It is truly the 11th hour for most all things related to refrigerants. The year 2009 was a pivotal year leading up to dramatic changes in 2010 in terms of refrigerants used and refrigerant supplies. But much remains undone and much uncertainty surrounds what will happen when things get done.
Tentative legislative actions that could affect HFCs have yet to become law; proposed Environmental Protection Agency (EPA) regulations governing HCFC allocations and sale of R-22 equipment have yet to be finalized; the final changeover of OEM air conditioning equipment from R-22 to R-410A is nearly done but going down to the wire; alternative refrigerants to replace R-22 in existing systems are available but in a wide variety, each with a fairly narrow range of applications; alternatives beyond HFCs are being talked about with some being installed; and reclamation, which was supposed to offset cutbacks in virgin R-22 production, still has not caught on as was once hoped.
“There are challenges and opportunities ahead,” said Talbot Gee, vice president of Heating, Air-conditioning, Refrigeration Distributors International (HARDI). As he told a group of contractors and technicians at the Refrigeration Service Engineers Society’s (RSES’s) recent annual conference, “What’s going on is not nice background noise. The key is how to use it to your advantage even if you don’t agree with all of it. With these challenges there are opportunities for quality contractors.”
WAXMAN-MARKEYRegarding pending legislation that could affect supplies of HFCs in the future, the most high profile one currently is the American Clean Energy and Security Act of 2009 (the so-called Waxman-Markey bill named for its two sponsors in Congress). In terms of refrigerants, the proposed bill “creates cap-and-trade program for the production and importation of HFCs such as R-410A and the importation of products containing HFCs,” said Matt Lattanzi, director of product and brand management for Nordyne.
“The program reduces the number of allowances each year starting in 2012. According to the legislation, the allowances will steadily decrease from 90 percent of a baseline to 15 percent of the established baseline by 2032.
“Basically, this legislation effectively begins the phaseout of R-410A starting as soon as 2012.”
However, Lattanzi did say that “this bill has not become law and it has a long way to go in Washington prior to becoming law.”
On June 26, 2009 the U.S. House of Representatives approved the bill and the Senate published a draft version on Sept. 29.
Said Lattanzi, “The most likely scenario is that committees from both the House and Senate will negotiate and merge the two pieces of legislation into one bill. The merged bill would then proceed to the floors of both to be heard and eventually a vote would take place. If the bill fails to pass in either house, it would likely be referred back to the committees and the process continues. This back and forth activity may go through several revisions and the legislation will likely look very different from what it does today if and when it eventually passes.”
There is also the possibility that HFCs may not be directly linked to the cap-and-trade formula, said Ted Gartland of Verisae, a company that provides energy management, carbon footprinting, and refrigerant tracking software. “There may be separate HFC caps including a provision for $1 per metric ton “buy-ins,” he said in reference to a formula for, in effect, taxing various HFCs based on global warming potential.
Waxman-Markey is also facing opposition on numerous fronts; with many citing negative effects on an already struggling economy and predicting it will never pass.
“The Waxman-Markey bill is on political life support now, primarily because citizens have awakened to the crushing costs, job losses, and market uncertainty these bills would inevitably cause,” said Jim Sims, president and CEO of the Western Business Roundtable, a coalition of business leaders.
EPA REGSThe two proposed EPA rules have yet to become finalized even though they would become law Jan. 1. Gee told the RSES audience that the rules have been sent to the Office of Management and Budget with a request that approval from there be expedited. Gee said approval could come by mid-December.
One dealing with “sale or distribution of pre-charged appliances” was designed to clarify what R-22 equipment could be sold starting in 2010, as well as some servicing aspects.
“Equipment manufactured and pre-charged with virgin R-22 before Jan. 1, 2010, can still be sold after Jan. 1, 2010,” said Karim Amrane, vice president, regulatory and research at the Air-Conditioning, Heating, and Refrigeration Institute (AHRI). “This is true also of components as long as they are used to service an existing unit manufactured prior to Jan. 1, 2010.”
The one thing that is certain is that OEMs will no longer be producing R-22 units come Jan. 1. According to Amrane, “As of September, about 60 percent of all unitary equipment shipped in 2009 were R-410A units. I believe that the conversion is on track and that we will have a smooth transition on Jan. 1, 2010.”
In a talk at the RSES convention, Al Maier of Emerson Climate Technologies Flow Controls expanded on that a bit by noting that there are a number of HFCs acceptable to the EPA currently in the market. He said “R-410A will dominate the U.S. residential a/c market while R-407C is likely in new larger tonnage equipment.”
The second proposed EPA rule deals with allocations of HCFC refrigerants as of Jan. 1. It is expected that would allow the production of 110 million metric tons of virgin R-22 for use in the United States, according to Mack McFarland, DuPont Environmental Fellow. “R-22 users need a plan to respond to decreased availability now.”
There is a concern among refrigerant producers over a shortfall in supply and demand for R-22. DuPont said during a September Webinar event that in 2010 demand will be 137 metric tons, which cannot be covered with a 110 million MT production quota on virgin R-22.
The solution, echoed throughout the industry, involves maintaining leak tight systems to preserve as much R-22 as possible in existing systems, looking at HFC alternatives that can be retrofitted into R-22 systems, and more reclamation.
