 

		and Explosion Prevention    	    X

Sterilization       	 		     

Aerosols 				     

Adhesives, Coatings, and Inks 	      

Tobacco Expansion 		     

Pesticides 			      

You may need additional copies of Part II if there are several
manufacturing, processing, or use operations that you will describe in
this notice.  Please reproduce these sections as needed.

If you substitute is also subject to review under FIFRA, provide the
FIFRA Registration Number:

 _____________________________

	Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on the
form to fully answer a question.  Label each continuation sheet with the
corresponding section heading and the question.  In part IV, list these
attachments and any test data, other data, or any optional information
that you include in this notice.

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or control
and to provide a description of all other data known to you if these
data are related to the health and environmental effects of the
manufacture, processing, distribution in commerce, use, or disposal of
the alternative.  Standard literature citations may be submitted if they
do not appear in the open scientific literature.  Complete test data (in
English), not summaries of data, must be submitted if they do not appear
in the open literature.  The following are test data and other data that
might be submitted (see the Guidance Manual for a more complete list of
data to be submitted.)  Please indicate test data to be included in your
submission notice by checking the appropriate boxes:

 Yes    No

Flammability Data		 Yes    No

Environmental Effects 

	Data			 Yes    No

Environmental Fate 

	Data			 Yes    No

Risk Assessments		 Yes    No

Test Data Not in the Possession/

	Control of the Submitter	 Yes    No

Other Data 			 Yes    No

You must provide the identity of the alternative chemical of processes
and the identity and percentages of all components in a blend and/or
process, even if you claim the identity as confidential.  You may
authorize another person to submit the identity for you, but your
submission will not be complete and review cannot begin until EPA
receives this information.





CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at
the time of submission for any data which are to be treated as
Confidential Business Information (CBI).  Substantiation of this claim
must also be provided at this time.  All information claimed as CBI will
be treated in a manner consistent with 40 CFR Part 2, Subpart B. 
Failure to assert a claim of confidentiality at the time of submission
may result in disclosure of information by the Agency without further
notice.

To assert a claim on this form, circle or bracket the information you
claim as confidential and mark the confidential box at the bottom of the
page.  Then provide substantiation of this claim on an attachment to the
notice.  If any information is claimed as confidential, you must provide
a “sanitized” version of this notice, including attachments, to EPA
with our submission.  For additional information on claiming information
as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as
Authorized Representatives of the United States Environmental Protection
Agency (EPA) under an EPA contract for the purpose of assisting EPA in
the development and implementation of national regulations for the
protection of stratospheric ozone, including the development of the SNAP
program.  These Authorized Representatives may have access to any
information received by the Stratospheric Protection Division within EPA
Office of the Atmospheric Programs for use in reviewing the need for
possible control of any substance, practice, process or activity that
may reasonably be anticipated to affect stratospheric ozone.  Access to
such information is necessary to ensure that these companies can
complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the
provisions of 42 U.S.C. 7414(c) respecting confidential business
information as implemented by 40 CFR 2.301(h).





Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION



1. (a) Person Submitting Notice (in U.S.)

__Adam
Richardson______________________________________________________________
_President____________________

Name of Authorized Official                                             
                                                                 Title

__N2Towers
Inc.____________________________________________________________________
___________________________

Company/Organization

10 Forin Street Belleville,   ON,  Canada,  K8N
2H6___________________________________613-962-2401_  
613-968-3519_________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 

 Email address Adam.Richardson@n2towers.com

(b) Agent (if applicable)

___George W
Goetz_____________________________________________________________Consul
tant________________________

Name of Authorized Official                                             
                                                                 Title

________________________________________________________________________
____________________________________

Company/Organization

_16033 E. Primrose Drive #107,  Fountain Hills,  Az, 
85268______________________________480-836-8333_____________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 

email address georgewgoetz@gmail.com

(c) Joint Submitter (if applicable)

________________________________________________________________________
____________________________________

Name of Authorized Official                                             
                                                                 Title

________________________________________________________________________
____________________________________

Company/Organization

__. Primrose Drive #107,  Fountain Hills,  Az, 
85268_______________________________________480-836-8333________________
__

