From: VonDemHagen, Rebecca

Sent: Wednesday, July 31, 2013 8:46 AM

To: Bober, Katarzyna

Cc: Sheppard, Margaret

Subject: RE: 1233zd

‐ Refrigeration Sector

Hi Kasia,

Thank you for the additional exposure monitoring results you submitted to SNAP about a month ago. As

Margaret said in her e

‐ mail, I am the SNAP coordinator. After conducting out preliminary review of the

data, we have a few additional questions and requests for clarification on your submission for

1233zd(E).



###  On the June 6, 2012 conference call, you informed EPA that 1233zd(E) would be substituting for

the refrigeration uses where HFC

‐ 245fa is currently used and that it was not expected to be

used in consumer applications. Please confirm if it is still the case that you not do plan to use

1233zd(E) in consumer applications.



###  The monitoring data provided on June 27, 2013 for the heat transfer are very helpful. We are

very interested in receiving additional information on the context of the data collected in order

to inform our review.



### o Please provide a written description of the charging and discharging process for which

the monitoring data was conducted, including descriptions of the recovery equipment

used, engineering controls, and personal protective equipment. If exposure may occur

during other activities related to ORC systems, please provide these descriptions as well.



### o What was the total quantity of refrigerant being charged and discharged associated with

the monitoring data? Please clarify if this charge size is representative of the average or

maximum charge size for the range of ORC applications anticipated. If the charge size

represents an average charge size, what is the maximum expected charge size?

Please let me know if you have any questions. My contact information is below.

Best Regards,

Rebecca von dem Hagen

Stratospheric Protection Division

Office of Atmospheric Programs

U.S. Environmental Protection Agency

(202) 343

‐ 9445

vondemhagen.rebecca@epa.gov

From: Sheppard, Margaret

Sent: Thursday, June 27, 2013 2:51 PM

To: Bober, KatarzynaCc: VonDemHagen, Rebecca

Subject: RE: 1233zd - Refrigeration Sector

Kasia,

Thank you for the additional information! I will share this with our review team.

Our SNAP coordinator, Rebecca von dem Hagen, will get back to you if we need further information.

Sincerely,

Margaret Sheppard

Environmental Scientist

Significant New Alternatives Policy (SNAP) Program

US EPA/Stratospheric Protection Division

Tel. 202-343-9163

Fax 202-343-2338

Email sheppard.margaret@epa.gov

From: Bober, Katarzyna [ mailto:Katarzyna.Bober@Honeywell.com ]

Sent: Thursday, June 27, 2013 2:16 PM

To: Sheppard, Margaret

Subject: 1233zd - Refrigeration Sector

Dear Margaret,

We were finally able to obtain the exposure monitoring data for the Heat Transfer (ORC) application for

1233zd. There are two reports attached. The first one shows the charging of 1233zd on 5/21/13 and

the second one shows discharging on 5/24/13.

It should be noted that on 5/24/13 there was a small leak at a seal at the end of that test, so the

refrigerant PPM levels were elevated slightly upon shutdown, you can then see additional spikes in

addition to this static level while the service events occurred.

Batch 1 is the room sniffer that was located at the level and nearby to where the technician would be

doing the service event. Batch 2 is located in the room’s exhaust duct and is diluted by excess air as it

leaves the building so it read lower peaks than Batch 1.

We have graphed a range that shows the peak for the day for each log file. The peak value captured

during charging was 86 ppm and during discharging was 114 ppm.

The maximum measured vapor

‐ in

‐ air values in the charts are well below the anticipated PEL of 800 ppm.Please let me know if you required additional information,

With kind regards,

Kasia

-----Forwarded by Margaret Sheppard /DC/USEPA/US on 06/28/2013 08:37AM -----

To: "Bober, Katarzyna" < Katarzyna.Bober@Honeywell.com > From: Margaret Sheppard/DC/USEPA/US

Date: 06/06/2012 12:21PM

Cc: "Tanphanich, Jenny" < JTanphanich@icfi.com >, Melissa Fiffer/DC/USEPA/US@EPA,

"Mark Wagner" < MWagner@icfi.com > Subject: Questions for 1233zd( E) in heat transfer uses

Kasia,

Here are a number of questions for our call at 1 pm.

Are any applications anticipated where cons umer exposure may occur (e.g., cooling

apparatus in personal PCs, workstations, gami ng consoles, and server microprocessors, in

residential and commercial settings)? If so, please indicate all consumer applications

anticipated, as well as the maximum charge size for these applications.

Attachment 18 of the original submission provided exposure information on the

manufacture, testing/installation, servicing/repair, and disposal of chillers and indicated that

service practices for organic rankine cycle (ORC) systems are largely the same as for

centrifugal chillers. So that we may complete the risk screen for the he at transfer end-use,

please 1) specify the activities related to ORC systems when exposure may occur, and 2)

provide data on the potential exposure concentr ations during these acti vities. If these are

the same as in the information Honeywell previously gave for chillers, please state so.

In addition, please specify if manufacture, use, or disposal of equipment using 1233zd(E) as

a heat transfer fluid is anticipa ted to occur in closed systems.

What is the maximum ch arge size for ORC systems?

