i G ~ iV y" G w E .t/ fS/.~ T 

EPA SNAP Comments 

Wednesday August 27, 2014 

Good Morning. Thank you for the opportunity to be here 

today. 

My name is Kenny Owen. I am Vice President of Engineering 

for Master Bilt Products. Master-Bilt is a small manufacturer of 

commercial refrigeration equipment with manufacturing 

located in New Albany, MS. Master-Bilt employs approximately 

400 people. 

Master-Bilt manufacturers over 215 models of self-contained 

and remote refrigerators and freezers. It also imports over 50 

models of commercial refrigerators and freezers. Master-Bilt 

also manufactures walk-in coolers and freezers and associated 

refrigeration units that go with these walk-ins. 

We manufacture over 700 condensing unit models, 400 

evaporator models as well as custom designed multi circuit 

racks, parallel racks, and Secondary loop parallel racks. 

Every single product we manufacture uses an HFC that EPA 

plans to ban. Every single one. AII refrigeration units use 

either R134a or R404a. R245fa is used for all foam blowing. 

My company is not opposed to converting to more 

environmentally friendly refrigerants and blowing agents but 
EPA must provide a more realistic time than is currently 

proposed. 

When we converted from CFC refrigerants to HFC refrigerants 

in the mid 1990's drop in replacements were readily available. 

So were the components for using these new refrigerants such 

as compressors, and expansion valves. 

At this time no commercially available drop-in replacement for 

R134a, R404a, or R245fa exists. This makes this transition for 

Master-Bilt infinitely more difficult. 

Since the non-drop-in alternatives available and proposed by 

EPA have many bad characteristics such as flammability, 

toxicity, and poor energy efficiency, much more testing is going 

to be required than was required with the switch from CFCs to 

HFCs. Also many proposed alternatives have restrictions on use 

which may prohibit their use in our larger capacity equipment. 

Every one of our 1300+ models will have to be redesigned. 

Every one of our 1300+ models will have to be retested and 

relisted for UL Safety, CSA safety, NSF Sanitation, DOE energy, 

and EPA Energy Star requirements (when applicable). This 

testing can take as long as 18 weeks per model. Even if 

performed concurrently by our small engineering staff, we 

estimate that it will take us working non-stop for over three 

years; and this at the expense of new product development. 
We estimate that this conversion will cost in excess of 1.8 

million dollars. 

And we can't begin the conversion until the components are 

available from our suppliers. I'm sure you will hear from 

component manufacturers or have already from them the 

challenges and time frame required to design and manufacture 

these components. 

Before Master-Bilt can sell these newly redesigned products to 

our customers, many things must take place. Among them are: 

1) our factory will have to be upgraded with many new 

pieces of equipment since our current equipment is not 

compatible with the alternative refrigerants. This will 

be a very large expense to my company and many other 

small businesses. 

2) Our service technicians have to be trained to work on 

flammable, toxic, or extremely high pressure systems. 

3) Our customers will have to be convinced that it is OK to 

have flammable and/or toxic refrigerants in their 

facilities and near their employees and customers and 

around their food products 

4) Our agency testing companies, UL, CSA, and Intertek, 

will have to add a lot of new test facilities since every 

company in the commercial refrigeration industry will 
be redesigning their products and all will require the 

retesting. 

5) Building codes will have to be updated to allow 

flammable and toxic refrigerants. 

These are just a few of things that have to happen. I'm sure 

that many others will be necessary. 

Regarding blowing agents for polyurethane foam, replacements 

are available to replace R245fa. But these blowing agents are 

not drop in replacements for our current foam system. AII are 

either unable to pass Class 1 burn tests which are required by 

building codes, or they are less energy efficient. Less efficient 

foam will cause standard walk-in panels to go from 4" thick to 

5" thick to meet the R value required by DOE. This means our 

manufacturing costs go up and our customers will have to pay 

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Given the facts of the situation, Master-Bilt does not see any 

way we can comply with the 2016 and 2017 deadlines 

proposed. We feel that better alternatives to the currently 

available refrigerants must be developed and made 

commercially available. We think that the proposed phase out 

of the HFC's should be put off until at least 2025 to allow 

enough time for all of the above mentioned things to happen. 

I hope that his brief overview of the situation will help you 

understand the urgency of the matter. Master-Bilt will submit 
detailed comments to EPA before the comment deadline, 

which we request be extended by 60 days. 

Thank you again for the opportunity to be here today.