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 

email address georgewgoetz@gmail.com

2. Technical Contact (in U.S.)

___George W
Goetz_____________________________________________________________Consul
tant___________________________________

Name of Authorized Official                                             
                                                                 Title

________________________________________________________________________
_________________________________

Company/Organization

________________________________________________________________________
__________________________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 



3. If you have had a prior communication with EPA concerning this
notice, note the date and type of communication (letter, phone, etc.)
and the EPA staff person’s name:

Mark (X) if None _email conference call Nov 10, 2009 with Bella Maranion
& Margaret Sheppard______

Mark (X) this box if this page contains CBI __________



Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: N2 Towers, comes with N2
Generator Fire Suppression System which produces 100% clean nitrogen gas
(N2) (an inert gas). 



2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process
name.  For blends, provide the percent composition of each constituents.

    (b) Chemical Abstracts Service (CAS) registry number and molecular
formula.

    (c) For alternative processes and technologies describe the
technology and  provide a diagram of the system.  Also provide the
information on any chemical constituents.

    (d) If you hold a patent on the substitute, provide the patent name
and number and include a copy of the patent as an attachment.  If you
have submitted a patent application but have not been granted one yet,
indicate the date submitted and the expected time frame for a response. 

Answers a & b

        N2 Generator Estimated Room Toxicological Results	 After
Accidental Discharge

			CAS #    Measured  ACGIH     TLV's	Ceiling			

			               Exposure  8Hr TWA	STEL	 Inflators which could have
species		

	

Carbon Dioxide	CO2	124-38-9   882 ppm 	5000	30000-15min		Augment	

Carbon Monoxide	CO	630-08-0     80 ppm	 50 OSHA	200	 50/35/25
OSHA/NIOSH/ACGIH		

Particulates Total		1-16-8         31 Mg/M3 10 Mg/M3	15-30 min	 STEL was
30 Penn Health Laws		

					 STEL Canada 20 - 30 min

Nitrogen    & Air       N2/O2	7727-37-9 & 132259-10-0 (Balance)  (12% to
15%) 5 minutes maximum per NFPA 2001 Standard 

Note: Occupants located inside a space do not need any type of
protective goggles, clothing and or respirator equipment in which there
has been an accidental N2 Generator discharge.   

(c)  See attached Addendum A

(d) See attached Addendum B



3. Generic chemical name (if chemical name of substitute is declared
Confidential Business Information).

Non applicable



4. Specific End-Use

   (a) Describe each end-use that may be reasonably anticipated for the
alternative.  Be sure to provide a broad description          (e.g.
terpene-based semi-aqueous solvent cleaner for electronic parts, or HFC
substitute refrigerant for centrifugal chillers).  For a list of end
uses, see Appendix A to the instructions, beginning on p. 19.

   (b) Identify the ODS and the quantity of substitute (if applicable)
needed to replace it for each end use in pounds (replacement ratio).

(a)  N2 Towers (N2 Generators) are total flood nitrogen inert gas fire
suppression systems whereby the oxygen inside a space is inerted down
below 15% per volume. Combustion can not support a flame below 15%
oxygen inside a space, thereby the fire is extinguished. During actual
N2 Generator fire extinguishing tests at UTeC Labs in Hallowell, Kansas
during 2009, it has been observed by N2 Towers Inc. that the actual
nitrogen discharge vorticity (turbulence) created inside the test space,
separates the flame from the fuel and extinguishes the test fire before
the oxygen inside the test booth is inerted below 15% by volume. By then
inerting the test space below 15% oxygen by volume the test fire does
not reignite.

 

(b) Filtered nitrogen gas is supplied without any Ozone Depletion or
Global Warming effect.

 



Mark (X) this box if this page contains CBI __________



Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. (a) Identify each impurity that may reasonably be anticipated to be
present in the chemical alternative as manufactured for commercial
purposes.  If there are unidentified impurities, enter
“unidentified.”

    (b) Provide the CAS Registry Number if available.

    (c) Estimate the maximum weight percentage of each impurity.  If
there are unidentified impurities, estimate their total weight   
percentages.

