Steven Cousins

Cold Drink Technical Manager

Cooler & Vender Platform Group

Coca-Cola Refreshments

One Coca-Cola Plaza, NW

Atlanta, GA 30313

T 404-676-5735

F 404-598-5735

stcousins@coca-cola.com

March 13, 2012

Margaret A. Sheppard

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

U.S. EPA

1200 Pennsylvania Ave., NW

Washington, D.C. 20460

Dear Ms. Sheppard,

Thank you for your letter dated February 23, 2012 pertaining to the Coca-Cola SNAP application for the 

R-744 substitute in the vending machine end-use. That letter requested clarification on several matters 

in the submission.

Below I provide answers and more information in response to those questions. I reference your specific 

question with blue-colored text. The answer follows.

1. CBI Claims. Please clearly identify which information you are claiming as confidential business 

information (CBI).

Attachments declared as CBI Rationale (reason why)

Attachment 1_Technical Document on R744 

Refrigerated Beverage Vending Machines.pdf

The only part of this document that is CBI is Table 

2 at the end of the document.

This table is from the Sanden Corporation of Japan. 

Sanden declares this in-house test results of 

refrigeration system performance as proprietary 

and confidential. Sanden makes money by building 

and selling R744 cooling cassettes, and do not want 

their business lucrative system performance details 

made public which causes them to lose a 

competitive advantage and potential sales.

Application Part II, Section B, 2.(b) – The “0-10% 

energy reduction relative to R-134a system, 

depending on ambient conditions” is public, 

common knowledge. However, the Attachment 3 

is CBI from Sanden Corporation of Japan.

Attachment 4 is not CBI.

Attachment 3 _Energy efficiency of R744 Vending 

machine.pdf

This document is from the Sanden Corporation of 

Japan. Sanden declares their in-house test data and 

refrigeration system performance variables are 

proprietary and confidential. Sanden makes money 

by building and selling R744 cooling cassettes, and 

do not want their business lucrative system 

performance details made public which causes 

them to lose a competitive advantage and potential 

sales.
Attachment 5b_ UL Advisory on New CO2.pdf It is the Underwriters Laboratories business practice 

to keep their compensated services confidential 

with their paid client. The Advisory references 

documents and opinions that are owned by UL, and 

UL has declared the document confidential.

Coca-Cola is not at liberty to make it public.

For example, is any information in Attachment 9, “Supplementary Information on the Market 

Penetration of R744 Beverage Vending Machines” considered CBI?

No.

The document contains projections about the future, and therefore is not absolute fact. Business 

variables, market behaviors, and regulatory dictates influence what will actually happen. Currently in 

the United States, there are three primary purchasing customers of beverage vending machines. The 

installed populations are gross figures that are not absolutely accurate.

One of these dominant beverage vending machine purchasers (Coca-Cola) is publically committed to 

purchasing all vending machines with R-744 refrigeration going forward. We do not know about the 

other dominant purchasers. They are committed to buying HFC-free. But they have not announced a 

commitment to any refrigerant or any timetable. However, all of the US packaged beverage vending 

machine manufacturers have already developed a model for CO2 refrigerant. They all are developing 

their entire model portfolio for CO2 refrigerant. Full production of these models is dependent on EPA 

allowance of the refrigerant, which would open the door to R-744 machine purchases.

The large US beverage companies are all members of the United Nations Consumer Goods Forum and 

the Refrigerants Naturally! Consortium, and have all made the commitment (via those organizations) to 

begin transitioning their new vending machines to HFC-free refrigerants starting at-least by 2015.

The Coca-Cola Company has already committed to transitioning all of its vending machine purchases to 

CO2 refrigerant. The other large US beverage companies, in their transition to HFC-free refrigerants, will 

have to acquire at-least some of their machines in CO2 refrigerant because other HFC-free refrigerants 

have charge limitations, and thereby size limitations for the machines.

Because there will likely be other HFC-free refrigerant alternatives, there will likely never be the 

occurrence of 100% new machines with CO2 refrigerant. There will likely never be the occurrence of the 

entire vending machine population with CO2 refrigerant. Without regulatory mandates eliminating HFC 

refrigerants, the maximum likely saturation of CO2 refrigerant in beverage vending machines is 66%.

