









                          THE U.S. PHASEOUT OF HCFCS:
                    PROJECTED SERVICING NEEDS IN THE U.S. 
         AIR-CONDITIONING, REFRIGERATION, AND FIRE SUPPRESSION SECTORS
                           UPDATED FOR 2015 TO 2025
                                       
                                       
                                       
                                 Prepared for 
                                       
                     U.S. Environmental Protection Agency
                          Office of Air and Radiation
                       Stratospheric Protection Division
                         1200 Pennsylvania Avenue, NW
                             Washington, DC 20460
                                       
                                       
                          Prepared with support from 
                                       
                               ICF International
                              1725 Eye Street, NW
                             Washington, DC 20006
                                       
                                       
                                       
                               Draft, March 2014
         
         
         
         
         
         
         
         
         
         
This draft report estimates the quantity of HCFC-22 (also recognized by the American Society of Heating Refrigerating and Air- Conditioning Engineers (ASHRAE) designation, R-22), HCFC-142b, HCFC-123 and HCFC-124 needed to service air-conditioning and refrigeration equipment and the anticipated installed base of such equipment beyond 2015 in the United States. The report also discusses the uses and need for other HCFCs, including HCFC-123 use in nonresidential fire suppression. This analysis has been developed to inform the allocation of HCFC consumption allowances in 2015-2019. This report updates the 2009 version of the report of the same name that was released with the 2009 Final Rule titled "Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export," (December 2009, 74 FR 66412). This draft report also builds on the discussion included in the memo to the docket titled "Analysis of HCFC-22 Servicing Needs in the U.S. Air Conditioning and Refrigeration Sector: Additional Considerations for Estimating Virgin Demand," (Adjustment Memo, docket ID # EPA-HQ-OAR-2011-0354-0003). A description of notable updates and additions to the Vintaging Model (the model used to develop the data provided in this report) since the 2009 report can be found in Appendix C of this document. 



   Questions concerning this report should be directed to: 

         Elizabeth Whiteley
         Stratospheric Protection Division 
         U.S. Environmental Protection Agency
         1200 Pennsylvania Avenue, NW (6205J)
         Washington, D.C. 20460
         1-202-343-9310 (phone)
         1-202-343-2338 (fax)
         whiteley.elizabeth@epa.gov


Contents

Executive Summary	1
1.	Background: The U.S. HCFC Phaseout Schedule	5
1.1.	Report Objective	6
2.	Methodology Overview	8
3.	Overview of HCFC Use in the United States	9
3.1.	Projected HCFC Servicing Need	10
3.2.	HCFC Use in Refrigeration and Air-Conditioning	11
3.3.	HCFC Use in Nonresidential Fire Suppression	15
4.	Projected HCFC Scenarios	17
4.1.	HCFC-22	17
4.1.1.	HCFC-22 Equipment Used Beyond 2015	17
4.1.2.	Projected HCFC-22 Servicing Needs	18
4.2.	HCFC-123	19
4.2.1.	HCFC-123 Equipment Used Beyond 2015	19
4.2.2.	Projected HCFC-123 Needs	20
4.3.	HCFC-124	21
4.3.1.	HCFC-124 Equipment Use Beyond 2015	21
4.3.2.	Projected HCFC-124 Needs	21
4.4.	HCFC-142b	22
4.5.	HCFC Sources	22
4.6.	Meeting Refrigeration and AC Service Need	24
4.6.1.	Servicing Need and Recovery Projections for HCFC-22	25
4.6.2.	Need and Recovery Projections for HCFC-123	27
4.6.3.	Servicing Need and Recovery Projections for HCFC-124	28
4.6.4.	Summary of HCFC-22, HCFC-123, and HCFC-124 Servicing Need and Recovery Projections	28
4.7.	Factors Affecting Projections	30
4.7.1.	Transitioning to Alternative Refrigerants	30
4.7.2.	Recovery and Reuse Practices	31
4.7.3.	Recycling, Reuse, and Managing Inventory	32
4.7.4.	HCFC-22 Economics	32
4.7.5.	Increasing Seasonal Energy Efficiency Ratio (SEER)	33
4.7.6.	Lower Loss Rates	33
5.	Conclusion	34
Appendix A: Methodology Used to Calculate Projected Servicing Needs	36
Appendix B: HCFC Projections by End-Use	46
Appendix C: Changes to the Vintaging Model	48
Appendix D: Sensitivity Analyses	49
Appendix E: HCFC-22 Inventory Estimate	54
References	55




