### Thermo-Kool EPA Comments
I am Lee Thames, Vice President and Operations Manager with Thermo-Kool, a small business walk-in cooler/freezer manufacturer located in Laurel Mississippi.
We currently use an HFC blowing agent to expand the urethane foam in our walk-in panels that is on the unacceptable list by EPA. Since 1992, due to the Montreal Protocol, we have gone 

### through two blowing agent changes; from a CFC to an HCFC and now to an HFC. Each time this has occurred, process ability becomes more and more difficult as well as extreme cost, time and labor due to equipment changes and numerous other parameters that come with each change that highly affects our business.



## 9 Due to the proposea ruie by EPA to phase out the current HFC blowing agents, we are extremely concerned about a number of issues:

1. We believe that the change to the alternative blowing agents are inevitable; however 

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~ the proposed date of lanuary 1, 2017, especially the idea to accelerate the announced a 

## ~ unacceptable blowing agents to January 2016, is totally unreasonable. (_ 

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a. There are three refrigerant companies that have developed HFOs, and only one has a plant that is manufacturing product. However, there is no way that the current capacity of this plant can handle the number of walk-in cooler companies



## ~ and other panel manufacturers that use blowing agents by 2017. In discussion

with an account manager with one of these refrigerant plants, it was stated that after engineering drawings for the plant are completed, it would take approximately 18-24 months to erect the m

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~ acturing plant that could be either built in the states or possibly in Asia. Ther`e w r '` 

## ~ i I n8'Me enough supply of the refrigerants used as blowing agents to supply the entire walk-in manufacturing industry. b. The foam system houses, BASF, DOW and Carpenter, to name a few, do not have systems utilizing HFOs as blowing agents readily available. Based on past development schedules, it takes at minimum, two years for flammability, toxicity and field testing before they feel confident to actually sell a new system to their customers. As a panel manufact rer, the last thing we need is failure or a safety
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## ~ m -4 ers that consist of schools, restaurants, hospitals, hotels, prisons, etc.
c. It took a major appliance manufacturer five years to do developmental testing, 

### :;.o qualify and get an HFO commercially available as the blowing agent.

d. There are a lot of uncertainties regarding equipment modifications that would most likely be required to adjust to the new molecules in the HFOs and if hydrocarbons are used as an alternative, explosion proof motors and equipment would be required. Lead times of the equipment would significantly be increased since this would affect all walk-in manufacturers.

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# ~2. There would be a significant cost burden.


### a. Equipment modifications due to changing to an HFO or hydrocarbon blown systems could be

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~ n the neighborhood of $100K to $500K. b. Third party testing"Ss a m jo ost burden that is required not only for fire safety but for numerous municipalities requiring seismic, wind and other load bearing tests. Every time there is a foam formulation change, new testing is required that easily exceeds $150K for the various tests. Certifying testing labs would not be able to manage the amount of testing in the time frame proposed since this change would affect every walk-in manufacturer in the industry.
c. We are just now recovering from lost margins due to the recession that we have encountered over the recent years. Especially small business are struggling to get back to a financially stable position and just need more time before we have 

### to go through the next generation of the blowing agent changes. d. It has been stated that the new HFO blowing agents would increase the foam system cost by at least .20 per pound which would have to be passed on to our customers, knowing that margins would significantly be reduced since the dollar value of the number of quoted projects would have to be honored in the proposed time frame. 3. Reduced efficiency
a. There are no guarantees that the new foam formulations would have K factors as good as what we have today to satisfy the DOE requirements. If this is the case, we would have to increase the panel thickness in most cases from a four inch thick panel to a five inch thick panel. This alone, would increase the foam cost by 25 percent that, again, would have to be passed on to the end user. b. If thicker panels are required, based on the IBCs section on walk-in coolers/freezers, there would be sprinkler requirements that would add cost to theendusel ~.5 ~@J~


### /It 08-25-14

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