Hodayah
Finman/
DC/
USEPA/
US
02/
17/
2006
11:
59
AM
To
cc
bcc
Subject
Fw:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
­­­­­
Forwarded
by
Hodayah
Finman/
DC/
USEPA/
US
on
02/
17/
2006
11:
59
AM
­­­­­
Bella
Maranion/
DC/
USEPA/
US
02/
06/
2006
04:
25
PM
To
Hodayah
Finman/
DC/
USEPA/
US@
EPA
cc
Julius
Banks/
DC/
USEPA/
US@
EPA
Subject
Fw:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
Hodayah,
It
seems
the
only
issue
DoD
is
raising
is
to
change
the
definition
to
use
the
term
"
aircraft"
rather
than
"
airline":

"
Aircraft
halon
bottle
means
a
vessel
used
as
a
component
of
an
aircraft
airlinefire
suppression
system
containing
halon­
1301."

I
would
support
the
change
on
the
basis
that
it
makes
the
definition
more
accurate
by
not
implicitly
limiting
it
to
only
bottles
coming
into
the
US
from
commercial
airlines
because
of
use
of
the
term
"
airlines",
but
to
make
the
rule
applicable
to
any
aircraft
halon
bottles
brought
in.
I
don't
believe
this
should
raise
any
issues
with
the
US
servicing
companies
or
if
you
need
to
run
this
change
by
them.

If
you
want
to
discuss,
please
let
me
know.

Thanks,
Bella
Bella
A.
Maranion,
Program
Analyst
Alternatives
and
Emissions
Reduction
Branch
Stratospheric
Protection
Division,
Office
of
Atmospheric
Programs
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
(
mailstop
6205J)
Washington,
D.
C.
20460­
0001
phone:
(
202)
343­
9749
fax:
(
202)
343­
2363
e­
mail:
maranion.
bella@
epa.
gov
­­­­­
Forwarded
by
Bella
Maranion/
DC/
USEPA/
US
on
02/
06/
2006
04:
15
PM
­­­­­
Pete
Mullenhard
<
PETER.
M.
MULLENHARD@
saic.
com>
Sent
by:
peter.
m.
mullenhard@
saic.
com
02/
06/
2006
04:
09
PM
Please
respond
to
peter.
m.
mullenhard@
saic.
com
To
Bella
Maranion/
DC/
USEPA/
US@
EPA
cc
Hodayah
Finman/
DC/
USEPA/
US@
EPA,
william.
leach@
navy.
mil,
Jim
Rudroff
<
jim.
rudroff@
navy.
mil>,
gregory.
toms@
navy.
mil,
Sherman
Forbes
<
sherman.
forbes@
pentagon.
af.
mil>,
Kenneth.
Dormer@
pentagon.
af.
mil
Subject
RE:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
Bella,

I'm
pretty
sure
that
at
least
some
bottles
on
military
aircraft
sold
to
other
foreign
militaries
are
sent
back
to
the
US
for
servicing.
Whether
this
is
considered
an
"
import"
or
not,
I
don't
know.
Also,
what
about
other
categories
of
transport
aircraft
such
as
air
cargo.
Wouldn't
foreign
air
cargo
companies
send
their
bottles
back
to
the
US
for
servicing
just
like
the
airlines?
For
example,
Boeing
737/
747/
767/
777
aircraft
are
sold
to
airlines,
air
cargo
companies,
foreign
militaries,
and
other
corporations
(
Boeing
Business
Jets)
throughout
the
world.
Seems
like
it
is
likely
that
others
besides
the
airlines
may
ship
bottles
back
to
US
service
companies.
Just
thought
it
might
be
something
for
you
to
ask
the
service
companies.
Seems
like
it
would
be
an
easy
modification
to
the
definition
as
follows:
"
Aircraft
halon
bottle
means
a
vessel
used
as
a
component
of
an
aircraft
fire
suppression
system
containing
halon­
1301."

Pete
Mullenhard
Senior
Engineer
GEO­
CENTERS
Operation
Homeland
Protection
and
Preparedness
Business
Unit
Science
Applications
International
Corporation
(
SAIC)
2001
Jefferson
Davis
Hwy,
Suite
307
Arlington,
VA
22202
Phone:
(
703)
562­
4135
Fax:
(
703)
416­
1178
E­
mail:
peter.
m.
mullenhard@
saic.
com
­­­­­
Original
Message­­­­­
From:
Maranion.
Bella@
epamail.
epa.
gov
[
mailto:
Maranion.
Bella@
epamail.
epa.
gov]

Sent:
Monday,
February
06,
2006
2:
14
PM
To:
peter.
m.
mullenhard@
saic.
com
Cc:
finman.
hodayah@
epamail.
epa.
gov;
william.
leach@
navy.
mil
Subject:
RE:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
Pete
and
Bill,
I
think
an
important
distinction
is
that
the
rule
is
intended
to
address
"
imported"
aircraft
halon
bottles
for
servicing.
The
practice
being
addressed
is
that
commercial
airlines
are
returning
these
bottles
to
US
servicing
companies
for
testing,
and
the
intent
of
the
rule
is
to
ease
the
burden/
streamline
the
process
(
import
petition
process)
for
these
companies
and
airlines.
Does
the
other
aircraft,
particularly
military,
that
you
mention
observe
this
similar
practice
of
bringing
in
bottles
for
servicing
in
the
US
that
would
have
to
go
through
an
ODS
import
petition
process?
I'm
not
sure
that
this
particular
rule
applies.