Executive Summary
Hydrochlorofluorocarbons (HCFCs) are a class of chemical compounds that deplete the stratospheric ozone layer, increasing the chances of overexposure to ultraviolet (UV) radiation at the earth's surface. Excessive UV radiation damages biological systems and causes malignant melanoma and other skin cancers, cataracts and other eye damage, and harm to certain crops and marine organisms. Reversing the course of stratospheric ozone depletion is crucial to human and environmental health worldwide. As a Party to the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), the United States is subject to a cap on HCFC consumption -- defined as production plus imports minus exports -- in an international effort to protect the stratospheric ozone layer (UNEP 2000). Specifically, the United States is obligated to phase out production and consumption of HCFCs by 2030 by making graduated reductions in HCFC production and consumption by certain dates. 

To meet these interim reduction targets, the U.S. Environmental Protection Agency (EPA) established a schedule for the phaseout of HCFCs. EPA phased out consumption of HCFC-141b in 2003. On January 1, 2010, the production and import of HCFC-142b and HCFC-22 were banned except for servicing equipment manufactured before January 1, 2010. The next phaseout milestone will occur in 2015 with a ban on production and import of any other HCFCs, except for use as refrigerants in equipment manufactured prior to January 1, 2020. In addition, in December 2011, Title VI of the Clean Air Act was amended to permit the use of HCFCs in non-residential fire suppression applications. Starting on January 1, 2020, there will be a ban on any remaining production and import of HCFC-22 and HCFC-142b, and production and import of other remaining HCFCs will be limited to use as a refrigerant to service existing equipment. 

Thus, starting in 2015, the production and import of virgin HCFCs in the United States will be limited to servicing existing refrigeration and AC equipment, and non-residential fire suppression applications. Historically, only HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 have been used in significant quantities in these applications. Table ES 1 presents an overview of the use limitations, applications, and servicing need projections for these four HCFCs. 

ES 1: Overview of HCFC Use Limitations, Applications, and Projections for 2015 to 2025
                                     HCFC
                            Regulatory Limitations
                                 Applications
                  Is Servicing Need Projected for 2015- 2025?


                                    Ref/ AC
                       Non-Residential Fire Suppression

HCFC-22
Production and import limited January 1, 2010 to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2010.
                                       
                                      --
Yes.
HCFC-142b

                                       
                                      --
Not in the Vintaging Model. HCFC-142b is a component of certain blends that have limited refrigeration applications, some of which (e.g., R-409A) are not modeled.
HCFC-123
Production and import will be limited beginning January 1, 2015, to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2020. HCFC-123 and HCFC-124 can also be produced and imported for use as a nonresidential fire suppressant until 2020.
                                       
                                       *
Yes. 
HCFC-124

                                       
                                      --
Yes. In addition, HCFC-124 is a component of certain blends that have limited refrigeration applications, some of which (e.g., R-409A) are not modeled.
* HCFC-123 is a constituent of the Halotron I blend used in fire applications.

Table ES 2 presents the Vintaging Model's projected servicing need for HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 in refrigeration, air conditioning, and non-residential fire suppression applications. As noted above, although the Vintaging Model projects no servicing need for HCFC-142b and minimal servicing need for HCFC-124 between 2015 and 2025, other information -- such as refrigerant sales data collected by the California Air Resources Board -- suggests that HCFC-142b and HCFC-124 are still in use in niche refrigeration applications.

Table ES 2: Projected HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 Servicing Need for 
Refrigeration, Air-Conditioning, and Fire Suppression, 2015-2025 (Metric Tons)
                                     HCFC
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
HCFC-22
                                                                         46,100
                                                                         41,600
                                                                         36,700
                                                                         32,300
                                                                         27,700
                                                                         22,500
                                                                          5,500
HCFC-142b
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
HCFC-123
                                                                          2,200
                                                                          2,200
                                                                          2,200
                                                                          2,300
                                                                          2,300
                                                                            800
                                                                            700
HCFC-124
                                                                              4
                                                                              4
                                                                              4
                                                                              4
                                                                              4
                                                                              4
                                                                              -
Source: Vintaging Model (2012).

