EPA’s Summary of Meeting of Standard - Setting Groups for SAE International, Interior Climate

Control Committee New and Revised Standards for HFO - 1234yf , HFC - 134a, and R - 744 Meeting held January

18, 2010 in L as Vegas, NV Representatives from SAE Internati onal, automotive manufacturers (“original equipment manufacturers” or OEMs), and suppliers discussed 16 standards under consideration. EPA staff was also in attendance (Yaidi Cancel and Margaret Sheppard, Stratospheric Protection Division and Kristen Tadd

onio, Climate Protection Partnerships Division) For abbreviation purposes, HFO - 1234yf appears as R - 1234yf and HCF - 134a appears as R - 134a. Standards = stds Agenda : 9:30am: R - 1234y f service fittings and stds 10:00am: Review of topics discussed on the Nove mber 20 th meeting with EPA 11:00am: Break out of work teams 2:00pm: Group work team allots resolution for the stds 4:00pm: Future SEA meetings 4:15pm: Lubricant std The committee is broken up into the following teams: OEMs, Motor A/C (MAC) suppliers, flui ds, and servicing. Standards issues discussion A brief introduction about the proposed standards for HFO - 1234yf and the expected time in the ballot was discussed. At the end of the meeting the expected publication dates for the standards were changed. T hese dates were presented in the CRP1234 meeting of January 20 th . For more information the presentation is available as a pdf document in the docket. SAE J 639 fitting issues (proposed changes/updates for this standard): SAE J 639 “provides design standards and safet y requirements for MAC systems. Also included are cautionary

statements for the mobile air conditioning service industry to alert service technicians to the inadvisability and the possible health and safety effects associated with venting refrig erant during service.” (Atkinson, 2010) The stakeholders commented that fitting measurements should be consistent according to the refrigerant used in the motor vehicle air conditioning (MVAC) s ys tem. Fittings for R - 1234yf should be different from fitti ngs for R - 134a. Also, the attention was brought to update the coupling leading configuration to provide an adequate area to seal, and therefore, preventleakages. Focus was brought to revise the cap seal and a reduction of the diameter of ball lock

feature was proposed. SAE J 2844 - Refrigerant Purity and Container Requirements for New HFO - 1234yf Refrigerant Used in Mobile Air - Conditioning Systems The attendees commented about the cylinder connections for R - 1234yf, and pointed that such connections shoul d be verified b y the Compress Gas Association (CGA) to meet their requirements. There is a requested proposal to develop a standard including three new cylinder connections for R - 152a, R - 1234y f and R - 744. However, priorities for this proposal might be low at the moment due to consistency issues with J 639. The attendees mentioned that changes may be done on the check valve assembly due to the flammability

of R - 1234yf. Also, discussion regarding the label for R - 1234yf container was brought. The label is li kely to contain a white background with a red border. The OEMs brought to attention an issue regarding most of the listed SNAP - MVAC alternative refrigerants due to the lack of certified service equipment that could lead into cross contamination of the MVAC systems. CRP 1234 meeting summary (from November 20, 2009) During this session the presenter showed a summary of the topics discussed during the OEMs meeting with EPA on November 20, 2009. (Further details from this meeting can be viewed in the docket). OEMs discussed the exposure limits of HF (AEGL - 2 limit (94ppm, 10 min)) and compared with the actual results of HF production during the risk assessments. Comments from OEMs: The OEMs commented that there should be a restriction of refrigerant use fo r professionals only (therefore no DIY - ers). Also they commented that the proposed use conditions or proposed mitigations to limit the concentration such as applying blowers, could create problems with toxic fumes being brought into the passenger compartme nt, increasing safet y issues concerns. The OEMs mentioned that HF generation is to be a low level of risk and added that risks with R 1234y f are 20 times lower than R - 152a. They recognized that EPA accepted R - 152a to be used as a secondary

loop, but suc h engineering strategy is not necessary with R - 1234yf and will not work due to efficiency

issues. The OEMs expressed that MVACs using R - 1234yf should be acceptable without the specific use conditions mentioned in the proposed rule. The proposed rule shou ld focus on standards such asJ639 and risk assessments and studies made b y the industry. “Raise those standards (referring to

SAE stds) in the rulemaking”. Attention was brought again to the Ignition/explosion LFL test showing the ping - pong balls (showe d during the November 20, 2009 meeting) as an approach to show that ignition during normal conditions is almost impossible with R - 1234yf, since the ignition was assisted using a butane lighter. This showed that a high energy source is needed to ignite the refrigerant; however the flame propagation is minimal. OEMs agreed (as discussed on the November 20 meeting) with the following use conditions from the proposed rule:

- Unique fittings, labeling, high pressure compressor cutoff switch, and failure mode and affect anal ys is (FMEA) on MVACs as stated in SAE J 1739 standard. Attendees Question and Answer session: Some OEMs asked if the A/C lubricant ha s an effect on the refrigerant in the MVAC sy stem . Others responded that, ye s, the lubricant has an effect o n flammability . Tests were conducted with lubricants as well ( in risk anal ys is). OEM work group std review teams: Attendees broke into several groups to discuss topics to be addressed into the SAE stds and agree for a completion date for each std. MAC group review team & stds to review J2064

