United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460	AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives	Date of Receipt:

Date 90 Day Review Begins:

Date Review Completed:

CBI Status:



When completed send this form to:

Via US Postal Service:                                                  
                                 Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER                       SNAP DOCUMENT
CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J                      U.S. EPA

U.S. EPA                                                                
         1310 L STREET NW

1200 PENNSYLVANIA AVE NW                                     10th FLOOR
(MC 6205J)

WASHINGTON, DC 20460                                     WASHINGTON, DC
20005



	Enter the total number of pages in your SNAP information Notice:
Document Control Number



INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit information under the Significant New
Alternatives Policy (SNAP) program for the review of alternatives to
class I and class II ozone-depleting substances (ODS) under section 612
of the Clean Air Act.  Submitters are required to provide this
information on new substitutes to assist the Agency in assessing the
acceptability of chemicals or processes that are considered alternatives
for ODSs.  A separate notice must be filed for each alternative you are
submitting.

All submissions must be provided in three complete copies.  If
information is to be claimed as confidential, all confidential
information must be excised from one of the copies, which will be placed
in the public docket; the other two copies must include the confidential
material.  If no claims of confidentiality are made for the submission,
all copies must be identical.

The attached “Guidance Manual for the SNAP Information Notice” is
designed to assist applicants in completing this form.  The manual
provides instructions on submitting a SNAP notice, asserting
confidentiality claims, completing the notice form, sector-specific data
requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled
out as completely as possible.  Please provide all information requested
to the extent that it is known or reasonably ascertainable.  Make
reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission:  New alternative, Substance, or
Formulation___________________________________________X

Petition: New alternative, Substance, or
Formulation__________________________________________________________

Petition: Revision of the Existing SNAP
list__________________________________________________________________


 Petition: Request to Grandfather Use of An Unacceptable
Substitute_____________________________________________





You must provide the identity of the alternative chemical of processes
and the identity and percentages of all components in a blend and/or
process, even if you claim the identity as confidential.  You may
authorize another person to submit the identity for you, but your
submission will not be complete and review cannot begin until EPA
receives this information.

Part II - ALTERNATIVE-SPECIFIC INFORMATION

                                                       

Please indicate the sector(s) for which you are submitting information
on the substitute by checking the appropriate boxes:

Refrigeration and Air Conditioning 	      X    

Foam Blowing    			     

Solvent Cleaning      	  	       

Fire Extinguishing 

		and Explosion Prevention    	     

Sterilization       	 		     

Aerosols 				     

Adhesives, Coatings, and Inks 	      

Tobacco Expansion 		     

Pesticides 			      

You may need additional copies of Part II if there are several
manufacturing, processing, or use operations that you will describe in
this notice.  Please reproduce these sections as needed.

If you substitute is also subject to review under FIFRA, provide the
FIFRA Registration Number:

 _____________________________

	Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on the
form to fully answer a question.  Label each continuation sheet with the
corresponding section heading and the question.  In part IV, list these
attachments and any test data, other data, or any optional information
that you include in this notice.

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or control
and to provide a description of all other data known to you if these
data are related to the health and environmental effects of the
manufacture, processing, distribution in commerce, use, or disposal of
the alternative.  Standard literature citations may be submitted if they
do not appear in the open scientific literature.  Complete test data (in
English), not summaries of data, must be submitted if they do not appear
in the open literature.  The following are test data and other data that
might be submitted (see the Guidance Manual for a more complete list of
data to be submitted.)  Please indicate test data to be included in your
submission notice by checking the appropriate boxes:

 Yes    No

Flammability Data		 Yes    No

Environmental Effects 

	Data			 Yes    No

Environmental Fate 

	Data			 Yes    No

Risk Assessments		 Yes    No

Test Data Not in the Possession/

	Control of the Submitter	 Yes    No

Other Data 			 Yes    No

You must provide the identity of the alternative chemical of processes
and the identity and percentages of all components in a blend and/or
process, even if you claim the identity as confidential.  You may
authorize another person to submit the identity for you, but your
submission will not be complete and review cannot begin until EPA
receives this information.





CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at
the time of submission for any data which are to be treated as
Confidential Business Information (CBI).  Substantiation of this claim
must also be provided at this time.  All information claimed as CBI will
be treated in a manner consistent with 40 CFR Part 2, Subpart B. 
Failure to assert a claim of confidentiality at the time of submission
may result in disclosure of information by the Agency without further
notice.

