Form 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 1 United States 

### ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 AGENCY USE ONLY OMB 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 10 th 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 informat ion 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 a ssessing the acceptability of chemicals or processes that are considered alternatives for ODSs. A separate notice must be fil ed for each alternative you are submitting.

All submissions must be provided in three co mplete 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 includ e the confidential material. If no claims of confidentiality are made for the subm ission, all copies must be identical.

The attached “Guidance Manual for the SNAP In formation Notice” is designed to assist applicants in completing this form. The manual provides instructions on submitting a SNAP notice, asserting confidentialit y 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 complete ly as possible. Please provide all inform ation requested to the extent that it is known or reasonably ascertai nable. 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 alter native, 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 

### 2 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. Pleas e reproduce these sections as needed.

If you substitute is also s ubject 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 questi on. 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, dist ribution 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 clai m 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 tre ated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at th is time. All information cla imed as CBI will be treated in a manner consistent with 40 CFR Part 2, S ubpart B. Failure to assert a claim of confidentiality at the time of submission may result in disclosure of inform ation by the Agency without further notice.

To assert a claim on this form, circle or bracket the informat ion you claim as confidential and mark the confidential box at th e bottom of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confi dential, you must provide a “sanitized” version of this notice, including attachments, to EPA with our submission. For additional infor mation on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be acce ssed 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 fo r the protection of stratospheric ozone, including the development of the SNAP program

. These Authorized Representatives may have access to any informat ion received by the Stratospheric Protection Division within EP A Office of the Atmospheric Programs for use in reviewing the need for possible control of any subs tance, practice, process or ac tivity that may reasonably be anticipated to affect st ratospheric ozone. Access to such inform ation is necessary to ensure that these companies can complete the wo rk required by the contract.

Authorized Representatives of the Administ rator are subject to the pr ovisions of 42 U.S.C. 7414(c) respecting confidential busi ness information as implemented by 40 CFR 2.301(h).Form 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 3 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., 18 th 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 ________________________________________________________Engineeri ng Manager

______________________ Name of Authorized Official Title

_____Daikin U.S. Corporation

__________________________________________________________________________________ Company/Organization

_______.475 Fifth Ave., 18 th 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, phon e, etc.) and the EPA staff person’s name: June 1, 2010 meeting to discuss SNAP submittal re quirements with the following persons at EPA:

• Margaret Sheppard (Team Leader, E nvironment 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 re quirements with the following persons at EPA:

• Margaret Sheppard (Team Leader, E nvironment 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) Previous editions are obsolete 

### 4 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 tec hnologies describe the technology and provide a diagram of the system. Also provide t he 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 attac hment. 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 [CH 2 

### F 2 

### ] (c) R32 use as a refrigerant in house hold and light commercial ai r conditioning, and in re sidential 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 st andards 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 proce ss and warehouse, and warni ngs 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 subs titute is declared Confiden tial Business Information).



### Difluoromethane (R32)

4. Specific End-Use (a) Describe each end-use that may be reasonably anticipated for the a lternative. Be sure to provide a broad description ( e.g. terpene-based semi-aqueous solvent cleaner for electronic parts, or HFC subs titute 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 th e quantity of substitute (if a pplicable) needed to replace it for each end use in pounds (replace ment ratio).


### (a) R32 is a primary substitute refrigerant in residen tial air conditioning and heat pumps.

(b) R32 is a substitute for R410A and/ or R134A (which were substitutes fo r CFCs and HCFCs). The replacement ratio for R32 from R410a is 66% (i.e., R32 can achieve th e 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 

## OccurrenceForm 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 6 Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight 

### 52.03 g/mole 2. Physical state at 20 Ε 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 Ε C g/L
8. Solubility in water @ temperature 0.44 mass% @ 25°C

9. Partition coefficient Log K ow 

### 0.21 Log K %
10. Vapor pressure @ 20 Ε 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 us ed to minimize the risks associated with flammable substances or mi xtures, detail those techniques below. If a substitute is flammable, an assessment o f overall risk in each end-use may be required. (See Instructions for sect or-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 refrigerant s 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 in corporate 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 dat a that was gathered befor e publication of IEC60335- 2-40, and which can be updated by using the latest informa tion and data on the evaluation of ve ry low burning velocity gases.

