Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

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United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE 

ONLYOMB Control No.: 

2060-0226 

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER 

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA 

U.S. EPA 1310 L STREET NW 

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J) 

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Date of Receipt:

Date 90 Day Review Begins: 

Date Review Completed: 

CBI Status: 

Enter the total number of pages in your SNAP information Notice: Document Control Number

INTRODUCTION

GENERAL INSTRUCTIONS 

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of 

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are 

required to provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or 

processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting. 

All submissions must be provided in three complete copies. If information is to be claimed as confidential, all confidential 

information must be excised from one of the copies, which will be placed in the public docket; the other two copies must include 

the confidential material. If no claims of confidentiality are made for the submission, all copies must be identical. 

The attached “Guidance Manual for the SNAP Information Notice” is designed to assist applicants in completing this form. The 

manual provides instructions on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sectorspecific data requirements, and submitting test data and supplemental information. 

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box) 

Select the appropriate box identifying the type of notice submitted: 

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________

Petition: New alternative, Substance, or Formulation_________________________________________________________X

Petition: Revision of the Existing SNAP list__________________________________________________________________

 Petition: Request to Grandfather Use of An Unacceptable Substitute________________________________________ _____
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

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You must provide the identity of the alternative chemical of 

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim the 

identity as confidential. You may authorize another person 

to submit the identity for you, but your submission will not be 

complete and review cannot begin until EPA receives this 

information. 

Part II - ALTERNATIVE-SPECIFIC INFORMATION

 

Please indicate the sector(s) for which you are submitting 

information on the substitute by checking the appropriate 

boxes: 

• Refrigeration and Air Conditioning x 

• Foam Blowing 

• Solvent Cleaning  

• Fire Extinguishing 

 and Explosion Prevention 

• Sterilization 

• Aerosols 

• Adhesives, Coatings, and Inks 

• Tobacco Expansion 

• Pesticides 

You may need additional copies of Part II if there are several 

manufacturing, processing, or use operations that you will 

describe in this notice. Please reproduce these sections as 

needed. 

If you substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number: 

 ____Not Applicable_________ 

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary. 

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information that you include in this notice. 

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or 

control and to provide a description of all other data known to you if 

these data are related to the health and environmental effects of 

the manufacture, processing, distribution in commerce, use, or 

disposal of the alternative. Standard literature citations may be 

submitted if they do not appear in the open scientific literature. 

Complete test data (in English), not summaries of data, must be 

submitted if they do not appear in the open literature. The following 

are test data and other data that might be submitted (see the 

Guidance Manual for a more complete list of data to be submitted.) 

Please indicate test data to be included in your submission notice 

by checking the appropriate boxes: 

• Health Effects Data Yes x No 

• Flammability Data x Yes No 

• Environmental Effects 

 Data Yes x No 

• Environmental Fate 

 Data Yes x No 

• Risk Assessments x Yes  No 

• Test Data Not in the Possession/ 

 Control of the Submitter Yes x No 

• Other Data x Yes No 

You must provide the identity of the alternative chemical of 

processes and the identity and percentages of all components in a 

blend and/or process, even if you claim the identity as confidential. 

You may authorize another person to submit the identity for you, 

but your submission will not be complete and review cannot begin 

until EPA receives this information. 

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice. 

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with our submission. For additional information 

on claiming information as confidential, please see the Instructions Manual. 

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and 

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. 

These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within EPA 

Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or activity 

that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that these

companies can complete the work required by the contract. 

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business 

information as implemented by 40 CFR 2.301(h).
Form 1265-07 (Revised 06/2008) 

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Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION 

1. (a) Person Submitting Notice (in U.S.)

_____________________________________________________Kosei Uematsu_________ _____President_________________________ 

Name of Authorized Official Title 

_______Daikin U.S. Corporation ____________________________________________________________________________________ 

Company/Organization 

_______.475 Fifth Ave., 18th FL. New York, NY 10017 ________________________________212-340-7400; 212-779-5925___________ 

Mailing Address Telephone & Fax Numbers 

(b) Agent (if applicable) 

______Mark Stanga____________________________________________________________Consultant___________________________ 

Name of Authorized Official Title 

_____Competition Advocates, LLC___________________________________________________________________________________ 

Company/Organization 

____3188 Key Blvd, Arlington, VA 22201________________________________________202-669-2002; 703-243-5038_____________ 

Mailing Address Telephone & Fax Numbers 

(c) Joint Submitter (if applicable)

