A/S Vestfrost Tel. +45 79 14 22 22 CVR. 37101117

Falkevej 12 Fax +45 79 14 22 55

DK-6705 Esbjerg Ø www.vestfrostsolutions.com 1 / 4

Dear Rebecca von dem Hagen

Answer to Margaret Sheppard e-mail of 14.03.2013 

Estimated marked size: 

Regarding the estimate of projected marked size for Isobutane in commercial stand-alone refrigerators 

It can be difficult to judge, but thinking of future production the quantity will be similar to existing

products sold in US with R134a year 2012 which were 40.000 units.

Worker exposure: 

All gas charging area in A/S Vestfrost factory is build and constructed as a closed area. This area is 

automatic ventilated and gas release will automatically be ventilated out. This area must only be 

entered and used by trained people.

The area is equipped with detectors and lower alarm will turn on at 10% of LEL and high alarm will turn 

on at 25% LEL.

Rebecca von dem Hagen

Environmental Scientist

Significant New Alternatives Policy Program

USEPA/Stratospheric Protection Division

Telephone (202) 343-9445

Email vondemhagen.rebecca@epa.gov

Your ref. Our ref. Jørn Skov Date 29.04.2013
A/S Vestfrost Tel. +45 79 14 22 22 CVR. 37101117

Falkevej 12 Fax +45 79 14 22 55

DK-6705 Esbjerg Ø www.vestfrostsolutions.com 2 / 4

Regarding concentration of Isobutane in the gas charging area for type CC70.

 

The limit for R600a Isobutane is 500 ppm (1,200 mg / m3)

The volume of the controlled gas charging area is 5.7 m3

The controlled ventilation in the gas charging area is 2,750 m3 / h

Air exchange in the gas charging area = 482 times per second. h

The capacity of the production line is 30 units per. hour.

After each gas charge we have a gas released or emission of 1.3 g.

Gas release or emissions per. hour:

30 x 1.300mg = 39.000 mg / h

Concentration of gas in charging area:

39,000 (mg / h) / 5.7 (m3) = 6842 ((mg / h) / m3)

6,842 ((mg / h) / m) / 482 / h = 14.2 (mg / m3)

Concentration in ppm:

(500ppm/1.200 (mg / m3)) x14, 2 (mg / m3) = 5.9 ppm.
A/S Vestfrost Tel. +45 79 14 22 22 CVR. 37101117

Falkevej 12 Fax +45 79 14 22 55

DK-6705 Esbjerg Ø www.vestfrostsolutions.com 3 / 4

Regarding concentration of Isobutane in the gas charging area for type M034, M036.

 

The limit for Isobutane is 500 ppm (1,200 mg / m3)

The volume of the controlled gas charging area is 6,5 m3

The controlled ventilation in the gas charging area is 1,000 m3 / h

Air exchange in the gas charging area = 154 times per second. h

The capacity of the production line is 30 units per. hour.

After each gas charging we have a gas released of 0.2 g.

Gas release or Emissions per. hour:

30 x 200mg = 6.000 mg / h

Concentration in the gas charging area:

6.000 (mg / h) / 6.5 (m3) = 923 ((mg / h) / m3)

923 ((mg / h) / m) / 154 / h = 6.0 (mg / m3)

Concentration in ppm:

(500ppm/1.200 (mg / m3)) x6, 0 (mg / m3) = 2.5 ppm.
A/S Vestfrost Tel. +45 79 14 22 22 CVR. 37101117

Falkevej 12 Fax +45 79 14 22 55

DK-6705 Esbjerg Ø www.vestfrostsolutions.com 4 / 4

If refrigerant is released due to a leak on one appliance which are in the gas charging area you 

will have the following estimated emission. 

A typical gas charge is maximum 65 gram and if there is a leak on one appliance all gas will not be 

released to the environment immediately, but estimated 60 % if we have a leak at high pressure side 

which gives 43 grams.

