Stay Away from Unapproved Flammable R22 Substitutes

At the risk of sounding like a broken record, I am once again talking about the dangers of unapproved, highly flammable R22 substitute refrigerants which are still easily available over the internet to anyone who wants to buy them. A quick Google search for R22 replacement refrigerant will list several places to buy these dangerous mixtures. The manufacturers market these under a variety of names. The EPA has listed many of them as specifically NOT approved for use. They include refrigerant products sold under the names R-22a, 22a, Blue Sky 22a refrigerant, Coolant Express 22a, DURACOOL-22a, EC-22, Ecofreeez EF- 22a, Envirosafe 22a, ES-22a, Frost 22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, Priority Cool, and RED TEK 22a. The main component of all of these is propane.
 
It is true that the EPA has approved some flammable refrigerants for use in new systems with  lot of restrictions. However, the allowed use is for small refrigerators. The total allowable amount is very small, the systems must be new and specifically designed for flammable refrigerant. Refrigeration systems designed for flammable refrigerant meet strict safety standards, including non-sparking controls and labeling.  Class 3 flammable refrigerants are specifically NOT approved for use as a retrofit refrigerant for R22, or any other system designed for non-flammable refrigerant.

Every time a contactor or relay opens or closes they make a spark which is hot enough to ignite a flammable gas. If someone is losing refrigerant, their system has a leak. Continuing to add a flammable refrigerant on top of R22 will eventually create a flammable mixture. More worrying is that the flammable mixture will be leaking out somewhere.

As a practical matter, most recovery units are not designed to handle flammable refrigerants. Master Cool has just come out with one that is  specifically designed to safely handle flammable refrigerant. Even if you did not use any flammable refrigerant, are you certain that someone before did not add one of these flammable substitutes?

Here is a copy of some of the text from the EPA ruling

“ For retrofit residential and light commercial AC and heat pumps— unitary split AC systems and heat pumps, EPA is listing as unacceptable, as of January 3, 2017:
• All refrigerants identified as flammability Class 3 in American National Standards Institute (ANSI)/ American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 34–2013; and
• All refrigerants meeting the criteria for flammability Class 3 in ANSI/ ASHRAE Standard 34–2013. These include, but are not limited to, refrigerant products sold under the names R-22a, 22a, Blue Sky 22a refrigerant, Coolant Express 22a, DURACOOL-22a, EC-22, Ecofreeez EF- 22a, Envirosafe 22a, ES-22a, Frost 22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, Priority Cool, and RED TEK 22a. “

Here is a link to the EPA ruling banning flammable refrigerant as a retrofit refrigerant. https://www.gpo.gov/fdsys/pkg/FR-2016-12-01/pdf/2016-25167.pdf

Refrigerant Don'ts

With summer now upon us and the price of R22 skyrocketing there are many questions regarding replacement refrigerants. This discussion could fill a book, so I am going to restrict this post to a list of don'ts. The intent is to help people avoid issues that can be caused by improper application of 400 series R22 replacements.

Do NOT use a flammable replacement refrigerant in ANY system originally designed for R22. There are some hydrocarbon (propane) based replacement refrigerants sold online. They are NOT EPA approved and represent an explosive hazard when charged into a system that was not designed for flammable refrigerant.

Do NOT add ANY replacement refrigerant on top of an existing R22 charge. This is an EPA violation. You are essentially creating a “new” refrigerant which has not been tested or approved. There are NO replacement refrigerants which are legal to add in on top of an existing R22 charge. You must first remove ALL of the R22 when doing a conversion.

Do NOT use ANY 400 series refrigerant in a flooded system. Even refrigerants which are advertised to work in systems with mineral oil will still separate in the flooded portions of the system because they are not truly miscible. There is a difference between miscibility and solubility, but that is the subject for another whole article.

Do NOT use ANY replacement refrigerants in ANY system using an electronic expansion valve. This would primarily be older R22 minisplits, multisplits, and VRF systems. Trane hyperion heat pumps can sometimes have an R22 charge. In that specific case, the indoor air handler is designed for both R22 or R410A, so switching to R410A and changing the refrigerant dip switch solves that problem for the indoor air handler. Unfortunately, you will still have to replace the outdoor unit with one designed for R410A.