___[Not Applicable]___________________________________________________________________________________________ 

Name of Authorized Official Title 

____________________________________________________________________________________________________________ 

Company/Organization 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

2. Technical Contact (in U.S.) 

______Tao Jia________________________________________________________Engineering Manager______________________ 

Name of Authorized Official Title 

_____Daikin U.S. Corporation__________________________________________________________________________________ 

Company/Organization 

_______.475 Fifth Ave., 18th FL. New York, NY 10017 ________________________________262-227-2356; 212-779-5925_____ 

Mailing Address Telephone & Fax Numbers 

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phone, 

etc.) and the EPA staff person’s name: 

June 1, 2010 meeting to discuss SNAP submittal requirements with the following persons at EPA: 

• Margaret Sheppard (Team Leader, Environment Specialist, SNAP program) 

• Monica Shimamura (Environment Specialist, Office of Atmospheric programs) 

• Dave Godwin (Environment Scientist) 

• Melissa Fiffer (Environment Scientist) 

March 3, 2011 meeting to discuss SNAP submittal requirements with the following persons at EPA: 

• Margaret Sheppard (Team Leader, Environment Specialist, SNAP program) 

• Dave Godwin (Environment Scientist) 

• ______________________________ 

Mark (X) if None _______________ 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008) 

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: 

Genetron® 32 / KLEA® 32 / HFC-32 / Zyron 32

2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process name). For blends, provide the percent composition of each 

constituents. 

 (b) Chemical Abstracts Service (CAS) registry number and molecular formula. 

 (c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information 

on any chemical constituents. 

 (d) If you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attachment. If you 

have submitted a patent application but have not been granted one yet, indicate the date submitted and the expected time frame for a response. 

(a) Difluoromethane 

(b) CAS # 75-10-5 [CH2F2] 

(c) R32 use as a refrigerant in household and light commercial air conditioning, and in residential air conditioning 

and heat pumps (new equipment only). 

- R32 has one-third of the GWP of R410A.

- R32 performs with a reduced charge volume, 70% compared to R22, resulting in one-fifth of the direct global 

 warming impact compared to a R410A system. 

-Development and design parameters for using R32 are similar to those of R410A, with the same operating 

pressure as that of R410A, and almost all same parts as are used for R410A. 

-Small system changes will be required for the optimized use of R32, e.g. parameters of refrigerant control and 

lubricant. 

-Limitation of refrigerant charge for large units will be required according to the standards and regulations for 

flammability class of A2L at less than 10cm/sec burning velocity defined in ASHRAE34. 

-Production and manufacturing information. 

Manufacturing process is almost same as current process for R410A. 

-Additional safety measurements for manufacturing process and warehouse, and warnings for transportation and 

servicing will be required, but cost up is small. 

-Energy efficiency of the product in comparison to others. 

R32 shows 2-3% better than R22 or R410A, and better than HFO1234yf in LCCP. 

(d) None

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information). 

Difluoromethane (R32)

4. Specific End-Use 

 (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g. terpene-based 

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A 

to the instructions, beginning on p. 19. 

 (b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ratio). 

(a) R32 is a primary substitute refrigerant in residential air conditioning and heat pumps.

(b) R32 is a substitute for R410A and/or R134A (which were substitutes for CFCs and HCFCs). The replacement 

ratio for R32 from R410a is 66% (i.e., R32 can achieve the same cooling effect as R410a, but with 66% of the 

charge that would be required for R410a). 

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1 Part I - GENERAL INFORMATION (continued) 

I Section B - ALTERNATIVE IDENTIFICATION (Continued) I 

5. (a) Identify each impurity that may reasonably be anticipated to be. present in the chemical alternative as manufactured for commercial 

purposes. If there are unidentified impurities, enter "unidentified." 

(b) Provide the CAS Registry Number if available. 

(c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight 

percentages. 

6. Byproducts: 

(a) Describe any byproducts of degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts1 degradation products enter "unidentified." 

(b) Provide the CAS Registry Number if available. 

(c) Indicate where the byproductldegradation product is formed (e.g. during manufacturing, during use, etc.) and the amount or rate at which 

it is formed. 