Although limited production and consumption of virgin HCFC-22 and HCFC 142b can be allowed until 2020, and HCFC-123 and HCFC-124 production can be allowed until 2030 (HCFC-22, HCFC-142b), with industry effort, a significant portion of the need for HCFCs for servicing is expected to be met with previously used refrigerant that is recovered and then recycled or reclaimed. To determine the potential amounts of used refrigerant available to service equipment, EPA used its Vintaging Model to develop three scenarios of recovery to estimate: 1) the projected amount of recovered HCFCs potentially available to meet servicing need of equipment still in use; and 2) the subsequent quantity of HCFCs needed to satisfy the remaining need. Scenarios based on the Vintaging Model were not developed for HCFC-142b.

Box ES-1: Sensitivity Analysis
While EPA's assumptions are frequently updated to refine assumptions, the projections of future servicing needs for HCFC-22 can be affected by outside factors that are not fully reflected in the estimates. A sensitivity analysis performed on key modeling assumptions suggests that HCFC-22 servicing demand could be marginally to significantly lower than what is projected. In particular, servicing need may be lower if the system charge size, leak rate, and/or equipment lifetime are less than current assumptions. The projections in this report provide only some of the information necessary for determining post-2015 servicing needs.
Box ES-1: Sensitivity Analysis
While EPA's assumptions are frequently updated to refine assumptions, the projections of future servicing needs for HCFC-22 can be affected by outside factors that are not fully reflected in the estimates. A sensitivity analysis performed on key modeling assumptions suggests that HCFC-22 servicing demand could be marginally to significantly lower than what is projected. In particular, servicing need may be lower if the system charge size, leak rate, and/or equipment lifetime are less than current assumptions. The projections in this report provide only some of the information necessary for determining post-2015 servicing needs.
Figure ES-1, Figure ES-2, and Figure ES-3 present the results of these lower, baseline, and higher HCFC recovery scenarios. For HCFC-22, the lower recovery scenario assumes that 35 percent of HCFC-22 from retired or retrofitted equipment is recovered and available for reuse in equipment; the baseline scenario assumes a recovery rate that is equal to the rate that is modeled by EPA's Vintaging Model; and the higher recovery scenario assumes 65 percent recovery. For HCFC-123 and HCFC-124, the recovery rate modeled by the Vintaging Model is used for all three scenarios, since it is significantly higher (approximately 80 to 90 percent). 
In accordance with U.S. commitments under the Montreal Protocol, HCFC consumption (i.e., production and imports of virgin HCFCs) cannot exceed 1,524 ODP-weighted metric tons from 2015 to 2019 and cannot exceed 76.2 ODP-weighted metric tons starting in 2020. Figures ES-1 through ES-3 summarize servicing need in comparison to this U.S. HCFC consumption cap. The figures also present the amount of need that can be met by recovered and reused material (dark grey) and the remaining amount that would need to be met by virgin material. 






       Figure ES 1: Total Projected HCFC Demand, Lower Recovery Scenario
                                       
       Figure ES 1: Total Projected HCFC Demand, Lower Recovery Scenario
                                       






















     Figure ES 2: Total Projected HCFC Demand, Baseline Recovery Scenario
                                       
     Figure ES 2: Total Projected HCFC Demand, Baseline Recovery Scenario
                                       
































      Figure ES 3: Total Projected HCFC Demand, Higher Recovery Scenario
                                       

      Figure ES 3: Total Projected HCFC Demand, Higher Recovery Scenario
                                       

                                       





















The analysis demonstrates that it is possible to meet the projected servicing and new equipment needs for HCFC-22, HCFC-123, and HCFC-124 in 2015 under the baseline and higher recovery scenarios (see Figure ES-2 and Figure ES-2). Recovered refrigerant, in addition to limited amounts of virgin refrigerant (not exceeding the cap), can satisfy future servicing needs. As shown in Figure ES-1, the AC and refrigeration industry may face potential shortage risks in a lower recovery scenario. 

