### A.S. TRUST 

### & HOLDINGS 44-129 MIKIOLA DRIVE

KANEOHE, HI 96744 TELEPHONE: (808) 235-1890 FAX: (808) 235-0116 CELLNM: (808) 561-4688 EMAIL: richard@astrust.net

February 25.2012 Margaret Sheppard Environmental Scientist Significant New Alternatives Policy Program USEPA/Stratospheric Protection Division Margaret:

The response to the New Vending Machine application is as follows. Please refer to attachments:

• The Guidelines for use of HCR I 

### 88C/R44 I A.
o Page 5: The cylinder size and type
o Page 12: Recovery cylinder type
• Com star letter and documentation on cylinder type.
• Brandon Button's email on recovery machines. At present there is no recovery machine available for flammable refrigerants. His email will explain the situation. I am using an existing recovery machine without any problems. Brandon is the AHRI testing engineer for recovery machines at Intertek in Columbus, Ohio. Email address: brandon,button@intertck,com and phone number: (614) 2798090
• Copy of my certification on refrigerant recovery. At present, there is no EPA certification for recovery of flammable refrigerants. VCI training center has informed me they are working on one and hope to get it out by the end of this year.
On the matter of a safety standard for flammable refrigerant in vending machines, I contacted Mr. Emad lafa at Pepsi and his response was that he has no idea. See attached. I also contacted Mr. Michael Lideman of Intertek in Columbus, Ohio. Michael informs me UL541 is the correct safety guideline for vending machines. See attached email.

I feel all of your questions have been answered.

### Guidelines for Using HCR188C R441A/R443A in Refrigeration and Air Conditioning Systems

R441A and R443A will be referred as HCR188C

Introduction HCR188C is a new hydrocarbon-based refrig erant that does not deplete our Earth’s protective ozone layer like fluorocarbon refrigerants including R-12 and R-22. It is now known that breathing these ch lorofluorocarbon and hydrochlorofluorocarbon (CFC’s and HCFC) refrigerants can cause oxygen deprivation, serious heart problems and possibly other health issues. For these and other technical reasons, ozone-safe HCR188C was developed to replace all of the legacy fluorocarbon refrigerants. A direct replacement for fluorocarbon refrigeran ts, HCR188C is compatible with gaskets, seals, and most lubricants in existing re frigeration systems. HCR188C is also an economical replacement for the medium-pressure automotive refrigerant 134a. HCR188C is flammable like other hydrocarbon products and must be used only by HVAC personnel trained and certified in the specif ic, safe handling procedures for HCR188C. Fully trained and EPA-certified HVAC pe rsonnel following these precautions will find that HCR188C is easily and safely charged into legacy HVAC systems. Although HCR188C is flammable, very little is used to charge a refrigeration system; usually only 25-35% for R441A and 30-40% R 443A of the charge of fluorocarbons! Workplace safety is no accident! That is, it doe s take an effort to learn and to follow new safety procedures and to make them part of every refrigerant retrofit job. You alone have the responsibility to follow these HCR188C safe handling procedures to prevent accidents and injuries and to uphold the high safety standards of the HVAC industry.
Waiver of Liability Statement This summary of safe handling procedur es is intended for professional HVAC technicians servicing stationary home air condition systems, refrigeration, and automotive air condition systems containing HCR188C. Only trained, licensed and EPAcertified HVAC technicians have received spec ific safety training and are authorized to service equipment containing HCR188C

. 

### This material is not approved for use by Do -it-Yourself amateurs, home owners and alley mechanics. The hobbyist and HVAC professional alik e are strongly cautioned that all liability is entirely the end user’s responsibility including equipment failure, personal injury, death, and loss of property. Standard disclaimers apply.

### 2 HCR188C Safe Handling Procedures
SECTION 1. The following procedures apply to all users of HCR188C. Specific precautions and safe practices for automotive, light re frigeration, and air conditioning service are summarized in sections following these general precautions: Personal Protective Equipment – PPE is always used for extra protection, just in case something goes wrong and energy is unexpectedly released. Anyone handling this refrigerant must use the following personal protective equipment (PPE): Eye Protection - Refrigeration technicians and observers must wear Z87.1 approved mechanical safety glasses when

• moving, connecting, & insta lling HCR188C gas cylinders

• working on equipment, piping, & fittings containing HCR188C

• charging or recovering HCR188C from a refrigeration system

• Hand Protection - Wear gloves for thermal protection since

• operating compressors may exceed 120 F o 

### causing skin burns

• keep a first aid kit where you can reach it

• expanding HCR188C reaches subzero temperatures instantly causing frostbite on contact
Frostbite First Aid

• Immerse with water at 100 – 110 o 

### F to warm rapidly. Use body heat or warm air if a water bath or shower are unavailable.

• Do not expose the wound to an open fire or flame.

• Do not rub or massage the af fected parts of the body.

• Patients should not walk on frostbitten feet.

• Do not use medications. Do not apply dressings on intact skin.

• Keep the patient calm and at normal body temperature until medical help arrives.

Controlling Energy – Search for these hazards and eliminate them from the work area before working with HCR188C: Ignition Sources - Eliminate open flames or other ignition sources like operating thermostats, relays, & open frame motors. Do not light a halogen flame leak de tector, candle, or strike a match.

