"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 re frigerant 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 asse ssment.
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 p ressure. 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 goo ds 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 ai r 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 workp lace 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 arelease 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 a ssessments. 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

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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

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