## Whitmyre Research

2111 Wilson Blvd., Suite 600 Arlington, Virginia 22201 (703) 351
- 5072 (703) 243
- 4399 (FAX) April 4, 2008 Margaret Sheppard Stratospheric Protection Division SNAP Program U.S. Environmental Protection Agency (6205J) 1310 LStreet, NW Washington, DC 20005 RE: Response to USEPA Comments on Outline for White Goods Fault Tree Analysis Dear Ms. Sheppard: My thanks to y ou and yo ur colleagues for taking the time to review the outline for the fault tree anal ys is report relating to use of HCR
- 188C in white goods. Your comments are a good starting point for reaching an understanding of the key issues to discuss in our report. To continue the discussion, my responses to y our comments are as follows: (1) Sections VI.C and VII.A to Include Recovery During Disposal
. We agree in principal with this comment and will provide some additional limited text. Recovery of HCR
- 188C from appliances at end of product life will be conducted at organized locations by

trained technicians. Recovery operat ions during disposal would consist of removal of HCR
- 188C from appliances using a vampire valve connected to a line, and a recovery

pump to capture the HCR
- 188C until the sy stem is empty . During recovery , HCR
- 188C would be pumped into a tank. Once full, the tank would be picked up by a recy cling company , which would filter the material and re
- bottle it for sale as gas for barbecue grilles. Richard Maru yaand I thought it would be helpful to establish boundaries for the disposal scenario for the Fault T ree Anal ys is. We propose that the disposal scenario end once the recovered HCR
- 188C is picked up by the recy cler. Therefore, occupational exposures in the re
- bottling process, transportation risks for the recovered and re
- bottled material, and residentia l risk for handling of flammable barbecue grille gas products seem to us to be outside of the scope of the Fault Tree Anal ys is. Similarly , we suggest that disposal and recy cling considerations for the appliance body bey ond the recovery

of HCR
- 188C from th e spent products are outside of the purview of the Fault Tree Anal ys is. To include such considerations would really encompass a full Life Cy cle Anal ys is, which I don’t think the Agency is requesting at this time. Once again, for the purpose of the Fault Tree Anal ys is, we think our area of responsibility for the Fault Tree Anal ys is should end once the recovered HCR
- 188C leaves the service center or recy cling center. Does the Agency agree with this?Ms. Margaret Sheppard

Response to USEPA Comments on Outl ine for White Goods Fault Tree Analysis April 4, 2008 Page 2 (2) Addition of Scenario for Untrained Service Technician . You have suggested that we consider adding a scenario for an untrained technician (which would affect Sections VI.C, VI.D, VII.A and VII.B). Richard Maruy a and I have discussed this, and we find that this is a very unlikely scenario, for the following reasons:

- HCR
- 188C will be listed for use in new refrigerator/freezers, window air conditioners, and stand
- alone freezers, not in existi ng appliances.

- Any

new appliances that are “dead
- on - arrival” (DOA) at customer locations would most likely be returned to the store, which would then ship the failed appliance to a service center or appliance recy cling/disposal center. Itis unlikel y that a major chain (e.g., Best Buy) would attempt a DOA repair at a homeowner’s home with untrained technicians.

- The frequency

of release of HCR
- 188C during appliance repair is greatly reduced b y consideration of cost. For low cost appliances such as window air conditioners, the cost of most repairs done in the US using trained technicians could approach the original or depreciated monetary value of the appliance. This would result in a preference for replacement of the appliance and disposal of the defect ive unit, rather than repair.

- The HCR
- 188C guidelines for use, which have been developed at the Agency ’s request, direct that only trained certified technicians handle it.

- It is unlikel y that a service center or appliance recycling center in the US would allow an untrained technician to work with, or handle, an y product that is flammable without proper training. The potential for legal liability would prevent a service center from employing untrained technicians to perform this critical work. Nor would untrained technicians be permitted to work with flammable gases because this would violate both OSHA rules and general industry standards.

- Importantly , it is unclear whether we could even obtain the required data to undertake a Fault Tree Analy sis for the untrained technician scenario. As with any

other product, when warning labels and safet y guidelines are provided to the user, it is up to the individual end user to follow proper procedures. Safe handling is more likely

to happen if the individual using the product has received proper training. This is why

we are specifyingthat HCR
- 188C be used only by trained technicians. Accordingl y, we are respectfully requesting that the Agency withdraw their request to add an untrained technician scenario to the f ault tree analy sis (FTA) for white goods.Ms. Margaret Sheppard

Response to USEPA Comments on Outline for White Goods Fault Tree Analysis April 4, 2008 Page 3 (3) Add Other Cases for W indow AC . We described 3 different cases as examples to be analyz ed in the fault tree anal ys is for window air conditioning units. You have asked that we add an additional case wherein the fan is running but the AC mode is off. We will include this case in the anal ys is if we have the necessary supporting data. Your co nclusion regarding the function of the “vent” we mention for bringing in outside air is correct. (4) Parameter Values in Section VII.D (Consumer Use of W indow AC Unit)
. If we find updated parameter values that are more current that those in the 1991 AD Li ttle report, we agree to provide references for the sources of the values used in our anal ys is. (5) Comment on Safety Valve Not Needed . Unfortunately , m y annotation in the outline in Section IX regarding a lack of need for an y kind of safet y valve wa s inadvertentl y included. This statement in Section IX, which was more really a note to my self rather than a major point, was accidentall y carried over from a draft into the version y ou reviewed. This caused some confusion among reviewers of the outline. The point that was being made was that such a small amount of HCR
- 188C is required in these appliances (HCR
- 188C is a “medium
- pressure” refrigerant) that a pressure relief valve is not necessary

because there is virtuall y no risk of over
- pressurization. I suggest that we delete this point from the outline, given that it has already caused confusion, and not raise this issue in the report, because it is not relevant. Does the Agency agree? My apologies for an y confusion. (6) Correction of Terminology
. Thank y ou for pointing out our incorrect use of the term “registered use”. We will make the correction to “listed use” as you suggest, wherever this would have occurred in our report. I will be providing a signed hardcop y of this letter to y ou for your files via overnight Federal Express delivery . Feel free to contact me at (703) 351
- 5072 or b y email at riskscicom@aol.com if you have an y questions, or if you would like to further discuss the proposed outline. Best regards, Gary Whitmy re, D.A.B.T.
CC: Richard Maru ya(A.S. Trust)