May 30, 2014 -- Final 1 

## Significant New **Alternatives Policy Pr ogram**  **Refrigeration and Air Conditioning Sector**  **Risk Screen on Substitutes for CFC -**  **12 , HCFC**  **- 22,**  **and R -**  **502 in**  **Vending Machines Substitute:**  **R -**  **441 A**  **This risk screen is restricted to vending machines meeting the requirements of UL 541:**  **Refrigerated Vending Machines .**  **This risk screen does not**  **contain Clean Air Act (CAA) Confidential Business Information (CBI) and, therefore, may be disclosed to the p**  **ublic.** 

### 1. **INTRODUCTION** Ozone - depleting substances (ODS) are being phased out of production in response to a series of diplomatic and legislative efforts that have taken place over the past two decade s , including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAAA). The U.S. Environmental Protection Agency (EPA), as authorized by Section 612 of the CAAA, administers the Significant New Alternatives Policy (SNAP) Program, which identifi es acceptable and unacceptable substitutes for ODS in specific end -uses based on assessment of their health and environmental impacts. EPA’s decision on the acceptability of a substitute is based on the findings of a screening assessment of potential human health and environmental risks posed by the substitute in specific applications. EPA has already screened a large number of substitutes in many end -use applications within all of the major ODS using sectors including : refrigeration and air conditioning, solvent cleaning, foam blowing, aerosols, fire suppression, adhesives, coatings and inks, and sterilization. The results of these risk screens are presented in a series of Background Documents that are available in EPA' s docket. The purpose of this risk screen is to supplement EPA’s Background Document on the refrigeration and air conditioning sector (EPA 1994) (hereinafter referred to as the Background Document) . This risk screen evaluates the potential use of R- 441A as a substitute for CFC - 12 , HCFC - 22, and R - 502 i n the vending machine end -use . Table 1 presents the composition of the proposed substitute. **Table 1**  **. Composition of R** **- 44**  **1 A**  **Constituent Chemical Formula**  **CAS Number Concentration**  **(Weight Percent**  **) a**  Propane C 3 H 8 74 - 98 - 6 55% n - Butane C 4 H 10 106 - 97 - 8 36% Isobutane C 4 H 10 75 - 28 - 5 6% Ethane C 6 H 14 74 - 84 - 0 3% a There are no impurities of toxicological or ecological significance anticipated for this formulation. Isomers of hydrocarbons present in formulation mixture will exist, but are not considered to be an imp urity, contaminant or byproduct . Section 2 summariz es the results of the risk screen for the proposed substitute blend listed in Table 1 . The remainder of the risk screen is organized into the followin g sections:

 Section 3 : Atmospheric Assessment  Section 4 : Volatile Organic Compound Assessment  Section 5 : Discussion of End - Use Scenario s Modeled  Section 6: Potential Health Effects  Section 7 : Flammability AssessmentMay 30, 2014 -- Final 2  S ection 8 : Asphyxiation Assessment  Section 9 : End -Use Exposure Assessment  Section 10 : Occupational Exposure Assessment  Section 11 : General Population Exposure Assessment  Section 12 : References 

### 2. **SUMMARY OF RESULTS** R - 441A is recommended for SNAP approval for vending machines that comply with Underwriters Laboratory (UL) Standard 541: Refrigerated Vending Machines . E PA's risk screen indicates that the use of the proposed substitute will be less harmful to the atmosphere than the continued use of CFC - 12 , HCFC - 22, and R - 502 as it is less harmful to the ozone layer, has lower climate impact, and a shorter atmospheric lifetime . Three of the four components of R - 441A are subject to volatile organic compound (VOC) regulations u

nder the CAA (40 CFR 51.100(s)). Based on analysis o f potential impacts of hydrocarbon refrigerant emissions on ground - level ozone concentrations , VOC emissions from the use of R - 441A in vending machines are not anticipated to contribute significantly to ground level ozone concentrations in the United State s . It is expected that procedures identified in the material data safety sheet ( MSDS ) for R- 441A and good manufacturing practices will be adhered to . Additionally, it is expected that the appropriate safety and personal protective equipment (PPE) ( e.g., pr otective gloves, tightly sealed goggles, protective work clothing, and suitable respiratory protection in case of leakage or insufficient ventilation) consistent with Occupational Safety & Health Administration ( OSHA ) guidelines will be used during manufacture, installation and servicing, and disposal of vending machines using R441A . Because vending machines are to be installed in locations with adequate space and/ or ventilation in accordance with EPA recommendations and the equipment maintenance manual for R- 441A as discussed in greater detail in Section 9 , significant toxicity or flammability risk to consumers is also unlikely. Additional safeguards , including specified refrigerant concentration limits (RCL) of R- 441 A components, are also provided by adherence to industry standards including American Society of Heating, Refrigerating and Air - Conditioning Engineers (ASHRAE) Standards 15 , 1 34 , 2 and 62 3 and Underwriters Laboratory (UL) Standard 541, Supplement SA . 4 

### 3. **ATMOSPHERIC ASSESSMENT**  This section presents an assessment of the potential risks to atmospheric integrity posed by the use of R441 A in vending machines . The ozone depletion potential ( ODP ) , global warming potential ( GWP ) , and atmospheric lifetime (ALT) of the proposed substitute are presented in Table 2 . The proposed substitute is substantially less harmful to the oz one layer, has l ower climate impact, and a shorter atmospheric lifetime when compared to CFC - 12 , HCFC - 22, and R- 502 . Inaddition, R- 441A also has lower climate impact and a shorter atmospheric lifetime than those predicted for other substitutes examined in the Background Document , as well as commonly utilized substitutes R - 404A and HFC - 134a. Thus, EPA believes that the use of R- 441A would result in substantially less harm to the climate and ozone layer than the continued use of ODS and commonly used ODS sub stitutes.

1 Safety Standard for Refrigeration Systems ASHRAE Standard 15 establishes safeguards for life, limb, health, and property and prescribes safety requirements. 2 Designation and Safety Classification of Refrigerants ASHRAE Standard 34 is establishes a uniform system for assigning reference numbers, safety classifications, and refrigerant concentration limits to refrigerants. Safety classifications based on toxicity and flammability data are included. 3 Ventilation for Acceptable Indoor Air Quality ASHRAE Standard 62 establishes minimum ventilation rates and other measures intended to provide indoor air quality that is acceptable to human occupants and that minimizes adverse health effects. 4 UL 541: Refrigerated Vending Machines Supplement SA: Requirements for Refrigerated Venders Employing a Flammable Refriger ant in the Refrigerating SystemMay 30, 2014 -- Final 3 **Table 2**  **. Atmospheric Impacts of R** **- 441**  **A Components**  **Compared to Other Vending Machine**  **Refrigerants Refrigerant**  **Ozone Depleting Potential (ODP)**  a **Global Warming Potential (GWP)**  b **Atmospheric Lifetime in**  **Years (ALT)**  Propane 0 3.3 0. 03 a n - Butane 0 4.0 0. 018 c Isobutane 0 ~4 0. 016 a Ethane 0 5.5 0. 21 c CFC - 12 0. 82 10,900 100 b R - 502 d 0. 2 4,650 NAe HCFC - 22 0.04 1,810 12 b R - 404Af 0 3,92 0 NAg HFC - 134a 0 1,430 14 b a WMO 2010 Scientific Assessment Report (2011). b IPCC 4 th Assessment Report (Forster et al. 2007) c IPCC /TEAP (2005) d R - 502 is a blend consisting of HCFC - 22 (49%) and CFC - 115 (51%) . e Atmospheric lifetimes are not given for blends, because the components separate in the atmosphere. T he ALT for HCFC - 22 is 12 years and the ALT for CFC - 115 is 1,700 years (IPCC 4 th Assessment Report [Forster et al. 2007]). f R - 404A is a blend consisting of HFC - 143a (52%), HFC - 125 (44%) and HFC - 134a (4%). g Atmospheric lifetimes are not given for blends, because the components se parate in the atmosphere. The ALT for HFC - 143a is 52 years, the ALT for HFC - 125 is 29 years, and the ALT for HFC - 134a is 14 years. 

