Re: Large Bus HVAC Systems  

	

Julius Banks 

to:

Johnson, Steve D. - TK

05/29/2009 04:04 PM

	

	

Cc:

Cindy Newberg, Ross Brennan

	

	

	

Mr. Johnson,

On December 23, 2008, EPA published two proposed rules that, working 

together, will restrict the availability and use of HCFCs (including
R-22) 

starting in 2010. One proposal would allocate allowances to continue the


Montreal Protocol phasedown of production and import of HCFCs. The other


proposal would ban the sale or distribution (including import) of 

pre-charged air-conditioning and refrigeration products and components 

containing HCFC-22 or HCFC-142b.

1) As described in the proposal, EPA considers an appliance manufactured


once the refrigerant circuit is complete, and the appliance is charged
and 

ready for its intended purpose.  So yes, the HVAC system would be 

considered to be manufactured after the bus builder installs it in the
bus 

and connects it.  

2) If the proposal is finalized, the bus manufacturer could not
configure 

the unit and charge it with virgin R-22 after January 1, 2010.  

3) & 4) EPA has not finalized the proposed rule, but is considering how 

manufacturers would be able to comply with a requirement that would rely


on the manufacturer to determine the origin of the refrigerant being
used 

to charge a new hvac unit (i.e., appliance)  to determine if the 

refrigerant were used or virgin when charging a newly manufactured hvac 

unit (i.e., appliance).  

5 If the proposal is finalized, the bus manufacturer could not configure


the unit and charge it with virgin R-22 after January 1, 2010.  So any 

R-22 on hand could only be used to service existing appliances.  

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:	"Johnson, Steve D. - TK" <Steve_Johnson@thermoking.com>

To:	Cindy Newberg/DC/USEPA/US@EPA, Ross Brennan/DC/USEPA/US@EPA, Julius 

Banks/DC/USEPA/US@EPA

Date:	05/27/2009 06:12 PM

Subject:	Large Bus HVAC Systems

Hello,

 

We manufacture HVAC systems for buses.  The HVAC unit and compressor are


shipped separately, without a refrigerant charge to the bus manufacturer


for installation into the bus during the final assembly.  The unit and 

compressor are then connected with hoses and the system is evacuated and


charged with R22.   As a manufacturer, we will not produce equipment for


R22 after December 31, 2009.  However, our bus customers will have HVAC 

systems that will have to be installed, connected and charged after 

January 1, 2010.  This raises several questions.

1.       Is the HVAC system considered to be manufactured after the bus 

builder installs it in the bus and connects it?  The HVAC system’s
name 

plate will have a 2009 serial number.

2.       Can the HVAC unit be charged by the bus manufacturer with R22 

that was manufactured and purchased in 2009 if it is already on hand?

3.       Can the HVAC unit be charged with R22 manufactured in 2010, or 

newly produced R22 under any circumstance?

4.       How will the EPA distinguish “newly produced” R22 from the 

existing supplies?

5.       Given that the bus builders can predict their beginning
inventory 

in 2010, should the bus manufacturers pre-buy R22 for this purpose?

 

 Please give these questions your immediate consideration.

 

Regards,

 

Steve D Johnson

Product Manager, Large Bus and Rail HVAC

Thermo King Corporation

314 West 90th Street

Bloomington, MN 55420

Direct: 952/887-2241

FAX: 952/887-2689

 

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----- Forwarded by Julius Banks/DC/USEPA/US on 12/11/2009 10:01 AM -----

	

	Fw: SPLIT SYSTEMS A/C R-22 phase-out

	

	Julius Banks 

	to:

	jimhunt

	08/19/2009 05:53 PM

	

	

	Cc:

	Cindy Newberg

	

	

	

Mr. Hunt,

We are currently drafting a final version of the rule that proposed a
ban 

on the sale and distribution of a/c and refrigeration appliances and 

equipment components (such as condensing units, linesets, acoils) that
are 

pre-charged with R-22 

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

proposed, as of January 1, 2010 no person may sell or distribute air 

conditioning or refrigeration equipment (including appliances and 

equipment components) that are pre-charged with R-22.  While this
proposal 

allows for the sale of inventoried components that were manufactured
prior 

to January 1, 2010, under a separate proposal 

(www.epa.gov/fedrgstr/EPA-AIR/2008/December/Day-23/a29965.pdf) such 

components could not be used in new construction and would only be
allowed 

to service existing R-22 systems.  

EPA understands the time sensitivity of these important actions.   We 

anticipate final versions of the rules to be published later this year. 


EPA will post copies on-line(www.epa.gov/ozone/strathome.html) as soon
as 

the final versions can be made public.   Additional information is 

available at www.epa.gov/ozone/title6/phaseout/rulesoverview.html and 

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

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

----- Forwarded by Cindy Newberg/DC/USEPA/US on 08/19/2009 05:17 PM
-----

From:	"Jim Hunt" <jimhunt@royalmhs.com>

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

Date:	08/19/2009 12:06 PM

Subject:	SPLIT SYSTEMS A/C R-22 phase-out

   If i am reading rules right we as a supplier of pre-charged a/c 

equipment (R-22) can we sell and install any equipment that we have in 

stock and long as it was manufactured before Jan 1st  2010

condensing units - linesets - a-coils

or has a final rule been made yet...thank you for any help

 

 

Jim Hunt

Royal / Durham Supply

Tulsa, Oklahoma  74115

Ph # 918-835-5536

fax#  918-835-6462

website.  

www.royal-durhamsupply.com

