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 for
hydro 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 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)--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.hcr188c.com

The "CLIMATE FRIENDLY" Refrigerant
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