CAS No. - 

Mark (X) this box if this page contains CBI X 

/ 

Form 126507 (Revised 0612008) 

Previous editions are obsolete 

Byproduct CAS No. Point of Occurrence 
Form 1265-07 (Revised 06/2008) 

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Part II - ALTERNATIVE-SPECIFIC INFORMATION 

Section A - PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight 52.03 g/mole 2. Physical state at 20Ε C Gaseous

3. Melting point -136°C (-212.8°F) 4. Boiling point at 1 atm. Pressure –51.7 °C

5. Specific gravity 0.96 g/ml 6. Odor threshold (Unknown) mg/m3

7. Solubility using solvent @ temperature ΕC g/L

8. Solubility in water @ temperature 0.44 mass% @ 25°C 

9. Partition coefficient Log Kow 0.21 Log K%

10. Vapor pressure @ 20Ε C 213.87 psi 11. Critical temperature 

78.1° C

12. Critical Pressure 

838.32 psi

13. Are spectra attached? No 14. Disassociation constant (Unknown)

15. Particle size distribution (Unknown) 16. Volatilization from soil (Unknown)

17. Volatilization from water (Unknown) 18. Viscosity @ 20 °C 120.33 mPa• s

19. pH@concentration (Unknown) 20. Thermal conductivity 129.7 mW/m• k

21. Adsorption coefficient N/A 22. Flammability limits (LFL, UFL) 13.8-29.9 % vol

23. Flash point (Unknown) 24. Heat of combustion 486 kJ/mol

25. Maximum pressure rise (Unknown) 26. Maximum rate of pressure rise (Unknown)

27. Other (specify)

28. Provide any information on flammability concerns. For example, if any abatement techniques are being used to minimize the risks 

associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an assessment of overall risk 

in each end-use may be required. (See Instructions for sector-specific data requirements for flammable substances). 

ASHRAE recently reclassified R32 under ASHRAE Standard 34 as an A2L low flammability refrigerant. No standard on the 

use of flammable refrigerants is published in the U.S. 

Only the International Standard for Air-Conditioning of IEC60335-2-40-2005 to use flammable refrigerants is now published. 

For VRV systems, JSO5149-2010 is now drafting a standard to use flammable refrigerants for VRV systems, and 

ASHRAE15 revisions are currently under development that are likely to incorporate some aspects of ISO5149. 

DOE funded a risk assessment by Arthur D. Little (ADL) for the use R32 in some residential air conditioning applications in 

1996. The 1996 ADL risk assessment used data that was gathered before publication of IEC60335-2-40, and which can be 

updated by using the latest information and data on the evaluation of very low burning velocity gases. 

Mark (X) this box if this page contains CBI __________
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1. Ozone-depletion potential (ODP): 

 (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of individual 

constituents 

. 

 (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading 

potentials). Reference the source of this information and attach any supporting documentation. 

(a) R32 has no ODP. 

(b) The hydrofluorocarbons (HFCs), including R32, are a class of replacements for CFCs. Because they do not 

contain chlorine or bromine, HFCs do not deplete the ozone layer. All HFCs have an ozone depletion potential of 

0. 

Source: http://www.epa.gov/ozone/defns.html

2. Global Warming Characteristics: 

 (a) Provide the alternative’s global warming potential (GWP) relative to carbon dioxide over 100- and 500-year time horizons, if known. If 

the substitute is a blend, provide the GWPs of the individual constituents.

 (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/- X%) and results 

of any testing or modeling done (both theoretical and actual testing). 

 (c) Provide source of GWP or any additional data on the GWP of the alternative, including the atmospheric lifetime, infrared absorption 

spectrum, and infrared absorption capacity. If the alternative (e.g. CO2 captured from a stream of waste gas as a by-product of fermentation). 

(a) GWP=675 (IPCC 4th Assessment Report). 

(b) The COP ratio of R32 to R410A under the rated cooling condition in Japan was 110% by experimental data, 

according to JISB8615. 

 (Reported in Proceedings of 2000 Purdue International Refrigeration Conference) 

(c) Atmospheric lifetime of R32 is 4.9 years (IPCC 2007 4th Assessment Report).

 

Mark (X) this box if this page contains CBI __________ 

Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section C - OTHER STATUTES AND STANDARDS 

1. Describe whether and how the alternative is regulated under other environmental regulatory statutes, for example other titles under the 

Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act 

(RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Comprehensive 

Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), and state and local laws. List any concentration-based or other numerical standards to which the 

alternative is subject under the above standards and regulations. 