Do NOT use ANY 400 series replacement refrigerant in systems which were originally designed for R22 and have Trane 3D Scroll compressors. The lubrication system that specific compressor design uses does not work well with HFC refrigerants, including ones advertised as being compatible with mineral oil.

This all come down to one main strategy for replacing R22 in most older systems: it is generally best to replace the whole system. Not only does this avoid application problems, it usually provides a significant efficiency upgrade as well.

EPA Warns of Flammable Replacement Refrigerants

As the summer cooling season gets under way it is a good time to reiterate that flammable refrigerants should NOT be used as replacement for R-22 in existing systems. Some people are putting in R-290, which is simply propane.  A few have tried charging their systems with fuel grade propane. Not only is this dangerous, but fuel grade propane has lots of water contaminants and will screw up your systems, that is if it does not blow up. Yes, it is true that the EPA approved flammable refrigerants for a few very specific uses in systems with a very limited charge. However, these are NEW SYSTEMS ONLY! These systems are designed from the outset to handle a flammable refrigerant.

Your R-22 air conditioner of heat pump has many spark creating controls, such as relays and contactors. A leaky system recharged with a flammable refrigerant could have all the components for an explosion: fuel, oxygen, and an ignition source. The EPA has started fining companies for selling non-approved, propane based R-22 replacement refrigerants. Most have “22a” in their name. Unfortunately, there are still plenty of places to buy this stuff over the internet. A few other names include “Frosty Cool” and Eco-Freeze”. You should be wary of anyone that sells refrigerant directly to consumers over the internet.

I don’t believe regular HVACR wholesalers will have any of this stuff, and major refrigerant companies such as Honeywell, DuPont, or Arkema are not selling it either. They do each offer their own R-22 replacement solutions, none of which are flammable. Some legal replacement solutions have very small percentages of hydrocarbon components to improve oil return. Their hydrocarbon components are in such small quantities that they generally pose no threat of flammability. So what is the best thing to put in an R-22 system? R-22. Read more about the EPA actions and warnings here.

EPA Announces R-22 Allocations for 2015 - 2020

The EPA has released their R-22 allocations for 2015 – 2020, and it looks like the days of free-flowing R-22 are about to come to an abrupt end. To put things in perspective, the R-22 allocation for this current year, 2014, was 51 million pounds. The allocation for 2015, coming up in a few months, is 22 million pounds. That is just over 43% of the 2014 allocation. From there the cutbacks are more gradual with a reduction of approximately 4 million pounds each year until 2020 when the allocation is 0. Trying to figure out R-22 prices has been a bit difficult these last few years. They have spiked twice but then gone back down as supply increased. This time look for the high prices to last  because there will be no turning the tap back on this time. The main question remaining is how long demand for R-22 will continue. Although there is still a very large installed base of R-22 air conditioning equipment, it is starting to get old. As older equipment fails and supplies tighten, it will be increasingly difficult financially to keep an older R-22 system operating. I remember with R-12 and other CFCs, prices climbed high enough to kill demand. A local wholesaler took a bath on a large quantity of 502 just to get rid of it because nobody wanted it at the “market” price. Consider that a dry ship unit costs about the same as a 410A builder grade, but you still have to buy the refrigerant. It is conceivable that a dry ship unit charged with R-22 at inflated prices would be as expensive as replacing both the condenser and evaporator with a builder grade 410A system. Who would want to keep their old system if it costs as much as a system with current technology, higher efficiency, and a refrigerant that is still available? To read more about the EPA's ruling, check out

https://www.federalregister.gov/articles/2014/10/28/2014-25374/protection-of-stratospheric-ozone-adjustments-to-the-allowance-system-for-controlling-hcfc

