Copied from the EPA page, sham retrofits are addressed. Also note the
states you can not drive through with the Hydrocarbon refrigerants. For
the Vanagon, the proper retrofit includes all new hoses, the expansion
valve, draining and flushing the compressor and for some, the addition
of a high pressure compressor cut out.

"Is it legal to replace HFC-134a in a motor vehicle with hydrocarbon
refrigerants such as DURACOOL 12aR and HC-12aR?

In certain circumstances, the replacement of HFC-134a in a motor vehicle
with hydrocarbon refrigerants might be permitted. At a minimum, in order
to avoid violating the Clean Air Act, the motor vehicle A/C system must
have either been originally designed for use with HFC-134a refrigerant,
or must have been previously retrofitted from CFC-12 to HFC-134a
refrigerant, AND no sham retrofit must have occurred to convert the
system to the hydrocarbon refrigerant. In order to avoid violating other
laws, the replacement of the refrigerant must not violate any state or
local prohibition on the use of flammable refrigerants in motor vehicle
A/C systems.
The following 19 states ban the use of flammable refrigerants such as
HC-12aR and DURACOOL 12aR in motor vehicle air conditioning, regardless
of the original refrigerant: Arkansas, Arizona, Connecticut, Florida,
Idaho, Indiana, Iowa, Kansas, Louisiana, Maryland, Nebraska, North
Dakota, Oklahoma, Texas, Utah, Virginia, Wisconsin, Washington, and the
District of Columbia."

Dennis

-----Original Message-----
From: Vanagon Mailing List [mailto:vanagon@gerry.vanagon.com] On Behalf
Of Kim Brennan
Sent: Sunday, April 16, 2006 2:12 AM
To: vanagon@GERRY.VANAGON.COM
Subject: Re: AC convert

Bah. We've been over this before...

In order to be legal, you must first convert from CFC-12 to HC-134,
including fittings. THEN you can convert to Duracool.

As the EPA notes, it is illegal to convert any AC system from CFC-12
to Duracool. However, there is a nice gray area, where there is no
such restriction on AC systems that are using HC-134.

In order to fall into that legal gray area, you must convert to
HC-134 first. Find out how sucky HC-134 is. Then you can switch to
Duracool, and once again enjoy a nice cold AC system.

On Apr 15, 2006, at 9:29 PM, Robert Fisher wrote:

> There may be legal issues, just FYI:
>
> http://www.epa.gov/ozone/snap/refrigerants/hc-12a.html
>
> Cya,
> Robert
>
> ----- Original Message -----
> From: "John Reddick" <SVYOLO@YAHOO.COM>
> To: <vanagon@GERRY.VANAGON.COM>
> Sent: Saturday, April 15, 2006 5:53 PM
> Subject: Re: AC convert
>
>
>> I used Duracool last summer and it worked great.  Far better than
>> 134A.
>>
>> John
>> Vanaru.com