R134a Refrigerant

Do you use R-134a refrigerant?

A-Gas RemTec can provide you with R-134a in 30lb, 145lb, 1,000lb, 2,000lb, ISO Truck Tank and 30lb pallet quantities.

The R-134a meets AHRI 700-2006 Specification and we provide a certificate of analysis for every shipment.

Are any of your cylinders out of test date?

A-Gas RemTec is a certified Department of Transportation (DOT) hydrostatic testing facility.
We'll internally wash, hydrostatically test and recertify your tanks.

Other required services (based on cylinder size) and optional services are available.

Do you recover R-22?

A-Gas RemTec will pay you for it if it meets 98% purity.


We'll pay the freight both ways, if you can provide us with our minimum net weight requirement of R-22.

EPA Warns Against Use of Refrigerant Substitutes That Pose Fire and Explosion Risk

FOR IMMEDIATE RELEASE
July 1, 2013

WASHINGTON – The U.S. Environmental Protection Agency (EPA) is warning homeowners, propane manufacturers and sellers, home improvement contractors and air conditioning technicians of potential safety hazards related to the use of propane or other unapproved refrigerants in home air conditioning systems.

EPA is currently investigating instances where propane has been marketed and used as a substitute for HCFC-22 (R-22), a refrigerant that is widely used in home air conditioning systems.

Home air conditioning systems are not designed to handle propane or other similar flammable refrigerants. The use of these substances poses a potential fire or explosion hazard for homeowners and service technicians. 

EPA is aware of incidents that have occurred both overseas and in the U.S. where individuals have been injured as a result of the use of propane and other unapproved refrigerants in air conditioning systems. We are investigating and will take enforcement actions where appropriate. Other names for these unapproved refrigerants include R-290, 22a, 22-A, R-22a, HC-22a, and CARE 40.

At this time, EPA has not approved the use of propane refrigerant or other hydrocarbon refrigerants in any type of air conditioner. Homeowners and technicians are strongly recommended to limit use of propane or other hydrocarbons to only those appliances specifically designed for these substances and that are properly marked to alert technicians that the equipment contains a flammable substance. EPA has approved the use of propane as a substitute refrigerant for R-22 in industrial process refrigeration systems and in new, stand-alone retail food refrigerators and freezers that are specifically designed to use flammable hydrocarbon refrigerants.

R-22 is being phased out of production and importation under the Montreal Protocol, an environmental treaty ratified by every country in the world designed to reduce and eventually eliminate the use of ozone depleting substances. EPA’s Significant New Alternatives Policy (SNAP) Program has already listed numerous refrigerants with improved environmental, health and safety profiles and continues to evaluate other refrigerants that can be used to replace R-22 and other ozone-depleting substances.

More information about the EPA’s SNAP program: http://www.epa.gov/ozone/snap/
More information about R-22a and alternatives for air conditioning: http://www.epa.gov/ozone/snap/r22a.html

Industry Encourages Cap Use on Refrigerants

Recent Deaths Demonstrate Dangers of Huffing R-22

By Peter Powell

 

This past March, Kristal Salcido, a 12-year-old seventh grader in Victorville, Calif., inhaled HCFC-22 from an air conditioning unit in the backyard of her grandmother’s home. She was later found passed out on the bathroom floor. Rushed to the emergency room, Salcido was pronounced brain dead. Four days later, her family decided to take her off life support.
She had used the R-22 in a ritual called huffing — the intentional inhalation of chemical vapors to attain a mental high or euphoric effect.
Refrigerants such as CFCs, HCFCs, HFCs, and propane are just part of that chemical basket of inhalants. Others are gasoline, paint thinners, nail polish, and nitrous oxide. According to the website www.inhalants.org, one in five students has inhaled a chemical to get high by the eighth grade.

The Hazards of Huffing

In the case of the R-22, “When you inhale it, it kills your brain cells — that’s all,” said Ron Postoian, president of AC Plus Heating & Air of Hesperia, Calif., who was interviewed by television station KTLA for its story on a recent huffing fatality in his home state.
“People really don’t realize how dangerous this is,” said Dr. Craig Sanford, Tulsa, Okla., in a news report broadcast by NewsOn6. “Inhaling this substance prevents the body from getting oxygen and you can get frostbite from it, inside the tissues of your nose, mouth, and face.”
Postoian said that he’s serviced a number of condensing units where the refrigerant had suspiciously been used up.
That “missing refrigerant” aspect was echoed by Ryan Rentmeister, who owns Rentmeister Total Home Service of Salt Lake City. A few years ago in his hometown, people were turning on their air conditioners, but the machines were failing to provide cool air, due to absent refrigerant. “We’ve had four cases in the last week,” he said, suspecting huffing as the cause.
Ronda Szymanski of Advanced Air and Refrigeration Inc., Fort Myers, Fla., said a telltale sign is when service techs find a butter knife laying next to a central air conditioning condenser that has been depleted of refrigerant, with its service port visibly damaged.

