John M. Mandyck 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

SEP 2 4 2013 

UTC Climate, Controls and Security (Carrier Corporation) 

One Carrier Place 

Farmington, Connecticut 06034 

OFFICE OF 

AIR AND RADIATION 

Re: Incomplete SNAP Submission for Carbon Dioxide in Refrigerated Transport 

Dear Mr. Mandyck: 

Thank you for your submission to the Environmental Protection Agency (EPA) Significant New 

Alternatives Policy (SNAP) program that you submitted on July 19,2013. The Agency has 

reviewed the information in the application and determine-d that the SNAP submission for carbon 

dioxide (COz) in refrigerated transport is incomplete. The following information is necessary in 

order to allow the Agency to begin reviewing your SNAP submission for C02• 

1. Impurities. In Part I, Section B, Number 5, your application states that the proposed C02 

formulation will contain various 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 refrigerants 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. 

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

impurity concentrations, please provide information on those methods. 

2. Energy Efficiency. In your application you indicate that 

- and you provide a summary of these data. Please provide the final test reports, 

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

results. 

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

is the type of compressor oil you expect to use with C02 refrigerant? 

Internet Address (URL) • http:llwww.epa.gov 

Recycled/Recyclable ·Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
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 size and the 

typical and minimum volume of refrigerated spaces, for each type of equipment listed 

below. 

5. 

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

or outdoors). 

b. In Part III Section D (a) and (c), the .. ..,~,. ........ ~ ... , .. 

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 parts of the refrigeration system and the pressure 

release valve would be located. In addition, please provide information on the 

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

pressure transducer and pressure relief valve. 

6. Confidential Business Information. If you wish to claim any ofthe information submitted 

in response to the above requests as confidential business information (CBI), please 

provide two copies of your response, one containing CBI and one with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: C02 

Substance(s) the substitute will replace: HFC-134a, R-404A 

Sector: Refrigeration and Air Conditioning 

End-uses: Refrigerated transport 

New or retrofit usage: new 

Date received: July 19,2013 

Status of submission: incomplete 
Responses to these questions are 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) 343-9445 or vondemhagen.rebecca@epa.gov. 

Sincerely, 

~~ { 

:;;:: 

- Rebecca von dem Hagen 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division