Note: Please see Part I- GENERAL INFORMATION, Sections 2 a & b of this
application.



6. Byproducts:

    (a) Describe any byproducts of degradation products resulting from
the manufacturer, processing, use or disposal of the chemical
alternative or chemicals used in the new alternative.  If there are
unidentified byproducts/ degradation products enter “unidentified.” 

    (b) Provide the CAS Registry Number if available.

    (c) Indicate where the byproduct/degradation product is formed (e.g.
during manufacturing, during use, etc.) and the amount or rate at which
it is formed.

(a) Our N2 Generator propellant grain undergoes the following chemical
reaction 4NaN3 + Fe2O3 -> 2Na2O.FeO + 6N2 during discharge.   Clean
nitrogen gas is delivered into the space, which leaves a sinter (a solid
at flame temperature) inside the generator (2Na2O.FeO) a high
temperature stable mixed salt is treated as if it were Na2O (CAS #
1313-59-3) or  NaOH (CAS # 95077-05-7).  This material is contained
within the filter inside the N2 Generator and is neutralized at the mill
when the metal body of the inflator is smelted and recycled. 

(b) See above for CAS #.

(c) See above in answer (a), during use in 100 millisecond discharge of
a N2 Generator.



Mark (X) this box if this page contains CBI __________







Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION

1.  Ozone-depletion potential (ODP):

     (a) Provide the 100 year ODP of the alternative relative to CFC-11,
if known.  If the substitute is a blend, provide the ODPs of individual
constituents.

     (b) Provide source of ODP or any additional data on the ODP of the
alternative (e.g. atmospheric lifetime, chlorine or bromine loading
potentials).  Reference the source of this information and attach any
supporting documentation.

(a) & (b)  No   Ozone-depletion potential (ODP):  Nitrogen gas N2



2.  Global Warming Characteristics:

    (a) Provide the alternative’s global warming potential (GWP)
relative to carbon dioxide over 100- and 500-year time horizons, if
known.  If the substitute is a blend, provide the GWPs of the individual
constituents.

    (b) If known, provide the alternative’s expected impact on energy
efficiency relative to the substance it is replacing (e.g. +/- X%) and
results of  any testing or modeling done (both theoretical and actual
testing).

    (c) Provide source of GWP or any additional data on the GWP of the
alternative, including the atmospheric lifetime, infrared absorption
spectrum, and infrared absorption capacity.  If the alternative (e.g.
CO2 captured from a stream of waste gas as a by-product of
fermentation).

(a) & (b) & (c) Not a Global Warming gas.  Nitrogen N2



Mark (X) this box if this page contains CBI __________

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1.  Describe whether an d how the alternative is regulated under other
environmental regulatory statutes, for example other titles under the
Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water
Act (SDWA), the Resource Conservation and Recovery Act (RCA), the
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic
Substances Control Act (TSCA), the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), the Emergency Planning and
Community Right-to-Know Act (EPCRA, also known as SARA Title III), and
state and local laws.  List any concentration-based or other numerical
standards to which the alternative is subject under the above standards
and regulations.

 Note; Our N2 Generator propellant grains were previously manufactured
by TRW in Mesa, Arizona and undergo the following chemical reaction
4NaN3 + Fe2O3 -> 2Na2O.FeO + 6N2 during our N2 Generator discharge.
Clean nitrogen gas is delivered into the space, which leaves a sinter (a
solid at flame temperature) inside the generator (2Na2O.FeO) a high
temperature stable mixed salt is treated as if it were Na2O (CAS #
1313-59-3) or  NaOH (CAS # 95077-05-7). This material is contained
within the filter inside the N2 Generator and is neutralized at the mill
when the metal body of the inflator is smelted and recycled. 

 

2.  Describe whether and how the alternative is regulated under health
and safety related statutory authorities, such as those implemented by
the Food and Drug Administration (FDA), the Occupational Safety and
Health Administration (OSHA), the Department of Transportation (DOT),
and state and local laws.  List any concentration-based or other
numerical standards to which the alternative is subject under the above
statutes and regulations.  Also list any other standard-setting
organizations such as the National Fire Prevention Association (NFPA) or
the American Society of Heating, Refrigerating, and Air Conditioning
Engineers (ASHRAE), by which the substitute is evaluated.

