Well, the adventures of hydrochlorofluorocarbon (HCFC)-22 have certainly gotten interesting.
For seemingly forever, we’ve known the final phaseout for the production and importation of R-22 was going to be Dec. 31, 2019. To coincide with that, the U.S. Environmental Protection Agency (EPA) proposed a timeline for the phasedown with a yearly step down in production/importation until zeroing out in 2020.
But, then the EPA threw a bit of a curve into the equation, offering what it called a more aggressive reduction, set to end in 2018.
Then, some industry folks entered into the fray this year, encouraging the EPA to end allowances for production/importation as of Dec. 31, 2014, about six months from now.
And there is yet another sub sector that had been talking about filing a suit in federal court to get a judge to issue an order to force the EPA to rescind its permission to allow production of 51 million pounds of R-22 this year. (With regards to that legal effort, the longer that drags on, the more moot it becomes because manufacturers have been making virgin R-22, and imports have been allowed all along. The further we go into the year, the closer the number comes to the 51 million pounds allowed.)
Waiting for the Word
No one is sure when the EPA will issue its final phasedown time line. Best guesses are late this summer or early fall. As noted above, EPA could allow 30.2 million pounds as of Jan. 1, 2015, with the phaseout coming in 2020. Or, it could allow 27.3 million pounds as of this Jan. 1, aiming for a 2018 ending. Some of those other talked-about aspects — such as an end in 2014 or the lawsuit effort to speed up the process — could also end up in play, but that’s highly unlikely. The 2020 finale seems most probable.
What does all this mean to contractors? First, uncertainty could mean prices spike. And, no matter what scenario plays out, we know for certain that while 51 million pounds of new R-22 can enter the market this year, at best, only 30.2 million will come into the market in 2015 — about a 40 percent reduction.
So, here are some things to consider for those who work on R-22 equipment: The industry is apparently sitting on close to a 100-million-pound inventory of yet-to-be-used R-22. That inventory can be drawn down. Even if the EPA says zero new R-22 in 2015, that inventory could be used to replace the current production allowance of 51 million pounds for two more years.
R-22 currently being used in systems can be pulled and reintroduced over and over again through recovery and recycling. Keeping a system tight and the refrigerant clean extends that option.
R-22 currently in use can be brought to reclamation facilities and brought back to Air-Conditioning, Heating, and Refrigeration Institute (AHRI)-700 purity standards, which means as good as new (virgin) refrigerant.
There are a number of hydrofluorocarbon (HFC) refrigerants that can be retrofitted in R-22 units with proven procedures and a favorable track record already on the books. And, the current inventory of R-22 equipment is finite. Even with the furor a few years ago about dry-shipped R-22 equipment, not a lot has been flooding the market, and, frankly, the U.S. economy hasn’t allowed a deluge of new equipment with R-22. Basically, every time an R-22 piece of equipment is decommissioned, that’s one less unit in need of R-22.
So the takeaways stay the same, as they have been for a long time:
• Keep systems tuned up and leak tight;
• Continue to recover and recycle R-22 and, when needed, send the gas to a reputable reclaimer so it can be reused again and again;
• Use HFC retrofit refrigerants if there is not an R-22 option; and
• Recommend customers to replace aging, inefficient R-22 with new equipment that doesn’t use an HCFC refrigerant.
Publication date: 5/26/2014