### 3 Remove or eliminate hot surfaces from the work area including bare light bulbs, hot plates, and other hot surfaces near the refrigerant or working area, for example, use a shielded fluorescent work light

Table of Ignition Sources *
A r c wel d ing, pl a sma a r c cutting Open flame, b u r ning c a n d le, l a n te r n Cig a rette o rothe r b u r n ing m a te r i a l Open frame moto r s Condensate pump switch On/off manual switches Contactors Oil differential switches Defrost timers/switches Pressure switches Fan delay switches 

### P r op a ne o r MAPP g a s sol d e r ing torch Fan speed controllers Potential relays Flow switches Start relays 

### G a s wel d ing o r cutting torch St a tic elect r icity H a logen fl a me le a k d etecto r St r i k ing a m a tch Hot a utomotive exh a ust system Thermostats 

### Hot pl a te o roven Thermal overload relays Humidity controllers Time switches/relays 

### Inc a n d escent light b ul b Universal relays Isolator switches Programmable controllers Liquid level switch 

### * List is not exh a ustive Prevent live sparking of components and electrocution

• replace or install line shields over electrical contacts

• use solid state relays and controllers in equipment

• fix loose capacitors and other electrical ignition sources Warning Labels - Replace any missing ignition source warnings on HCR188C equipment and gas lines.



### No Open Flames No Smoking

Lockout Tag out (LOTO) - Lockout and tag electrical disconnect switches to protect the worker from energized electrical controls and unexpected motor starts. The tag lists the name and tag out date.

• pull fuses or trip circuit breaker before working

• disconnect battery in automotive work

• test after de-energizing electrical lines

### 4 Energy Stored as Compressed Gas - Relieve system gas pressure before installing safety retrofit kit

• pump out and recover refrigerant

• pump out before breaking fittings
Job Hazard Review – It is the refrigeration technician’s first duty to size up the work area and equipment to identify and mitigate hazards before starting work. A Hazard Review will assure that energy is controlled and adequate PPE is used. First, list the sequence of steps or tasks for the job at hand. Then list what can go wrong at each step. Finally list the safety factors and PPE necessary to prevent accident or injury. This is a good opportunity for HVAC technicians and their supervisor to work the JHR together, developing safe work practices for routine jobs. Job Hazard Review: Cutting the Refrigeration Line to Install a Retrofit Safety Valve

Tas k P r o b le m Acciden t Prevention PPE Require d 1. pump out old refrigerant Vacuum pump fittings leak Hose separates from quick connect Inspect/Replace O-rings Push collar until fitting locks Gloves, Safety Glasses Gloves, Safety Glasses 2. cut refrigeration tubing Sharp edges on cut tubing Use deburring tool Gloves, Safety Glasses 3. install retrofit valve Tight tubing fit, may leak Sand off paint layer first Safety Glasses



### Checks for Electrical Hazards

• verify that electrical ignition sources are eliminated

• check that electrical equipment and lines are in good condition

• complete an electrical ground continuity check

• isolate electrical line voltages from the work area

• verify that lock out tag out is complete
Checks for Mechanical Hazards

• check that guards and shields are installed and in good condition

• inspect entrapment and pinch points around rotating equipment

• remove gloves before worki ng around rotating equipment

• secure loose clothing, long hair, and jewelry

• do not work around rotating shafts, pulleys, and belts unless guards are complete and in place Ask “what can go wrong” and what if...?

• Answer all questions raised before starting work

• Are eye protection and other PPE adequate if something goes wrong?

### 5 • If there is a fire, where is the fire extinguisher?

• Is there a clear exit route from the work area for evacuation? Storing and Transporting HCR188C - We are all required to follow Federal, State and Local safety laws, and the c onsensus Standards; for example from the American National Standards Institute (ANSI), The National Fi re Protection Association (NFPA), and the American Society of Heating, Refrigerati on, and Air Conditioning Engineers (ASHRAE). Some of these standards and safety codes are summarized:

• Close the cylinder (canister) valve after each use and when in storage
o Screw the shipping plug into the cylinder valve before shipping

• Strap or chain cylinders to secure in storage
o Store the cylinder upright
o Lock the cylinder to prevent tampering
o 3-point contact with other cylinders in storage is permitted

• Keep oxygen cylinders away from cylinders of HCR188C or equipment containing HCR188C
o Comply with local codes on flammable gases
o Store with a 20 ft minimum separatio n or use a rated 1⁄2 hour fire wall between oxygen and HCR188C cylinders

• Take precautions against overfilling
o The cylinder must have a work ing overpressure relief device
o Never invert the HCR188C cylinder. The pressure relief device must relieve from the vapor phase, not the liquid phase
o Fill recovery cylinders only to 80% capacity
o The cylinder must have an overfill protection device

• Store HCR188C at an ambient air temperature less than 120 o 

### F
o Do not expose the cylinder to fire or strike an electric welding arc on the cylinder
o Immediately return a cylinder to the vendor if damaged
o HCR188C is filled in Dot-39 20 lb cylinders. Should a need for a smaller cylinder be required for service technician s, a cylinder no less than 5 lb will be available. Confined Space Warnings – You can die by asphyxiation if you store or use HCR188C in a confined space. HCR188C like other combus tible and inert gases is an asphyxiate. These gases displace breathing air when released.