The following standards are being used:

(a) OSHA for our discharged N2 Generator Carbon Monoxide, Carbon Dioxide
and particulate levels which are acceptable for occupied spaces.  

(b) DOT approval for non-hazardous shipping of our N2 Generators for air
cargo, land and sea travel.  

(c) NFPA 2001 Standard for using our N2 Generators to displace oxygen
inside a normally occupied space down to a 12 % oxygen level per volume
with a required 5 minute maximum egress time limit for the occupants
from the space. 



Mark (X) this box if this page contains CBI __________



Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1.  Estimate the cost per pound for the substitute chemical.  For
alternative processes and technologies, describe installation costs
associated with the alternative.  

Answer; Our N2 Generators can protect 1,000 cubic feet for a wholesale
cost of approximately $2,000 US which is the approximate cost for
existing UL Listed stored pressure cylinder, inert gas fire suppression
systems or occupied spaces, sold in the USA today.   



2.  Provide information on production of the substitute.  Include
estimates on:

    (a) Year substitute will be available if not currently produced.
Answer; full scale production capable by June 2010 or sooner.  

    (b) Total pounds production per year (current figure). Answer;
155,138 pounds of propellant in 2010, 1,000,000 pounds in 2011.

    (c) Years to maximum market penetration. Answer; 2 to 4 years.

    (d) Maximum total production per year at market saturation. Answer;
the USA will wholesale approximately $120,000,000 clean agent fire
systems in 2010, this equates to approximately 60,000,000 stored
pressure inert gas fire system bottles and an equivalent number of N2
Generators. .  

    (e) Estimated percentage of market at market saturation. Answer; 80%
of market for N2 Generator fire system for market saturation.  



3.  Describe any new equipment and use profiles.  If retrofitting of
existing equipment is required, detail changes in technologies needed to
use the alternative and address any materials compatibility issues. 
Provide information on each end-use and capital costs associated with
the substitute or alternative process.  Include cost of equipment and/or
any new materials, equipment lifetime, changes in labor and energy
costs.

Answer; our N2 Tower and N2 Generator fire suppression systems can be
used for 100 % of all applications where clean agent fire suppression
and explosion suppression systems are used in the fire system’s
industry today. The wholesale cost of our N2 fire suppression systems is
mentioned above in Section D – 1. 

Answer; an existing halon, compressed chemical and or inert gas, total
flood clean agent fire suppression system can be easily retrofitted with
a N2 Tower fire suppression system because our N2 Tower fire systems
require no discharge piping system. Also, our N2 Towers (c/w N2
Generators stacked inside the N2 Tower) total flood, inert gas fire
suppression system can use existing detection and control equipment to
be put into alarm and actuated (discharged).     





Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative
processes, summarize below (and attached supporting information) the
acute and chronic toxicity of the substitute and of its constituent
chemicals on any organism (e.g. human and/or other mammals, fish,
wildlife, and plants), if available.  Include any data on impurities and
degradation products if known.  Also include information on any
“Allowable Exposure Limits” (AELs) that have been set for the
substitute for use in the workplace.  In addition, please attach a copy
or facsimile of any hazard warning statement, label, material safety
data sheet, or other information which will be provided to any person
who is reasonably likely to be exposed.  (See Guidance Manual for
sector-specific data requirements).

Answer; our N2 Tower (N2 Generator) total flood fire suppression systems
discharge clean nitrogen gas into a normally occupied. The above
questions are non-application to our N2 Tower fire systems.  



Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

     (a) Identify all site locations (i.e. name and address) for each
chemical manufacturing process.

     (b) Identify all site locations for manufacturing of products using
substitutes (e.g. refrigerators containing the substitutes).

     (c) Identify the points of release and/or exposure during the
manufacture of: (i) the substitute and/or (ii) products containing the
substitutes.

     (d) Provide information on the magnitude of release if available,
along with the media to which the substitute is released (e.g. indoor
air, outdoor air, water, land). 

