EPA Finalizes R-22 Allocations for 2012-2014

By Charlie McCrudden | April 4, 2013 | Leave a Comment

On April 3, the U.S. EPA published in the Federal Register the final rule adjusting the allocation of HCFCs (including R-22 refrigerants) for the years 2012-2014 (2013 Final Adjustment Rule).

According to the Final Adjustment Rule, R-22 allowances for 2013 will rise by about 13% relative to 2012, and decrease by 20% in 2014 relative to 2012. The allocations for the years 2015-2019 will be set in a subsequent rulemaking. These allocations became effective on April 3, 2013.
See the chart below (click to enlarge).

Contractors may want to contact their wholesalers or gas distributors to inquire about any changes in pricing or sales policies in light of the 2013 Final Adjustment Rule. Despite the unexpected increase in the allocations for 2013, the market remains volatile and prices for R-22 may not respond to the increased supply.

Background
The U.S. EPA controls the production and use of HCFCs, including the refrigerant R-22, through a cap and trade program. The amount of virgin R-22 that can be produced in a given year is set by annual allocations. The production and use of HCFCs is slowly being phased out in the United States, because these chemicals are known to damage the ozone layer when released into the atmosphere.

In 2011 the EPA was ordered to reopen the 2009 Allocation Rule that set the allocations for the years 2010-2014. The order came from the U.S. Court of Appeals for the District of Columbia Circuit in a lawsuit filed by two gas producers who charged that the EPA had failed to recognize their legally traded allocations.
In August 2011, the EPA proposed to adjust the R-22 allocations in the three remaining years of the 2009 Allocation Rule (2012-2014).

Based on consultation with industry stakeholders, the EPA determined there was an oversupply of virgin R-22 in the marketplace, evident with low demand, increased reuse of R-22, and low wholesale prices. In 2010, R-22 producers only utilized 86% of their allocations. A trade organization representing the manufacturers and importers of R-22 supported these claims, and advocated for a 20% reduction in allocations for 2012-2014.

Since 2012 refrigerant producers and importers have been operating with only temporary, 12 month authority through “No Action Assurance” letters from the EPA. Without a finalized Adjustment Rule, and without the No Action Assurance letters, virgin R-22 could not be legally produced or imported into the United States. The No Action Assurance letter from the EPA advised allocations would be less than the 2009 Allocation Rule.

The 2013 Final Adjustment Rule sets the allocations for the years 2012 (retroactively), 2013, and 2014.
In 2013, the total amount of R-22 allocated to all producers and importers is about 62.8 million pounds, compared with about 55.4 million pounds allocated for 2012. In 2014, the total allocation of R-22 will drop to 51 million pounds.

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.

Low-GWP HFCs

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 R744.com 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.”

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.