As the 2010 deadline for the use of R-22 in new equipment comes ever closer, efforts are on the increase to put the topic on a need-to-know basis for contractors and technicians who work with the refrigerant.

As part of that, the U.S. Environmental Protection Agency a few months ago provided training for HVACR and plumbing instructors under the topic, “The 2010 HCFC-22 Phase Down.” It was part of the Air-Conditioning & Refrigeration Institute’s (ARI’s) Train the Trainer Program, and provided some of the most comprehensive information and clarifications yet of refrigerant-related topics. Julius Banks and Cindy Newberg, of the Stratospheric Protection Division, were the presenters.

THE 2010 MILESTONE

Newberg described 2010 as “the next major milestone in the HCFC phaseout.” The phaseout is a component of the Clean Air Act, which itself was created in response to the Montreal Protocol, an international agreement signed by 190 countries including the United States.

“Ozone-depleting substances such as HCFC-22 deplete stratospheric ozone, which shields Earth from radiation,” she said. “Overexposure to UV radiation can cause skin cancer, cataracts, and weakening of the immune system.”

The production of HCFCs including R-22, she noted, has been on a decline since the base year of 1995. There was a 35 percent reduction in 2005 and will be another 30 percent in 2010 (the ban on the use of R-22 in new equipment), for a total 65 percent reduction since the baseline year. The next bell-weather year will be 2015, when the reduction will be 90 percent of the baseline year; 2015 is often seen as the cross-over year, when supplies could fall short of demand unless better recovery and reclamation efforts are implemented.

Newberg noted that the reduction will be 99.5 percent in 2020 and 100 percent in 2030. In fact, some see those last 10 years as only allowing for production of such HCFCs as R-123, which is used in some chiller applications.

The presentation noted exceptions for HCFCs that are recovered, then recycled or reclaimed. They can be used forever.

IMPACT ON TECHS

The EPA presentation delved into nitty-gritty details of what all the formal rules mean to manufacturers and technicians come midnight Jan. 1, 2010.

Here are some key points:

• Production and import of virgin 22 and 142b will be for servicing existing equipment only.

• Refrigeration or air conditioning equipment coming off the assembly line as of Jan. 1, 2010, “will not be charged with virgin 22, 142b, or blends containing these substances.”

At this point things get a bit tricky. Since HCFCs can continue to be produced after Jan. 1, 2010, and since there are a number of HCFCs (of which 22 is just one), there is still a question of how much of each HCFC will be allowed to be produced.

The only set-in-stone criteria the agency is working with is making sure the total amount of HCFCs stays below those percentage caps noted earlier, that they are used for servicing only, and that the ruling takes into consideration the efforts the industry is making in recovering refrigerants.

The report also makes it clear that “consumers won’t be required to stop using 22, and won’t be required to replace existing equipment.” Furthermore, equipment made before 2010 using R-22 or -142b “may be serviced as usual,” which assumes proper recovery techniques and no venting.

SUPPLY AND DEMAND

The caveat, of course, is the issue of supplies. For the record, the EPA is saying, “After 2010, supplies of R-22 will be more limited and after 2020, only stockpiled or reclaimed 22 will be available.”

The 2015 cross over date is based on supply-demand statistics. The EPA report said the industry could need 43,200 metric tons of R-22 in 2015, whereas production caps on new R-22 are expected to be under that. So, “use of recovered reclaimed refrigerant will be necessary to avoid 22 supply shortages.”

So, look for the EPA in 2008 to propose “allowance allocations” for HCFCs that includes 22, 142b, 123, 225ca, and 225cb. And look for whatever poundage production numbers the EPA comes up with in 2008 to “step down” in subsequent years, according to the report.

At the same time, the EPA is calling on the industry to help it “set allocations for future consumption caps by projecting units of equipment using HCFCs beyond 2010, and HCFCs needed to service equipment after 2010.”

Newberg said the EPA is currently working on “two supply scenarios modeling varying refrigerant recovery and reuse rates from retired equipment.” One scenario assumes the industry is capable of recovering 50 percent of refrigerant in retired equipment, and that refrigerant could be reused after recycling or reclamation. The other scenario assumes a 10 percent recovery rate (which the EPA estimates is the current percentage of recovery).

Those scenarios are critical. If the industry can get up to a 50 percent recovery rate, there may be adequate supplies. If the recovery rate is only 10 percent, there could be significant shortages.

Factors entering into the supply questions are even more varied. EPA cited:

• “Changes in equipment charge sizes to accommodate 13 SEER.”

• “Rate of market transition to alternative refrigerants.”

• “R-22 costs.”

• “Leak rates and servicing loss rates.”

• “Levels of refrigerant recovery for reuse, reclamation, and/or banking.”

• “Level of imports of used 22.”

• “Volume of precharged 22 equipment imported.”

FASTER PHASEOUT?

Contractors and technicians should be aware of the possibility of even faster phaseouts than those on the books, said Newberg. “Several countries have submitted proposals to accelerate the HCFC phaseout.” Even though the U.S., as a so-called developed country, is on a faster phaseout than so-called ‘developing’ countries such as China and India, Newberg said look for the possibility of:

• Accelerating the phaseout for both developed and developing countries by 10 years.

• Adding interim reduction steps for developing countries.

• Setting an earlier date for developing countries to set a baseline and freeze HCFC consumption.

• Phasing out the most damaging HCFCs first.

One final reason contractors and technicians need to be aware of the current rules and possible changes is that September 2007 marks the 20th anniversary of the signing of the Montreal Protocol - mainstream media and environmentalists are expected to make much ado about what the protocol was supposed to do and how well it has done with what it was expected to do.

For more information, visit www.epa.gov.

Sidebar: Import & Export

The presentation tried to clear up the confusing and sometimes controversial issues surrounding the import and export of HCFCs. Major manufacturers of refrigerants used widely in North America have been especially aggressive in taking legal action to stave off “off-shore” refrigerants that fall outside the framework for importing and exporting.

The exact terminology from the EPA regarding this is as follows:

• An importer “must hold allowances to import virgin 22 and 142b in bulk, comply with recordkeeping and reporting rules, and must have EPA approval to import used HCFCs.”

• For an exporter, “allowances (are) not currently required, but annual reporting is required.”

• Exporting companies “should contact the destination country to ensure compliance with its domestic requirements.” The EPA further noted, “Some countries have banned HCFC imports.”

Sidebar: Phaseout Dates

The following phaseout dates were given by the U.S. EPA:

Jan. 1, 2010: “Ban on production and import of 22 and 142b, except for ongoing servicing needs in equipment manufactured before Jan. 1, 2010.”

Jan. 1, 2015: “Ban on introduction into interstate commerce or use of all HCFCs except where the HCFCs are used as a refrigerant in (equipment) manufactured prior to Jan. 1, 2020. Ban on production or import of HCFCs except where the HCFCs are used as a refrigerant in appliances made prior to Jan. 1, 2020.”

Jan. 1, 2020: “Ban on remaining production and import of -22 and -142b.”

Jan. 1, 2030: “Ban on remaining production or import of all other HCFCs.”

Publication date: 08/06/2007