"John Poole" <rs@refsols.com> 

07/01/2008 03:59 AM	

To

Dave Godwin/DC/USEPA/US@EPA

cc

Subject

SNAP LISTINGS FOR RS-44 & RS-45

 



 

 

Hello Dave,

 

You may recall that EPA accepted RS-44 (R424A) and RS-45 (R434A) on to
the SNAP list in 2003 and 2007 respectively.

 

I have just been advised by a company in the US, which is involved in
the bus and train business, that in order for them to consider using
RS-44 and RS-45 they need to be SNAP approved for the category “Bus
and Train Air Conditioning”. I must say that I was unaware of this use
category when applying for a SNAP listing, so mine is the error in the
first place.

 

Is it possible to get approval for this category of use and, if so, how
is this done?

 

Most grateful for your comments here.

 

Best regards

John

 

 

 

 

John Poole

Refrigerant Solutions Ltd.

8 Murieston Road,

Hale,

Altrincham,

Cheshire, WA15 9ST

Tel: (+44) (0)161 926 9876

Fax: (+44) (0)161 926 9875

Email:   HYPERLINK "mailto:rs@refsols.com"  rs@refsols.com 

Web:   HYPERLINK "http://www.refsols.com/"  www.refsols.com 



----- Forwarded by Dave Godwin/DC/USEPA/US on 11/12/2008 03:21 PM -----

"Mougharbel, Marwan" <MMougharbel@ltk.com> 

07/02/2008 10:48 AM	

To

Dave Godwin/DC/USEPA/US@EPA

cc

"Schwab, Robert" <RSchwab@ltk.com>, Monica Shimamura/DC/USEPA/US@EPA,
<rs@refsols.com>

Subject

RE: RS-44 and RS-45

 



Dave,

Thank you for the quick and detailed answer.

Is it possible to put LTK (Bob Schwab and myself) on the list of

interested customers to receive the letter you mentioned that indicates

the acceptability finding?

Regards, 

Marwan Mougharbel, MSME

Staff Consultant

LTK Engineering Services

100 West Butler Avenue

Ambler, PA 19002

Phone: 215-641-8835

-----Original Message-----

From: Godwin.Dave@epamail.epa.gov [mailto:Godwin.Dave@epamail.epa.gov] 

Sent: Tuesday, July 01, 2008 6:56 PM

To: Mougharbel, Marwan

Cc: Schwab, Robert; Shimamura.Monica@epamail.epa.gov

Subject: Re: RS-44 and RS-45

Thanks Marwan,

Yes, John contacted me submitting these two refrigerants for use in what

we usually refer to as "motor vehicle air conditioning (buses and

passenger trains)."  I've forwarded that on to Monica, who is

coordinating our SNAP process.

The SNAP regulations stipulate that it is legal to sell the alternative

90 days after the complete submission is received by EPA.  We've added

these refrigerants / end-use to our list for our next SNAP Notice, which

we will publish in the Federal Register.  Once the Notice is published

in the Federal Register, we usually update our website accordingly in a

week or two.  Given the publication process we need to follow, however,

I can't predict when we will have something officially published in the

Federal Register.  Regardless, once the decision is made we would send a

letter to John and interested customers to indicate the acceptability

finding.

In the meantime, the SNAP regulations allow you to pursue "research and

development" without an official determination under SNAP.  So, feel

free to work with John to obtain samples to test in your applications.

-- Dave

David S. Godwin, P.E.

Acting Branch Chief

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 1005D,

Washington, D.C. 20005, USA

Phone: +1-202-343-9324

Fax: +1-202-343-2363

Godwin.Dave@epa.gov

                                                                        

             "Mougharbel,                                               

             Marwan"                                                    

             <MMougharbel@ltk                                        To 

             .com>                    Dave Godwin/DC/USEPA/US@EPA       

                                                                     cc 

             07/01/2008 03:11         "Schwab, Robert"                  

             PM                       <RSchwab@ltk.com>                 

                                                                Subject 

                                      RS-44 and RS-45                   

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Dave,

I'm sorry I missed your call yesterday afternoon. Since I was not able

to get a hold of you on the phone, I think e-mailing would be a better

way of communication.

We had a phone meeting with John Poole from Refrigerant Solutions Ltd.

on Monday June 30, 2008, and he confirmed that refrigerants RS-44 and

RS-45 are actually valid as R-22 substitutes for "Bus & Passenger

Railcar" HVAC systems even though this was not specified on the SNAP

application.

I believe he will be contacting you, if he already did not, about

modifying the specific end use section of the application to add those

refrigerants in the "Bus & Passenger Railcar" SNAP category for class II

ODS.

On behalf of LTK Engineering Services, I would like to express our

interest in accommodating RS-44 and RS-45 on EPA's SNAP list for "Bus &

Passenger Railcar AC" end usage for class II ODS.

Can you give us an estimate on the time that it takes to update the SNAP

list if/when the addition is approved?

Best Regards,

Marwan Mougharbel, MSME

Staff Consultant

LTK Engineering Services

100 West Butler Avenue

Ambler, PA 19002

Phone: 215-641-8835

