### RE: UL 484 Monica Shimamura to: richard 11/20/2009 11:03 AM Cc: Margaret Sheppard, gary Follow Up: Normal Priority. 

### Hi Richard, The SNAP program does not provide "clearance" for an alternative refrigerant. Instead, it finds alternatives acceptable, acceptable subject to use conditions, acceptable subject to narrowed use limits, or unacceptable in a particular end-use . The original SNAP rule, published in the Federal Register on March 18, 1994 (59 FR 13044, available at http://epa.gov/ozone/fedregstr/59fr13044.html), clearly explains that EPA would review substitute refrigerants in the end-use for which they are intended, and that an acceptability determination in one end-use does not apply to other end-uses. Therefore, we are seeking to understand the risks associated with your refrigerants in the variety of window-air conditioner appliances that may eventually use those refrigerants, as well as any safety mitigation strategies or components that may be employed. We feel that a national safety standard that, unlike UL 484 today, addresses the use of a flammable refrigerant, helps such understanding. While it may be the appliance manufacturer or appliance user rather than the refrigerant producer that is subject to potential use restrictions, we must address these issues before we make a final determination on a particular substitute. Concerning the testing procedure using UL 484, it is not so much that it was the "incorrect procedure" as that the standard in its current form does not sufficiently address the risks specific to flammable refrigerants. Without tests to address those specific risks, we are concerned that the test results may not show whether a passing window AC unit with HCR-188C or HCR-188C1 is comparable in risk to a passing window AC unit with a non-flammable refrigerant. Thanks, 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>richard 11/18/2009 01:57:46 PM To all. From: richard@astrust.com To: Robert Hill Intertek <robert.hill@intertek.com>, Scott Mautz Intertek <scott.mautz@intertek.com> Cc: Wayne Reeves Intertek <wayne.reeves@intertek.com>, Matt Snyder Intertek <matt.snyder@intertek.com>, Monica Shimamura/DC/USEPA/US@EPA, Margaret Sheppard/DC/USEPA/US@EPA, gary <riskscicom@aol.com> Date: 11/18/2009 01:57 PM Subject: RE: UL 484



### To all. As explained to me via phone conversation by Monica Shimamura of the EPA on Thursday November 12, 2009

. Intertek is only a testing body and does not write the test protocol for a hydrocarbon refrigerant. UL writes the testing procedure and are testing window air conditioners at this time. UL will be coming up with a test procedure and refrigerant charge amount for hydrocarbon refrigerants to be used in a window air conditioner. I was informed the test procedure done on the window air conditioner using UL484 is incorrect. This can be verified by Monica at the EPA. Monica: this is what was explained to me as I understood it. Is this correct? This is the reason my window ac listing is being held up. I have to wait for UL to come up with a charge amount and test plan for window ac units which will take 6 to 8 months. I just developed the refrigerant. The industry has to comply with how it uses it. Holding HCR188C or HCR188 C has nothing to do with the appliance. I'm coming in for an alternative refrigerant clearance not an appliance clearance 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, 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.

--- On Wed, 11/18/09, Scott Mautz Intertek <scott . mautz @intertek
. com> wrote: From: Scott Mautz Intertek <scott.mautz@intertek.com> Subject: RE: UL 484 To: "Robert Hill Intertek" <robert.hill@intertek.com> Cc: richard@astrust.com, "Wayne Reeves Intertek" <wayne.reeves@intertek.com>, "Matt Snyder Intertek" <matt.snyder@intertek.com> Date: Wednesday, November 18, 2009, 8:16 AM As far as Safety is concerned, The EPA allowed us to list with this refrigerant. We made sure the components were compatible with this refirgerant and did testing to verify that it still complied with UL 484 with regards to pressures

. The compatibility test was already performed on the compressor and Richard provided us with the data done in our Columbus Facility.

Scott Mautz Project Engineer - HVAC Safety / Quality Manager Phone: 607-758-6557 Intertek 3933 US Route 11 Cortland, NY 13045 Fax: 607-758-6595 Mobile: 315-415-1109 E-mail: Scott.Mautz@intertek.com www .intertek-etlsemko.com 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: Robert Hill Intertek Sent: Wednesday, November 18, 2009 1:12 PM To: Scott Mautz Intertek Cc: richard@astrust.com Subject: FW: UL 484 Scott, I believe that Richard has this information and what is needed to explain to the EPA is compliance to UL 484. Thanks, Robert J. Hill Senior Engineer / HVAC Sales Telephone +1 607 758 6270Intertek 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: Scott Mautz Intertek Sent: Wednesday, November 18, 2009 12:43 PM To: Robert Hill Intertek; Wayne Reeves Intertek Cc: Wayne Niggli Intertek Subject: RE: UL 484 See the attached

Scott Mautz Project Engineer - HVAC Safety / Quality Manager Phone: 607-758-6557 Intertek 3933 US Route 11 Cortland, NY 13045 Fax: 607-758-6595 Mobile: 315-415-1109 E-mail: Scott.Mautz@intertek.com www .intertek-etlsemko.com 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: Robert Hill Intertek Sent: Wednesday, November 18, 2009 11:20 AM To: Wayne Reeves Intertek; richard@astrust.com Cc: Wayne Niggli Intertek; Scott Mautz Intertek Subject: UL 484 Wayne, Scott mentioned that you received a letter regarding the HCR-188C in the room air conditioner and also a ruling from Bill Fiske additional information that you can give Richard for him to submit to the EPA will be helpful. EPA consulted with UL and they said that ETL could not list that refrigerant per UL 484 and Richard needs to show the EPA how we got a round that. Thanks,

Robert J. Hill Senior Engineer / HVAC Sales Telephone +1 607 758 6270 Intertek3933 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

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