ExxonMobil
Chemical
Company
Intermediates
Americas
13501
Katy
Freeway,
WL3
­
1474
Houston,
TX
77063
281
870
6146
Telephone
281
588
2507
Facsimile
January
22,
2004
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
NW
Mail
Code
6205J
Washington,
DC
20460
Suzanne
Kocchi
U.
S.
Environmental
Protection
Agency
1310
L
Street,
NW
Washington,
DC
20005
ExxonMobil
Chemical
Company
wishes
to
comment
on
the
U.
S.
Environmental
Protection
Agency
proposal
to
implement
a
use
ban
for
HCFC
141b
in
insulation
foam
in
2005.
Our
comments
are
directed
to
the
EPA
Significant
New
Alternative
Policy
(
SNAP)
program
rule
published
on
July
22,
2002
(
67
FR
47703).
We
believe
the
EPA
should
move
forward
with
a
final
phase
out
of
HCFC
141b
given
the
availability
of
viable
nonozone
depleting
alternatives
in
virtually
all
industry
sectors.

ExxonMobil
Chemical
Company
has
developed
a
range
of
products
and
invested
in
facilities
that
provide
the
manufacturing
sector
(
e.
g.
appliance,
construction,
commercial
refrigeration,
water
heater,
rigid
spray)
with
technically
viable
and
commercially
attractive
alternatives
that
are
cost
competitive.
Alternative
non­
ozone
depleting
blowing
agents
being
developed
for
all
end
use
applications
and
manufacturers
have
or
soon
will
convert
to
alternative
technologies
such
as
Exxsol
 
Blowing
Agents.

Rigid
Spray
This
sector
has
been
relatively
slow
in
the
transition
to
alternatives.
However
great
strides
have
been
made
in
the
past
year
to
utilize
non­
ozone­
depleting
options.

 
Rigid
spray
foam
systems
utilizing
Exxsol
 
Blowing
Agents
and
other
non
ODS
options
have
been
commercially
available
in
the
market
place
since
2003.
 
These
non
ODS
formulated
rigid
spray
foam
systems
have
achieved
the
necessary
ASTM
E84
and
UL
790
approval
listings.
 
Spray
foam
equipment
designed
for
non­
ozone­
depleting
alternatives
such
as
Exxsol
 
Blowing
Agents
have
been
commercially
available
since
4Q'
03.
Endysis
and
Gusmer
both
offer
appropriate
machines
for
this
end
use
application.
 
Several
leading
urethane
system
suppliers
have
completed
blending
facilities
which
offer
customers
non­
ozone­
depleting
alternative
systems.
Additional
facilities
are
under
development.
 
Extensive
safety
data
and
training
materials
are
available
supporting
the
transition
to
Exxsol
 
Blowing
Agents
for
both
exterior
and
more
challenging
interior
spray
applications
such
as
stud
wall
cavities.

Water
Heater
The
industry
selected
hydrocarbon
in
2002
­
2003
as
their
preferred
non­
ozone­
depleting
blowing
agent
alternative.

 
Several
manufacturing
facilities
will
have
converted
to
Exxsol
 
Blowing
Agents
by
early
2Q'
04
with
the
majority
of
the
others
transitioned
during
late
3Q'
04.

Metal
Panel
Several
metal
panel
manufacturers
have
converted
to
hydrocarbons
in
2003.
This
transition
included
both
continuous
and
discontinuous
applications.
They
include
cold
storage,
industrial,
and
architectural
panels
as
well
as
entry
doors.

 
Urethane
foam
systems
using
Exxsol
 
Blowing
Agents
have
achieved
industry
required
Class
I
and
II
fire
ratings
where
appropriate.
 
Additional
insulated
panel
manufacturers
are
transitioning
to
non­
ozone­
depleting
Exxsol
 
Blowing
Agents
in
2004.

We
believe
a
real
need
exists
for
the
EPA
to
address
the
importation
issues
of
HCFC
141b
blended
polyol
systems
from
countries
like
Mexico,
which
continues
to
have
a
negative
impact
on
U.
S.
industry
development
and
investment
in
alternatives.
Importation
of
these
"
HCFC
141b
blends"
encourages
many
companies
both
large
and
small
to
further
defer
their
transition
to
acceptable
alternatives.
Failure
to
address
this
ongoing
issue
will
continue
to
undermine
those
U.
S.
companies
that
have
developed
alternatives,
made
the
investments,
and
are
in
a
position
to
offer
a
significant
reduction
in
ODS
emissions.

Please
contact
me
at
(
281)
870­
6146
with
any
questions
you
may
have.

Sincerely,

Robert
G.
Begbie
Jr
ExxonMobil
Chemical
Company
Fluids
Market
Development
c:
D.
C.
Kaczor
N.
J.
Sarginson
