

"richardastrust.com" <richard@astrust.com> 

11/21/2007 12:25 PMTo 

Margaret Sheppard/DC/USEPA/US@EPA, Darren Burks <dburks@acsalaska.net>,
Dave Godwin/DC/USEPA/US@EPA, Julius Banks/DC/USEPA/US@EPA



cc





bcc











Subject

Re: supplement to risk assessment for window unit









 

For Follow Up:

  



Normal Priority

 



 History:













This message has been replied to.















 



Margaret

 

Attached the window ac risk.

 

Any questions please feel free to ask.

 

Happy Thanksgiving to All

 

Richard



"richardastrust.com" <richard@astrust.com> wrote: 

Darren

 

Please address the issues that the EPA has and get back to me.

 

Richard



Sheppard.Margaret@epamail.epa.gov wrote:



Richard,

For the window unit, we still need a document that traces from the

charge size, in g, to the exposure level and then compares this to the

LEL and the appropriate exposure limit. The September 25, 2007 letter

from Alaska Industrial Hygiene Services is based upon the original

charge size estimate and does not address toxicity as an issue.



I am expecting either a revised risk assessment or a supplemental,

stand-alone set of calculations that includes:

-The charge of HCR-188C in the window unit (g)

-Assumptions on room size, duration of exposure, molecular weight

(g/mole), temperature and pressure

-Calculation of exposure level, in ppm and in %

-Comparison of the exposure level to the LEL of 2%/20,000 ppm for both

consumers and workers

-Comparison to the AEGL of 10,000 ppm for consumer exposure

-Comparison to the TLV of 1000 ppm for worker exposure



Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

----- Forwarded by Margaret Sheppard/DC/USEPA/US on 11/13/2007 11:43 AM

-----



Margaret 

Sheppard/DC/USEP 

A/US To 

"richardastrust.com" 

11/01/2007 05:06 

PM cc 

Dave Godwin/DC/USEPA/US@EPA, 

Julius Banks/DC/USEPA/US@EPA 

Subject 

Re: window ac test(Document link: 

Margaret Sheppard) 



















Richard,

Thanks for informing me about the situation with the manufacturer and

the testers.



If this is the case, then the risk assessment for the window unit needs

to use the charge value based on 40% of nameplate, since that is the

charge supported by the testing. You may address this either by

revising and resubmitting the risk assessment from July 2007 for window

units and freezers, or by separately submitting revised risk assessment

calculations for the window unit.



Also, please identify the charge size in grams or ounces.



Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov







"richardastrust. 

com" 

.com> Margaret Sheppard/DC/USEPA/US@EPA 

cc 

10/31/2007 03:03 

PM Subject 

window ac test 





















Margaret:



On the 5000 BTU unit, Intertek explains that at the low charge rates,

the room overwhelmed the unit and they could not get a steady reading.

On the 10000 BTU unit, the charge at 40% started to stabilize at the

best EER. The attached report explains this. In order for me to get the

unit to perform at the lower charge rates, I would need to work with the

cap tubes. An adjustment of these tubes, would then bring the BTU up

with the EER at around 30% charge. I don't want to attempt this at this

point for it would create ill feeling between the manufacturer (who had

an engineer there) and myself.



As per our conversation, the manufacturer would be willing to work with

me if, and only, HCR-188C is passed. This is the one benefit I would

have to deal with other air conditioners at a lower charge rate and a

better EER.





Richard







Richard Maruya

phone 808 2351890

fax 808 235 0116

cell 808 5614688

e mail richard@maruya.net or richard@astrust.com

web site HCR188C www.hcr188c.com







CONFIDENTIALITY NOTICE This e-mail may contain confidential or

privileged information, if you are not the intended recipient, or the

person responsible for delivering the message to the intended recipient,

then please notify us by return e-mail immediately. Should you have

received this e-mail in error then you should not copy this for any

purpose nor disclose its contents to any other person.(See attached

file: window ac test intertek.pdf)







Richard Maruya

phone  808 2351890  

fax 808 235 0116

cell 808 5614688

e mail      richard@maruya.net  or      richard@astrust.com

web site HCR188C         www.hcr188c.com

 

 

 

CONFIDENTIALITY NOTICE This e-mail may contain confidential or
privileged information, if you are not the intended recipient, or the
person responsible for delivering the message to the intended recipient,
then please notify us by return e-mail immediately. Should you have
received this e-mail in error then you should not copy this for any
purpose nor disclose its contents to any other person.







Richard Maruya

phone  808 2351890  

fax 808 235 0116

cell 808 5614688

e mail      richard@maruya.net  or      richard@astrust.com

web site HCR188C         www.hcr188c.com

 

 

 

CONFIDENTIALITY NOTICE This e-mail may contain confidential or
privileged information, if you are not the intended recipient, or the
person responsible for delivering the message to the intended recipient,
then please notify us by return e-mail immediately. Should you have
received this e-mail in error then you should not copy this for any
purpose nor disclose its contents to any other person. 

