"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

History:

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 like 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 there is anything in

that email that you would not want to be available to the general

public.

Margaret Sheppard

USEPA/Stratospheric Protection Division
SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

"richardastrust. 

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 retrofit 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 feeling 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.
Could 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