Curbing the Problem

Regulators and many within the HVACR industry have been working hard to get a handle on this deadly situation. Both the International Mechanical Code 1101.10 and the International Residential Code M1411.6 have mandated that “refrigerant-circuit access ports located outdoors shall be fitted with locking-type tamper-resistant caps.”
Code requirements have been in place since 2009, but these requirements need to be codified by each state, said Gerry Spanger, director of HVACR engineered products for Rectorseal Corp.
So far, at least five states have adopted the codes, said Spanger. However, limiting more widespread acceptance, the codes are only related to new construction. He said eventually the codes will extend into retrofits and existing buildings. “It is not a question of ‘no, this won’t happen.’ It is just a question of how long it takes,” said Spanger.
Once state codes are in place, inspectors cannot sign off on a job until the locking caps are in place.
“The products are a must for companies and technicians to comply with local codes as well as liability concerns connected with refrigerants,” said Oscar Lopez, vice president of sales for JB Industries Inc., Aurora, Ill.
Spanger said that even as all the regulatory aspects eventually fall into place, there is still the possibility of abuse within the HVACR sector. He said he’d even heard of contractors buying the caps, locking them in place when required, and then removing them after an inspection for use in the next project.
“They don’t understand they are laying themselves open to liabilities,” he said.
He also said that even though the caps can only be sold to contractors who are U.S. Environmental Protection Agency (EPA)-certified to handle refrigerants, he had heard of instances of some wholesalers and contractors who sell the caps on websites, even though they may not be able to verify the certification status of the purchaser.
According to Jon Melchi, director of government affairs for Heating, Air-conditioning & Refrigeration Distributors International (HARDI), “Wholesalers and suppliers strongly believe that these products should not be available online. They should only be sold to licensed contractors. As an industry we must be diligent in making sure that the entire channel is aware of best practices regarding these products.”

Locked and Loaded

While controlling huffing remains a key aspect of locking caps, the devices have long been offered in the HVACR distribution channel for a number of applications. Even as regulations move toward the requirement of locking caps, the devices themselves are being fine tuned.
For example, this past February, Rectorseal Corp. introduced its GasGuard™, a tamper-resistant locking valve cap designed to help prevent refrigerant theft, leaks, and huffing. It screws and locks onto threaded refrigerant Schraeder valves.
“GasGuard restricts unauthorized access because it can only be installed or removed with a unique matching proprietary socket tool,” said Jerry Tomasello, director of marketing for RectorSeal. “It cannot be removed with a core remover or Allen wrench.”
JB’s Lopez also noted that his company is launching a new American-made refrigerant safety cap with greater security under the brand name The Shield.

Contractor Support

Numerous contractors, including Chase Tunnell, president, Dominion Service, Richmond, Va., are strong advocates of locking caps. For a number of years, Tunnell has been involved with the Substance Abuse Free Environment (SAFE) program, which encourages the use of locking caps.
“SAFE is still actively pushing it and Dominion Service is currently doing a public service campaign in the Hampton Roads, Va., area,” he said. “Our Richmond division has had huge success with the program but Hampton Roads has been a little slower to catch on. We are working on fixing that.
“We are currently installing 10-15 caps each week. We’re confident that number will increase significantly as the summer season hits.”

 

 

Counting down to the ban on R22

As the months pass towards the total ban on the use of R22 for servicing air-conditioning equipment, Kevin Groves of Ergro gives his perspective.

The final removal of the HCFC refrigerant R22 from the world’s air conditioning systems has long been heralded and is now upon us here in the UK. Manufacturers of equipment have not included it in new systems since 2003. In 2010 the use of virgin R22 refrigerant was banned, and systems can only now be serviced utilising reclaimed refrigerant for maintenance. Now the final date in the legislative removal of recycled R22 because of its ozone-depleting properties is near. On 1 January 2015, the use of recycled R22 refrigerant will be banned in the EU.

