Daikin AC (Americas), Inc.

1645 Wallace Drive, Suite 110

Carrollton, TX 75006 USA

TEL: 866-4DAIKIN

FAX: 972-245-1038

www.daikinac.com

February 8, 2013

Rebecca von dem Hagen Dave Godwin

Alternatives & Emissions Reduction Branch Alternatives & Emissions Reduction Branch

Stratospheric Protection Division Stratospheric Protection Division

Environmental Protection Agency Environmental Protection Agency

1310 L Street, NW 1310 L Street, NW

10th Floor (MC 6205J) 10th 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 providing 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 for HFC-32 (R32) in (1) household and light 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 R32 as an alternative refrigerant 

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 sent 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 R32 SNAP 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 R32 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 R32.

Daikin’s R32 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 R32 as the 

refrigerant in Japan in November 2012. These high-efficiency units being 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 refrigerant.

III. 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 conditioning and heat pumps 

(new uses only). In supplemental materials submitted to EPA on December 6, 2011, Daikin 

indicated that its R32 SNAP petition covers equipment that uses charges up to 8.8 kilograms (kg), 

or 19.4 pounds (lbs).

EPA is not required to wait 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, even if EPA determines that reliance on a safety standard is 

necessary 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 R32 in air conditioners and heat 

pumps within the scope of Daikin’s SNAP petition, Daikin observes that the UL Standard for 

Safety for Room Air Conditioners (Eighth Edition including revisions through August 3, 2012)

(UL 484), applies to a significant portion of the equipment covered 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 70.

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. These 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 conditioner may additionally 

serve a single adjacent room. Such units employ cabinet or enclosure 
Daikin 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 

employ 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 establishes safety standards for products within the scope of UL 484 that employ 

refrigerants with flammable characteristics. Specifically, Supplement SA establishes product 

construction requirements (SA4), leakage, ignition and temperature testing requirements (SA5), 

and marking, installation and operating instruction requirements (SA6) for systems governed by 

UL 484 employing flammable refrigerants. 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 refrigerant mass (M) of all refrigerating systems within the 

appliance employing flammable refrigerants shall not exceed m2 as defined in Appendix F.” 

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

conditioners based 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 covered by UL 484.

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

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

for all installations. None of the equipment within the scope of Daikin’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 

classes of products under Daikin’s R32 SNAP petition 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 Standard, 

and by the references to reverse cycle heating tests for heat pumps in Table 35.1 and Section 36 

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 that 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 

scope 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