### 4. **VOLATILE ORGANIC COMPOUND (VOC) ANALYSIS** Three of the four components of R- 441A

— propane, n -butane, and isobutane

– - are regulated as VOC s under the CAA (40 CFR 51. 1 00 (s) ) , while the component ethane is exempted. Through regulations and standard industry practices, VOC emissions should be controlled. A separate analysis was prepared by EPA (2014) to evaluate the potenti al impact of the use of hydrocarbon refrigerants on ground level ozone concentrations in the United States. The analysis estimated refrigerant emissions from refrigeration and air conditioning equipment, which were assumed to contain propylene, isobutane, and /or propane 4 under different scenarios. Under the most conservative scenario , it was assumed that propylene was used in all refrigeration and air conditioning equipment. In the most realistic scenario, all three hydrocarbons were assumed to be used in certain types of refrigeration and air conditioning equipment , depending on the proposed use of each alternative under submissions received by the SNAP Program at the time of the analysis . End -uses in the evaluation included self - contained refrigeration u nits , for which SNAP hydrocarbon applications have been received and /or UL Standards covering flammable refrigerants exist. Th e hydrocarbon emissions from these scenarios were estimated based on U.S. EPA’s Vintaging Model, and their potential contribution s to ozone concentrations were assessed using U.S. EPA’s Community Multiscale Air Quality (CMAQ) model. CMAQ modeling was performed for April through the end of September, as these months presented the largest releases of hydrocarbon refrigerant as well a s weather conditions favorable for ozone formation. The ozone concentrations were estimated for the Atlanta, Houston and Los Angeles regions, due to their distinctive geographic setting and chronic high levels of ground level ozone, and then scaled for national emission estimates. The results of the CMAQ modeling indicated that under the most realistic scenario , hydrocarbon refrigerants could potentially increase the maximum 8 -hour average ground level ozone by lesson more than 0.15 ppb in Los Angeles, the city with the greatest ozone problem. This is roughly 0.2 percent of the current National Ambient Air Quality Standard (NAAQS) for ozone of 75 ppb . In the most conservative case which assumed that the most reactive hydrocarbon, propyle ne, was used in

4 EP A uses the maximum incremental reactivity (MIR) of ethane (0.28 g - O 3 /g - substance) as the threshold for determining whether a compound has negligible reactivity. Propylene (MIR = 11.57), isobutane (MIR = 1.34), and propane (MIR 0.56) are all considered to be reactive compounds and are therefore subject to V OC regulations.May 30, 2014 -- Final 4 all refrigeration and air conditioning equipment, there could be an incremental maximum increase of the 8 -hour average as high as 6.61 ppb ozone, or an increase of up to 9 percent of the NAAQS. However, this upper bound level of increase is not likely, as most ozone nonattainment areas are not VOC - limited (i.e., the formation of ozone in these areas are not by limited by VOC emissions, but by other compounds such as nitrogen oxides [NO x ]). In addition, the analysis assumed no use of VOC - exem pt refrigerants which may be used in the refrigeration and air conditioning end -uses . Based on the results of this analysis, VOC emissions from the use of R - 441A in vending machines are not anticipated to contribute significantly to ground level ozone conc entrations in the United States. 

### 5 **. DISCUSSION OF END**  **- USE SCENARIOS MODELED**  R - 441A has been proposed for the vending machine refrigeration end -use. The submission states that R441A vending machines will have a typical charge size of 63.5 grams, and a maximum charge size of 90.7 grams (i.e., 25 - 36 percent the charge size of a HFC - 134a vending machine); however, UL Standard 541: Refrigerated Vending Machines states that vending machines containing flammable refrigerants may have a charge size of up to 15 0 grams of A3 refrigerant . To represent a reasonable worst - case scenario, it is assumed that a catastrophic leak of refrigerant occurs while the vending machine is installed at the end -use. Because vending machines can be installed in a wide range of locations with varying room volumes, the analysis in this risk screen conservatively assumes that the vending machine contains the maximum charge size indicated by UL 541 (150 grams) , and is located in the minimum room size, an enclosed alcove of a commercial building that can be isolated by a door. Under the worst - case scenario, the alcove is assumed to have an effective floor area of 6.15 m2 (i.e., excluding the space filled by the vending machine, furniture, boxes, etc.) and a height of 2.4 meters (A.S. Trus t & Holdings, Inc. 2011), equivalent to a volume of 15 m3 (530 ft 3 ). Under the worst case scenario, the full charge of the unit is assumed to be emitted over the course of one minute, into the enclosed alcove with 0.5 air changes per hour (ACH). A vertica l concentration gradient is also assumed since R- 441A is denser than air (specific gravity of R- 441A relative to air is 1.67 [air = 1]) and will settle in higher concentrations closer to the ground . In order to simulate the vertical concentration gradient , it is assumed that 95 percent of the leaked refrigerant mixes evenly into the bottom 0.4 meter of the room, and the rest of the refrigerant mixes evenly in th e remaining volume (Kataoka 2000 ). To represent a more typical scenario, this risk screen also evaluates potential risk associated with less conservative conditions. Based on ICF expert opinion, the enclosed alcove is assumed to have an effective floor area of 10m 2 (108 ft2 ) with a height of 2.7 m (9 ft), equivalent to a volume of 27.5 m3 (972 ft 3 ), with an air exchange rate of 1.5 ACH (EPA 1997) . Additionally, because the typical breathing zone is above 0.4 meters (1.3 feet) and mixing is likely to occur upon release of R- 441A from the unit because the system pressure is higher than the surroundin g atmospheric pressure, a vertical concentration gradient is not assumed . Table 3 details the end -use modeling assumptions used throughout the risk screen (i.e., in Sections 7, 8, and 9). **Table 3. End**  **- Use**  **Scenario Model Assumptions Parameter**  **Assumption s**  **Reasonable Worst**  **- Case Scenario**  **Typical Scenario Room Type**  Enc losed Alcove Enc losed Alcove Effective Size (m 3 ) a 15 (530 ft 3 ) 27.5 (972 ft 3 ) Ventilation Rate (air changes per hour) 0.5 1.5 **Refrigeration Unit** Vending Machine Vending Machine Charge Size (g) 150 150 Length of Release (minutes) 1 1 Vertical Concentration Gradient Yes No a The volume of the room minus the volume occupied by the vending machine or other large pieces of equipment or furnitu re present.May 30, 2014 -- Final 5 EPA recognizes that while the majority of vending machines may be placed outdoors or in other well ventilated areas, which would largely minimize the risks of exposure, there may a few instances in which the consumer chooses to place multiple vending machi nes in an enclosed space (thus further limiting the effective volume of the space) or chooses to place a single vending machine unit in a very small enclosed space (with the size of the vending machine being the limiting factor). A typical beverage vending machine measures 72 in x 39 in x 33 in, which is equal to 53.6 ft 3 or 1.5 m3 (Vending Solutions 2009). To address these concerns, this risk screen incorporates threshold analyses in addition to the worst - case scenario modeling. The results from the thresh old analyses are used to establish guidelines for choosing an effective room size, charge size, and ventilation rate such that use of R- 441A in vending machines does not present risk to consumers or servicing technicians. 

