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Telephone: (571) 208-0428
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February 1, 2010
Environmental Protection Agency (EPA/DC)
Air and Radiation Docket
Mail Code 2822T
1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE:
Docket ID No. EPA-HQ-OAR-2008-0664
Title:
Protection of Stratospheric Ozone: New Substitute in the Motor Vehicle Air Conditioning
Sector under the Significant New Alternatives Policy (SNAP) Program, 74 Fed. Reg.
53,445 (Oct. 19, 2009)
Dear Sir or Madam:
The Automotive Recyclers Association (ARA) is pleased to provide comments on the EPA
proposed rule regarding a new substitute refrigerant under the Significant New Alternatives
Policy (SNAP) Program issued on October 19, 2009 (74 FR 53445). ARA supports the intent of
the SNAP Program, to evaluate and regulate substitutes for the ozone-depleting chemicals that
are being phased out under the stratospheric ozone protection provisions of the Clean Air Act.
Since 1943, ARA has represented an industry dedicated to the efficient removal and reuse of
"green" automotive parts and the recycling of inoperable motor vehicles. Today, ARA
represents over 4,500 automotive recycling facilities in the United States and fourteen other
countries around the world. ARA members around the globe provide consumers with quality,
low-cost alternatives for vehicle replacement parts, while preserving the environment for a
"greener" tomorrow.
The statutory and regulatory background is described in detail in the Federal Register proposed
rule of October 19, 2009 (74 FR 53445). In that document, EPA proposed to find HFO– 1234yf
acceptable as an alternative refrigerant for motor vehicle air conditioning, subject to use
conditions. While ARA understands EPA's obligations to identify best available alternatives for
use in motor vehicle air conditioners, we have several concerns regarding potentially adverse
consequences from the new refrigerant. EPA has identified proposed use conditions located
throughout the Federal Register notice. Those conditions highlighted by EPA include
engineering design, environmental hazards, cost and public exposure.
Automotive Recyclers Association
Re: Docket ID No. EPA-HQ-OAR-2008-0664
It is these conditions, however, that lead ARA to examine and comment on HFO-1234yf in
terms of the perceived consequences on the professional automotive recycling industry. ARA
would like to raise several concerns with the use of HFO-1234yf as EPA reviews comments
associated with this proposed rule. Those concerns include: the recyclability, safety and
feasibility of HFO-1234yf to the environment, employees and the general public. Below you will
find specific questions that are associated with the corresponding EPA specific condition that
may impact the automotive recycling industry:

Once the EPA approves 1234yf in its SNAP, it would have to approve the refrigerant
also as a new chemical entity as part of its Toxic Substances Control Act (TSCA)
program. Service equipment, technician certification and end-of-life disposal
specifications will be addressed in a follow-on rulemaking(s) under Section 609 of the
Clean Air Act. Consequently, is it known if 1234yf can be recycled? What is the
best means for processing end-of-life vehicles that contain HFO1234yf? How will
end-of-life disposal specification be addressed in the follow-on rulemaking in
considering cost recovery for professional U.S. automotive recyclers? Can it be
easily stored in a containment bottle? How long can it be held before disposal?

In terms of toxicological concerns, the TSCA New Chemicals Program review of HFO–
1234yf determined that potential consumer (passenger) exposure from refrigerant leak
into the passenger compartment of a vehicle is not expected to present an unreasonable
risk. However, consumer exposure from filling, servicing, or maintaining MVAC systems
without professional training and the use of CAA Section 609 certified equipment may
cause serious health effects. significant industrial or commercial worker exposure is
unlikely due to CAA section 609 technician training, the use of CAA section 609 certified
refrigerant handling equipment, and other protective measures. Therefore, the proposed
manufacture, processing, and use of HFO–1234yf are not expected to present an
unreasonable risk to workers. Based on EPA's research, does 1234-yf present any
occupational risks to dismantling employees? Is it then considered a safe
substance?

HFO–1234yf is a “near” drop-in replacement for HFC-134a, meaning OEMs do not have
to do much re-engineering of AC systems themselves, according to Tom Morris, director,
commercial developments, refrigerants, Honeywell, Inc. Conversely, the Agency has not
evaluated the safety issues associated with retrofitting HFO–1234yf MVAC systems with
other MVAC refrigerants previously approved under SNAP. The use conditions
proposed for HFO–1234yf are specific to the properties of this chemical, and would not
be protective of fire hazards... Besides the safety concerns of retrofitting to another
refrigerant, the practice could lead to increased refrigerant emissions because of
materials compatibility or/and leakage due to hose permeation. Will 1234yf require
new or specialized equipment to handle this refrigerant? Will it require an
environmentally protected storage area?

HFO–1234yf has an ozone-depletion potential (ODP) of nearly zero. Thus, in terms of
direct refrigerant emissions, HFO–1234yf would have a significantly smaller impact on
Automotive Recyclers Association
Re: Docket ID No. EPA-HQ-OAR-2008-0664
climate compared to the ozone depleting substance it replaces and other common
alternatives available in the same end use. We note that one concern about HFO–
1234yf atmospheric effects is trifluoroacetic acid (CF3COOH, TFA). TFA is produced
from atmospheric oxidation of HFO–1234yf. TFA is naturally occurring, but at certain
levels is toxic to aquatic life forms. Initial analysis indicates that the projected maximum
TFA concentration in rainwater should not result in a significant risk of aquatic toxicity.
What is the impact of 1234yf on the environment, in terms of air quality and storm
water run-off? What actions will automotive recyclers be required to take in
handling 1234yf to prevent environmental impacts? Will there be restrictions on
venting to the atmosphere?
ARA would like to thank EPA for consideration of the concerns from the professional automotive
recycling industry. We appreciate that you are considering a follow-on rulemaking (under
Section 609 of the Clean Air act) on end-of-life disposal specification and look forward to
working with EPA staff on this matter. If you have any questions, please contact me.
Respectfully submitted,
Michael E. Wilson
Executive Vice President