UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D
.C
. 20460 

## JUN 0 

## 3 2014
OFFI C E O F AIR AND RADIATI O N 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 ofthe device. Please also provide quantified measurements ofthe amount ofleakage that is avoided with the use ofthe safety valve with a variety of system and charge sizes, both in

Internet Addres s ( URL ) • http //wwwepa
.gov Recycled /Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer
. Process Chlorine Free Recycled Papergrams and in percentage ofthe total refrigerant charge
. Please also provide information on the reliability and failure rates ofthe safety valve. 3. Refrigerant recovery equipment. Please provide further information on your plans for recovery ofrefrigerant 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 ofusing 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 ofall kinds ofrefrigerants 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 ofresidential 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 ofthis SNAP submission. 6. CBI Claims. Ifyou 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 ofinformation 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 submissionand 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. Ifyou 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