• Do not use HCR188C in an unventilated room or space
o Especially do not use it below grade or ground level.
o Do not enter any confined space together with a gas cylinder188C
o For Example, do not ride in an elevator with any gas cylinder 

### Do Not Ride Elevator with A Compressed Gas Cylinder

### 6 • If someone is unconscious in a confined space, do not enter to attempt a rescue. You will become a second victim. Immediately call 911 for help.

### 7 Retrofit Labeling and Color Code – Safety instructions are prominently labeled on the compressor and on the condenser coil. Alert others by replacing any missing pink stickers on compressors and systems containing or re trofitted with HCR188C. (Pink is the EPAapproved color code for HCR188C).

• The Certified Refrigeration Mechanic completes the required information details on the preprinted pink stickers:

o The installer’s name
o The service company’s address
o Date of retrofit
o HCR188C charge rate for the system, grams



## NOTICE: Converted to HCR188C Non-Ozone Depleting This Refrigerant is FLAMMABLE - Take Appropriate Precautions Service by Qualified Personnel Only SERVICED BY: TECHNICIAN: COMPANY:

_ _ _ ADDRESS:

_ _

_ _ _ _ DATE:

_ REFRIGERANT: 

### HCR188C
CHARGE AMOUNT: LBS. OZ. 

### [ Grams 

### ] DO NOT ADD LUBRICANT DO NOT REMOVE THIS LABEL

### 8 Leak Detection - Learn about and prepare equipment for portable leak detection of HCR188C. The manufacturer blends HCR-188C with a warning odor agent (mercaptan) smell.

• Warning Odor
o Replace any missing warning labels on all appliances
o Use a polymer-soap solution to find gross leaks
o Use a battery powered gas sensor fo r detecting hydrocarbon refrigerant
o check all connections and lines with a leak sensor after servicing any unit
o DO NOT use a halogen flame leak detector

HCR188C Warning Odor - Light Refrigeration

• If warning odor is noticed, extinguish smoking materials, turn off burners and other open flames.

• Immediately open windows and doors for ventilation.

• Leave the room.

• The AC manufacturer has added fluor escent dye to the system before charging
o Use an ultraviolet light to find the leak

• Tool and equipment Safety and Best Practices
o Use only proper tools and servicin g equipment approved for HCR188C
o Never improvise tools and service equipment
o Piping and fittings-Comply with all c odes, standards, and best practices

### 9 SECTION 2 .Automotive Air Conditioning Precautions Installation of the Retrofit Safety Ch eck Valve (RSCV)* is mandatory on supply and return lines whenever performing an au tomotive or a split-system air conditioning retrofit to HCR188C. The RSCV includes the EPA-approved quick connect fittings for HCR188C in a tamper-proof design to prevent accidents and injuries. The RSCV is a required safety device installed on the engine side of the firewall. It protects the passenger compartment from a sl ow evaporator coil leak and also prevents a refrigerant discharge into the passenger co mpartment from AC tubing severed in a font end collision. The EPA-approved pink colo r code dust cap seal and pink stripe identify the HCR188C Retrofit Safety Check Valve.

Figure 1 . Required Locations of the HCR188C Retrofit Safety Check Valves (RSCV)

### 9 Front View Side View Figure 2. HCR188C Retrofit Safety Check Va lve * (pink dust cap not shown) *patent pending Retrofit Safety Check Valve Installation Instructions

• Recover pre-existing fluorohydrocarbon refrigerant by pumping into an evacuated and labeled refrigerant canister
o cut out the legacy high and low pressure ports
o deburr the tubing ID and OD to remove any metal chips
o remove paint or powder coat layer from tubing OD using stoppers to keep tubing clean inside
o insert RSCV into appropriate high and low pressure lines
o apply sealant onto the compression ferrule sleeves
o orient the quick connect fittings vertically upwards
o use two opposing wrenches to properly tighten compression fittings

• Use only piping with the required HCR188C pink label

• Use only the dedicated pink-labeled H CR188C refrigerant recovery tanks
o Use an oil filter when recovering HCR188C
o Do not recharge recovered HCR188C back into refrigeration system since HCR188C composition change s during recovery and precludes reuse o Reclaimed HCR188C can be us ed as gas BBQ grill fuel Warning and Precautions

HCR188C Warning Odor - Automotive

• If warning odor is noticed, extinguish smoking materials

• Roll down windows

• Pull off the road when safe to do so

• Turn off ignition, step away from the vehicle

### 10 SECTION 3. Automotive Air Conditioning and Split Unit Air Conditioning
CHARGING – This section describes the approved procedures for charging evacuated CFC or HCFC System with up to HCR188C. This work is to be performed only by a Certified Air Conditi oning Technician. First inspect the work site and remove or fix hazards before starting. Always charge the system with fresh HCR188C to assure the correct charge rate; do not reuse recovered HCR188C. Please see Appendix II for maximum a llowable refrigerant charge based on occupancy category and room size.

