UTC Building & Industrial Systems One Carrier Place Farmington, Connecticut 06032 U.S.A. John Mandyck Vice President Sustainability, Marketing & Communications

Ms. Rebecca von dem Hagen U.S. Environmental Protection Agency Office ofAir and Radiation Stratospheric Protection Division (6205J) 1310 L Street, N.W. Washington, D.C. 20005 DearMs. von dem Hagen: November 30,2013 

# United Technologies Building & Industrial Systems

OnbehalfofUTC Building & Industrial Systems and its CatTierbusiness unit, thank you for your letter ofSeptember 24,2013 regarding Carrier's Significant New Alternatives Policy ("SNAP") submission for the approval ofcarbon dioxide ("C02") for Refrigerated Transpmi, New Equipment (including marine containers, trailers, trucks and direct drive applications). This letter is intended to respond to your questions and provide the infmmation necessary for the Environmental Protection Agency ("EPA") to proceed with approval. Wehave reprinted each question from your September 24111 letterbelow along with our response (in italics). We have also included several attachments to this letter which are referenced in ourresponses. Altogether, we are pleased to continue working with the Stratospheric Ozone Division on our application for SNAP approval. Ifneeded, we would be more than willing at any time to discuss any matter concerning our original submission as well as the infonnation contained in the response and attachments below. (1) Impurities 1. Impmities. In Pati I, Section B, Number 5, your application states that the proposed C02 fonnulation will contain vmious impurities in concentration units of"ppm," "ppm by weight," and "ppm byvolume." Pleaseprovide the concentrations ofthese components using a single, consistent unit ofmeasurement, preferablytotal weight percent.
a. You state that the formulation will contain less than 50 ppm byweight of hydrocarbons and other refiigerants as impurities. Pleaseprovide information on what specific hydrocarbons and refrigerants are expected to bepresent. Additionally, to help us understand how these impurities are generated, please indicate the source ofyourraw C02. 1Belowplease find revised text for the answer to Part 

### L Section B(c) regardingImpurities. Wherepossible, we have attempted tofu(fillyour request that concentrations of these components use a consistent unit of measurement (i.e., weight). However, in some areas, applicable industry specifications utilize volume, so we have retained these specifications.
A. Water (H20), Air, Hydrocarbons (e.g., methane, ethane, etc.) andother refrigerants (HFC, HCFC, CFC), high boiling residue B. CASRegistryNumbers: water (H20) 7732-18-5; air 132259-10-0; hydrocarbonsN/A; high boiling residue N/A 

### C. Water (H 2

0) < 20ppm by wt; Air :S 250ppm by vol; Hydrocarbons (e.g., methane, ethane, etc.) andother refi"igerants (HFC, HCFC, CFC) ::S50ppm bywt. High boiling residue ::S5ppm by vol. or wt. [ CBIredacted

### 1 b. Ifyou are following manufacturing standards or specifications that result in these impurity concentrations, please provide information on those methods. [ CBIredacted

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2. Energy Efficiency. In your application you indicate that [ ] and you provide a summary ofthese data. Please provide the final test repmis, including detail on the methods and conditions used to perfonn the tests, and the test results. [ CBIredacted

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3. Refrigerant/Oil Solubility. Please provide information on refrigerant/oil solubility. What is the type ofcompressor oil you expect to use with C02 

### refi·igerant? We are including an attachment includinggraphic information regarding refrigerant/oilsolubility. [ CBIredacted

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4. Charge Size. Please confirm that the charge sizes listed below are the maximum charge sizes expected for each application. Please also provide the typical charge

2size and the typical and minimum volume ofrefrigerated spaces, for each type of equipment listed below.



### We areproviding the additional information requested with regard to confirming the charge sizes for COrbasedsystems and listing both maximum andtypical refrigeratedspaces [ CBIredacted

}. 5. Magnitude ofRelease. In Pmi III, Section B (d), the application states that [ ] Both quantities are greater than the equipment charge sizes. Please clarify ifthe source ofthese estimates is based on [ ] . 

### [ CBIredacted

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a. Please identify the locations of where the potential for release occurs (i.e., indoors or outdoors). 

### [ CBIredacted

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b. In Pmi III Section D (a) and (c), the application states that[ ]

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### [ CBIredacted]. Please provide additional information on the mitigation technologies you intend to deploy, including a diagram ofa reefer truck and a refrigerated storage container that shows where the different patis ofthe refrigeration system and the pressure release valve would be located. In addition, please provide infonnation on the activation time ofthe pressure reliefvalve and the reliability or failure rates ofthe pressure transducer and pressure reliefvalve. 

### [ CBIredacted} Thank you again for the opportunity to clarify and provide additional inf01mation with regard to our SNAP submission. Ifyou have any questions, please do not hesitate to contact me 

### [ ]. Sincerely,

John M. Mandyck Vice President Sustainability, Marketing & Communications

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