	

Re: Fw: R22 A/C equipment  

	

Julius Banks 

to:

ErnestoGarcia

02/03/2009 10:55 AM

	

	

Cc:

Cindy Newberg

	

Mr. Garcia,

Here is the weblink to the precharged products proposed rulemaking 

(www.epa.gov/ozone/title6/phaseout/Factsheetprecharged.html).  

Please note that the comment period closes on Feb. 6.  I'd encourage you


to provide comment on behalf of yourself or your company concerning the 

import of products with a nitrogen charge as well as the issue of
storage 

in a bonded warehouse.  

The full text of the proposed rule is available at 

www.epa.gov/fedrgstr/EPA-AIR/2008/December/Day-23/a29999.pdf

Regards,

Julius Banks

Team Lead, Refrigerant Recovery and Recycling Prog.

Stratospheric Protection Division

tel:  202.343.9870

fax:  202.343.2338

www.epa.gov/ozone/title6/608/608fact.html

From:	Cindy Newberg/DC/USEPA/US

To:	Julius Banks/DC/USEPA/US@EPA

Date:	02/02/2009 03:36 PM

Subject:	Fw: R22 A/C equipment

++++++++++++++++++++++++++++++++++++++

Cindy Newberg

Branch Chief, AERB

Stratospheric Protection Division

US Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.  6205J

Washington, D.C.  20460

ph: 202-343-9729

----- Forwarded by Cindy Newberg/DC/USEPA/US on 02/02/2009 03:36 PM
-----

From:	"Ernesto Garcia" <ErnestoGarcia@innovair.com>

To:	Cindy Newberg/DC/USEPA/US@EPA

Date:	02/02/2009 03:35 PM

Subject:	R22 A/C equipment

Dear Ms. Newberg

Our company is an importer/exporter of air conditioning equipment in
Miami 

and I need to clarify the new law regarding the ban on R22 equipment.

We currently import R22 A/C equipment from China and export 100% to
Latin 

America. Our units are clearly marked “Not for Sale in the U.S….(as 

required by the government). I have heard but have not been able to 

confirm that after January 2010, all R22 equipment imported must be kept


in a bonded warehouse for export.

I have researched the internet but have not found any information that 

this is true. 

I would appreciate it if you could help me find out what our company
needs 

to do in order to comply with the new law. 

Awaiting your reply 

Sincerely

Ernesto Garcia

 

Innovair Corporation

11490 NW 39th St.

Miami, FL 33178 U.S.A.

Tel:  (305) 463-9998 

Fax: (305) 463-9161

E-mail: ErnestoGarcia@innovair.com

Website: www.innovair.com

 

 

 

----- Forwarded by Julius Banks/DC/USEPA/US on 12/11/2009 09:57 AM -----

	

	R22 Phase-out

	

	Ernesto Garcia 

	to:

	Julius Banks

	08/14/2009 05:10 PM

	

	

	Cc:

	juliogomez, mariagomez

	Please respond to ErnestoGarcia

	

	

Dear Mr. Banks

I would like to thank you for your time and for the information you gave


me regarding the phase out of R22 by January 2010. I would like to
confirm 

in order to make sure I have all the correct information. There are also


some other questions that I had forgotten to ask. The current proposal 

states the following and is subject to change.

1)      All A/C products that have R22 charge cannot be imported into
the 

U.S. We can import R22 charged equipment into the U.S. for export only
as 

long as it is kept in a U.S. Customs approved bonded warehouse.

2)      The R22 equipment can be imported into the U.S. with a nitrogen 

charge instead of R22. 

3)      I would like to know if the a/c equipment can be imported into
the 

U.S. if it comes charged  with a drop-in EPA approved alternative gas
such 

as NU22 (see attached literature).

4)      If the proposal has not been approved by December 2009 and we
have 

merchandise that has already shipped from China in transit to the U.S., 

will we have problems if it gets to the U.S. in January 2010? 

5)      In our conversation you mentioned you had no idea when this 

proposal will be approved. If it is not approved by January 2010 what 

happens?

6)      Do you have the current proposal and if so could you email me
this 

information?   

 

Hope to hear your reply,

Sincerely

 

Ernesto Garcia

 

Innovair Corporation

11490 NW 39th St.

Miami, FL 33178 U.S.A.