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

-----"Bober, Katarzyna" < Katarzyna.Bober@Honeywell.com > wrote: -----

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

From: "Bober, Katarzyna" < Katarzyna.Bober@Honeywell.com >

Date: 06/05/2012 04:26PM

Cc: Melissa Fiffer/DC/USEPA/US@ EPA, "Tanphanich, Jenny" < JTanphanich@icfi.com >,

< MWagner@icfi.com >

Subject: RE: Incompleteness letter for 1233zd (E) in solvent cleaning and adhesives,

coatings and inksDear Margaret,

We would be happy to have a conference call to di scuss any additional questions EPA may have with

regards to the heat transfer uses of 1233zd(E). Tomorrow, Wednesday, June 6 th , 1pm-2pm works for

us. I have invited Gary Zyhowski to our call. He is a Senior Principal Engineer and is best suited to

answer any technical questions that may come up. It would be helpful if you could provide the questions

ahead of time if at all possible. If not, he will do hi s best to answer questions as they come up. Also,

could you provide a list of EPA/contract or attendees that we can expect?

I have set up the following call in number:

1-888-443-7713, meeting number * 8743902 *

With regard to your question about solvent cleaning, just to be clear, the low emission vapor degreaser

that was tested with 245fa is an ope n top vapor degreaser. And yes, we are assuming that 1233zd would

have a lower emission rate than 245fa in an open top v apor degreaser due to the higher boiling point of

1233zd.

With kind regards,

Kasia

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

Sent: Monday, June 04, 2012 9:10 AM

To: Bober, Katarzyna

Cc: Melissa Fiffer; Tanphanich, Jenny; MWagner@icfi.com

Subject: RE: Incompleteness letter for 1233zd(E) in solve nt cleaning and adhesives, coatings and inks

Kasia,

Thank you for the additional information concerning the heat transfer uses of 1233zd(E). When we

discussed this with our review team, our contra ctors still had questions. Perhaps this would best be

handled in a conference call, where our contractors could share what they need to complete a risk

screen.

Thanks also for the information on solvent uses of 1233zd(E) from your May 8 letter. I'll need to check

with the rest of our team before officially saying w hether it's complete, but I did find that information

helpful.

I have a question about the solvent cleaning exposure data for open top vapor degreasers. If I understand

correctly, the loss rate of 15 ml/hr was based on te sting that found losses of 342 ml/day HFC-245fa from

a low emission vapor degreaser without secondar y cooling coils, rather than from an open top vapor

degreaser. So, are you saying that the emissions of HFC-245fa from the low emission vapor degreaser

should equal or exceed emissions of 1233zd(E) fr om an open top vapor degreaser because HFC-245fa

has a boiling point 6.5 degrees F lower than that of 1233zd(E)? If this is what you intended, can you

please provide either further evi dence that the estimated loss rate of 15 ml/hr does not underestimate

emissions from open top vapor degreasers, or else pr ovide additional exposure data specific to open top

vapor degreasers?

Concerning the remaining end uses, we are still completing our review. I expect we will have a preliminary

determination on aerosol solvents in the next few weeks.

Please suggest some good times for you and your team th is week to join us for a conference call. Some

times that work for me, Melissa and our reviewers at ICF are:

Monday June 4 1-1:30 or 2-2:30

Wednesday June 6 between 1 and 2

Thursday June 7 between 1 and 3Sincerely,

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

-----"Bober, Katarzyna" < Katarzyna.Bober@Honeywell.com > wrote: -----

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

From: "Bober, Katarzyna" < Katarzyna.Bober@Honeywell.com >

Date: 05/23/2012 11:25AM

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

Subject: RE: Incompleteness letter for 1233zd(E) in solvent cleaning and adhesives, coatings and inks

Dear Melissa,

The applications for Organic Rankine Cycle are geot hermal and waste heat recovery systems generating

from less than 1MW to ~5 MW of power. Thes e installations range from small power plants to

supplemental systems in industrial plants, like Steel, Cement, and Refining. The attached document

provides additional information on occupational exposure and releases.

By the way, can you give us an update on the review of our response to the last incompleteness letter?

Do you anticipate a preliminary determination lette r coming out any time soon for these remaining

applications?

Thank you,

Kasia

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

Sent: Thursday, May 10, 2012 5:54 PM

To: Bober, Katarzyna

Cc: Margaret Sheppard

Subject: RE: Incompleteness letter for 1233zd(E) in solvent cleaning and adhesives, coatings and inks

Hi Kasia,

Thank you for your speedy response to the incomp leteness letter for solvents and adhesives, coatings

and inks, and for the public versions. We'll let you kn ow when we receive the hard copies via FedEx.

We also had a question regarding 1233zd(E) in the h eat transfer use. Does Honeywell anticipate the

specific heat transfer applications to be similar to those for HFO-1234ze (i.e., cooling apparatus in

personal PCs, workstations, gaming consoles, and server microprocessor s, in residential and commercial

settings)? If not, what are examples of organic ranki ne cycle applications and sensible heat transfer

applications where you anticipate 1233zd may be used, and what are examples of scenarios in which

refrigerant would be released? This clarification will help us more accurately analyze scenarios for risks inour review.

Thanks,

Melissa

Melissa Fiffer

Stratospheric Protection Division

U.S. Environmental Protection Agency

Office: (202) 343-9464

Mobile: (202) 500-3531

Fiffer.Melissa@epa.gov