Re: Fwd: Re: Fwd: Proposed Outline for Fault Tree Analysis for Use of HCR-188C in White Goods Monica Shimamura to: richardastrust.com, riskscicom 05/23/2008 05:17 PM Cc: Julius Banks Follow Up: Normal Priority.

Hi Richard and Gary, I received comments back from our technical staff concerning your fault tree analysis outline for HCR-188C for white goods. Margaret's comments from her e-mail on April 2, 2008 still apply (which are in blue) to the outline. Furthermore, we have several other comments and questions that are in black that we would like you to include in the analysis. Please be aware that even though we have made comments on the HCR-188C fault tree analysis outline for white goods, EPA still needs to review the actual fault tree analysis for white goods once it is complete. We reserve the right to comment on your completed fault tree analysis.

Section II (Introduction and Background) Please be aware EPA will not evaluate for retrofit or use in existing refrigerators until a  compatibility analysis that includes a lubricant and compressor compatibility is performed and approved by an industry setting body such as ARI or UL.

For the section "Will be handled by trained and certified technicians only", could you  explain what type of certification the technicians would posses? Currently the technicians certification requirements are only required for CFCs or HCFCs handlers in stationary

sources.

Section VI D (Occupational Parameters [During servicing]) For "Following standard guidelines and procedures" could you explain what the specific  standards and guidelines and procedures are. This section should apply to recovery during servicing or disposal, not just  servicing. We suggest also adding a scenario for an untrained technician. Consider risks of an event that is more likely to occur if the technician has not learned about use of HCR-188C and flammable refrigerants in particular.

Section VII A (FTA for recovery of HCR-188C during servicing) For "Most recovery events will occur in product service centers" - what about the scenario  service occurring in the home? And the worst case scenario of venting occurring in the home? "Recovery event in residential setting would be the worst-case" Could you explain how  recovery would take place? Has a manufacture of recovery equipment stated that their equipment has been manufactured or certified for such use? "Work conducted only by EPA-certified technicians" has to be changed to "untrained  technicians" since EPA does not have any regulations requiring technicians to be trained forhydro carbon in stationary sources. Could you explain what "Use the EPA-approved adaptor connectors and cylinders  connectors only" means? This section should apply to recovery during servicing or disposal, not just  servicing. Please also examine a scenario for an untrained technician. Consider risks of an event that is more likely to occur if the technician has not learned about use of HCR-188C and flammable refrigerants in particular.

Section VII B Could you specify what the guidelines in "Reference to guidelines for HCR-188C in  refrigeration and AC systems" is. "Work conducted only by EPA-certified technicians" has to be changed to "untrained  technicians" since EPA does not have any regulations requiring technicians to be trained for hydro carbon in stationary sources. Could you explain what "Use the EPA-approved adaptor connectors and cylinders  connectors only" means?

Section VII C (FTA for consumer use of window AC) --Why are other  permutations not included? In particular, it seems that there should be a scenario where the fan is running and the AC is "off." We are assuming that the vent referred to is a vent from the outside that pulls in outside air. Is that correct?

Section VII D (FTA for consumer use of refrigerator/freezer) Compressor burnout might be the worst case scenario  If this section uses different values from those in the AD Little 1991 report,  please provide the source of the values used.

Section IX

. (Discussion and Conclusions)--There is a statement that a  "safety valve" is not needed for appliances. What kind of safety valve does the outline refer to--a pressure-relief valve? a service port?

Also, it is more appropriate to refer to a "listed" use than a "registered" use. (See attached file: EPA comm White Goods FTA Outline 4-2-08.doc)

We look forward to seeing the fault tree analysis. Please contact me if you have any questions. Thanks, Monica

Monica Shimamura U.S. Environmental Protection Agency Stratospheric Protection Division 1200 Pennsylvania Ave. NW (6205J)Washington DC 20460 (tel) 202.343.9337 (fax) 202.343.2362
Address for hand delivery: 1310 L St. NW, 10th Floor (1027N) Washington DC 20005
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"richardastrust.com" <richard@astrust.com>

"richardastrust.com" <richard@astrust.com>
05/11/2008 08:46 PM To Monica Shimamura/DC/USEPA/US@EPA, Dave Godwin/DC/USEPA/US@EPA, Karen Thundiyil/DC/USEPA/US@EPA, Julius Banks/DC/USEPA/US@EPA, Jeff Cohen/DC/USEPA/US@EPA, Stephen Andersen/DC/USEPA/US@EPA, Drusilla Hufford/DC/USEPA/US@EPA
cc gary <riskscicom@aol.com> Subject Fwd: Re: Fwd: Proposed Outline for Fault Tree Analysis for Use of HCR-188C in White Goods

Monica

Margaret sent this email to us, they wanted these things added on to the fault tree. We agreed so is the fault tree guidelines acceptable.

Richard

Sheppard

. Margaret@ epamail

. epa
.gov wrote: Subject: Re: Fwd: Proposed Outline for Fault Tree Analysis for Use of HCR-188C in White Goods To: "richardastrust.com" <richard@astrust.com> CC: godwin.dave@epa.gov, banks. julius @epamail.epa.gov, gary <riskscicom@aol.com>, Thundiyil.Karen@epamail.epa.gov From: Sheppard.Margaret@epamail.epa.gov Date: Wed, 2 Apr 2008 16:54:28 -0400

Richard and Gary, Here are our comments on the draft outline for the fault tree analysis: Section VI C (Occupational Parameters [During servicing])--This section should apply to recovery during servicing or disposal, not justservicing. We suggest also adding a scenario for an untrained technician. Consider risks of an event that is more likely to occur if the technician has not learned about use of HCR-188C and flammable refrigerants in particular.

Section VII A (FTA for recovery of HCR-188C during servicing)--This section should apply to recovery during servicing or disposal, not just servicing. Please also examine a scenario for an untrained technician. Consider risks of an event that is more likely to occur if the technician has not learned about use of HCR-188C and flammable refrigerants in particular.

Section VII C (FTA for consumer use of window AC) --Why are other permutations not included? In particular, it seems that there should be a scenario where the fan is running and the AC is "off." We are assuming that the vent referred to is a vent from the outside that pulls in outside air. Is that correct?

Section VII D (FTA for consumer use of refrigerator/freezer)--If this section uses different values from those in the AD Little 1991 report, please provide the source of the values used.

Section IX.(Discussion and Conclusions)--There is a statement that a "safety valve" is not needed for appliances. What kind of safety valve does the outline refer to--a pressure-relief valve? a service port?

Also, it is more appropriate to refer to a "listed" use than a "registered" use. (See attached file: EPA comm White Goods FTA Outline 4-2-08.doc) 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

. hcr 188 c

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