• Hookup – Connect the HCR188C charging canister to a gauge set
o check the vacuum pump capacity, HCR188C cylinders, and fittings
o Inspect condition of hoses, fittings, gaskets and O-ring seals
o use the EPA-approved HCR188C ad apter connectors on a standard low pressure gauge set o use the EPA-approved HCR 188C cylinder connection

• Preparation – Charge the system with HCR188C
o Unlock both Retrofit Safety Check Valves (RSCV)

• insert a splined Allen wrench through the quick connect stem

• engage and turn clockwise until the screw stops turning

• attach gauge set hoses with HCR188C adapter fittings to both RSCVs and to vacuum pump before opening slider valve
o Open slider valve

• Slide stem horizontally over the pedestal until cleat stops, aligning the internal valve service ports
o Pump down the system

• evacuate the system to remove moisture and air

• close the vacuum port valve

• Charging the System – Calculate HCR188C charge rate (0.25 x CFC charge).
o attach HCR188C canister

• set on digital scale and tare scale

• open canister valve until calculated charge flows into system.

•

• Sealing the System – Close the HCR188C canister valve.

• slide retrofit safety check valves (RSCVs) closed

• disconnect gage set hoses and fittings

• set anti-tamper lock screw in RSCVs

• install pink cap and tamper seal
RECOVERY – This process describes the approved procedures for recovering and recycling HRC188C refrigerant by a Ce rtified Motor Vehicle Air Conditioning

### 11 (MVAC) Technician. First inspect the work site and remove or fix hazards before starting the recovery and making repairs.

• Hookup – Connect the empty HCR188C recovery canister to a gauge set
o inspect condition of hoses, fittings, gaskets and O-ring seals

• use the EPA-approved HCR 188C adapter connectors on standard low pressure gauge set

• use the EPA-approved H CR188C cylinder connection

• install an oil separator when recovering HCR188C
o connect the hose between the vacu um pump and recovery cylinder

• evacuate the recovery cylinder

• repeat to evacuate additional recovery cylinders

• Evacuating the System – unlock the Retrofit Safety Check Valves

• insert splined Allen wrench through the quick connect stems

• engage and turn counterclockw ise to back out lock screw

• do not slide valve to ope n until hoses are attached
o attach gauge set hoses with HCR188C adapter fittings

• connect to a refrigerant recovery machine (pending EPA clearance)

• if not available, set evacuated canister onto top-loading digital scale; tare to monitor recovery
o open slider valve sliding horizontally over the pedestal until cleat stops travel
o pump down system

• evacuate the system to remove moisture and air

• when fully evacuated, close the vacuum port valve

• Recovering into an evacuated recovery canister
o open the refrigerant canister valve to recover HCR188C from AC system o after recovery, look for a pressure increase on the gauge

• this shows that some refrigerant remains dissolved in oil and that additional recovery is needed

• continue recovery with another evacuated recovery canister until the system holds vacuum
o disconnect recovery setup when pressure is constant

• close both HRC188C RSCVs

• close recovery canister valve

• disconnect gage set hoses and fittings

• Sealing the System – Close the HCR188C canister valve.
o lock RSCVs

• set anti-tamper screw in RSCVs

• install pink cap and tamper seal
o label recovery cylinder contents

### 12 • Recovered HCR188C is not recharged back into refrigeration system

o Note that composition changes dur ing recovery preclude reuse of recovered HCR188C . Recovery cylinder DOT -4BA-400 would be best suited for this use
o Reclaimed HCR188C can be used as gas BBQ grill fuel

• recharge repaired system with fresh HCR188C to assure the correct charge rate

### 13 Section 4, Window Air Conditioner, Air Conditioner, Refrigerator, Freezer, Vending Machines including Wine Chillers and Dehumidifiers
This section describes how to recover HCR 188C from appliances at the end-of-appliance life. Applicable precautionary measures from Section 1 are required when recovering HCR188C. The refrigerant recharging process fo r light refrigeration is also reviewed.

• The HVAC Technician recovers the re frigerant using either a recovery machine or following the recovery process described above in Section 3. In both processes an oil separator is requ ired to isolate clean HCR into the recovery canister.

• 

### If no access port is available, a vampire connection is used to recover all HCR188C from the system under repair , e.g.: removing the compressor or removing evaporator. Old refrigerant is recycled as described in Section 3

.



### • Following the HCR188C recovery, a hand tubing cutter can part the tubing, then compressed air or flushing fluid is used to clear the system of any remaining oil/refrigerant mixture. Clean and degrease all tubing surfaces to prepare for joining the new component.

• The system is evacuated and recharged * through the vampire fitting. The Certified Refrigeration Mechanic completes the required information details on the preprinted pink sticker shown in Section 1:

o The installer’s name
o The service company’s address
o Date of retrofit
o HCR188C charge rate for the system, grams

• Legacy appliances may also require upda ting to sparkless electrical wiring and solid state or potted com ponents to prevent ignition. * The EU and British standards for hydrocarbon refrigerants permit a maximum1.5 Kg. (3.3. lb) charge for sealed domestic appliances.

