From: VonDemHagen, Rebecca To: "David Berchowitz" Cc: Sheppard, Margaret Bcc: Fiffer, Melissa ; Newberg, Cindy Subject: Re: SNAP submission received for Ethane in very low temp Date: Tuesday, April 09, 2013 5:28:00 PM


### Dear Mr. Berchowitz, Thank you for the additional information submitted to the Significant New Alternatives Policy ( SNAP) program via e-mail on December 7, 2012 and March 19, 2013. Below are the Agency’s responses. Your submission remains incomplete. The remaining outstanding information that must be submitted to the Agency to complete Global Cooling’s SNAP application includes a flammability assessment and information on flammability characteristic. Please let me know if you have any additional questions. 1. CBI Claims. It is the understanding of the Agency that the submission does not contain CBI. 2. Standards . In your response you indicate that you will follow ASHRAE 15. On March 19, 2013 you also provided information that UL has begun testing of ‘very low temperature’ applications using UL 471, commercial refrigeration standard, and Supplement SB. Upon completion of this testing by UL, please submit the results to the Agency. 3. Flammability Assessment . The UL Standards are a very useful tool for developing mitigation methods; however, they do not function as flammability risk assessments. A flammability assessment should consist of two parts. The first is a fault tree analysis, fault mode effects analysis or other flammability analysis. A fault tree analysis identifies all of the areas where exposure could occur and then calculates a probability of adverse events. Below are links to documents that may serve as a useful framework for your assessment. The second part is a full characterization of typical and worst-case exposure including the size of the space in which the freezer is being used, the typical and maximum charge size, and an analysis of maximum exposure rate versus lower flammability limit. This information can be combined to form a complete flammability assessment.

o Ben & Jerry’s (see Attachment A). http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2003-0118-0242

o Example of a fault tree for household refrigerators and freezers: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0286-0023 4. Servicing. Thank you for providing a copy of your service man ual. No further information is required for this item.

### 5. Training . The Agency believes that the service manual is sufficient to serve as a basis for training. No further information is required for this item. 6. Refrigerant Recovery Equipment . In your response you indicated that you will use hydrocarbon refrigerant recovery equipment such as, “The Caresaver Universal Refrigerant Recovery Unit”. You also asked if following the process recommended by the manufacturer of the equipment would be sufficient. Hydrocarbon refrigerant recovery equipment, used in accordance with the manufacturer’s instructions, is sufficient. No further information is required for this item. 7. Flammability Properties . In response to the Agency’s request for maximum rate of pressure increase during combustion you requested additional information on how to conduct the study. The Agency has identified an example of an open literature source that could be used to obtain the information necessary for your SNAP application without conducting additional testing. Minimal calculations may be necessary to adjust the available information for your specific submission and to provide the information in units of bar/sec, psi/sec or kPa/sec. http://www.morechemistry.com/SAFEKINEX/deliverables/46.Del.%20No.%209.pdf 8. Additional CBI. The Agency requests that you specify the presence of CBI in all aspects of the submission process because all material not marked CBI will be made public when a final decision is made. Question 1 asks if you wish to mark any subject matter confidential in your application. This question (8) asks if you’d like to mark anything in this specific correspondence as confidential. At this time, it is the understanding of the Agency that none of the material submitted by Global Cooling is confidential. If you ’ d like any submitted material or correspondence to remain confidential, please let us know. Thank you, Rebecca von dem Hagen Stratospheric Protection Division Office of Atmospheric Programs U.S. Environmental Protection Agency (202) 343-9445 vondemhagen.rebecca@epa.gov ----- Forwarded by Melissa Fiffer/DC/USEPA/US on 01/29/2013 10:09 AM -----
From: David Berchowitz < dberchowitz@globalcooling.com >To: Melissa Fiffer/DC/USEPA/US@EPA Cc: Dave Godwin/DC/USEPA/US@EPA, Margaret Sheppard/DC/USEPA/US@EPA, Neill Lane < nlane@globalcooling.com > Date: 12/07/2012 11:43 AM Subject: Re: SNAP submission received for Ethane in very low temp 

