AL a ,alliedSignal

C H E MI C A L S

March 15, 1999

Mr. Fred L. Brown

Deputy Assistant Director

Office of Hearings and Appeals

U.S. Department of Energy

1000 Independence Avenue, S.W.

Washington, D.C. 20585-0107

AlliedSignal inc.

P.O. Box 1053

Morristown, NJ 07962-1053

1Scy.f 'F, A1035

Subject: Case Number VEE-0054: Amana Appliances' Application For Exception To The

Department Of Energy, 10 CFC Part 430, Energy Conservation Program For

Consumer Products: Energy Conservation Standards For Refrigerators,

Refrigerator/Freezers, & Freezers; Final Rule

Dear Mr. Brown:

AlliedSignal has recently received written notification from Amana Appliances regarding their

above referenced application for exception. AlliedSignal would like to take this opportunity to

provide formal comments on Amana's application. Prior to commenting, however, a brief

description of AlliedSignal and AlliedSignal's interests in this matter is appropriate.

AlliedSignal is an advanced technology and manufacturing company serving customers

worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced

materials. AlliedSignal is a Fortune 100 company; additionally, it is one of the 30 stocks that

make up the Dow Jones Industrial Average. The Company employs 70,400 people in some 40

countries. Within AlliedSignal's Specialty Chemicals business resides the Fluorine Products

division. AlliedSignal Fluorine Products is engaged in the manufacture and sale of.

• Hydrofluoric Acid

• Fluorocarbons (CFC's, HCFC's, HFC's) used in refrigerant, foam blowing, solvent, industrial

aerosol, and metered dose inhaler aerosol applications

• Industrial Fluorine Products (SF6, UF6, SbF5, IF5)

• Fluorine Based Pharmaceutical Intermediates

• Fluorocarbon Based Sterilants

Of note, AlliedSignal has been in the fluorocarbon business for more than 40 years.

Specifically, with regard to foam blowing, AlliedSignal has a long history manufacturing and

selling fluorocarbon blowing agents to various foam end uses including refrigerator/freezer

manufacturers . With regard to refrigerators/freezers , prior to the mid-1990 's, AlliedSignal sold

the U. S. appliance industry CFC-1 1, which, at the time , was the blowing agent of choice in the

industry. CFC's, as we now know, are ozone depleting substances . In the mid-1990's in the

U.S., the appliance industry migrated to the use of HCFC -141 b as the blowing agent of choice.

AlliedSignal today manufacturers and sells HCFC-141 b to the U.S. appliance industry. The

migration to HCFC- 141 b was only an interim solution , however, as HCFC-141 b, although not as

damaging to the ozone layer as CFC -11, still has ozone depletion potential (ODP). As such,

and in conjunction with current U.S. regulations , HCFC-141b is scheduled for phase out in the

U.S. on 01/01/2003.

Page I of 3

 EE-RM-93-801 COMMENT 338

~lIiedSignal CHEMICALS 

AlliedSignallnc. 

P.O. Box 1053 

Morristown, NJ 07%2·1053 

=!*-5 

-: ~_ .~L~ ... 

March 15, 1999 

ISqq i,Hi I \-. A 10: 35 

Mr. Fred L. Brown 

Deputy Assistant Director 

Office of Hearings and Appeals 

U.S. Department of Energy 

1000 Independence Avenue, S.W. 

Washington, D.C. 20585-0107 

Subject: Case Number VEE-0054: Amana Appliances' Application For Exception To The 

Department Of Energy, 10 CFC Part 430, Energy Conservation Program For 

Consumer Products: Energy Conservation Standards For Refrigerators, 

Refrigerator/Freezers, & Freezers; Final Rule 

Dear Mr. Brown: 

AlliedSignal has recently received written notification from Amana Appliances regarding their 

above referenced application for exception. AlliedSignal would like to take this opportunity to 

provide formal comments on Amana's application. Prior to commenting, however, a brief 

description of AlIiedSignal and AlliedSignal's interests in this matter is appropriate. 

AlliedSignal is an advanced technology and manufacturing company serving customers 

worldwide with aerospace and automotive products, chemicals, fibers, plastiCS and advanced 

materials. AlliedSignal is a Fortune 100 company; additionally, it is one of the 30 stocks that 

make up the Dow Jones Industrial Average. The Company employs 70,400 people in some 40 

countries. Within AlliedSignal's Specialty Chemicals business resides the Fluorine Products 

division. AlliedSignal Fluorine Products is engaged in the manufacture and sale of: 

• Hydrofluoric Acid 

• Fluorocarbons (CFC's, HCFC's, HFC's) used in refrigerant, foam blowing, solvent, industrial 

aerosol, and metered dose inhaler aerosol applications 

• Industrial Fluorine Products (SFs, UFs, SbFs, IFs) 

• Fluorine Based Pharmaceutical Intermediates 

• Fluorocarbon Based Sterilants 

Of note, AlliedSignal has been in the fluorocarbon business for more than 40 years. 

