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, Katarzyna 
Cc: 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 consumer exposure may occur (e.g., cooling 

apparatus in personal PCs, workstations, gaming 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 heat transfer end-use, 

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

provide data on the potential exposure concentrations during these activities. 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 anticipated to occur in closed systems.

What is the maximum charge 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 inks
Dear Margaret,

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

regards to the heat transfer uses of 1233zd(E). Tomorrow, Wednesday, June 6th, 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 his best to answer questions as they come up. Also, 

could you provide a list of EPA/contractor 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 open top vapor degreaser. And yes, we are assuming that 1233zd would 

have a lower emission rate than 245fa in an open top vapor 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 solvent 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 contractors 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 whether 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 testing that found losses of 342 ml/day HFC-245fa from 

a low emission vapor degreaser without secondary 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) from 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 evidence that the estimated loss rate of 15 ml/hr does not underestimate 

emissions from open top vapor degreasers, or else provide 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 this 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 3
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

-----"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 geothermal and waste heat recovery systems generating 

from less than 1MW to ~5 MW of power. These 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 letter 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 incompleteness letter for solvents and adhesives, coatings 

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

We also had a question regarding 1233zd(E) in the heat 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 microprocessors, in residential and commercial 

settings)? If not, what are examples of organic rankine 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 in 
our 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