### Hi Melissa, Thank you for your letter. I apologize for not responding immediately, I was unavailable for two weeks but I am trying to get back on top of this as it is an urgent matter for us. I'll take the points one by one in your letter to me: 1. I indicated explicitly that we make no CBI claims in the original submitted material. So, for the record, we have no objection that our submission be entirely available to the public. 2. I do not know of any specific industry standards other than ASHRAE 15 specific to laboratory equipment used in very low temperature refrigeration that address flammable refrigerants. We are engaged with Underwriter's Laboratories with this matter and they will apply the commercial refrigeration standard UL471. Please note that this is a commercial standard not a laboratory equipment standard. 3. Flammability assessment. We will provide the requested fault tree analysis, quantitative flammability risk analysis, fault mode effects analysis as requested. Do you have such an analysis for commercial refrigeration that you could share with us, since flammable refrigerants are already acceptable under SNAP for those applications? 4. We will provide the service manual for service technicians. 5. We have no training program or guidance materials for end users and service technicians other than what will be in the product manual. We will provide that. Is this material essential in order to qualify this refrigerant? 6. Refrigerant recovery equipment. We specified that hydrocarbon refrigerant recovery equipment must be used. The name of the example given is "The Caresaver Universal Refrigerant Recovery Unit". This is a standard unit for the process. Would the process recommended by the manufacturer of this equipment be sufficient? 7. You ask us to provide the maximum rate of pressure increase during combustion for R-170 (ethane). We do not have this information and we have difficulties understanding how this determination should be made. Could you please give us some guidance as to how we might obtain this information? For example, are we to assume stoichiometric combustion or is there excess air? If there is excess air, how much should we assume? Do we assume constant volume or constant pressure conditions? 8. I think this is a repeat of question 1. Please let me know if it is different.

### Would you be available next week for a call to discuss this matter further? If so, could you please suggest a time. Thanks and best regards, Dave Berchowitz On Nov 20, 2012, at 6:39 PM, Fiffer.Melissa@epamail.epa.gov wrote: Hi Dave, Attached please find an incompleteness letter detailing our review team's questions on your submission for ethane in very low temperature refrigeration. A hard copy will follow in the mail. Please feel free to contact me with any questions. Thanks and have a nice Thanksgiving, Melissa 

### (See attached file: SNAP incompleteness ltr_R170_11.20.12.pdf) Melissa Fiffer Stratospheric Protection Division U.S. Environmental Protection Agency Office: (202) 343-9464 Mobile: (202) 500-3531 Fiffer.Melissa@epa.gov 

### <19918648.gif> Protecting our atmosphere for generations to come 25 years of the Montreal Protocol 

### <graycol.gif> David Berchowitz ---10/24/2012 02:14:36 PM---Thanks, Margaret. I'll look into this immediately. Our concern is that we want to ship our products

From: David Berchowitz < dberchowitz@globalcooling.com >

To: Margaret Sheppard/DC/USEPA/US@EPA

Cc: Dave Godwin/DC/USEPA/US@EPA, Melissa Fiffer/DC/USEPA/US@EPA, "Neill Lane" < nlane@globalcooling.com >

Date: 10/24/2012 02:14 PM Subject: Re: SNAP submission received for Ethane in heat transfer/very low temp



### Thanks, Margaret.

### I'll look into this immediately. Our concern is that we want to ship our products and we believe that we are following SNAP guidelines for hydrocarbons already. The only distinction is that this hydrocarbon is not listed as a SNAP drop in but it is very similar to hydrocarbons already accepted by the EPA under the SNAP program. Thanks again, Dave Berchowitz On Oct 24, 2012, at 11:26 AM, Sheppard.Margaret@epamail.epa.gov wrote: Dave, Melissa is out of the office this week. We've looked at your submission and find it is missing some of the information we will need to do our technical review. We are preparing a letter that will state the information that we require for our review. That letter is still undergoing internal review. A heads up--one major area where we need more information is on the flammability risk assessment. We typically expect a fault tree analysis, which estimates the likelihood of the different events and conditions that could lead to ignition. A fault mode effects analysis, that identifies parts of the equipment that might fail and identifies steps to be taken to address those potential failure modes, would also meet that need for flammability risk assessment. Margaret Sheppard Environmental Scientist Significant New Alternatives Policy Program USEPA/Stratospheric Protection Division Tel. 202-343-9163 Fax 202-343-2338 email: sheppard.margaret@epa.gov -----David Berchowitz < dberchowitz@globalcooling.com > wrote: ----- To: Melissa Fiffer/DC/USEPA/US@EPA From: David Berchowitz < dberchowitz@globalcooling.com > Date: 10/23/2012 05:39PM Cc: Margaret Sheppard/DC/USEPA/US@EPA, Neill Lane < nlane@globalcooling.com >, Dave Godwin/DC/USEPA/US@EPA Subject: Re: SNAP submission received for Ethane in heat transfer/very low tempDear Melissa, Do you have an update on our SNAP submission? Thanks so much, Dave Berchowitz On Aug 28, 2012, at 5:19 PM, Melissa Fiffer < Fiffer.Melissa@epamail.epa.gov > wrote: Hi Dave, Our review team is taking a look at the submission. I will let you know if questions arise. It may take another month or so for us to determine whether the submission is complete. Thanks, Melissa Melissa Fiffer Stratospheric Protection Division U.S. Environmental Protection Agency Office: (202) 343-9464 Mobile: (202) 500-3531 Fiffer.Melissa@epa.gov 

### <11626714.gif> Protecting our atmosphere for generations to come 25 years of the Montreal Protocol <graycol.gif> David Berchowitz ---08/27/2012 02:29:17 PM---Dear Ms. Fiffer, I was wondering if you could give me some idea of progress on our Snap