Substitute Refrigerant Safety

As R22 prices increase and R22 availability decreases, many technicians have at least thought about using a substitute refrigerant in place of R22. Usually, we are looking for a drop-in which can be used to charge a system instead of R22. My primary consideration is safety. Of course I want any substitute refrigerant to work well and be environmentally friendly, but most of all, I want it to not hurt me or my customers. The refrigerant manufacturer should be able to show that their refrigerant is listed on the EPA SNAP list of acceptable replacement refrigerants. If they can’t, I would not use it. Another source of safety information is the required MSDS sheet. Any chemical sold in the United States must have an MSDS sheet. If the seller cannot provide an MSDS sheet, I would not consider using the refrigerant. The MSDS sheet will list important information such as toxicity and flammability. One replacement refrigerant that is advertised on the internet has enough information on the MSDS sheet to let me know I don’t want any part of it. The proper shipping name is “Petroleum Gasses Liquified.” Other statements include “Vapor may ignite if exposed to static discharge", and "Flammable vapor may form if allowed to mix with air. Accumulation of gas is an ignition hazard. Vapors are heavier than air and may travel to an ignition source." R22 systems are not built to operate safely with a flammable refrigerant. There is no way I would put this in a system designed for R22. Last year technicians were killed while working on refrigerated shipping containers that exploded.(See post about it). They were R22 systems which had been charged with a flammable substitute refrigerant. Although the EPA has recently approved the use of flammable refrigerant in limited charge applications, it is important to note that there are many requirements a system must meet to be safe with flammable refrigerants. R22 systems meet none of these. For more information on flammable refrigerants, take a look at my previous post on Flammable Refrigerants. For more information on R22, take a look at my previous post on R22 Conversion. A couple of simple rules to follow will help keep you safe. Can you buy the refrigerant at your local wholesaler? If you can only get it over the internet or from a guy at a flea market, you don’t want it. Is the refrigerant listed on the EPA SNAP list for the specific application? If not, you don’t want it. Does it seem too good to be true? If so, you probably should avoid it like the plague.

Dry R22 Units

I got my first look at a “dry” unit the other day. A wholesale house had one on its showroom floor with a big sign “we have dry units!” I looked at the nameplate to see what it said about refrigerant. A refrigerant amount was actually listed. Instead of the familiar “factory charge” preceding the refrigerant quantity, it had “Field Charge” and then the amount. I asked about coil matching for older systems. They recommend 1/2 ton smaller condenser than the original for heat pumps and the same size condenser for air conditioning. Then I asked about warranty and they said the units came with a 5 year compressor warranty regardless of the coil connected to it. They pointed out that this was less than the warranty on new matched equipment. Many of the units are being sold to replace condensing units that have been stolen or chopped up in place, often in rental property. Another wholesaler requires you to take coil measurements and then uses software to try and figure out the coil SEER. If the calculated SEER is less than 13, they recommend against buying the dry unit. Companies that just a few years ago were cautioning against the perils of mismatches units are now selling units that will almost certainly be mismatched. They cannot provide any meaningful charging chart without knowing what coil is on the other end of the system.  

If you do decide to install a “dry’ unit, make sure and follow good refrigeration system installation practices. The fact that you are creating your own special blend of equipment makes it all the more important to be careful, not careless. It would be wise to treat the job like a compressor burnout. Flush the lines and coil, install a filter drier, pull a good vacuum, and weigh in the charge using an accurate digital scale. You can see more about line flushing at Mainstream Engineering. They sell a flush designed for this type of use. You will need to adjust the data plate charge for line length and possibly coil mismatch, but the nameplate charge should be in the ballpark unless you have very long lines. I think it might be wise to start a little under, so I would not adjust for line length until after starting the unit.  I found a good set of instructions for installing dry systems online provided by Century, a supplier that is offering dry units. No, these are NOT the folks who suggested the 1/2 under ton heat pump coil adjustment. The link to the guide is:

http://www.centuryac.com/DryChargeInstructionsandchart.pdf

All I Want for Christmas is a Final Rule

The EPA has released a new final ruling on HCFC reduction for Christmas! I know you are probably thinking that is not much of a Christmas present, but it really is. First, the HCFC allocations were due to expire, so without a new ruling spelling out HCFC allocations, all R-22 manufacturing and importing would have ceased January 1, 2010. A new ruling setting allocations of HCFCs has been released, fixing this potential train wreck. You can download a copy of the ruling and read all the details on the EPA website

