Today, continuing our series of more in-depth blog articles, we shall be following up on our post of March 2013 and examining the recent legislative changes governing the use of R22 refrigerant gas in air conditioning systems.
We’ll be looking in detail at just how these changes could affect your business or property, and exploring the solutions that are currently available to ensure that you are meeting your legal requirements in operating air conditioning equipment in 2015.
With the new R22 legislation in force from 1st January 2015 affecting an estimated 750,000* businesses in the UK alone, it is of the utmost importance to understand the exact scope of this and to be able to plan effectively and immediately a coping strategy should you be affected by it.
In order to best help you do this, we’ve therefore broken down this article as a whole into 4 helpful sections in which we’ll be:
- Clarifying the legislation surrounding the use of refrigerants
- Highlighting the potential impact that the R22 ban will have on your business or property
- Explaining why simply ‘doing nothing’ is no longer a viable option
- Proposing a range of cost-effective solutions and outlining the pros and cons of each of these
Background to R22 phase-out – What is R22 and why is it now being banned?
In this section, we’ll be explaining what R22 is exactly and reviewing the legislation governing its usage to date.
Put in its simplest terms, R22 is a refrigerant which has common usage in air conditioning, process chiller and industrial refrigeration plant applications.
It belongs to a group of substances known as hydrochlorofluorocarbons (HCFCs).
As such, it has an ozone depletion potential, meaning that it can harm the environment if allowed to leak into the atmosphere, and is covered by the Montreal Protocol on Substances that Deplete the Ozone Layer and, by extension, the EC Ozone Regulation (No. 1005/2009).
With legislation providing for a strict timetable according to which the production of all Ozone Depleting Substances (ODS) such as R22 refrigerant needed to be phased out and eventually eliminated, the following milestones have now passed:
- Since 31st December 2000, the use of R22 refrigerant in new air conditioning equipment has been banned
- Since 31st December 2009, the use of virgin R22 refrigerant for servicing and maintenance has been banned
- Since 31st December 2014, there is a total ban on all recycled and reclaimed R22 thereby making the top-up of any systems using it illegal and, consequently, making the service and maintenance of such systems nigh-on impossible
Furthermore, it has been mandated that provision should be made to prevent leakages of R22 from currently operational air conditioning systems using it, under Section 608 of the Clean Air Act (which is implemented by the Environmental Protection Agency).
How exactly could the R22 ban affect my business?
Let’s consider again at this point precisely what this ban entails – all operators of processes or air conditioning systems that use R22 refrigerant need to be aware that virgin, recycled and reclaimed R22 will not be available or permitted from 1st January 2015, which will make it increasingly impossible to maintain associated equipment effectively.
Such a ban therefore represents a very real threat to any business which uses R22 in any of these systems.
R22 remains one of the most commonly used refrigerants in the UK meaning that the effects of the ban will be far-reaching and its consequences felt by many organisations nationwide across a broad spectrum of industry sectors; affecting many different types of building air conditioning.
Many of these applications can be considered to be of critical importance to the continued operation of their owner’s business and, as such, the need to address the ban of R22 has been brought into sharp focus.
Of course, although the thought of zero capital outlay remains appealing for many, the simple fact is that attempting to ‘soldier on’ with existing R22 equipment will prove detrimental to any business over time.
This is the driving force behind what many in the air conditioning industry are dubbing ‘the case to replace’.
One thing remains certain though – any affected business simply cannot afford to ‘do nothing’.
R22: The case to replace – Why simply ‘doing nothing’ is no longer an option
Typically, it is considered within the industry that quality, well-maintained air conditioning equipment has a lifespan of around 10-15 years.
Given that new equipment using HCFC refrigerants such as R22 was banned in 2001 (or 2004 for smaller air conditioning systems) this effectively means that any R22 equipment is now, or shortly will be, within its end-of-life risk zone.
Of course, it may seem more cost-effective to attempt to avoid any equipment replacement until it becomes essential, but this ‘do nothing’ approach does come with several risks attached, such as:
- Failure of old equipment could leave you without cooling or heating and lead to unplanned downtime for your business
- Spare parts for older equipment are likely to be more expensive or even no longer available, forcing an unplanned system replacement
- Inflated maintenance costs and energy bills
With these risks in mind, there is a lot to be said for taking a planned approach to replacement; also meaning that you could be considering other ways of improving the energy efficiency of your business as part of the process.