### 14 SECTION 5. Commercial Refrigeration Compressor Room Precautions

• Room Design - Ensure that non-combustible materials are used for room construction
o Design the room with pressure-relie f blowout panels if a release of refrigerant will exceed the Lower Explosive Level (LEL)
o Provide ventilation for the compressor room

• Vent room to outside air

• place the air inlet at floor level sized match the air discharge fan

• Maintain a negative air pressure balance

• this prevents entrainment into occupied building areas

• else, natural ventilation is acceptable if six to ten air exchanges per hour are maintained

• avoid stratification that could occur in dead air areas, pits, confined spaces; install local ventilation to evacuate these spaces

• Ensure free air movement around all components containing HCR188C

• Run forced ventilation continuously, or

• instead use an exhaust fan activated by fixed combustible gas sensor

• instead use a fan relay set to ensure concentrations no more than 0.5%, which is 25% of the lower explosive level (LEL)

• Use the following type of fan system

• maintains a negative air balance
o prevents leak flowing to other areas

• has non-sparking fan system components

• has an emergency fan contro l outside equipment room

• Use HCR188C fixed leak detection in compressor rooms o Install permanent combustibles sensor if a release can reach the LEL
o The combustibles detector activates exhaust fan system and alarm

• A/V in mechanical room and at facilities trouble desk

• mount heavier-than-air combustibles detector at floor level

• the manufacturer must calibrate the detector for HCR188C, set below one-fourth of LEL=0.5% (as stated in OSHA 29 CFR 1910.94)

• service sensors at manufacturer’s recommended intervals

• Administrative Controls
o Have a response plan if the dete ctor signals a trouble alarm and practice the response action
o Provide for compressor room security

### 15 • The facility owner must provide access key access only to HCR188C-certified technicians
o Post flammable gas warning signs at all entrances

• The signs must warn <<No Open Flames, No Smoking>>
o Eliminate Ignition Sources

• No bare light bulbs, hot plates, other hot surfaces

• use a shielded fluorescent work light

• No open flames or other ignition sources

• use only brushless motors

• Boilers, welding torches, and other open-flame devices must not share this space

• Insulate electrical contacts

• use solid state relays and controllers in equipment

• Enclose the ignition source and use an inert gas purge

• if ignition sources cannot be removed
o Provide fire extinguishers to meet local code requirements

### 16 References

a. ANSI/ASHRAE Standard 34-2007 , Designation and Safety Classification of Refrigerants, 1791 Tullie Circle NE, Atlanta, GA 30329 b. Alaimo, R. J. ed, Handbook of Chemical Health and Safety , Oxford University Press, 2001 c. Callahan, F. J. Swagelok TM 

### Tube Fitting and Installation Manual ; The Swagelok Companies; Solon, OH 1998 d. DOE Jefferson Lab EH&S Manual , Cryogenic and ODH Safety; http://www.jlab.org/ehs/manual/EHSbook-434.html ; 2000 e. Clayton, G., Clayton, F., eds, Patty’s Industrial Hygiene and Toxicology , 5th ed; Wiley and Sons: New York, 2000 f. Colbourne, D ., Ritter, T.J., Hydrocarbon Refrigerant Safety: Standards and Quantitative Risk Assessments , Calor Gas Ltd, Warwick CV34 6RL, UK g. EPA Stratospheric Protection Division, http://www.epa.gov/ozone/desc.html h. European Standard EN 13313, Refrigerating Systems and Heat Pumps, Competence of Personnel , DIN Deutsches Institut fur Normung e. V, Beuth Verlag GmbH, Berlin, 2001 i. National Fuel Gas Code : NFPA 54; National Fire Protection Association: Quincy, MA. 1999. j. OSHA Hazard Communication Standard, 29 CFR 1910.1200, appendix A k. OSHA Permit Required Confined Space Standard, 29 CFR 1910.146 l. OSHA The Control of Hazardous Energy Standard, 29 CFR 1910.147 m. OSHA Personal Protective Equipment Standards, 29 CFR 1910 sections 132-138
n. Storage, Use and Handling of Co mpressed and Liquefied Gases in Portable Cylinders : NFPA 55; National Fire Protection Association: Quincy, MA. 1999. o. Whitmyre, G. Compressed Gases: Compressed Hazards ; American Chemical society; Washington, DC, 1995 p. Whitmyre, G. Compressed Gases: Safe Handling Procedures ; American Chemical society; Washington, DC, 1995