The likely period to full market penetration is twenty-nine years. The attached table illustrates the 

percentage change in the vending machine population. Without regulatory mandates eliminating HFC 

refrigerants, the maximum total production per year at market penetration is 45,000 machines.

The table provided is only an assumption, with Coca-Cola providing 100% of their annual purchases of 

vending machines as R-744, and with the other dominant purchasers acquiring only a percentage of 

their new vending machines as R-744.

None of these projections are confidential – just speculative.

We believe you are claiming the energy efficiency information in section II.B.2(b)(p.8 of SNAP form) ...
No. The energy efficiency information is not confidential. It is already public. We are not claiming it as 

CBI.

... and all of Attachments 1, “Technical document on R-744 refrigerated beverage vending machines”;

We are not claiming the entire document of Attachment 1. We are only claiming Table 2 at the end of 

the document as CBI.

3, “Energy efficiency of R-744 vending machine-test results”;

Yes. This is CBI.

This document is from the Sanden Corporation of Japan. Sanden declares that their in-house test data 

and refrigeration system performance variables are proprietary and confidential. Sanden makes money 

by building and selling R744 cooling cassettes, and do not want their business lucrative system 

performance details made public which causes them to lose a competitive advantage and potential 

sales.

“UL Advisory on New CO2”; as CBI

Yes. This is CBI.

It is the Underwriters Laboratories business practice to keep their compensated services confidential 

with their paid client. The Advisory references documents and opinions that are owned by UL, and UL 

has declared the document confidential. Coca-Cola is not at liberty to make it public.

... and you are not claiming the other parts of the submission as CBI.

Nothing else is CBI.

2. CBI Substantiation. Please substantiate your claims of confidential business information. For 

example, what is sensitive about this information and what would be the negative impact if this 

information were made public.

The below information is provided above, but it more directly relates to this question.

Attachments declared as CBI Rationale (reason why)

Attachment 1_Technical 

Document on R744 Refrigerated 

Beverage Vending Machines.pdf

The only part of this document 

that is CBI is Table 2 at the end 

of the document.

This table is from the Sanden Corporation of Japan. Sanden declares 

these their in-house test results of refrigeration system performance 

as proprietary and confidential. Sanden makes money by building 

and selling R744 cooling cassettes, and do not want their business 

lucrative system performance details made public which causes 

them to lose a competitive advantage and potential sales.

Attachment 3 _Energy efficiency 

of R744 Vending machine.pdf

This document is from the Sanden Corporation of Japan. Sanden 

declares that their in-house test data and refrigeration system 

performance variables are proprietary and confidential. Sanden 

makes money by building and selling R744 cooling cassettes, and do 

not want their business lucrative system performance details made 

public which causes them to lose a competitive advantage and 

potential sales.
Attachment 5b_ UL Advisory on 

New CO2.pdf

It is the Underwriters Laboratories business practice to keep their 

compensated services confidential with their paid client. The 

Advisory references documents and opinions that are owned by UL, 

and UL has declared the document confidential. Coca-Cola is not at 

liberty to make it public.

3. Equipment Changes for Retrofitting. The discussion in Attachment 1, “Technical document on R-744 

refrigerated beverage vending machines” seems to imply that substantial changes must be made to the 

refrigeration equipment when designing for R-744 refrigerant. In addition, Attachment 8, 

“supplementary exposure and safety information for R-744 beverage vending machines,” states, “R134a systems cannot be recharged using CO2.” Please clarify whether your submission of R-744 is for 

new refrigeration equipment only and not for retrofitting existing refrigeration systems to use R-744 

refrigerant. Note that we consider an existing cabinet using new refrigeration equipment (e.g., a new 

cassette using R-744) to be “new” equipment, not a “retrofit” of existing equipment.

The specific end-use is R-744 as a refrigerant substitute in new vending machines.

The design, constituent components, and configuration of an R-744 refrigeration system for vending 

machines are much different from the CFC-12 or HFC-134a refrigeration systems. The R-744 

refrigeration system operates at a much higher pressure than these other pre-existing CFC and HFC 

vending machines. The hermetic refrigeration systems of these pre-existing vending machines operate 

at pressures of 7 to 8 bar. The hermetic R-744 refrigeration system operates at 85 to 90 bar. The 

compressor of an R-12 or R-134a system cannot generate high enough pressures to make R-744 

effective, and the components of an R-12 or R-134a system cannot tolerate the high pressures of a 

properly operating R-744 system. Therefore R-744 cannot be used as a drop-in replacement for preexisting vending machine refrigeration systems.

This submission is for new equipment only.

4. Standards. Are there any additional industry standards specific to vending machines that would likely 

be followed in the U.S.? If so, what are those standards? How do they address issues with refrigerants 

under high pressure of transcritical systems?

The answer to this question is contained in Attachment 5b_ UL Advisory on New CO2.pdf.

ANSI/UL-541 (The Standard for Safety for Refrigerated Vending Machines) is the vending machine safety 

standard used by all in the United States. It accommodates high-pressure R-744 use in a vending 

machine.

CSA C22.2 No. 128-95 (The Standard for Vending Machines) is the vending machine safety standard 

referred to in Canada. It also addresses high-pressure R-744. Evaluation and treatment of R-744 is 

identical for ANSI/UL 541 and CAN/CSA-C22.2 No.128-95 with regard to the use of CO2 refrigerant.

Section 56 of the ANSI/UL-541 vending machine standard addresses refrigerants, and it points to UL2182 (Standard for Refrigerants) for general treatment of refrigerants.

Section 57 of ANSI/UL-541 addresses the refrigerant containing parts of the vending machine, and it 

specifically mentions treatment for R-744. This treatment is explained in detail in the Attachment 5b_ 
UL Advisory on New CO2.pdf. It explains how the R-744 refrigeration system for a vending machine is 

evaluated for safety per the ANSI/UL-541 standard.

ASHRAE 32.1-2010 covers vending machines, but it is a method of rating the performance, and does not 

cover handling or safety aspects of the equipment.

5. Exposure Estimates. Please confirm whether the exposure assessment in Attachment 6, “Carbon 

dioxide exposure information for R-744 beverage vending machines” assumes *no ventilation]. Do you 

have information on minimum and typical ventilation rates in places where vending machines are likely 

to be located? If so, please provide this information.

The exposures detailed in Attachment 6, “Carbon dioxide exposure information for R-744 beverage 

vending machines” are for scenarios where there is no ventilation (a very rare situation for vending 

machine placements). Although vending machines are always placed into locations where there is 

robust turnover of air (HVAC or outdoor locations) the documentation and installation manuals provided 

with and for beverage vending machines do not identify any environmental or atmospheric prerequisites for locating the machine. Coca-Cola has roughly 850,000 beverage vending machines in use 

within the United States, but we do not maintain an inventory or information on the range of ventilation 

rates for those varied locations. Almost all of these installations are public places. Nearly half of them 

are outdoor. The locations are so varied, that there cannot be criteria which can be construed as 

“typical.”

6. Charge Size. The SNAP information notice and Attachments 1, 6 and 8 say that the typical charge size 

will be 8 oz (`227 g). The compressor manufacturer’s manual that you provided with the draft 

submission says the charge should be [500 g]. Under what circumstances would the charge size be 

greater than 8 oz?

The compressor manual of the draft SNAP submission (Embraco Carbon Dioxide R744 Application 

Manual) states that the maximum R-744 charge size allowed for that specific compressor is 500 grams. 

A charge size that large is not necessary for the standard size vending machines.

There are currently 23 commercial beverage vending machine models available for purchase. These 

vending machines fit industry-standard size profiles and product capacities; there are six-different 

standard sizes. The dominant vending machine size in the marketplace – the 72”tall, 37”wide, 34”deep 

vending machine with a product capacity of 280 – 680 packages (dependent on package size) that is 

designed to perform under the environmental conditions of ASHRAE 32.1 would have an R-744 charge 

size of 8 ounces. In other words, a majority of the R-744 beverage vending machines will have a charge 

size of eight ounces.

The compressor manual of the draft SNAP submission (Embraco Carbon Dioxide R744 Application 

Manual) states that the largest R-744 charge size allowed using the Embraco EK compressor is 500 

grams. Although an Embraco EK compressor may be used in an R-744 vending machine, the other 

components of the refrigeration system (gas-cooler, cold-end heat exchanger, and associated tubing) 

will not need a charge size anywhere near 500 grams. In beverage vending machines the R-744 

refrigeration system will use a capillary tube expansion device (due to lack of commercial TXV or TEV), so 

the system will not have a receiver nor filter/dryer. Without a refrigerant reservoir, the system will not 

have a substantial charge.
The charge size may be larger for the large profile, shelf-styled Glass Front Vendors with 504 package 

capacity. But that size machine has not been sold commercially for four years, and may not have a 

future in commerce.

7. Market estimates. Are the market estimates in Attachment 9, “Supplementary information on the 

market penetration of R-744 vending machines,” referring only to vending machines that are installed 

and used in the U.S.? Or do they apply to the global market? 

Only the USA. Nothing internationally. This projection is only for the U.S. beverage vending business.

Please clarify why the full market penetration is assumed to occur [in year 29]. Is it expected that [the 

typical lifetime of a vending machine is 29 years and hence, after that,] the population of CO2 beverage 

vending machines as shown in the table would not grow (assuming non-CO2 models are not replaced 

with CO2 models)?

As Attachment 9 states, “100% CO2 refrigerant penetration will be improbable.” Although 

The Coca-Cola Company is committed to R-744 in 100% of new vending machine purchases, other major 

vending machine purchasers have expressed commitment to low-GWP refrigerants but not necessarily 

R-744.

This projection assumes:

 No government regulatory or statutory requirements mandating R-744 for refrigerated 

beverage vending.

 HFCs will remain allowable refrigerant options, without restrictions.

 Other low-GWP refrigerants (HFOs, HCs) will become approved by 2013.

 The overall population of beverage vending machines remain unchanged.

 Large US beverage company “A” purchasing 7,000, 12,000, 16,000, 20,000 and 26,000 R-744 

machines in years 2012 – 2016.

 Large US beverage company “A” purchasing 30,000 R-744 machines per year, for each year after 

2016.

 Large US beverage company “B” purchasing 4,000, 6,000 and 8000 R-744 machines in years 

2013 – 2015, with 10,000 R-744 machines in each of years 2016 – 2018, and 12,000 R-744 

machines in each of years 2019 – 2021.

 Large US beverage company “B” purchasing 15,000 R-744 machines per year, for each year after 

2021.

 Beverage vending machines with other refrigerants (HFCs, HCs, HFOs) will continue to be 

purchased and placed.

 Purchased vending machines are salvaged (scrapped) after a 13-year life.

Under these assumptions, R744 vending machines reach market saturation in 29 years, and does not 

exceed 66% of the installed base.

8. Placement in small unventilated spaces. Attachment 8 indicates “the manufacturer will add a 

warning in the installation manual regarding this possibility.” Please provide a manual that includes this 

warning.

Manuals for R-744 refrigerant vending machines do not exist yet because R-744 vending machines are 

not commercial yet. Should SNAP approval occur, then manufacturers will move forward, complete 

models, develop production capability, and supporting infrastructure including documentation and 

manuals.
If no manual with this warning has been produced, please verify that such statements will be added to 

the manuals and provide the text and graphics that will be included.

Coca-Cola does not manufacturer beverage vending machines, nor produce documentation for those 

machines. However, the guidance from the R-744 medium-temperature compressor manufacturers to 

the beverage vending machine manufacturers is to include this nature of warning. Such a caution occurs 

on page 2, 3, 5 and 7 of Attachment 7.

Also, the manufacturer of the R-744 refrigeration system used in the beverage vending machines that 

Coca-Cola has test marketed provides a warning about placement of cabinets with the refrigeration 

system in well ventilated areas. See page 6 (Installation & Preparation) of the “Service Manual –

SRC_SS40MZA” provided.

9. Claims of Confidentiality. In your response please include any claims of confidential business 

information, if you wish to claim any of the information submitted in response to the above as CBI.

No information in this response letter contains CBI.

Should additional information or greater clarity be needed to complete the R-744 SNAP application for 

the vending machine end-use, I can be contacted by telephone at (404) 676-5735, by e-mail at 

stcousins@coca-cola.com, or the address shown at the above-right.

Thank you.

Steven Cousins

Cold Drink Technical Manager

Coca-Cola Refreshments