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 of Air and Radiation 

Stratospheric Protection Division (6205J) 

1310 L Street, N.W. 

Washington, D.C. 20005 

Dear Ms. von dem Hagen: 

November 30,2013 

United 

Technologies 

Building & Industrial Systems 

On behalf ofUTC Building & Industrial Systems and its CatTier business unit, thank you 

for your letter of September 24,2013 regarding Carrier's Significant New Alternatives Policy 

("SNAP") submission for the approval of carbon 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. 

We have reprinted each question from your September 24111 letter below along with our 

response (in italics). We have also included several attachments to this letter which are 

referenced in our responses. 

Altogether, we are pleased to continue working with the Stratospheric Ozone Division on 

our application for SNAP approval. If needed, 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 by volume." Please provide the concentrations of these 

components using a single, consistent unit of measurement, preferably total weight 

percent. 

a. You state that the formulation will contain less than 50 ppm by weight of 

hydrocarbons and other refiigerants as impurities. Please provide information 

on what specific hydrocarbons and refrigerants are expected to be present. 

Additionally, to help us understand how these impurities are generated, please 

indicate the source of your raw C02. 

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Below please find revised text for the answer to Part L Section B(c) 

regarding Impurities. Where possible, we have attempted to fu(fill your 

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.) 

and other refrigerants (HFC, HCFC, CFC), high boiling 

residue 

B. CAS Registry Numbers: water (H20) 7732-18-5; air 

132259-10-0; hydrocarbons N/A; high boiling residue N/A 

C. Water (H20) < 20ppm by wt; Air :S 250ppm by vol; 

Hydrocarbons (e.g., methane, ethane, etc.) and other 

refi"igerants (HFC, HCFC, CFC) ::S50ppm by wt. High 

boiling residue ::S5ppm by vol. or wt. 

[ CBI redacted 1 

b. If you are following manufacturing standards or specifications that result in 

these impurity concentrations, please provide information on those methods. 

[ CBI redacted 1 

2. Energy Efficiency. In your application you indicate that [ 

] and you provide a summary of these data. Please provide the final test repmis, 

including detail on the methods and conditions used to perfonn the tests, and the test 

results. 

[ CBI redacted 1 

3. Refrigerant/Oil Solubility. Please provide information on refrigerant/oil solubility. 

What is the type of compressor oil you expect to use with C02 refi·igerant? 

We are including an attachment including graphic information regarding 

refrigerant/oil solubility. [ CBI redacted 1 

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 

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size and the typical and minimum volume of refrigerated spaces, for each type of 

equipment listed below. 

We are providing the additional information requested with regard to 

confirming the charge sizes for COrbased systems and listing both 

maximum and typical refrigerated spaces [ CBI redacted 

}. 

5. Magnitude ofRelease. In Pmi III, Section B (d), the application states that [ 

] Both quantities are greater than the equipment charge sizes. Please clarify 

if the source of these estimates is based on [ ] . 

[ CBI redacted 1 

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

indoors or outdoors). 

[ CBI redacted 1 

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

] 

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[ CBI redacted]. 

Please provide additional information on the mitigation technologies you intend 

to deploy, including a diagram of a reefer truck and a refrigerated storage 

container that shows where the different patis of the refrigeration system and the 

pressure release valve would be located. In addition, please provide infonnation 

on the activation time of the pressure relief valve and the reliability or failure 

rates of the pressure transducer and pressure relief valve. 

[ CBI redacted} 

Thank you again for the opportunity to clarify and provide additional inf01mation with 

regard to our SNAP submission. If you have any questions, please do not hesitate to contact me 

[ ]. 

Sincerely, 

John M. Mandyck 

Vice President 

Sustainability, Marketing & Communications 

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