### 17 Appendix I. HCR188C replaces most of these medium-pressure refrigerants : Ozone-depleting substances - Chlorofluorocarbons ("CFCs") (1) CFC-11, also known as fluorotrichloromethane (2) CFC-12, also known as diclorodifluoromethane (3) CFC-13, also known as chlorotrifluoromethane (4) CFC-111, also known as pentachlorofluoroethane (5) CFC-112, also known as tetrachlorofluoroethane (6) CFC-113, also known as 1,1,2-tr ichloro-1,2,2, trifluoroethane (7) CFC-114, also known as 1,2-dich loro-1,1,2,2-tetrafluoroethane (8) CFC-115, also known as 1-chloro-1,1,2,2,2-pentafluoroethane (9) CFC-211, also known as heptachlorofluoropropane (10) CFC-212, also known as hexachlorodifluoropropane (11) CFC-213, also known as pentachlorotrifluoropropane (12) CFC-214, also known as te trachlorotetrafluoropropane (13) CFC-215, also known as trichloropentafluoropropane (14) CFC-216, also known as dichlorohexafluoropropane (15) CFC-217, also known as chloroheptafluoropropane Azeotropic Mixtures (16) CFC-500 (CFC-12/HFC-132a, 73.8/26.2 wt. %) (17) CFC-501 (CFC-12/HCFC-22, 25.0/75.0 wt. %) (18) CFC-502 (HCFC-22/CFC-115, 48.8/51.2 wt. %) (19) CFC-503 (CFC-13/HCFC-23, 59.9/40.1 wt. %) (20) CFC-504 (HFC-32/CFC-115, 48.2/51.8 wt. %) (21) CFC-505 (CFC-12/HCFC-31, 78/22 wt. %) (22) CFC-506 (HCFC-31/CFC-114, 55.1/44.9 wt. %) Ozone-depleting substances - Hydrochlorofluorocarbons ("HCFCs") (1) HCFC-21, also known as dichlorofluoromethane (2) HCFC-22, also known as chlorodifluoromethane (3) HCFC-31, also known as chlorofluoromethane (4) HCFC-121, also known as tetrachlorofluoroethane (5) HCFC-122, also known as trichlorodifluoroethane (6) HCFC-123, also known as dichlorotrifluoroethane (7) HCFC-124, also known as chlorotetrafluoroethane (8) HCFC-131, also known as trichlorofluoroethane (9) HCFC-132, also known as dichlorodifluoroethane (10) HCFC-133, also known as chlorotrifluoroethane (11) HCFC-141, also known as dichlorofluoroethane (12) HCFC-142, also known as chlorodifluoroethane (13) HCFC-221, also known as hexachlorofluoropropane (14) HCFC-222, also known as pentachlorodifluoropropane

### 18 (15) HCFC-223, also known as tetrachlorotrifluoropropane Ozone-depleting substances, continued - Hydrochlorofluorocarbons ("HCFCs") (16) HCFC-224, also known as trichlorotetrafluoropropane (17) HCFC-225, also known as dichloropentafluoropropane (18) HCFC-226, also known as chlorohexafluoropropane (19) HCFC-231, also known as pentachlorofluoropropane (20) HCFC-232, also known as tetrachlorodifluoropropane (21) HCFC-233, also known as trichlorotrifluoropropane (22) HCFC-234, also known as dichlorotetrafluoropropane (23) HCFC-235, also known as chloropentafluoropropane (24) HCFC-241, also known as tetrachlorofluoropropane (25) HCFC-242, also known as trichlorofdifluoropropane (26) HCFC-243, also known as dichlorotrifluoropropane (27) HCFC-244, also known as chlorotetrafluoropropane (28) HCFC-251, also known as trichlorofluoropropane (29) HCFC-252, also known as dichlorodifluoropropane (30) HCFC-253, also known as chlorotrifluoropropane (31) HCFC-261, also known as dichlorofluoropropane (32) HCFC-262, also known as chlorodifluoropropane (33) HCFC-271, also known as chlorofluoropropane

Appendix II. Permitted HCR 188C Charge Based on Room Size and Occupancy Type

Occupancy Type Charge Si z e * System Category Example Domestic 1.5 Kg (3.3 l b ) sealed sys t e m s Ho m es, apart m ents Public 5.0 Kg (11.0 l b ) open ai r o r m achiner y rooms Pu b lic p laces, institutions, businesses Commercial 2.5 Kg (5.5 l b ) p e r sys t e m Offices, m anufacturing Private 10 Kg (22.0 l b ) open ai r o r m achiner y rooms Offices, m anufacturing
Industrial 10 Kg (22.0 l b ) occu p ie d s p aces N on- p u b lic areas Restricted Access 25 Kg (55.0 l b ) open ai r o r m achiner y rooms Cold roo m s, foo d processing, plants * not to exceed, providing ignition sources are not normally present 

### These limits were established by the European Union ( EN 378 annex C of Part 1) 

### to maintain the room air concentration belo w 25% of the lower explosive limit or 0.008 Kg/m 3 

### (0.0005 lb/ft 3 

### ). The British Flammable Refrigerant Standard (BS4434:1995) also allows up to a 1.5 Kg maximum charge, w ith systems using up to 0.25 Kg located anywhere. The maximum charge for systems below ground level is 1.0 Kg.

Please Visit our Website for the Latest Updates: http://www.hcr188c.com/February 22, 2012

Mr. Richard Maruya A.S. Trust & Ilolding. Inc. 44-129 Mikiola Drive Kaneoke. HI 96744

Reference: R441 a Cylinder Size Inl<.mnation

Dear Richard:

In response for information relating [p the cylinder sizes mentioned in the L:.S. EPA's letter of February 22 sent to) ou by \1s. i\1argan:t Sheppard. please notl: the following:
Currently. Com Star International Inc. has bccn tilling a DOT-39 cylinder \vith 20 Ibs of R441a; attached is the Worthington DOT-l9 specitication sheet. The DOT-39 cylinder meets the requirements of and is accepted worldwide 1<'>1' the R441 a refrigerant. This size cylinder and fill rate has been used liJr appliance. uutDl11otin: and air conditioning OEM test purposes.
Since R441a is not currently hcing used commercially in the U.S

.. \Ve have not settled on an appropriate size cylinder lor service technicians. Ilowen:r. a smaller container size and fill rate of 5 lbs would be acceptahk.

