# Competition Advocates, LLC

February 21, 2012

Response to EPA Questions Dated February 7, 2012 Relating to Pending R32 SNAP Petition

TO: Dave Godwin, EPA Alternativ es & Emission Reductions Branch

CC: Melissa Fiffer, Margaret Sheppard

Thank you for your additional questions regarding Daik in’s pending R-32 SNAP application. I have consulted with the engineers at Daikin U.S. Corporation and with Daikin Industries Ltd.’s Ch ief Engineer Mr. Tsujii in Osaka, and based on the information I received from them Daikin is providing the following answers to your questions below (I have extracted the questions from your February 7, 2012 email and edited them for clarity, with questions in blue font and answers in red font).

Question 1: How were these maximum charge sizes in the c hart under item 3 in Daikin’s December 6, 2011 submittal determined? For instance, do they assume a large number of indoor units or very long refrigerant lines from the outdoor unit to the indoor unit(s)?

Answer 1: These maximum charge sizes were calculated based on the assumption that the R-410a and R-32 systems are using the longest factor y-recommended refrigerant pipe run fo r these systems from the outdoor unit to the indoor unit, a distance of 165 feet. This ma y account for the larger refrigerant charge than you expected. We used the maximum feasible pipe run in our calculation because this analysis is being done for a risk assessment, and we assumed the largest possible volume of refrigerant in the system for that purpose to
simulate the worst-case scenario. In contrast, t he Trane presenter who you mentioned at the recent UL working group meeting was probably using the shortest f easible pipe run and the smallest possible volume of refrigerant in the system that he was describing.

Question 2: If so, how often would one likely see these maximum values?

Answer 2: Based on the sales experience of Daikin AC (Ameri cas), Inc., our U.S. equipment sales subsidiary, the typical length of the pipe run between the indoor and outdoor unit is approximately 50 ft. Longer pipe runs

than 50 feet are unusual.

Question 3: What would be a "typical" charge size for these units?

Answer 3: The charge of a SEER 18 2-ton R-32 ducted split system with a 50-foot pipe run between the

indoor and outdoor units would be 10.0 lbs. of R-32. The comparable amount of refrigerant for a SEER 18 R410a 2-ton ducted split system with a 50-foot pipe run between the indoor and outdoor units would be 11.8 lbs.

Question 4: Does the calculation of 425 square feet per pound / 850 square feet per ton sound reasonable to you for Daikin equipment?

Answer 4: Regardless of manufacturers or systems, the fl oor area (space) per ton should be same. Daikin AC (Americas), Inc.’s experience in the U.S. market indicates that the aver age square fee per ton amount ranges between 400 and 500 square feet.

Question 5: Does your table assume a particular type of space or load?

Answer 5: Our table assumes that the systems are operating in residential-type space in Japan.

Question 6: Also, does your current submission anticipate R-32 equipment being used in restaurant or kitchen applications?

3188 Key Boulevard, Arlington, Virginia 22201, 202-669-2002, mstanga@verizon.net- 2 -

Answer 6: Yes, our current SNAP submission anticipates t hat R-32 equipment would be used in restaurant or kitchen applications as well as in residential applications.

Question 7: Regarding your response 2.b. in Daikin’s Januar y 25, 2012 submittal, did you mean the reverse? For example, in the summertime, wouldn't the high-tem perature part be the unit in the outdoor ambient, rather than the unit inside the cooled space?

Answer 8: We apologize that the previous answer was inco rrect. As you speculated, we inadvertently reversed the parts of our previous re sponse 2.b. in our January 25 submitta l. The high-temperature part of the system will be the outdoor units in the summert ime, and the indoor units in the wintertime.

Thanks again, let me know if you have any more questions.

Sincerely,

Mark Stanga For Daikin U.S. Corporation