UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mr. Richard H. Maruya 

A.S. Trust & Holdings 

44-129 Mikiola Drive 

Kaneohe, Hawaii 96744 

MAY 1 5 2013 OFFICE OF 

AIR AND RADIATION 

Re: Incomplete SNAP Submission for R-443A (HCR-188C2) for Residential Air 

Conditioning 

Dear Mr. Maruya: 

Thank you for A.S. Trust & Holdings' SNAP application to the Environmental Protection 

Agency (EPA) received on February 13,2013. The Agency has reviewed the information in the 

letter and determined that the Significant New Alternatives Policy (SNAP) program submission 

for R-443A in residential air conditioning (A/C) is incomplete. The following information is 

necessary in order to allow the Agency to move forward with the A.S. Trust & Holdings, Inc.'s 

SNAP submissions for R-443A in residential air conditioning. 

1. Charge Size. Throughout your SNAP application for R-443A you estimate varying 

charge sizes (i.e., Part I Section 4(b), Part II Section 2(b) and the risk assessment). Please 

clarify your typical charge sizes and provide information on the maximum charge sizes, 

minimum and maximum room sizes and equipment capacity for each of the end uses 

applications in your submission. Below is one option for providing this information. 

a. Please clarify what EPA requirement you are referencing in Part I Section 4(b) of 

you application when you state, " .. . while meeting the EPA regulated maximum 

charge for a flammable refrigerant in new systems." 

R-443A Application Typical Maximum Minimum Typical Room Equipment 

Charge Size Charge Size Room Size Size Capacity 

Residential splitsystem A/C units 

Residential heat pump 

Portable room A/C 

2. Risk Assessment. Please provide additional information and responses to the following 

questions regarding your risk assessment. 

Internet Address (URL) • http //www.epa.gov 

Recyc led/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
a. What are the risks of refrigerant release and of fire in a furnace room or utility 

closet that contains the indoor portion of a heat pump or residential A/C splitsystem? 

1. Please provide fault trees related to a catastrophic release in a furnace 

room, utility/mechanical closet or crawl space of a home for split systems 

and for heat pumps. 

11. What differences, if any, would there be in risk for an A/C system coinstalled with a gas furnace or electric heater? Please provide information 

on both types of equipment. 

b. The modeling of concentrations you conducted assumes that a release from a heat 

pump or split system disperses evenly throughout the entire house immediately 

upon release. Please explain why the release is modeled this way instead of 

modeled as a release into one room followed by dispersion into subsequent 

rooms. How do the risk calculations and the maximum concentrations change for 

a residential release if the risk assessment is revised by: 

1. Assuming that during the catastrophic release scenario, all the refrigerant 

from the split system or heat pump initially leaks in a utility closet or room 

and then over time migrates into neighboring rooms, and then throughout 

the entire building? 

11. Assuming that the safety valve does not operate as intended and does not 

reduce the maximum charge release? 

111. Both of the assumptions above? 

c. Please include information on potential impacts of human exposure to refrigerant 

released during servicing or charging. 

d. Please explain the calculations and assumptions behind the fault tree condition 

"Sufficient Leak Occurs During Servicing" on page 217 of your application. 

e. What is the basis or source for the assumption in the risk assessment that for a 

split A/C system, 71.9% of repairs will be to the outdoor unit? 

3. Safety Valve. In which section of the refrigerant circuit should the safety valve be 

installed to mitigate risk? Please provide a schematic diagram of a refrigerant circuit for 

each of the three types of equipment covered in the submission, and indicate where the 

safety valve should be placed. 

4. Environmental Release and Disposal at Manufacture. Please describe the process for 

manufacturing, and assembling A/C equipment using R-443A, detailing whether it is 

automated or manual and whether or not workers use personal protective equipment. 

Also, please describe the anticipated waste management practices for manufacture of 

household A/C systems using R-443A, including whether or not workers use personal 

protective equipment during clean up. Please provide this information on all three 

equipment types. 

5. Occupational and Consumer Exposure. Please clarify whether the A/C equipment is 

expected to be charged during manufacture, installation or a combination of both. 

Further, if charging occurs at the manufacture site, is the unit entirely sealed by the time 
it reaches the end-use site? What are typical values for ventilation in air changes per hour 

at the charging location? Please provide this information on all three equipment types. 

6. Additional Resources. Please provide a copy of the Colbourne 2001 study, Risk 

Assessment of Flammable Refrigerants in Room Air Conditioners, referenced in the risk 

assessment. 

7. CBI Claims. If you wish to claim any of the information submitted in response to the 

above requests as confidential business information (CBI), please provide two copies of 

your response, one containing CBI and one with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: R-443A (HCR-188C2) 

Substance(s) the substitute will replace: HCFC-22 

Sector: Refrigeration and Air Conditioning 

End-uses: Residential and light commercial air conditioning and heat pumps 

Applications: Residential split-system A/C units, residential heat pumps, and portable (floor 

model) room AJC 

New or retrofit usage: New 

Date received: February 13,2013 

Status of submission: Incomplete 

Responses to these questions would be helpful for our review. The information can be submitted 

via electronic mail or hard copy. If you have questions about your submission, please contact our 

SNAP Coordinator, Rebecca von dem Hagen at (202) 343-9445 or 

vondemhagen.rebecca@epa. gov. 

Sincerely, 

Cindy Newberg 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division