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### 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



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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.



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## ~lIiedSignal CHEMICALS AlliedSignallnc. P.O. Box 1053 Morristown, NJ 07%2·1053 

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## 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 forexception. AlliedSignal would like to take this opportunityto provide formal comments on Amana's application. Priorto commenting, however, a brief description ofAlIiedSignal 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 ofthe 30 stocks that make upthe DowJones Industrial Average. The Company employs 70,400 people in some40 countries. Within AlliedSignal's Specialty Chemicals business resides the Fluorine Products division. AlliedSignal Fluorine Products is engaged in the manufacture and sale of: • HydrofluoricAcid • Fluorocarbons (CFC's, HCFC's, HFC's) used in refrigerant, foam blowing, solvent, industrial aerosol, and metered dose inhaleraerosol 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 agentsto various foam end uses including refrigerator/freezer manufacturers. With regard to refrigerators/freezers, priorto the mid-1990's, AlliedSignal sold the U.S. appliance industry CFC-11, which, atthe time, wasthe blowing agent ofchoice in the industry. CFC's, as we now know, are ozone depleting substances. Inthe mid-1990's in the U.S., the appliance industry migrated to the use of HCFC-141b as the blowing agent ofchoice. AlliedSignal today manufacturers and sells HCFC-141btothe U.S. appliance industry. The migration to HCFC-141b was only an interim solution, however, as HCFC-141b, although not as damaging to the ozone layeras 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.

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### 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 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 ofa viable third generation (zero COP) blowing agent. Specificto AlliedSignal's development of HFC-245fa, the Company has expended considerable man hours and significant research and developmentfunds (>$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 ofall possible HFC molecules that meet customer requirements versus the economics involved in the manufacturing ofsaid molecules. • Selection of HFC-245fa as the candidate ofchoice. • Process development centered around the commercial manufacture of HFC-245fa. • Toxicological testing of HFC-245fa. • Production ofsignificant HFC-245fa pilot plant material to support both commercial process design and customertrials. • Technical developmentwith our customers centered around the use of HFC-245fa as a blowing agent. • Oesign ofa commercial HFC-245fa manufacturing facility and an estimation ofthe 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 forexception. AlliedSignal is not in the business ofmanufacturing refrigerators, freezers, or refrigerator/freezers. As such, AlliedSignal has no formal position, for oragainst, concerning the actual granting or rejecting ofAmana's application for exception. AlliedSignal, does, however, wish to provide thefollowing specific comments relating directlyto HFC-245fa: • HFC-245fa is AlliedSignal's candidate moleculeto replace HCFC-141b in foam blowing applications. HFC-245fa possessesthe following positive attributes: • zero-COP • non-flammable • non-VdC • liquid (59.5° F boiling point) • equivalentthermal performance to HCFC-141b • superiorthermal performance when compared to otherzero-COP alternatives (Le. hydrocarbons and HCFC-134a) • low orderoftoxicity • lowTotal EquivalentWarming Impact (TEWI) value

• AlliedSignal is working diligently to commercialize HFC-245fa priorto the 01/01/2003 HCFC141b phase out. Atthis point in time, AlliedSignal fully expects that HFC-245fa

### will be commercially available priorto said phase out date.

• The construction ofcommercial 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 ofa contractual commitmentto the product by our appliance customers. AlliedSignal is working closely with the appliance industry through the Association of Home

Paae 

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### 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

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Appliance Manufacturers (AHAM) to secure this commitment to the product. As part ofthis 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 ofthe supply agreement related concerns expressed by Amana in their application for exception.

• Under section 5 ofAmana'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-141b 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 ofthis 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 forfurther comment with regard to this issue. Again, AlliedSignal has no formal position, for oragainst, concerning the actual granting or rejecting ofAmana'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. Ifthere 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



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