866 Horan Drive Fenton, MO 63026 USA (800) 729-8220 toll-free (636) 349-5333 (636) 349

-5335 fax

October 20, 2014
Air and Radiation Docket Environmental Protection Agency Mail Code 6102T 1200 Pennsylvania Ave. NW Washington, DC 20460 Email: A-And-R-Docket@epa.gov
Delivered via email to: A-And-R-Docket@epa.gov Delivered via upload at regulation.gov (EPA-HQ-OAR-2014-0198) Delivered via UPS

Re: Proposed SNAP Program Status Change RuleDocketID No. EPA-HQ-OAR-2014-0198
Attention: Cindy Newberg: Clayton Corporation appreciates the opportunity to submit comments on the Environmental Protection Agency's ("EPA") proposed rule for Protection of Stratospheric Ozone: Change of Listing Statusfor Certain Substitutes Under the Significant New Alternatives Policy Program ("SNAP") dated August 6, 2014. Clayton Corporation has particular concerns regarding Section V(D)(2b)iv of the SNAP program status change covering Rigid Polyurethane Spray Foam products. This SNAP program status change adversely affects Clayton Corporation's Two Component Low Pressure Spray Polyurethane Foam ("2K LP-SPF") products which require a gaseous blowing agent, as there currently is no stable gaseous blowing agent option available for the purpose ofreformulating ourproducts.
The SNAP listing for alternative non-flammable gaseous blowing agents provides only one option, HF0-1234ze, for our 2K LP-SPF products. Unfortunately, our testing demonstrates that HF0-1234ze does degrade by reacting with other chemical ingredients in the polyol (or 'B') components. This breakdown ofthe HF0-1234ze molecule causes issues with stability, toxicity, corrosion and storage as further outlined in this letter. This appears to be a known issue with two-component polyurethane foam systems containing HF0-1234ze, and is confirmed by Honeywell, the sole supplier of HF0-1234ze, in its published patent application (Patent Reference 7).
There are a number of substantial technical challenges as indicated by our initial testing results ofHF0-1234ze. The testing has shown that HF0-1234ze is not a drop-in replacement to HFC134a. As such, we are required to complete a massive project to reformulate and requalify each ofour 2KLP-SPF products

.

Products With 1 

# [Q

In MindOnce Clayton Corporation is ultimately successful in completing its reformulation, we must then complete a series ofplant trials, field trials, and required certification testing. Clayton sells its 2KLP-SPF products to various industries, each with strictregulatory testing requirements. Each ofthese steps significantly adds to the time frame to comply wit h the SNAP Program.
The proposed transition date ofJanuary 1, 2017 does not provide an adequate amount oftimeto address the identification of a replacement gaseous blowing agent when combined with the lengthy reformulation and testing issues. Accordingly, we ask thatthe SNAP office consider our comments and approve an extension of HFC-134a acceptance for 2K LP-SPF until January 1, 2021. Background
On August 6, 2014, the EPA published a proposed rule change, 40 CFR Part 82, detailing changes to the status of "certain hydrofluorocarbons in various end-uses in the aerosols, refrigeration and air conditioning, and foam blowing sectors". The focus ofthese changes is to phase out the use ofmaterials that have alternatives that pose lower risk overall to human health and/or the environment. Clayton Corporation supports the ultimate goal ofreducing or eliminating the consumption and production of ozone-depleting substances and substances with high global warming potential. Unfortunately, there is only one substitute listed in the SNAP as a replacement for HFC-134a, the non-flammable gaseous blowing agent currently used in 2K LP-SPF. This proposed substitute, HF0-1234ze, has not been sufficiently laboratory tested or field tested in order to demonstrate that it would make a viable replacement for HFC-134a. Testing that Clayton Corpora tion has already completed demonstrates that HF0-1234ze is not a stable, drop-in replacement for HFC-134a.
Historical Precedents
The SNAP program has previously published and executed nineteen rules which allow various industry sectors to take practical steps to make substance transitions in their products. A good example is the HCFC-22 phase-out process for the rigid spray foams industry. The SNAP program allowed the rigid foam industry twelve years (1996-2008) to be ready for the transition. As the substitute, HFC-134a, is a stable chemical and performs similarly to its predecessor, it became almost a drop-in replacement for HCFC-22. The foam industry was able to make the smooth transition intime.
In the current proposed transition the SNAP program is allowing only a two and a half year period to transition from HFC-134a to HF0-1234ze. As our tests have proven, HF0-1234ze is not a stable drop-in replacement thus making the transition more difficult and will require more time than the transition from HCFC-22 to HFC-134a.
The transition from HFC-134a (a stable gaseous propellant) to HF0-1234ze (a non-stable gaseous propellant) will be significantly more difficult than the phase out ofHCFC-22.