### 6 **. POTENTIAL HEALTH EFFECTS**  To assess potential health risks from exposure to the proposed substitute in vending machines , EPA identified the relevant toxicity threshold values for comparison to modeled exposure concentrations for different scenarios for each constituent of R- 441A . To p rotect consumers from the potential dangers of a catastrophic leak from the refrigeration unit, ASHRAE Standard 34 determined refrigerant concentration limits (RCLs) for the components of R- 441A which are intended to reduce the risks of acute toxicity, asp hyxiation, and flammability hazards in normally occupied, enclosed spaces during refrigerant use (ASHRAE 2010b). ASHRAE Standard 15 implements the aforementioned standard, requiring that “the concentration of refrigerant in an enclosed space following a co mplete discharge of a high -probability system shall not exceed the RCL” to ensure that there is not a significant risk of toxicity, asphyxiation, and flammability (ASHRAE 2010a). As such, this risk screen references the RCL of the R- 441A components in addition to the lower flammability limit, hypoxia No Observed Adverse Effect Level (NOAEL ) , and exposure limits, as an additional, conservative limit to ensure that significant flammability, asphyxiation, and end -use exposure risks , respectively, do not occur. For the occupational exposure analysis, potential risks from chronic and acute worker exposure were evaluated by comparing exposure concentrations to available occupational exposure limits. Potential risks of chronic worker exposure were evaluated usin g workplace guidance levels (WGL). Risks from potential short - term consumer exposures were evaluated by comparing exposure concentrations to e mergency guidance levels (EGL). Potential short - term, end -use exposures are compared to an established short - term exposure limit (STEL), acute exposure guideline level (AEGL), or emergency response planning guideline (ERPG); in the absence of these limits, an excursion limit, calculated according to the methodology described in ACGIH (2004), is applied. 5 When evaluati ng the toxicity of R - 441A , the cumulative effects and additivity of toxicities of short - chain aliphatic hydrocarbons are not considered to be a concern. ACGIH and OSHA do not consider these cumulative risks. Furthermore, a recent study evaluated alkane gas es (ethane, propane, n -butane, and isobutane) in combined repeated exposure studies with reproduction/development toxicity screening tests. No significant effects on systemic toxicity or neurotoxicity were found at concentrations from 9,000 to 16,000 ppm, and no significant effects on developmental or reproductive toxicity were found at the highest concentrations tested (McKee RH et. al. 2013). Furthermore, the components of R- 441A do not share an end -point of concern.

5 I t should be noted that this risk screen evaluates both short - term occupational and end -use (i.e., non - occupational) exposure to ethane by comparison to the excursion limit, which is typically used to evaluate short - term occupational expo sure. EPA believes, however, that in the absence of an AEGL, STEL, or ERPG, the excursion limit provides a reasonable proxy. Notably, the ACGIH methodology (i.e., a calculation of three times the TLV - TWA) has also been used by DOE (2008) to develop temporary emergency exposure limit s (TEEL) for ethane ( 3,500 mg/m3 or 2,900 ppm 15 - min TWA), which apply to the general population.May 30, 2014 -- Final 6 Table 4 lists the relevant toxicity limits of each component of R- 441A, and is followed by Table 5, which provides an explanation of each toxicity limit . EPA’s approach for identifying or developing these values is discussed in Chapter 3 of the Backgro und Document. **Table 4**  **. Exposure Limits**  **of R** **- 441A**  **Components R**  **- 441A**  **Component 8**  **- hr**  **WGL (Long -**  **term Exposure)**  **ppm EGL (Short**  **- term Exposure)**  **ppm Refrigerant**  **Concentration Limit**  **(RCL) ppm**  Propane 1,000 a

(OSHA PEL ) 10,000 c , d (10 min AEGL - 1) 6,900 d (30 min AEGL - 1) 5,300 g n - Butane 1,000 b (ACGIH TLV) 6,900 e (30 min AEGL - 1) 4,000 g Isobutane 1,000 b (ACGIH TLV) 6,900 f 4,000 g Ethane 1,000 b (ACGIH TLV) 3,000 h (30 min ACGIH Excursion Limit) 2,900 i (15 - min TEEL - 1) 7,000 g

a OSHA PEL available at: http://www.cdc.gov/Niosh/npg/npgd0524.html b ACGIH TLV for aliphatic hydrocarbon gases: alkane (C 1 - C 4 ) is 1 , 000 ppm TWA (ACGIH 2012) c An IDLH of 2,100 ppm has been established for propane. However, NIOSH (1996) states that "[b]a sed on acute inhalation toxicity data in humans (ACGIH 1991; Braker 1980), a value much greater than 10,000 ppm would have been appropriate. However, the revised IDLH for propane is 2,100 ppm based strictly on safety considerations (i.e., being 10% of the lower explosive limit of 2.1%)." Therefore, as this IDLH value is based on flammability concerns and not toxicity concerns, it is not used in the evaluation of toxicity risks in this risk screen. d AEGL - 1 available at: http://www.epa.gov/opptintr/aegl/pub s/tsd96.pdf e AEGL - 1 available at: http://www.epa.gov/opptintr/aegl/pubs/tsd102.pdf f Because n - Butane and isobutane have the same molecular formula, EGL for isobutane is conservatively assumed to be that for n - Butane. However, OSHA (2004) notes the follow ing regarding isobutane: “OSHA does not have a PEL for isobutane, which is affirmed as "generally recognized as safe" as a direct human food ingredient (21 CFR 184.1165). No toxic effects reported below 18,000 ppm.” g ASHRAE (2010 b ) h Calculated as three times the TLV - TWA (ACGIH 2004). i DOE (2008) **Table 3**  **. Explanation of Exposure Limit** **- Related**  **Terminology a**  **Organization Definition**  OSHA Occupational Safety and Health Administration NIOSH National Institute for Occupational Safety and Health ACGIH American Conference of Governmental Industrial Hygienists AIHA American Industrial Hygiene Association **Exposure Limit Definition**  **Explanation Short**  **- Term Exposure**  RCL Refrigerant Concentration

Limit The RCL for a refrigerant is intended to reduce the risks of acute toxicity, asphyxiation, and flammability hazards in normally occupied, enclosed spaces. The RCL for each refrigerant is the lowest of the Acute - Toxicity Exposure Limit (ATEL), Oxygen Deprivation Limit (ODL), and Flamma ble Concentration Limit (FCL). Determination assumes full vaporization with no removal by ventilation, dissolution, reaction, or decomposition and complete mixing of refrigerant in the space to which it is released. STEL Short - Term Exposure Limit A 15 - min ute TWA exposure that should not be exceeded at any time during a workday, even if the 8 - hour TWA is within the TLV–TWA , set by ACGIH. AEGL b,c Acute Exposure Guideline

Level 1 AEGL - 1 is the airborne concentration of a substance above which it is predicted that the general population, including susceptible individuals, could experience notable discomfort, irritation, or certain asymptomatic nonsensory effects. However, the effects are not disabling and areMay 30, 2014 -- Final 7 transient and reversible upon cessation of exposure. Acute Exposure Guideline Level 2 AEGL - 2 is the airborne concentration (expressed as ppm or mg/m3) of a substance above which it is predicted that the general population, including susceptible individuals, could experience irreversible or other serious, long - lasting adverse health effects or an impaired ability to escape. Acute Exp osure Guideline Level 3 AEGL - 3 is the airborne concentration (expressed as ppm or mg/m3) of a substance above which it is predicted that the general population, including susceptible individuals, could experience life - threatening health effects or death.

