

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

07/06/2007 12:37 PMTo 

Margaret Sheppard/DC/USEPA/US@EPA



cc

Dave Godwin/DC/USEPA/US@EPA, Karen Thundiyil/DC/USEPA/US@EPA, Julius
Banks/DC/USEPA/US@EPA



bcc











Subject

Re: white goods









 

For Follow Up:

  



Normal Priority

 



 History:



















This message has been forwarded.









 



Dear Margaret

 

Just got this from Don at Mesa Gas - he explains the blending process in
a refinery atmosphere. As we discussed this will be the most accurate
way to blend my product.

When doing this, it is at it's highest level of safety devices and rules
that is applied to the operator. He also tells of the type of cylinders
that will be used for the refrigerant and the code. 

 

Please note that I will not bottle in small 1 pound cans.The cylinder
sizes here are for certified technicians only - ones that are licensed
and have the proper training.  No do-it- yourselfer is likely to
purchase 5 pounds only to use just a few ounces.

 

If I get the EPA clearance, then companies using this product would put
training manuals and classes to their technicians under OSHA rules and
regulations. I was told this morning  if HCR188c is not accepted by the
EPA, why bother to put together any training manuals or classes.

 

On the weight percentage, I would like to keep that confidential.

 

Thank you

Richard



Sheppard.Margaret@epamail.epa.gov wrote: 

Richard,

Thank you for the clarification and the additional information. I will

share this with my colleagues, as well.



So, my understanding is that your submission is for household

refrigerators (which may include a freezer) and for residential and

light commercial air conditioning. In terms of air conditioning, you

are considering window units, but not heat pumps or central air

conditioning units. Is that correct?



I would like to place your email below in the docket, because it

clarifies your submission. Please let me know if there is anything in

that email that you would not want to be available to the general

public.

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 

07/04/2007 10:13 

PM Subject 

white goods 





















Dear Margaret:



My intention for HCR188C is to be used in new refrigerators and new home

air conditioners units.To retrofit a refrigerator or AC home unit is

not feasible because of cost.



The normal home window unit 12000 BTU is around $200.00 and the

normal-sized refrigerator is approx $500.00. Whenever one fails, it is

cheaper to buy a new one and not fix it.



I guess I did not clarify this.



Most of the exposure of HCR188c would be at a factory when they charge

the new system.



If there is a failure or warranty, they would just discard it and the

store would replace it with a new one. The old one is scrapped. Scrap

yards just recycle the unit by removing the refrigerant and sell it as

propane for the barbecue grill. It would be easier to blend the

refrigerant from new hydrocarbons.



I have used a Robin air EPA-approved reclaimer for HCR188c which has an

oil-separator

which separates the compressor oil from HCR188C and recycles HCR188C

back into a canister. I found it much more effective using the recycled

refrigerant in a BBQ charcoal burner. It can be reused as a refrigerant

but my own personal feeling is that it is such a small amount and that

part of the blend might get lost in the process so I would rather have a

brand new blend in an air conditioner. Although I've used it over and

over many times, the barbecue grill was the best.



At Cortland, New York while testing my refrigerant at Intertek in

February of this year, I did ask Rob Hill about a reclaimer for

Hydrocarbon Refrigerant, All he told me was that there was no company

that he knows is doing it since the EPA has not approved it as an

Alternative Refrigerant.



I will ask him again in writing and get his response.



If this is part of a satisfactory explanation then I will get the rest

of the clarification to you

in a formal letter.



Thank you

Richard



  

