UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Inadvertent Errors in the Notice of Proposed Rulemaking - Protection of Stratospheric 

Ozone: Change of Listing Status for Certain Substitutes under the Significant New 

Alternatives Policy Program (Tier 3; SAN 5750; RIN 2060-AS 18) - Correction of 

Inadvertent Errors 

FROM: Janet G. McCabee1cJ7._ 

Acting Assistant Administrator 

THRU: Lorie Schmidt {]J.;__£n& ... f /2- J.~S'J m·, d)-\ Associate General Counsel 1\t ) 

TO: 

Office of General Counsel (2344A) 

Joel Beauvais, Associate Administrator ~ec..LU.. v<:? / 

Office of Policy (1806A) J 'c::/ '6 

Gina McCarthy 

Administrator ( 11 0 lA) UL 2 9 2014 

We recommend correcting some inadvertent errors made in the process of preparing the signature 

package for the proposed rule, "Protection of Stratospheric Ozone: Change of Listing Status for Certain 

Substitutes under the Significant New Alternatives Policy Program," which was signed on July 9, 2014. 

The attached red-line/strike-out version of the preamble identifies the errors and shows the corrected 

text. In addition, it does the same for several typographical and grammatical errors and for nonsubstantive edits necessary to make the package consistent with the requirements of the Federal 

Register.' 

1. Page 8, item 6 is amended to clarify that HFC- 134a and the HFC blend F ormacel TI are 

proposed to be unacceptable in all foam blowing end-uses including spray foam. New 

clarifying language regarding "narrowed use limits" indicates that there is an exception for 

military and aeronautics-related applications. 

2. Page 38, for consistency, same correction made as for page 8 above and for the same reasons. 

3. Pages 89-90, the final sentence beginning on page 89 is amended to be consistent with the 

previous two corrections above. 

1 The page numbers cited refer to the attached redline/strikeout version of the preamble and rule. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
4. Page 90, the final sentence in the first paragraph is amended to delete "and 5) HFC-134a and 

blends thereof in spray foam," to remove redundancy. 

5. Page 1 09, the beginning of the first paragraph is revised to refer directly to the regulatory 

requirements rather than referring to Agency guidance for information that would need to be 

documented in support of an application under a narrowed use limit. 

We recommend that you correct these inadvertent errors and approve these changes by signing and 

dating below. 

Attachment 

Gina McCatthy 

Administrator 

Date 
HCFC Blend Delta (also known as Free Zone), Freeze 12, GHG-X5, and HCFC 

Blend Lambda (also known as GHG-HP) as unacceptable starting with MY 2017. 

3) For new and retrofit retail food refrigeration (including stand-alone equipment, 

condensing units, direct supermarket systems, and indirect supermarket systems) and new 

and retrofit vending machines, we are proposing to list, as of January 1, 2016 

• The HFC blends R-507A and R-404A as unacceptable. 

4) For new and retrofit retail food refrigeration (including direct supermarket systems and 

indirect supermarket systems), we are proposing to list, as of January 1, 2016 

• HFC-227ea, R-407B, R-421B, R-422A, R-422C, R-422D, R-428A, and R-434A 

as unacceptable. 

5) For new stand-alone retail food refrigeration and new vending machines, we are 

proposing to list, as of January 1, 2016 

• HFC-134a and certain other HFC refrigerant blends as unacceptable. 

6) For tt!!-foam blowing a~ cntsend uses except spray foam a:, specitied bel· .... , we are 

proposing to list, as of January 1, 2017, except where allo...,ed under a narrO\\ed use limit. 

• HFC-134a and blends thereof as unacceptable i 1 all foam blowing end-uses; 

• HFC-143a, HFC-245fa and HFC-365mfc and blends thereof, and the HFC blends 

Formacel B, and Formacel Z-6 as unacceptable in all foam blowing end-uses 

where they are currently listed as acceptable, except for spray foam applications; 

and 

• The HFC blend Formacel TI as unacceptable in all foam blowing end-uses where 

it is currently listed as acceptable. 

In general, EPA is proposing modifications to the listings based on the SNAP program's 

Page 8 of 141 
indirect supermarket systems), we are proposing to list, as of January 1, 2016 

• HFC-227ea, R-407B, R-421B, R-422A, R-422C, R-422D, R-428A, and R-434A 

as unacceptable. 

5) For new stand-alone retail food refrigeration and new vending machines, we are 

proposing to list, as of January 1, 2016 

• HFC-134a and certain other HFC refrigerant blends as unacceptable. 

6) For a+!- foam blowing end usesaeer s, we are proposing to list, as of January 1, 2017. 

except \\here allowed under a narrowed use limit, 

• HFC-134a and blends thereof as unacceptable _i!l all foam-blo\\ ing end-u..,es; 

• HFC-143a, HFC-245fa and HFC-365mfc and blends thereof, and the HFC blends 

Formacel B, and Formacel Z-6 as unacceptable in all foam blowing end-uses 

where they are currently listed as acceptable, except for spray foam applications; 

and 

• The HFC blend Formacel TI as unacceptable in all foam blowing end-uses where 

it is currently listed as acceptable. 

In general, the dates in this proposal for modifying the SNAP listings are based on 

information concerning the availability of alternatives with lower overall risk to human health 

and the environment for the end-uses considered. EPA is requesting comment on the proposed 

dates. As not~d in the Regulatory Flexibility Act discussion in section IX of this preamble, EPA 

would like information on technical challenges that may exist. EPA is particularly interested in 

information concerning the supply of substitutes in sufficient quantities to meet the dates 

proposed in this action. EPA notes that several of the end-uses could be broken down further. 

