### Additional Questions Monica Shimamura to: Kline, Kelley (GE Indust, ConsInd) 10/03/2008 07:18 PM Cc: Margaret Sheppard, Dave Godwin, Karen Thundiyil
Follow Up: Normal Priority.



### Hi Kelley, Thank you for your e-mail response concerning Monday. We are looking forward to the call. I wanted to share with you some questions from the SNAP team that will help us evaluate the GE submission.

Design and Risk Engineering - Please provide a list of all components for which GE created 1. an FMEA. On that list, please identify those components which GE thought were the greatest concern or risk for creating flammable conditions, both through your own analysis and experience and through your review of the A. D. Little paper and other literature. From your 9/30/08 presentation, we know some of these components -- were there others? Label - Please provide a sample permanent label that distinguishes the hydrocarbon 2. refrigerator from a non-hydrocarbon refrigerator. We would have concern if the current label had small print, did not clearly distinguish a hydrocarbon refrigerator from any other refrigerator easily, or could potentially fade or fall off. Do you think this is possible, and if so, could the label be redesigned -- e.g. with larger print and/or a colored background -- to reduce these concerns? Are there other possible color or physical differentiations to the refrigerator itself to identify 3. to technicians or disposal workers that the refrigerator has a flammable refrigerant? For example, could different refrigerant fittings be used on the refrigerant service ports (as is required for the use of flammable HFC-152a in motor vehicle air conditioners) to prevent charging an HFC into the system and to prevent recovering the hydrocarbon into an HFC cylinder? Could the ports or refrigerant tubing be a distinct color (e.g., red, similar to the use of an orange wire in hybrid cars to denote the fact that the wire is not the usual wire found in cars)? Servicing & Disposal - Is the planned HC refrigerant recovery equipment (using the GE 4. activated carbon method to recover the refrigerant) built to any particular industry standard (ISO, AHRI, UL, etc)? Is the carbon canister used on its own, or will it be used together with refrigerant recovery equipment? How much of the refrigerant will be captured, and how fast over time? Please expand further on what is stated in the current draft submission about disposal. (this is in addition to the previous inquiry on GE's take back scheme) How will GE ensure safe use and disposal after the refrigerator leaves the manufacturing facility? Training - What kind of training program and guidance will you provide? What will you do 5. to encourage servicing only by properly trained personnel?
Thank you and have a great weekend as well! Cheers, Monica

Monica Shimamura U.S. Environmental Protection AgencyStratospheric Protection Division 1200 Pennsylvania Ave. NW (6205J) Washington DC 20460 (tel) 202.343.9337 (fax) 202.343.2362
Address for hand delivery (UPS/Fed Ex/etc): 1310 L St. NW, 10th Floor (1027N) Washington DC 20005
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"Kline, Kelley (GE Indust, ConsInd)" <Kelley.Kline@ge.com>

"Kline, Kelley (GE Indust, ConsInd)" <Kelley.Kline@ge.com>
10/03/2008 02:52 PM To Monica Shimamura/DC/USEPA/US@EPA

cc Subject RE: FMEA

Monica,

My apologies. I just realized I had not yet respnded to you here. 2:30 on Monday works great for us. We can use the same number we have been, which is (888) 455-7074, participant code 1518241. We will send you a copy in advance of the call.

Thanks, and hope you have a great weekend!

Kelley

-----Original Message----- From: Shimamura.Monica@epamail.epa.gov [ mailto:Shimamura.Monica@epamail.epa.gov] Sent: Wednesday, October 01, 2008 5:11 PM To: Kline, Kelley (GE Indust, ConsInd) Subject: Re: FMEA

Hi Kelley, Thank you for your time as well. How about Monday Oct 6 at 2:30 for the FMEA conference call? From our end, it will be Dave Godwin and maybe Margaret Sheppard. An advance copy of the FMEA will be greatly appreciated.

We look forward to your SNAP application. Cheers, Monica

Monica Shimamura U.S. Environmental Protection Agency Stratospheric Protection Division 1200 Pennsylvania Ave. NW (6205J)Washington DC 20460 (tel) 202.343.9337 (fax) 202.343.2362

Address for hand delivery (UPS/Fed Ex/etc): 1310 L St. NW, 10th Floor (1027N) Washington DC 20005

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"Kline, Kelley (GE Indust, ConsInd)" To <Kelley.Kline@ge Monica Shimamura/DC/USEPA/US@EPA

.com> cc
10/01/2008 04:04 Subject PM FMEA

Monica,

Thanks again for all of your time yesterday on the call. Hopefully, you all felt it was worthwhile, and it was a good overview.

I wanted to follow up on the call on the FMEA, involving the smaller group. That would probably be Marty Zentner, Jeff Mellinger, and Lee Bishop on our end. We would be free tomorrow and Friday at 2:00 pm, or also generally free on Monday afternoon after 2:30 pm. If you could let me know what would work for you all, we can go ahead and get that scheduled. We will send an FMEA example in advance, and would anticipate the call lasting half an hour or so.

We are working on the additional questions you had posed, and will have responses to you by early next week at the latest. If you have any additional issues you would like to see us address in the SNAP submittal, we would very much appreciate receiving them by early next week as well, as we are shooting to have the final version submitted to you by October. 15.

Thanks so much, and please feel free to call with any questions.

KelleyKelley A. Kline GE Consumer & Industrial Counsel - Regulatory Compliance T 502 452-7603 F 502 452-0947 C 502 403-7840 D *334-7603 E Kelley.Kline@ge.com
www.ge.com
Appliance Park, AP2-225 Louisville, KY 40225, USA

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