Daikin AC (Americas), Inc.

1645 Wallace Drive, Suite 110
Carrollton, TX 75006 USA TEL: 866

- 4DAIKIN

FAX: 972

- 245

- 1038

www.d aikinac.com

February 8 , 2013

Rebecca von dem Hagen Dave Godwin

Alternatives & Emissions Reduction Branch Alternatives & Emissions Reduction Branch

S tratospheric Protection Division Stratospheric Protection Division Environmental Protection Agency Environmen tal Protection Agency 1310 L Street, NW 1310 L Street, NW

10 th Floor (MC 6205J) 10 th Floor (MC 6205J) Washington, DC 20005 Washington, DC 20005

RE: Supplemental Information Regarding, and Request for Expedited Procedural Approach to Approval of, Daikin U.S. Corporation’s Pending SNAP Petition for

HFC

- 32 in Residential and Light Commercial Air Conditioners and Heat Pumps

VIA EMAIL AND U.S. MAIL FIRST CLASS MAIL

Dear Ms. von dem Hagen and Mr. Godwin :

Daikin U.S. Corporation (Daikin) is pr oviding the following supplemental information to the Environmental Protection Agency (EPA) , and is making the following request for an expedited procedural approach to EPA , regarding Daikin’s pending Significant New Alternatives Program ( SNAP ) petition fo r HFC

- 32 (R 32) in (1) household and l ight commercial air conditioning (new uses only), and (2) residential air conditioning and heat pumps (new uses only)

.

I. BACKGROUND

Daikin filed a SNAP petition with EPA requesting approval of R 32 as an a lternative r efrigerant

for HCFC

- 22 and CFC

- 12 in residential and light commercial air conditioners and heat pumps on June 13, 2011. After filing the petition, Daikin provided supplemental information in support of its petition to EPA on several occasions, and EPA sen t Daikin a Completeness Determination Letter dated May 23, 2012, initiating EPA’s 90

- day review period pursuant to 40 C.F.R. § 82.180(a)(4). In its Completeness Determination Letter, EPA found the information that Daikin submitted in support of its R 32 SN AP petition “to be complete for the residential air conditioning and light commercial air conditioning and heat pumps end use.”

On November 1, 2012, Daikin submitted additional information to EPA in relation to the pending R 32 SNAP petition. The November 1, 2012 submittal was new information under 40

C.F.R. § 82.180(a)(5), consisting of a risk assessment of heat pumps using 2L refrigerants

, including R 32.

Daikin’s R 32 SNAP petition remains under consideration by EPA’s Alternatives and Emissions

Reduction Branch at this time.Daikin Supplemental Information on R32 SNAP Petition Page 2

II. ADDITIONAL INFORMATION

Daikin is informing EPA that Daikin introduced split system heat pumps using R 32 as the refrigerant in Japan in November 2 012. These high

- efficiency units be ing sold in Japan range

from 2.2 kW to 7.1 kW in cooling capacity. The Japanese market is responding favorably to

these new products due to their high

- energy efficiency and use of a lower

- GWP refriger ant.

I II. SAFETY STANDARDS APPLICABLE TO SOME USES COVERED BY PETITION

Daikin’s petition and supplemental materials requested approval for: (1) household and light commercial air conditioning (new uses only), and (2) residential air conditi oning an d heat pumps (new uses only). In supplemental materials submitted to EPA on December 6, 2011 , Daikin

indicated that its R 32 SNAP petition covers equipment that uses charges up to 8.8 kilograms ( kg )

,

or 19.4 pounds (lbs)

.

EPA is not required to wa it to take any action on Daikin’s R32 SNAP petition until EPA

concludes it has a definitive basis to approve or disapprove all equipment categories covered by Daikin’s petition. For example, e ven i f EPA determines that reliance on a safety standard is

nec essary for approval but that no safety standards currently apply to some R32 equipment and applications within the scope of Daikin’s R32 SNAP petition, EPA can still proceed now to approve all R32 equipment categories covered by Daikin’s petition for which EPA finds that safety standards presently exist, provided that all other regulatory approval criteria are met.

In the context of safety standards that may apply to uses of R 32 in air conditioners and heat pumps within the scope of Daikin’s SNAP petiti on, Daikin observes that the UL Standard for Safety for Room Air Condi tioners ( Eighth Edition including revisions through August 3, 2012 ) (UL 484) , applies to a significant portion of the equipment cove red by Daikin’s SNAP petition.