Bella
Pete
Mullenhard
<
PETER.
M.
MULLENH
ARD@
saic.
com>
To
Sent
by:
william.
leach@
navy.
mil
peter.
m.
mullenha
cc
rd@
saic.
com
Hodayah
Finman/
DC/
USEPA/
US@
EPA,
Kenneth.
Dormer@
pentagon.
af.
mil,
Sherman
Forbes
02/
06/
2006
01:
28
<
sherman.
forbes@
pentagon.
af.
mil>,
PM
Bella
Maranion/
DC/
USEPA/
US@
EPA,
Jim
Rudroff
<
jim.
rudroff@
navy.
mil>,
Please
respond
gregory.
toms@
navy.
mil
to
Subject
peter.
m.
mullenha
RE:
Proposed
EPA
Rules
at
OMB
­
rd@
saic.
com
Request
for
Comments
Bill,

The
term
"
spherical"
is
not
actually
used
in
the
definition
in
the
rule
which
is:

Aircraft
halon
bottle
means
a
vessel
used
as
a
component
of
an
airline
fire
suppression
system
containing
halon­
1301.

However,
now
that
you
mention
it,
the
term
"
airline
fire
suppression
system"
does
not
seem
to
encompass
all
of
the
types
of
aircraft
that
use
fire
suppression
systems
and
use
these
bottles
(
military,
cargo
carriers,
private
aircraft,
corporate
aircraft,
etc.)
since
I
believe
the
term
"
airline"
is
generally
defined
as
a
commercial
enterprise
that
provides
scheduled
flights
for
passengers.

I'll
pass
this
along
to
EPA
so
they
can
take
a
look
at
it.

V/
r,
Pete
Mullenhard
Senior
Engineer
GEO­
CENTERS
Operation
Homeland
Protection
and
Preparedness
Business
Unit
Science
Applications
International
Corporation
(
SAIC)
2001
Jefferson
Davis
Hwy,
Suite
307
Arlington,
VA
22202
Phone:
(
703)
562­
4135
Fax:
(
703)
416­
1178
E­
mail:
peter.
m.
mullenhard@
saic.
com
From:
william.
leach@
navy.
mil
[
mailto:
william.
leach@
navy.
mil]
Sent:
Monday,
February
06,
2006
10:
28
AM
To:
peter.
m.
mullenhard@
saic.
com
Subject:
RE:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
Pete,
How
critical
is
the
word
"
spherical"?
At
least
one
of
the
Navy's
aircraft
engine
halon
bottles
(
F/
A­
18)
is
more
Tylenol
shaped
­
definitely
not
spherical.
Any
concern
here?

Thanks
much.

Bill
­­­­­
Original
Message­­­­­
From:
peter.
m.
mullenhard@
saic.
com
[
mailto:
peter.
m.
mullenhard@
saic.
com]
Sent:
Monday,
January
30,
2006
11:
09
AM
To:
'
Dormer,
Kenneth
Ctr
SAF/
AQRE';
'
Forbes,
Sherman
Civ
SAF/
AQRE';
'
Koehler­
Contractor,
David
CCI';
Toms,
Gregory
S
CIV
SEA
05;
'
Elliott,
Martin
G
Mr
ACSIM';
odsreserve@
dscr.
dla.
mil;
''
David
Coffie'
';
OSD­
ATL
Asiello;
GravesDI@
hqmc.
usmc.
mil;
'
Verdonik­
Contractor,
Daniel
OCR';
Leach,
William
CIV
NAVAIR
AIR
4.3.5.1;
Hammerer,
Mary
Q
CIV
NAVAIR;
'
Manzione,
John
Mr
RDECOM
CERDEC
C2D
APES'
Cc:
Rudroff,
Jim
CIV;
'
George
Barchuk
';
Mestey,
Felix
CIV
(
NAVFACHQ);
Michael
Cernoch
Subject:
Proposed
EPA
Rules
at
OMB
­
Request
for
Comments
Importance:
High
All,

I
received
no
comments
on
the
proposed
SNAP
rule
to
list
HFC­
152a
and
CO2
as
acceptable
alternatives
for
new
design
Motor
Vehicle
Air
Conditioners
(
MVAC)
subject
to
certain
use
restrictions
and
the
direct
final
rule
that
would
exempt
entities
that
import
aircraft
fire
extinguishing
spherical
pressure
vessels
containing
halon­
1301
("
aircraft
halon
bottles")
for
hydrostatic
testing
from
the
import
petitioning
requirements
for
used
controlled
substances.
As
such,
the
ODS
Services
Steering
Committee
does
not
plan
to
submit
any
comments
to
OMB
on
these
two
rules.

V/
r,
Pete
Mullenhard
Senior
Engineer
GEO­
CENTERS
Operation
Homeland
Protection
and
Preparedness
Business
Unit
Science
Applications
International
Corporation
(
SAIC)
2001
Jefferson
Davis
Hwy,
Suite
307
Arlington,
VA
22202
Phone:
(
703)
562­
4135
Fax:
(
703)
416­
1178
E­
mail:
peter.
m.
mullenhard@
saic.
com