To assert a claim on this form, circle or bracket the information you
claim as confidential and mark the confidential box at the bottom of the
page.  Then provide substantiation of this claim on an attachment to the
notice.  If any information is claimed as confidential, you must provide
a “sanitized” version of this notice, including attachments, to EPA
with our submission.  For additional information on claiming information
as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as
Authorized Representatives of the United States Environmental Protection
Agency (EPA) under an EPA contract for the purpose of assisting EPA in
the development and implementation of national regulations for the
protection of stratospheric ozone, including the development of the SNAP
program.  These Authorized Representatives may have access to any
information received by the Stratospheric Protection Division within EPA
Office of the Atmospheric Programs for use in reviewing the need for
possible control of any substance, practice, process or activity that
may reasonably be anticipated to affect stratospheric ozone.  Access to
such information is necessary to ensure that these companies can
complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the
provisions of 42 U.S.C. 7414(c) respecting confidential business
information as implemented by 40 CFR 2.301(h).





Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION



1. (a) Person Submitting Notice (in U.S.)

David K. Hinde                                                          
                                Manager, Research and Development

________________________________________________________________________
_____________________________________

Name of Authorized Official                                             
                                                                 Title

Hill PHOENIX, Inc.                    

________________________________________________________________________
____________________________________

Company/Organization

8166 Industrial Blvd., Covington, GA 30014                              
             Ph. 770-285-3047, Fax 770-285-3092

________________________________________________________________________
____________________________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 



(b) Agent (if applicable)

________________________________________________________________________
____________________________________

Name of Authorized Official                                             
                                                                 Title

________________________________________________________________________
____________________________________

Company/Organization

________________________________________________________________________
____________________________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 

(c) Joint Submitter (if applicable)

________________________________________________________________________
____________________________________

Name of Authorized Official                                             
                                                                 Title

________________________________________________________________________
____________________________________

Company/Organization

________________________________________________________________________
____________________________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 



2. Technical Contact (in U.S.)

David K. Hinde                                                          
                                Manager, Research and Development

________________________________________________________________________
_____________________________________

Name of Authorized Official                                             
                                                                 Title

Hill PHOENIX, Inc.                    

________________________________________________________________________
____________________________________

Company/Organization

8166 Industrial Blvd., Covington, GA 30014                              
             Ph. 770-285-3047, Fax 770-285-3092

________________________________________________________________________
____________________________________

Mailing Address                                                         
                                                                        
Telephone & Fax Numbers 



3. If you have had a prior communication with EPA concerning this
notice, note the date and type of communication (letter, phone, etc.)
and the EPA staff person’s name:

                                                     Letter to David
Godwin dated July 22, 2008

                                                                  Draft
Application to Monica Shimamura and Margaret Sheppard Feb. 2, 2009

Mark (X) if None ________________    



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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative:

Carbon Dioxide, CO2, R-744



2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process
name.  For blends, provide the percent composition of each constituents.

    (b) Chemical Abstracts Service (CAS) registry number and molecular
formula.

    (c) For alternative processes and technologies describe the
technology and provide a diagram of the system.  Also provide the
information on any chemical constituents.

    (d) If you hold a patent on the substitute, provide the patent name
and number and include a copy of the patent as an attachment.  If you
have submitted a patent application but have not been granted one yet,
indicate the date submitted and the expected time frame for a response. 

a. Carbon Dioxide

b. CAS Registry Number 124-38-9, molecular formula: CO2

c. See attachment “CO2 Refrigeration for Retail Food Stores” for
description of system.

d. N/A

Note on Associated Oils:  Refrigeration systems using CO2 compressors
require oil to properly function.  Oil type is commonly specified by the
application and by the manufacturer of the compressor.  The most common
oil type used in CO2 Cascade Refrigeration Systems as described in item
“c” above is POE oil.  This oil is very similar to that used in
conventional systems using HFC refrigerants today, but has slightly
different viscosity.  See attached document “MSDS Emkarate RL68HB”
for detailed information on one such oil specified for CO2 cascade
refrigeration systems today.  POE oils are soluble with liquid CO2 for
CO2 cascade system applications.



3. Generic chemical name (if chemical name of substitute is declared
Confidential Business Information).

Carbon Dioxide, CO2, R-744



4. Specific End-Use

   (a) Describe each end-use that may be reasonably anticipated for the
alternative.  Be sure to provide a broad description          (e.g.
terpene-based semi-aqueous solvent cleaner for electronic parts, or HFC
substitute refrigerant for centrifugal chillers).  For a list of end
uses, see Appendix A to the instructions, beginning on p. 19.

