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Supermarket Industry Q & A on R-22 Use

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Repair of an Existing R-22 System after January 1, 2010

EPA allows virgin R-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 R-22 system or conversion of that system to an alternative refrigerant. However, EPA is phasing out R-22 (an ozone-depleting substance with a high global warming potential). Therefore, there will be less virgin R-22 produced and imported each year. Supermarket owners should carefully consider all options when deciding whether to service or replace an existing system.

Scenario #1:

A store that was built in 2007 was constructed with an R-22 refrigeration system. That refrigeration system needs its liquid filter drier core replaced as part of normal maintenance to the system. Can virgin R-22 be used to service the system, if needed?

  • Yes. This maintenance work (i.e., servicing) can be carried out with virgin R-22 refrigerant.

Scenario #2:

A store that was built in 2005 was constructed with an R-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 R-22?

  • Yes. The use of virgin R-22 is allowed because a component failure necessitated the repair and subsequent refill of R-22 (i.e., servicing).

Scenario #3:

A service technician discovers a leaking solenoid valve in an R-22 system that was manufactured and installed in 2009. She repairs the valve and sees that the system needs 500 lbs of R-22 refrigerant to get back to its normal operating condition. Can she use virgin R-22?

  • Yes. The use of virgin R-22 is allowed because the R-22 refill was necessary due to a leak, which was then repaired (i.e. servicing).

Manufacture of a New R-22 System after January 1, 2010

EPA does not allow virgin R-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.

Scenario #1:

A contract to build a new grocery store was signed in May, 2010. Can a newly-manufactured R-22 refrigeration system be installed in the new store using virgin R-22?

  • No. Commercial refrigeration systems cannot be installed using virgin R-22 on or after January 1, 2010.

Expansion of an Existing R-22 System after January 1, 2010

In determining whether an expansion of an existing R-22 system results in a newly-manufactured R-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 R-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 R-22 may not be used in a system that has become a newly-manufactured system through an expansion.

Scenario #1:

As part of a store remodel, a company wants to expand an existing R-22 system that had a charge size of 3,000 lbs by adding a new aisle of frozen food cases. After the expansion, the R-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 R-22?

  • 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 R-22 must be used any time refrigerant is added to this system. Therefore, no virgin R-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 R-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 R-22. Any additional recharging of the system must be performed with recovered or reclaimed R-22. Of course, the company may also choose to convert the R-22 system to an acceptable alternative refrigerant during the expansion.

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 R-22 for this?

  • 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 R-22 may be used to service existing systems.