7705 Technology Drive Melbourne Florida 32904 

Phone 321-951-9464 Fax 321-728-9071

April 13th, 2015

Supplement to submittal under Docket ID No. EPA-HQ-OAR-2014-0198

Air and Radiation Docket

U.S. Environmental Protection Agency

1200 Pennsylvania Ave. NW

Mail Code 6102T

Washington DC 20460 

RE: Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the 

Significant New Alternatives Policy Program (79 Fed. Reg. 46,126 April 3, 2014

Dear Sir/Madam:

Structural Composites, Inc and its sister company Compsys, Inc (SC), of Melbourne Florida has 

commented (20 Oct 14) on the Environmental Protection Agency’s (EPA) proposed rule titled “ 

Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant 

New Alternatives Program” published in the Federal Register on August 6, 2014. 

We want to add new consideration to the growing body of evidence that the 134A foam blowing agent 

is largely retained in the foam. Our Preform process results in a structure that is completely 

encapsulated in composite, and as the 134A molecule is very large it cannot escape through the 

composite matrix. In discussion with our supplier BASF we estimate an order of magnitude decrease in 

the CO2 equivalent from the current method which assumes 100% of the 134a is released. We believe 

that for use in Preforms for Composites (boats, transportation, infrastructure and the like) we estimate 

the CO2 equivalent of 120 vs the current 1400.

In our past letters our GHG Return on Investment calculations were based on the CO2 factor of 1400, 

While this was favorable and had a 2 year break even, The GHG ROI will dramatically increase if we can 

properly account for the 134a retained in the foam.

As we have no alternative for our preforming technology and as we can clearly demonstrate that our 

technology has a GHG Return on Investment in life cycle GHG, we hereby request a full exemption for 

use of 134a as a blowing agent in foam used in our composite preforms. 

Thank you,

Scott M. Lewit

President

321-252-4566

slewit@aol.com
 7705 Technology Drive Melbourne Florida 32904 

Phone 321-951-9464 Fax 321-728-9071

Appendix A- Green House Gas Return-On-Investment Calculations

The following is used from

http://www.epa.gov/climateleadership/documents/emission-factors.pdf

Gas and Diesel CO2 Equivalents

Thus from the above EPA data it is determined that 

Diesel has 22.49 lb/gal of GHG

Gasoline has 22.39 lb/gal of GHG

Refrigerated Trailer Example- Prisma Advanced Trailer- 53ft. Semi- Trailer-Refer- 15% weight reduction, 

25% better Thermal, double the current life cycle.

The trailer uses approx. 80lbs of 134a in the polyurethane foam thus it produces 114,400 lbs of GHG, it 

is non-recurring during the foaming process, it is trapped in the foam and encased in the composite.

Product Foam Usage- Impact- Fuel Offset Needed- it will take 5,086 gal of fuel savings to offset the GHG 

due to the non-recurring GHG in the 134a foam.

Fuel Usage- Semi Refer Trailer usage is 22,630 gal/year

CO2 1 emission-factors.pdf

134A 1430 emission-factors.pdf

245fa 1030 emission-factors.pdf

N2O 298 emission-factors.pdf

CH4 25 emission-factors.pdf

emission-factors.pdf 4 APL 14 CO2 CH4 N2O

Gas 8.78 kg/gal 19.316 lb/gal 0.000837 0.000176

diesel 10.19 kg/gal 22.418 lb/gal 0.000925 0.000176

Refer Trailer Analysis

Thermal 25% Improvement

Weight 15% Reduction

Life 2 Times 15 yrs

GHG in Trailer

Foam 1000 foam factor CO2

134a 80 lbs 1430 114400 lbs One Time Non-Recurring

134A-GHG 114400 lbs

Fuel Needed 5086 Gallons

Annual Usage- Refer Trucks

units gal fuel gal/Truck per year

Truck 59,659.00 1,350,114,617.00 22,630.53 Per Unit Annual Fuel

Paper 06-2567 Estimation of Fuel Use by Idling Commerical Trucks Center for Transportation Reseach ANL
 7705 Technology Drive Melbourne Florida 32904 

Phone 321-951-9464 Fax 321-728-9071

GHG Savings due to Reduced Weight is approximately 25 tons/year or 650,000 lbs net GHG savings over 

the life of the trailer. This gives a net GHG ROI of 6.7.

Estimated GHG Savings due to Increased Refrigeration Efficiency- 25% efficiency gain. Assuming 30% 

duty cycle it shows a 15 year GHG ROI of 1.9

The Summary for the trailer is below- the Data shows a GHG ROI of 860% and a fuel savings of over 

$160,000 over the 15 year life cycle. This is conservative as ROI is based on fuel savings alone and does 

not factor in extended life, improved thermal efficiently retention and reduced maintenance.

134A usage in Boats- Prisma Technology has demonstrated significant weight reductions for boats. A 

1995 Baseline Sea Ray 250 converted from Wood to Prisma had a 50% reduction in hull weight (Industry 

Award Entry). It allowed a V6 Engine in-place of a V8, smaller trailer, lighter tow vehicle, extended life.

GHG Savings annual 7yr 15yr NET 15 GHG ROI MULT

Payload Efficency 10% 50,904 356,330 763,564 649,164 6.674514

Fuel Use GPH Savings GHG Sav/Hr hrs to GHG Break evenDays Run Time Duty Cycle Payoff Payoff-YR Life-YR GHG ROI MULT

Refer 1 0.25 5.62340969 20344 847.6470554 30% 2825.49 7.741069 15 1.9

Fuel Savings $/YR 7yr 15yr

Transport Savings $ 8,713 $ 60,989 $ 130,691

Refigeration Savings $ 2,398 $ 16,786 $ 35,971

GHG Savings (lbs) GHG/YR 7yr 15yr

Transport Savings 50,904 356,330 763,564

Refigeration Savings 14,778 103,448 221,675

Total 65,683 459,778 985,239

134A NonRecurring 114,400 114,400 114,400

NET Total GHG (48,717) 345,378 870,839

Data Indicates that GHG payoff in 2 yrs GHG ROI 15 Years 8.6

Boat Size Foam Gal Fuel Needed

(ft) 134A To Offset GHG Note

20 8 590 Floatation Required

25 6 443 Structure Only-Gas

40 8 509 Structure Only- Diesal