ERPG Emergency Response

Planning Guideline 1 T he maximum airborne concentration below which it is believed that nearly a ll individuals could be exposed for up to 1 hour without experiencing other than mild transient health effects or perceiving a clea rly defined, objectionable odor according to AIHA. Emergency Response Planning Guideline 2 T he maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ab ility to take protective action according to AIHA. Emergency Response Planning Guideline 3 The maximum airborne concentration below which it is believed nearly all individuals could be exposed for up to 1 hour without experiencing or developing life - threatening health effects according to AIHA. Excursion Limit d Excursion Limit Because methane (and other short - chai n alkane gases through butane) does not have a TLV - short - term exposure limit, an excursion limit may be applied. Excursions in worker exposure levels may exceed 3 times the TLV- TWA for no more than a total of 30 minutes during a workday, and under no circumstances should they exceed 5 times the TLV - TWA, provided that the TLV - TWA is not exceed ed according to ACGIH. IDLH Immediately Dangerous to

Life and Health If exposed to this concentration, room occupants are expected to be able to escape the room within 30 minutes without experiencing escape impairing or irreversible health effects.

TEEL e Temporary Emergency

Exposure Limit 1 TEEL - 1 is the maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing other than mild transient adverse health effects or perceiving a clearly defined, objectionable odor. Temporary Emergency Exposure Limit 2 TEEL - 2 is the maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective a ction. Temporary Emergency Exposure Limit 3 TEEL - 3 is the maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing or developing life - threatening health effects. **Long -**  **Term Exposure** PEL Permissible Exposure Limit This is an 8 - hour time - weighted average exposure limit set by OSHA. TLV- TWA Threshold Limit Value – Time Weighted Average The TWA concentration for a conventional 8 - hour workday and a 40 - hour workweek, to which it is believed that nearly all workers may be repeatedly exposed, day after day, for a working lifetime without adverse effect according to ACGIH. a All information in this table taken from EPA (1994) except where otherwise noted. b EPA (2012) c A pplicable to emergency exposure periods ranging from 10 minutes to 8 hours. d ACGIH (2004) e Chemical exposure guidelines to use for emergency planning if no AEGL or ERPG is available. TEELs are developed based on conc entration limits or toxicology parameters (DOE 2008).May 30, 2014 -- Final 8 According to the MSDS, exposure to R- 441A may be hazardous if inhalation, skin contact, or eye contact with R- 441A occurs. The most likely pathway of exposure is through inhalation. R - 441A can cause symptoms of asphyxiation when present in concentrations h igh enough to significantly lower oxygen concentrations below 19.5 percent by volume, such as headaches, ringing in ears, dizziness, drowsiness, nausea, vomiting, depression of all senses, and also unconsciousness. Under some circumstances of over exposure (i.e., oxygen levels fall below 6 percent by volume), death may occur. In addition, at high concentrations, propane, a major component of the R- 441A blend, can act as a narcotic and cause central nervous system depression, including dizziness, drowsiness, and headaches. If R - 441A is inhaled, person(s) should be immediately removed and exposed to fresh air. In accordance with the MSDS , EPA further recommends that if breathing is difficult, person(s) be given oxygen, provided a qualified operator is present , and medical attention be sought. Rescuers should not attempt to retrieve victims of exposure to R- 441A without adequate PPE. At a minimum, a self - contained breathing apparatus (SCBA) should be worn. Exposures of R- 441A to the skin may cause frostbite. In the case of dermal exposure, the MSDS for R- 441A recommends that person(s) immediately wash the affected area with water and remove all contaminated clothing; if frostbite occur s , bathe (not rub) the affected area with lukewarm, not hot, water. If water is not available, cover the affected area with a clean, soft cloth. Alternatively, if the fingers or hands are frostbitten, warm the affected area by placing it in the armpit; gently exercise the affected part while being warmed, and seek medic al attention immediately . Exposures of R- 441A to the eyes could cause eye irritation . In case of ocular exposure, the MSDS for R- 441A recommends that person(s) immediately flush the eyes, including under the eyelids, with copious amounts of water for 15 minutes . EPA’s review of the human health impacts of this proposed substitute is contained in the public docket for this decision. The potential health effects of R- 441A can be minimized by following the exposure guidelines and ventilation and PPE recommendations outlined in the MSDS for R- 441A and this risk screen. 

### 7 **. FLAMMABILITY ASSESSMENT**  ASHRAE Standard 34 classifies R- 441A a s a Class A3 refrigerant. R- 441A is flammable when its concentration in air is in the range of 2.05% and 9.25% by volume (20,5 0 0 ppm to 92 ,500 ppm). In the presence of an ignition source (e.g., static electricity, a spark resulting from a switch malfunction, or a cigarette), an explosion or a fire could occur when the concentration of R- 441A exceeds its lower flammability limit (LFL) of 20,5 0 0 ppm , posing a significant safety concern for workers and consumers if it is not handled carefully. The remainder of this section assesses flammability risks and summarizes the recommended measures to ensure safe handling and use of the refrigerant during manufacture, servicing, and end -use. **7 .1**  **Flammability Risks at**  **Manufacture** As indicated by the submitter, the manufacture of R- 441A refrigerant (i.e., formulation mixing) and the charging of R- 441A vending machines (i.e., receiving, blending. and filling operations) occurs in a closed system; all units are completely sealed before delivery and installation. In addition, manufacturing facilities are anticipated to maintain proper ventilation at all times during the manufacture of equipment containin g R - 441A and adhere to good manufacturing practices 

### . As a result, releases of R- 441A during these manufacturing and installation operations in the presence of an ignition source are not anticipated. All R- 441A storage and transport equipment should be installed with safety devices that minimize the likelihood of catastrophic releases For example, NFPA 58 Liquefied Petroleum Gas Code (NFPA 2014 )May 30, 2014 -- Final 9 for liquefied propane requires the use of overfill protection devic es (OPD) on cylinders to minimize the likelihood of leaks. The NPFA 58 Code also contains propane storage and transportation requirements/guidelines. Similar equipment safety and procedural requirements should be developed for R - 441A and other flammable refrigerants. EPA believes that because relevant safety standards, the MSDS for R - 441A, and OSHA requirements under 29 CFR 1910 (e.g., proper ventilation and storage practices within manufacturing facilities to prevent fire and explosion) are followed by w orkers, flammability during manufacture is not a concern. **7 .**  **2 Flammability Risk at Servicing and End**  **- Use**  The risk of flammability during servicing and end -use for the reasonable worst - case scenario and typical scenario (see Section 5 ) was investigated for R- 441A . Both servicing and end -use of R- 441A vending machines are expected to take place in the same room. In order to determine the potential flammability risks during servicing or end -use in case of a catastrophic release of refrig erant in an enclosed alcove (see Section 5 ), concentrations of R- 441A immediately following a complete release of refrigerant, either accidental or deliberate (e.g., through vandalism or theft), were compared to the LFL for R- 441A. The reasonable worst - cas e scenario assumes an effective room size of 15 m3

