Bjorn Skattberg 

Frigadon AB 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

SEP 2 9 2015 

OFFICE OF 

AIR AND RADIATION 

K vamdalsvagen 12 

SE-30241 

Halmstad, Sweden 

Re: Incomplete SNAP Submission for R-1270 (Propylene) in Chillers (Commercial Comfort Air 

Conditioning) and Cold Storage Warehouses 

Dear Mr. Skattberg: 

Thank you for the additional information you provided in your June 24, 2015, letter regarding 

Frigadon AB 's submission to the Environmental Protection Agency's (EPA's) Significant New 

Alternatives Policy (SNAP) program. The EPA established the SNAP program to implement 

section 612 of the Clean Air Act. Your revised submission has been reviewed for completeness 

as part of the initial SNAP review. We find the submission to be incomplete. To be able to 

complete the SNAP submission review, EPA requires the following information: 

1. Occupational Exposure and Safety Precautions. In Part III, Section C, the submission 

states that workers may be exposed to the proposed substitute at the " testing facility, 

during factory commissioning." 

a. Please provide information on guidance and training for workers who may come 

into contact with this refrigerant during the scenarios you have outlined in Part III, 

Section C of your application. 

1. Please provide information on safety precautions to be implemented 

during maintenance, repair, service, disposal, and transport of equipment 

using R-1270 refrigerant. If you have prepared any manuals or training 

documents, please include those. 

11. If available, please provide examples of recommended warnings, markings 

or labels that would go on equipment. 

111. In the United States there are strict requirements for the transportation of 

hazardous material. Applicable U.S. Department ofTransportation 

regulations are located in 49 CFR Subtitle B. Please explain how you 

intend to comply for R-1270 cylinders and equipment pre-charged with R1270. 

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Internet Address (URL) • http //www epa gov 

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b. Please clarify whether the equipment using the proposed substitute is expected to 

be charged during manufacture, installation, or a combination of both. 

1. If charging occurs at the manufacture site, is the unit entirely sealed before 

it leaves the manufacturing site? 

11. If charging does not ·occur at the manufacture site, where is the equipment 

charged? 

1. Will equipment charged at the end-use site containing the proposed 

substitute always be installed and/or charged outdoors? 

2. If not, what are typical values for ventilation in air changes per 

hour at the inside charging location? 

3. If not, what control technologies are used to prevent releases of the 

substitute to air inside the fac ility during charging? 

4. If you have monitoring information on occupations exposure levels 

during installation, please provide this information. 

2. Environmental Releases. In Part III, Section 0 , Parts (a) and (c), the submission states 

that there are no releases to the environment at end-use, and that a qualified engineer 

empties the substitute into a refrigerant cylinder for gas destruction or re-use. 

a. Please specify what control technologies (e.g., collection, recycling, reclamation, 

and/or destruction) are used to limit releases of the substitute to air at end-use and 

recovery of the proposed substitute. 

3. Resource Conservation and Recovery Act (RCRA). In Part III, Section 0 , Part (d), the 

submission states that RCRA requirements are "N/ A" for releases of the proposed 

substitute. However, hydrocarbons being recovered, vented, or otherwise disposed of 

from commercial and industrial appliances are likely to be hazardous waste under RCRA 

(see 40 CFR Parts 261- 270). As discussed in U.S. EPA's Final Rule (Protection of 

Stratospheric Ozone: Listing of Substitutes for Refrigeration and Air Conditioning and 

Revision of the Venting Prohibition for Certain Refrigerant Substitutes), which allows for 

the venting of isobutane (R-600a) and R-441A as refrigerant substitutes in household 

refrigerators, freezers, and combination refrigerators and freezers, and propane (R-290) 

as a refrigerant substitute in retail food refrigerators and freezers (stand-alone units only), 

incidental releases may occur during the maintenance, service, and repair of appliances. 

This activity would also not be subject to RCRA requirements for the disposal of 

hazardous waste, as such releases would not constitute disposal of the refrigerant charge 

as a solid waste, per se. 

However, for commercial and industrial appliances, it is likely that flammable 

hydrocarbon refrigerants would be classified as hazardous waste and would need to be 

managed as hazardous waste under the RCRA regulations (40 CFR parts 261- 270). 

a. Given that hydrocarbons from commercial and industrial appliances are likely to 

be hazardous waste under RCRA, please identify the applicable RCRA hazardous 

waste codes, and provide a description of how you intend to comply. 

4. Fault Tree Analysis. Please provide quantitative estimates of the probability of different 

events in the fault tree analysis on page 6 of the SNAP application (Part II, Section A, 

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item 28), and provide the source of the infonnation. Also, please provide separate fault 

tree analyses for chillers and cold storage warehouses. The probabilities should differ for 

each. 

5. Refrigerant Recycling In Part III, Section 0, Part (f), the submission states that 

information on recycling of the substitute is "N/A. " Please provide information on how 

R -1270 could be recovered and recycled during servicing or at the end of the life of the 

product. This should include any additional training, guideline updates, and equipment 

needs. 

a. Please provide a description of how you propose that the refrigerant be handled 

upon disposal, including the procedures and types of equipment involved. 

b. Please provide standards, reports, or analyses from ETL, UL, AHRI, or equivalent 

on refrigerant-specific servicing equipment or the feasibility of using existing 

refrigerant recovery/recycling equipment. 

c. Also, the Agency would be interested to know if you expect that, if the equipment 

stops working properly, the chillers and cold storage warehouses will typically be 

serviced or instead, the equipment will be disposed of and replaced. 

6. CBI Claims. If you wish to claim any of the information submitted in response to the 

above as CBI, please provide two copies of your response, one containing CBI and one 

with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: R- 1270 (Propylene) 

Sector: Refrigeration and Air Conditioning 

End-uses: Chillers (Commercial Comfort Air Conditioning); Cold Storage Warehouses 

New or Retrofit usage: ew Equipment 

Date received: June 24, 20 15 

Status of submission: Incomplete 

Responses to these questions are necessary for us to begin our review. The information can be 

submitted via electronic mail or hard copy. Please direct any questions about your submission to 

me, the case manager for this submission. I can be reached at (202) 564-7768 or 

Farquharson. Chenise(ci),epa. QO-v . 

Sincerely, ,., 

CJU!J~(JJ} y~~~ Chenise Farquharson 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division 

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