Steven Cousins Cold Drink Technical Manager Cooler & Vender Platform Group Coca

- Cola Refreshments One Coc a - 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., N W 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 Jap an. Sanden declares this in

- house test results of refr igeration 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 advan tage 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. Att achment 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 confide ntial. 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 decla red 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 futur e, 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 ins talled 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 mo del 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 bever age 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 start ing 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
occ urrence 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 sa turation of CO2 ref rigerant 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 refriger ants, 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 ac quiring 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 effici ency 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 ar e 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 refriger ation 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 com pensated services confidential with their paid client. The Advisory references documents and opini ons 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 substantia te 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 t o 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 th e 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 lucra tive 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 th eir 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 whic h 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 refere nces 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 refrig erated beverage vending machines” seems to imply that substantial changes must be made to the refrigeration equipment when designing for R

- 744 refrigerant. In addition, A ttachment 8, “supplementary exp osure and safety information for R

- 744 beverage vendin g machines,” states, “R

134a 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 co nsider 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

- ex isting 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 syst em 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 pre

exist ing 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? H ow 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 th e 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 a lso 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 UL

2182 (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 explaine d 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 ratin g 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 informa tion 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 out door locations) the documentation and installation manuals provided with and for beverage vending machines do not identify any environmental or atmospheric pre

requisites for locating the machine. Coca

- Cola has roughly 850,000 beverage vending machines in use within the United States, but w e 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 va ried, 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 provid ed 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 maxim um 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
ven ding 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 pac kages (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 u se 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 la rge 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, “Supplem entary 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
v ending 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% o f 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 refrigerate d 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 year s, 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 supporti ng 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 manufactu rer 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 cauti on 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 i n 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.

S hould 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 t he address shown at the above

- right

.

Thank you.

Steven Cousins Cold Drink Te chnical Manager Coca

- Cola Refreshments