From: Wally Plumley [wplumley@bellsouth.net]
Sent: Wednesday, August 16, 2000 9:14 AM
To: 928
Subject: [928] Re: A/C Help and Knowledge Required

A lister recently recommended R-409A for use in a 928 A/C system. I
thought that I should post this letter from the EPA for additional info.

From: JEFFREY LEVY
Subject: R-409A, MT-31, Duracool
Date: Wed, 14 May 1997

I've received several inquiries recently on three refrigerants:
R-409A, MT-31, and Duracool.  Right up front, let be perfectly clear:
Replacing R-12 with any of these in a motor vehicle air conditioner is
a violation of federal law.  Period.

First, R-409A.  We listed it as an acceptable substitute for R-12 in a
number of stationary uses, but NOT in motor vehicle AC.  Furthermore,
the
manufacturer, Elf Atochem, doesn't want R-409A used in motor vehicle AC,
so
they haven't developed unique fittings or labels.  They have set up a
hotline at 1-800-retro95 where you can get more info.

Second, MT-31.  This is a new refrigerant that we intend to list as an
acceptable substitute for R-12 in a number of stationary uses, but NOT
in
motor vehicle AC.  The manufacturer, Millenia Tech, doesn't want MT-31
used
in motor vehicle AC, and they haven't developed unique fittings or
labels.
Furthermore, we haven't even finalized the decision on stationary uses.

Third:  Duracool.  This is just HC-12a being marketed under a different
name by an Australian company.  It is made in Canada.  It is precisely
the same refrigerant as HC-12a, so it is just as illegal to replace R-12

with this product in motor vehicle air conditioners.

See our web site (http://www.epa.gov/ozone/title6/609) for info on
MVACs,
including fact sheets specifically listing alternative refrigerants and
others discussing the legal status of HC-12a under the SNAP program.

Two more items:  1) our next Notice, the one that will list MT-31 for
stationary uses (but not MVAC!) will also list a new refrigerant that is

acceptable, subject to use conditions, in MVACs:  GHG-X5.  You may see
ads
for it.
2) We recently updated the web versions of several fact sheets to
discuss
the requirement to add a high-pressure compressor shutoff switch when
retrofitting any system that includes a pressure relief device.
The requirement has been in place for over 2 years, but it hasn't
received
as much attention as the fittings and labeling rules.
It's still a requirement, though.  See the fact sheet titled
"Choosing and Using..." for more details.
_________________________________
Jeffrey Levy
USEPA Stratospheric Protection Division
levy.jeffrey@epamail.epa.gov
EPA & Ozone Depletion Web Site - http://www.epa.gov/ozone/



Wally




From: Wally Plumley [wplumley@bellsouth.net]
Sent: Wednesday, August 16, 2000 9:50 AM
To: 928
Subject: [928] Re: A/C Help and Knowledge Required

At 09:25 AM 8/16/00 -0400, Eric L. Johnson wrote:
>Wally,
>Thanks for the info. www.refrigerants.com lists R409A as a direct
>replacement but we were never informed about it being against federal law
>to use it in automotive applications. If you have the exact document,
>please fax it to me asap. R409A seems to work great. We have stickers to
>apply to the systems to notify it has been changed over.
>Thanks again,
>Eric Johnson


The EPA site at http://www.epa.gov/ozone/title6/snap/macssubs.html has the 
last word on the legality of substitute refrigerants for automotive use. 
R-409A is specifically mentioned as illegal in MVAC systems.

One additional comment on R-409A - it is a blend of existing refrigerants, 
and is 65% R-22. R-22, which is commonly used as a household refrigerant, 
has much smaller molecules than does R-12. These smaller molecules can 
readily escape thru the existing rubber lines in an auto A/C system, and 
will also leak more thru the joints and fittings.

Wally