Several other factors also influence the level of HCFC servicing need and sufficiency of recovered supply in 2015 and beyond. For example, with approximately 97 million AC and refrigeration units projected to be in use in 2015, the sooner consumers transition to equipment using alternative refrigerants, the better the chance for an adequate HCFC-22, HCFC-123, and HCFC-124 supply to satisfy the forecasted servicing need. This report explores the following market trends and how they may influence future HCFC servicing need and available supply estimates, including:

      :: the rate of market transition to alternative refrigerants in the United States;
      :: HCFC-22 cost;
      :: assumed equipment leak and servicing loss rates; 
      :: increased seasonal energy efficiency ratio (SEER) standards; and
      :: quantities of refrigerant recovered for reuse, reclamation, and/or banking.

If leak rates, practiced equipment lifetimes, and charge sizes are less than what the agency currently assumes -- as suggested by some stakeholders -- servicing need, as well as necessary virgin supply, could be significantly lower than what is presented in the figures above.
Background: The U.S. HCFC Phaseout Schedule
Title VI of the 1990 Clean Air Act Amendments (CAAA) mandates the development and implementation of regulations to protect the stratospheric ozone layer and ensure U.S. compliance with the Montreal Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol). Under the Montreal Protocol, the United States and other signatories have agreed to achieve progress toward the total phaseout of the consumption and production of HCFCs, which are ozone-depleting substances (ODS) and have been widely used as refrigerants, solvents, foam blowing agents, and fire suppressants. Consumption is defined as production plus imports minus exports; production is defined as the manufacture of a controlled substance minus amounts destroyed and amounts completely used as feedstock in the manufacture of other chemicals. Neither consumption nor production includes amounts that are reused or recycled (UNEP 2000). 

In September 2007, the nineteenth Meeting of the Parties to the Montreal Protocol was held in Montreal, Canada, marking the 20[th] anniversary of the signing of the Protocol. At the meeting, the Parties agreed upon a strengthened phaseout of HCFCs. The adjustments call for non-Article 5 countries -- the Protocol's identifying term for developed countries -- to limit HCFC production and consumption to 25 percent of baseline by 2010, 10 percent by 2015, and 0.5 percent by 2020 -- allowing for 0.5 percent of the baseline for annual servicing over the period 2020-2030. Previously, the 2010 reduction step was 65 percent and was limited solely to consumption, not production.

Table 1-1 presents the HCFC consumption baseline and the graduated reductions (caps) to allowable HCFC consumption for the United States (and all Article 2 countries). 

Table 1-1: U.S. HCFC Consumption Phaseout Schedule Under the Montreal Protocol
                                     Date
                                Consumption Cap
                          ODP Weighted Metric Tons[a]
                 Quantity Expressed in HCFC-22 Metric Tons[b]
Jan 1, 1996
Baseline set at 2.8% of the 1989 ODP-weighted CFC consumption plus 100% of the 1989 ODP-weighted HCFC consumption
                                    15,240 
                                   277,091 
Jan 1, 2004
35% reduction from the baseline
                                    9,906 
                                   180,109 
Jan 1, 2010
75% reduction from the baseline
                                    3,810 
                                    69,273
Jan 1, 2015
90% reduction from the baseline
                                    1,524 
                                    27,709 
Jan 1, 2020
99.5% reduction from the baseline
                                     76.2 
                                      0[c]
Jan 1, 2030
100% reduction from the baseline
                                      0 
                                       0
 [a]An ODP-weighted metric ton takes into account each ODS' relative contribution to ozone depletion. One metric ton equals approximately 2,204 pounds. 
 [b]Calculated using an ODP of 0.055 for HCFC-22. 
  [c]In 2020, 0.5 percent of the U.S. consumption baseline remains, but the U.S. phaseout schedule prevents any allocation to HCFC-22. 