Practically speaking, where R22 refrigerant is in use, there are two main options to make an air-conditioning system serviceable after the ban comes into force. One option is to convert the existing system to enable it to operate using a legal but often less efficient refrigerant or replacing part of or the entire system.

There are two main routes to a conversion solution.

In some cases it will be possible to make a few modifications to the system, such as replacing some gaskets and the oil, which will enable it to run on a new refrigerant such as R422D. This is known as the drop-in refrigerant option, which, in most cases, will lead to a reduction in cooling capacity and increased running costs.

Where another refrigerant cannot be dropped in, there may be the potential to convert the system by installing new fan coils or condensers whilst still retaining much of the building’s existing internal infrastructure such as piping. As well as increasing system capacity, conversion is likely to improve the overall efficiency of a system through the use of modern refrigerants (except when using the drop-in option).

Both solutions are, however, heavily dependent on site, installation conditions and age of the plant.
Systems not suitable for conversion will need to be replaced. Despite the higher installation costs, replacement can lead to greater system efficiencies, lower maintenance requirements and reduced operating costs.

For building-services engineers, the effect of the legislation is likely to mean that air conditioning will take centre stage in many of their operations in the coming years. It’s important that the engineering community understands what is business-critical air conditioning and impresses the importance of preparedness upon facilities managers and business leaders.

Who should act and when, what market forces and liabilities are involved and why it’s becoming the most important news in air conditioning may not be immediately obvious to many business leaders and even facilities managers. In fact, many people who could be affected most acutely won’t even know if R22 is used in their air conditioning or even realise they are responsible for the air conditioning in the spaces they occupy.

At a recent summit in London, held at the Royal Society of Medicine, Ergro assembled a panel of experts to answer some of these questions and to raise awareness of the issues surrounding the ban of R22.

The panel introduced the subject from their various perspectives and took questions from an invited audience comprising building managers, consultants, architects and business leaders.
There were several points upon which the panel was in complete agreement, chief among which was the need for people to gain the knowledge required to properly evaluate their position in relation to a date which, while it seems distant, taken in the context of the financial cycles and business-critical nature of the systems involved, is actually almost upon us.

I represented Ergro on the panel to offer the insight of a contracting engineer who works with air conditioning for skyscrapers, manufacturing, data centres and offices. Also on the panel were representatives of leading air-conditioning manufacturers Mitsubishi Electric and Daikin, legal and liability expertise from property law firm Taylor Wessing and chartered accountants and chartered tax advisors LB Group.

One question concerned the subtleties of supply and demand of the refrigerant itself. R22 is presently trading at around £30 per kilo in the UK, and this price is rising all of the time. When considering the fact that it will become illegal to buy or sell from the end of 2014 it would seem likely that the upward trend in its value will continue.

And what about installing new equipment? If it’s critical to the business that maintenance is possible and downtime avoidable, as it is in many of the instances where an estimated 750 000 systems using R22 exist, then a lot of companies will be looking to replace equipment at around the same time.
Needless to say, where demand outstrips supply in terms of the expertise to fit new systems, there are likely to be delays that could cause unnecessary risk to business continuity.

While it does seem to be a little way off, the R22 refrigerant ban will very soon make its presence felt across the business community. From now and for the next 18 months and beyond, building-services engineers will be at the heart of making business-critical systems compliant and serviceable into the future. But the whole facilities management and building services industry must come together with manufacturers and business services to help the business community to understand how the changes will affect them. Knowledge is power, and a full evaluation of existing systems will equip business leaders with the knowledge to make the right decisions to get ahead of the ban. More information and a countdown to the ban clock is available at the link below.

Kevin Groves is group operations director with Ergro
- See more at: http://www.modbs.co.uk/news/fullstory.php/aid/11893/Counting_down_to_the_ban_on_R22.html#sthash.HbKs8XtY.dpuf

Reclamation Looking for Jumpstart

By Peter Powell

April 8, 2013

A fractional distillation tower in Ohio.
(Photo courtesy of A-Gas RemTec.)