2Rigid Polyurethane Spray Foam Systems There are two types of two-component rigid polyurethane spray foam systems, high-pressure ("HP"), and low-pressure ("LP"). These systems have significant differences in their chemistry and packaging attributes. HP uses a liquid blowing agent, such as HFC-245fa, for which the SNAP rule does not adversely impact its product performance, as there is a suitable liquid blowing agent replacement. LP systems require the use of a gaseous blowing agent which is impactedbythe proposed SNAP status change. Descriptions and attributes ofHP and LP are: I. High-Pressure SprayFoam HP systems are sold in non-pressurized 55-gallon drum sets, with 'A' (isocyanate) and 'B ' (polyol blend) components. The 'B' side typically contains polyols, surfactants, catalysts, fire retardant and blowing agent. HP systems are sprayed through a specialized high-pressur e rig where 'A' and 'B' sides are heated and the chemicals are atomized through an impingent mixer under pressure (1200-1800 psi) during application. Since HP systems are used primarily for large volume applications, such as full cavity insulation and roofcoatings, the HP materials are used in a short period oftime. Therefore, the shelf-life requirement for an HP system is only 2-3 months. More importantly, because the 55-gallon drums are not pressurized, it is possible to add additional material into the drums on thejob site, such as adding additional catalyst or surfactant, to correct issues during application. II. Low-Pressure Spray Foam LP kits are sold in pressured 'A' and 'B' cylinders. Since the cylinders are under pressure, they cannot be modified after manufacture in the plant, whereas HP systems can be modified after they leave the manufacturer. The LP systems currently use a non-flammable gaseous blowing agent, HFC-134a. HF0-1234ze is the only non-flammable gaseous blowing agent proposed to replace HFC-134a. In addition to sta bilit y concerns ofHF0-1234ze, there is only one supplier ofthis molecule. HF0-1234ze is only produced by Honeywell, which raises issues with supply considerations. The 2K LP-SPF cylinders are sold with an internal cylinder pressure ofless than 250 psi. The foam is dispensed as a 'froth' using disposable hoses and applicator. These LP kits are sold through distribution, and require a minimum of 12 -18 months shelf stability. Because of chemistry differences, HP and LP products have distinct storage and use requirements. Therefore, the replacement gaseous blowing agent for HFC-134a must be shelf-life sta ble, which HF0-1234zeisnot.

LowPressure Systems Technical Challenges Transitioning to HF0-1234ze
There are numerous technical challenges 2K LP-SPF products face when transitioning to any new raw material. The challenges currently facing the proposed changeover to HF0-1234ze are substantial and time-consuming:

3I. Stability
There are stability concerns using hydrofluoroolefin blowing agent HF0-1234ze. The HF0- 1234ze blowing agent contains a double-bond which causes the molecule to be chemically unstable in both the atmosphere and foam products

. It has been documented in numerous publications, such as Patent references (3) ( 4) (5), that HF0-1234ze adversely reacts with common ingredients of2KLP-SPF, especially amine catalysts. Development work using HF0-1234ze in Low Pressure Systems has shown an almost complete loss ofcatalyst and surfactant function in short-term, aged product testing of2K LP-SPF, which resulted in catastrophic product failures. The HF0-1234ze gaseous blowing agent causes 2K LP-SPF systems shelf life to be reduced from 12 to 18 months to less than 10 days; an unacceptable shelf life. Again, as 2K LP-SPF systems leave the manufacturing plant under pressure, they cannot be modified at a later date to extend their useful life. There has been little, if any information published on stabilizing the gaseous blowing agent, HF0-1234ze. As referenced in an Arkema patent (6), the HF0-1234ze is markedly less stable than the liquid propellant, HF0-1233zd. Therefore, we expect that additional time will be required to convert from HFC-134ato HF0-1234ze.
It will take substantial efforts by the entire 2K LP-SPF industry, including formulators and raw material suppliers, to create new formulation technology to successfully use HF0-1234ze in 2K LP-SPF products. Creating and optimizing such systems will require on extended period oftime to identify, research, and test alternative catalysts and surfactants. One of the most pressing needs is the identification and study ofnon-amine catalyst systems that canbe proven compatible with the HF0-1234ze, ifany exist. Once a stable catalyst system is developed, other aspects of the formulation may need to change such as polyol, surfactant and fire retardant selection. The stability ofthese components will also need to be proven in fully blended systems with the HF0- 1234ze.
There are numerous other characteristics that will need to be optimized through formulation testing once a stable catalyst and blowing agent system has been developed. These include maximizing physical properties ofthe 2K LP-SPF products, which include density, closed cell content, tensile and compressive strength and water absorption, among other tests