Table 1-2 details the U.S. phaseout schedule for HCFCs established under the 1990 CAAA to comply with the targets set by the Montreal Protocol (as presented in Table 1-1). The production and import of HCFC-141b, the HCFC with the highest ODP, was phased out with limited exemptions on January 1, 2003. Beginning in 2003, EPA established an allowance system to control the U.S. production and consumption (including import and export) of HCFCs and to apportion consumption allowances amongst HCFCs. Allowances are the privilege granted to an allowance holder to produce and/or import a limited quantity of an HCFC on an annual basis. Production and consumption allowances for HCFC-141b (for limited exemptions), HCFC-22, and HCFC-142b were authorized and distributed (on a kilogram basis) to certain companies (EPA 2003a). In the 2009 HCFC allocation rule, Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export, EPA authorized and distributed (on a kilogram basis) production and consumption allowances for HCFC-123, HCFC-124, HCFC-225ca, and HCFC-225cb to certain companies in addition to HCFC-22 and HCFC-142b (EPA 2009). The 2009 HCFC allocation rule was challenged in Arkema v EPA (618 F.3d 1, DC Cir. 2010) and the portion of the rule that establishes company-by-company production and consumption baselines and calendar-year allowances for HCFC-22 and HCFC-142b was vacated. All other aspects of the rule are intact. In August 2011, EPA issued an interim final rule that established new company-by-company HCFC-22 and HCFC-142b baselines and allocated production and consumption allowances for 2011 (EPA 2011). In April 2013, EPA published a final rule allocating HCFCs for 2012 through 2014.

Table 1-2: U.S. HCFC Phaseout Schedule as Implemented by EPA Under the 1990 CAAA 
(To Comply with the Protocol)
                                     Date
                                  Restriction
Jan 1, 2003
   * Ban on production and import of HCFC-141b.
Jan 1, 2010
   * Ban on production and import of HCFC-22 and HCFC-142b except for on-going servicing needs in equipment manufactured before January 1, 2010.[a]
Jan 1, 2015
   * Ban on the production, import, and introduction into interstate commerce or use of HCFCs except where the HCFCs are used as a refrigerant in equipment manufactured prior to January 1, 2020 or where HCFCs are used as a fire suppression agent for nonresidential applications.[a][, b]
Jan 1, 2020
   * Ban on remaining production and import of HCFC-22 and HCFC-142b.[a]
   * Ban on production and consumption of all other HCFCs except for use in servicing refrigeration and AC equipment produced before January 1, 2020.[c]
Jan 1, 2030
   * Ban on production and import of all HCFCs.[a]
   [a]Certain additional exemptions apply, including exemptions for (1) HCFCs used in processes resulting in their transformation or destruction, or (2) pre-authorized import of HCFCs that are recovered and either recycled or reclaimed.
   [b]Title VI of the Clean Air Act was amended in December 2011 to allow the continued use of virgin HCFCs for nonresidential fire suppression purposes until January 1, 2020.
   [c]Article 2F of the Montreal Protocol requires that each Party shall ensure that consumption and production of hydrochlorofluorocarbons does not exceed zero; however, each Party may exceed that limit provided that consumption is restricted to the servicing of refrigeration and AC equipment manufactured before January 1, 2020.
   Source: EPA (2003a); EPA (2007); United States Congress (2011); UNEP (2000).

Effective January 1, 2010, U.S. production and import of HCFC-22 and HCFC-142b were limited to use in equipment manufactured prior to January 1, 2010, with a complete phaseout of these HCFCs by January 1, 2020. In addition to the HCFC-22 and HCFC-142b restrictions, beginning January 1, 2015, U.S. production, import, use, or introduction into interstate commerce of all other HCFCs will be banned except for use as refrigerants in equipment manufactured prior to January 1, 2020 or for use in nonresidential fire suppression. Starting in 2020, the Montreal Protocol further restricts production and import of virgin HCFCs to servicing of existing AC and refrigeration equipment. A complete ban on production and import of HCFCs goes into effect January 1, 2030. 

