By the middle of 2010, a number of manufacturers had begun to ramp up production of such equipment and dry-shipping them without the refrigerant. Several industry observers think the shipments are in the tens of thousands with one such observer - Ted Gartland of Allied Representatives, saying, “Millions will be sold.”
The reasons for the development - which, to many, was unexpected - include:
• The original U.S. Environmental Protection Agency (EPA) ruling of 2009 - designed to curtail use of R-22 - only said that entire systems could not be manufactured and that any replacement components for aftermarket use could not be pre-charged with the refrigerant.
• The fact that condensing units constitute a component not an entire system.
• There is still an ample supply of R-22 at fairly reasonable prices.
• A sluggish economy is helping prop up R-22 supplies.
• There is a customer demand for the less expensive R-22 components to use in repair of older R-22 components, rather than changing out to R-410A a/c equipment.
The concerns raised include:
• The continuing manufacture of entire condensing units - while not in violation of the letter of the law with regards to the EPA regulations - may not be meeting the spirit of the law even if that spirit is somewhat unclear.
• The possibility that the stepped up use of R-22 to charge on site the dry shipped equipment will increase the use of the refrigerant to the point where some R-22 equipment could become stranded and unable to be serviced with dwindling supplies of R-22.
• Some questions about the ability of service technicians to fully charge a residential air conditioner on site especially in terms of accidental venting.
FORMAL ACTIONSThe Air Conditioning, Heating and Refrigeration Institute (AHRI), a trade association representing more than 300 manufacturers of air conditioning, heating and commercial refrigeration, told The NEWS that its relevant committees and sections are reviewing the issue. “Quite frankly, we did not anticipate that R-22 units would continue to be manufactured in any significant quantity,” said Stephen Yurek, AHRI president and CEO.
“Accordingly, we had decided to remove all R-22 condensing units from our directory as discontinued. Now that most of the members who produce these products have decided to reopen their manufacturing lines, we are re-evaluating whether to certify them.” Yurek said his organization is consulting with members, the Department of Energy, and the EPA before making a decision about certification.
The confusion goes back to late 2009 when the EPA’s final ruling related to R-22 equipment focused on not having R-22 in the units rather than what could be manufactured.
Reactions among manufacturers in the industry have been rapid and frequent in the days leading up to publication of this story inThe NEWS. As of press time, the new, dry R-22 condensing units being manufactured are currently outside the scope of AHRI’s certification program.
Though the possibility exists that EPA could clarify its regulations, EPA has not committed to any changes yet. If a rulemaking is required to clarify or modify the rule, a final decision could be a year or more away. At that point the supply of R-22 could be so low as to make a revised regulation a moot point.
That point was amplified by Gartland in his address in mid-September to the Food Marketing Institute Energy and Store Development Conference. While primarily highlighting legislative issues that could affect the refrigeration sector, Gartland said phase-outs of R-22 equipment and a sluggish economy was keeping supplies of R-22 adequate at a reasonable price. But the R-22 condensing unit issue that arose at mid-year could put new pressures of R-22 supplies especially with his estimate that “millions of units” will be manufactured post-Jan. 1, 2010, “to be used as replacements.”
MANUFACTURER VIEWPOINT“Nordyne supports maintaining the availability of dry HCFC-22 units for the marketplace,” said Philip Windham, vice president of sales for Nordyne. “This is why we stand behind our business decision to produce dry (uncharged) R-22 units as an alternative component instead of a compressor change-out or other less-efficient options.
“We believe this equipment provides the consumer with a more conscientious option for the repair choice that they are already making. This choice, when made by the consumer, is more energy efficient, reliable and protects the environment due to the highest level of leak protection offered on all controlled production units. “We do not see these units displacing R-410A systems. Rather, we see dry R-22 units as an option to repairing less efficient, older R-22 units.”
According to Bill Hanesworth, VP and general manager for Rheem Heating and Cooling, “Rheem is committed to supplying its customers with replacement parts and components to service existing installations. With a replacement market three times the size of the new construction market, and with the economy being the worst in decades, Rheem is dedicated to supporting consumers who have our products installed in their homes.”
He added, “As such, Rheem will produce a limited supply of split system air conditioners that will be shipped dry (nitrogen holding charge) and require a field-supplied charge of R-22 refrigerant.”
The NEWShas learned that Carrier, Goodman, Lennox, Nordyne, and Rheem all will produce dry R-22 condensing units.
NOT UNEXPECTEDThe possibility of dry-shipped condensing units was on the industry radar screen as far back as early 2008. A Feb. 11, 2008 article inThe NEWSsaid, “A closer reading of the Environmental Protection Agency 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.”
The article went on to quote Talbot Gee, vice president of HARDI, as saying, “Basically there is no ban on the production of R-22 equipment as long as it is not pre-charged with virgin R-22.”
CERTIFICATIONThe issue of self-certification and the role of the Department of Energy (DOE) - which requires testing, verification, and labeling of products sold - were also discussed by the manufacturers responding to The NEWS’ request for comment.
Said Hanesworth, “For products that are not covered by an approved third party certification program, such as AHRI, manufacturers are to submit certification reports and compliance statements directly to the Department of Energy. Rheem will certify these products directly with DOE and, thus, meet all obligations to comply with submission of energy efficiency data.”
Said Nordyne’s Windham, “There is a process for certifying directly with the DOE. Keep in mind that the equipment was certified before and ratings were removed only three months prior to the initial scheduled removal.”
WHOLESALERSHARDI also has become involved in the issue. According to Gee, “HARDI met with DOE enforcement and compliance staff to better understand how the appliance-standards certification process worked for residential split HVAC systems, and to determine whether HVAC distributors have a compliance obligation with respect to the sale and installation of central air conditioning and heat pump systems that may not meet federal minimum efficiency performance standards.
“Based on this information, HARDI recommends that any HVAC distributor obtain the following from the manufacturer or importer of newly-produced residential R-22 condensing units prior to taking possession of the product:
• Copies of valid Manufacturers Certificate for each unique model number purchased;
• Copies of the test data submitted to DOE showing minimum 13-SEER performance for each unique model number purchased; and
• Agreement with manufacturer or importer to take back any newly-produced residential R-22 condensing units if U.S. EPA or DOE regulations change regarding the sale and distribution of R-22 condensing units manufactured after Jan. 1, 2010.”
Gee described the problem as “frustrating with all the uncertainty. What will be the long term exposure for (HARDI) members and our contractor customers?”
Windham said, “We are telling wholesalers that the decision on whether or not to stock and sell uncharged R-22 units is entirely up to them. We encourage them to research the matter and make the decision that is best for their marketplace and their customers.”
INSTALLATIONOne aspect of the issue in which there seems to be agreement is that the installation of dry-shipped R-22 condensing units should not pose a problem for service technicians. Anecdotal conversations with air-conditioning technicians point to just putting a larger amount of R-22 into a system rather than the typical topping off or taking out a bit of R-22 on site as was the case with pre-charged systems.
Added Windham, “The main difference between installing an uncharged R-22 system component versus one with a factory charge is that the contractor must first purge the dry nitrogen in the unit and then charge according to factory-supplied charging charts. It is also a more cost-effective and less-complicated install than using an R-410A outdoor component with an existing indoor R-22 indoor component. We emphasize that contractors use a standard recovery system anytime they reclaim refrigerant, as well as install a filter dryer to protect the system components.”
Hanesworth agreed. “Contractors should perform a complete system evacuation and follow the charging information included with the unit.”