. In this worst - case scenario, the modeling results reflect the maximum co ncentration in the lower 0.4 meters of the room, as the u pper portion of the room presents a much lower risk, with only 5 percent of the leaked refrigerant present in this area , which also has a great er volume than the lower 0.4 meters of the room . In the typical scenario, an effective room size of 27.5 m3 and air exchange rate of 1.5 ACH are assumed while the modeling results reflect the maximum concentration in the entire room, as a vertical concentration gradient is not assumed . Table 6 presents the results of the analysis. **Table 6**  **. Flammability Assessment a**  **Scenario Charge**  **Size (g)**  **Effective Room** 

**Size (m 3**  **) Vertical** 

**Concentration Gradient**  **Height (m) Maximum** 

**Instantaneous Concentration**  **(ppm) b,c**  Reasonable Worst - Case 150 15 (530 ft 3 ) 0.4 **29,800** Typical 150 27.5 (972 ft 3 ) None **2,710** Threshold Analysis 1a: Charge Size **101** 15 (530 ft 3 ) 0.4 20,5 0 0 Threshold Analysis 1b: Charge Size **1,110** 27.5 (972 ft 3 ) None Threshold Analysis 2a: Room Size 150 **22.3 (731 ft**  **3 )**  0.4 Threshold Analysis 2b: Room Size 150 **3.7 (122 ft 3**  **)** None **Bold font** indicates modeling results. a Cells highlighted in green are the scenarios with exposure levels deemed acceptable given various modeling assumption options b Lowe r Flammability Limit of R - 441A is equal to 20,050 ppm. c Values provided in these columns refer to the concentration in the lower 0.4 meters of the room , which presents the most conservative risk as 95 percent of the leaked refrigerant in present in this space. In the reasonable worst - case scenario, at a charge size of 150 grams, the maximum instantaneous concentration of R- 441A in the lower 0.4 meters of the room would be approximately 29,800 ppm, which is 1 4 5 percent of the LFL for R- 441A (see Table 6). In the typical scenario, the maximum instantaneous concentration of R- 441A in the entire room would be approximately 2,710 ppm, which is 1 3 percent of the LFL for R- 441A. However, the accidental release of all refrigerant into the enclosed alcove is highly unlikely. This is because the refrigerant system is located in a protected compartment on the back side of the vending machine and acciden ts resulting in a puncture to the compressor, whether through attempted theft of the vending machine contents or vandalism, would be unlikely. In the case of accidental release, however, R- 441A is likely to be dispersed into the air evenly and almost instantaneously upon release; the vending machine compressor is pressurized, which will cause R- 441A to be released into the roomMay 30, 2014 -- Final 10 (assumed to be at atmospheric pressure of approximately 14.7 psi) under pressure, resulting in the refrigerant’s a quick and turbul ent release, and subsequent mixing into the air (A.S. Trust & Holdings, Inc. 2011). However, it is also unlikely that 100 percent of the refrigerant charge will be released from the system because as the refrigerant leaks, the system pressure will decrease and eventually equilibrate with atmospheric pressure, leaving a small amount of refrigerant in the system. To completely remove the entire refrigerant charge from the system , a vacuum pump must be used . Catastrophic releases of large quantities of refrige rant, especially in areas where refrigerant is stored, could cause an explosion. For the flammability threshold analysis, the conditions at which a flammability concern would exist (i.e., when the maximum instantaneous co ncentration in the lower 0.4 meter s of the enclosed alcove equals the LFL for R- 441A) was determined. Under the room size, vent ilation rate, and vertical concentration gradient assumed within the reasonable worst - case scenario, the charge size of the R - 441A refrigeration unit would have to be at least 101 grams for a flammability concern to exist, as shown in Threshold Analysis 1a. Under the room size and ventilation rate assumed within the typical scenario, the charge size of the R- 441A refrigeration unit would have to be at least 1,110 gr ams for a flammability concern to exist, as shown in Threshold Analysis 1b. Using a 150 - gram refrigeration unit, as shown under Threshold Analysis 2a and 2b, the volume of the room would have to be smaller than 22 m3 (781 ft 3 ) or 3.7 m3 (122 ft 3 ) for a flammability risk to occur und er the reasonable worst - case and typical scenarios, respectively . EPA recommends that these guidelines be followed to further minimize risk of flammability. According to the results of this flammability analysis, the risk of fire is minimal if a vending machine is installed in a room with volumes in accordance with standards and regulations. For this reason, it is important that only properly trained and certified technicians handle R- 441A . The submitter has provid ed safety guidelines for handling R - 441A , which should be followed. As a further precaution , certification requirements and training programs for technicians that handle R- 441A should be developed u sing these guidelines. During servicing operations, technicians should ensure that proper ventilation is in place through the use of fans (or other mechanical ventilation devices) and portable refrigerant detectors should be used to alert technicians to the presence of flammable gases in the area. Vending mach ines should not be installed in small, poorly ventilated spaces such as very small enclosed areas or storage closets (especially as other equipment or appliances in the space would reduce the effective volume of the room). F or vending machines installed i n larger areas, the risk of fire and explosion is minimal. Vending machines installed with R- 441A should be clearly labeled as containing a flammable refrigerant and designed to prevent catastrophic leaks. The installation of leak prevention devices would further protect against the very limited risk of explosion. EPA believes that the risk of fire is minimal if an R- 441A vending machine is installed in a room with volumes and ventilation in accordance with standards, MSDS, and recommendations. 

### 8 **. ASPHYXIATION**  **ASSESSMENT** The risk of asphyxiation for the reasonable worst - case scenario was investigated for R- 441A . In this section, risk of asphyxiation is assessed in three ways: 1) modeling the oxygen concentration under the charge size and room size specified in the worst - case scenario, 2) performing a threshold analysis of minimum charge size needed to cause an asphyxiation risk in the room size specified in the worst - case scenario 3) performing a threshold analysis of the maximum room size needed to cause an asphyxiation risk with the charge size specified in the worst - case scenario. This analysis does not consider conditions that are likely to occur that would increase oxygen levels to which individuals would be exposed, such as open doors or window s, fans operating, conditioned airflow (either heated or cooled), or even openings at the bottom of doors that allow air to flow in and out. As specified in Section 5 , this analysis assumes a vertical concentration gradient . If the proposed substitute pas ses the screening analysis with these restrictive assumptions in place, it can be reasonably assumed that no risks of asphyxiation will be present under real -world conditions. The results of the asphyxiation assessment are summarized in Table 7 below .May 30, 2014 -- Final 11 **Ta ble**  **7 . Asphyxiation Assessment**  **a Scenario**  **Charge Size**  **(g) Effective** 

