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VonDemHagen, Rebecca

From: VonDemHagen, Rebecca

Sent: Friday, October 16, 2015 6:48 PM

To: richardastrust.com

Cc: Newberg, Cindy; Sheppard, Margaret

Subject: RE: HCR188C/R443A second request

Attachments: R-443A Incompleteness Letter_3 Jun 2014.pdf

Hi Richard,

It is not legal for R‐443A to enter interstate commerce in the United States at this time because we have not yet

received sufficient information to consider your submission complete. Under 40 CFR 82.174, a complete submission

must be received 90 days prior to a substitute entering interstate commerce which is defined at 40 CFR 82.104(n) as:

“The distribution or transportation of any product between one state, territory, possession or the District of Columbia,

and another state, territory, possession or the District of Columbia, or the sale, use or manufacture of any product in

more than one state, territory, possession or the District of Columbia. The entry points for which the product is

introduced into interstate commerce are the release of a product from the facility in which the product was

manufactured, the entry into a warehouse from which the domestic manufacturer releases the product for sale or

distribution, and at the site of United States Customs clearance.”  

On May 15, 2013 EPA informed you that the submission received February 13, 2013 was incomplete and requested

additional information. You responded to this letter on May 7, 2014. Did you receive the attached letter from June 3,

2014? According to my records, the June requests for additional information remain outstanding. You also provided

some information in response to a conference call with EPA on August 18, 2014. We are taking that information into

consideration; however, it is not responsive to the information requested in June 2014 and additional information is

necessary in order to fully address our concerns.  

Regards,

Rebecca von dem Hagen

Stratospheric Protection Division

Office of Atmospheric Programs

U.S. Environmental Protection Agency

(202) 343‐9445

vondemhagen.rebecca@epa.gov

From: richardastrust.com [mailto:richardastrust@yahoo.com]  

Sent: Friday, October 16, 2015 11:51 AM

To: Sheppard, Margaret <Sheppard.Margaret@epa.gov>; VonDemHagen, Rebecca <VonDemHagen.Rebecca@epa.gov>

Cc: Steven P. Mella <spmella@comstarproducts.com>; Andy Tujios <tujios@aol.com>; Charles Breest <charles‐

breest@crossworldgroup.com>

Subject: Re: HCR188C/R443A second request

Rebecca and Margaret 

Would you let me know EPA's position on the email below. 

Thank you 

Richard 
2

 

Richard Maruya 

phone 808 2351890 fax 808 235 0116 cell 808 5614688 

e mail richard@astrust.com or richard@maruya.net

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. 

From: richardastrust.com <richardastrust@yahoo.com> 

To: Margaret Sheppard <sheppard.margaret@epa.gov>; Rebecca VonDemHagen <vondemhagen.rebecca@epa.gov> 

Cc: Steven P. Mella <spmella@comstarproducts.com>; Andy Tujios <tujios@aol.com>; Charles Breest <charlesbreest@crossworldgroup.com> 

Sent: Friday, October 9, 2015 10:06 AM 

Subject: HCR188C/R443A

Margaret 

It's been a while and I need your assistance on a matter of my HCR188C/R443A refrigerant. 

It is common knowledge that I have a pending application with EPA on the use of HCR188C/R443A 

refrigerant in 

household Split AC, heat pumps stc. 

I'm being asked if it is legal for me to sell my HCR188C/R443A in the U S. 

Please let me know. 

Thank you 

Richard 

 

Richard Maruya 

phone 808 2351890 fax 808 235 0116 cell 808 5614688 

e mail richard@astrust.com or richard@maruya.net

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, 
3

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.