Reclamation is in a rut. Shortly after the arrival of the Montreal Protocol, 25 years ago, came the 3 R’s: Recover, Recycle, and Reclaim. Service technicians would recover refrigerant to avoid fines for illegal venting. They’d then run the gas through an on-site recycling machine to clean it up a bit. But if they were not sure how pure the stuff they were planning to put back into the system was, they would put a virgin version of the same refrigerant into the system and send the old stuff to off-site reclamation facilities, to be brought back to the certified highest level of purity — ARI 700. The reality is that in 2012, and thus far in 2013, few technicians and contractors are bringing R-22 back for reclamation despite an abundance of capacity at many reclamation facilities. “Based on the U.S. Environmental Protection Agency (EPA) report, the amount of R-22 reclaimed year over year has remained relatively flat for the past five to six years, hovering around 5 or 6 percent of HCFC-22 demand,” said Debra D. Goodge, refrigerant reclaim programs manager for DuPont. “Beginning in 2010 with the issuance of the Final Rule (regarding phase out of R-22), there was an expectation that reclaim would be needed to fill a projected R-22 supply-demand imbalance — somewhere in the neighborhood of 27.5 million pounds each year. For the past two years, there has not been an uptick in the amount of reclaimed R-22 going through reclaimers. It’s remained steady around 8 million pounds.” Christopher Foutz, marketing manager, Honeywell Refrigerants, said, “The amount of R-22 reclaimed in 2011 was similar to the amount of R-22 that was reclaimed in 2006.”

What’s the Problem?

“One of the major contributors to the flat or declining recovery rate is that many R-22 users have adopted a practice of reusing their recovered refrigerant,” said Gordon McKinney, vice president and COO, ICOR Intl. “Even though some might be making an attempt to recycle (filter out particulates and/or separate out oils), without properly analyzing the recovered gas to determine composition and quality, the user and equipment owner are rolling the dice.”

Walt Baker, vice president of sales and marketing, Polar Technology, said, “A lot of this can be attributed to the commodity nature of refrigerant gases. Supplies are plentiful and prices reflect the availability of supplies. Therefore, the role of reclaim has been relegated to philosophies regarding environmental stewardship.”
Then there is the economics of reclamation for the contractor, said Ken Beringer, senior vice president of Airgas Refrigerants Inc. “The industry has not seen a significant increase in returned R-22 because, in my opinion, the majority of the product is harvested in small batches which do not have a great deal of value. Until January 2012, the returned gas had very little value and, in many cases, there was a disposal charge when the product was returned.”

Patti Conlan, who manages the reclaim program for Arkema, said, “In the past, the volume of reclaim has been low due to monetary gains not being passed down to the contractor level as an incentive to reclaim, as well as the possible legal and illegal reuse of R-22.”

Yet awareness is growing, said James Sweetman, president, Consolidated Refrigerant Solutions. “We have seen heightened awareness among contractors regarding the need to become involved in a viable reclaim program.”

Arkema’s Conlan is also predicting an uptick. “As the EPA has anticipated, we have just recently started to see an increase in reclaim coming back with the increasing price of R-22.” Said Beringer, “With the phaseout of HCFCs, the amount returned should increase as the price of used gas continues to rise. The very rapid appreciation in new product pricing may have led to the illegal practice of filtering used product and introducing it into the system of a different owner.” Ken Logan, president of A-Gas U.S. Holdings Inc., agrees, stating that “Currently the decreasing availability of virgin product is starting to make a difference. Over time the gap will widen further and the two will become inversely proportional.”

The HFC Factor

Also entering the equation is the industry’s focus on the use of HFC refrigerants as retrofits into systems originally designed for R-22. Owners of large amounts of equipment can move recovered R-22 around to not-yet-retrofitted systems and may or may not look at the reclamation option.

Honeywell’s Foutz said, “Retrofit HFC refrigerants have been available for several years. To date, the availability of the retrofit HFC refrigerants has not stimulated significant growth in R-22 reclamation. As R-22 supplies tighten, the economic incentive should stimulate retrofits to HFC refrigerants and stimulate R-22 reclamation growth.”

ICOR’s McKinney looks at the HFC retrofit from a historical perspective. “If given the opportunity, equipment owners will squeeze the most life out of their systems as possible. It was R-12-alternative HCFC refrigerants that played the most significant role in closing the supply/demand gap during the CFC phase out. Based upon the tremendous market shift in the last few months to HFC alternatives, history is set to repeat itself.”

He noted, “In the near future the R-22 supply — virgin and reclaimed — will be set aside for critical applications where alternative refrigerants are not suitable, such as flooded chillers and systems that have highly sophisticated refrigerant-specific controls.”