**Room Size (m**  **3 )**  **Vertical**

**Concentration Gradient Height**  **(m) Percent Oxygen** 

**Concentration b**  Reasonable Worst - Case 150 15 (530 ft 3 ) 0.4 **21** Typical 150 27.5 (972 ft 3 ) None **21** Threshold Analysis 1a: Charge Size **2,710** 15 (530 ft 3 ) 0.4 12 Threshold Analysis 1b: Charge Size **29,810** 27.5 (972 ft 3 ) None 12 Threshold Analysis 2: Room Size 150 **0.83 (29.3 f t**  **3 )**  0.4 12 Threshold Analysis 2a: Room Size 150 **0.14 (4.9 ft 3**  **)** None 12 **Bold font** indicates modeling results. a Cells highlighted in green are the scenarios with exposure levels deemed acceptable given various modeling assumption options . b The typical c oncentration of oxygen in air is considered to be 21 percent (Mackenzie & Mackenzie 1995) . In order for a risk of asphyxiation to occur, the normal concentration of oxygen in air (21 percent) in the lower 0.4 meters of the room must be reduced to 12 percent. 6 Based on both reasonable worst - case scenario and typical scenario modeling ass umptions, R- 441A in vending machines does not present a significant risk of asphyxiation. The concentration of R- 441A in the air in the lower 0.4 meters of the room following the release of the 150 - gram charge size does not exceed 2.4 percent or 0.2 percent in the reasonable worst - case and typical scenarios, respectively , which has an insignificant impact on the normal concentration of oxygen in air. Because this modeling does not take into account any ventilation which is likely to occur, such as condition ed airflow, open doors, or even openings at the bottom of doors that allow air to flow in and out, as mentioned above, the actual asphyxiation risk to personnel is likely to be even smaller than modeled. For the a sphyxiation threshold analyses shown in Table 7 , the conditions at which an asphyxiation concern would exist were determined. As shown in Threshold Analysis 1a , the minimum charge of R441A necessary to reduce the oxygen levels to 1 2 percent in air in the lower 0.4 meters of a room o f volume 15 m3 ( 530 ft 3 ) was calculated to be 2,710 grams, which is more than 18 times the maximum UL 541 charge size of 150 grams . As shown in Threshold Analysis 1b, the minimum charge of R- 441A necessary to reduce the oxygen levels to 12 percent in the air of a room of volume 27.5 m3 (972 ft 3 ) was calculated to be 29,810 grams, which is approximately 200 times the maximum UL 541 charge size of 150 grams. These analyses, Threshold Analysis 1a and 1b, assumed that 1) nitrogen and oxygen retain the same relative volumes in the rooms with the balance composed entirely of R- 441A , and 2) the pressure of the room does not increase significantly with the addition of the refrigerant. As shown in Threshold Analysis 2 a , f

or asphyxiation to be of concern with the proposed maximum charge size of 150 grams, in a 15 m3 room, the effective volume of the enclosed alcove would have to be about 0.83 m3 ( 29.3 ft 3 ) (see Table 7 ), which is smaller than the size of the vending machine itself. As shown in Threshold Analysis 2b, for asphyxiati on to be of concern with the proposed maximum charge size of 150 grams and assuming no vertical concentration gradient in a 27.5 m3 room, the effective volume of the enclosed alcove would have to about 0.14 m3 (4.9 ft 3 ), which is also smaller than the size of the vending machine itself. Based on the worst - case modeling results and threshold analysis, EPA does not believe that the use of R- 441A in vending machines poses a significant risk of asphyxiation or impaired coordination to consumers. 

### 9 **. END**  **- USE**  **EXP OSURE**  **ASSESSMENT** This section presents estimates of potential consumer exposures to the components of R- 441 A in vending machines . A consumer exposure analysis was performed to examine potential catastrophic releases for

6 Twelve percent oxygen in air is the No Observed Adverse Effect Level (NOAEL) for hypoxia (ICF 1997).May 30, 2014 -- Final 12 each of the chemical constituents of R- 441 A under the reasonable worst case scenario and typical scenario outlined in Section 5 . For the end -use exposure assessment scenario, 30 - min TWA exposures for the proposed substitute and each of its impurity cons tituents were calculated using the box model described in the Background Document, which was adapted to estimate concentrations on a minute -by - minute basis. The analysis was undertaken to determine the 30 - minute TWA exposures for each component of R- 441 A , because consumers are anticipated to only spend short amounts of time in the presence of vending machines while purchasing and consuming products ( A .S. Trust & Holdings, Inc. 2011). The se exposures were then compared to the standard toxicity limits present ed in Table 4 to assess the risk to end -users . However, the TWA values are fairly conservative as the analysis does not consider opened windows, fans operating, conditioned airflow (either heated or cooled) and other variables that would reduce the levels to which individuals would be exposed . Modeling was performed for all constituents of R- 441A ; however, only the results for propane are presented in Table 8 . As the primary component of R- 441A, propane presents the greatest risk of exceeding the STEL and thus is the most conservative assessment. **Table 8**  **. End**  **- Use**  **Exposure Assessment a**  **Scenario Charge Size**  **(g) Effective** 

**Room Size (m**  **3 )**  **Ventilation**

**Rate ( ACH)**  **Vertical**

**Concentration Gradient**  **Height (m) 30**  **- minute** 

**TWA End -**  **Use Exposure**  b ,c **(ppm)** Reasonable Worst - Case 150 15 (530 ft 3 ) 0.5 0.4 **16,000** Typical 150 27.5 (972 ft 3 ) 1.5 None **1,170** Threshold Analysis 1a: Charge Size **65** 15 (530 ft 3 ) 0.5 0.4 6,900 Threshold Analysis 1b: Charge Size **885** 27.5 (972 ft 3 ) 1.5 None Threshold Analysis 2a: Room Size 150 **34.8 (**  **1,142 ft**  **3 )**  0.5 0.4 Threshold Analysis 2b: Room Size 150 **4.7 (**  **153 ft**  **3 )**  1.5 None Threshold Analysis 3a: Ventilation Rate 150 15 (530 ft 3 ) **4.9** 0.4 Threshold Analysis 3b: Ventilation Rate 150 27.5 (972 ft 3 ) **0** None **Bold font** indicates modeling results. a Cells highlighted in green are the scenarios with acceptable exposure levels given various modeling assumption options. b 30 - min A EGL - 1 STEL for propane is 6,900 ppm; See Table 4 for more information . c Values provided in this column refer to the concentration in the lower 0.4 meters of the room , which presents the most conservative risk as 95 percent of the leaked refrigerant in present in this space. In the reasonable worst - case scenario and typical scenario described in Section 5 , catastrophic release of R - 441A from a vending machine with a charge size of 150 grams was modeled. During the release event in the typical scenario, the modeling results indicate the maximum anticipated 30 - min TWA end -use exposure does not exceed 17 percent of the 30 - min AEGL - 1 for propane. Under the reasonable worst - case scenario, the 30 - min AEGL - 1 for propane of 6,900 ppm is likely to be exceeded (see Ta ble 8) . However , the cal culated 30 - min TWA exposure does not exceed the AEGL - 2 (17,000 ppm) for propane or the AEGL - 3 (33,000 ppm). S uch consumer exposure is unlikely, as the reasonable worst - case scenario ( see Section 5) assumes that 95 percent of the ref rigerant is leaked into the lower 0.4 meters of the room, where it is unlikely that persons would be contained. In addition, these modeled exposures were derived using conservative assumptions (e.g., minimum room volume, low ventilation rate [0.5 ACH], max imum charge size) that do not necessarily reflect the typical location for R- 441A vending machine installations (e.g., vending machines will be installed in commercial buildings, which have higher ventilation rates. [A .S. Trust & Holdings, Inc. 2011 ] ) . N onetheless, these potential exposures emphasize the importance associated with proper equipment installation (i.e., matching charge size with room dimensions). A threshold analysis was performed to determine the charge size, minimum room volume and ventilation rates where vending machines containing R - 441A could be installed to avoid the short - term exposure limit for each of the componentsMay 30, 2014 -- Final 13 of R- 441A. Under the reasonable worst - case scenario in Threshold Analysis 1a, the maximum charge size that sho uld be installed in a room of 15 m3 (530 ft 3 ) volume is 65 grams. Under the typical scenario in Threshold Analysis 1b, the maximum charge size that should be installed in a room of 27.5 m3 (972 ft 3 ) volume is 885 grams. If the maximum charge of 150 grams is used in vending machines, EPA recommends that the vending machines should be installed in larger spaces with higher ventilation rates (i.e., assuming the condition s in the reasonable worst - case scenario, vending machines should be i nstalled in rooms that are at least 34.8 m3 ( 1,142 ft 3 ) at a ventilation rate of 0.5 ACH or vending machines installed in a space of 15m3 [530ft 3 ] must have a ventilation rate of at least 4.9 ACH [see Threshold Analysis 2a and 3a] ). Assuming more conservative conditions in the typical scenario in Threshold Analysis 2b and 3b, vending machines should be installe d in rooms that are at least 4.7 m3 (153 ft 3 ) at a ventilation rate of 1.5 ACH while vending machines installed in a large space of 27.5 m3 (972 ft 3 ) do not require ventilation. Because end -use exposure is only a concern under the most conservative scenario, EPA recommends these minimum room and ventilation rate guidelines to ensure that if a catastrophic leak of R- 441A occurs, it is not ant icipated to result in a significant risk to consumers at end -use . To prevent exposure and potential serious side effects during larger releases, EPA proposes to require compliance with UL 541 in any space containing a vending machine , unless proper leak pr otection devises are in place in order to prevent exposures of R- 441A beyond the recommended limits. Additionally, these room volume and ventilation rate requirements simultaneously ensure that there is not a significant flammability or asphyxiation risk, as these requirements are more restrictive than the room size s recommend ed in the flammability and asphyxiation assessment s (see Section s 7 and 8 ). P roper leak protection devi c es and engineering control requirements and adherence to the MSDS will fu rther ensure that exposure limits are maintained below those described in Table 8. 