   (b) Identify the ODS and the quantity of substitute (if applicable)
needed to replace it for each end use in pounds (replacement ratio).

Retail Food Refrigeration, New Equipment

Replacement primarily for HCFC-22 as well as first generation HFC
substitutes; replacement ratio approximately 1:1.



Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. (a) Identify each impurity that may reasonably be anticipated to be
present in the chemical alternative as manufactured for commercial
purposes.  If there are unidentified impurities, enter
“unidentified.”

    (b) Provide the CAS Registry Number if available.

    (c) Estimate the maximum weight percentage of each impurity.  If
there are unidentified impurities, estimate their total weight   
percentages.

Water (H2O) < 20 ppm, CAS Registry Number 7732-18-5, 0.002% by wt.

Oxygen (O2) < 20 ppm, CAS Registry Number 7782-44-7, 0.002% by wt.

Air < 70 ppm, 0.007% by wt.



6. Byproducts:

    (a) Describe any byproducts of degradation products resulting from
the manufacturer, processing, use or disposal of the chemical
alternative or chemicals used in the new alternative.  If there are
unidentified byproducts/ degradation products enter “unidentified.” 





(Unknown)

10.  Vapor pressure @ 20ºC:  831  psia	11.  Critical temperature:      
                                                 30.9 ºC	12.  Critical
Pressure                                           psia

13.  Are spectra attached? NO	14.  Disassociation constant:  (Unkown)

15.  Particle size distribution:  (Unknown)	16.  Volatilization from
soil: (Unknown)

17.  Volatilization from water: (Unknown)	18.  Viscosity @ 20ºC:  14.7
Pa-s

19.  pH@concentration: (Unknown)	20.  Thermal conductivity: 16.2 mW/m-K

21.  Adsorption coefficient: N/A	22.  Flammability limits (LFL, UFL):
N/A  % vol

23.  Flash point: N/A	24.  Heat of combustion: N/A

25.  Maximum pressure rise: (Unknown)	26.  Maximum rate of pressure
rise: (Unknown)

27.  Other (specify)

	28. Provide any information on flammability concerns.  For example, if
any abatement techniques are being used to minimize the risks associated
with flammable substances or mixtures, detail those techniques below. 
If a substitute is flammable, an assessment of overall risk in each
end-use may be required.  (See Instructions for sector-specific data
requirements for flammable substances).

Non-Flammable

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION

1.  Ozone-depletion potential (ODP):

     (a) Provide the 100 year ODP of the alternative relative to CFC-11,
if known.  If the substitute is a blend, provide the ODPs of individual
constituents.

     (b) Provide source of ODP or any additional data on the ODP of the
alternative (e.g. atmospheric lifetime, chlorine or bromine loading
potentials).  Reference the source of this information and attach any
supporting documentation.

ODP = 0



2.  Global Warming Characteristics:

    (a) Provide the alternative’s global warming potential (GWP)
relative to carbon dioxide over 100- and 500-year time horizons, if
known.  If the substitute is a blend, provide the GWPs of the individual
constituents.

    (b) If known, provide the alternative’s expected impact on energy
efficiency relative to the substance it is replacing (e.g. +/- X%) and
results of  any testing or modeling done (both theoretical and actual
testing).

    (c) Provide source of GWP or any additional data on the GWP of the
alternative, including the atmospheric lifetime, infrared absorption
spectrum, and infrared absorption capacity.  If the alternative (e.g.
CO2 captured from a stream of waste gas as a by-product of
fermentation).

GWP = 1

Impact on energy consumption: 0 to 5% reduction in energy per modeling
results – see attached technical paper “CO2 Experiences in North
American Supermarkets-A4-Final”.

Dictated by definition of GWP



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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1.  Describe whether an d how the alternative is regulated under other
environmental regulatory statutes, for example other titles under the
Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water
Act (SDWA), the Resource Conservation and Recovery Act (RCA), the
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic
Substances Control Act (TSCA), the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), the Emergency Planning and
Community Right-to-Know Act (EPCRA, also known as SARA Title III), and
state and local laws.  List any concentration-based or other numerical
standards to which the alternative is subject under the above standards
and regulations.

TSCA 8(b) inventory: Carbon Dioxide

SARA 302/304/311/312 extremely hazardous substances: No products were
found.

SARA 302/304 emergency planning and notification: No products were
found.

