Protection of Stratospheric Ozone: Listing of Substances under the Significant New Alternatives Policy Program in Refrigeration, Air Conditioning, and Fire Suppression

Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 Docket ID: EPA-HQ-OAR-2021-0836 RE: NRDC advance comments on potential SNAP listing decisions for ODS-VSLSs The Natural Resources Defense Council (NRDC) appreciates the opportunity to provide advance comment on potential approaches to SNAP listing decisions for very short-lived substances (VSLS) that have ozone depletion potential (ODP) similar to those of class II ODSs, and in particular CF3I and blends thereof. NRDC opposes EPA action that would approve the use of substances with ozone depleting potential, especially ones with ODP comparable to class II substances already being phased out. The Montreal Protocol and subsequent domestic action under the Clean Air Act to phase out the use of ODSs has always been based on robust scientific evidence of ozone layer depletion due to chemical releases of certain chemicals. Concerted efforts around the globe have led to still ongoing recovery of the ozone layer. CF3I has an ODP comparable to that of already prohibited substances. Approving the use of CF3I (either on its own or as a blend component) would be a step backward in years of action to move away from ODSs. The role of the SNAP program is to list substitutes as acceptable based on a comparative risk analysis that examines the risks associated with a new chemical and its predecessor, and that considers other options and alternatives. CF3I is a component of R-446A, a refrigerant blend with potential application in refrigeration and air conditioning. EPA has already approved other refrigerants for all those applications, none of which have higher risk than that posed by CF3I to ozone recovery. EPA recognizes in the SNAP rule 25 proposal that the Agency has in the past approved CF3I for certain specialized fire-suppression applications (60 FR 31092, June 1995) but that the application was very limited and therefore did not lead to considerable emissions. However, R-466A is being considered for a much broader array of applications which will likely lead to non-negligible emissions of CF3I. In addition, CF3I poses challenges to smoke abatement systems and equipment. For example, a recent comparative study on refrigerant conducted by AHRI had originally selected R-466A as one of the four refrigerants to be tested but subsequently suspended the use of R-466A from the study because the testing facility's smoke abatement system was not equipped to scrub iodine from the exhaust gases, resulting in elemental iodine emissions. R-466A is being considered by some equipment manufacturers because of its classification as an A1 refrigerant, the lowest flammability classification under ASHRAE. Equipment manufacturers are well-positioned to use moderately flammable A2L refrigerants without compromising safety and are doing so in many applications like air-conditioning and refrigeration. Thank you for your consideration of our comments. Sincerely, David Doniger Senior Strategic Director Climate & Clean Energy Program Natural Resources Defense Council Christina Theodoridi Policy Advocate Climate & Clean Energy Program Natural Resources Defense Council