in the sn2 mechanism, the nucleophile attacks the carbon atom in the C-X bond from the side opposite to the halogen atom
in a tertiary haloalkane, attack from that side is likely to be hindered because 3 alkyl groups will limit access to the C+ atom
primary haloalkanes have no more than 1 alkyl group attached to the halogen bearing carbon atom so the access to the C+ atom will be much easier