I've stumbled upon the same issue.

Here's what I found:

https://answers.launchpad.net/ubuntu/+source/apt-btrfs-
snapshot/+question/263994

https://bugs.launchpad.net/ubuntu/+source/apt-btrfs-snapshot/+bug/833980

In my opinion "older than" should NOT imply "last accessed/used". Such a
feature should be taken care of separately / optionally. I'd guess that
most users use apt-btrfs-snapshot exclusively in order to revert their
system in case of an update gone wrong. In this use case, atime is of no
practical use whatsoever. (Of course some users will use apt-btrfs-
snapshot to switch between different versions of their OS and this
should be supported, but preferably not at the expense of the "main"
feature.)

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https://bugs.launchpad.net/bugs/1569724

Title:
  noatime option

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