DuPont Fluoroproducts Chestnut Run Plaza P.O. Box 80702 

# Q*PDN DuPont Fluoroproducts Wilmington, DE 19880-0702

cc: Alan F. Kessler March 4, 1999

Office of Hearings and Appeals U. S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585-0107 

### Amana Application for Exception m

0 We are in receipt of a copy of the Amana Application for Exception of the Department of Energy, 10 CFR Part 430. Receipt of this notification was delayed resulting in our late response. I hope your offices can still incorporate our input.

Our technical staff has studied the Amana request and compared it with both our knowledge and experience within DuPont as well as our experience based on interactions we routinely have with other U.S. equipment producers. It is our opinion that while many of Amana's claims are correct and justified, we feel their request should not be accepted. Other manufacturers have been able to develop options beyond those listed in the Amana request in such a way as to allow them to meet proposed DOE standards. The refrigerator/freezer polyurethane foaming technology has traditionally been based on blowing agents which are liquids at room temperature. When CFC blowing agents were phased out, new compounds and technologies were pursued and are being developed. While there may be uncertainty around new liquid compounds (like HFC-245fa) for use in traditional technology, new technology using blowing agents which are gases (low boiling point) at room temperature (e.g., HFC-134a) has progressed significantly. Background data in the report for HFC-134a foams is limited (confidentiality reasons), but the overall discussion is concerned with lower insulation values for HFC-134a foams. As is the case with any new technology, initial results may not achieve desired performance. However, published research work has shown that the technology can be optimized and that HFC-134a technology is commercially available for use today. In fact, HFC-134a appliance foam technology was commercially used in Europe in 1993.

FI do Pont de Nemours and Company ® Printed on Recycled Paper DuPont

# Fluoro~rOducts#-1 Chestnut Run Plaza P,O, Box 80702 Wilmington, DE 19880·0702


### DuPont Fluoroproducts

Office ofHearings and Appeals U.S, DepartmentofEnergy 1000 Independence Avenue, SW Washington, DC 20585-0107 cc: Alan F. Kessler March 4, 1999



### Amana Application for Exception ::D ..D ..D ::;r::::**~** ::.:0

I co 

### J>



# - 0 (}"l We are in receipt ofa copy ofthe Amana Application for Exception ofthe Department ofEnergy, 10 CFRPart430. Receipt ofthis notification was delayed resulting in ourlate response. I hope your offices can still incorporate ourinput. Ourtechnical staffhas studied the Amanarequest and compared it with both ourknowledge and experience within DuPont as well as ourexperience based on interactions we routinely have with otherU.S. equipment producers. It is ouropinion that while many ofAmana's claims are correct andjustified, we feel their request should not be accepted. Other manufacturers have been able to develop options beyond those listed in the Amana request in such a way asto allowthem to meet proposed DOE standards. Therefrigerator/freezerpolyurethane foaming technology has traditionally been based onblowing agents which are liquids at room temperature. When CFC blowing agents were phased out, new compounds and technologies were pursued and are being developed. Whilethere may be uncertainty around new liquid compounds (like HFC-245fa) for use in traditional technology, new technology using blowing agents

,which aregases (lowboiling point) at room temperature (e.g., HFC-134a) has progressed

significantly. Background data in the report for HFC-134afoams is limited (confidentiality reasons), butthe overall discussion is concerned with lower insulation values for HFC-134a foams. As is the case with any newtechnology, initial results may not achieve desired perfonnance. However, published research work has shown that the technology canbe optimized and that HFC-134atechnology is commercially available for use today. In fact, HFC-134a appliance foam technology was commercially used in Europe in 1993.

F I du Pont de Nemours and Company @ Printed on Recycled Paper 

## -

- '.,



### -

, .' .' '- -, 

## -**~#**Since gas technology can require an additional processing step, some

investment may be needed for a conversion. Gas blowing agent technology, however, offers potential advantages which can also make it economically attractive: • Gasses like HFC-134a, ETC-152a, HCFC-124, HCFC-22, HCFC-142b are commercially available today at competitive prices. • Through reformulation and use of additives, foam k-factors are equivalent to those for HCFC-141b foams. (HFC-134a foam k-factors have been measured as low as 0.135 BTU-in/ft2-hr-°F, which is the k-factor cited for HCFC-141b foams.) • Insulation value for foams made with blowing agent gases increases at low temperature, while foams made with liquid blowing agents decreases at low temperature because the insulating gas is condensing. • Gas foaming technology provides more uniform foam densities and improves the foam's dimensional stability at low temperatures (potential foam cost savings). • HFC gases have zero ODP • HFC-134a, HCFC-22, and HCFC-124 are non-flammable • The ETC and HCFC gases have better toxicity than HCFC-141b (higher allowable exposure limits). • Per attachment A-1, HFC-134a and HCFC-22, at least, have low TEWI.

While we recognize that energy consumption for appliances involves the total unit design, it is important to note that gas (low boiling blowing agents ) foaming technology can-provide insulation foams that perform at levels equivalent to HCFC-141b foams. Gas technology is a viable, competitive, and currently available option for replacing liquid foaming technology, and can produce insulation foams that contribute as much as current foams toward meeting energy standards. Yours truly,

Steven H. Bernhardt, PhD Environmental Manager DuPont Fluoroproducts 

### Since gas technology can require an additional processing step, some investment may be needed for a conversion. Gas blowing agent technology, however, offers potential advantages which can also make it economically attractive:

• Gasses like HFC-134a, HFC-IS2a, HCFC-I24, HCFC-22, HCFC-142b are commercially available today at competitive prices.

• Through reformulation and use ofadditives, foam k-factors are equivalent to those for HCFC-I4Ib foams. (HFC-134a foam k-factors have been measured as low as 0.135 BTU-inlft2-hr_oF, which is the k-factor cited for HCFC-14Ib foams.)

• Insulation value for foams made with blowing agent gases increases at low temperature, while foams made with liquid blowing agents decreases at low temperature because the insulating gas is condensing.

• Gas foaming technology provides more uniform foam densities and**improve~** 

### the foam's dimensional stability at low temperatures (potential foam cost savings).

• HFC gases have zero ODP

• HFC-134a, HCFC-22, and HCFC-I24 are non-flammable

• The HFC and HCFC gases have bettertoxicity than HCFC-141b (higher allowable exposure limits).

• Per attachment A-I, HFC-134a and HCFC-22, at least, have low TEWI. While we recognize that energy consumption for appliances involves the total unit design, it is important to notethat gas (low boiling blowing agents) foaming technology can provide insulation foams that perform at levels equivalent to HCFC-141b foams. Gas technology is a viable, competitive, and currently available option for replacing liquid foaming technology, and can produce insulation foams that contribute as much as current foams toward meeting energy standards. Yourstruly,

# ;d!~1-- StevenH. Bernhardt, PhD Environmental Manager DuPontFluoroproducts