This report evaluates the amount of HCFCs needed to ensure that the U.S. meets its international commitment under the Montreal Protocol, while also allowing for equipment owners to service HCFC-dependent equipment until the end of its useful life. 
Report Objective
This report presents quantitative estimates of the projected amount of (a) units of equipment using HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 beyond 2015 in the United States and (b) HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 needed to meet servicing need beyond 2015 in the United States. This report is an update to the 2009 report The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. Air-Conditioning and Refrigeration Sector that provided projections through 2020. This report estimates HCFC consumption needs for air-conditioning (AC) and refrigeration equipment (the largest HCFC market and the largest industry sector using HCFCs) that will be in use after 2015 and possible future recovery scenarios to help meet those needs. This analysis also explores, in a limited way, servicing need for HCFCs for nonresidential fire suppression applications beyond 2015. 

The remainder of the report is organized as follows:

   * Section 2 provides a brief overview of the methodology used to project servicing scenarios.
   * Section 3 provides an overview of HCFC use in the United States, including projected servicing need of HCFCs, an overview of HCFC use in the AC and refrigeration sector, and an overview of HCFC use for nonresidential fire suppression.
   * Section 4 provides three projected recovery scenarios and resulting HCFC-22, HCFC-123, and HCFC-124 consumption needs. Section 4 also provides some discussion on expected HCFC-142b servicing need based on industry feedback.
   * Section 5 summarizes factors that may affect the projections presented in the report.
   * Appendix A presents further information on the projection methodology and its limitations.
   * Appendix B provides AC and refrigeration projections by end-use.
   * Appendix C provides an overview of the changes that have been made to EPA's Vintaging Model since the 2009 report The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. Air-Conditioning and Refrigeration Sector ("Servicing Tail Report").
   * Appendix D provides sensitivity analyses performed to determine the effect that several key assumptions may have on HCFC-22 servicing need. Assumptions considered include: system charge size, average annual equipment leak rates (i.e., loss rates), and the expected length of time a system is in operation (i.e., equipment lifetime). 


Methodology Overview
This report provides projections estimating the servicing need for HCFCs for 2015 to 2025. Appendix A discusses the assumptions used to develop the supply and servicing need estimates presented in this report and the limitations and caveats inherent in the analysis. EPA's Vintaging Model is the primary tool used to perform the analysis and forms the basis for quantitative estimates of current and projected HCFC consumption. The Vintaging Model estimates the annual chemical emissions from industry sectors that have historically used ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. Within these industry sectors, there are over 60 independently modeled end-uses. The model uses information on the market size and growth for each end-use, as well as a history and projections of the market transition from ODS to alternatives. As ODS are phased out, a percentage of the market share originally filled by the ODS is allocated to each of its substitutes. The model tracks emissions of annual "vintages" of new equipment that enter into operation by incorporating information on estimates of the quantity of equipment or products sold, serviced, and retired or retrofitted each year, and the quantity of the chemical required to manufacture, charge, and/or maintain the equipment. EPA's Vintaging Model uses this market information to build an annual inventory of in-use stocks of equipment and the ODS and non-ODS substitutes in each end-use. The model is updated on a regular basis to reflect changes in the market and new industry information. Updates to the Vintaging Model since the release of the 2009 Servicing Tail Report are summarized in Appendix C.

This report provides an update of HCFC-22 servicing needs for air-conditioning and refrigeration equipment, as well as an update on the estimated servicing need for other HCFCs. This analysis has undergone many revisions; key milestones include:

      * The first release of this report was on November 4, 2005 when EPA made the preliminary draft version available for comment in a Notice of Data Availability (NODA, 70 FR 67172). Based on comments received from stakeholders, EPA used the Vintaging Model to test whether servicing need might exceed supply under some circumstances. 
      * On September 29, 2006, EPA's Stratospheric Protection Division held a meeting for HCFC stakeholders regarding the 2010 milestone in the HCFC phaseout. EPA issued a September 2006 version of this report at that time. This version contained one additional scenario of consumption needs for HCFC-22 based on stakeholder input on the 2005 draft report. 
      * A June 2008 version of the report took into account the comments from stakeholders and provided an updated set of analyses based on the most recent Vintaging Model output. The June 2008 version of the report included the HCFC-22 estimates of a recovery rate of 15, 20, and 75 percent in addition to updating the previous scenarios of 10 and 50 percent.
      * On December 23, 2008, EPA published two proposed rules, Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export (73 FR 78680) and Ban on the Sale or Distribution of Pre-charged Appliances (73 FR 78705). Comments on both proposed rules were submitted during the public comment period in early 2009 in Docket ID No. EPA - HQ - OAR - 2008 - 0496 and Docket ID No. EPA - HQ - OAR - 2007 - 0163 respectively. The Allowance System proposed rule requested comments on the draft servicing tail analysis. 
      * In December 2009, another version of the report took into account relevant comments from stakeholders. The report focused on two recovery rates scenarios (20 and 50 percent) and presented the actual allocation amounts for the 2010-2014 control periods as found in EPA's final rule. 
      * In November 2011, EPA conducted research and analysis to account for the changes in the HCFC-22 market since the 2009 Final Rulemaking. The 2011 memorandum (Docket ID No. EPA-HQ-OAR-2011-0354-0003) provided additional information on virgin HCFC-22 inventory, recovery and reuse practices in large retail food, and reclamation trends and capacity. 
         
