&­
3600­
B+
IV­
c­
0s
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
$,@
J
%&..

WASHINGTON,
D.
C.
20460
mi2~
%
c
d
+?
4c
PRO#

FEB
2
I
2000
Matthew
0.
Tanzer
GE
Lighting
General
Electric
Company
1975
Noble
Road
­
Nela
Park
Cleveland,
OH
44
1
12
Dear
Mr.
Tanzer:
OFFICE
OF
AIR
AND
RADIATION
This
is
in
response
to
your
comment
dated
March
29,
1999,
regarding
the
Environmental
Protection
Agency's
(
EPA's)
proposed
rule
entitled
"
Protection
of
Stratospheric
Ozone:
Incorporation
of
Montreal
Adjustment
for
a
1999
Interim
Reduction
in
Class
I,
Group
VI
Controlled
Substances."
64
FR
9290
(
February
25,
1999).

In
your
letter
you
state,
"
These
comments
address
GE's
current
and
planned
use
of
a
very
small
amount
of
methyl
bromide
in
the
manufacture
of
halogen
lamps;
a
use
that
generates
no
emissions
of
methyl
bromide
because
during
the
manufacturing
process
the
methyl
bromide
is
completely
transformed
and
no
longer
exists."
As
such,
G.
E.'
s
use
of
methyl
bromide
in
the
manufacture
of
halogen
lamps
is
exempt
from
the
reduction
steps
and
phaseout
controls
on
the
production
and
consumption
of
methyl
bromide
as
published
under
40
CFR
Part
82,
Subpart
A.

IJndcr
40
CFR
Part
82.3,
thc
definition
of
tlic
tcnn
"
transform"
is
listcd
as
"
to
LISC
and
cntircly
consunie
(
except
for
trace
quantities)
a
controllcd
substance
in
the
innufacture
of
other
chemicals
for
commercial
purposes."
As
you
explain
in
your
letter,
the
methyl
bromide
introduced
into
each
lamp
dissociates
into
hydrobromide,
hydrogen
and
carbon.
EPA
believes
this
demonstrates
that
the
methyl
bromide
is
transformed
during
G.
E.'
s
manufacturing
process
and
the
end
product
is
sold
for
commercial
purposes.
Under
40
CFR
Part
82.4(
c),
there
is
an
exemption
for
the
production
and
import
of
methyl
bromide
(
Class
I,
Group
VI
controlled
substances)
if
the
controlled
substance
is
transformed.

If
you
have
any
hrther
questions
about
this
matter,
please
do
not
hesitate
to
contact
me
by
phone
(
202)­
564­
9
185,
fax
(
202)­
565­
2093,
or
e­
mail:
land.
t.
omi2epa.
aov.

Tom
Land
Stratospheric
Protection
Division
Intenlet
Address
(
URL)
http://
www.
epa.
gov
RecycledlRecyciable
Printed
with
Vegetable
Oil
Based
Inks
mi
Recycled
Paper
(
Mlniinum
20%
Postconsumer)
