Wednesday, March 20, 2013

The EPA Cracks Down on Illegal R-22 Importation and Sale

The Alliance for Responsible Atmospheric Policy, an industry coalition, said in November 2012 the United States government successfully concluded 11 criminal and civil cases related to HCFC-22 refrigerant smuggling over the last two years. The alliance said that individuals and companies were found guilty of various crimes related to the illegal importation or sale of over 3.3 million pounds of R-22, fined over $1.5 million, required to forfeit proceeds of almost $2.7 million, and received jail and probation amounting to over 26 years.

“The U.S. government is very serious about tracking down those who illegally import or sell HCFC-22. Anyone devising illegal schemes to import or sell this refrigerant is on notice that the U.S. will arrest and convict you,” said Dave Stirpe, alliance executive director.

Only Buy Legal R-22

Stirpe went on to say that the alliance cautions industry and the public to be certain that their R-22 refrigerant purchases are legal, and to report any offers to buy illegally imported refrigerants to the U.S. Environmental Protection Agency (EPA). R-22 refrigerant may be legally produced domestically and imported into the U.S. provided that EPA-issued quota allowances are expended. Anyone importing HCFCs without legal allowances is in violation of federal law. R-22 is generally used to service and maintain existing commercial air conditioning and refrigeration equipment. Newly produced equipment generally relies on HFCs and other refrigerants.

"Purchasers of the illegal refrigerant are at risk,” Stirpe said. “The government may confiscate any illegally imported refrigerant, even if it has been passed down through the marketplace, and it may prosecute purchasers who knowingly buy illegal material. Consumers should also be wary of the refrigerant since some of the imported material has been found to be of poor quality, or it could be counterfeit.”

He went on to say that purchasers of imported R-22 should verify that their importer is an authorized EPA baseline consumption allowance holder, or was involved in a subsequent legal trade of consumption allowances. An EPA list of baseline consumption allowance holders can be found at

Some other points made by the alliance about importation and purchase of R-22:

• The recipient of a trade can show a letter from EPA acknowledging the approval of the trade.

• Purchasers who question the legitimacy of an HCFC-22 importer should request a copy of the EPA approval letter from the seller.

• Importers of used HCFCs must follow EPA petition process requirements listed at

• Violations should be reported at, and may be done so anonymously.

Monday, March 18, 2013

Beyond Familiar HFCs

DALLAS — While much of the buzz at the AHR Expo was on dwindling supplies of new HCFC-22, reclamation of that refrigerant, and use of alternative HFCs in retrofits, a number of conversations centered on alternatives beyond familiar HFCs. Even with the regulatory landscape unclear, the high global warming potential (GWP) of some HFCs was causing a stir on the show floor.


While HFC-410A was firmly encamped as the refrigerant of choice for air conditioning in a large number of applications, its high GWP was turning attention in Dallas to use of HFC-32 as a stand-alone refrigerant. HFC-410A, which was introduced to the industry more than a decade ago as an alternative to R-22 in new equipment, carries a high GWP. R-32 has a much lower GWP (675 vs. 2088). This is a topic that has been in the industry for a number of years, since it first surfaced as a high-profile topic in 2010 at industry conferences hosted by Purdue University.

Danfoss furthered this notion at its AHR Expo booth, where it displayed its SG scroll compressor with the signage: “Get ready for Green Solutions with R-32.”

HFOs on Display

HFO refrigerants are widely recognized as the next generation of refrigerants. The alternative garnered its fair share of attention at the expo as well.

On the show floor, Honeywell was issuing a statement about its HFO refrigerant 1234ze which it markets as Solstice L-41. The manufacturer compared its refrigerant, stating that their refrigerant offers “significant advantages over another (R-410A) alternative, R-32, which has a higher GWP and limitations related to high-discharge temperatures, which can affect performance and durability in hot climates, and may also require new lubricants.”

Honeywell boasted that Solstice L-41 offers a 75 percent reduction in GWP compared to R-410A and is intended to replace R-410A in residential and light commercial air conditioning and heat pump applications. In addition to its lower GWP, Solstice L-41 offers excellent energy efficiency, is cost effective, and can be used in existing equipment designs with minimal changes.

“Honeywell has been working closely with leading equipment manufacturers to optimize Solstice L-41 to meet the demanding requirements of both stationary air conditioning and heat pump applications across a broad range of operating conditions,” said Tom Morris, director of commercial development for Honeywell Fluorine Products. “Solstice L-41 will allow these manufacturers to offer more environmentally friendly air conditioning and heat pump systems to help address climate change.”

Solstice L-41 is based on Honeywell’s HFO-1234ze technology, which was “first introduced in 2008 and has since been proven and commercialized for chillers, insulating-foam, and aerosol applications. A new HFO-1234ze manufacturing plant is currently under construction to meet the needs of equipment manufacturers.”