SARA 302/304/311/312 hazardous chemicals: Carbon Dioxide

SARA 311/312 MSDS distribution - chemical inventory - hazard
identification: Carbon Dioxide: Sudden Release of Pressure, Immediate
(Acute) Health Hazard, Delayed (Chronic) Health Hazard

Clean Water Act (CWA) 307: No products were found.

Clean Water Act (CWA) 311: No products were found.

Clean air act (CAA) 112 accidental release prevention: No products were
found.

Clean air act (CAA) 112 regulated flammable substances: No products were
found.

Clean air act (CAA) 112 regulated toxic substances: No products were
found.



2.  Describe whether and how the alternative is regulated under health
and safety related statutory authorities, such as those implemented by
the Food and Drug Administration (FDA), the Occupational Safety and
Health Administration (OSHA), the Department of Transportation (DOT),
and state and local laws.  List any concentration-based or other
numerical standards to which the alternative is subject under the above
statutes and regulations.  Also list any other standard-setting
organizations such as the National Fire Prevention Association (NFPA) or
the American Society of Heating, Refrigerating, and Air Conditioning
Engineers (ASHRAE), by which the substitute is evaluated.

FDA: GRAS (Generally Recognized As Safe)

OSHA: TLV-TWA value of 5,000 ppm

DOT:   Vapor UN1013, Liquid UN2187, Class 2.2, 

ASHRAE: Considered as A1 refrigerant (R-744) which is non-flammable (no
flame propagation), low-toxicity as stated in ASHRAE Standard 34. 
System design for CO2 refrigeration equipment (and all refrigeration
equipment) is covered by ASHRAE Standard 15 – this standard is
currently being revised to add language specific to use of CO2 as a
refrigerant and secondary coolant. 

Additional notes: ASHRAE has released a “Position Document on Natural
Refrigerants” which was approved by their board on Jan. 28, 2009. 
Regarding CO2, their viewpoint is that “carbon dioxide has found
widespread acceptance in the full range of vapor compression systems,
from low-temperature freezers to high-temperature heat pumps. It has
also been widely used as a secondary refrigerant, offering significant
improvements in efficiency compared with traditional water, glycol or
brine systems.”  This document is provided as an attachment to this
application.  ASHRAE is also adding a chapter specifically on CO2
Refrigeration Systems to the upcoming 2010 Refrigeration Handbook. 





Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1.  Estimate the cost per pound for the substitute chemical.  For
alternative processes and technologies, describe installation costs
associated with the alternative.

Cost of substitute: $0. 50/lb

Cost of installation: +10-20% higher initially, expected to lower as
commercialization and economies of scale increase.

Grade of CO2: Our current recommendations are to use Coleman
(Instrument) Grade CO2 for the initial system charge – this is 99.99%
pure and features low levels of moisture and non-condensable gases.  In
emergency situations when Coleman/Instrument Grade is not readily
available, Industrial Grade 99.5% may be used.   The attached document
“SNLTX2 Installation Guide – Draft Feb 2008” (to be considered
CONFIDENTIAL) contains specific information on what precautions may need
to be taken if a grade of lower purity is used in emergency situations. 



2.  Provide information on production of the substitute.  Include
estimates on:

    (a) Year substitute will be available if not currently produced.

    (b) Total pounds production per year (current figure).

    (c) Years to maximum market penetration.

    (d) Maximum total production per year at market saturation.

    (e) Estimated percentage of market at market saturation.

a. Substitute is currently widely available

b. N/A – application for refrigeration uses only small % of total
production 

c. Estimated 10 years to maximum market penetration

d. Implementation of substitute not expected to impact annual production
amounts

e. Estimated market penetration of 80% of low-temperature refrigeration
systems

3.  Describe any new equipment and use profiles.  If retrofitting of
existing equipment is required, detail changes in technologies needed to
use the alternative and address any materials compatibility issues. 
Provide information on each end-use and capital costs associated with
the substitute or alternative process.  Include cost of equipment and/or
any new materials, equipment lifetime, changes in labor and energy
costs.

Cost of commercialized systems not yet known.





Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative
processes, summarize below (and attached supporting information) the
acute and chronic toxicity of the substitute and of its constituent
chemicals on any organism (e.g. human and/or other mammals, fish,
wildlife, and plants), if available.  Include any data on impurities and
degradation products if known.  Also include information on any
“Allowable Exposure Limits” (AELs) that have been set for the
substitute for use in the workplace.  In addition, please attach a copy
or facsimile of any hazard warning statement, label, material safety
data sheet, or other information which will be provided to any person
who is reasonably likely to be exposed.  (See Guidance Manual for
sector-specific data requirements).

