"richardastrust.com" <richard@astrust.com> 
02/01/2008 02:07 PM	To
	Margaret Sheppard/DC/USEPA/US@EPA, Julius Banks/DC/USEPA/US@EPA, Dave 
Godwin/DC/USEPA/US@EPA, Darren Burks <dburks@acsalaska.net>
	cc
	
	bcc
	
	Subject
	Fwd: RE: Additional info needed for HCR-188C in white goods
	
		
	For Follow Up:	
		 
		
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Margaret
 
Got this from Don on the cylinder and type that should be used.
20lbs of HCR188C is a lot of refrigerant since a refrigerator will be 
using an average of 1 oz  total charge.
 
Will this type of cylinder be acceptable. Don at Mesa has been using this 
for a number
of years for HCR188C.
 
Please let me know so Darren can continue the risk assessment.
 
 
Richard

Don Tyssee <dtyssee@mesagas.com> wrote:
From: "Don Tyssee" <dtyssee@mesagas.com>
To: "'richardastrust.com'" <richard@astrust.com>
Subject: RE: Additional info needed for HCR-188C in white goods
Date: Fri, 1 Feb 2008 10:54:55 -0800

Richard â€“
 
There appears to be some confusion. Your refrigerant is a flammable liquid 
under its own vapor pressure.
 
The DOT-39 cylinder referenced in your email to me refers to a 
non-refillable cylinder used for typical refrigerants (see the attached). 
According to US-DOT/Title 49 of the US Code of Federal Regulations, this 
cylinder and valve are allowed only for non-flammable gases or liquids 
under their own vapor pressure (i.e., halocarbon based refrigerants). As 
you will notice, the valve is not very robust in appearance.
 
The cylinders required by US-DOT/Title 49 of the US Code of Federal 
Regulations for your application are rated for filling (and refilling) of 
low pressure flammable gases and hydrocarbon liquids under pressure. A 
common example would be propane cylinders used for BBQâ€™s and forklift 
applications. Because of their approved use for flammable gases and 
liquids under pressure, they are much more robust.
 
In either case as you will see in the attached, all cylinders are 
manufactured with a protective collar so as to avoid damage to the valve 
in the event of dropping or mishandling.
 
Regards,
 
Don
 
 
Â 
 

From: richardastrust.com [mailto:richard@astrust.com] 
Sent: Friday, February 01, 2008 8:11 AM
To: don tyssee
Subject: Fwd: Additional info needed for HCR-188C in white goods
 
Don
 
Can you help me  on the cylinder.
 
Richard

Sheppard.Margaret@epamail.epa.gov wrote:
Subject: Additional info needed for HCR-188C in white goods
To: "richardastrust.com" <richard@astrust.com>
CC: Godwin.Dave@epamail.epa.gov,
Banks.Julius@epamail.epa.gov
From: Sheppard.Margaret@epamail.epa.gov
Date: Tue, 29 Jan 2008 11:59:37 -0500

Richard,
As we discussed yesterday, there is an important piece of information
that my office requires to complete our review of HCR-188C that you can
provide us.

After careful review, we have additional questions concerning the risk
assessments you have provided for refrigerators, freezers, and window
air conditioning units. In particular, the risk assessments for
occupational exposure provide a typical scenario that would occur during
recharging or disposal of appliances. However, the risk assessments do
not provide a worst-case scenario for the workplace related to an
accident or inappropriate usage of a storage cylinder.

I request that you provide my office with a supplement to the risk
assessments for each end use that considers the possible risks due to a
release from a typical Department of Transportation (DOT) Ã¢â‚¬â€œ 39 
storage
cylinder of 30 pounds in an appliance servicing or disposal center. If
you believe that a different size cylinder is likely to be used in the
field with HCR-188C for one or more end uses, please state the sizes you
believe will be used for servicing and disposal in each end use and
provide an explanation for why a cylinder size other than 30 pounds is
appropriate. Then select the largest cylinder size in each end use for
calculations in three supplementary risk assessments.

I expect to follow with a more formal letter later this week. Please
let me know if your risk assessor needs more information to respond to
my request.
Margaret Sheppard
USEPA/Stratospheric Protection Division
SNAP Program
Tel. 202-343-9163
Fax 202-343-2362
email: sheppard.margaret@epa.gov


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
 
 
 
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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.