135
Little
Nine
Drive
E­
mail:
mhcballyrefboxes.
com
Morehead
City,
NC
28557
Tel:
800­
24BALLY
Website:
www.
ballyrefboxes.
com
Fax:
252­
240­
0384
April
12,
2005
Ms.
Suzanne
Kocchi
Environmental
Protection
Agency
1310
L
Street,
N.
W.,
8th
floor
Room
802J
Washington,
D.
C.
20005
Dear
Ms.
Kocchi:

It
is
my
understanding
that
you
are
interested
in
feedback
from
industrial
Companies'
experiences
with
foam
blowing
agents
using
alternatives
to
HCFC­
141b,
HCFC­
142b,
and
HCFC­
22.

As
a
producer
of
urethane
insulated
panels
(
used
primarily
in
the
commercial
refrigeration
industry),
Bally
must
meet
demanding
standards
of
thermal
efficiency
in
its
products.
In
the
past,
we
used
foam
blowing
agent
formulations
that
were
based
on
HCFC­
141b.
In
2003,
we
converted
half
our
operations
to
foam
blowing
formulations
using
HFC­
245fa.
In
June
of
2004,
we
converted
the
remaining
segments
of
our
business
to
HFC­
245fa.

These
conversions
were
done
to
comply
with
the
current
law
and
were
done
without
significant
complications.
We
found
that
HFC­
245fa
is
readily
available.
We
did
not
have
any
significant
problems
with
our
conversion.
Indeed,
HFC­
245fa
was
virtually
a
"
drop­
in"
replacement
for
HCFC­
141b
in
our
operations.

The
performance
of
HFC­
245fa
has
also
met/
exceeded
our
expectations
in
terms
of
ease
of
use,
and
quality
of
the
product.
Foam
blown
with
HFC­
245fa
actually
exceeds
the
thermal
insulating
efficiency
required
in
our
products.

We
understand
that
EPA
is
currently
considering
a
regulation
that
would
eliminate
the
use
of
HCFC­
22
and
HCFC­
142b
in
foam
blowing
formulations
used
in
commercial
refrigeration
equipment
at
the
end
of
2009.
Our
experience
suggests
that
alternatives
to
those
HCFC's
such
as
HFA­
245fa
are
technically
feasible
and
widely
available
for
use
in
commercial
insulated
panels.
Finally,
it
is
my
understanding
that
many
urethane
panel
manufacturers
have
delayed
conversions
to
alternative
blowing
agents
claiming
undue
financial
harm
or
lack
of
availability
of
alternatives.
These
claims
lack
substance
and
are
now
putting
my
Company
at
a
significant
competitive
disadvantage.
I
believe
this
was
not
EPA's
desired
result
for
companies
complying
with
current
legislation
and
those
who
have
simply
done
"
the
right
thing".
I
would
enjoy
a
continued
discussion
of
this
issue
at
your
convenience
at
any
time.
My
number
is
(
800)­
242­
2559.
Thank
you
in
advance
for
your
attention
to
this
matter.

Sincerely
yours,

Michael
Coyle
President
Cc:
Mr.
Mark
Lewis
Honeywell
International
Inc.
