Hone ell 


Specialty Materials 

Honeywell 

20 Peabody Street 

Buffalo, NY 14210 

716-827-6200 

February 25, 2011 

Carole Cook 

Climate Change Division 

Office of Atmospheric Programs (MC-62071), 

Environmental Protection Agency 

1200 Pennsylvania Ave., NW. 

Washington, DC 20460 

Honeywell International's Buffalo Research Laboratory (BRL) is requesting the use of 


alternate GWPs whose GWPs are not listed in Table A- 1 in subpart A of The Code of 


Federal Regulation Part 98 - The Mandatory Greenhouse Gas Reporting Rule published 


by the Environmental Protection Agency On October 30, 2009. 


Honeywell is citing Subpart L 98.123(a) of the regulation Published to the Code of 


Federal Regulations on December 1, 2010 as the grounds behind submitting this request. 


This request is being made using the guidelines issued under Subpart L 98.123 


( c )(1 )(B)( 4 )(iii)(B )(vi). 


The Buffalo Research Laboratory currently produces two commercial products that meet 


the definition of a fluorinated greenhouse gas and subsequently will require reporting 


under both subpart oo and subpart 1 of the rule. Neither product is listed in Table A-1 of 


subpart A. These two products are 1234ze CAS# 29118-24-9 and 1234yf CAS#754-12-l. 


Both products have a wide variety of uses such as blowing agents, sterilants, aerosols and 


foams; but primarily they are used in refrigeration. They both were developed as next 


generation products designed to replace the non-ozone depleting products with high 


GWPs that we use today. 


1234ze has a GWP of 6 and 1234yfhas a GWP of 4. With these revised GWPs BRL's 


anticipated annual C02e emissions for 1234yf and 1234ze will fall below the 10,000 


metric ton threshold excluding them from subpart 1 reporting requirements. 


Contained within you will find attachments 1 through 2 which contain information 


required to fulfill requirement 98.123 (c)(l)(B)(4)(iii)(B)(vi)(A)(4) and they will contain 


the engineering calculations, assessments and underlying data that demonstrate that the 


process vent for both 1234ze and 1234yf are calculated to emit less than 10,000 metric 


tons C02e when the proposed provisional GWPs, not the default GWP of 2,000 are used. 


BRL GHG-MRR ALT. GWP Request to EPA 2/25111 

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Also you will find attachments 3 through 5 which are published scientific papers (cited 

below) which will fulfill the requirements requested by the EPA under 98.123 

(c)(1)(B)(4)(iii)(B)(vi)(A) parts (1) through (3). In addition you will find attachments 6 

and 7, the SNAP approval for 1234ze and the 1234yf SNAP proposal respectively. 

Finally, is attachment 8, a paper published by the EPA at epa.gov (EPA-430-F-10-044) in 

October of 2010 entitled "Transitioning to Low-GWP Alternatives in Unitary Air 

Conditioning" 

Attachment 3 


Vassileios C. Papadimitriou, Ranajit K. Talukdar, R. W. Portmann, A R. Ravishankar and James B. 


Burkholder, 2008, CF3CF=CH2 and (Z)-CF3CFQCHF: Temperature Dependent OH Rate Coefficients and 


Global Warming Potentials, Physical Chemistry Chemical Physics, v. 10, p. 808-820. 


Attachment 4 


OJ. Nielsen, M.S. Javadi, M.P. Sulbaek Andersen, M.D. Hurley, T.J. Wallington, R. Singh, 2007, 


Atmospheric Chemistry oftrans-CF3CH@CHF: Kinetics of the Gas-Phase Reactions with Cl Atoms, 


OH radicals, and 03, Chemical Physics Letters, v. 443, p. 199- 204. 


Attachment 5 

0 .1. Nielsen, M.S. Javadi, M.P. Sulbaek Andersen, M.D. Hurley, T.J. Wallington, R. Singh, 2007, 


Atmospheric Chemistry of CF3CF@CH2: Kinetics and Mechanisms of Gas-Phase Reactions with Cl 


Atoms, OH Radicals, and 03, Chemical Physical Letters, v. 439, p. 18-22. 


Please contact my HS&E Compliance Coordinator directly with any questions or 


comments regarding this submittal at (716) 827-6325 or 


Brandon. Emerson@ Honeywell. com. 


Sincerely, 

<?Jay Kelly uy~

Plant Manager 


Honeywell Intl. Buffalo Research Laboratory 


20 Peabody St. 


Buffalo, NY 14210 


(716) 827-6382 

BRL GHG-MRR ALT. GWP Request to EPA 2/25/11 

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