### 10. **OCCUPATIONAL EXPOSURE ASSESSMENT** This section assesses potential exposures to workers during manufacture, installation, servicing, and disposal of R- 441A. As indicated by the submitter, the manufacture of R- 441A refrigerant (i.e., formulation mixing) and the charging of R- 441A vending machines (i.e., receiving, blending. and filling operations) occurs in a closed system; all units are completely sealed before delivery and installation. As a result, exposure during these manufacturing and installation operations is not anticipated. To ensure that use of the proposed substitute in vending machines does not pose an unacceptable risk to workers during servicing and disposal, occupational exposure modeling was performed using a box model approach . For a detailed description of the methodology used for this screening assessment , the reader is referred the occupational exposure and hazard analysis described in Chapter 5 of the Background Document . Estimates of refrigerant release per event for various release scenarios and data on number of events in 20 10 were obtained from the Vintaging Model. 7 To det ermine the estimated level of occupational exposure for a constituent in a blend, the total anticipated release rate of the refrigerant is multiplied by the weight percent composition of each compound in the blend. For the vending machine end use, 8 the re lease per event was conservatively assumed to be 0.25 percent of the equipment charge during servicing and 3 5 percent of the equipment charge during disposal. 9 Additionally, EPA is proposing to allow intentional venting or release of R- 441A as a refrigerant during installation, servicing, maintenance and disposal from vending machines. If venting does occur, it should be done in a well - 7 ICF International maintain s the Vintaging Model for EPA in order to simulate the aggregate impacts of the ODS phaseout on the use and emissions of various ODS and their substitutes over a period of several years across 60 different end - uses. The model tracks the use and emissions of various compounds for the annual vintages of new equipment that enter service in each end - use. The vintage of each type of equipment determines such factors as leak rate, charge size, number of units in operation, and the initial ODS substance that the equipment contained. 8 For the purposes of this assessment, vending machines were modeled as small retail food refrigeration units . 9 During disposal it is assumed that 100 percent of the refrigerant charge remains in the unit.May 30, 2014 -- Final 14 ventilated area ( e.g., outdoors). Therefore, s cenarios in which 100 percent of the equipment charge was rel eased during servicing and disposal were also considered . The release rate per event was multiplied by the number of events estimated to occur over a workday. For equipment servicing , the number of events per workday was assumed to equal the maximum numbe r of units anticipated to be serviced in one day (eight units [A .S. Trust & Holdings, Inc. 2011]) divided by eight hours per workday. These assumptions result i n approximately 8 events per day. For disposal, i t was conservatively assumed that 10 units ar e disposed during an 8 -hour work day. The modeled exposure concentrations were compared to short - term occupational exposure limits at installation and servicing and long - term exposure limits at disposal. **10 .1**  **Occupational Exposure at Servicing** As indicated by the submitter, when R- 441A vending machines are serviced, the used refrigerant is pumped into a canister, where it is stored until it is recycled (i.e., filtered and reused) (A .S. Trust & Holdings, Inc. 2011) . During the transfer to the initia l canister, incidental refrigerant releases may occur during connection and disconnection of the recharging hose fittings, which should last approximately 30 seconds per unit (A .S. Trust & Holdings, Inc. 2011) . The potential occupational exposure during servicing was analyzed. The maximum 30 - minute time weighted average (TWA) exposure for each R- 441A constituent w as estimated for the servicing exposure scenario and compared to the ir respective short term exposure limits . As summarized in Table 9 , modelin g results indicate that maximum occupational exposure concentrations t o R - 441A at no point exceed 0.01 percent and 2.4 percent of the short - term exposure limits (STEL) with a 150 - gram charge size for both 0.25 percent release and 100 percent release of ref rigerant during servicing , respectively . Because the exposure concentrations modeled under the conservative assumptions is significantly lower than the exposure limits for each constituent, occupational exposure to the proposed substitute during servicing is not considered a significant risk to workers . Further, the estimated exposure s w ere derived using conservative assumptions, and represent a worst - case scenario with a low probability of occurrence. These types of systems are typically serviced by train ed personnel using proper industrial hygiene techniques. **Table 9**  **. Occupational Risk Assessment at Servicing**  **a**