Even with its involvement with R-32 in some applications, Danfoss was waving the HFO flag. The company used a press conference to announce its involvement with HFO-1234ze in its Turbocor line and the commercialization of TG310 compressors, which were released as a developmental prototype in early 2012. The company said the compressors “utilize the ultra-low GWP, zero ozone depletion potential (ODP) refrigerant HFO-1234ze.”

Safety First

As the HFO sector evolves it is becoming clear that there are HFOs with A1 (nonflammable) safety ratings and those that have A2L (slightly flammable) safety ratings. A1s generally carry higher GWPs than A2Ls. This means the sector will have to sort itself out. If regulations set especially low GWP maximums, only A2Ls would be allowed to establish a beachhead; which would require UL certification, as well as building code modifications, for the installation of such equipment in certain portions of the country.

One HFO topic that appears to be sorting itself out is in the automotive sector. After automaker Daimler expressed some safety concerns over the use of HFO-1234yf in vehicle air conditioners last fall, General Motors issued a statement at the time of the expo pledging to move ahead with the use of that HFO in its vehicles — saying that in all its testing, the refrigerant proved safe and effective.

HCs and CO2

A number of manufacturers showed equipment for natural refrigerants such as HCs and especially CO2 at the expo.

During a Danfoss press briefing, Scott Martin, director of sustainable technologies, Hill Phoenix, spoke about CO2 developments that his company has been doing in conjunction with Danfoss. He said that his company’s systems that utilize CO2 technology offer several distinct advantages over traditional DX-refrigeration systems. “These CO2 sub-critical systems deliver superior refrigeration performance with enhanced sustainability, reduced refrigerant-charge requirements, and greatly reduced refrigerant-leak rates. Simply, they are the most energy-efficient and environmentally friendly refrigeration systems available in the industry today.”

He also noted advances in CO2 in transcritical-application use of which are growing in North America. That was reinforced on the show floor at the Bitzer booth where a transcritical-CO2 compressor was displayed.

The editors of the European-based online publication also walked the floor at AHR and provided a viewpoint for its global readership regarding the future direction of CO2 use in the United States.

“The pure number of booths displaying CO2 refrigerant components and systems has not significantly increased from last year’s trade show. However, the showcase of breakthrough innovations, prototypes, and optimized product lines in R-744 (CO2) compressors, heat pumps, or air conditioners, as well as commercialization announcements expected for the next 12 months are all solid indicators that the U.S. market is getting serious about R-744.”

Climate Change Rejoins Agenda

So just when we thought regulatory actions related to the environment were pretty mute, given not much traction in Washington mainly due to a sluggish economy, along comes, of all people, the president of the United States.

Barack Obama was barely into his second inaugural address when he said, “We will respond to the threat of climate change, knowing that the failure to do so would betray our children and future generations.” He did call it climate change instead of global warming, since the former is the more popular catch phrase, especially when temperatures are below average. When temps are above average, the buzz phrase goes back to global warming.

He even had a dig for those few who still doubt what used to be called global warming. “Some may still deny the overwhelming judgment of science, but none can avoid the devastating impact of raging fires, and crippling drought, and more powerful storms.”

It has never been clear to me how much the HVACR industry contributes to “devastating impacts,” and certainly the president’s examples can’t seem to be directly blamed on HVACR.

Next came the plug for alternative energy sources such as wind and solar. “The path toward sustainable energy sources will be long and sometimes difficult. But America cannot resist this transition; we must lead it.”

Here, the idea is that wind and solar will be taking us off the electric grid, which powers nearly all our HVACR needs. It is just that when there is no wind or no sun, the grid has to be relied on — and nobody has really come up with a cost-effective, energy-efficient option.

And speaking of money, the inaugural speech did not go into specific dollars and cents when it comes to addressing climate change and embracing new energy options. It was more like we can do it all. He said, “We cannot cede to other nations the technology that will power new jobs and new industries — we must claim
its promise.”

This is not a political column so I won’t comment on how the president intends for the United States to become a leader in taking on climate change and getting more interest in alternative energy sources and what it will cost. He did make a brief reference to dealing with the cost issue in the context of healthcare and the deficit. “We must make the hard choices to reduce the cost of health care and the size of our deficit. But we reject the belief that America must choose between caring for the generation that built this country and investing in the generation that will build its future.”

The point here is that he is trying to put climate change back on the front-burner/high-priority list during his last term in office. If climate change includes global warming issues, then many HFC refrigerants come back into the political/regulatory arena because of their perceived high GWP.

That issue never goes into the background in Europe. Even now, the European Commission, which does a lot of the regulatory legwork for the European Union, which is made up of 27 countries, is putting pressure on some sort of phase-down of HFC use in Europe, and, in cases where natural refrigerant options can be used, a phaseout of HFCs. There is still a way to go in Europe in terms of anything taking hold and manufacturer organizations over there are continuing to draw attention to the potentially higher total energy costs of using alternative refrigerants.

