Cover Letter for HC-12a ® Petition Response
This letter and its attachment comprise EPA's response to the May 1, 1998 petition from OZ Technology requesting that EPA find HC-12a® acceptable . The full response is 18 pages long and may be obtained from the Air and Radiation Docket at 202-260-7548. The docket number is A-91-42 and the file number is VI-C-28. It is also available in Adobe Acrobat (PDF) format (57K). The petition was not submitted electronically, so it is not available online.
Registered mail; return receipt requested
Dear Mr. Lindgren and Mr. Harkins:
This is in response to your Petition dated May 1, 1998, requesting that the Environmental Protection Agency (EPA) change the status of Hydrocarbon Blend B under EPA's Significant New Alternatives Policy (SNAP) program from unacceptable to acceptable. Based on our reading of the Petition, it appears that OZ Technology, Inc. ("OZ") is only requesting a change in SNAP status with respect to the use of Hydrocarbon Blend B in new refrigeration and air-conditioning equipment, but not in retrofitted equipment. In reviewing this Petition, EPA considered the documents attached to the Petition as exhibits, as well as all information previously submitted, regarding Hydrocarbon Blend B. OZ should also interpret this response to incorporate EPA's responses dated July 25, 1995, and August 30, 1996, to OZ's two earlier Petitions.
For the reasons stated in the enclosure, EPA is denying this Petition. In summary, none of the documents submitted as part of this Petition adequately addresses the use of Hydrocarbon Blend B as a CFC-12 substitute in new equipment. As the EPA has stated in its responses to the previous Petitions submitted by OZ, levels of risk posed by flammable refrigerants can only be assessed through a scientifically valid, comprehensive risk assessment. Such an assessment must accurately reflect potential leak scenarios, potential ignition sources, the likelihood of ignition, the consequences of ignition or explosion, and potential measures to mitigate the risk. It also must address risks specific to particular refrigeration and air-conditioning end-uses involving different charge sizes and system designs. Without a valid assessment, no reliable judgments can be made about the actual risk that flammable refrigerants pose to people using them.
A comprehensive response to each of the paragraphs contained in the Petition is enclosed. If you have any questions about this response or EPA's determinations, please contact Jeff Cohen, Chief, Analysis and Review Branch, Stratospheric Protection Division. Mr. Cohen supervises the Significant New Alternatives Policy (SNAP) program. He may be reached at (202) 564-0135.