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

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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

 EE-RM-93-801 COMMENT 333

DuPont Fluoro~rOducts#-1 Chestnut Run Plaza 

P,O, Box 80702 

Wilmington, DE 19880·0702 

DuPont Fluoroproducts 

Office of Hearings and Appeals 

U.S, Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585-0107 

cc: Alan F. Kessler 

March 4, 1999 

Amana Application for Exception 

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We are in receipt ofa 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 staffhas 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 perfonnance. 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. 

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

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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

 EE-RM-93-801 COMMENT 333

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 of additives, 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 better toxicity than HCFC-141 b (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 note that gas (low boiling blowing agents) foaming 

technology can provide insulation foams that perform at levels equivalent to HCFC-141 b 

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, 

;d!~1--

Steven H. Bernhardt, PhD 

Environmental Manager 

DuPont Fluoroproducts