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. Y anwei: 

OFFICE OF 

AIR AND RADIATION 

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 minisplit? Ifthe heat pump equipment is substantially similar to window air conditioning, 

then the information requested throughout this letter may change. 

2. Fault Tree Analysis. 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 of the 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 Recycling. Please provide information on how R-290 could be recovered and 

recycled during servicing or at the end of the life 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 

stops working properly, the window A/C units and dehumidifiers will typically be 

serviced or instead, the equipment will be disposed of and replaced. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyc lable · Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
4. 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 sizes, 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 

Residential dehumidifiers 

7. CBI Claims. If you wish to claim any of the information submitted in response to the 

requests above 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-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, 

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Rebecca von dem Hagen 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division