Consider this, for example: It has been estimated that a 15-year-old air conditioning system has typically lost 15% of its capacity and consumes 15% more energy (to provide that capacity) than when new**. This leads to an increase in running costs and CO2 emissions and, depending on how the building’s use may have evolved, the system may no longer be able to deliver the capacity required.
This lends increasing weight to the argument for a complete system overhaul in the face of the R22 ban, although there are other options available.
So, let’s move on to outlining some possible R22 phase-out solutions, and to the different criteria that need to be assessed when considering each of these.
R22 phase-out solutions
A planned approach to the challenges posed by the R22 ban is key and there may well be many factors influencing any given business to opt for one solution in particular.
Careful planning can ensure that the operational impact of any downtime for your systems is minimised, and that an installation schedule can be phased to suit your requirements.
The first step in formulating an ongoing strategy lies in identifying all affected systems using R22, and then assessing each one against decision criteria in order to assign one of three main phase-out solutions. These are:
Some older systems, including those that are in a state of poor repair, operating inefficiently or failing to meet their current (or forecast) cooling load, should be replaced with new systems using a non-ODS (ozone depleting substance) and legally-compliant refrigerant. This will involve a total system replacement including wiring and controls.
A replacement system can include hydroflurocarbons (HFCs), which must comply with the EU F-Gas Regulations, or a ‘natural’ refrigerant like hydrocarbons.
Pro: This option has a number of benefits, not least the opportunity to significantly improve energy efficiency. Hand-in-hand with this improvement, savings on running costs can be substantial. Indeed, Mitsubishi Electric have stated that a reduction of up to 65%*** is possible in this respect.
Furthermore, any new equipment installed will be provide under warranty. Here at Quantech, our working relationships with all the major air conditioning manufacturers allow us to offer, in many cases, free extended warranties of up to 5 years, for example, subject to regular maintenance.
This will give you peace of mind and guarantee trouble-free operation, as well as ensuring a degree of ‘payback’ based on the energy cost savings you will gain from newer equipment.
Con: Of course, the downside to a complete system overhaul is, however, that it will be the most expensive option in terms of up-front cost.
This solution is recommended over and above any other (even given the high initial capital outlay).
Not only will the installation of a new air conditioning system maximise potential ongoing energy savings, but it will also offer the security of hassle-free operation, under warranty, of all your new equipment.
For those air conditioning and refrigeration systems assessed as being in good working order, a conversion solution may be possible.
A conversion solution can take many forms, from a ‘retrofill’ operation (using one of the ‘service’ or ‘drop-in’ HFC refrigerants that are compatible with the existing system) to a more comprehensive modification to the existing system to use a standard HFC refrigerant.
In the case of system modification to using a standard HFC refrigerant, it is also worth bearing in mind that this may well require a new type of oil at least, and possibly additional compressor and/or heat exchanger capacity.
Pro: In adopting a conversion solution, up-front costs are much smaller versus the installation of completely new equipment. In the case of system modification, a variety of R22 replacement technologies allow the re-use of pipework to minimise the costs of replacement and disruption to the customers’ business. This allows for the replacement of outdoor units, or both outdoor and indoor units, but retains existing pipework.
Con: It should be noted that a converted system may operate with a lesser cooling capacity and, as a result, possibly be less efficient than the original system. It is also vitally important to ensure that refrigerant leakage does not get worse after the conversion, a process which carries with it its own associated expense.
It must also be pointed out that manufacturers themselves do not endorse the use of ‘drop-in’ refrigerants which as yet are untested in terms of their reliability. As such, we do not recommended this option.
This is not a ‘do nothing’ option, and is only applicable if:
The system represents no business-critical risk.
This may be appropriate, for example, to a small non-critical split air conditioning system in an office. Although much R22 equipment can be considered to be coming to the end of its useful life, this particular type of system may continue to operate without trouble for some time.
It could also be replaced relatively quickly and cheaply with a new system using a newer, legally-compliant refrigerant should it fail.
Pro: No up-front costs are associated with this particular solution.
Con: Manufacturers have said they will continue to supply spare parts for systems originally sold as R22, as legislation relates to the gas itself, not the equipment using it. Our experience, however, is already that a number of R22 units are no longer being supported by manufacturers with spare parts, and this is especially true with the older ranges of equipment, and with certain manufacturers compared to others.
It is also worth bearing in mind that if you continue to use refrigeration or air conditioning equipment containing R22, you must take measures to prevent any leakage of this from the system, through a programme of regular equipment maintenance.
