New EPA Refrigerant Regulations for 2019

As you may already be aware, the EPA 608 update, issued in November 2016, updated the existing refrigerant management requirements (i.e., for CFCs and HCFCs) and also extended them to non-exempt substitute refrigerants (e.g., HFCs). The requirements from these new refrigerant regulations affect: Record Keeping, Leak Rate Calculations, Equipment Leak Thresholds, Leak Repair Time Frames, Leak Inspection Requirements, Retrofit & Retirement Timescales, and Chronically Leaking Appliance Reporting. As of January 1, 2019, there are new allowable refrigerant leak rate thresholds for the triggering of leak repair requirements.

If you are a facilities manager responsible for older air conditioning systems, chances are you are alarmed by the news that R22 is being phased out. You’re probably also wondering about the R22 phase out schedule and how quickly you need to act. The remaining R22 phase out schedule in the United States (as per the EPA final rule) is as follows:

  • January 1, 2019 – R22 production drops 55% from 2018 supply to 4 million pounds.
  • January 1, 2020 – R22 phased out completelyno new or imported R22 allowed in U.S.

 

So what does this R22 phase out schedule mean for you? Each time supply is reduced, R22 prices (and repair prices) will rise. Come January 2020 when “virgin” R22 is phased out completely, it will not be legally available at any price. That could mean your old equipment can no longer be repaired and you’ll be forced to replace it the next time it breaks down. For businesses that may have many pieces of air conditioning equipment, the fact that R22 is being phased out means you have to take a hard look at your equipment and your budget. And you’ll need to decide on your comfort level with risk.

So What Can You Do?

  • Do nothing now and wait for the inevitable breakdown of each unitThe closer we get to 2020, there will be a lot of equipment owners in the same boat as you, all needing their systems replaced. Ever needed a repair during an August heat wave? This situation will likely be a whole lot worse. When your system finally breaks and you need an emergency replacement, you could be without A/C for some time while you wait for installation availability.
  • Retrofit your older systems to use a new refrigerantIn some cases, you can invest in a retrofit or conversion that allows your older system to use certain newer refrigerants. That option won’t be possible for all systems, so you’ll need to do an inspection to determine if it might work for you. Options include: NU22, R421A and R407C.

 

Those in charge of older air conditioning equipment have a decision to make before R22 is phased out. Here are a few recommendations that can help:

  1. Consider the impact on your business of being without air conditioning – As mentioned earlier, the longer you wait to replace, the longer you may have to wait for that replacement installation to be done. How will your business function in the meantime? Is it a risk you’re willing to take until R22 is phased out and your hand is forced?
  2. Factor in energy savings – When figuring out the cost of replacement, don’t forget that installing newer, more efficient systems can result in big reductions in energy expenses. Those savings can add up faster than you may think.
  3. Consider your longer-term need for the equipment – In some situations it may make sense to wait. For example, if you are closing a location or moving to a new location soon and the old equipment will no longer be your problem. However, don’t forget to check out the equipment you’ll be getting in your new space!
  4. Consider retrofit as a short-term solution – A retrofit can be a solution that can help you buy time until you’re ready to invest in an expensive replacement. Since there are technical limitations, you’ll need an HVAC expert to inspect and tell you if it’s a viable option for your equipment.
  5. Plan for replacement to spread out the cost – If you’ve got a lot of equipment to replace, you should work to prioritize and come up with a plan to replace equipment over time before R22 is phased out. This strategy will help to minimize your risk and manage the cost in a way that doesn’t break your budget.

Leave a Reply

Your email address will not be published. Required fields are marked *