### hcr188c1 test Monica Shimamura to: richard 11/10/2009 07:46 PM Cc: gary, Margaret Sheppard Follow Up: Normal Priority. Hi Richard, As Margaret suggests in her email below, it appears like you are testing equipment for two other end uses - retail food refrigeration and vending machines. Unfortunately, these two end uses are different from household refrigerators and MVAC therefore would require separate submissions. I am including a link to our SNAP web page which discusses the different end uses in the Refrigeration and Air Conditioning sector for your convenience. Similar to the household refrigerator and freezer submission we would need a fault tree analysis and the SNAP application form filled out. http://epa.gov/ozone/snap/refrigerants/index.html Please also note that vending machines might be more challenging end use to evaluate for HC refrigerants as it has many different electrical components within the machine - increasing the potential for sparking to occur. Also, as I understand, there is no UL or any other national safety standard for vending machines for flammable refrigerants. Margaret has responded to your charge testing question in the email below. Please feel free to contact me concerning the additional end uses. The Federal Government is observing Veteran's Day tomorrow therefore we will be back in the office on Thursday. Cheers, Monica Monica Shimamura U.S. Environmental Protection Agency Stratospheric Protection Division 1200 Pennsylvania Ave. NW (6205J) Washington DC 20460 (tel) 202.343.9337 (fax) 202.343.2362 Address for hand delivery (UPS/Fed Ex/etc): 1310 L St. NW, 10th Floor (1027N) Washington DC 20005 .· ́ ̄`·. ̧ ><((((o> .· ́ ̄`·. ̧ ̧.· ́ ̄`·. ̧ ><((((o> ,.· ́ ̄`·. ̧.· ́ ̄`·. ̧ ><((((o>  ̧.· ́ ̄`·..· ́ ̄`·. ̧ ><((((o> .· ́ ̄`·. ̧ ̧.· ́ ̄`·. ̧.· ́ ̄`·. ̧ ><((((o>.· ́ ̄`·. ̧ ><((((o> .· ́ ̄`·.><((((o> ̧.· ́ ̄`·. ̧ ><((((o>.· ́ ̄`·.><((((o> ̧.· ́ ̄`·. ̧><((((o> ----- Forwarded by Monica Shimamura/DC/USEPA/US on 11/10/2009 07:26 PM -----

From: Margaret Sheppard/DC/USEPA/US To: Monica Shimamura/DC/USEPA/US@EPA Date: 11/10/2009 04:36 PM Subject: Fw: hcr188c1 test Monica, Richard has raised a number of issues here. It seems like he is doing testing related to a number of new end uses for which he has not yet submitted under the SNAP program.To date, HCR-188C has been tested for charge size against HFC-134a in household refrigerators and in motor vehicle air conditioning, and the mass percentage ratio was different for the two different types of equipment. HCR-188C has been tested for charge size against HCFC-22 in a window air conditioning unit. The mass percentage ratio was 40%. But there were some problems with the testing (the capillary tube) that made Richard think at the time that a smaller charge size might possibly be appropriate. I believe it is still necessary to have test results in other types of equipment to verify whether Richard and Robert's impression is correct that the percentage will the same when the same two refrigerants are compared. If results agree for each refrigerant pair after looking at several different kinds of equipment (especially for different end uses), then we might be able to agree that additional testing is not required. Please share this message with Richard and add your thoughts about whether there will be submissions for the new end uses. Margaret Sheppard Environmental Scientist Significant New Alternatives Policy Program USEPA/Stratospheric Protection Division Tel. 202-343-9163 Fax 202-343-2338 email: sheppard.margaret@epa.gov ----- Forwarded by Margaret Sheppard/DC/USEPA/US on 11/10/2009 04:24 PM -----

From: richard@astrust.com To: Robert Hill Intertek <robert.hill@intertek.com> Cc: gary <riskscicom@aol.com>, Monica Shimamura/DC/USEPA/US@EPA, Margaret Sheppard/DC/USEPA/US@EPA Date: 11/10/2009 10:53 AM Subject: RE: hcr188c1 test



### Rob: We need to do the fault tree and risk assessment for the application for other appliances. The charge amounts will be important to Gary who does the fault tree analyis and risk assessment. We know that on tests done at Intertek on 134a systems, HCR188C1 uses 25% charge and, on R22 systems, it uses 40% charge. No matter how many tests we run the percentages are the same. Do you agree with this? My last conversation with Margaret Sheppard was that the charge amounts had to be done for every appliance that I am applying for clearance will confirm with her and get back to you. Margaret: Are the charge amounts still required in actual physical tests or can we presume, at this point, that HCR stated as above? Please let us know so we can proceed. Thank you,

Richard

### Richard Maruya phone 808 2351890 fax 808 235 0116 cell 808 5614688 e mail richard @ maruya . net or richard @ astrust
. com web site HCR188C www . hcr 188 c . com The "CLIMATE FRIENDLY" Refrigerant

CONFIDENTIALITY NOTICE This e-mail may contain confidential or privileged information, if you are not the intended recipient person responsible for delivering the message to the intended recipient, then please notify us by return e-mail immediately received this e-mail in error then you should not copy this for any purpose nor disclose its contents to any other person

--- On Tue, 11/10/09, Robert Hill Intertek <robert
. hill@intertek
. com> wrote: From: Robert Hill Intertek <robert.hill@intertek.com> Subject: RE: hcr188c1 test To: richard@astrust.com, "monica shimamura" <shimamura.monica@epamail.epa.gov>, "margaret sheppard" < Cc: "gary" <riskscicom@aol.com> Date: Tuesday, November 10, 2009, 4:35 AM Richard, Refrigerant systems that are similar will all take the same percentage of refrigerant - so I do not see any reason to test every shape and color may see a difference in commercial equipment that contains devices such as liquid receivers and suction line accumulators refrigerant so the percentage may be higher. Thanks, Robert J. Hill Senior Engineer / HVAC Sales Telephone +1 607 758 6270 Intertek 3933 US Route 11 Cortland, NY 13045 Cell: +1 607 423 3190 Fax: +1 607 753 7560 Email Address: robert

. hill @ intertek

. com www
. intertek

. com /hvac

From: richard@astrust.com [mailto:richard@astrust.com] Sent: Tuesday, November 10, 2009 9:15 AM To: Robert Hill Intertek; monica shimamura; margaret sheppardCc : gary Subject: hcr188c1 test



### Rob: As per our conversation. The test which I require will show the charge amount of HCR188C1 for other appliances used in commercial and residential settings including vending and dispensing machines. The test will be HCR188C vs 134a and R22 charge amounts Please let me know what it would take to do this. Thank you Richard Richard Maruya phone 808 2351890 fax 808 235 0116 cell 808 5614688 e mail richard @ maruya . net or richard @ astrust
. com web site HCR188C www . hcr 188 c . com The "CLIMATE FRIENDLY" Refrigerant

CONFIDENTIALITY NOTICE This e-mail may contain confidential or privileged information, if you are not the intended recipient person responsible for delivering the message to the intended recipient, then please notify us by return e-mail immediately received this e-mail in error then you should not copy this for any purpose nor disclose its contents to any other person

CONFIDENTIALITY NOTICE This email 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 email immediately. Should you have received this email in error then you should not copy this for any purpose nor disclose its contents to any other person http ://www
. intertek

. com