Answer; this N2 Generator SNAP List application is for our N2 Generators
which will be made from an existing stockpile of sodium azide propellant
grains which were manufactured and are presently stored at TRW’s Mesa,
Arizona facility.    



Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or
products containing substitutes):

     (a) Describe the activities in which workers may be exposed to
chemicals.

     (b) Describe any protective equipment and engineering controls used
to protect workers (e.g. goggles, gloves, chemical hoods).

     (c) Indicate the physical form of chemicals at the time of
handling/exposure (e.g. solid, liquid, gas).

     (d) Estimate average and maximum numbers of workers involved in
each activity.

     (e) Estimate average and maximum duration of activity for any
worker, in terms of (1) hour/day and (2) days/year.

     (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (g) Estimate the average and high-end exposure concentrations
(separated by a /), being sure to provide units of measure.

Answer; our existing stockpile of TRW sodium azide propellant gains will
be shipped to UTeC Labs in Hallowell, Kansas and loaded into our N2
Generators using a down draft loading table inside the UTeC propellant
grain loading facility, as permitted by the local health and safety
authority having jurisdiction in this matter. Glove use is recommended
when loading sodium azide propellant grains but no respirator is needed
for the worker when using a down draft, propellant grain lading table.
N2 Generator propellant grain loading can be performed 24 hours per day
and 365 days per year. Sodium azide is not to be ingested because it is
a poison. Total number of workers allowed in the exposure area is per
building code permitted allowances for that particular space.   

Coated TRW Grains:                                               ACGIH  
     OSHA          

Component                         CAS#           Percent       TLV      
     PEL              UNITS

Sodium Azide (S)            26628-22-8      50-70         0.3 (C)      
Not Est.          mg/M3    

Ferric Oxide                    1309-37-1         20-35           5 (F) 
      10 (F)(T)        mg/M3    

Graphite                           7782-42-5           2-7             2
(R)       15(T) 5(T)      mg/M3    

Bentonite 1.                     1302-78-9           0-5       10(T)
3(R)    15(T) 5(T)       mg/M3    

Sodium Nitrate                7631-9-4             0-5         Not Est. 
     Not Est           mg/M3    

Potasium Perchlorate       7778-74-7           0-3         Not Est.     
 Not Est.         mg/M3    

Amorphous Silica            112926-00-8       0-2           10(T)       
                        mg/M3    

                                                                        
                                  20(T)         MPPCF

N2 Generator Filter Pad Material inside the N2 Generator
(non-carcinogenic):  

Fibrox paper                                                            
 ACGIH        OSHA          

Component                      CAS#               Percent       TLV     
      PEL              UNITS

Mineral Wool        65997-17-3                  90-95          10       
       15                mg/M3    total dust

                                                                        
               5                                    mg/M3   respirable
dust

Latex                                                           5-10    
     Not established         (Baked out in manufacture)

ACGIH TLVs are based on 2003 valvues

OSHA PELs are based on 1970 values

All values are 8 hour averages unless otherwise noted.

S = Material can be absorbed through intact skin

C = Ceiling Exposure Limit

F = Fume

T = Total Particulate Matter

R = Respirable Fraction of Particulate Matter

1.  Exposure limits are for Particulates Not Otherwise Classified.  No
OSHA or ACGIH standards exist for this material.



Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute:

     (a) Provide the estimated amount (in kg/day) of each chemical
released directly to the environment (e.g. as a hazardous waste or
wastewater effluent) at a site using the substitute (e.g. in products
containing the substitute and processes using the substitute).

     (b) Identify the media (indoor air, outdoor air, land, water) to
which the chemical will be released from that release point.

     (c) Describe the control technology used to limit release; estimate
the amount released to the environment with the control technology in
place to limit release.  If the substitute is to be disposed of,
indicate the method and location of disposal.

     (d) Are releases covered under RCRA?  If so, identify the RCRA
hazardous waste codes.

     (e) Identify the appropriate number of sites expected to use the
substitute.

     (f) Provide information on recycling of the substitute.  Describe
any associated costs and equipment.

