"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 se tting 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 re frigerant 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 Refrigeran t 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 sui table for HCR188C recovery. Mr.Wander asked me aboutthe 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 pass ed, 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 HC R188C 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 n o 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 t he 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

- friend ly 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 u se 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 safet y 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 t he 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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