For A-Gas’s Logan, this can be iffy. “Keep in mind, retrofitting a system to a refrigerant it wasn’t initially designed for normally involves compromises and not everything is capable of retrofit. The industry itself will decide what can and cannot be retrofitted successfully. Retrofit activity will help conserve supplies of reclaimed R-22 overall.”

Jump Start

What will jump start the sector?

DuPont’s Goodge said, “It is a matter of supply-demand dynamics. If R-22 supply is limited, or the price increases dramatically, there is added incentive to manage the R-22 asset. A major element of a refrigerant management plan is extracting value from the installed R-22. Options include using recovered R-22 to do one or more of the following: gain access to lower-cost R-22 to continue to service equipment that remains on R-22, lowering the cost to retrofit existing equipment to an alternative HFC refrigerant, and/or reducing equipment replacement costs by extending the life of R-22 equipment by using either reclaimed R-22 or an HFC alternative.”

Airgas’s Beringer said it is a matter of economics, “People do not waste what is valuable. If the EPA had more enforcement, and made people accountable for their used product, then the culture would change. Higher pricing should help.”

As will awareness, said Consolidated’s Sweetman. “We believe that there is sufficient interest within the cooling and refrigeration industry to support increased reclamation. Companies that, for years, have been ‘kicking the can down the road’ or ‘dragging their butts’ are really starting to get on the ball. These contractors that have been conducting business as usual are finally reaching out to us for a more viable reclaim option.”

Publication date: 4/8/2013

Peter Powell is Refrigeration Editor. E-mail him at peterpowell@achrnews.com.

The Future of HFCs in Montreal Protocol

My Peter Powell

April 8, 2013

It’s easy to argue that no single development has impacted the HVACR industry as much as the Montreal Protocol. The international treaty, which was signed 25 years ago, ultimately phased out CFC and HCFC production; introduced refrigerant recovery, recycling, and reclamation; and, essentially, enveloped the HVACR industry under the power of the U.S. Environmental Protection Agency (EPA), which now dictates certifications and penalties related to the use and handling of refrigerants.

More than two decades later, the worldwide contract is still strongly impacting many sectors of the HVACR industry, including the decisions of contractors and service technicians. Ongoing discussions are currently underway, examining ways to incorporate HFCs into the protocol in order to phase down their use due to relatively high global warming potential (GWP). And while no changes are expected in the foreseeable future, these continuing conversations, and the potential developments pending, have surely caught the attention of those across the industry.

Good News

But first, the good news: The protocol was designed to protect the ozone layer by phasing out the production of substances found to be responsible for ozone depletion, those having ozone depleting potential (ODP).
And, it appears to be working.

“The Montreal Protocol is widely recognized for being very effective in reducing ozone depleting substances including CFCs and HCFCs,” said Robert Wilkins, vice president of public affairs, Danfoss. “Although we do not expect atmospheric chlorine to return to pre-1980 levels until about 2050, it has peaked and has been trending downward for several years.”

The Emergence of HFCs

With the HVACR industry forced to turn away from CFCs and HCFCs, it has moved on to HFCs, which include no ODP. However, many HFCs carried a high GWP due to their abilities to trap infrared radiations in the atmosphere, which does contribute to the greenhouse effect.

The latest efforts to revise the Montreal Protocol include rating gases based on GWP, as well as ODP.
Rajan Rajendran, vice president of engineering services and sustainability for Emerson Climate Technologies, noted, “The U.S., Canada, and Mexico have proposed an amendment to the Montreal Protocol to address global warming with a phase down of HFCs. This effort has been in place for a few years now. While there are 107 other countries supporting it, there are other, more developing countries like India, China, and Brazil who oppose. One barrier that is often mentioned is that the Montreal Protocol has historically had a very clear mission of addressing ozone depletion, but climate change is outside of its charter.”

Danfoss’ Wilkins added, “The EPA and the Department of State jointly held a stakeholders meeting in Washington on Feb. 5 with American industry leaders and others to discuss possible steps forward. With industry representatives expressing support for a well-planned orderly global HFC phase down on a GWP-weighted basis, it is likely the North American proposal will be resubmitted in 2013 for consideration at this year’s annual meeting.”

But what happens after that is uncertain, although many expect minimal action for a few subsequent years.
Mack McFarland, environmental fellow, DuPont Chemicals & Fluoroproducts, said, “The proposed amendment to the Montreal Protocol has not yet been endorsed by all of the developing countries. Amendments are adopted by consensus. Discussions continue with more and more countries voicing their support each year. I think the industry views the predictable process under the Montreal Protocol as preferable to country-by-country command and control regimes.”