Tel:  (305) 463-9998 

Fax: (305) 463-9161

E-mail: ErnestoGarcia@innovair.com

Website: www.innovair.com

 ----- Forwarded by Julius Banks/DC/USEPA/US on 12/11/2009 09:57 AM
-----

	

	Re: R22 Phase-out  

	

	Julius Banks 

	to:

	ErnestoGarcia

	08/17/2009 01:22 PM

	

	

	Cc:

	juliogomez, mariagomez

	

	

	

Mr. Garcia,

The final rule has not yet been published.  So my responses are only 

applicable to the proposed rule.  

As of 1/1/10, air conditioning and refrigeration equipment that was 

manufactured prior to 1/1/10 and  is precharged with HCFC-22 or
HCFC-142b 

(or blends containing one of these HCFCs) cannot be sold or distributed 

into interstate commerce.   Interstate commerce includes import/export 

into the U.S.  

The proposed rule did not address transhipments of precharged products. 


This issue will be addressed in the final rule.  

EPA does not recognize alternatives as "drop in" replacements.  NU-22
has 

been found acceptable as an alternative in residential and light 

commercial A/C.   Products for which NU-22 has been found acceptable can


be sold or distributed in interstate commerce. Keep in mind that as of 

1/1/10, virgin HCFC-22 cannot be used to charge newly manufactured air 

conditioning and refrigeration equipment.  An EPA finding of
acceptability 

does not mean that manufacturers have agreed to the use of certain 

alternatives.  I suggest contacting the OEM for their recommendations or


possible warranty implications prior to using any alternative.  

EPA is unable to advise you on business decisions pertaining to the 

shipment of products from Asia.  As of 1/1/10, air conditioning and 

refrigeration equipment that was manufactured prior to 1/1/10 and  is 

precharged with HCFC-22 or HCFC-142b (or blends containing one of these 

HCFCs) cannot be sold or distributed into interstate commerce.  As 

previously stated interstate commerce includes imports.  

If EPA does not finalize the rulemakings, then under the Clean Air Act 
it 

shall be unlawful for any person to introduce into interstate commerce
or 

use any HCFC if is used as a refrigerant in appliances manufactured
prior 

to January 1, 2010. HCFC-22 would not be allowed to be imported or 

manufactured for the service of existing equipment or to charge new 

equipment. 

Visit www.epa.gov/ozone/title6/phaseout/classtwo.html and 

www.epa.gov/ozone/title6/phaseout/rulesoverview.html for more
information.

Julius Banks

Team Lead, Refrigerant Recovery and Recycling Prog.

Stratospheric Protection Division

tel:  202.343.9870

fax:  202.343.2338

www.epa.gov/ozone/title6/608/608fact.html

From:	"Ernesto Garcia" <ErnestoGarcia@innovair.com>

To:	Julius Banks/DC/USEPA/US@EPA

Cc:	<juliogomez@innovair.com>, <mariagomez@innovair.com>

Date:	08/14/2009 05:10 PM

Subject:	R22 Phase-out

Dear Mr. Banks

I would like to thank you for your time and for the information you gave


me regarding the phase out of R22 by January 2010. I would like to
confirm 

in order to make sure I have all the correct information. There are also


some other questions that I had forgotten to ask. The current proposal 

states the following and is subject to change.

1)      All A/C products that have R22 charge cannot be imported into
the 

U.S. We can import R22 charged equipment into the U.S. for export only
as 

long as it is kept in a U.S. Customs approved bonded warehouse.

2)      The R22 equipment can be imported into the U.S. with a nitrogen 

charge instead of R22. 

3)      I would like to know if the a/c equipment can be imported into
the 

U.S. if it comes charged  with a drop-in EPA approved alternative gas
such 

as NU22 (see attached literature).

4)      If the proposal has not been approved by December 2009 and we
have 

merchandise that has already shipped from China in transit to the U.S., 

will we have problems if it gets to the U.S. in January 2010? 

5)      In our conversation you mentioned you had no idea when this 

proposal will be approved. If it is not approved by January 2010 what 

happens?

6)      Do you have the current proposal and if so could you email me
this 

information?   

 

Hope to hear your reply,

Sincerely

 

Ernesto Garcia

 

Innovair Corporation

11490 NW 39th St.

Miami, FL 33178 U.S.A.

Tel:  (305) 463-9998 

Fax: (305) 463-9161

E-mail: ErnestoGarcia@innovair.com

Website: www.innovair.com

 [attachment "NU-22B product sheet.pdf" deleted by Julius 

Banks/DC/USEPA/US] 

