Ms. Drusilla Hufford

Environmental Protection Agency

1200 Pennsylvania Avenue, NW

MC  6205J

Washington, DC  20460

June 22, 2011

Subject:  SNAP EPA-HQ-OAR 2008-0664 HFO-1234yf LGWP MAC Refrigerant
Industrial Transfer

Dear Drusilla

It was nice to meet your team last week, thanks to all for taking time
to discuss commercial introduction of HFO-1234yf refrigerant for mobile
air conditioning.  The pace towards full production is rapidly
accelerating as we look to support our MAC customers around the globe. 
Expedient movement of the refrigerant to the various global regions is
critical the operation of our business and the successful implementation
of this new lower global warming refrigerant.

We need to move HFO-1234yf today for industrial transfers but vitally
need EPA non-objection to allow use of other than the SAE J2844 service
cylinder fitting. We would appreciate your agreement with our
interpretation that such shipments would not conflict with the intent of
the SNAP ruling. Honeywell needs to move material immediately both
internal inventory transfers and to support customer production
activities.  These shipments are not for “professional service or
service for consideration” usage.  

During our discussion we briefly addressed HFO-1234yf SNAP Final Rule
EPA-HQ-OAR-2008-0664 and the SAE J2844 quick connect fitting standard
referencing professional service cylinder fittings.  From our
discussion, it is our understanding that the SNAP reference relates to
“professional service or service for consideration” when identifying
a specific fitting.  Therefore, any industrial transfer either internal
to Honeywell or to a non-professional service usage would be excluded
from the fitting requirement. It is this last point that we need
immediate clarification to allow movement of refrigerant.

Please provide a response indicating your agreement with our desire to
utilize standard industry fillings for  material transfers for
industrial usage. 

Thank you for your assistance, I look forward to your feedback.  As we
discussed at the meeting, please communicate directly with me at   
HYPERLINK "mailto:Steven.Bernhardt@Honeywell.com" 
Steven.Bernhardt@Honeywell.com  or (973) 455-6294.

Thanks,

Steven H. Bernhardt, PhD

Global Director Regulatory Affairs

Honeywell International

101 Columbia Road, NIC-5

Morristown, NJ  07962

cc. Cindy Newberg

      Margaret Sheppard 

      Yaidi Cancel

Honeywell 

101 Columbia Road

Morristown, NJ  07962

	

 