**R -**  **441A Component**  **30 -**  **minute TWA Occupational Exposure (ppm)**  **30 -**  **min Short Term Exposure Limits**  **(ppm) 0.25**  **% Release 100% Release**  Propane 0.41 164 6,900 b n - Butane 0.20 81.7 6,900 b Isobutane 0.03 13.6 6,900 b Ethane 0.03 13.1 3,000 c a Cells highlighted in green are the scenarios that are deemed to be acceptable given various modeling assumption options. b 30 min AEGL - 1 c ACGIH (2004) **10 .**  **2 Occupation**  **al Exposure at Disposal**  Disposal of R- 441A vending machines is expected to occur with limited frequency (up to approximately one disposal event per day) at disposal facilities and with limited duration of exposure to the refrigerant charge. Potential exposures to the refrigerant during recovery and disposal are expected to occur during activities related to draining the refrigerant from the vending machine into cylinders (e.g., connecting of pipes). Such activities and related exposure is anticipated to occur within 15 - 30 minutes (per event/day). Table 10 displays the maximum estimated 8 -hour TWA occupational exposure levels of the components of R- 441A during disposal. Based on the assumptions described in the beginning of S ection 10 , theMay 30, 2014 -- Final 15 modeling indicates that 8 -hour worker exposure concentrations for each of the R- 441A blend components during the 3 5 percent and 100 percent release scenario s will at no point exceed 10 percent and 29 percent , respectively, of the long - term exposure limits for each component during disposal of R- 441A for vending machines with a 150 - gram charge size . Table 10 displays the maximum estimated 8 -hour TWA occupational exposure levels of the components o f R- 441A during disposal. Because each value is significantly lower than the exposure guidelines for each constituent, occupational exposure to the proposed substitute during disposal is not considered a toxicity threat. Further, the estimated exposure s w ere derived using conservative assumptions, and represents a worst - case scenario with a low probability of occurrence. These types of systems are typically disposed of by trained personnel using proper industrial hygiene techniques. **Table 10**  **. Occupation al Risk Assessment**  **at Disposal Component**  **8 -**  **Hour TWA Occupational Exposure (ppm)**  **8 -**  **Hour Long Term Exposure Limits**  **(ppm) 3**  **5 % Release**  **100% Release** Propane 102 291 1,000 a n - Butane 50.6 145 1,000 b Isobutane 8.4 24 1,000 b Ethane 8.2 23 1,000 b Cells highlighted in green are the scenarios that are deemed to be acceptable given various modeling assumption options. a OSHA PEL b ACGIH TLV Although anticipated occupational exposures are well below the exposure limits for each of the components of R- 441A, the recommendations for proper engineering controls and PPE in the MSDS for R - 441A should be followed. Adequate ventilation should always b e established during any use, handling, or storage of R- 441A. Engineering controls should include vapor - in air detection systems and local exhaust ventilation during use of R- 441A to prevent dispersion of R- 441A throughout the work place. In addition, an e ye wash and safety shower should be near the manufacturing facility and locations where R441A is stored and ready for use. In general, use of OSHA Category B or higher PPE is recommended, such as splash goggles, mechanically -resistance gloves when handlin g cylinders and chemically -resistant gloves when handling the gas mixture (e.g., butyl rubber, chlorinated polyethylene, or neoprene). A selfcontained breathing apparatuses and fire retardant protective clothing should be worn in case of an accidental rel ease (A.S. Trust & Holdings, Inc. 2011). EPA believes that if proper handling and disposal guidelines are followed in accordance with good industrial hygiene and manufacturing practices and the MSDS for R- 441A , there is no significant risk t o workers durin g the manufacturing, installation, servicing, and disposal of R- 441A in vending machines . 

### 11 **. GENERAL POPULATION EXPOSURE**  **ASSESSMENT** R - 441A is not expected to cause a concern for human health in the general population when manufactured for use and used as a refrigerant in vending machines . The proposed substitute will be manufactured in a closed process and is proposed for use in closed systems, and thus, significant releases are not anticipated. At room temperature, R- 441A is a gas and, therefore, releases to ground or surface water are not anticipated, as R- 441A is anticipated to dissipate into the atmosphere upon release to outside air (i.e., because natural ventilation rates would be higher and there is no enclosed space to keep R - 441A concentrated). Should air releases during manufacturing operations occur, engineering controls should be used (e.g. carbon absorption scrubbers) to collect R- 441A and prevent the release of R- 441A to the atmosphere. EPA believes that by using proper engineering con trols and by following disposal andMay 30, 2014 -- Final 16 containment recommendations outlined in the proposed substitute’s MSDS, exposure to R- 441A is not expected to pose a significant toxicity risk to the general population.May 30, 2014 -- Final 17 

### 12 **. REFERENCES**  ACGIH. 2012. Guide to Occupatio nal Exposure Values. American Conference of Governmental Industrial Hygienists. ANSI/ASHRAE . 2010a. Standard 15: Safety Standard for Refrigeration Systems . American Society of Heating, Refrigerating and Air - Conditioning Engineers, Inc. ANSI/ASHRAE . 2010b. Standard 34: Designation and Safety Classification of Refrigerants . American Society of Heating, Refrigerating and Air - Conditioning Engineers, Inc. ANSI/ASHRAE. 2013 a . Standard 62: Ventilation for Acceptable Indoor Air Quality. American Society o f Heating, Refrigerating and Air - Conditioning Engineers, Inc. A.S. Trust & Holdings, Inc. 2011 . R- 441A in Vending Machines. Significant New Alternatives Policy Program Submission to the United States Environmental Protection Agency . September 2011 . Braker W, Mossman AL. 1980. Matheson gas data book. 6th ed. Secaucus, NJ: Matheson Gas Products, pp. 615 623. Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. S chulz and R. Van Dorland. 2007. Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate Change 2007:The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Cha nge [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. ICF. 1997. Physiological Effects of Alternative Fire Protection Agents - Hypoxic Atmospheres Conference. Stephanie Skaggs prepared the proceedings of the conference held May 22, 1997 in New London, CT. IPCC/TEAP. 2005. Bert Metz, Lambert Kuijpers, Susan Solomon, Stephen O. Andersen, Ogunlade Davidson, José Pons, David de Jager , Tahl Kestin, Martin Manning, and Leo Meyer (Eds). Safeguarding the Ozone Layer and the Global Climate System. Intergovernmental Panel on climate Change Technology and Economic Assessment Panel. Cambridge University Press, UK. pp 478. Kataoka, O., M. Yo shizawa, & T. Hirakawa 2000. “Allowable Charge Limit of Flammable Refrigerants and Ventilation Requirements.” Daikin Industries. International Refrigeration and Air Conditioning Conference. Paper 506. Available online at: http://docs.lib.purdue.edu/iracc/506 . Mackenzie, F.T. and J.A. Mackenzie. 1995. Our changing planet. Prentice - Hall. NFPA. 20 14 . NFPA Liquified Petroleum Gas Code. 20 14 Edition. OSHA. 2004. “Safety and Health Topics: Isobutane.” February 2004. Available online at: http://www.osha.gov/dts/chemicalsampling/data/CH_247840.html . UL. 2011. UL 541 : Standard for Refrigerated Vending Machines . Underwriters Laboratory. U.S. Department of Energy (DOE). 2008. DOE Handbook

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.May 30, 2014 -- Final 18 U.S. EPA . 1994. Significant New Alternatives Policy Technical Background Document: Risk Screen on the Use of S ubstitutes for Class I Ozone - depleting Substances: Refrigeration and Air Conditioning. Stratospheric Protection Division. March, 1994. U.S. EPA. 1997. Exposure Factors Handbook. National Center for Environmental Assessment, Office of Research and Development. Available online at: http://www.epa.gov/ncea/pdfs/efh/front.pdf 

### . U.S. EPA. 2012. Acute Exposure Guidelines (AEGLs) Definitions. Available online at: http://www.epa.gov/oppt/aegl/pub s/define.htm . U.S. EPA. 2014. Draft Assessment of the Potential Impact of Hydrocarbon Refrigerants on Ground Level Ozone Concentrations. Prepared for the U.S. EPA Stratospheric Protection Division by ICF International. February 24, 2014. Vending Solution s. 2009. “Soda Machines.” Available online at: http://www.vendingsolutions.com/vending - machines/ . WMO (World Meteorological Organization). 2011. Scientific Assessment of Ozone Depletion: 2010 , Global Ozone Research and Monitoring Project

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