"richardastrust.com" <richard@astrust.com> 
09/09/2007 01:11 PM	To
	Margaret Sheppard/DC/USEPA/US@EPA
	cc
	
	bcc
	
	Subject
	white goods continue
	
		
	For Follow Up:	
		 
		
		Urgent Priority
					
					

2
 
Margaret
 
 
Factory setting
 
In a factory setting, majority of the new AC or refrigerator units are 
manufactured in China.
Any company producing the units will have a machine that automatically 
charges and adds the refrigerant and oil to the system. This machine will 
also evacuate (remove the moisture)
in the system before charging. All the worker has to do is connect and 
disconnect the nozzle. It is usually a quick disconnect.  The rest is all 
done by computer and the machine is programed to only allow so much 
refrigerant and oil. The worker has nothing to do with this.  The machine 
is basically a production-line type. 
 
As far as the risk and engineering control - that I cannot answer, that 
is, China or a third world country where they never heard of OSHA. please 
understand we cannot in enforce our rules on their turf.
 
Attached is a guideline that the EU use on Venting of Hydrocarbon 
refrigerant.
According to the EU guideline and the people that I spoke to at CARE, the 
venting of hydrocarbon refrigerant is alright as long as the safety 
measures are met. The hydrocarbon refrigerant poses no threat to the 
environment, ozone, and global warming potential. I was told look at all 
of the oil fields that vent natural gases. Hydrocarbon Refrigerant is no 
different that what comes out of the ground.
 
On the recovery machine:
 
I spoke to a Mr.Jerry Wander at Inificon in East Syracuse New York about 
the Vortex Recovery machine. I have just purchased one and was inquiring 
about it being suitable for HCR188C recovery.  Mr.Wander asked me about 
the pressure on HCR188C and pointed me to the ARI 740 1998. He said that 
HCR188C falls into a medium pressure category and the unit should be 
suitable for the recovery of my refrigerant. Once passed, all his company 
will do is submit to ARI the HCR188C  pressure and then the recovery 
machine will be rated. 
This will happen with every other one that is in the market at this time 
which are all EPA approved. You can verify this by calling him at 315 
4341100.
 
Any appliance which has any refrigerant in the system must be recovered 
before disposal. Any automobile AC refrigerant must be recovered. This is 
an EPA ruling. As far as the recovery equipment goes, it will be certified 
when HCR188C is approved. This is what Mr. Wander told me. He said that 
all recovery machines are made of high quality parts and can be used on 
many applications - the only difference is the pressure rating. Since 
HCR188C falls in medium pressure, he sees no problems even if it is 
hydrocarbon.
 
As far as recycling HCR188C, my opinion is with the small amount that is 
being used, it is not feasible. The charge rate is so small and some of 
the components are under 1% of the mixture and can be lost in the 
recycling process. When this happens the full effects of HCR188C will not 
be there yet it can still be used but in my opinion it will not be 100% 
effective.
 
Below you will find thew web site for the recovery machine in question and 
attached the ARI 740 1988
 
There is also a company in the US that came out with a guideline for Techs 
and the handling and use of hydrocarbon refrigerant.  See attached HC 
Guidelines
 
When marketing HCR188C, the product will be marketed as an ozone-friendly 
and >5 GWP
refrigerant that uses much less refrigerant than any other on the market.
It will also be detailed to follow the guidelines of testing and handling 
of the product.
The MSDS will be posted with the product to advise the technicians to use 
caution in handling of HCR188C.
 
I will also note that HCR188C is not a ozone-depleting refrigerant. The 
only time a retrofit will be done will be on automobiles. In that case, 
the existing refrigerant will be recovered 
and the retrofit safety kit will be installed with the correct charging 
procedure to be used.
The appliances that HCR188C will be used in are new refrigerators 
,freezers, and home window or split air conditioners.
 
This is where the guidelines will come in when we get the EPA's input on 
the matter.
 
 
Richard
 
 
 
 
 
 
 
 


Richard Maruya
phone  808 2351890  
fax 808 235 0116
cell 808 5614688
e mail richard@maruya.net  or richard@astrust.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.