Estimated gas release or emissions when you have a gas leak at high side cooling system:

1 x 4300mg = 4.300 mg / h

Concentration in the gas charging area:

4.300 (mg / h) / 6.5 (m3) = 662 ((mg / h) / m3)

662 ((mg / h) / m) / 154 / h = 4,30 (mg / m3)

Concentration in ppm:

(500ppm/1.200 (mg / m3)) x 4,3 (mg / m3) = 1,8 ppm.

Yours faithfully

A/S Vestfrost

Jørn Skov

Dir.  4579142510

E-mail: js@vestfrostsolutions.com
From: Jørn Skov

To: VonDemHagen, Rebecca

Cc: Sheppard, Margaret

Subject: SV: SV: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Date: Thursday, May 02, 2013 5:44:47 AM

Attachments: Answer to Margaret Sheppard e-mail 14.03.2013.pdf

Dear Rebecca,

Please receive attached my comments to Margaret e-mail of 14.03.2013 in which she request for more

information in for you to review our submission for use of Isobutane in Stand-alone refrigerators for the

US marked.

Thank you and best regards.

jorn

Fra: Sheppard, Margaret [mailto:Sheppard.Margaret@epa.gov] 

Sendt: 4. marts 2013 19:01

Til: Jørn Skov

Cc: VonDemHagen, Rebecca

Emne: RE: SV: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Dear Jorn,

There are two more types of information that we need for our review.

For information on worker exposure, your response stated that there will be no worker

exposure to workers during the day. Please explain further. What concentration might a

worker experience due to a pinhole leak, in ppm on an eight-hour time-weighted average?

What exposure would likely occur if all the refrigerant were released at once, in ppm, both

on a short-term and an 8-hour basis?

We also need an estimate of the projected market size for isobutane in commercial standalone refrigerators. We think that is information that is more appropriate coming from your

client, Red Bull.

Red Bull has indicated that they would like to be a co-submitter with AS Vestfrost on your

submission. We request that you provide us with a letter stating that Red Bull is your cosubmitter. Also please state whether Red Bull is granted access to the documents you

have already submitted during the application process, and whether they may access all

information you send for your application in the future. Please clarify for EPA whether we

may contact Red Bull directly on matters related to the application without including a

representative from Vestfrost in the conversation. Finally, please clarify whether we should

always provide you with copies of emails and correspondence with Red Bull related to

your submission.

At this time, I would like to introduce you to the newest member of our SNAP team,

Rebecca von dem Hagen. Rebecca is taking over the role of SNAP Coordinator, working

with our submitters and preparing correspondence. She would be the person to whom you

would address the letter.

Rebecca’s contact information is as follows:
Telephone (202) 343-9445

Email vondemhagen.rebecca@epa.gov

We look forward to working with you.

Sincerely,

Margaret Sheppard

Environmental Scientist

Significant New Alternatives Policy Program

USEPA/Stratospheric Protection Division

Tel. 202-343-9163

Fax 202-343-2338

email: sheppard.margaret@epa.gov

From: Jørn Skov [mailto:js@vestfrostsolutions.com] 

Sent: Tuesday, February 26, 2013 9:54 AM

To: Sheppard, Margaret

Cc: Godwin, Dave; Fiffer, Melissa; Hamlin, Sally

Subject: SV: SV: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Dear Margaret,

Its time to follow up on my application.

Can I ask you if you have received all needed information.

Kind regards

jorn

Fra: Sheppard.Margaret@epamail.epa.gov [mailto:Sheppard.Margaret@epamail.epa.gov] 

Sendt: 10. januar 2013 15:13

Til: Jørn Skov

Cc: Godwin.Dave@epamail.epa.gov; Fiffer.Melissa@epamail.epa.gov; Hamlin.Sally@epamail.epa.gov

Emne: Re: SV: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Jorn,

Thank you for the additional information! This is a good way to start the new year.

We'll let you know what we think after our team has had a chance to look at this.

