UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mike Sattan 

President & CEO 

Eppendorf 

175 Freshwater Boulevard 

Enfield, Connecticut 06082-4444 

AUG 0 3 2015 

OFFICE OF 

AIR AND RADIATION 

Re: Incomplete SNAP Submission for Ethane (R-1 70) and Propane (R-290) in very low 

temperature refrigeration (two-stage cascade system). 

Dear Mr. Sattan: 

Thank you for Eppendorfs submission to the U.S. Environmental Protection Agency (EPA). 

EPA established the Significant New Alternatives Policy (SNAP) program to implement section 

612 ofthe Clean Air Act. Your application submitted on May 6, 2015 has been reviewed for 

completeness as part of the initial S AP review. We have found the submission to be 

incomplete. The following information is necessary in order to allow the Agency to review of 

Eppendorfs submission for ethane (R-170) and propane (R-290) in very low temperature 

refrigeration. 

I. Applications and End-Uses. In Part I, Section B, Number 4, Part (a), the submitter 

indicates that the proposed substitutes are intended for use in new "Very Low 

Temperature Refrigeration" equipment. 

a. In what type(s) of locations will the equipment be used (e.g., hospitaL 

laboratory)? 

b. Please provide the typical and minimum room sizes (in m3) where the equipment 

will be used. 

c. Please also provide the anticipated room air exchange rate (ACH) for the 

locations where the equipment will be used. 

2. Charge Size. In Part I, Section B. Number 4. Part (b), the submitter indicates that the 

proposed very low temperature refrigeration equipment would have a charge size of less 

than 150 grams for each refrigerant circuit (i.e., less than 150 grams of R-290 in the first 

circuit and less than 150 grams R-170 of in the second circuit). 

a. Please provide the typical charge size estimates for the various applications (e.g .. 

medical freezer equipment, laboratory freezer equipment) in which the proposed 

substitutes will be used using the table below. 

Internet Address (URLl · http //www epa gov 

Recycled/Recyclable • Pronted w th Vegetab'e 011 Based Inks on 100' · Postconsumer Process Chlorone Free Recycled Paper 
End-Use Application Potential Typical Charge Maximum Charge 

Substitute Size (g) Size (g) 

R-170 !50 

R-290 150 

Very Low R-170 150 

Temperature R-290 150 RefTigeration 

R- 170 !50 

R-290 150 

3. Flammability. In Part II, Section A, Number 28, the submitter indicates that the proposed 

substitutes are flammable. For flammable substitutes, various test results and analyses 

must be submitted: 

a. Please submit documentation of testing safety results conducted by independent 

laboratories. 

b. Please include both evaporator and condenser temperature and pressure 

conditions. 

c. Please provide a flammability risk assessment 

1. Please include a full characterization of typical and worst-case exposures 

including the size of the space in which the freezer is being used, the 

typical and maximum charge size consistent with the table above, and a 

comparison of maximum exposure concentrations to the lower 

flammability limits of the proposed substitutes. 

d. Please provide a fault-tree analysis, and please specify probabilities associated 

with each event in the analysis. See Appendix B of the instructions for the SNAP 

Program Information Notice for more information. 

e. Please detail any abatement techniques that are used to minimize the flammability 

risks associated with use of the proposed substitutes. 

4. Occupational Exposure. In Part II, Section A, Number 28, the submission states [ 

] 

a. What are typical values for ventilation in air changes per hour at the charging 

location? 

b. What control technologies (e.g .. carbon absorption, collection systems, air 

filtration, enclosed environment) are used to prevent releases of the proposed 

substitutes to the workplace environment? 

5. Market Penetration. In Part II, Section D, Number 2, the submission states that the 

substitutes are "currently available." Please provide the following information on 

production of equipment containing the proposed substitute. 

a. Please provide the year the submitter intends to begin selling the equipment 

containing the substitute. 

In Part III, Section C, the submission states [ 

] 
1. If not, please provide the projected amount of sales, in units of equipment 

containing the proposed substitute, at maximum market saturation. 

c. Please provide the estimated amount of refrigerant, in the U.S. in pounds per year, 

which will be installed at maximum market saturation. Please also include, the 

projected import/export amount of refrigerant either into, or out of the U.S, in 

pounds per year. 

d. Please also provide the anticipated market share (percentage) of equipment 

containing the proposed substitutes at market saturation. 

6. Servicing. How does the risk during servicing change if a technician were to vent the 

refrigerant to the atmosphere, as EPA allows for certain uses of hydrocarbon refrigerant? 

7. Training. Please provide information on training materials related to manufacture, 

installation and servicing, and disposal of the proposed equipment. 

a. How do these guidelines differ from training for non-flammable refrigerants? 

8. Recove1y. Please indicate the anticipated percent of refrigerant charge remaining in the 

equipment after recovery (i.e., recovery efficiency), assuming recovery processes are not 

l 00 percent efficient. 

9. CBI Claims. If you wish to claim any of the information submitted in response to the 

requests above as confidential business information (CBl) under the Clean Air Act and its 

Amendments, please also provide two copies of your response, one containing CBI using 

brackets and one with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: Ethane (R- 170) and Propane (R-290) 

Sector: Refrigeration and Air Conditioning 

End-uses: very low temperature refrigeration 

New or Retrofit usage: New Equipment Only 

Date received: May 6, 2015 

Status of submission: Incomplete 
Responses to these questions is necessary for us to begin our review. The information can be 

submitted via electronic mail or hard copy. If you have questions about your submission, please 

contact me at (202) 343-9624 or \Vozniak.geraldw epa.Q.O\'. 

Cc: 

Dr. Wilhelm Pluester 

Board Member, CTO 

Barkhausenweg 1, 22339 

Hamburg, Germany 

Sincerely, 

Gerald Wozniak 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division