Mark (X) this box if this page contains CBI __________Form 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 7

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 O DPs of individual constituents

. (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmos pheric lifetime, chlorine or bro mine loading potentials). Reference the source of this info rmation and attach any supporting documentation.



### (a) R32 has no ODP. (b) The hydrofluorocarbons (HFCs), in cluding R32, are a class of replacemen ts 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 horizon s, if known. If the substitute is a blend, provide th e 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 GW P of the alternative, including th e atmospheric lifetime, infrare d absorption spectrum, and infrared absorption cap acity. If the alternative (e.g. CO 2 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 coo ling condition in Japan was 110% by experimental data, according to JISB8615. (Reported in Proceedings of 2000 Purdue International Re frigeration Conference) (c) Atmospheric lifetime of R32 is 4.9 years (IPCC 2007 4 th 

### Assessment Report).

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

##  Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATIONForm 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 8

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether and how the alternative is regulated unde r other environmental regulatory statutes, for example other titl es under the Clean Air Act (CAA), the Clean Water Act (C WA), the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act (RCA), the Federal Insecticide, Fungicide and Rodenticide Act (F IFRA), the Toxic Substances Control Act (TSCA), the Comprehensi ve Environmental Response, Compen sation and Liability Act (CERCLA), the Emergenc y 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 th e above-referenced sta ndards and regulations.

2. Describe whether and how the alternative is regulated under health and safety related statut ory authorities, such as those implemented by the Food and Drug Administration (FDA), the O ccupational Safety and Health Administrati on (OSHA), the Department of Transportat ion (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-s etting organizations such as th e National Fire Prevention Associ ation (NFPA) or the American Society of Heating, Refrigerating, and Air C onditioning Engineers (ASHRAE), by which the substitute is evaluate d.



### 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 Cla ssification, Health; 1, Flammability; 4, Reactivity; 1

ASHRAE 34_2010 has classified R-32 as an A2L low flammability refrige rant, 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 obsoleteForm 

### 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



## 10 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) Previous editions are obsolete 

### 11 Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

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

(a) Describe the activities in whic h workers may be exposed to chemicals. (b) Describe any protective equipment and engineering c ontrols used to protect workers (e.g. goggles, gloves, chemical hoo ds). (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). (d) Estimate average and maximum num bers 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 phy sical 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-USEForm 1265-07 (Revised 06/2008) Previous editions are obsolete 

### 12

For each end-use of a substitute:

(a) Provide the estimated amount (in kg/day) of each chemi cal released directly to the e nvironment (e.g. as a hazardous wa ste or (b) Identify the media (indoor air, outdoor air, land, wate r) to which the chemical will be released from that release poi nt. (c) Describe the control technology used to limit release; estimate the amount released to the environment with the contro l technology in place to limit release. If the substitu te 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 subs titute. Describe any associated costs and equipment. Recovery unit will be developed by Japane se 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 presen tly 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) Previous editions are obsolete 

### 13 Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the s ubstitute (end-uses utilizing the substitu te in products and/or processes):

(a) Describe the activities in wh ich workers may be exposed to chemicals. (b) Describe any protective equipment or engineering c ontrols used to protect workers (e.g. goggles, gloves, chemical hood s). (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). (d) Estimate average and maximum num bers 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 concentr ations (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 concentrati on. 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 

### 14 Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes a nd products containing substitutes:

(a) Identify and number potential exposure points. (b) For each exposure point describe d in (a), identify the poten tially 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/m 3 ). Provide (1) average and (2) high-end estimates.



### No general population exposure is anticipated.

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## 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 

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# 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 - 

## Part 

## III, Section A - 

## 11 No