R-22 Phase Out Begins in U.S.

The recently issued U.S. government schedule for the phase out of R-22 is set to create opportunities for both the providers of natural refrigerants and for the developers of small charge technologies.

Those opportunities will become available as end users see “natural refrigerants as a more stable refrigerant choice for the future,” said Lowell Randel, IIAR’s Director of Government Relations.

Fostering the growth of those opportunities is the Environmental Protection Agency’s regulation that is steering the nation away from R-22.

That rule is designed to end R-22 use within the United States as quickly as possible, while providing industry some time to make the transition, he said.

R-22 is a hydrochlorofluorocarbon (HCFC)-22 that has been used as a refrigerant because it has a relatively low ozone depletion potential, but now, even HCFs with low ozone depletion potentials are being banned under the Montreal Protocol, which seeks to protect the ozone layer by phasing out the production of substances responsible for ozone depletion, as well as those that have high global warming potential.

R-22 is a greenhouse gas that has a global warming potential 1,810 times as powerful as carbon dioxide.

As directed by the Montreal Protocol, in October 2014, the EPA issued its final rule —Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import and Export, 2015- 2019 — that schedules the phase out of HCFC-22, which is mostly R-22.

The EPA developed the schedule for the phase out of R-22 in accordance with the Montreal treaty and the Clean Air Act, said Randel.

Once the EPA determined a baseline production level, the agency developed the schedule for the reduction of allowable amounts of R-22 that can be produced or imported from 2014 to 2020, so that by 2020, HCFC use is projected to decline by 99.5 percent below the baseline level.

Under the schedule, for 2015, the rule caps the production and import of R-22 at about 22 million pounds, which is a 29 million pound reduction from the 51 million pounds allowed in 2014.

For 2016, the cap is set at 18 million pounds of R-22; for 2017, 13 million pounds; for 2018, 9 million pounds; for 2019, 4 million pounds; and by 2020, the production and importation of R-22 is ended, according to the schedule.

The EPA’s phase out of R-22 is an aggressive schedule, and industry might find it to be more aggressive than expected, “but at this point, everyone knows that this is moving forward, so they are going to have to make their transition plans to match the schedule,” Randel said.

The rule does allow for the use of reclaimed R-22, but even that can become problematic as far as supply goes, according to Randel. R-22 that meets the reclamation standard can be recycled and reused, so it will remain an option, but limited supplies will increase its cost, he said.

Eventually, organizations are going to have to make decisions on which refrigerant they use for the longer term, and that is where the opportunity exists for the producers of natural refrigerants.

“If you’re in the ammonia or CO2 business, you can expect that some of the organizations that are transitioning away from R-22 are going to make the leap to natural refrigerants,” he said.

Such decisions by organizations become more likely as the trend grows in Europe to move away from HFCs. And the EPA has indicated that the U.S. is probably going to phase out the use of such HFCs as well.

While organizations will be aware that HFCs are likely to be banned in U.S., they will also be aware that the EPA is not going to ban ammonia or CO2 .

“From a policy perspective, organizations are going to end up saying natural is the more stable refrigerant,” Randel said.

The levels of how much ammonia or CO2 will be used in an organization’s refrigeration system will be determined by how large those refrigeration operations are, said Randel. In addition, because regulations for the safe use of ammonia such as the EPA’s Risk Management Program and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management are imposed on larger systems with over 10,000 pounds of ammonia, smaller charge systems that avoid those regulations are likely to become attractive to users, and that creates opportunities for those technologies.

The technologies that have been developed over the last few years make it possible for organizations to use smaller charges of ammonia and still maintain the level of refrigeration that is needed by a facility, he said.