. Once all of the reformulation challenges have been worked through, the products will then require the completion ofthird party testing to meet various certifications. If any third-party testing fails, the process is required to start all over again. Third party testing could take up to one year from the start date oftesting.
II. Toxicity and Corrosion
The new HF0-1234ze is known to break apart or adversely react with other ingredients to create toxic and corrosive chemicals, such as hydrofluoric acid ("HF"), as reported by Honeywell (Patent Reference 7). This Honeywell patent references work on Catalysts for Polyurethane Foam Polyol Premixes Containing Halogenated Olefin Blowing Agents (HF0-1234ze, -1233zd). The summary section ofthe patent confirms this gaseous propellant is not a drop-in replacement for HFC-134a. The HF0-1234ze has an adverse reaction with amine catalysts common to rigid polyurethane spray foam systems. This reaction breaks down the molecule of halogenated 4blowing agents (e.g. HF0-1234ze or -1233zd). The result is total loss ofamine, blowing agent, surfactant functionality and significant loss in shelf-life. There are also other unintended consequences that may result by transitioning to HF0-1234ze. There currently is no health hazard data available for by-products ofthe breakdown of HF0- 1234ze in 2K LP-SPF products

. It has been shown in numerous publications that hydrofluoroolefins, in varying degrees, suffer from this type ofdecomposition. This is why we need to identify and test non-amine catalysts to resolve the HF0-1234ze degradation and hopefully solve this stability issue.
III. Storage Hazards Hydrofluoric Acid ("HF") has a potential adverse effect on 2K LP-SPF products as this corrosiveness may cause the container (cylinders) of foam systems to lose integrity. HF is known to attack metal and cause pitting. When the metal inside a pressurized cylinder is pitted, there is a possibility ofthe tank rupturing and exposing an applicatorto toxic chemical vapors.
IV. Manufacturing Concerns
There are numerous manufacturing concerns when a major chemical, in this case HF0-1234ze, is introduced into manufacturing plants. EPA regulations, OSHA regulations and our internal regulations all govern our manufacturing facilities. These regulations require a specific safety testing and training process when we make changes in our manufacturing facilities. These regulatory requirements must be built into the time line ofany formulation changes.
We ha ve both an established Process Safety Management (PSM) as required by OSHA, and a Risk Management Plan (RMP) as required by EPA in our manufacturing facility which address formulation changes. We must follow Management ofChange protocol when changes are made to our manufacturing process (including new chemicals). One ofthe most time-consuming and resource-consuming steps included in the project of changing to the HF0-1234ze will be the replacement of seals and gaskets in our manufacturing equipment to materials that are compatible with HF0-1234ze. It may be necessary to purchase and install new equipment to properly and safely handle the HF0-1234ze inside the plant.
These concerns and others will have to be addressed before any pilot or full-scale batch testing can be undertaken. Once production issues have been resolved field trials can be initiated. An estimateto convert our equipment and performing pilot batches is 180 days.
V. Field Trials I Internal Testing
New 2K LP-SPF product formulas require extensive field testing. Field tests must be performed to ensure these new products are safe and perform under various climate conditions and various types of spray applications. This process includes plant scale-up and the process to coordinate and complete field tests with our customers. Ifthe tests are unsuccessful or ifthe new product formula needs to be modified, this process is required to begin again and potential retesting must also be completed.

5Along with field trials, each product must undergo safety and environmental testing as well. This includes, but is not limited to, MDI emission testing, reentry timing and testing of VOC levels. Itcan take up to twelve months to successfully field trial and approve a newproduct.

