GASES, WELDING & SAFETY PRODUCTS

Airgas, Inc.

259 North Radnor-Chester Road

Suite 100

Radnor, PA 19087-5283

Tel : 610- 902-6228

Fax : 610-687-6932

http://www.airgas.com

john.batt@airgas.com

September 6, 2011

Docket Number: EPA-HQ-OAR-2010-1040 

Air and Radiation Docket and Information Center

U.S. Environmental Protection Agency

Mail Code 6102T

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Re: Docket Number: EPA-HQ-OAR-2010-1040 

Airgas appreciates the opportunity to provide comments to the EPA on the Interim Final Rule 

entitled Protection of Stratospheric Ozone: Adjustment to the Allowance System for Controlling 

HCFC Production, Import, and Export (76 Federal Register 47451 August 5, 2011). Airgas is 

the largest U.S. distributor of industrial, medical, and specialty gases, and hardgoods, such as 

welding equipment and supplies. Airgas is also a leading distributor of refrigerants, as well as 

one of the largest reclaimers of refrigerants. 

The EPA has requested comments on whether new information supports revisiting in the future 

the determinations EPA made in the 2009 Final Rule. These determinations concerned the total 

estimated demand for HCFC–22 in 2010–2014 and the percentage of that estimated demand that 

EPA would address through an allowance allocation in order to encourage reclamation and 

ensure a smooth transition and phase-out of HCFC-22. 

The demand for HCFC-22 has, in fact, changed markedly from the estimate the EPA used in 

2008/9. The demand has continued to drop each year since 2008 faster than EPA anticipated. 

This is good. However, since supply continued to exceed demand, pricing has continued to drop, 

dropping approximately 8-10% this past year alone. The ample and abundant supply of product 

and the ensuing lower pricing has exacerbated the situation, keeping some applications from 

switching to alternative available refrigerant products. The continued demand for HCFC-22 for 

use in newly manufactured “dry” systems is one example.

The fact that so many individuals, contractors, as well as equipment manufacturers have changed 

back to buying and producing HCFC-22 based equipment, is proof that none of these groups 

clearly believe that HCFC-22 will be difficult to get or even be in a supply shortage situation for 

the foreseeable future -- not the type of message that the EPA wants to promote if it expects the 

industry to convert to more environmentally sound alternatives.
With pricing for HCFC-22 remaining low, the value of recovering and reclaiming HCFC-22 is 

depressed. Instead of increasing, as EPA had anticipated, nationally reclaimed volumes of 

HCFC-22 have been relatively flat for the past two years (3,422 MT in 2009; 3,622 MT in 2010), 

remaining down more than 20% from 2008 volumes (4,456 MT), nowhere near the EPA’s 

anticipated need for reclaimed HCFC-22 of 12,500 MT in 2010.

The EPA’s allowance allocations made in the 2009 Final Rule have unexpectedly resulted in an 

ample supply of virgin HCFC-22 in the market, far exceeding demand for the past couple of 

years. It is painfully obvious that if EPA truly wants to encourage the recovery and reclamation 

of HCFC-22 that further, more aggressive, reductions in supply of virgin material are needed to 

create the scenario that the EPA originally envisioned – a very tight supply which would spur 

switching to alternative refrigerants and increased dependence on reclamation.

Current market conditions demonstrate that significantly reduced amounts of HCFC–22 should 

be allocated in future control periods (2012-2014; 2015 and beyond) to encourage reclamation 

while ensuring a smooth and accelerated transition to full phase-out of production. The EPA 

should explore all available options to address this in a future proposed rule.

Respectfully submitted,

John M. Batt

Director of Product Stewardship & Regulatory Advocacy