Legislation requires that a suitably-qualified technician must check your equipment for leaks:
- every 12 months if it’s charged with (contains) 3kg or more HCFCs and isn’t hermetically sealed
- every 12 months if it’s charged with 6kg or more HCFCs and is hermetically sealed
- every 6 months if it’s charged with 30kg or more HCFCs
- every 3 months, if it’s charged with 300kg or more HCFCs
HCFCs are hermetically sealed in equipment if any part of the product that contains HCFCs is permanently sealed shut. Most commercial and industrial refrigeration and air conditioning systems are not hermetically sealed though.
Under terms of law, any leaks must be repaired within 14 days and the affected equipment checked again within 1 month to ensure that the repair has been effective.
As you can see, this solution is really only applicable in very specific use cases and cannot be considered one with any degree of permanence. It should only be proposed in the event that your air conditioning systems are not critical in any way to the daily operation of your business and the up-front cost of taking any immediate action is not able to be met.
How do I assess which solution I should be choosing?
So, which of these solutions is right for your business?
Besides the pros and cons that we have already outlined, the decision to either replace, convert or leave ‘as-is’ any equipment using R22 should be based on a number of factors.
Unfortunately, because of the number of variables involved, there is no ‘quick fix’ way of arriving at a conclusion in this respect, and a balanced assessment must be made of factors affecting each piece of equipment in turn. These factors will include:
Does your system use ‘direct expansion’ or a ‘flooded’ evaporator?
To make the distinction, direct expansion (or DX) evaporators are typically used in air conditioning systems below 100 tons of cooling capacity and may be suitable for conversion to an HFC replacement gas, whereas flooded evaporators, which are in systems of over 100 tons in capacity (refrigerating and technological tasks also use flooded evaporators) warrant much further consideration.
This distinction is an important one and requires professional assessment of your particular system in order to make the most appropriate recommendation.
Refrigeration and air conditioning systems exceeding 10 years in age are likely to be approaching the end of their natural life and should be strong candidates for replacement.
As the majority of R22 systems are aged between 10 to 15 years these should be assessed further before a solution is decided upon.
It is also worth noting that if a system has previously been converted from using a refrigerant such as R12 or R502 to using R22 then this should be replaced and not converted for a second time.
In the event that a system has been well maintained and is in good condition, a conversion solution may be an option.
In this respect, it can be useful to consult with available records of refrigerant leakage, as these will provide important indicators as to the likely success of a ‘retrofill’ operation, for example.
Meeting Operational Requirements
As many industries continue to develop apace, it can be seen that their systems are no longer operating according to their original design specification.
Likely impacted are operating performance, reliability and energy efficiency.
Thus, the phase-out of R22 represents a golden opportunity to replace or modify systems to best meet current and forecast application requirements.
When considering initial capital outlay on replacement air conditioning systems, it is vital to take into account on-going savings in running costs.
New legally-compliant air conditioning systems, incorporating latest inverter-driven technology and free-cooling capability, are so much more energy-efficient than R22 systems.
Major manufacturers such as Daikin and Mitsubishi claim savings in operating costs comfortably in excess of 50%.
The benefits of replacing an old system should be professionally assessed, but should not be underestimated, especially in view of rising utility costs highlighting the benefits of energy efficiency.
Ease Of Implementation
In some cases, systems may be so embedded within the factory or building housing them that replacement may prove almost impossible, and such cases will warrant further investigation.
In such circumstances, it may be possible as an alternative to install a replacement system alongside the existing one and then to switch over with the minimum of disruption.
How can Quantech help me deal with the fallout of the R22 ban?
With over 25 years of experience in the industry, Quantech have helped many a customer navigate changes in legislation or operational requirements of their businesses.
As you can see, the ban on R22 presents its own unique set of challenges to business owners using it in their current air conditioning and/or refrigeration systems, and the decisions surrounding opting for one of the available solutions can be fraught with difficulty.
This is where we are here to help you.
If this article has raised some questions that you would like answering, or if you would just like to chat with us informally in the first instance then why not get in touch with us today?
We’ll be happy to provide a professional assessment of your current systems and to provide sound and practical advice to help you moving forward.
Coming Up Next Time: Air Conditioning In 2015
We’ll be looking at innovations and initiatives from the prominent air conditioning manufacturers for 2015, and seeing how these are helping to drive businesses forward this year, both in meeting environmental legislation and in improving their overall energy efficiency.
* Estimated figure from Mitsubishi Electric Jan 2013
** Running cost comparing new 7kW Power Inverter Mr Slim cassette with equivalent 12-year-old system. Source: Mitsubishi Electric’s Audit Tool.
*** Source: Mitsubishi Electric Audit Tool