But should that effort in Europe gain some momentum, it is sure to cross over the Atlantic just as the phaseout of CFCs and then HCFCs started in Europe and then came to North America. The question then becomes, if that momentum does reach the U.S. within the next four years, how much will President Obama’s renewed attention on climate change in his speech move things forward?

Monday, March 11, 2013

A-Gas Acquires RemTec and Refrigerant Reclamation Technologies

Refrigerant Updates

Converting Away From R-22

Editor’s Note: The following article was prepared by ICOR International and references some technologies and products specific to the company.

With the impending phaseout of R-22 looming, the price and availability of the product will soon make it impractical to use.

With virtually tens of millions of R-22-designed a/c systems in operation, refrigerant users and equipment owners will need to employ a number of alternative options to satisfy their cooling needs. Due to the special application designs and cooling requirements found in multifamily structures, there are a unique set of challenges in maintaining cooling equipment and fewer practical options.

It is illegal to purposely vent any refrigerant. All refrigerant users must possess an EPA 608 certification (required by law under The Clean Air Act) to recover all refrigerants. Recovered refrigerants are to be recycled or returned to an EPA-registered reclaim service provider (one example of which is Refri-Claim []).

The law does allow equipment owners to recycle and reuse refrigerants in their own equipment without processing it through a reclaim company. However, this practice adds additional costs in the form of equipment, labor, and energy, and, if done improperly, can create additional service problems and even equipment failures.

Equipment Replacement

HFC-410A is the non-ozone depleting replacement of choice by new equipment manufactures. Since R-410A operational pressures are much higher than that of R-22, R-410A-designed systems incorporate unique materials and components. For this reason users cannot use R-22 in an R-410A-designed system, or use R-410A in an R-22-designed system. The refrigerants must be segregated and used only in systems designed for their unique characteristics.

Even though R-410A is a highly efficient refrigerant and the equipment’s physical footprint does not pose any new challenges, the cost of replacing an existing R-22 designed system with an R-410A system may be impractical. With most multifamily systems, the evaporator (indoor unit) has a much longer lifespan than does the condenser (outdoor unit). However, R-410A pressures require the replacement of the outdoor unit as well as the indoor unit. And since R-410A systems require the use of a product specific lubricant — POE oil — the system piping (line sets) must be flushed with a special solvent to remove any build up along the piping walls.

Refrigerant Conversion

For equipment owners with a restrictive budget, full equipment replacement to R-410A may be impractical.

The simplest and least costly option to maintaining an existing piece of R-22 equipment is to convert the system to a direct replacement refrigerant. For example, HFC-422B (marketed by ICOR International as NU-22B) is a non-ozone depleting, nontoxic, and nonflammable direct replacement that nearly duplicates the operating characteristics of R-22. System conversions to R-422B do not require the use of any product-specific materials or components. Therefore decision-makers can extend the lifespan of both the indoor and outdoor units and avoid any costs associated with flushing or replacing system piping.

The Conversion Process

Here is the conversion process using R-422B as an example:

1. Recover all of the R-22 from the system following EPA regulations.

2. Complete all necessary system services and repairs.

3. Pressurize system and performance leak check.

4. Pull system into a vacuum.

5. With the system off, initially charge R-422B in the system to 80 percent of the original R-22 charge as a liquid. Note: Charging a system with R-422B as a vapor will reduce system performance.

6. Start system and allow pressure to stabilize.

7. To maximize system performance on a fixed orifice system, check compressor superheat; on expansion valve units check system subcooling. Adjust charge as necessary. Note: Refer to the original equipment manufacturer’s superheat and subcooling specifications.

8. Leak check the system and establish preventive maintenance schedule.

A special note: For large-tonnage equipment or unique systems, and or applications, contact ICOR’s Tech-2-Tech department for conversion assistance. Do not use R-422B or any other 400 Series refrigerant in a flooded evaporator application.

International Heating and Cooling Product Distributor Please Guilty

International Heating and Cooling Product Distributor Pleads Guilty and

Sentenced for Illegal Purchase and Sale of Smuggled Ozone-Depleting Refrigerant Gas

        Wifredo A. Ferrer, United States Attorney for the Southern District of Florida, Maureen O’Mara, Special Agent in Charge, United States Environmental Protection Agency (EPA), Criminal Investigation Division, Atlanta Area Office, and Alysa D. Erichs, Special Agent in Charge, United States Immigration and Customs Enforcement’s Homeland Security Investigations (ICE-HSI), announced today that defendant, FSD Group, LLC a Florida corporation with its headquarters in Miami, was convicted and sentenced in connection with the illegal receipt, purchase, and sale of ozone-depleting refrigerant gas that had been smuggled into the United States contrary to the Clean Air Act, in violation of Title 18, United States Code, Section 545.