The alternative R-32 is regulated under the Section 612 of the Clean Air Act and 40 C.F.R. Part 82, Subpart G 

(SNAP approval is required for end use as a substitute for CFCs or HCFCs). There are no concentration-based 

or other numerical standards for R-32 under the above-referenced standards and regulations.

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as those implemented by 

the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), the Department of Transportation 

(DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the 

above statutes and regulations. Also list any other standard-setting organizations such as the National Fire Prevention Association (NFPA) 

or the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), by which the substitute is evaluated. 

Daikin is submitting this petition only for the following applications: 

-Household and Light Commercial Air Conditioning (New Uses Only) 

-Residential Air Conditioning and Heat Pumps (New Uses Only) 

OSHA has not published a permissible exposure limit for R-32. ASHRAE 34 has established an Occupational 

Exposure Limit (OEL) of 1000ppm, which is the same OEL that of R410A. 

The DOT has classified R-32 as follows under the Hazardous Materials Transportation Standards: Hazard Class: 

2.1; Label: Flammable Gas 

The NFPA has classified R-32 as follows: HMIS Classification, Health; 1, Flammability; 4, Reactivity; 1 

ASHRAE 34_2010 has classified R-32 as an A2L low flammability refrigerant, the same category as R-1234yf. 

Mark (X) this box if this page contains CBI __________
Part I1 - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE 

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated 

with the alternative. 

2. Provide information on production of the substitute. Include estimates on: 

(a) Year substitute will be available if not currently produced. 

(b) Total pounds production per year (current figure). 

(c) Years to maximum market penetration. 

(d) Maximum total production per year at market saturation. 

(e) Estimated percentage of market at market saturation. 

NIA for all questions. 

- --- - - 

3. Describe any new equipment and use profiles. If retrofitting of existing equipment is required, detail changes in technologies needed to use 

he alternative and address any materials compatibility issues. Provide information on each end-use and capital costs associated with the 

iubstitute or alternative process. Include cost of equipment andlor any new materials, equipment lifetime, changes in labor and energy costs. 

Daikin does not anticipate that there will be retrofitting of any equipment with R-32. 

I 

Mark (X) this box if this page contains CBI X 

Form 1265-07 (Revised 0612008) 

Previous editions are obsolete 
Form 1265-07 (Revised 0612008) 

Previous editions are obsolete 

Part III - RELEASE AND EXPOSURE DATA 

Section A - TOXICITY AND HAZARD INFORMATION 

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attached supporting information) the acute 

and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, and 

plants), if available. Include any data on impurities and degradation products if known. Also include information on any "Allowable 

Exposure Limits" (AELs) that have been set for the substitute for use in the workplace. In addition, please attach a copy or facsimile of any 

hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonably likely 

to be exposed. (See Guidance Manual for sector-specific data requirements). 

Mark (X) this box if this page contains CBI X 

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Exposure Limit 

LC50: >760000ppm 

ATEL: 200000ppm (80% Anesthesia NOEL) 

OEL: 1000ppm (ASHRAE34) 

LC50:>220000ppm 

ATEL: 59000ppm (100% Cardiac NOEL) 

OEL: 1000ppm (ASHRAE34) 

N/A 

OSHA PEL TWA: 100ppm (ACGIH) 

OSHA PEL:5ppm ceiling 

TWA:3ppm,STEL:6ppm, 

IDLH:30ppm, AEGL2:98ppm for lOsec 

OEL:5000ppm (ASHRAE34) 

Substances 

Alternative 

Impurity 

Byproduct 

The OEL value is defined by ASHRAE 34. 

A very small portion of the refrigerant charge into products is released at the manufacturing process in case of 

R410A, and R32 will be same as the case of R410A. 

Hydrogen fluoride will be generated in the atmosphere in the long term after R32 is released, and aRer R32 is 

burned. 

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE 

For each manufacturing site: 

(a) Identify all site locations (i.e. name and address) for each chemical manufacturing process. 

(b) Identifi all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitutes). 

(c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing the substitutes. 

(d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e.g. indoor air, 

outdoor air, water, land). 

1 

1 

2 

3 

1 

2 

3 

Name of chemical 

Difluoromethane (HFC-32) 

Difluorochloromethane (HCFC-22) 

Fluorochloromethane (HCFC-3 1) 

Chloromethane (HCC-40) 

Hydrogen chloride (HCI) 

Hydrogen fluoride (HF) 

Carbon dioxide (C02) 
Form 1265-07 (Revised 06/2008) 

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Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products containing substitutes): 

 (a) Describe the activities in which workers may be exposed to chemicals. 

