"richardastrust.com" <richard@astrust.com> 
07/05/2007 11:03 PM	To
	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
	
						
	History:	
		This message has been replied to.			

Dear Margaret:
 
As follows below 

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?
 
A:  Yes, for home refrigerators and freezers or stand alone refrigerators 
or freezers.
At this time only the residential air condition units such as window units 
or
split units.  
 
I'd also like to keep this portion confidential: I spoke w/ Keith @ Robin 
air today7/5/07 and was told they do not have any reclaimer and do not 
know if their reclaimer will work with hydrocarbon refrigerants. As far as 
they were concerned, since it is not an EPA approved refrigerant, they 
could find no justification to run any type of test or study.  I got the 
same answer from Sergio @ UL.
 
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.
 

Could you also keep this confidential:
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

