GASES, WELDING & SAFETY PRODUCTS Airgas, Inc.
259 North Radnor

- Chester Road
Suite 100
Radnor

, PA 19087

- 5283
Tel : 610

- 902

- 622 8
Fax : 610

- 687

- 6932 http://www.airgas.com john.batt @airgas.com September 6, 201 1

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

A irgas 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 P roduction, Import, and Export (76 Federal Register 47 451 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, s ince supply continued to exceed demand, pricing has continued to drop, dropping approximately 8

- 10% this past year alone. The a mple 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 di fficult 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 remaini ng 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 do wn 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 allo wance 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

cre ate 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 s hould 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