– R - 134a & R - 1234y f refrigerant auto a/c hose and assemblies J2842 - HFO - 1234y f and R744 Design Criteria and Certification for OEM Mobile Air Conditioning Evaporator and Service Replacements J2911 - Certification Re quirements For Mobile Air Conditioning Sy stem Components, Service Equipment, and Service Technicians to Meet SAE J Standards Service work group review team J2843 - HFO - 1234y f Recovery /Recycling/Recharging Equipment for Flammable Refrigerants for Mobile A ir - Conditioning Sy stems J2845 - Technician Training for Safe Service and Containment of Refrigerants Used in Mobile A/C Sy stems (R - 744, and HFO - 1234y f) J2851 - HFO - 1234y f Refrigerant Recovery Equipment for Mobile Automotive Air - Conditioning Sy stems J291 3 - HFO - 1234y f Refrigerant Electronic Leak Detectors, Minimum Performance Criteria J2888 - HFO - 1234y f Service Hose, Fittings and Couplers for Mobile Refrigerant Sy stems Service EquipmentJ2912 - HFO - 1234y f Refrigerant Identification Equipment for Use with Mobile Air Conditioning

Sy stems J2927 - HFO - 1234y f Refrigerant Identifier Installed In Recovery and Recycling Equipment For Use With Mobile A/C Sy stems J2911

– Procedure For Certification That Requirements For Mobile Air Conditioning Sy stem Components, Service Equipment and Service Technicians Meet SAE J Standards Fluids work review team J2099 - Standard of Purity for Recycled HFC - 134a (R - 134a) and HFO - 1234yf (R - 1234yf) or Use in Mobile Air - conditioning Sy stems J2670 - Stability

and Compatibility

Cri teria for Additives and Flushing Materials Intended for Use in R - 134a and HFO - 1234y f Vehicle Air - Conditioning Sy stem J2844 - HFO - 1234y f New Refrigerant Purity and Container Requirements Used in Mobile Air Conditioning Systems OEM J2772 - Measurement of Passenger Compartment Refrigerant Concentrations under s ys tem refrigerant leakage conditions J2773 - HFO - 1234y f and R744 Refrigerant Standard for Safety and Risk Analy sis for use in Mobile Air Conditioning Sy stems J2842 - HFO - 1234y f and R744 Design Crit eria and Certification for OEM Mobile Air Conditioning Evaporator and Service Replacements Other topics: HFO - 1234y f name discussion: Attendees agreed that the refrigerant HFO - 1234yf could be called for technical purposes as R 1234y f. Fluids group : Issu es: refrigerant purity , relationship to AHRI/ASHRAE standards, fittings, lubricants, impurity levels after recovery

of refrigerant. Some attendees asked if vehicles using R - 134a should be retrofitred to for R - 1234yf . The group consensus was “no.” Refri gerant service group Issues: leak detectors, recovery /recycling/recharging equipment, who may test to meet SAE standards, fittings, hoses, evaporators, technician training Also concerns about dye s, refrigerant purity, aftermarket additives and flushing a gents. Outstanding issues on the proposed SAE J standardsJ2911 - Certification Requirements for Mobile Air Conditioning System Components,

Service Equipment, and Service Technicians to Meet SAE J Standards An issue was brought into discussion addressin g the concern of having equipment being labeled as SAE certified from labs with unknown credentials. One of the attendees brought into discussion the lack of enforcement to control testing facilities and find out if such facilities are following the standard testing procedures. The suggested SAE J2911 standard states: “Certification is required prior production of equipment for market sale, and application of the label that recognizes SAE as the certifying entity . Additional certification might be required if within one year after the product goes to market using a component purchased on the open market” J2912 - HFO - 1234yf Refrigerant Identification Equipment for Use with Mobile Air Conditioning Systems Concern was brought into discussion regarding cross contamination in the MVAC sy stem and the service equipment. Attendees commented on the importance to test the equipment prior having it available in the market. Future SAE congress meetings

- ICCC April 13 (9 - 5 in COBO)

- Climate control tech session (April 15)

- ISO/CRP/L CCP... TBA

- suites)

– (focus on s ys tem efficiency) New lubricant std – proposed by VDA The proposed standard focuses on lubricant oils for refrigerant compressors, and requirements for its use with R - 1234y f. The current oil alternatives include PAG, POE & PVE. The presenter stated that R - 1234y f lubricants might have a larger demand compared with R134a for lubricants. Several issues were addressed to consider including different compressor ty pes since all need oil and have to meet industry and st d specifications, differences in viscosit y, and stability when mixing with the refrigerants and metal parts. There were no suggestions to change the already available oils in the market. However, there may be changes in compressor design. VDA said that the y considered risks and performed conductivity measures of the oil. On of the attendees asked to pursue std, test methods used, and how much lubricant takes the a/c s ys tem. VDA said that the details regarding the oil and the studies and the proposal for wer e already sent for a review to the committee members. Question & Answer session with EPA : Question - Does EPA want to consider comments after the close of the comment period? Answer: Yes, we can consider comments once the public comment period is closed . (After that point, we are not legally

obligated to consider).Question: What’s the timing now? Does the timing on the standards matter?

Answer : It will probabl y take EPA around 6 - 12 months to prepare a final rule. Standards must be final before there is a final rule. Ideally , standards would be final now so that we can take comment on the actual standard. Question : Hy

pothetically

— could EPA say

that you’ve already

taken comment, many

have offered comments in support, so you could finalize? Answe r : We would need to check with legal counsel on that. Based on experience with other rules, ideall y, we would like to give public the chance to actually see a document.