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

09/09/2007 01:11 PM To

Margaret Sheppard/DC/USEPA/US@EPA

cc

bcc

Subject

white goods continue

For Follow Up:

Urgent Priority

2

Margaret

Factory setting

In a factory setting, majority of the new AC or refrigerator units are 

manufactured in China.

Any company producing the units will have a machine that automatically 

charges and adds the refrigerant and oil to the system. This machine will 

also evacuate (remove the moisture)

in the system before charging. All the worker has to do is connect and 

disconnect the nozzle. It is usually a quick disconnect. The rest is all 

done by computer and the machine is programed to only allow so much 

refrigerant and oil. The worker has nothing to do with this. The machine 

is basically a production-line type. 

As far as the risk and engineering control - that I cannot answer, that 

is, China or a third world country where they never heard of OSHA. please 

understand we cannot in enforce our rules on their turf.

Attached is a guideline that the EU use on Venting of Hydrocarbon 

refrigerant.

According to the EU guideline and the people that I spoke to at CARE, the 

venting of hydrocarbon refrigerant is alright as long as the safety 

measures are met. The hydrocarbon refrigerant poses no threat to the 

environment, ozone, and global warming potential. I was told look at all 

of the oil fields that vent natural gases. Hydrocarbon Refrigerant is no 

different that what comes out of the ground.

On the recovery machine:

I spoke to a Mr.Jerry Wander at Inificon in East Syracuse New York about 

the Vortex Recovery machine. I have just purchased one and was inquiring 

about it being suitable for HCR188C recovery. Mr.Wander asked me about 
the pressure on HCR188C and pointed me to the ARI 740 1998. He said that 

HCR188C falls into a medium pressure category and the unit should be 

suitable for the recovery of my refrigerant. Once passed, all his company 

will do is submit to ARI the HCR188C pressure and then the recovery 

machine will be rated. 

This will happen with every other one that is in the market at this time 

which are all EPA approved. You can verify this by calling him at 315 

4341100.

Any appliance which has any refrigerant in the system must be recovered 

before disposal. Any automobile AC refrigerant must be recovered. This is 

an EPA ruling. As far as the recovery equipment goes, it will be 

certified 

when HCR188C is approved. This is what Mr. Wander told me. He said that 

all recovery machines are made of high quality parts and can be used on 

many applications - the only difference is the pressure rating. Since 

HCR188C falls in medium pressure, he sees no problems even if it is 

hydrocarbon.

As far as recycling HCR188C, my opinion is with the small amount that is 

being used, it is not feasible. The charge rate is so small and some of 

the components are under 1% of the mixture and can be lost in the 

recycling process. When this happens the full effects of HCR188C will not 

be there yet it can still be used but in my opinion it will not be 100% 

effective.

Below you will find thew web site for the recovery machine in question 

and 

attached the ARI 740 1988

There is also a company in the US that came out with a guideline for 

Techs 

and the handling and use of hydrocarbon refrigerant. See attached HC 

Guidelines

When marketing HCR188C, the product will be marketed as an ozone-friendly 

and >5 GWP

refrigerant that uses much less refrigerant than any other on the market.

It will also be detailed to follow the guidelines of testing and handling 

of the product.

The MSDS will be posted with the product to advise the technicians to use 

caution in handling of HCR188C.

I will also note that HCR188C is not a ozone-depleting refrigerant. The 

only time a retrofit will be done will be on automobiles. In that case, 

the existing refrigerant will be recovered 

and the retrofit safety kit will be installed with the correct charging 

procedure to be used.

The appliances that HCR188C will be used in are new refrigerators 

,freezers, and home window or split air conditioners.

This is where the guidelines will come in when we get the EPA's input on 

the matter.
Richard

Richard Maruya

phone 808 2351890 

fax 808 235 0116

cell 808 5614688

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

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