Answers; 

a) This information is provided above in Part 1 – General Information
– section # 2 of this application. 

b) Again, this information is mentioned in Par 1 – General Information
– section # 2 of this application; this information and data of
chemical release happens after discharge of our N2 Generator. 

  

c) We make a ceramic paper and steel wool filter roll/pad which is
inserted inside the N2 Generator and the TRW propellant grains are then
placed inside the filter roll. When the pyrotechnic squibs are actuated
inside both end caps of the N2 Generator they ignite the propellant
grains and the filter pad catches the particulate and clean nitrogen gas
is discharged from the N2 Generator into the protected space. 

d) Our N2 Generator nitrogen release is not covered under RCRA. After
discharge the sinter product left inside the discharged N2 Generator is
considered as sodium hydroxide (re: commercially known as Drano), in an
industrial setting sodium hydroxide is covered under RCRA. However N2
Towers Inc. will provide a “cradle to grave” program for our N2
Generator end users who can, if they wish, ship the discharged N2
Generators back to our recycling facility, which will smelt down and
recycle our N2 Generator metal valve bodies. 

e) In all potential clean agent applications across the USA. 

f) Answered above in (d).     





Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the
substitute in products and/or processes):

     (a) Describe the activities in which workers may be exposed to
chemicals.

     (b) Describe any protective equipment or engineering controls used
to protect workers (e.g. goggles, gloves, chemical hoods).

     (c) Indicate the physical form of chemicals at the time of
handling/exposure (e.g. solid, liquid, gas).

     (d) Estimate average and maximum numbers of workers involved in
each activity.

     (e) Estimate average and maximum duration of activity for any
worker, in terms of (1) hours/day and (2) days/year.

     (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (g) Estimate the average and high-end exposure concentrations
(separated by a /), being sure to provide units.

Answer  (a);.  

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50 OSHA	200	 50/35/25 OSHA/NIOSH/ACGIH		

Particulates Total		1-16-8         31 mg/M3 10 Mg/M3	15-30 min	 STEL was
30 Penn Health Laws		

					 STEL Canada 20 - 30 min   

Nitrogen    & Air       N2/O2	7727-37-9 & 132259-10-0 (Balance)  (12% to
15%) 5 minutes maximum per NFPA 2001 Standard     

Answer (b): Occupants located inside a space do not need to wear any
type of protective goggles, gloves, chemical hoods, clothing, dust
respirator equipment or self contained breathing apparatus in which
there has been an accidental N2 Generator discharge. 

Answer (c): The CO2, CO and nitrogen is discharged as a gas into a space
by an N2 Generator the above noted particulate is a tiny solid.   

Answer (d): Total number of occupants which are allowed inside a room
after accidental N2 Generator discharge is as per the existing building
occupancy permit for that particular room. 

Answer (e): After accidental discharge of an N2 Generator if the oxygen
level inside the space is 12 % per volume then the occupants must vacate
the space within five minutes. 

Answer (f): The contact pathway for the above mentioned gas and
particulate levels are by way of inhalation.  

Answer (g): The above noted N2 Generator gas and particulate amounts are
the estimated high end levels after a N2 Generator discharge. 



Section F - CONSUMER EXPOSURE

For each end-use of a substitute:

     (a) Identify the potentially exposed population (e.g. indoor
residents).

     (b) Identify the exposure medium (e.g. air).

     (c) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (d) Enter the exposure point of concentration.  Provide (1) average
and (2) high-end estimates.



Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

     (a) Identify and number potential exposure points.

     (b) For each exposure point described in (a), identify the
potentially exposed population (e.g. residents at the fenceline).

     (c) Identify the contact pathway (e.g. ingestion, inhalation,
dermal).

     (d) Identify the exposure medium (e.g. air, water).

     (e) Enter the exposure point concentration (mg/m3).  Provide (1)
average and (2) high-end estimates. 

Answer; through the use of our stockpile of existing TRW sodium azide
propellant grains our N2 Generator’s only expose the general public to
100 % clean nitrogen gas, as it is discharged from an activated N2
Generator into a space and noted in various sections of this N2
Generator SNAP List application.     



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 PAGE   

 PAGE   21 

Form 1265-07 (Revised 06/2008)			

Previous editions are obsolete