Specifically, with regard to foam blowing, AlliedSignal has a long history manufacturing and 

selling fluorocarbon blowing agents to various foam end uses including refrigerator/freezer 

manufacturers. With regard to refrigerators/freezers, prior to the mid-1990's, AlliedSignal sold 

the U.S. appliance industry CFC-11, which, at the time, was the blowing agent of choice in the 

industry. CFC's, as we now know, are ozone depleting substances. In the mid-1990's in the 

U.S., the appliance industry migrated to the use of HCFC-141b as the blowing agent of choice. 

AlliedSignal today manufacturers and sells HCFC-141b to the U.S. appliance industry. The 

migration to HCFC-141 b was only an interim solution, however, as HCFC-141 b, although not as 

damaging to the ozone layer as CFC-11, still has ozone depletion potential (ODP). As such, 

and in conjunction with current U.S. regulations, HCFC-141b is scheduled for phase out in the 

U.S. on 01/01/2003. 

Page 1 of 3 
AlliedSignal's interest in the matter at hand centers around HFC-245fa. HFC-245fa is a blowing

agent candidate to replace HCFC-141b. Unlike HCFC-141b, and CFC-11 before it, HFC-245fa

contains no chlorine, and thus, has zero ODP. Within the fluorocarbon industry as a whole,

AlliedSignal has taken the lead in the development of a viable third generation (zero ODP)

blowing agent. Specific to AlliedSignal's development of HFC-245fa, the Company has

expended considerable man hours and significant research and development funds (>$20

million) to develop this product. AlliedSignal has had an active HFC-245fa development

program in place since 1994. This HFC-245fa development program has entailed:

• Working with customers to identify the key characteristics needed in a third generation

blowing agent.

• Identification of possible HFC molecules that meet customer requirements.

• Analysis of all possible HFC molecules that meet customer requirements versus the

economics involved in the manufacturing of said molecules.

• Selection of HFC-245fa as the candidate of choice.

• Process development centered around the commercial manufacture of HFC-245fa.

• Toxicological testing of HFC-245fa.

• Production of significant HFC-245fa pilot plant material to support both commercial process

design and customer trials.

• Technical development with our customers centered around the use of HFC-245fa as a

blowing agent.

• Design of a commercial HFC-245fa manufacturing facility and an estimation of the capital

dollars needed to build said facility.

As can be seen from the above, AlliedSignal has made a considerable investment in HFC245fa. It is the "potential unavailability of HFC-245fa" on which Amana has based it's

application for exception. AlliedSignal is not in the business of manufacturing refrigerators,

freezers, or refrigerator/freezers. As such, AlliedSignal has no formal position, for or against,

concerning the actual granting or rejecting of Amana's application for exception. AlliedSignal,

does, however, wish to provide the following specific comments relating directly to HFC-245fa:

• HFC-245fa is AlliedSignal's candidate molecule to replace HCFC-141b in foam blowing

applications. HFC-245fa possesses the following positive attributes:

• zero-ODP

• non-flammable

• non-VOC

• liquid (59.5° F boiling point)

• equivalent thermal performance to HCFC-141 b

• superior thermal performance when compared to other zero-ODP alternatives (i.e.

hydrocarbons and HCFC-134a)

• low order of toxicity

• low Total Equivalent Warming Impact (TEWI) value

• AlliedSignal is working diligently to commercialize HFC-245fa prior to the 01/01/2003 HCFC141 b phase out. At this point in time, AlliedSignal fully expects that HFC-245fa will be

commercially available prior to said phase out date.

• The construction of commercial HFC-245fa manufacturing capacity for the appliance

industry involves a significant capital expenditure by the Company. AlliedSignal has stated

to the appliance industry that the Company is dedicated to expending the capital required

upon receipt of a contractual commitment to the product by our appliance customers.

AlliedSignal is working closely with the appliance industry through the Association of Home

Paae2of3

 EE-RM-93-801 COMMENT 338

AlliedSignal's interest in the matter at hand centers around HFC-245fa. HFC-245fa is a blowing 

agent candidate to replace HCFC-141b. Unlike HCFC-141b, and CFC-11 before it, HFC-245fa 

contains no chlorine, and thus, has zero COP. Within the fluorocarbon industry as a whole, 

AlliedSignal has taken the lead in the development of a viable third generation (zero COP) 

blowing agent. Specific to AlliedSignal's development of HFC-245fa, the Company has 

expended considerable man hours and significant research and development funds (>$20 

million) to develop this product. AlliedSignal has had an active HFC-245fa development 

program in place since 1994. This HFC-245fa development program has entailed: 

• Working with customers to identify the key characteristics needed in a third generation 

blowing agent. 

• Identification of possible HFC molecules that meet customer requirements. 

• Analysis of all possible HFC molecules that meet customer requirements versus the 

economics involved in the manufacturing of said molecules. 

• Selection of HFC-245fa as the candidate of choice. 

• Process development centered around the commercial manufacture of HFC-245fa. 

• Toxicological testing of HFC-245fa. 

• Production of significant HFC-245fa pilot plant material to support both commercial process 

design and customer trials. 

• Technical development with our customers centered around the use of HFC-245fa as a 

blowing agent. 

• Oesign of a commercial HFC-245fa manufacturing facility and an estimation of the capital 

dollars needed to build said facility. 

