John
Poole
<
rs@
refsols.
com>
06/
13/
2006
11:
29
AM
To
Dave
Godwin/
DC/
USEPA/
US@
EPA
cc
Subject
RE:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Hello
Dave,

Thanks
for
this
message.
I
will
try
&
answer
the
questions
you
raise
as
follows:

(
1)
We
are
planning
to
sell
the
ASHRAE
composition
RS­
24
for
auto
a/
c
&
intend
to
use
the
same
fittings
for
the
old
blend
(
2)
No,
we
have
not
sold
(
the
old
RS­
24
formulation)
into
MAC
yet.

(
3)
ASHRAE
tolerances
for
RS­
24
are:

Component
Tolerances
%
R134a
+
1.0,
­
1.0
R125
+
1.0,
­
1.0
R600
+
0.1,
­
0.2
R601a
+
0.1,
­
0.2
These
tolerances
appear
to
cover
the
old
RS­
24
formulation,
except
in
the
case
of
R601a
(
isopentane)
where
the
new
blend
contains
0.6%
&
the
old
blend
0.75%.

But,
I
think
you
are
right
in
that
both
formulation
fall
within
ARI
700
Standard
tolerances.

(
4)
No
problem
with
your
wording
of
with
regard
to
disclosure
of
the
old
blend.

(
5)
R424A
has
at
last
been
published
in
May
­
&
copy
of
the
notice
is
attached.

(
6)
R426A:
after
the
Chicago
meetings
last
January
where
RS­
24
received
this
designated
ASHRAE
number,
this
was
put
out
for
public
comment.
No
comments
have
been
received,
&
copy
of
this
position
is
attached
in
e0mail
dated
8
May
from
ASHRAE.
O
guess
we
go
to
the
next
stage
of
the
process
now,
&
I
will
let
you
know
if
anything
happens
at
the
Quebec
meetings.

I
hope
this
answers
your
queries
but
please
contact
me
if
you
need
anything
more.
Best
regards
John
John
Poole
Refrigerant
Solutions
Ltd.
8
Muriestion
Road,
Hale,
Altrincham,
Cheshire,
WA15
9ST
Tel:
(+
44)
(
0)
161
926
9876
Fax:
(+
44)
(
0)
161
926
9875
Email:
rs@
refsols.
com
Web:
www.
refsols.
com
­­­­­
Original
Message­­­­­
From:
Godwin.
Dave@
epamail.
epa.
gov
[
mailto:
Godwin.
Dave@
epamail.
epa.
gov]
Sent:
12
June
2006
22:
02
To:
John
Poole
Cc:
Sheppard.
Margaret@
epamail.
epa.
gov;
Glover.
Hillary@
epamail.
epa.
gov
Subject:
RE:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Hi
John.

We
are
drafting
our
next
Federal
Register
notice
that
will
include
notification
of
the
change
in
composition
of
RS­
24
and
RS­
44
and
our
findings
of
acceptability
for
the
new
compositions.
One
sticky
point
that
arises
is
the
issue
of
RS­
24
as
a
substitute
for
CFC­
12
in
motor
vehicle
air
conditioning.
When
we
approved
the
original
composition
(
http://
www.
epa.
gov/
ozone/
snap/
regs/
67fr77927.
pdf),
we
included
information
that
you
provided
on
the
unique
fittings
(
quick­
connect)
and
unique
labels
(
gold
with
black
text)
that
we
require
for
all
acceptable
refrigerants
in
automobile
air
conditioning.
Technically,
we
would
require
another
set
of
unique
fittings
for
a
new
refrigerant,
but
that
certainly
seems
not
warranted
in
this
case.
So,
some
questions
to
help
us
get
around
this:

*
Do
you
plan
to
sell
the
new
RS­
24
composition
(
i.
e.,
R­
426A)
for
use
in
auto
air
conditioning?
If
so,
do
you
plan
on
using
the
same
fittings
and
labels
as
previously
designed
for
the
old
composition?

*
Did
you
sell
any
of
the
OLD
composition
of
RS­
24
for
use
in
auto
AC,
or
do
you
know
of
any
such
use?

*
What
tolerances
were
set
by
ASHRAE
(
or
voted
for
public
review
by
ASHRAE)
for
the
mass
percent
composition
of
the
R­
426A
blend?
It
might
be
that
the
old
composition
falls
within
the
ASHRAE
tolerance
range,
or
if
not,
I'm
guessing
it
would
fall
within
typical
ARI
Standard
700
tolerances.

*
If
we
discuss
these
tolerance
issues,
how
much
information
on
the
old
composition
may
we
divulge?
We
plan
to
keep
the
old
composition
confidential
per
your
request,
so
we
want
to
know
if
saying
something
like
"
the
old
composition
falls
within
the
tolerances
proposed
in
the
ASHRAE
designation
of
R­
426A"
goes
too
far.
We
won't
have
our
Federal
Register
notice
ready
until
after
the
upcoming
ASHRAE
meeting
in
Quebec,
so
we'd
appreciate
any
update
you
have
after
that
meeting
with
regards
to
the
designations
­­
whether
R­
424A
(
RS­
44)
was
finalized
and
published
and
whether
R­
426A
(
RS­
24)
was
voted
by
the
ASHRAE
Board
of
Directors
for
publication
(
or
recommended
by
SSPC
34
for
publication).