From: David Berchowitz < dberchowitz@globalcooling.com >

To: Melissa Fiffer/DC/USEPA/US@EPA

Cc: Margaret Sheppard/DC/USEPA/US@EPA, Neill Lane < nlane@globalcooling.com >

Date: 08/27/2012 02:29 PM Subject: Re: SNAP submission received for Ethane in heat transfer/very low temp Dear Ms. Fiffer, I was wondering if you could give me some idea of progress on our Snap submission?Thanks so much, <11592023.gif>
Dave Berchowitz
CTO 6000 Poston Road Athens, Ohio 45701, USA

t: 740.274.7925 m: 740.591.2585 f: 740.274.7901 www.stirlingultracold.com
Like us on Facebook CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and contains confidential and/or privileged material belonging to Global Cooling BV and / or Global Cooling Inc. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately. From: Melissa Fiffer < Fiffer.Melissa@epamail.epa.gov > Date: Wednesday, August 8, 2012 5:50 PM To: David Berchowitz < dberchowitz@globalcooling.com > Cc: Margaret Sheppard < Sheppard.Margaret@epamail.epa.gov >, Neill Lane < nlane@globalcooling.com > Subject: Re: SNAP submission received for Ethane in heat transfer/very low temp Hi Dave, Thank you for the confirmation. We'll be in touch. Best, Melissa Melissa Fiffer Stratospheric Protection Division U.S. Environmental Protection Agency Office: (202) 343-9464 Mobile: (202) 500-3531 Fiffer.Melissa@epa.gov 

### <11626714.gif>Protecting our atmosphere for generations to come 25 years of the Montreal Protocol <graycol.gif> David Berchowitz ---08/08/2012 05:41:51 PM---Dear Ms. Fiffer, Thank you for your message.

From: David Berchowitz < dberchowitz@globalcooling.com >

To: Melissa Fiffer/DC/USEPA/US@EPA

Cc: Margaret Sheppard/DC/USEPA/US@EPA, Neill Lane < nlane@globalcooling.com >

Date: 08/08/2012 05:41 PM Subject: Re: SNAP submission received for Ethane in heat transfer/very low temp

Dear Ms. Fiffer, Thank you for your message. I confirm that nothing in the submission is to be considered confidential business information. I too am looking forward to working with you. With best regards, Dave Berchowitz <11592023.gif>
Dave Berchowitz
CTO 6000 Poston Road Athens, Ohio 45701, USA

t: 740.274.7925 m: 740.591.2585 f: 740.274.7901 www.stirlingultracold.com
Like us on Facebook CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and contains confidential and/or privileged material belonging to Global Cooling BV and / or Global Cooling Inc. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately. From: Melissa Fiffer < Fiffer.Melissa@epamail.epa.gov > Date: Wednesday, August 8, 2012 4:28 PMTo: David Berchowitz < dberchowitz@globalcooling.com > Cc: Margaret Sheppard < Sheppard.Margaret@epamail.epa.gov > Subject: SNAP submission received for Ethane in heat transfer/very low temp Dear Mr. Berchowitz, I am writing to confirm that the EPA SNAP program has receivedyour submission for use of ethane in the following two end-uses: nonmechanical heat transfer and very low temperature refrigeration. Please confirm that nothing in the submission is to be considered confidential business information. The SNAP submission process is often a dialogue, and we look forward to working with you as we review your submission. We will let you know whether we need further information in order to complete our review. Please feel free to contact me should you have any questions. Thank you, Melissa Melissa Fiffer Stratospheric Protection Division U.S. Environmental Protection Agency Office: (202) 343-9464 Mobile: (202) 500-3531 Fiffer.Melissa@epa.gov 

### <11626714.gif> Protecting our atmosphere for generations to come 25 years of the Montreal Protocol

< Image.791111DB-F746-42AA-812D-DC435AD79AC7@OffWhite.local.jpg >

Dave Berchowitz CTO 6000 Poston Road Athens, Ohio 45701, USA t: 740.274.7925 m: 740.591.2585www.stirlingultracold.com Like us on Facebook CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and contains confidential and/or privileged material belonging to Global Cooling BV and / or Global Cooling Inc. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately. 

### <19466374.jpg>

Dave Berchowitz CTO 6000 Poston Road Athens, Ohio 45701, USA t: 740.274.7925 m: 740.591.2585 www.stirlingultracold.com Like us on Facebook CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and contains confidential and/or privileged material belonging to Global Cooling BV and / or Global Cooling Inc. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately. <SNAP incompleteness ltr_R170_11.20.12.pdf>

Dave Berchowitz CTO

6000 Poston Road Athens, Ohio 45701, USA

### t: 740.274.7925 m: 740.591.2585

www.stirlingultracold.com Like us on Facebook

CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and contains confidential and/or privileged material belonging to Global Cooling BV and / or Global Cooling Inc. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately.