Sent via Email October 17, 2014 Air and Radiation Docket Environmental Protection Agency 

### 1200 Pennsylvania Ave. NW Washington D.C. 

### 20460 A-And
-R-Docket@epa.gov Re : Proposed SNAP Program Status Change Rule Docket ID No. EPA-HQ-OAR-2014
-0198 DearCindy Newberg, Forno Products Inc. appreciates the opportunityto submit comments in response to the Environmental Protection Agency's (EPA) Significant NewAlternatives Policy Program (SNAP) Office's proposed change of listing status rule for HFC-134a

. We strongly urge the SNAP Office to consider extendingthe Jan.l,2017134a de-listing date forthe following rigid sprayfoam subcategories: low pressure SPF and low pressure pour-in-place. As a manufacturerofthese types offoams, we are deeply concerned at the lack ofsuitable alternative blowing agents forthese two foam categories, as well as the short time granted for adapting tothe only suitable alternative identified by the EPA, Solstice GBA. These foam categories possess unique technical and safety challenges related to reformulation, especially when one considers the stability issues ofthe only available gaseous, non-flammable HFO alternative allowed in the draft ruling

. Further, the proposed de-listing date for HFC-134a (Jan

. 1 , 2017) actually becomes aJan

. 1, 2016 date forthese foam categories because theyare typically sold through distribution and require a one year shelf life

. We strongly support the EPA's ultimate goal of HFC reduction. However , ourfindings showthatan extension oftime will be essential in orderto surmountthe extraordinarytechnical challenges thatwe face in reformulation

. BlowingAgent Requirements for Low Pressure SPF 

### & Pour-in-Place Low pressure SPF and pour-in-place foams require a gaseous blowing agent for proper on-ratio dispensing and chemical cure. The gas creates the pre-expansion ofthe foam, atrait required for applications like air sealing and insulating. Shelf lives ofthese products must be at least one year due to the fact thatthey are sold through distribution

. Flammable blowing agents cannot be considered for safety reasons inthese field applied products. Thus, agaseous, low GWP blowing agent must not be flammable, and must notdegrade during its travels through distribution

.Since the blowing agent is preloaded to maintain on-ratio dispensing in field use, its degradation would produce off-ratio foams, creating health, safety, and product performance issues forend-usersand consumerswho may be inthe vicinity ofthe off ratio (uncured foam)

. Our R&D group has reported that they see rapid blowing agent degradation in every formulation attemptto date with HFO Solstice GBA (Appendix). HFO Solstice GBA, the lone gaseous, non-flammable blowingagent allowed underthe SNAP Office's proposed draft ruling, has been found to be highly unstable in all ofour low pressure produci:s. Other low pressure manufacturers report the same results. This, no doubt, is due to the fact that thismolecule, designed initiallyto breakdown in the atmosphere, is subject to pressures between 150-250 psi within the cylinders containing the low pressure products. In pre-pressurized products such as low pressure SPF and low pressure pour-in-place foams, the well-known organic chemistry principle comes into play; increased pressure rapidlyaccelerates all chemical reactions, in this case the breakdown of HFO Solstice GBA in polyurethane B
-side systems. Furtherdetails are contained in the following sections. Chemist's Challenge Solstice GBA was designed as a nextgeneration blowing agent replacement for HFC-134a. Use of HFOs like Solstice GBA reduces the dependence on HFCs for low pressure foams, and decreases global warming potential from approximately 1400 (HFC-134a) to below 6. Solstice GBA contains a carbon double bond designed to enhance atmospheric degradation, thus maintaining lowglobal warming potential. However, this feature, beneficial tothe environment overall, presents significant technical challenges to the low pressure polyurethane chemist. As mentioned, the arrangement ofatomsthroughout Solstice GBA's structure is designed to enhance its degradation when exposed to harsh conditions (i.e

. UVenergy in the atmosphere). However, this particulardouble bond is also prone to attack by many ofthe components ofstandard low pressure SPF and pour-in
-place formulations. These interactions are accelerated in pre-pressurized systems. Using standard low pressure SPF and pour-in-place ingredients, required for desired cured properties, Forno Products investigations show severe foam degradation (off-ratio, foam collapse, incomplete chemical cure) atthe first shelf life test point of3 months. Overthis short time period, the dispensed foam shows severe degradation, exhibiting poor surface appearance and cell structure (See Appendix). This breakdown in physical properties such as closed cell content leads to furtherfailures, including decreased R-Value and a decrease in performance as an air barrier. The two characteristics which set SPF apart from other building materials. HFC-134a formula replacements will have to carefully design around Solstice GBA's propensityfor degradation and thus requires a completely new approach to formulating. The process of learning and combining new catalysts, flame retardants, and surfactants puts astrain on R&D's abilityto develop a high quality product in the shorttime frame proposed bythe draft rule. Forno Products ChemistJulie Shoemaker states, "The nature ofthis molecule presents significant and novel challenges to the formulators ofour industry. These challenges will require significanttime and resources to overcome and provide the customers ofour Industrywith asuitable replacement forthe quality productsthat they are used to using in theirjobs". Low Pressure OCF vs. Low Pressure SPF & Pour
-in
-Place While it is recognized that Solstice GBA can be stable in low pressure OCF foams, it is also known that OCF formulas require a completely differing set of ingredients (catalysts, flame retardants, polyols) for propercure when compared to low pressure SPF and pour-in-place foams. Low pressure OCF foams are moisture cured, with cure times between 5- 20 minutes. Low pressure SPF and pour-in-place foams, however, require a 30 second- 2 minute chemical cure. These differing requirements- slow moisture cure vs. averyfast chemical cure- separate these product categories. Thus, low pressure OCF ingredients cannot be directly substituted in low pressure SPF and pour-in-place foams. They will not provide the required cure orend
-use properties.

### Stability As mentioned, Solstice GSA is the onlyalternative allowed for low pressure SPF and pour-in-place systems. It repeatedly exhibits rapid degradation in low pressure systems. This chemical breakdown creates off-ratio dispensing or incomplete cured foam, resulting in situations which raise the possibility ofchemical exposure to applicators and consumers. The current use of HFC-134a in low pressure foam systems provides a minimum oneyear shelf life. In fact, most 134a blown foams will still produce safe, qualityfoams longafter the required one year shelf life expires. A critical component ofour R&D effortsfor new products isto eliminate any uncertainties which may occur in the field. The limited phase-outtimeline doesn't allow us sufficient time for the extended shelf life studies needed to reduce potential risks, i.e

. end
-user exposure to uncured foam

. Regarding the rapid degradation ofSolstice GBA witnessed by low pressure manufacturers, Arkoma's Patent Application US 2014/0103248 A1 teaches us: • GC/MS results for a typical B side foam system placed in an autoclave for 24 hours@ 100' Fwith Solstice GBA show 2% degradation ofthe Solstice GBA (HF0-1234ze)

. US 2014/0103248 A1 Examples 9 & 10, pg. 4, Table 4. a. Note: 100' F represents typical transport and storage conditions for low pressure SPF and pour-in-place products in many regions ofthe US. • This fast degradation most likely produces hydrofluoric acid (HF) as a by-product. HF corrodes metal. a. Forno's assessment ofthat potential situation: presence of HF will cause pressurized cylinder leakage, resulting in chemical exposure to unknowing distributors and end users. Through the years, R&D experience at Forno has shown that when HF is developed we can expect pin-hole corrosion to occur in the cylinder, causing the productto leak

. This leakage is a threatto humans and the environment. • "Presence ofalkene linkage it is expected to be chemically unstable, especially relative to HFC" 

### Request for Low Pressure Subcategories and Relationship to EPA Proposed Alternatives We respectfully ask that the EPA SNAP Office review the CPI's submitted comments. These comments represent the polyurethane foam industry's collective beliefthatthe definitions used in the ruling regarding rigid foam are overly broad. We request that 

### low pressure SPF 

### &pour-in-place foam products be considered separately from other rigid spray foams, and offerthe following comments:
• Suggested definition of low pressure SPF: o Used in thermal building insulation and airsealing. Low pressure SPF products are pressurized to <250 psi during manufacture and are sold in pressurized containers as two parts (A-side & 8-side) and are sprayed applied inthe field forthermal insulation and airsealing ofbuildings. • Rule 20 lists eight acceptable substitutesfor HFC-134a in Rigid Polyurethane Spray Foam: HFC245fa (narrow use exemption), HFC-365 mfc/HFC-227ea, C02 , Water, Exxsol, ecomate, HF0- 1234ze(E), and trans-1-chloro-3,3,3 trifluoroprop
-1-ene (HF0-1233zd)

. o However, the onlyviable option for low pressure SPF and pour-in-place foams is HFO Solstice GBA (HF0
-1234ze). The other alternatives are not suitable to use with LP SPF due to use restrictions orsafety considerations: low pressure foam kits need a high vapor pressure propellantto dispel and emptythe kit; flammable options introduce toomany additional in field risks not previously encountered with non-flammable HFC-134a blown systems; and waterand C02 blown foams need the addition of heat and higher pressures to be used successfully. • Japan's Ministryof Economy, Trade, and Industry classifies HFO Solstice GBA (1234ze(E)) as a flammable gas. Honeywell has been tryingto change the categorization for 8 years with no success. • Low Pressure SPF Products are sold through distribution and the methods that we use to transport our products to market must be considered. Atypical transport run can expose the product to elevated temperatures 

### (> lOO"F) which can have deleterious consequences on the shelf life ofSolstice GBA-blown low pressure SPF & pour-in-place products. A shelf-life ofone year is an absolute necessity in order to account fortime spent in the distribution chain and storage by end-users priorto use. • Low pressure products are under constant pressure (150- 250 psi) and with additional heat (i.e. lOO"F) the pressure inside the kits increases, leading to pressure and thermal acceleration ofthe chemical reactions within the foam cylinders. These factors are proven to affect the shelf-life stability ofSolstice GBA in a negative fashion. We will need additional time to test our productsthoroughly so that we can offerourend-users safe and reliable foam products. • A single source supplier. Ifthe foam industry/blowing agent manufacturers are given a reasonable (longer) time frame forthe HFC-134a phase-down in low pressure products, an additional alternative blowing agent may emerge. The presence ofan additional alternative may help ensure minimal disruptions to business, increase end-user safety, and result in the low pressure foam performance required by building codes, fire codes, and other specifications. • Normally, successful low pressure foam formulations go through years ofshelf-life studies, field testing and external testing to ensure that asafe, quality productwill be on the market.


### In conclusion, we requestan additional3 years tofully integrate a safeandeffective transition. The proposedtimeframe to becompliantbyJanuary 1, 2017willforce manufacturers to launch products thatdonotgo through the complete battery oftests, thus increasing risk tohuman health andthe environment. The requestedHFC-134a phase-outin lowpressurefoams would be complete byJanuary 1, 2020. This date would be soonerthan thecurrentEUdeadline of 2021for HFC-134a in two-component PUfoams.

# Sinc**~~J**
Dr. Thomas Fishback Vice-President, Research & Development Forno Products, Inc.

# APPENDIX Compilation of Fomo Products Lab Studies on the Stability of Solstice GBA in Low Pressure SPF and Pour-in-Place Foam Systems Oct. 17, 2014 Julie Shoemaker, Product Development Chemist
Honeywell blowing agent Solstice GBA (HF0-1234-ze(E)) was designed as a next generation blowing agent replacement for HFC-134a; this blowing agent reduces the dependence on hydrofluorocarbons and decreases global warming potential from approximately 1600 (HFC134a) to 6 (HF0-1234-ze(E)).
Currently, the most viable (ONLY??) replacement for HFC-134a in the low pressure spray polyurethane foam industry is the Honeywell Solstice GBA blowing agent. This molecule presents significant technical challenges to a polyurethane foam chemist orformulator based on the inherent structure ofthe molecule, which was designed to break apart in the atmosphere.

The most significant challenge with the mol' ecuie is formulating a product thatwill meet the aggressive shelf life requirements ofthe low pressure spray polyurethane foam industry. Our products are pressurized into cylinders under a pressure ofapproximately 200 psi. The products are exposed to a large range oftemperatures based on the end use application, and are delivered without the aid of proportioning units, etc.
Investigations to date prove degradation ofthe molecule and failure ofthe system at the first time point of 3 months accelerated aging 

# csooq.

Over this short time period, the foam degrades and shows poor surface appearance:

### INmAL 3 MONTH

Additional observations include poor cell structure, a decrease in the foam rise 

## I height and a decrease in the closed cell content



## INITIAL

3 MONTH

A breakdown in physical properties such as closed cell content lead to further failures including decreased R-value 

## I k-factor and a decrease in performance as an air barrier. These are key performance characteristics for many applications in the industry.

### Additional failures of note include an increase in density, which results in significantly decreased product yields, poor compression strength, tensile strength, etc.

Another obvious indicator ofchemistry break down is a significant change in tack free time, an indication of improper cure (as are all ofthe deteriorated properties).

A second failure of note with this molecule is an incompatibility over shelf life with the flame retardant, Tris (2-chloroisopropyl) phosphate (TCPP). TCPP is the most commonly used flame retardant and is required at loading levels ofapproximately 40% to meet the ASTM E84 class I requirement for SPF 

## I building codes 

## I etc. The systems tested using HF0-1234ze(E) fails when levels exceed much over 20% loading.
Laboratory testing proves that a formulation must either be carefully designed around this known degradation to the system, or will require investigation ofa completely new approach to flame retardancy in this industry.

Current generation molecules like HFC-134a do not contain a carbon
- carbon double bond. The new HF0-1234ze(E) molecule contains a double bond as it is designed for degradation to maintain low global warming potential. This design was to address issues in Montreal and Kyoto protocols. This double bond is prone to attack by many other parts ofthe chemistry and will also degrade in our pressurized systems.

The nature ofthis molecule presents significant and novel challenges to the formulators of our industry. These challenges will require significant time and resources to overcome and provide the customers ofour industry with a suitable replacement for the quality products they are used to using in their areas ofexpertise.