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

07/05/2007 11:03 PM To Margaret Sheppard/DC/USEPA/US@EPA cc Dave Godwin/DC/USEPA/US@EPA, Karen Thundiyil/DC/USEPA/US@EPA, Julius Banks/DC/USEPA/US@EPA bcc Subject Re: white goods

Hi story: This message has been replied to. Dear Margaret: As follows below Sheppard.Margaret@epamail.epa.gov wrote: Richard, Thank you for the clarification and the additional information. I will share this with my colleagues, as well. So, my understanding is that your submission is for household refrigerators (which may include a freezer) and for residential and light commercial air conditioning. In terms of air conditioning, you are considering window units, but not heat pumps or central air conditioning units. Is that correct? A: Yes, for home refrigerators and freezers or stand alone refrigerators or freezers. At this time only the residential air condition units such as window units or split units. I'd also lik e to keep this portion confidential: I spoke w/ Keith @ Robin air today7/5/07 and was told they do not have any reclaimer and do not know if their reclaimer will work with hydrocarbon refrigerants. As far as they were concerned, since it is not an EPA approved refrigerant, they could find no justification to run any type of test or study. I got the same answer from Sergio @ UL. I would like to place your email below in the docket, because it clarifies your submission. Please let me know if t here is anything in that email that you would not want to be available to the general public.
Margaret Sheppard USEPA/Stratospheric Protection DivisionSNAP Program

Tel. 202

- 343

- 9163 Fax 202

- 343

- 2362 email: sheppard.margaret@epa.gov

"ri chardastrust. com" .com> Margaret Sheppard/DC/USEPA/US@EPA cc 07/04/2007 10:13 PM Subject white goods

Dear Margaret: My intention for HCR188C is to be used in new refrigerators and new home air conditioners units.To re trofit a refrigerator or AC home unit is not feasible because of cost. The normal home window unit 12000 BTU is around $200.00 and the normal

- sized refrigerator is approx $500.00. Whenever one fails, it is cheaper to buy a new one and not fix it. I guess I did not clarify this. Most of the exposure of HCR188c would be at a factory when they charge the new system. 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 sell it as propane for the barbecue grill. It would be easier to blend the refrigerant from new hydrocarbons. I have used a Robin air 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 using the recycled refrigerant in a BBQ charcoal burner. It can be reused as a refrigerant but my own personal f eeling 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.Coul d you also keep this confidential:

At Cortland, New York while testing my refrigerant at Intertek in February of this year, I did ask Rob Hill about a reclaimer for Hydrocarbon Refrigerant, All he told me was that there was no company that he knows is doing it since the EPA has not approved it as an Alternative Refrigerant. I will ask him again in writing and get his response. If this is part of a satisfactory explanation then I will get the rest of the clarification to you in a formal letter. Thank you Richard