Margaret Sheppard

Environmental Scientist

Significant New Alternatives Policy Program

USEPA/Stratospheric Protection Division

Tel. 202-343-9163

Fax 202-343-2338

email: sheppard.margaret@epa.gov

Jørn Skov ---01/10/2013 08:43:04 AM---Dear Margaret, Happy New Year

From: Jørn Skov <js@vestfrostsolutions.com>
To: Margaret Sheppard/DC/USEPA/US@EPA

Cc: Dave Godwin/DC/USEPA/US@EPA, Melissa Fiffer/DC/USEPA/US@EPA, Sally Hamlin/DC/USEPA/US@EPA

Date: 01/10/2013 08:43 AM

Subject: SV: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Dear Margaret,

Happy New Year

Please receive attached my answers to you letter of incompleteness date 11-16-12. As you can see

from my cover letter I have also attached some Annex with information which I hope fulfill your

requirements.

Please let me have your comments.

Best regards

jorn

Fra: Sheppard.Margaret@epamail.epa.gov [mailto:Sheppard.Margaret@epamail.epa.gov] 

Sendt: 16. november 2012 23:46

Til: Jørn Skov

Cc: Godwin.Dave@epamail.epa.gov; Fiffer.Melissa@epamail.epa.gov; Hamlin.Sally@epamail.epa.gov

Emne: Re: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Jorn,

Here is a letter that will go out in the mail on Monday. This explains the information that we need for

our review. Please let Melissa or me know if you have questions after reading this letter.(See attached

file: Incompleteness letter R-600a retail food refrigeration 11-16-12.pdf)

I hope you had a good weekend.

Sincerely,

Margaret Sheppard

Environmental Scientist

Significant New Alternatives Policy Program

USEPA/Stratospheric Protection Division

Tel. 202-343-9163

Fax 202-343-2338

email: sheppard.margaret@epa.gov

Jørn Skov ---10/03/2012 02:43:46 AM---Dear all, Just a follow up from my side to know if my

application is Ok or something is missing.

From: Jørn Skov <js@vestfrostsolutions.com>

To: Margaret Sheppard/DC/USEPA/US@EPA

Cc: Dave Godwin/DC/USEPA/US@EPA, Melissa Fiffer/DC/USEPA/US@EPA, Sally Hamlin/DC/USEPA/US@EPA

Date: 10/03/2012 02:43 AM

Subject: SV: VS: SV: SNAB application for use of alternative HC refrigerant R600a
Dear all,

Just a follow up from my side to know if my application is Ok or something is missing.

Kind regards

jorn 

Fra: Margaret Sheppard [mailto:Sheppard.Margaret@epamail.epa.gov] 

Sendt: 13. august 2012 17:45

Til: Jørn Skov

Cc: Dave Godwin; Melissa Fiffer; Sally Hamlin

Emne: Re: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Jorn,

Melissa is out of the office this week.

We will look at the information you sent us last week. Melissa or I will later send you a letter, either

stating that your submission is complete, or that it is incomplete. If your submission is incomplete, the

letter will tell you the information we still need to complete our review. If your submission is complete,

then we will send you a letter stating it is complete and stating the date when you may export to or sell

in the U.S. That date is 90 days after we receive all the information we need for our review.

Margaret Sheppard

Environmental Scientist

Significant New Alternatives Policy Program

USEPA/Stratospheric Protection Division

Tel. 202-343-9163

Fax 202-343-2338

email: sheppard.margaret@epa.gov

Jørn Skov ---08/13/2012 04:10:27 AM---Dear Mellisa, Do you have an idea of how long time you

need before I can get a permission to send my

From: Jørn Skov <js@vestfrostsolutions.com>

To: Margaret Sheppard/DC/USEPA/US@EPA, Melissa Fiffer/DC/USEPA/US@EPA, Dave Godwin/DC/USEPA/US@EPA

Date: 08/13/2012 04:10 AM

Subject: VS: SV: SNAB application for use of alternative HC refrigerant R600a

Dear Mellisa,

Do you have an idea of how long time you need before I can get a permission to send my product to

US with the alternative refrigerant?