        FSD Group pled guilty to a one count Information filed against it before United States District Court Judge Joan Lenard, for knowingly receiving, buying, selling and facilitating the transportation, concealment, and sale of approximately 65,592 kilograms of the ozone-depleting substance hydrochlorofluorocarbon-22 (“HCFC-22") which had been illegally smuggled into the United States contrary to the Clean Air Act.  HCFC-22 is a widely used refrigerant for residential heat pump and air-conditioning systems.

        Immediately following the guilty plea, FSD Group was sentenced to three years of probation and ordered to pay a $100,000.00 criminal fine.  In addition, as a special condition of probation, FSD Group was ordered to implement and enforce a comprehensive Environmental Compliance Plan.  FSD Group was also ordered to forfeit to the United States $180,051.00, which represents proceeds received as a result of the crime and pay owed duties to the United States Customs and Border Protection for incorrectly classified merchandise.

        Federal law prohibits dealing in merchandise that is imported contrary to law.  The Federal Clean Air Act regulates air pollutants including ozone depleting substances such as HCFC-22.  The Clean Air Act and its implementing regulations established a schedule to phase out the production and importation of ozone-depleting substances beginning in 2002, with a complete ban starting in 2030.  To meet its obligations under an international treaty to reduce its consumption of ozone-depleting substances, the United States issued baseline allowances for the production and importation of HCFC-22 to individuals and companies.  In order to legally import HCFC-22, you must hold an unexpended consumption allowance. 

        According to court records, FSD Group which also operates under the name Saez Distributors, is an international supplier and distributor of merchandise for heating, ventilation, air conditioning, and refrigerator systems, equipment and products including ozone-depleting substances.  In business for thirty five years, and itself, an original allowance holder under the Clean Air Act, FSD had extensive knowledge regarding the Act’s rules and prohibition against purchasing illegally imported HCFC-22.  During the course of the illegal conduct, in addition to its legal imports, FSD Group made additional purchases of HCFC-22 from various importers, knowing they did not hold the required unexpended consumption allowances, totaling approximately 65,592 kilograms, of restricted HCFC-22, with a fair market value of approximately $733,096.00.  

United States Attorney Wifredo A. Ferrer stated, “The regulatory program here is intended to protect us all from the harmful effects associated with depletion of the earth’s ozone layer.  By aggressively supporting the investigative agencies in their efforts to enforce federal laws that seek to protect our environment, we are both meeting our country’s commitment and responsibility to our future generations and the international community.”


        EPA SAC Maureen O’Mara said, “HCFC’s deplete the stratospheric ozone layer, which is critical to life on earth and protecting people from the harmful effects of ultraviolet radiation, including cancer.  EPA will continue working with ICE and other agencies to combat such criminal conduct, preventing these dangerous smuggling and distribution operations, and curbing the world-wide threat of stratospheric ozone depletion.  This plea and sentence, the first of its kind against an allowance holder, sends a strong message that those who jeopardize public safety in order to make illegal profits will be vigorously prosecuted and punished.”


        “EPA realizes that as HCFCs are phased out domestically, smuggling is likely to rise, jeopardizing human health and our atmosphere. This is why EPA is working harder than ever, in cooperation with our federal partners, to seek justice against those that not only illegally import R-22, but also knowingly purchase contraband material,” said Drusilla Hufford, Director of EPA’s Stratospheric Protection Division.


        “The unlawful importation of goods poses a significant threat to the national security, public safety, and in this particular case, the illegal importation posed a global hazard to our environment,” said Alysa D. Erichs, Special Agent in Charge of HSI Miami.  “We will continue to vigorously investigate those who are determined to line their pockets with the proceeds of crimes against the environment.”

        This matter and others involving the smuggling and distribution of ozone-depleting substances are being investigated through a multi-agency initiative known as Operation Catch-22.  Operation Catch-22 has, to date, including the successful conviction of nearly a dozen individuals and corporations at every level of the refrigerant gas smuggling and distribution chain. 

Mr. Ferrer commended the investigative efforts of the EPA, ICE-HSI, the Florida Department of Environmental Protection, Criminal Investigation Bureau, and the Miami-Dade Police Department.  The case was prosecuted by Special Assistant U.S. Attorney Jodi A. Mazer.

        A copy of this press release may be found on the website of the United States Attorney's Office for the Southern District of Florida at . Related court documents and information may be found on the website of the District Court for the Southern District of Florida at or on

Dave Stirpe
Executive Director
Alliance for Responsible Atmospheric Policy
2111 Wilson Blvd., 8th Floor
Arlington, VA 22201

phone: (703) 243-0344