"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 a ir condition units is attached. I t also gives the workers exposure risk. with maximum charge size risk for large home AC units. A ttachments "white_goods_amended_Risk.pdf" and "mesa_Weight_Percent.pdf" answers the rest of this request. Ijust received th e 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 safet y device and rules that are applied to th e operator. He also tells of the size and ty pe(DOT approved) of cy linders that will be used for the refrigerant and the code. Please note that I will not bottle in small 1 pound cans.The cy linder sizes here are for certified technicians onl y - ones that are licensed and have the proper training. N o 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 availabeand classes mandatory to their tech nicians under OSHA rules and regulations. Iwas told this morning i f 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 safet y guideline that they would follow. MSDS attached Most of the exposure of HCR188c would be at a factory when they

charge the new s ys tem. this is done by

computer and on a automatic charg ing 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 ya rds just recy cle the unit by removing the refrigerant and can sell it as propane for a barbecue gr ill. It would be easier to blend the refrigerant from new h ydrocarbons. 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 E PA
- approved reclaimer for HCR188c which has an oil
- separator which separates the compressor oil from HCR188C and recy cles HCR188C back into a canister. I found it much more effective to use the recy cled refrigerant in a BBQ charcoal burner. It can be reuse d 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
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