

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

09/09/2007 01:08 PMTo 

Margaret Sheppard/DC/USEPA/US@EPA



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Subject

white goods clarification









 

For Follow Up:

  



Urgent Priority

 



 History:













This message has been replied to.















 



Margaret

 

End use clarification:

 

My intention for HCR188C is to be used in new refrigerators, freezers
and new home air conditioning units (window or split unit). To retrofit
a used refrigerator or home AC unit is not feasible because of cost.

 

The average 12,000 BTU home window AC unit is around $200.00 and the
average-sized refrigerator is approx $600.00. When one fails, it is
cheaper to buy a new one and not fix it. 

 

Risk assessment:

 

Risk assessment for air condition units is attached. It also gives the
workers exposure risk.

with maximum charge size risk for large home AC units.  Attachments
"white_goods_amended_Risk.pdf"  and "mesa_Weight_Percent.pdf" answers
the rest of this request.  I just received the latter 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 its highest level of safety device and rules that
are applied to the operator. He also tells of the size and type(DOT
approved) 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.

 

With EPA clearance, then companies using this product would make
training manuals availabe and classes mandatory 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. Spoke to a ARI engineer and was told that when approved the
MSDS on my product will be the key manual on the training of
technicians. That will be the safety guideline that they would follow.
MSDS attached

 

 

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

this is done by computer and on a automatic charging machine. 

 

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 can sell it
as propane for a barbecue grill. It would be easier to blend the
refrigerant from new hydrocarbons. Don has mentioned it would cost more
to recycle as a refrigerant again, however, it can be done but the cost
factor would be more then purchasing a new unit.

 

I have used a Robinair 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 to use 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.

 

Next email

 





Richard Maruya

phone  808 2351890  

fax 808 235 0116

cell 808 5614688

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

 

 

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