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


## JUN 1 8 2013
Mr. Dou Yanwei China Household Electrical Appliance Association Room 709, Talent International Building No . 80 Guang Qumen Inner Avenue Beijing P
.R.C. 100062 Re: Incomplete SNAP Submission for R

- 290 in Air Conditioning Dear Mr. Yanwei : OFF I CE O F A I R AND RAD IAT I O N

Thank you for China Household Electrical Appliance Association's (CHEAA) submission to the Environmental Protection Agency (EPA). EPA established the Significant New Alternatives Policy (SNAP) program to implement section 612 ofthe Clean Air Act. Your application submitted on April19 , 2013 has been reviewed for completeness as part of the initial SNAP review. We have found the submission to be incomplete. The following information is necessary in order to allow the Agency to continue the review of CHEAA's SNAP submissions for R

- 290 in air conditioning (A/C). 1. Use and Equipment Clarification. Please define the residential heat pump use included in your application. For instance , does the equipment fall under the Underwriters Laboratories (UL) 484 standard for room air conditioners? Or alternatively , is it a mini

split? Ifthe heat pump equipment is substantially similar to window air conditioning, then the information requested throughout this letter may change
. 2. Fault Tree A nal y sis
. Please provide quantitative estimates of the probability of different events in the fault tree analysis on page 9 of the SNAP application (Sect. II.A.28) , and provide the source ofthe information. Also, please provide separate fault tree analyses for window A/C units , heat pumps and dehumidifiers. The probabilities should differ for each. 3
. Refrigerant R ecycling. Please provide information on how R

- 290 could be recovered and recycled during servi cing or at the end of the lif e of the product, in response to Sect. III.D
.f
. on page 16 of the SNAP application. This should include any additional training, guideline updates and equipment needs
. a . Please provide a description of how you propose that the refrigerant be handled upon disposal, including the procedures and types of equipment involved
. b
. Also , the Agency would be interested to know if you expect that, if the equipment stop s working properly, the window A/C units and dehumi difi ers w ill typically b e serviced or instead, the equipment will be disposed o f and replaced.

I n te rn e t Ad dress (URL ) • h ttp :// www . epa . go v R ec y c l e d/R e c y c l a bl e · Pri nted w ith Veg e tab le Oi l Base d I n ks o n 100 % Postco n s um er. Process Ch l orin e Free Recyc l e d Paper4. Occupational Exposure and Safety Precautions. Please provide information on guidance and training for workers who may come into contact with this refrigerant during the scenarios you have outlined in Part III, Section C of your application. a . Please provide information on safety precautions to be implemented during maintenance, repair, service, disposal, and transport of equipment using R

- 290 refrigerant. If you have prepared any manuals or training documents, please include those. b. If available, please provide examples of recommended warnings, markings or labels that would go on equipment. c . In the United States there are strict requirements for the transportation of hazardous material. Applicable U.S. Department of Transportation regulations are located in 49 CFR Subtitle B. Please explain how you intend to comply for R

- 290 cylinders and equipment pre-charged with R-290. 5. Occupational and Consumer Exposure
. Please clarify whether the equipment is expected to be charged during manufacture, installation or a combination of both. Further, if charging occurs at the manufacture site, is the unit entirely sealed by the time it reaches the end

-use site? What are typical values for ventilation in air changes per hour at the charging location? Please provide this information for all equipment types . 6. Charge Size
. Please provide information on the typical expected charge size for dehumidifiers. Please also provide information on the maximum charge siz es, minimum and typical room sizes and equipment capacity for each of the equipment types in your submission. The Agency is interested in receiving this information on your minimum and maximum capacity units
. Below is one option for providing this information. R

- 290 Application Typical Maximum Minimum Typical Equipment Charge Charge Room Room Capacity Size Size Size Size Minimum Capacity : Residential & light commercial window-type A/C units Maximum Capacity: Residential & light commercial window

-type A/C Minimum Capacity: Residential heat pumps Maximum Capacity : Residential heat pumps Re sidential dehumidifiers
7. CBI Claims. If you wish to claim any ofthe information submitted in response to the requests abov e a s confidential business information (CBI) , please provide two copie s of your respons e, on e containing CBI and one with CBI removed.Here is a summary of information concerning your submission: Substitute name: R-290 Substance(s) the substitute will replace: HCFC

- 22 Sector: Refrigeration and Air Conditioning End-uses: Window-type residential and light commercial air conditioning, heat pumps and residential dehumidifiers New or retrofit usage: New Date received: April 19, 2013 Status of submission: Incomplete Responses to these questions are necessary for us to begin our review. The information can be submitted via electronic mail or hard copy. If you have questions about your submission, please contact me at (202) 343-9445 or vondemhagen.rebecca @ epa . gov . Sincerely, () () /J I

# It{~---=-**··** . f}UA_**~** Rebecca von dem Hagen Alternatives and Emissions Reduction Branch Stratospheric Protection Division