SERVICING“The R-22 in your equipment is a valuable corporate asset,” said DuPont in a statement. “Use it. Service equipment with recovered R-22.”
As noted by Bacharach in one of its training publications, “Leak testing (is) one of the most challenging tasks faced by service technicians today. EPA rules are requiring service technicians to find leaks that are excessive of the law, thus not allowing technicians the choice of just adding refrigerants every so often to keep the system in operation. Add to this the cost of refrigerants today and it become imperative that refrigerant leaks must now be found.”
HFC ALTERNATIVESThere are about a dozen HFC refrigerants currently available that can be retrofitted into existing R-22 systems, according to their manufacturers. Some incorporate isobutene, propane or similar HC refrigerant to allow HFCs to be used with the existing mineral oil in the system while still maintaining an A1 safety rating. HFC refrigerants without HCs work with POE oils requiring a changeout of the mineral oil, although many in the industry say that the changeout does not have to be 100 percent.
“HFC refrigerants are the cost-effective option for replacing R-22,” said DuPont. Also in regards to HFCs, Honeywell issued a statement in 2009, saying, “Contractors should recommend to their customers a change to alternative refrigerants that are 100 percent non-ozone depleting and, in many cases, are more efficient than R-22, which will save money on utility bills.”
BEYOND HFCSEven though there is currently no regulations in effect that call for a reduction in the use of HFCs in North America, there is action underway to look at alternatives to such refrigerants. Two relate to CO2 (R-744) and HFOs.
“CO2 has no ozone depletion potential (unlike CFCs and HCFCs) and has negligible global warming potential (unlike HFCs),” said Raphel Gerber of Frigo-Consulting AG, when he spoke at the Food Marketing Institute Energy and Technical Services Conference this past September. “It is energy efficient and has no risk related to future taxes such as (might be) on HFCs.” He did say that currently there are challenges related to prices, lack of components, lack of training, and public perception.”
In its 15th annual refrigerant report, Bitzer described CO2 as used in sub-critical applications as “very beneficial from energy and pressure level points of view in industrial and larger commercial refrigeration applications.” The report did caution that “further development work is necessary with regard to adaptation of technical standards and safety requirements.”
Regarding the refrigerant in trans-critical applications, the report said, “Further development is necessary in many areas. For most applications, trans-critical CO2 technology cannot be regarded as state of the art.”
The other refrigerant being looked at beyond HFCs, is HFO-1234yf that was jointly developed by Honeywell and DuPont for use in the European automotive sector, which must begin a phaseout in the use of HFC-134a.
As of October 2009, German automakers seemed to be leaning toward CO2 as an air conditioning refrigerant, while much of the rest of Europe was favoring 1234yf.
The Bitzer report said the HFO based on “operating experiences gained from laboratory and field trials to date allow a positive assessment particularly with regard to performance and efficiency behavior.” Its application in stationary continues, with the Bitzer report saying, “There are questions regarding chemical stability during the generally very long run times of such plants, which must be addressed.”
RECLAMATIONThe reclamation of R-22 has long been considered critical in allowing adequate supplies of R-22. But that does not seem to be happening.
“According to the EPA, only 7 percent of the current 137 million pounds of annual R-22 demand is being recovered, reclaimed, or reused,” said George Dinsmore of Hudson Technologies Reclaim Center. “If R-22 supply is reduced to 110 million pounds as projected by the EPA, then the amount of R-22 that is reclaimed next year must triple to at least 20 percent to meet demand.”
“Roughly, 10 million pounds of R-22 is currently being reclaimed for reuse. The projected demand is roughly 125 million pounds.”
So how can contractors be motivated to step up reclaim efforts. Said Dinsmore, “Contractors and wholesalers need a reclaim program that is convenient and provides economic incentives to recover and return R-22.” He, like others in the sector, contend that his company does provide such convenience and incentives.
Said Ted Atwood of Polar Technology, “The motivator for bringing more contractors to the reclaim option? Money. In this particular case, lower costs. With the economic situation we are in, no one is in a position to spend more money than they absolutely have to in order to conduct business.”
While reclaimers continue to offer incentives for contractors, at least two other dynamics may also be affecting the reclamation sector.
Polar’s Atwood said the HFC refrigerants R-407A and R-407C are gaining ground as R-22 retrofit refrigerants. “The critical need for R-22 has dissipated.”
Then there is the recurring contention in the industry that the shortfall of R-22 may not materialize in 2010. One of those in that camp is industry observer Pete Williams who sees a similar situation regarding HCFCs that arose 20 years ago with CFCs.
“There was never a shortage of CFCs during or since the last phaseout. The fact is it was function of price. Holders of CFC-11, -12, -113, -114, -500, and –502 were willing to make their product available as long as the price was right.”
He said the industry today is raising the same concern over supplies of HCFCs that they did with CFCs concerns, which he said did not become reality.
“Look at the press releases from that era and you’ll see the same thing we are hearing today.”
So from the regulatory front to pending legislation to specific refrigerants, nothing is totally clear cut in the final days of 2009, and opinions on what 2010 holds remains wide ranging and often contradictory.