Next, the details of exactly when you may and may not install “new” equipment which uses HCFC refrigerant have been clarified. You may recall that last December the EPA shocked our industry by announcing that they considered systems which are field installed and charged to be “manufactured” when the refrigeration system was complete and the final charge added. For split systems, this would be when the system is installed. Most people in our industry were well aware of the manufacturing cutoff of January 1, 2010, but we assumed the more common definition of manufacturing date: when the equipment is made in the factory. The EPA is sticking with their definition of manufacturing, but that does not mean all R-22 inventory becomes rubbish on January 1, 2010. Packaged equipment like window units, PTACS, and packaged air conditioning equipment can all be legally sold and installed as new provided it is manufactured (in the factory) prior to January 1, 2010. You are allowed to sell and install pre-charged R-22 component parts made before January 1, 2010 to replace parts in existing systems. So you may swap out condensing units, evaporator coils, or even both in an existing system. Replacing both the condensing unit and evaporator coil on an existing system is legal. Another interesting twist is that manufacturers may ship component system parts with a nitrogen holding charge instead of refrigerant. These “dry” components can then legally be assembled into a new system provided the system is then charged with reclaimed refrigerant and not virgin refrigerant. The impact of these regulations will be minimized by the fact that most manufacturers reduced or eliminated their R-22 equipment manufacturing the past few years. Contractors have also widely accepted R-410A and few still install new R-22 systems now. R-22 production will be reduced to 41.9% of the baseline production, but that will probably be enough. With no manufacturers using it and no new systems being installed, I believe that R-22 will still be available for servicing existing systems.

I do not believe replacing an existing R-22 system with a new R-22 system is really in the customer’s best interest. Why would someone want a system that uses a refrigerant which is scheduled for extinction? Also, all new high efficiency equipment uses HFC refrigerant, not R-22. We still need R-22 equipment in schools simply because our students need to know how to work on it. You cannot assume that every call will be on a system with the latest technology. In fact, you can almost assume the opposite. Our students will continue to see R-22, so we need to teach it. However, we need to teach toward the future and not stay stuck in the past. Your lab should have many pieces of equipment with HFC refrigerant, like R-410A. You should have recovery equipment and gauges manufactured specifically for R-410A. Your texts, manufacturer’s literature, and technical literature should all support the newer refrigerants. One of our focuses in Fundamentals of HVAC/R is support for new refrigerants such as R-410A. The newer refrigerants are not only covered in the refrigerants section, but throughout the book with detailed examples using R-410A. You can learn more about Fundamentals of HVAC/R at Pearson’s site.

R22 Phase Out

If you are at all involved in the HVAC/R trade, you know that new equipment may not be manufactured or imported beginning January 1, 2010. This imminent date has most of us at least a little apprehensive about the future. Right now, all the details and rules have not been firmly established. In most people’s minds, the date a unit is “manufactured” is when it is made in the factory. The EPA has proposed a rule change that would set the date of “manufacture” as the date of final charge. For split systems, this would be when the unit is installed. Adopting this rule change would effectively mean that R-22 split systems could not be installed beginning January 1, 2010. This would make inventory of existing R-22 systems essentially worthless on January 1, 2010.

AHRI has launched a site dedicated to monitoring the issues regarding the HCFC phase out and passing on information to the industry: www.phaseoutfacts.org.

Another good web site to keep an eye on is the EPA site devoted to the HCFC phase out: www.epa.gov/ozone/title6/phaseout/hcfcfaqs.html

Although R-22 will continue to be available for servicing existing systems, the amount of new R-22 available will be substantially less than is available this year, see EPA web site for details
www.epa.gov/ozone/title6/phaseout/hcfc.html

R-22 systems will still be with us for some time since the majority of the current installed base of air conditioning systems use R-22. However, R-22 systems represent the past; R-410A air conditioning systems represent the future. All HVAC/R training labs should have a full complement of R-410A systems. We need to prepare our students for the future, not the past. The training materials you use should support training using the refrigerants of the future, including R-410A. Fundamentals of HVAC/R includes extensive coverage of R-410A. We don’t just talk about R-410A in Unit 23 Refrigerants and Their Properties, but throughout the book whenever specific refrigerant pressures and temperatures are mentioned in examples. In Unit 17 Refrigeration System Components and Operation, the refrigeration cycle diagram uses R-410A as the refrigerant. Unit 27 Refrigerant System Evacuation and Charging uses R-410A for many specific examples of charging charts and operating specifications. Specific details of handling zeotropic refrigerants like R-410A are given in Unit 26 Refrigerant Management and the EPA. In all, 14 units have specific examples of working with and using R-410A refrigerant. R-22 has certainly not been left out. There are still plenty of examples and details using R-22. After all, we will be working on R-22 systems for several years to come. If you have not already moved towards incorporating R-410 your curriculum, now is the time to take the first step. If you are looking for materials that will help your students meet the challenges of the future, please take a look at Fundamentals of HVAC/R.