Page 38 of 141 
substitutes that are being used in retail food refrigeration, such as R-407 A and R-407F, would be 

theoretically viable in these other end-uses too, given that the operational characteristics of such 

equipment, such as temperature to be maintained, are similar. Those two substitutes, and others, 

have been found acceptable in the four end-uses mentioned. In addition, low-GWP substitutes 

have been found acceptable under SNAP for some of these end-uses, and research is underway in 

the others. For example, for the industrial process refrigeration end-use, R-744, R-717, and 

several HCs have been found acceptable. For cold storage warehouses, R-744 is acceptable for 

new equipment, and R-717 is in widespread use. R-744 for refrigerated transport and HCs for ice 

machines have been tested and, although not yet listed under SNAP, are being used outside the 

United States. In these two end-uses, the list of acceptable refrigerants is similar to that for 

supermarket applications, spanning a wide range of GWPs. Several HFC blends with GWPs 

considerably lower than those ofR-404A and R-507 A are being used in retail food refrigeration, 

especially in supermarkets and, as stated above, are acceptable in the four end-uses mentioned; 

however, we have limited knowledge of their use in these other end-uses. For that reason, we 

have not proposed finding R-404A and R-507 A unacceptable in these other end-uses. 

EPA requests comment on the use and viability of both low-GWP refrigerants (e.g., R744, R-717, and HCs) and other HFC-blends (e.g., R-407A and R-407F) and the possibility of 

listing R-404A, R-507A, and other high-GWP blends unacceptable in any or all of these four 

end-uses--cold storage warehouses, ice machines, refrigerated transport, and industrial process 

refrigeration. EPA also solicits comments on the feasibility of the proposed deadlines and 

whether earlier or later dates would be more appropriate. 

D. Foam blowing agents 

EPA is proposing to change the listings rom acceptable to unacceptable beginning 

Page 89 of 141 
thert:of in all foam blo\\ in!! end-uses. and for. HFC-365mfc, HFC-245fa and blends thereof 'r-Ml 

acceptable to unacceptable beginning Jamtaf) I. 2017 for all foam blowirw end-uses <UtG 

applicatio'ls except spray foam pplication~ . Specific end-uses and applications include: 1) rigid 

polyurethane appliance foam; 2) flexible polyurethane; 3) rigid polyurethane: commercial 

refrigeration, and sandwich panels; 4) rigid polyurethane (slabstock and other); 5) rigid 

polyurethane and polyisocyanurate laminated boardstock; 6) integral skin polyurethane; 7) 

polystyrene (extruded sheet); 8) polystyrene: extruded boardstock and billet; 9) polyolefin; and 

1 0) phenolic insulation board and bunstock. In addition, EPA is proposing to change the listings 

from acceptable to unacceptable for the following foam blowing agents in the following end-uses 

as of January 1, 2017: 1) Formacel Bin polystyrene (extruded boardstock and billet); 2) 

Formacel TI in rigid polyurethane appliance foam, rigid polyurethane (spray, commercial 

refrigeration, and sandwich panels), rigid polyurethane slabstock, integral skin polyurethane, 

polystyrene extruded sheet and polyolefin; 3) Formacel Z-6 in rigid polyurethane appliance 

foam, rigid polyurethane (commercial refrigeration, and sandwich panels), rigid polyurethane 

slabstock, polystyrene (extruded boardstock and billet), integral skin polyurethane, and 

polystyrene extruded sheet; and 4) HFC-143a in phenolic insulation board and bunstock-;-' ~ 

Hl·C 13 Ia and blends thereof in spra~ team. 

1. Background 

Foams are plastics (such as polyurethane or polystyrene) that are manufactured using 

blowing agents to create bubbles or cells in the material's structure. The foam plastics 

manufacturing industries, the markets they serve and the blowing agents used are extremely 

varied. The range of uses includes building materials, appliance insulation, cushioning, furniture, 

Page 90 of 141 
fhe Agene~ has guidance de:.eribing additional dl ndcr a nammed use limit. the end 

user for a militan or space- and aeronautics- related application \\Ould need to ascertain that 

other alternati\es are not technicalh feasible and document the result~ of their anah~is. See 40 

C FR 82.180( h )(3) ocumentation •1::.er:s :should include for narro· ... ed use application·,. {C-ite--te 

name of guidance and ""here it is U'• ail able to the public) 1 his infom1ation shou \. include 

descriptions of: 

• Process or product in which the substitute is needed; 

• Substitutes examined and rejected; 

• Reason for rejection of other alternatives, e.g., performance, technical or safety 

standards; and/or 

• Anticipated date other substitutes will be available and projected time for 

switching. 

' EPA is seeking comment on this proposed narrowed use limitation for military or space- and 

aeronautics-related applications In addition, EPA is also seeking comment on the timeframe for 

this narrowed use limitation, recognizing that if all alternatives are not qualified in advance of 

2022, the Agency may need to revisit and adjust the end date. 

f. Summary 

EPA seeks comments on changing the listings for the proposed foam end-uses. In 

particular, EPA is interested in whether there are specific uses other than spray foam that require 

the use ofHFC-134a, HFC-365mfc, HFC-245fa, and blends thereof, or the blends Formacel B, 

Fonnacel TI, or Formacel Z-6 for reasons of fire safety or technical feasibility. We request 

comment on whether closed cell foam products and products containing closed cell foams should 

be subject to the unacceptability determinations, which under our current interpretation would 

Page 109 of 141