Re: Fwd: Re: Fwd: Proposed Outline for Fault Tree Analysis for Use of HCR

- 188C in White Goods richardastrust.com
to: Monica Shimamura, riskscicom 05/27/2008 01:04 PM Cc: Julius Banks, Dave Godwin, Karen Thundiyil, Stephen Andersen, Drusilla Hufford, jacqueline conant, Kert Davies Show Details

Follow Up: Normal Priority.

Monica

Thank you for your response, and questions

Please note that, as repeated many times to Margaret and her associates in the past, HCR188C is to be used for new refrigerators, new stand alone freezers, and new window air conditioners only as per the application on white goods.

I would also like to note that many of your questions below have already been answered on a number of occasions when asked by Margaret and her associates BUT we will do so again when submitting the Fault Tree Analysis.

Richard Page 1 of 6

4/2/2010 file://C:\Documents and Settings\jarling\Local Settings\Temp\notesB53680\~web6575.htmShimamura.Monica@epamail.epa.gov wrote:

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. Page 2 of 6

4/2/2010 file://C:\Documents and Settings\jarling\Local Settings\Temp\notesB53680\~web6575.htmCould 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 Page 3 of 6

4/2/2010 file://C:\Documents and Settings\jarling\Local Settings\Temp\notesB53680\~web6575.htmMonica 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" .com> Monica Shimamura/DC/USEPA/US@EPA, Dave Godwin/DC/USEPA/US@EPA, 05/11/2008 08:46 Karen Thundiyil/DC/USEPA/US@EPA, PM 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 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 Page 4 of 6

4/2/2010 file://C:\Documents and Settings\jarling\Local Settings\Temp\notesB53680\~web6575.htmSheppard.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" CC: godwin.dave@epa.gov, banks.julius@epamail.epa.gov,
gary , 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

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4/2/2010 file://C:\Documents and Settings\jarling\Local Settings\Temp\notesB53680\~web6575.htmFax 202

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- 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

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.(See attached file: EPA comm White Goods FTA Outline 4-2-08.doc)

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

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. Page 6 of 6

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