UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUN 0 3 2014 

OFFICE OF 

AIR AND RADIATION 

Mr. Richard H. Maruya 

A.S. Trust & Holdings 

44-129 Mikiola Drive 

Kaneohe, Hawaii 96744 

Re: Incomplete SNAP Submission for R-443A (HCR-188C2) for Residential Air 

Conditioning 

Dear Mr. Maruya: 

Thank you for A.S. Trust & Holdings' letter to the Environmental Protection Agency (EPA) 

received on May 7, 2014. The Agency has reviewed the information in the letter and determined 

that the Significant New Alternatives Policy (SNAP) program submission for R-443A in 

residential air conditioning (AC) remains incomplete. The following information is necessary in 

order to allow the Agency to move forward with the A.S. Trust & Holdings, Inc.'s SNAP 

submissions for R-443A in residential air conditioning. 

1. Charge Size. Thank you for providing information regarding the minimum and maximum 

charge sizes for the intended applications for R-443A. The additional information provided 

also noted that the previous risk assessment (Whitmyre Research 2013) assessed typical 

charge sizes of 1,080 grams for split-system heat pumps, 1,560 grams for split-system AC 

units, and 240 grams for a portable room AC unit. Please clarify that these charge sizes are 

still the intended typical charge sizes for these applications and please also include the 

corresponding typical capacity and room size for these charge sizes (see Table below). If 

the typical charge sizes have changed, please provide the updated charge sizes, capacity, 

and room size for each application. 

R-443A Application Typical Typical Typical 

Charge Size Capacity Room Size 

(g) (kW) (ft2) 

Split-System Heat 1,560 g 

Pump 

Split-System AC 1,080 g 

Portable AC 340 g 3.4kW 

2. Safety Valve. Thank you for providing a schematic diagram and description of the 

device. Please also provide quantified measurements of the amount of leakage that is 

avoided with the use of the safety valve with a variety of system and charge sizes, both in 

Internet Address (URL) • http //wwwepa .gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
grams and in percentage of the total refrigerant charge. Please also provide information 

on the reliability and failure rates of the safety valve. 

3. Refrigerant recovery equipment. Please provide further information on your plans for 

recovery of refrigerant during the lifetime ofthe equipment and at disposal including 

applicable refrigerant recovery equipment standards. This may include either: a) studies, 

reports or analyses from ETL, UL, ARI or equivalent on the feasibility of using existing 

refrigerant recovery/recycling equipment; or b) information and testing results from ETL, 

UL, or equivalent on equipment for refrigerant recovery/recycling designed for use with 

flammable refrigerants. 

4. Training. On page 21 on the additional information submitted to the EPA, you state that 

"Trained workers, who must be certified in the handling ofR-443A, will have experience 

in proper recovery of all kinds of refrigerants during servicing and will be familiar with 

handling flammable gases." Please provide additional information on technician training, 

including any materials that will be used to train technicians handling R-443A. How will 

the training specifically address servicing of residential AC equipment containing a 

flammable refrigerant? Also, please indicate how you intend to limit servicing ofR-443A 

equipment to technicians who have received training specific to this refrigerant and to 

flammable refrigerants. 

5. MSDS. Please provide an updated MSDS that incorporates the exposure limits, for the 

blend and for each component, identified in the risk assessment you conducted in support 

of this SNAP submission. 

6. CBI Claims. If you wish to claim any of the 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: R-443A (HCR-188C2) 

Substance(s) the substitute will replace: HCFC-22 

Sector: Refrigeration and Air Conditioning 

End-uses: Residential and light commercial air conditioning and heat pumps 

Applications: Residential split-system A/C units, residential heat pumps, and portable (floor 

model) room A/C 

New or retrofit usage: New 

Date received: February 13, 2013 

Most recent update received: March 7, 2014 

Status of submission: Incomplete 

Responses to these questions would be helpful for our review. The Agency is also currently 

reviewing A.S. Trust & Holding's addendum to this submission for the use ofR-443A in 

window air conditioners. Additional information on the uses ofR-443A in both this submission 
and the addendum, may be requested during the combined review of all end uses submitted to 

SNAP for R-443A. 

The information can be submitted via electronic mail or hard copy. If you have questions about 

your submission, please contact our SNAP Coordinator, Rebecca von dem Hagen at (202) 343-

9445 or vondemhagen.rebecca@epa.gov. 

Sincerely, 

C. Cindy Newberg 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division