VI. Third Party Testing and Certification
2K LP-SPF products must meet numerous regulatory requirements including local, state, and federal regulations and building code regulations. Once field trials are approved, 2K LP-SPF products must undergo rigorous and comprehensive testing by third-party laboratories

. Certifying tests include ICC, UL, FM, and CCMC approvals for 2K LP-SPF products. These statutory tests can only be performed by a limited number of accredited laboratories, and any scheduling conflicts or back-logs at these laboratories may delay the certification process. This situation can be further exacerbated ifall 2K LPF-SPF manufacturers are attempting to test their new formulations containing HF0-1234ze at the same time. This process can take up to 12 months.


### VII. Implementation Timeline
The development process to reformulate 2K LP-SPF products can take an extended period of time; this is especially true as there is not a stable drop-in gaseous blowing agent available. Once a new formulation is developed, other activities are necessary which include manufacturing, testing, and certification activities. The time frame to complete secondary activities canbe tentatively quantified follows: • Manufacturing

- 6 months
• Field Testing- 12 months
• Third Party testing

- 12 months This is not necessarily a definitive list, or implementation timetable, as the times expressed here may lengthen due to reformulation or retesting at any point in the development cycle. The development process, field evaluations, and third party certifications must be completed for every single product line being produced. We have numerous products, each having differences in the formula, distributed to various market segments and each one must be reformulated, retested, andrecertified based on the specific needs ofthat product. European Regulations
The European Union has examined HFC-134a forthe purposes ofprohibiting its use in European markets. In 2006, one component foams ("OCF") were required to discontinue the use ofHFC

- 134a before 2008. This was not a challenge for the European OCF manufacturers as HF0- 1234ze is a stable blowing agent for this technology. The chemistry of OCF systems does not cause a breakdown ofthe HF0-1234ze molecule, unlike the instability documented for 2K LPSPF systems.
However, European Regulations did provide a HFC-134a prohibition extension for 2K LP-SPF products. Regulation (EU) No 517/2014 ofthe European Parliament states a prohibition date of January 1, 2023 for of use of HFC-134a "other foams". Other foams include 2K LP-SPF products. 6Conclusion
Test results demonstrate that the HF0-1234ze gaseous blowing agent is not a stable drop-in replacement for HFC-134a

. This fact makes the January 1, 2017 SNAP deadline impossible to meet. There are a number of very challenging technical hurdles that must be resolved in transitioning from HFC-134a to HF0-1234ze in 2K LP-SPF products. Low pressure spray foam manufacturers require adequate time to resolve technical stability, issues, and reformulate and recertify products. Any reformulation must satisfy the aforementioned health, safety, and stability concerns. Accordingly, Clayton Corporation requests the phase out ofHFC-134abe extended to January 1, 2021.

Sincerely, Clayton Corporation 866 Horan Drive Fenton, MO 63026

7PATENT AND OTHERREFERENCES
1. 72 FR 14432- Protection ofStratospheric Ozone: Listing ofOzone Depleting Substitutes in Foam Blowing, Federal Register Volume 72, Issue 59 (March 28, 2007) 2. David J

. Williams, Clifford P. Gittere, Michael Van Der Puy, "Foams and Foamable Compositions Containing Halogenated Olefin Blowing Agents," US20110039964, Feb 17, 2011 3. David J. Williams, Michael Van Der Puy, "Stabilization of Polyurethane Foam Polyol Premixes Containing Halogenated Olefin Blowing Agents," US20090099272, Apr 16, 2009 4. Juan Jesus Burdeniuc, JeanLouise Vincent, et. al, "Delay Action Catalyst for Improving The Stability ofPolyurethane Systems Having Halogen Containing BlowingAgents," US 20140113984, Apr24,2014 5. Benjamin Bin Chen, Laurent Abbas, et. al, "Improved Stability of Polyurethane Polyol Blends Containing Halogenated Olefin Blowing Agents," US 20140051776, Feb 20, 2014 6. Brett L. Van Hom, Maher Y. Elsheikh, Benjamin Bin Chen, Philippe Bonnet, "Stable Formulated Systems with Chloro-3,3,3-trifluoropeopene," US20140103248, Apr 17, 2014 7. Michael A

.Ross, Ronald Grossman, DavidJ. Williams, Clifford P. Gittere, "Catalysts for Polyurethane Foam Polyol Premixes Containing Halogenated Olefin Blowing Agents," US20120248371 , Oct, 4, 2012

8