Thanks
again.

Best
regards,

­­
Dave
John
Poole
<
rs@
refsols.
com>
To
02/
21/
2006
01:
23
Dave
Godwin/
DC/
USEPA/
US@
EPA
PM
cc
Subject
RE:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Yes,
please
Dave
­
could
you
hold
the
old
compositions
confidential.

Thanks
and
regards
John
­­­­­
Original
Message­­­­­
From:
Godwin.
Dave@
epamail.
epa.
gov
[
mailto:
Godwin.
Dave@
epamail.
epa.
gov]
Sent:
21
February
2006
17:
59
To:
John
Poole
Subject:
RE:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Thanks
John.
One
more
question:

When
we
originally
approved
RS­
24
and
RS­
44,
we
held
the
exact
compositions
confidential.
Is
it
ok
to
say
what
those
old
compositions
were,
or
do
you
want
them
held
confidential?
For
the
new
versions,
we
will
indicate
the
ASHRAE
numbers
and
the
corresponding
composition.

­­
Dave
John
Poole
<
rs@
refsols.
com>
To
02/
15/
2006
05:
05
Dave
Godwin/
DC/
USEPA/
US@
EPA
PM
cc
Subject
RE:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Hello
Dave,

You
are
right.
It
looks
as
though
I
had
the
wrong
e­
mail
address
for
the
first
message,
but
glad
that
this
has
now
reached
you.

Let
me
try
and
answer
the
queries
you
have
raised:

(
1)
RS­
44
ASHRAE
number:
yes,
you
are
correct.
This
was
sent
out
for
Public
comment
after
the
meetings
in
Denver,
Colorado
last
June
and
no
comments
were
received.
I
understand
that
publication
is
estimated
for
March.

(
2)
RS­
24
ASHRAE
number:
again,
you
are
correct.
Standard
34
committee
accepted
a
classification
of
A1
for
RS­
24,
which
now
has
to
go
through
the
same
public
comments
process.

(
3)
United
Suppliers
of
America
(
USA):
yes,
they
are
an
authorized
dealer
For
both
RS­
24
&
RS­
44.
In
the
case
of
RS­
44,
they
made
the
submission
to
ASHRAE
for
a
refrigerant
number,
but
they
are
not
another
manufacturer
&
will
Not
be
selling
the
same
blend
under
another
name.
Same
position
applies
to
RS­
24.

Hope
this
answers
your
questions
but
please
let
me
know
if
you
need
any
More
information.

Best
regards
John
John
Poole
Refrigerant
Solutions
Ltd.
8
Muriestion
Road,
Hale,
Altrincham,
Cheshire,
WA15
9ST
Tel:
(+
44)
(
0)
161
926
9876
Fax:
(+
44)
(
0)
161
926
9875
Email:
rs@
refsols.
com
Web:
www.
refsols.
com
­­­­­
Original
Message­­­­­
From:
Godwin.
Dave@
epamail.
epa.
gov
[
mailto:
Godwin.
Dave@
epamail.
epa.
gov]
Sent:
15
February
2006
21:
20
To:
John
Poole
Cc:
Sheppard.
Margaret@
epamail.
epa.
gov
Subject:
Re:
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Hi
John,

Thanks;
this
email
came
through.
I'm
not
sure
what
happened
to
the
3
February
one.
The
message
says
it
was
addressed
to
Godwin.
Dave@
epamail.
gov
­­
that
address
probably
doesn't
work
but
Godwin.
Dave@
epamail.
epa.
gov
or
Godwin.
Dave@
epa.
gov
should
both
work.

I
believe
your
emails
will
suffice
for
the
formulation
and
company
name
change
and
are
all
that
SNAP
needs.
We
are
in
the
process
of
publishing
a
new
SNAP
Notice
of
Acceptability
in
the
U.
S.
Federal
Register.
If
it's
not
too
late,
we
may
be
able
to
include
this
formulation
change
in
that
notice.
If
not
that
one,
then
the
next
one.
After
we
publish
the
Notice,
we
will
update
our
website
(
www.
epa.
gov/
ozone/
snap/)
accordingly.
As
always,
if
any
of
your
customers
have
any
questions
regarding
the
legality
of
a
particular
blend/
composition,
they
can
contact
the
US
EPA
directly.

I
had
just
a
couple
questions.
My
understanding
was
that
ASHRAE
has
approved
for
publication
the
R­
424A
(
A1
rating)
designation,
but
has
only
recommended
for
public
review
the
R­
426A
(
A1
rating)
designation.
Is
that
correct?
Not
that
I
expect
any
issues,
but
just
so
we're
clear
in
the
Notice.

Also,
I
believe
the
application
to
ASHRAE
for
R­
424A
came
under
the
name
"
USA
United
Suppliers
of
America"
or
the
like.
How
are
they
related
to
Refrigerant
Solutions
Ltd.?
Are
they
an
authorized
dealer
for
you,
or
are
they
another
refrigerant
producer
that
will
make
and
sell
the
same
blend?
If
the
latter,
will
they
use
any
other
designations
besides
R­
424A
and
RS­
44?
Will
R­
426A
(
RS­
24)
also
be
sold
by
USA
United
Suppliers
of
America?

