"richardastrust.com" 

<richard@astrust.com>

09/09/2007 01:08 PM

To Margaret Sheppard/DC/USEPA/US@EPA

cc

bcc

Subject white goods clarification

For Follow Up: Urgent Priority

History:

This message has been replied to.

Margaret

End use clarification:

My intention for HCR188C is to be used in new refrigerators, freezers and new home air 

conditioning units (window or split unit). To retrofit a used refrigerator or home AC unit is not 

feasible because of cost.

The average 12,000 BTU home window AC unit is around $200.00 and the average-sized 

refrigerator is approx $600.00. When one fails, it is cheaper to buy a new one and not fix it. 

Risk assessment:

Risk assessment for air condition units is attached. It also gives the workers exposure risk.

with maximum charge size risk for large home AC units. Attachments 

"white_goods_amended_Risk.pdf" and "mesa_Weight_Percent.pdf" answers the rest of this 

request. I just received the latter from Don at Mesa Gas - he explains the blending process in a 

refinery atmosphere. As we discussed this will be the most accurate way to blend my product. 

When doing this, it is at its highest level of safety device and rules that are applied to the 

operator. He also tells of the size and type(DOT approved) of cylinders that will be used for the 

refrigerant and the code. 

Please note that I will not bottle in small 1 pound cans.The cylinder sizes here are for certified 

technicians only - ones that are licensed and have the proper training. No do-it- yourselfer is 

likely to purchase 5 pounds only to use just a few ounces.

With EPA clearance, then companies using this product would make training manuals availabe 
and classes mandatory to their technicians under OSHA rules and regulations. I was told this 

morning if HCR188c is not accepted by the EPA, why bother to put together any training 

manuals or classes. Spoke to a ARI engineer and was told that when approved the MSDS on my

product will be the key manual on the training of technicians. That will be the safety guideline 

that they would follow. MSDS attached

Most of the exposure of HCR188c would be at a factory when they charge the new system.

this is done by computer and on a automatic charging machine. 

If there is a failure or warranty, they would just discard it and the store would replace it with a 

new one. The old one is scrapped. Scrap yards just recycle the unit by removing the refrigerant 

and can sell it as propane for a barbecue grill. It would be easier to blend the refrigerant from 

new hydrocarbons. Don has mentioned it would cost more to recycle as a refrigerant again, 

however, it can be done but the cost factor would be more then purchasing a new unit.

I have used a Robinair EPA-approved reclaimer for HCR188c which has an oil-separator

which separates the compressor oil from HCR188C and recycles HCR188C back into a canister. 

I found it much more effective to use the recycled refrigerant in a BBQ charcoal burner. It can be 

reused as a refrigerant but my own personal feeling is that it is such a small amount and that part 

of the blend might get lost in the process so I would rather have a brand new blend in an air 

conditioner. Although I've used it over and over many times, the barbecue grill was the best.

Next email

Richard Maruya

phone 808 2351890 

fax 808 235 0116

cell 808 5614688

e mail richard@maruya.net or richard@astrust.com

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