ACGIH TLV (United States, 9/2004).

     STEL: 54000 mg/m3 15 minute(s). Form: All forms

     STEL: 30000 ppm 15 minute(s). Form: All forms

     TWA: 9000 mg/m 3 8 hour(s). Form: All forms

     TWA: 5000 ppm 8 hour(s). Form: All forms

NIOSH REL (United States, 6/2001).

     STEL: 54000 mg/m3 15 minute(s). Form: All forms

     STEL: 30000 ppm 15 minute(s). Form: All forms

     TWA: 9000 mg/m 3 10 hour(s). Form: All forms

     TWA: 5000 ppm 10 hour(s). Form: All forms

OSHA PEL (United States, 6/1993).

     TWA: 9000 mg/m 3 8 hour(s). Form: All forms

     TWA: 5000 ppm 8 hour(s). Form: All forms

See attachment “MSDS for Carbon Dioxide from Airgas”



Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

     (a) Identify all site locations (i.e. name and address) for each
chemical manufacturing process.

     (b) Identify all site locations for manufacturing of products using
substitutes (e.g. refrigerators containing the substitutes).

     (c) Identify the points of release and/or exposure during the
manufacture of: (i) the substitute and/or (ii) products containing the
substitutes.



Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or
products containing substitutes):

     (a) Describe the activities in which workers may be exposed to
chemicals.

     (b) Describe any protective equipment and engineering controls used
to protect workers (e.g. goggles, gloves, chemical hoods).

     (c) Indicate the physical form of chemicals at the time of
handling/exposure (e.g. solid, liquid, gas).

     (d) Estimate average and maximum numbers of workers involved in
each activity.

     (e) Estimate average and maximum duration of activity for any
worker, in terms of (1) hour/day and (2) days/year.

     (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (g) Estimate the average and high-end exposure concentrations
(separated by a /), being sure to provide units of measure.

N/A



Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute:

     (a) Provide the estimated amount (in kg/day) of each chemical
released directly to the environment (e.g. as a hazardous waste or
wastewater effluent) at a site using the substitute (e.g. in products
containing the substitute and processes using the substitute).

     (b) Identify the media (indoor air, outdoor air, land, water) to
which the chemical will be released from that release point.

     (c) Describe the control technology used to limit release; estimate
the amount released to the environment with the control technology in
place to limit release.  If the substitute is to be disposed of,
indicate the method and location of disposal.

     (d) Are releases covered under RCRA?  If so, identify the RCRA
hazardous waste codes.

     (e) Identify the appropriate number of sites expected to use the
substitute.

     (f) Provide information on recycling of the substitute.  Describe
any associated costs and equipment.

N/A



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Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the
substitute in products and/or processes):

     (a) Describe the activities in which workers may be exposed to
chemicals.

     (b) Describe any protective equipment or engineering controls used
to protect workers (e.g. goggles, gloves, chemical hoods).

     (c) Indicate the physical form of chemicals at the time of
handling/exposure (e.g. solid, liquid, gas).

     (d) Estimate average and maximum numbers of workers involved in
each activity.

     (e) Estimate average and maximum duration of activity for any
worker, in terms of (1) hours/day and (2) days/year.

     (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (g) Estimate the average and high-end exposure concentrations
(separated by a /), being sure to provide units.

Start-up, service, and maintenance of refrigeration equipment containing
the substance

Gloves, safety glasses – consistent with industry practice

Liquid and gas most typical

Average 1, maximum 3

Average 4 hours/day, 8 days/year.  Maximum 10 hours/day, 30 days/year

Primarily inhalation

Average 375 ppm (background concentration in air).  High-End 4,000 ppm
during leak inspection and servicing system.  High-End exposure most
likely encountered in mechanical room.  Leak detection (per ASHRAE-15)
set at 3,000-5,000 ppm would initiate exhaust system to bring fresh
outdoor air into mechanical room and exhaust CO2 outside.

Training of personnel installing, servicing, starting-up, using, and
maintaining systems using CO2 as the working fluid has shown to be very
important to successful implementation.  Hill PHOENIX has developed
training classes for all new technologies as part of the “Hill PHOENIX
Learning Center” – this includes manuals and presentation materials
that go along with classroom instruction.  Please see attached document
“SNLTX2 Installation Guide – Draft Feb 2008” that was developed
prior to the first test system installed in the field – it is a result
of knowledge gained from our experiences in testing the cascade
technology in the laboratory, along with extensive experience using CO2
as a secondary coolant.  This document (to be considered CONFIDENTIAL)
will be enhanced over time as more experience is gained through
additional field installation. 

