Commercial Refrigeration and Air Conditioning Equipment: Frequently Asked Questions
Q. Am I allowed to continue using equipment that contains hydrochlorofluorocarbon HCFC-22 (also known as R-22)?
A. Yes.
Q. If I expand an existing HCFC-22 system can I continue to use virgin HCFC-22?
A. No. Virgin HCFC-22 may not be used in a system that is expanded to increase its cooling capacity. EPA presumes expanded systems to be new systems, and new systems may not use virgin HCFC-22 (or R-22). Only reclaimed or recovered HCFC-22, or an alternative refrigerant, may be used.
More on this concept is covered in a Q & A developed for supermarkets.
Q. How can I ensure that HCFC-22 supplies will be adequate to meet my future needs?
A. Establish a plan for your company to repair or replace leaking equipment and to recover and reuse the refrigerant from equipment that is discarded. Your company can store recovered HCFC-22 to service any equipment you own.
Reclaimed refrigerant also is available and may continue to be used after the production and import phaseout in 2020. Both new and reclaimed HCFC-22 is likely to increase in price, however, as existing supplies are used up.
Q. When should I convert my company's equipment to an alternative refrigerant?
A. Many businesses have already transitioned to alternative refrigerants.
Even though there is no immediate need to change, HCFC-22 supply will decline and prices may rise. When you transition, you have three choices: (1) convert your existing system, (2) buy a new one, or (3) continue to operate your existing system. If you choose to convert, confirm with your equipment supplier that the system is retrofitted to use an ozone-friendly, SNAP-approved refrigerant, and that all system components are compatible with the new refrigerant. Buying a new, more efficient system may require more money initially, but may reduce your electricity bill and save money over time. If you choose to continue to operate your existing system, be sure to identify and repair leaks quickly.
Supermarket Industry Q & A on HCFC-22 Use
Repair of an Existing HCFC-22 (also known as R-22) System after January 1, 2010
EPA allows virgin HCFC-22 to be used for the servicing (maintenance and repair) of systems that were manufactured before 2010, referred to as “existing systems.” EPA does not require replacement of an existing HCFC-22 system or conversion of that system to an alternative refrigerant. However, HCFC-22 (an ozone-depleting substance) was phased out in the United States as of January 1, 2020. HCFC-22 that has been recovered and reclaimed is still available and legal to use. Supermarket owners should carefully consider all options when deciding whether to service or replace an existing system.
Q. Scenario #1: A store that was built in 2007 was constructed with a HCFC-22 refrigeration system. That refrigeration system needs its liquid filter drier core replaced as part of normal maintenance to the system. Can virgin HCFC-22 be used to service the system, if needed?
A. Yes. This maintenance work (i.e., servicing) can be carried out with virgin HCFC-22 refrigerant.
Q. Scenario #2: A store that was built in 2005 was constructed with a HCFC-22 refrigeration system. The discharge line on a compressor breaks, and the result is a major loss of refrigerant charge. Once the repair is carried out, can the system be filled with virgin HCFC-22?
A. Yes. The use of virgin HCFC-22 is allowed because a component failure necessitated the repair and subsequent refill of HCFC-22 (i.e., servicing).
Q. Scenario #3: A service technician discovers a leaking solenoid valve in a HCFC-22 system that was manufactured and installed in 2009. She repairs the valve and sees that the system needs 500 lbs of HCFC-22 refrigerant to get back to its normal operating condition. Can she use virgin HCFC-22?
A. Yes. The use of virgin HCFC-22 is allowed because the HCFC-22 refill was necessary due to a leak, which was then repaired (i.e. servicing).
Manufacture of a New HCFC-22 System after January 1, 2010
EPA does not allow virgin HCFC-22 to be used in refrigeration systems manufactured on or after January 1, 2010. A refrigeration system is “manufactured” on the date its refrigerant circuit is complete and it can function, holds a refrigerant charge, and is ready for use for its intended purpose.
Q. Scenario #1: A contract to build a new grocery store was signed. Can a newly-manufactured HCFC-22 refrigeration system be installed in the new store using virgin HCFC-22?
A. No. As of January 1, 2010, commercial refrigeration systems cannot be installed using virgin HCFC-22.
Expansion of an Existing HCFC-22 System after January 1, 2010
In determining whether an expansion of an existing HCFC-22 system results in a newly-manufactured HCFC-22 system, EPA considers whether the existing system was “ready for use for its intended purpose” prior to the expansion. If there is sufficient cooling capacity within the system to support the expansion (e.g., new display cases), then the store is not changing the intended purpose of the system, and may use virgin HCFC-22 after the modification/remodel. But, if the expansion includes an increase in cooling capacity, then EPA will presume that the system’s purpose is changing and a new system is being manufactured, unless the store can show that the intended purpose of the system has not changed. Also, an increase in charge size by itself does not necessarily indicate that the intended purpose of the system is changing, though an increase in cooling capacity (i.e., expansion) may often be accompanied by an increase in charge size. Virgin HCFC-22 may not be used in a system that has become a newly-manufactured system through an expansion after January 1, 2010.
Q. Scenario #1: As part of a store remodel, a company wants to expand an existing HCFC-22 system that had a charge size of 3,000 lbs by adding a new aisle of frozen food cases. After the expansion, the HCFC-22 system would need 3,500 lbs of refrigerant to operate properly. The system’s cooling capacity will increase by 20 tons. What part of the total charge, if any, can be virgin HCFC-22?
A. Probably none. Given the increase in cooling capacity associated with this expansion, EPA would presume that the existing system’s capacity was insufficient for the intended purpose of chilling the new aisle of frozen food cases. While the increase in charge size alone is not determinative, it is likely that the increase was required due to the increased capacity of the entire system. This remodel is not servicing. Recovered or reclaimed HCFC-22 must be used any time refrigerant is added to this system. Therefore, no virgin HCFC-22 may be used for the remainder of the life of the system. The 3,000 lbs contained in the system prior to the remodel can be recovered and reused, but the additional 500 lbs of HCFC-22 must not be virgin refrigerant. Instead, the 500 pounds could be recovered from the owner’s other equipment and reused for the expansion, or it may be reclaimed HCFC-22. Any additional recharging of the system must be performed with recovered or reclaimed HCFC-22. The company may also choose to convert the HCFC-22 system to an acceptable alternative refrigerant during the expansion.
Q. Scenario #2: A supermarket adds floor space by buying the restaurant next door. During a remodel, the store wants to move the front entrance and produce department to the added floor space, and sell more general merchandise where the produce used to be. Although no new refrigeration load is added, the additional pipe work to reach the new produce department will require additional refrigerant. Can the store add virgin HCFC-22 for this?
A. Yes, assuming the overall cooling capacity of the system is not increased, EPA considers this servicing of an existing appliance. The intended purpose of the system has not changed. Virgin HCFC-22 may be used to service existing systems.
Note that this guidance is relevant for systems containing HCFC-22 or other ozone-depleting refrigerants. For information on systems using hydrofluorocarbon refrigerants (e.g., R-404A), please review the Technology Transitions requirements under the American Innovation and Manufacturing (AIM) Act.