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

02/01/2008 02:07 PM To

Margaret Sheppard/DC/USEPA/US@EPA, Julius Banks/DC/USEPA/US@EPA, 

Dave 

Godwin/DC/USEPA/US@EPA, Darren Burks <dburks@acsalaska.net>

cc

bcc

Subject

Fwd: RE: Additional info needed for HCR-188C in white goods

For Follow Up:

Low Priority

History:

This message has been replied to.

Margaret

Got this from Don on the cylinder and type that should be used.

20lbs of HCR188C is a lot of refrigerant since a refrigerator will be 

using an average of 1 oz total charge.

Will this type of cylinder be acceptable. Don at Mesa has been using this 

for a number

of years for HCR188C.

Please let me know so Darren can continue the risk assessment.

Richard

Don Tyssee <dtyssee@mesagas.com> wrote:

From: "Don Tyssee" <dtyssee@mesagas.com>

To: "'richardastrust.com'" <richard@astrust.com>

Subject: RE: Additional info needed for HCR-188C in white goods

Date: Fri, 1 Feb 2008 10:54:55 -0800

Richard –

There appears to be some confusion. Your refrigerant is a flammable 

liquid 

under its own vapor pressure.

The DOT-39 cylinder referenced in your email to me refers to a 

non-refillable cylinder used for typical refrigerants (see the attached). 

According to US-DOT/Title 49 of the US Code of Federal Regulations, this 

cylinder and valve are allowed only for non-flammable gases or liquids 

under their own vapor pressure (i.e., halocarbon based refrigerants). As 

you will notice, the valve is not very robust in appearance.
The cylinders required by US-DOT/Title 49 of the US Code of Federal 

Regulations for your application are rated for filling (and refilling) of 

low pressure flammable gases and hydrocarbon liquids under pressure. A 

common example would be propane cylinders used for BBQ’s and forklift 

applications. Because of their approved use for flammable gases and 

liquids under pressure, they are much more robust.

In either case as you will see in the attached, all cylinders are 

manufactured with a protective collar so as to avoid damage to the valve 

in the event of dropping or mishandling.

Regards,

Don

From: richardastrust.com [mailto:richard@astrust.com] 

Sent: Friday, February 01, 2008 8:11 AM

To: don tyssee

Subject: Fwd: Additional info needed for HCR-188C in white goods

Don

Can you help me on the cylinder.

Richard

Sheppard.Margaret@epamail.epa.gov wrote:

Subject: Additional info needed for HCR-188C in white goods

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

CC: Godwin.Dave@epamail.epa.gov,

Banks.Julius@epamail.epa.gov

From: Sheppard.Margaret@epamail.epa.gov

Date: Tue, 29 Jan 2008 11:59:37 -0500

Richard,

As we discussed yesterday, there is an important piece of information

that my office requires to complete our review of HCR-188C that you can

provide us.

After careful review, we have additional questions concerning the risk

assessments you have provided for refrigerators, freezers, and window

air conditioning units. In particular, the risk assessments for

occupational exposure provide a typical scenario that would occur during

recharging or disposal of appliances. However, the risk assessments do

not provide a worst-case scenario for the workplace related to an

accident or inappropriate usage of a storage cylinder.

I request that you provide my office with a supplement to the risk

assessments for each end use that considers the possible risks due to a
release from a typical Department of Transportation (DOT) â€“ 39 

storage

cylinder of 30 pounds in an appliance servicing or disposal center. If

you believe that a different size cylinder is likely to be used in the

field with HCR-188C for one or more end uses, please state the sizes you

believe will be used for servicing and disposal in each end use and

provide an explanation for why a cylinder size other than 30 pounds is

appropriate. Then select the largest cylinder size in each end use for

calculations in three supplementary risk assessments.

I expect to follow with a more formal letter later this week. Please

let me know if your risk assessor needs more information to respond to

my request.

Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

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.hcr188c.com

CONFIDENTIALITY NOTICE This e-mail may contain confidential or privileged 

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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.hcr188c.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.