The current industry standard reti'jgerant reco\\:r) cylinder normally holds up to 30 Ibs of
a 

### eFe, HCFC or 1/ Fe refrigerant. 110\\ e'er. due to the physical properties Df R441 a this cylinder would most likely hold only 20 lh:-. RecO\w)' cylinder specification sheet is attached.

## ~~e~~l;r-' 

# .....• ',,-:' '-'

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# s~~~~**P'~l~;;'~/** 

# '­

Chief

### E~ccutive Oftieer

ComStar International Inc. 20-45 128 Street College Point. 1\Y 11356 Phone: (800) 328-0142 

### Fax: (718)353-5998 F:mail:**~.~~~L~J_~** ...**)t_n_~>.l...l.r\hl.if** .• 1 1)]' i.. ;: -J', Website: W\vw.comstarproducts.cOt11REF.

NRV W/ LUBRICATED O-RING. B000943S TIN REF. BURST DISC #563090

12" REF. TOP #B120200 

### ,+ 030" ¢.125 -:000" 

# # FLOW 

# --IfORIFICE

DWG. 

### NO·:B1201 OS/295495 WORTHINGTON CYLINDERS 200 OLD WILSON BRIDGE RD COLUMBUS, OH 43085 

# SECTION AA 12" REF. #8120300

49.6# lBS IN 260 PSI PSI 325 PSI PSI STANDARD 00To39

REV BY D PW E PW F DAH 9-02 G DAM 6-06 H NPH 6-19-07 J CAB 1-29-09 COLLAR #B000402



### A l:::::­

PRE-ASSEMBLED KRYTOX

17 5/8"
14 3/8" 1.0. ----I .036" MDT. -11--- ¢12.0"
BODOM



### WORTHINGTON CYLINDERS A Worthln\jton Indu.trI

.. Company

### REFRIGERANT 

### RECOVERY

LARGE RECOVEHY

SPECIFICATIONS

MODEL (LBS.) HEIGHT (IN.) HEIGHT (MM) WATER CAPACITY (LBS) WATER CAPACITY (KG) NOMINAL TARE WEIGHT (LBS.) NOMINAL TARE WEIGHT (KG) CYLINDER DIAMETER (IN.) CYLINDER DIAMETER (MM) CYLINDER VOLUME (CU. IN.) CYLINDER VOLUME (LITERS) COLLAR DIAMETER (IN.) COLLAR DIAMETER (MM) COLLAR HEIGHT (IN.) COLLAR HEIGHT (MM) FOOTRING DIAMETER (IN) FOOTRING DIAMETER (MM) STANDARD SPECIFICATION SERVICE PRESSURE (PSIG) SERVICE PRESSURE (BAR) TEST PRESSURE (PSIG) TEST PRESSURE (BAR) OPTIONAL SPECIFICATION SERVICE PRESSURE (PSI G) SERVICE PRESSURE (BAR) TEST PRESSURE (PSIG) TEST PRESSURE (BAR)

To (on vert to refrigerant capad1y**M;)j(II~lum** ,1!lowdtile**~)ro'i~** c.yln>,,1{>: HI**\iY0'9~"\** :. C S i< \',**tl!~' rp-fil~"'l"dPt**  iho"I>tNl**~l' 7r'F!~)S"C**  '';'" 

# ,. ,p'; ,',' ".'

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. .... )r::- •.... : •..... ,, ....

177 4509 262 11,9 II I.! 9 231 1 /26 11.9

1 I.K 198 1 [)O r 4h/\ L}On 400 )lb 800

WI

.. Nil' NiA 188 417', 41 I

1 1

126 i 2 ] 312 ,1 1,324

1 I

'). I 130

l)() 1 4bA 1,100

) ?b S()O

N/i\

Nil\ 1.23

263

10 254 3.393

3 9 984**~JiA** N/A 10

L)O'l ·<:lBV\} 400 400 )lb 800 5':,2 NiA N//\ Nil\ N1A Nll\ 481 1,231 239 108.4 18', ]',6 14.1 ll3i1 6,591

108 114 289.6

64 163 14. 3683 DOTABW·260 260 1 'J.9 520

Ni/\ N/f, N/A NiA N/A 57.3 1,455 1,000 450 334 151.5

30 762 27,461

450 16 4064

6.9 175 22 558.8 DOTABW·260 260 17.9 520 35.9 DOTABW-400 400 27.6 800 55.2



# , WORTHINGTON 

# 1.4

CYLINDERS A Worthington**Indu~tnt's** CompOIny

200 (lid \''Vds-on Br !dgc HOdd C.olumbu'l., OhiO**L~3085** lO!i·fri.:c' 3bb.VVC,TAhiKS (866.928,2657) Phone: 614.438.3013

FdX: 614.438.3083 (' yi! nd C'l ,;{jJ:Wor"! h I nqtnn I ndustries,(om VVc)rth,1 flU tonC yl Ind0rS.(On

### Print Page 1 of 3

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines
From: Brandon Button Intertek (brandon.button@intertek.com)
To: richard@astrust.com;
Cc: michael.lindeman@intertek.com; terrence.lansing@intertek.com;
Date: Thursday, February 23, 2012 6:08 AM