 (b) Describe any protective equipment and engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). 

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). 

 (d) Estimate average and maximum numbers of workers involved in each activity. 

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hour/day and (2) days/year. 

 (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). 

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure. 

a. Charging process and Inspection process. 

b. Workers use goggles, gloves and chemical hoods to avoid physical contact with the refrigerant and to achieve 

emission control. 

c. Gas 

d. N/A 

e. N/A 

f. Inhalation 

g. Minimal 

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE
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For each end-use of a substitute: 

 (a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous waste or 

 (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point.

 (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control technology in 

place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal.

 (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. 

 (e) Identify the appropriate number of sites expected to use the substitute. 

 (f) Provide information on recycling of the substitute. Describe any associated costs and equipment. 

 Recovery unit will be developed by Japanese manufacture.( Asada will cooperate to develop this unit.) 

For items of d, e, f DIL has no idea, except manufacturing site in Japan. 

(a) Daikin has no data on releases to the environment. 

(b) Outdoor air. 

(c) Daikin is unaware of any control technology presently available to limit releases to the environment. 

(d) Releases of R32 (difluoromethane, CAS No. 75-71-8) would be covered under RCRA (see 40 C.F.R. § 

261.33, hazardous waste code U075). 

(e) Uncertain 

(f) Recovery technology is expected to be developed by Japanese companies. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008) 

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Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes): 

 (a) Describe the activities in which workers may be exposed to chemicals.

 (b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

 (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units. 

(a) Installation, service, and maintenance 

(b) Gloves, safety glasses 

(c) Gas 

(d) N/A 

(e) N/A 

(f) Inhalation 

(g) Minimal 

Section F - CONSUMER EXPOSURE

For each end-use of a substitute: 

 (a) Identify the potentially exposed population (e.g. indoor residents). 

 (b) Identify the exposure medium (e.g. air).

 (c) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

 (d) Enter the exposure point of concentration. Provide (1) average and (2) high-end estimates. 

(a) Indoor residents and office building occupants 

(b) Air 

(c) Inhalation 

(d) In the room where the R-32 is being used in the system; (1) unknown (2) below OEL

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

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Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes: 

 (a) Identify and number potential exposure points. 

 (b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline). 

 (c) Identify the contact pathway (e.g. ingestion, inhalation, dermal). 

 (d) Identify the exposure medium (e.g. air, water). 

 (e) Enter the exposure point concentration (mg/m3

). Provide (1) average and (2) high-end estimates. 

No general population exposure is anticipated. 

Mark (X) this box if this page contains CBI __________
Part IV - LIST OF ATTACHMENTS 

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA's review of the alternative under Section 612 of the Clean Air Act. Also, provide citation for information already submitted to EPA as 

oart of vast regulatory and information activities. as well as for other information that could not be included with this submission. If vou have I &ached continuation pages, describe the Part, on and question number being continued. Attach additional pages if necessary. - I I I I Attachment Name Question # 

I I I Daikin Chemical Division, Material Sqfety Data Sheet (MSDS for Part 111, Section A 

R32), March 15,201 1 I 5 

R. Yajima et al., 2000, "R32 as a Solution for Energy Conservation 

and Low Emissions," Eighth Purdue International . . Refi.i&ration .. 

Conference 

Part 11, Section, B, 

2.b. 

H Horie et al., "Study on cycle property and LCCP evaluation of 

heat pump using HFO-1234yf, HFC-32, and HFC-4l0a as 

refrigerant", 2010 International Symposium on Next-generation Air 

Conditioning and Refi-igeration Technology, 17 - 19 February 

20 10, Tokyo, Japan 

Part 11, Section B, 

2.b. 

W. Goetzler et al., 1998, "Risk Assessment of HFC-32 and HFC321134a (30170 wt. %) in Split System Residential Heat Pumps," 

DOEICE123 8 10-92 Final Report (ART1 MCLR Project Number 

665-52402) 

Mark (X) this box if this page contains CBI X 

Part 11, Section A, 

24. 

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J. Calm, 2000, "Toxicity Data to Determine Refkigerant 

Concentration Limits," DOEICE1238 10- 1 1 0 

Form 126507 (Revised 0612008) 

Previous editions are obsolete 

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Part III, Section A 

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11 No