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 61 02T 

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 Rule Docket ID 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 Status for 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 of reformulating our products. 

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 

of our 2K LP-SPF products. 

Products With 

1 [Q In Mind 
Once Clayton Corporation is ultimately successful in completing its reformulation, we must then 

complete a series of plant trials, field trials, and required certification testing. Clayton sells its 

2K LP-SPF products to various industries, each with strict regulatory testing requirements. Each 

of these steps significantly adds to the time frame to comply with the SNAP Program. 

The proposed transition date of January 1, 2017 does not provide an adequate amount oftime to 

address the identification of a replacement gaseous blowing agent when combined with the 

lengthy reformulation and testing issues. Accordingly, we ask that the 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 of these changes is to 

phase out the use of materials that have alternatives that pose lower risk overall to human health 

and/or the environment. 

Clayton Corporation supports the ultimate goal of reducing 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 

Corporation 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 in time. 

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. 

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Rigid 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 

impacted by the proposed SNAP status change. Descriptions and attributes ofHP and LP are: 

I. High-Pressure Spray Foam 

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-pressure 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 roof coatings, the HP materials are used in a short period of time. 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 the job 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 

stability concerns of HF0-1234ze, there is only one supplier of this 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 of less 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 stable, which 

HF0-1234ze is not. 

Low Pressure 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: 

3 
I. 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 of2K LP-SPF, especially amine catalysts. 

Development work using HF0-1234ze in Low Pressure Systems has shown an almost complete 

loss of catalyst 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-134a to 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 of time 

to identify, research, and test alternative catalysts and surfactants. One of the most pressing 

needs is the identification and study of non-amine catalyst systems that can be proven compatible 

with the HF0-1234ze, if any 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 of these 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 of the 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 of third 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 of testing. 

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 of the 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 

4 
blowing agents (e.g. HF0-1234ze or -1233zd). The result is total loss of amine, 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 of the 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 of decomposition. 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 of the tank rupturing and exposing an applicator to 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 of any formulation changes. 

We have 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 of Change protocol when changes are made 

to our manufacturing process (including new chemicals). One of the 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 

estimate to 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. If the tests are unsuccessful or if the new product 

formula needs to be modified, this process is required to begin again and potential retesting must 

also be completed. 

5 
Along 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. It can take up to twelve months to successfully field trial and approve a new product. 

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 if all 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 can be 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, and recertified based on the specific needs of that product. 

European Regulations 

The European Union has examined HFC-134a for the purposes of prohibiting its use in European 

markets. In 2006, one component foams ("OCF") were required to discontinue the use of HFC -

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 of the 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 of the 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. 

6 
Conclusion 

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-134a be extended to January 1, 

2021. 

Sincerely, 

Clayton Corporation 

866 Horan Drive 

Fenton, MO 63026 

7 
PATENT AND OTHER REFERENCES 

1. 72 FR 14432- Protection of Stratospheric Ozone: Listing of Ozone 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, Jean Louise Vincent, et. al, "Delay Action Catalyst for Improving 

The Stability of Polyurethane Systems Having Halogen Containing Blowing Agents," 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, David J. Williams, Clifford P. Gittere, "Catalysts for 

Polyurethane Foam Polyol Premixes Containing Halogenated Olefin Blowing Agents," 

US20120248371 , Oct, 4, 2012 

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