Kind regards

jorn

Fra: Jørn Skov 

Sendt: 9. august 2012 16:41

Til: 'Melissa Fiffer'
Cc: Dave Godwin; Margaret Sheppard; Lars Gorzelak

Emne: SV: SV: SNAB application for use of alternative HC refrigerant R600a

Hi Melissa,

Thank you for your prompt response. I look forward to work with you too.

Have a nice day,

Kind regards

jorn

Fra: Melissa Fiffer [mailto:Fiffer.Melissa@epamail.epa.gov]

Sendt: 9. august 2012 16:32

Til: Jørn Skov

Cc: Dave Godwin; Margaret Sheppard

Emne: Re: SV: SNAB application for use of alternative HC refrigerant R600a

Hi Jorn,

Not a problem at all. I am now able to open the attachments. Thank you for re-sending them.

The SNAP submission process is often a dialogue, and we look forward to working with you as we

review your submission. We will let you know whether we need further information in order to complete

our review. Please feel free to contact me should you have any questions.

Regards,

Melissa

Melissa Fiffer

Stratospheric Protection Division

U.S. Environmental Protection

Agency

Office: (202) 343-9464

Mobile: (202) 500-3531

Fiffer.Melissa@epa.gov

Protecting our atmosphere for generations to come 

25 years of the Montreal Protocol

Jørn Skov ---08/09/2012 10:27:13 AM---Sorry Melissa, Please see attached,

From: Jørn Skov <js@vestfrostsolutions.com>

To: Melissa Fiffer/DC/USEPA/US@EPA

Cc: Dave Godwin/DC/USEPA/US@EPA, Margaret Sheppard/DC/USEPA/US@EPA

Date: 08/09/2012 10:27 AM

Subject: SV: SNAB application for use of alternative HC refrigerant R600a

Sorry Melissa,
Please see attached,

Kind regards

jorn

Fra: Melissa Fiffer [mailto:Fiffer.Melissa@epamail.epa.gov] 

Sendt: 9. august 2012 16:22

Til: Jørn Skov

Cc: Dave Godwin; Margaret Sheppard

Emne: Re: SNAB application for use of alternative HC refrigerant R600a

Dear Jorn,

Thank you for confirming that none of the information should be treated as confidential.

The attachment you sent did not come through on our end. Our email system does not enable us to

open zip file attachments. Please rename the file name extension and resend the attachments.

Thank you,

Melissa

Melissa Fiffer

Stratospheric Protection Division

U.S. Environmental Protection

Agency

Office: (202) 343-9464

Mobile: (202) 500-3531

Fiffer.Melissa@epa.gov

Protecting our atmosphere for generations to come 

25 years of the Montreal Protocol

Jørn Skov ---08/09/2012 06:51:20 AM---Dear Melissa, Attached I have included my application for

use of HC refrigerant R600a as alternative

From: Jørn Skov <js@vestfrostsolutions.com>

To: Melissa Fiffer/DC/USEPA/US@EPA

Cc: Margaret Sheppard/DC/USEPA/US@EPA, Dave Godwin/DC/USEPA/US@EPA

Date: 08/09/2012 06:51 AM

Subject: SNAB application for use of alternative HC refrigerant R600a

Dear Melissa,

Attached I have included my application for use of HC refrigerant R600a as alternative use in for stand-
alone commercial refrigerator and freezers. I would appreciate if you or your colleagues would let me

know if the application attached is sufficient or not to obtain your permission to use the alternative

refrigerant R600a in our cabinets in US.

For your information this application do not contain any confidential information that not may be shared

with the public.

Venlig hilsen/Best Regards 

Jørn Findall Skov

Adm. Myndighedschef / Appli. Certification Manager

A/S Vestfrost

Falkevej 12

DK-6705 Esbjerg Ø

Mob +45 2141 3510

Dir +45 7914 2510

Mail js@vestfrostsolutions.com

Fax +45 7914 2255

Visit our website: vestfrostsolutions.com

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*********************** ATTACHMENT NOT DELIVERED

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This Email message contained an attachment named 

image001.jpg 

which may be a computer program. This attached computer

program could

contain a computer virus which could cause harm to EPA's

computers, 

network, and data. The attachment has been deleted.