Hi Richard,
I oversee testing of refrigerant recovery equipment per the AHRI 740 Program. Presently, there are no manufacturers in that Program building equipment specifically designed for R441A or other flammable refrigerants. That is not to say that existing equipment would not be suitable. From a recovery standpoint, propane (R290) and your refrigerant, R441A, would be processed by the equipment in exactly the same way as old generation CFC's, HCFC's, and HFC's. Recovery performance would be expected to mirror other gases of similar saturation pressures. The only difference that would be expected for equipment designed specifically for 'nammable gases would be added requirements with respect to safety. Such equipment would be expected to have no arcing, sparking or high temperature parts, or to have such parts isolated and sealed. That equipment would be evaluated by some hazardous location standard such as ISA 12.12.01 in addition to the regular recovery machine standards such as AHRI 740 and UL 1963. In the automotive world, they have already started mandating flammable refrigerant safety requirements for recovery/recycyle/recharge equipment. An example would be SAE J2843, for equipment servicing R-1234yf (mildly flammable), which outlines performance requirements of such equipment, but has added text addressing the suitablility of components and proper ventilation of the equipment so as to avoid a fire/explosion.

Best regards,
Brandon Button Senior Associate Engineer Phone:

Intertek 1717 Arlingate Lane Columbus, OH 43228 Fax: (614) 279-4642 Email: brandon. button@intertekcorn

wwwintertek.colll 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.



### http://us.mgl.mail.yahoo.com/neo/launch 2125/2012"

. . ,**.'~** " ' "; 

### MairrstreartY E"ngi,neering**.Corporatipn~.** 

### ' Technician Certification.

. \, .;

...**~Uf;'I"**

# ~--:,.-.., ---,.----.'

# ~~;~ MVAC Tec;:hnician Certification EPA Clean Air Section 609 Program c"rtlficatlon Date Sept 1 9. 1996

### ;~rtt;.~'~~'l' RICHARD H MARUYA 932CF37761916CBEO has been certified as a Motor Vehicle Air CondlliOnlng Technician as ReqUIred by 4QCFR Part 82 40



### . {!edtflcate 

# of C!ompldwn .1JM4,. /4.,., 

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R**.y~:~~** .PA ApproY8cl**~30.18l13** SAL**\82~** fl

.



# .**~,** l'rMIdInI VIII,. TIllinlr4ll\V**'----,_._._-,._-~--**

### Print Page 1 of 1

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines
From: Michael Lindeman Intertek (michael.lindeman@intertek.com)
To: richard@astrust.com:
Cc: terrence.lansing@intertek.com: brandon.button@intertek.com:
Date: Friday, February 24, 2012 5:35 AM

Richard,
Per our conversation this morning, the UL standard for safety for vending machines is UL541. I looked at UL 541 and Supplement SA in UL541 covers the requirements for refrigerated venders employing a flammable refrigerant in the refrigeration system. Additionally, each unique make and model of vender would need to be evaluated to these requirements to ensure thier safety in the event of a refrigerant leak. If you have any additional questions, please feel free to contact me anytime. Thanks,
Mike Lindeman Phone:

Intertek 1717 Arlingate Lane Columbus, Ohio 43228 Fax: 614-279-4642 Email: michaellindeman@lntertek corn

wwwintertek.com

Valued Quality. Delivered.

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://wwwlfltertek.col11



### http://us.mgl.mail.yahoo.com/neo/launch 2/25/2012

### ul-541.8 

### Page 1 of 1 

# Re'frigerated Vending Machines UL 541
1 Scope
1.1 These requirements cover self-contained, refrigerated vending machines intended for connection to alternating-current circuits rated 600 volts or less in accordance with the National Electrical Code, ANSI/NFPA 70. Venders machines covered by these requirements: a) Incorporate refrigeration systems of the air-cooled or water-cooled type employing hermetic refrigerant motor-compressors; b) May be battery operated; c) May employ flammable refrigerant as defined in Requirements for Refrigerated Venders Employing a Flammable Refrigerant in the Refrigerating System, Supplement sa; d) May employ thermoelectric chilling systems.
1.2 These requirements do not cover vending machines incorporating universal motors rated at more than 250 volts, nor vending machines which have a principal function other than storage and dispensing of refrigerated products; nor to vending stations, that is, freestanding stationary structures for outdoor use.

Purchase UL Standards UL Standards InfoNet UL Standards Catalog



### http://ulstandardsinfonet. ul.com/scopes/0541.html 2/25/2012

### Print Page 1 of 3

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines
From: Jafa. Emad {PAS} (emadjafa@pepsico.com)
To: richard@astrust.com;
Date: Friday, February 24. 2012 12:52 PM

Richard,
I have no idea, but what I suggest is to contact Chevron or Linde who provide and sell HC refrigerant and understand the details for that or any refrigerant suppliers.
Thank you,
Emad

From: richardastrust.com [mailto: richard@astrust.com] Sent: Thursday, February 23,201210:29 AM To: Jafa, Emad {PAS} SUbject: Fw: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines



### Emad

# 

### 2 from the EPA is asking a question which I know

you have worked with. Would you be able to share any information with me.

Thank you

Richard

Richard Maruya

http://us.mgl.mail.yahoo.com/neo/launch 2/25/2012