Section F - CONSUMER EXPOSURE

For each end-use of a substitute:

     (a) Identify the potentially exposed population (e.g. indoor
residents).

     (b) Identify the exposure medium (e.g. air).

     (c) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

     (d) Enter the exposure point of concentration.  Provide (1) average
and (2) high-end estimates.

Shoppers in supermarket containing displays refrigerated with the
substitute. 

Exposure via air

Inhalation

Average 375 ppm (background concentration in air).  High-End (estimate):
1000 ppm during 25% leak event (single large circuit).  Catastrophic
leak event (100% of charge, extremely unlikely): 4000 ppm

Item “d” calculation example: Typical 35,000 sqft supermarket with
18’ ceilings – internal volume = 630,000 ft3

Total CO2 charge for LT cascade refrigeration system approx. 275 lbs.

Vapor volume at 75ºF, 1 atm. = 0.1133 lb/ft3

Partial leak event: 25% charge = 69 lbs CO2 = 609 ft3 CO2  >>
Concentration = 0.000966 or 966 ppm

Catastrophic leak event: 275 lbs CO2 = 2427 ft3 CO2 >> Concentration =
0.00385 or 3850 ppm

Note: Catastrophic leak events are generally on discharge side of system
in mechanical room, not sales area.

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Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

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tify and number potential exposure points.

     (b) For each exposure point described in (a), identify the
potentially exposed population (e.g. residents at the fenceline).

     (c) Identify the contact pathway (e.g. ingestion, inhalation,
dermal).

     (d) Identify the exposure medium (e.g. air, water).

     (e) Enter the exposure point concentration (mg/m3).  Provide (1)
average and (2) high-end estimates.

N/A



Mark (X) this box if this page contains CBI __________



Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions
on this form or that provide additional information that may assist
EPA’s review of the alternative under Section 612 of the Clean Air
Act.  Also, provide citation for information already submitted to EPA as
part of past regulatory and information activities, as well as for other
information that could not be included with this submission.  If you
have attached continuation pages, describe the Part, Section and
question number being continued.  Attach additional pages if necessary.

Attachment Name	Question #	Number of Pages	CBI

MSDS for Carbon Dioxide from Airgas	III-A	6

	CO2 Refrigeration for Retail Food Stores	I-B-2	6

	CO2 Experiences in North American Supermarkets-A4-Final	II-B-2	7

	SNLTX2 Installation Guide – Draft Feb 2008 - Confidential	II-D-1,
III-E	48	X

MSDS Emkarate RL68HB	I-B-2	10

	ASHRAE Position Document on Natural Refrigerants – Jan 2009	II-C-2	10























































































			



Part V - CERTIFICATION

I certify to the best of my knowledge and belief that:

1.  All information provided in this notice is complete and truthful as
of the date of the submission.

2.  I am submitting with this notice all test data in my possession or
control and a description of all other data known to or reasonably
ascertainable by me.

3.  If this is a submission of a new alternative, the company name in
Part I, Question 1a of this notice:

     (a) intends to manufacture, formulate, import, market, or use a new
alternative to a Class I or Class II ozone-depleting substance which is
identified in Part I, Section B, Question 2.

     (b) seeks an acceptability determination on a new alternative(s) to
a Class I or Class II ozone-depleting substance, which is identified in
Part I, Section B, Question 2.

4.  The accuracy of the statements made in this notice reflects my best
prediction of the anticipated facts regarding the alternative described
herein.  Any knowing and willful misinterpretation is subject to
criminal penalty pursuant to section 113(c) of the Clean Air Act and 18
U.S.C.§1001.

Signature and Title of Authorized Official (Original Signature
Required):                                 Date

                                                                  

Signature of Agent (Where Applicable):                                  
                                                       Date





For persons filing a SNAP Information Notice, the reporting burden is
estimated to average 150 hours per year.  For persons filing a TSCA/SNAP
Addendum, the reporting burden is estimated to average 46 hours her
year.  Burden means that total time, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instruction; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying
information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to
respond to a collection of information; search data sources; complete
and review the collection of information; and transmit or otherwise
disclose the information.  An agency may not conduct or sponsor, and a
person is not required to respond to, a collection of information unless
it displays a currently valid OMB control number.

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Washington, DC 20460.  Include the OMB control number in any
correspondence.  Do not send the completed form to this address.



 PAGE   

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Form 1265-07 (Revised 06/2008)			

Previous editions are obsolete