The scope of UL 484 is established in Section 1 of the standard, which provides:

1.1 These requirements cover room air conditioners rated not more than 600 volts alternating current (ac) and intended for installation in accordance with the National Electrical Code, ANSI/NFPA 7 0.

1.2 For the purposes of this standard, room air conditioners include packaged terminal air conditioners, special purpose air conditioners, and recreational

vehicle air conditioners. They are factory

- made encased assemblies designed as a unit primarily to provide free delivery of conditioned air to an enclosed space, room, or zone. This equipment is intended for installation in a window, through a wall, or as a console located in or adjacent to the room, zone, or space intended to

be conditioned. Thes e units employ hermetic refrigerant motor

- compressors with factory

- charged refrigeration systems and include means for circulating air. They may also have provision for heating and ventilation.

1.3 With regard to 1.2, a console or in

- wall type air condit ioner may additionally serve a single adjacent room. Such units employ cabinet or enclosureDaikin Supplemental Information on R32 SNAP Petition Page 3

constructions permitting attachment of an air discharge adapter or duct which extends into the adjacent room. Recreational vehicle air conditioners may also emplo y a limited amount of ductwork.

1.4 These requirements do not cover equipment intended for connection to duct systems for the purpose of providing central cooling, heating, or both.

UL 484 was amended effective October 21, 2011 to include Supplement SA, Requirements for Room Air Conditioners Employing a Flammable Refrigerant in the Refrigerating System. Supplement SA es tablishes safety standards for products within the scope of UL 484 that employ refrigerants with flammable characteristics . S pecificall y, S upplement SA establishes product

construction requirements (SA4)

, leakage, ignition and temperature testing requirements (SA5)

, and marking, installation and op e rating instruction requirements (SA6) for systems governed by UL 484 employing flammable re frigerants. The requirements of Supplement SA are in addition to the applicable requirements of UL 484 (SA1.3).

Supplement SA also limits the total charge size for refrigerants with flammable characteristics in SA3.3, providing that: “The total refrigera nt mass (M) of all refrigerating systems within the appliance employing flammable refrigerants shall not exceed m 2 as defined in Appendix F.”

Appendix F to UL 484 establishes total charge size limits for flammable refrigerants in room air

conditioners b ased on several factors including installation location, type of ventilation, lower flammability limit, and floor area where a unit will be installed. Appendix F establishes a maximum charge size for R32 in Table F.4 of 8.85 kg (19.5 lbs) for systems cove red by UL 484.

Trained contractors, not consumers, would install all of the equipment within the scope of

Dai kin’s R32 SNAP petition, and the contractors would determine the proper equipment sizing

for all installations . None of the equipment within the scope of Dai kin’s R32 SNAP petition

would be available for direct consumer purchase at retail locations.

IV. REQUEST FOR EXPEDITED PROCEDURAL APPROACH AND PARTIAL APPROVAL

There are several categories of equipment within the scope of Daikin’s R32 SNAP petition that are covered by UL 484, including

, but not limited to, mini

- split systems, packaged terminal air

conditioners and packaged terminal heat pumps

. Daikin strongly urges EPA to approve these

clas ses of products under Daikin’s R32 SNAP pe tition on an expedited basis.

For clarification, heat pumps are included within the scope of UL 484, as evidenced by the

inclusion of the definition for “ Packaged Terminal Heat Pump” in Section 3.16 of the Standar d, and by the references to reverse cycle heating tests for heat pu mps in Table 35.1 and Section 3 6

of the Standard.

If EPA decides to act in the near term on Daikin’s R32 SNAP petition on the product classes within the scope of UL 484, Daikin requests th at EPA not disapprove the other product classes,

but instead continue to hold them under review until EPA has an adequate basis to approve them.Daikin Supplemental Information on R32 SNAP Petition Page 4

V

. CONCLUSION

Daikin requests that EPA approve on an expedited basis all categories of equipment within the

s cope of Daikin’s R32 SNAP petition that are covered by UL 484, including mini

- split systems, packaged terminal air conditioners and packaged terminal heat pumps . If EPA decides to partially approve Daikin’s R32 SNAP petition for the product classes within the scope of UL 484, Daikin requests that EPA continue its review of all other product classes within the scope of Daikin’s R32 SNAP petition until EPA has an adequate basis to approve them.

Sincerely,

Mark V. Stanga for Daikin U.S. Corporation

cc:

SNAP Document Control Officer Office of Air and Radiation, 6205J

U.S. EPA 1200 Pennsylvania Ave., N.W. Washington, DC 20460