Rajendran agreed. “While there are efforts to make some changes in the protocol, I don’t believe we’ll see any changes in the next few years.”

Europe and the US

European leaders are conversationally discussing HFC regulations based on GWP.

According to the website R-744.com, “The debate did advance, with countries discussing HFC amendment proposals in an informal setting, as well as requesting more information on the availability of environmentally sound alternatives to ozone depleting substances.”

R-744.com noted that this debate has spanned four years, without resolution. In his second inaugural address President Barack Obama 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 not specify any specific proposals during this speech.

A Feb. 12 report from the White House, titled, “The President’s Plan for a Strong Middle Class and a Strong America,” revived calls for more reliance on solar and wind energy generation. The only reference to climate change was the statement, “The president has directed his cabinet to identify executive actions from across the administration to help reduce pollution, prepare our cities and nation for the worsening effects of climate change, and accelerate the transition to more sustainable sources of energy.”

But most do not see this as an omen for unilateral action. For one, a divided Congress seems unlikely to act on potentially costly initiatives. And many in the industry see the EPA wanting to work in the framework of a global consensus.

At the same time, Rajendran did suggest, “The HVACR industry in the U.S. should be watching the emerging U.S. state government regulations out of the West and Northeast as well as potential U.S. government actions and regulations on greenhouse gasses.”

DuPont’s McFarland said, “There are a broad range of global activities under way to address greenhouse gas emissions, such as the U.S. CAFE standard for lightweight motor vehicles, renewable fuels, electricity programs in various countries, and cap-and-trade pilots in China. We anticipate that absent of a global agreement such as the Montreal Protocol, the U.S. government will seek ways to reduce HFC emissions under its current authority.”

But, in the context of a global perspective, Wilkins said progress may occur slowly. “Any changes to the Montreal Protocol would take a few years to enact. If India and China could be persuaded to support an HFC phase down, leading to a global consensus, the Montreal Protocol would then undergo negotiations to finalize the amendment and provide specific targets and timetables for phasing down HFCs globally. The amendment would then need to be ratified country by country. In the U.S., that would likely require action by the Senate. Once approved, each country could begin its own process for phasing down HFCs — similar to the phase down of CFCs and HCFCs.”

SIDEBAR: A No-Go for Kyoto

If changes to the Montreal Protocol are slow starters in regards to any additional impact on HVACR contractors, the Kyoto Protocol is a non-starter. Kyoto was to be the document to obligate countries, starting in 2005, to reduce greenhouse gas emissions (GHG). Many countries signed and ratified it. The U.S. signed it, but failed to ratify it and Canada withdrew from it in 2011.

Even then, many ratifiers had problems reducing GHG emissions to promised levels. However, more than 100 nations have pledged support behind the regulation of GHG emissions through the Montreal Protocol, and a growing number of countries are ready to join on, if a draft is ever presented.

Mack McFarland, environmental fellow, DuPont Chemicals & Fluoroproducts, said, “While there are no discussions under the Kyoto Protocol specific to the HVACR industry, there are active discussions under the Montreal Protocol.”

Robert Wilkins, vice president of public affairs, Danfoss, acknowledged that climate change is emerging as an important issue for the Obama administration. “Since the U.S. never ratified the Kyoto Protocol, and nothing has developed regarding refrigerants, there isn’t likely to be any impact on the HVACR industry.”
Rajan Rajendran, vice president of engineering services and sustainability for Emerson Climate Technologies, said climate-change regulations could still surface in the U.S.

“From the Kyoto Protocol point of view, which is focused on climate change, the HVACR industry in the U.S. should be watching the emerging U.S. state government regulations on greenhouse gases.”

Publication date: 4/8/2013

Peter Powell is Refrigeration Editor. E-mail him at peterpowell@achrnews.com.

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 www.epa.gov/ozone/title6/allowance.html.

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 www.epa.gov/ozone/title6/imports/usedclasstwo.html.

• Violations should be reported at www.epa.gov/tips/, and may be done so anonymously.

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 [www.refri-claim.com]).

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 www.usdoj.gov/usao/fls . Related court documents and information may be found on the website of the District Court for the Southern District of Florida at http://www.flsd.uscourts.gov/ or on http://pacer.flsd.uscourts.gov.

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

phone: (703) 243-0344
website: www.arap.org