A closer reading of the Environmental Protection Agency (EPA) regulations regarding R-22 from several sources within the HVACR industry seems to say that equipment can no longer be pre-charged by the manufacturer with virgin R-22 as of 2010. But there does not appear to be any prohibition from manufacturers shipping R-22 units without virgin R-22, leaving it up to the buyer to figure out how to get enough R-22 to have the system later charged by a contractor.
In general, unitary manufacturers appear committed to a preponderance of R-410A coming off the assembly lines in 2010. But what, if any, new R-22 unitary equipment might still be in production in 2010 is unclear.
Entering into the mix is the fact that several refrigerant manufacturers have already introduced to the industry a number of HFC refrigerants designed to work with mineral oil and being marketed as retrofitable into R-22 systems.
“Basically there is no ban on the production of R-22 equipment as long as it is not pre-charged with virgin R-22,” said Talbot Gee, vice president of the Heating, Airconditioning & Refrigeration Distributors International (HARDI). In fact, Gee said his reading of regulations indicate that manufacturers would even be allowed to pre-charge systems with reclaimed R-22.
Gee said one concern has been the lack of adequate promotion of R-410A equipment. “Building and facility owners have no interest in R-410A. They still see R-22 equipment coming off the assembly line.”
A DANGEROUS ASSUMPTIONThat may be a dangerous - and costly - assumption, according to a statement from Trane. “While there may be ways around the R-22 phaseout regulations starting in 2010, such as shipping equipment less refrigerant and allowing customers to charge the unit with recycled/reclaimed/recovered refrigerant, the economics do not make this feasible.”
The reference was to the rising cost of and phaseout of virgin R-22.
“The recent Montreal Protocol changes and an updated look at supply-demand scenarios reveal that supplies in 2010 may be much tighter than originally anticipated, including the possibility that virgin R-22 supplies may be short,” said Kevin P. O’Shea, North American marketing manager for DuPont Refrigerants.
Rather than continuing to order new equipment formatted for R-22, O’Shea said owners need to look at what R-22 equipment they already have and make sure they have adequate supplies of refrigerant through the life of the equipment.
“Equipment owners that have a large base of HCFC systems in place today will need to actively implement plans to retrofit or replace equipment so they have sufficient time and budget for an orderly transition away from HCFCs.”
He went on to say, “Unless the HVACR industry immediately steps up actions and promotes techniques to ease demand for HCFCs and minimize potential supply shortfalls, accelerated HCFC phaseout targets in 2010 may significantly impact the availability and cost of R-22 in the marketplace sooner than originally thought. Contractors and equipment owners can mitigate the potential for a shortfall by taking action now to reduce demand for R-22 and reclaim the supply that is currently available. Additionally, they can implement proper maintenance and repair practices to increase the amount of viable R-22 that can be reclaimed.”
For the record, Trane said its approach “will be to stop offering new R-22 compatible equipment to the U.S. market post 2009. We do not anticipate much, if any, field-installed R-22 systems being implemented post 2009.”
Trane said it would continue to offer components, such as compressors, for R-22 equipment already in the field as part of the company’s commitment to the aftermarket sector.
NEW HFCSEntering into the equation is a current preponderance of HFC refrigerants that a number of refrigerant manufacturers say will work with equipment originally designed for HCFC-22. These blended refrigerants usually have a small amount of propane or similar refrigerant to assist in oil return and also work with mineral oil.
For the most part, the refrigerant manufacturers see such refrigerants as interim solutions in the transition from R-22 equipment to R-410A equipment. But at least one refrigerant producer sees the value of such refrigerants for OEMs who want to continue to produce R-22 equipment.
Steven Mella, CEO of ComStar International Inc., said a refrigerant his company has with an ASHRAE designation of R-434A “can be adapted by equipment OEMs that want to continue to use their R-22 systems without going through the re-engineering required for a R-410A system.”
But Ted Gartland, who once worked for a refrigerant manufacturer and now works for the refrigerant management company Verisae, wonders about using refrigerants for which a piece of equipment was not originally designed.
“Take, for instance, a field-built walk-in. A contractor could use HFC-407C equipment and charge it with recovered R-22. R-407C could be used in 13 SEER R-22 equipment, but would it still be 13 SEER?”
WHAT ABOUT WARRANTIESHARDI’s Gee said the aftermarket use of refrigerants for which the equipment was not originally designed raises questions about manufacturers honoring warranties. One development contractors should watch for in the next few years, he said, is for any OEMs designating certain refrigerants beyond those originally designed for use in a certain piece of equipment as acceptable for that equipment and honoring warranties.
The EPA regulation generating the questions is 40 CFR 32.16(c). It became part of the “frequently asked question” part of the agency’s Website. The Q&A dealt primarily with the issue of import and export of R-22 equipment. But within the language of the rule and the answer, some saw a connection to the issue of domestic production of R-22 equipment.
In part the reply said, “The current provisions limit production and import of virgin R-22 or R-142b as of Jan. 1, 2010. However, these provisions apply to bulk shipments only. They do not address products that contain or are manufactured with R-22 or R-142b. The EPA is concerned with the environmental impacts that could result from the potential continued imports of HCFC pre-charged products after the phase out of production and importation of bulk substances. Therefore, the EPA is evaluating options for addressing these concerns.”
The fact that the regulation relates to imports is yet another aspect of the equation. Gee said wholesalers are interpreting current regulations as allowing domestic manufacturers to continue to produce R-22 equipment offshore and import such products into the United States for sale, provided it is not actually charged with R-22.