## Hone ell Specialty Materials Honeywell 20 Peabody Street Buffalo, NY 14210 7 16-827-6200 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 1reporting 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 1 of2Also 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,

# <?**uy~** Jay Kelly 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 2 of2