January
29,
2004
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
NW
Mail
Code
6205J
Washington,
DC
20460
Ms.
Suzanne
Kocchi
U.
S.
Environmental
Protection
Agency
1310
L.
Street,
NW
Washington,
DC
20005
Dear
Ms.
Kocchi:

North
Carolina
Foam
Industries
(
NCFI)
would
like
to
provide
an
update
on
our
activities
to
transition
to
non­
ozone­
depleting
HCFC
141b
blowing
agent
alternatives.
Further
we
wish
to
comment
on
the
U.
S.
Environmental
Protection
Agency
proposal
(
67
FR
47703­
47721)
to
formally
ban
HCFC
141b
in
insulating
foam
beginning
in
2005.
We
feel
the
EPA
should
move
forward
to
ban
the
use
of
HCFC
141b
now
that
non­
ozone­
depleting
alternatives
are
clearly
commercially
viable
and
available
in
all
industry
sectors.

NCFI
has
made
significant
investments
over
the
past
two
years
in
new
production
facilities
to
manufacture
urethane
systems
using
non
ODP
blowing
agents.
In
addition
we
have
developed
and
qualified
a
full
range
of
new
urethane
products
incorporating
hydrocarbon
or
HFC
245
fa
blowing
agents
to
replace
our
older
HCFC
141b
systems.
We
are
actively
phasing
out
our
HCFC
141b
formulations
and
encouraging
all
of
our
customers
to
transition
to
these
new
environmentally
attractive
alternatives.

 
We
have
completed
investments
in
new
blending
facilities
for
both
Exxsol
®
(
hydrocarbon)
and
Enovate
 
3000
(
HFC
245
fa)
blowing
agents.

B
NCFI
is
commercially
offering
attractive
non
ODP
formulations
into
a
range
of
end
uses
including
rigid
spray
for
both
roof
and
interior
wall
applications.

B
In
2003
we
purchased
hydrocarbon
capable
spray
foam
equipment
from
Gusmer
and
Endysis
and
have
made
it
widely
available
to
spray
contractors
in
a
series
of
training/
demonstration
programs.
Ms.
Suzanne
Kocchi
U.
S.
Environmental
Protection
Agency
January
29,
2004
Page
2
NCFI
has
made
investments
in
alternative
blowing
agent
technologies
and
facilities
in
order
to
comply
with
the
mandated
phase
out
of
HCFC
141b.
The
continued
availability
of
HCFC
141b
however
has
undermined
our
efforts
to
convert
many
customers
to
the
non
ODP
alternatives.
To
accelerate
the
move
to
non
ODP
formulations
in
the
urethane
industry,
the
EPA
should
establish
an
HCFC
141b
end
use
ban
as
proposed
in
the
JULY
22,
2002
67
FR47703
program
rule.
We
at
NCFI
have
and
are
prepared
to
offer
viable
alternatives
that
truly
reduce
ODS
emmisions.

Very
truly
yours,

NORTH
CAROLINA
FOAM
INDUSTRIES
Swanson
Snow
Division
President
SS:
cm