Thank
you
for
your
diligence
in
informing
us
about
these
changes.

Best
regards,

­­
Dave
David
S.
Godwin,
P.
E.
Environmental
Engineer
U.
S.
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Atmospheric
Programs
Stratospheric
Protection
Division
Alternatives
and
Emissions
Reduction
Branch
Mailing
Address:
1200
Pennsylvania
Avenue,
NW;
Mail
Code
6205J;
Washington,
D.
C.
20460;
USA
Deliveries
/
Office
Location:
1310
L
Street,
NW;
Room
802K;
Washington,
D.
C.
20005;
USA
Phone:
1­
202­
343­
9324
Fax:
1­
202­
343­
2363
Godwin.
Dave@
epa.
gov
John
Poole
<
rs@
refsols.
com>
To
02/
14/
2006
01:
33
Dave
Godwin/
DC/
USEPA/
US@
EPA
PM
cc
Subject
FW:
RS­
24
&
RS­
44
SNAP
LISTINGS
Hello
Dave,

Further
to
our
telephone
conversation
today,
I
am
re­
sending
my
e­
mail
of
3
February
as
discussed.
I
think
this
covers
most
of
the
background
to
the
marginal
changes
in
compositions
of
RS­
24
&
RS­
44
but
please
let
me
know
if
you
need
any
more
information
or
clarification,

I
confirm
that
we
will
continue
to
use
the
unique
set
of
fittings
for
motor
vehicle
air
conditioning
that
are
currently
used
with
RS­
24
as
formulated
and
SNAP
listed.

As
requested,
I
am
also
attaching
copies
of
submissions
made
to
ASHRAE
Standards
34
committee
for
RS­
24
&
RS­
44.

Please
could
you
confirm
receipt
of
this
e­
mail.

Thanks
and
regards
John
John
Poole
Refrigerant
Solutions
Ltd.
8
Muriestion
Road,
Hale,
Altrincham,
Cheshire,
WA15
9ST
Tel:
(+
44)
(
0)
161
926
9876
Fax:
(+
44)
(
0)
161
926
9875
Email:
rs@
refsols.
com
Web:
www.
refsols.
com
From:
John
Poole
[
mailto:
rs@
refsols.
com]
Sent:
03
February
2006
15:
18
To:
'
Godwin.
Dave@
epamail.
gov'
Subject:
RS­
24
&
RS­
44
SNAP
LISTINGS
Dear
Dave,

We
were
SNAP
listed
for
RS­
24
and
RS­
44
refrigerants
in
2002
and
2003
respectively,
and
you
handled
our
applications
at
that
time.
I
do
not
know
if
you
are
still
involved
with
SNAP
applications,
so
forgive
me
if
you
are
not
in
which
case
maybe
you
could
provide
me
with
a
suitable
contact.

We
were
Refrigerant
Products
Ltd
at
the
time
of
these
applications,
since
when
we
have
changed
to
Refrigerant
Solutions
Ltd.
The
reason
that
I
am
contacting
you
is
to
do
with
the
formulations
of
these
2
refrigerant
blends
which
have
been
marginally
changed
as
follows:

RS­
24
%
Component
SNAP
listing
Revised
blend
R134a
93
93
R125
5
5.1
R600
Butane
1,25
1.3
R601a
Isopentane
0.75
0.6
R600a
Isobutane
Total
hydrocarbon
2.0
1.9
RS­
44
%
Component
SNAP
listing
Revised
blend
R134a
47
47
R125
50
50.5
R600
Butane
2.7
1
R601a
Isopentane
0.3
0.6
R600a
Isobutane
0.9
Total
hydrocarbon
3.0
2.5
The
reason
that
we
are
making
these
slight
adjustments
to
the
blends
is
because
of
ASHRAE
numbers
which
have
been
designated
as
follows:

Product
Designated
ASHRAE
number
Date
RS­
24
R426A
January
2006
RS­
44
R424A
June
2005
Both
RS­
24
&
RS­
44
have
been
classified
by
ASHRAE
as
A1,
namely
low
toxicity
&
non
flammable
under
all
conditions
of
fractionation.

As
you
can
see,
the
hydrocarbon
content
of
each
blend
has
been
marginally
reduced
&
the
HFC
contents
are
virtually
unchanged.

Do
our
current
SNAP
listings
remain
unchanged,
or
do
we
need
to
make
revised
submissions
incorporating
these
minor
changes?
I
guess,
also,
do
we
need
to
register
the
change
of
name
of
the
company?.

Thanks
and
best
regards
John
Poole
Refrigerant
Solutions
Ltd.
8
Muriestion
Road,
Hale,
Altrincham,
Cheshire,
WA15
9ST
Tel:
(+
44)
(
0)
161
926
9876
Fax:
(+
44)
(
0)
161
926
9875
Email:
rs@
refsols.
com
Web:
www.
refsols.
com