This was done to limit the distribution of computer viruses

introduced

into the EPA network. EPA is deleting all computer program

attachments

sent from the Internet into the agency via Email.
If the message sender is known and the attachment was

legitimate, you

should contact the sender and request that they rename the

file name

extension and resend the Email with the renamed attachment.

After

receiving the revised Email, containing the renamed

attachment, you can

rename the file extension to its correct name.

For further information, please contact the EPA Call Center at

(866) 411-4EPA (4372). The TDD number is (866) 489-4900.

*********************** ATTACHMENT NOT DELIVERED

***********************

*********************** ATTACHMENT NOT DELIVERED *******************

This Email message contained an attachment named 

SNAP Application submission HC R600a refrigerant 2012 PDF.ZIP 

which may be a computer program. This attached computer program could

contain a computer virus which could cause harm to EPA's computers, 

network, and data. The attachment has been deleted.

This was done to limit the distribution of computer viruses introduced

into the EPA network. EPA is deleting all computer program attachments

sent from the Internet into the agency via Email.

If the message sender is known and the attachment was legitimate, you

should contact the sender and request that they rename the file name

extension and resend the Email with the renamed attachment. After

receiving the revised Email, containing the renamed attachment, you can

rename the file extension to its correct name.

For further information, please contact the EPA Call Center at

(866) 411-4EPA (4372). The TDD number is (866) 489-4900.

*********************** ATTACHMENT NOT DELIVERED ***********************

[attachment "SNAP Information Notice - Application Submission for use of HC

R600a.pdf" deleted by Melissa Fiffer/DC/USEPA/US] [attachment "Attachment 1.

- Manufacturer Vestffrost Presentation.pdf" deleted by Melissa

Fiffer/DC/USEPA/US] [attachment "Attachment 2. - Scematic cabinet

construction.pdf" deleted by Melissa Fiffer/DC/USEPA/US] [attachment

"Attachment 3. - Functional specification for HC cabinets.pdf" deleted by

Melissa Fiffer/DC/USEPA/US] [attachment "Attachment 4. - ETL Test Report No.

913841STO.pdf" deleted by Melissa Fiffer/DC/USEPA/US] [attachment "Attachment

5. - Athorization to ETL Mark - Vestfrost Control No.3073459.pdf" deleted by

Melissa Fiffer/DC/USEPA/US] [attachment "Attachment 6. - MSDS sdcpc003_-

_Aeron_Isobutan_(UKG) for Vestfrost.pdf" deleted by Melissa

Fiffer/DC/USEPA/US] [attachment "Attachment 7. - Vestfrost Servicemanual

General.pdf" deleted by Melissa Fiffer/DC/USEPA/US] [attachment "Attachment

8. - ISO Certificates valid 2012.pdf" deleted by Melissa Fiffer/DC/USEPA/US]

[attachment "Answers 07-01-2013 to Snap Letter Incomplete submission 11-16-

12..pdf" deleted by Margaret Sheppard/DC/USEPA/US] [attachment "2. Making

Repairs to refrigeration System.pdf" deleted by Margaret

Sheppard/DC/USEPA/US] [attachment "4. Other equipment for use of R600a

refrigerant.pdf" deleted by Margaret Sheppard/DC/USEPA/US] [attachment "6.

Energy test report R134a versus R600a model CC70.pdf" deleted by Margaret

Sheppard/DC/USEPA/US] [attachment "6.1 WHY_HYDROCARBONS_SAVE_ENERGY.pdf"

deleted by Margaret Sheppard/DC/USEPA/US] [attachment "7. Special Equipment

and its Use..pdf" deleted by Margaret Sheppard/DC/USEPA/US]