UNITED STATES ENVIRONMENTA L PROTECTION AGENC Y WASHINGTON , D
. C
. 20460

OFFICE OF A I R A N D RAD I ATIO N MEMORANDUM SUBJECT: Inadvertent Errors in the Notice of Proposed Rulemaking - Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Sig nificant New Alternatives Policy Program (Tier 3; SAN 5750; RIN 2060-AS 18)

- Correction of Inadvertent Erro rs FROM: Janet G. McCabee1cJ7._ Acting A ss is tant 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 Adm ini strator ( 11 0 lA) 

### UL 

## 2 9 2014 We recommend correcting some inadvertent errors made in the process ofpreparing the signature package for the proposed rule , "Protection of Stratospheric Ozone: Change of Li sting S tatus for Certain Substitutes under the Significant New Alternatives Policy Program, " which was signed on July 9, 2014. The attached red-line/strike-o ut 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 Regis ter.' 1. P age 8, item 6 is amended to clarify that HFC- 1 34a and the HFC blend Formacel 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 i s 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 ofthe preamble and rule. I n t e rn et Add r ess ( U R L) • h ttp ://www. epa .go v Recycled/Recyclable • Prin ted w ith Ve g etable O il Based Ink s on 1 00% Pos tcons u mer, Process C hl orine Free Recyc l ed Paper4. 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 DateHCFC 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 indirec t 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:, spec itied bel·
.... , we are proposing to list, as ofJanuary 1, 2017 , except where allo...,ed under a narrO\\ed use limit.
• HFC-134a and blends thereof as unacceptable i 1 all foam blow ing 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 141indirect 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 -13 4a and certain other HFC refrigerant blends as unacceptable. 6) For 

### a+!- foam blowing end usesaeer s , we are proposing to list, as ofJanuary 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 ofthe end-uses could be broken down further.
Page 38 of 141substitutes that are being used in retail food refrigeration, such as R-407A 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 sub stitutes, 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 li sted 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-507A 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 oftheir use in these other end-uses. For that reason, we have not proposed finding R-404A and R-507A 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 ofthese 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 141thert: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 s heet) ; 8) polystyrene: extruded boardstock and billet; 9) polyolefin; and 10) phenolic insulat i on board and bunstock. In addition, EPA is proposing to change the listing s 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 141fhe**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~** oftheir**anah~is.** See 40 

### CFR 82.180( h )(3) o cumentation •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 sub stitute is needed ;
• Substitutes examined and reject ed;
• Reason for rejection ofother alternatives , e .g. , performance, technical or safety standards; and/or
• Anticip ated date ot her subst itutes will be avai lable 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 f or 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 use s other than spray foam that requir e 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 reque st 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