As can be seen from the above, AlliedSignal has made a considerable investment in HFC245fa. It is the "potential unavailability of HFC-245fa" on which Amana has based it's 

application for exception. AlliedSignal is not in the business of manufacturing refrigerators, 

freezers, or refrigerator/freezers. As such, AlliedSignal has no formal position, for or against, 

concerning the actual granting or rejecting of Amana's application for exception. AlliedSignal, 

does, however, wish to provide the following specific comments relating directly to HFC-245fa: 

• HFC-245fa is AlliedSignal's candidate molecule to replace HCFC-141b in foam blowing 

applications. HFC-245fa possesses the following positive attributes: 

• zero-COP 

• non-flammable 

• non-VdC 

• liquid (59.5° F boiling point) 

• equivalent thermal performance to HCFC-141b 

• superior thermal performance when compared to other zero-COP alternatives (Le. 

hydrocarbons and HCFC-134a) 

• low order of toxicity 

• low Total Equivalent Warming Impact (TEWI) value 

• AlliedSignal is working diligently to commercialize HFC-245fa prior to the 01/01/2003 HCFC141 b phase out. At this point in time, AlliedSignal fully expects that HFC-245fa will be 

commercially available prior to said phase out date. 

• The construction of commercial HFC-245fa manufacturing capacity for the appliance 

industry involves a significant capital expenditure by the Company. AlliedSignal has stated 

to the appliance industry that the Company is dedicated to expending the capital required 

upon receipt of a contractual commitment to the product by our appliance customers. 

AlliedSignal is working closely with the appliance industry through the Association of Home 

Paae 2 of3 
Appliance Manufacturers (AHAM) to secure this commitment to the product. As part of this

process, AlliedSignal has provided the appliance industry with unprecedented access to

both the manufacturing and capital costs associated with HFC-245fa. AlliedSignal is on an

aggressive path to address all of the supply agreement related concerns expressed by

Amana in their application for exception.

Under section 5 of Amana's application for exemption, Amana claims that their competitors

with manufacturing facilities outside the U.S. would have a significant cost advantage. That

cost advantage would be grounded in a scenario where said foreign manufacturing locations

could continue to produce refrigerators/freezers with HCFC-141 b and ship them into the

U.S. beyond the 01/01/2003 phase out date. AlliedSignal acknowledges that this scenario

could exist. The HCFC-141b would be considered an article and, based on current EPA

regulations, could be allowed as an import into the U.S. However, in informal discussions

with the EPA, AlliedSignal has learned that the EPA is aware of this potential "loophole".

Further, AlliedSignal has been informed that EPA is investigating this matter and can

independently close the "loophole" by baring articles containing HCFC-141 b from entering

the U.S. after 01/01/2003. AlliedSignal would encourage DOE to contact the EPA for further

comment with regard to this issue.

Again, AlliedSignal has no formal position, for or against, concerning the actual granting or

rejecting of Amana's application for exception. AlliedSignal's comments above are intended to

clarify certain aspects relating to HFC-245fa and blowing agents from the Company's point of

view.

If there are additional questions concerning these matters , please contact me at (973) 455-

3187.

Sincerely,

C

clan C. Strauss

Marketing Manager

CC: Alan Kessler, Amana Appliances

AlliedSignal Internal Distribution

Page 3 of 3

 EE-RM-93-801 COMMENT 338

, '. 

Appliance Manufacturers (AHAM) to secure this commitment to the product. As part of this 

process, AlliedSignal has provided the appliance industry with unprecedented access to 

both the manufacturing and capital costs associated with HFC-245fa. AlliedSignal is on an 

aggressive path to address all of the supply agreement related concerns expressed by 

Amana in their application for exception. 

• Under section 5 of Amana's application for exemption, Amana claims that their competitors 

with manufacturing facilities outside the U.S. would have a significant cost advantage. That 

cost advantage would be grounded in a scenario where said foreign manufacturing locations 

could continue to produce refrigeratorslfreezers with HCFC-141 b and ship them into the 

U.S. beyond the 01101/2003 phase out date. AlliedSignal acknowledges that this scenario 

could exist. The HCFC-141b would be considered an article and, based on current EPA 

regulations, could be allowed as an import into the U.S. However, in informal discussions 

with the EPA, AlliedSignal has learned that the EPA is aware of this potential "loophole". 

Further, AlliedSignal has been informed that EPA is investigating this matter and can -

independently close the "100phole" by baring articles containing HCFC-141b fr,om entering 

the U.S. after 01/01/2003. AlliedSignal would encourage DOE to contact the EPA for further 

comment with regard to this issue. 

Again, AlliedSignal has no formal position, for or against, concerning the actual granting or 

rejecting of Amana's application for exception. AlliedSignal's comments above are intended to 

clarify certain aspects relating to HFC-245fa and blowing agents from the Company's point of 

view. 

If there are additional questions concerning these matters, please contact me at (973) 455-

3187. 

SinCerelYC~ 

~.Strauss Marketing Manager 

CC: Alan Kessler, Amana Appliances 

AlliedSignal Internal Distribution 

Page 3 of3