The purpose of the projections presented in this report and earlier versions is to support the process of allocating HCFC consumption allowances. To that end, this report update focuses on the next segment of years in the phaseout -- 2015 through 2025 and the four main HCFCs of concern -- HCFC-22 HCFC-123, HCFC-124, and HCFC-142b.

Overview of HCFC Use in the United States
HCFCs have a variety of applications in the foam, aerosol, solvent cleaning, fire protection, and sterilization industry sectors; however, their largest presence is in the AC and refrigeration industries. Although the Montreal Protocol has identified numerous HCFCs under Article 2F, only those listed in Box 3-1 have been consumed in significant quantities in the United States. Starting in 2015, use of virgin HCFCs will be limited to refrigeration, AC, and nonresidential fire suppression applications. 
        Box 3-1: Summary of Common HCFCs and their End-Use Applications
      *      HCFC-141b - historically used as a blowing agent in rigid polyurethane foams and integral skim foams and in aerosol solvent cleaning applications. Production and consumption phased out in 2003 except for exemption production for specific applications.
      *   HCFC-22 - used as a refrigerant in several applications such as unitary air conditioners, cold storage, retail food refrigeration equipment, chillers, and industrial process refrigeration; see Section 4 for further information. Also used (in smaller quantities) as a blowing agent for certain foam applications and as a component of some sterilant mixtures. Production and consumption phased out in 2010 except for servicing appliances manufactured before January 1, 2010.
      *   HCFC-123 - used in centrifugal chillers and as a blend in portable fire extinguishers.
      *   HCFC-124 - used in sterilant mixtures and as a component in some replacements for CFCs as a refrigerant or for halon as a fire suppressant. Replaces CFC-114 in some heat pumps and special air conditioning equipment. HCFC-124 (combined with HCFC-142b) is also a component of some blends (e.g., R-409A, R-414B), which are primarily used as a retrofit alternative to CFC-12 and R-500 in refrigeration applications. Use of HCFCs as a sterilant is being phased out in 2015 by the Clean Air Act.
      *   HCFC-142b - historically used as a blowing agent in extruded polystyrene boardstock. Also used in small quantities in refrigerant blends as a retrofit refrigerant for applications such as motor vehicle ACs that previously used CFC-12 and other refrigeration applications that previously used CFC-12 and R-500. Production and consumption phased out in 2010 except for servicing appliances manufactured before January 1, 2010.
      *   HCFC-225ca/cb - used as a solvent, an aerosol solvent, and in small quantities in the adhesives, coatings, and inks sector. HCFC-225 ca/cb is a mixture of the two isomers HCFC-225ca and HCFC-225cb typically in a 45/55% by weight ratio. Use of HCFCs as a solvent is being phased out in 2015 by the Clean Air Act.
  Table 3-1: HCFC Atmospheric Lifetime (Years) and Ozone Depletion Potential
                                     HCFC
                                 Chemical Name
                                  CAS 
Number
                         Atmospheric
Lifetime (years)
                                    ODP[a]
HCFC-141b (CH3CFCl2)
1,1-Dichloro-1-fluoroethane
                                   1717-00-6
                                      9.2
                                     0.11
HCFC-142b (CH3CF2Cl)		
1-Chloro-1,1-difluoroethane
                                    75-68-3
                                     17.9
                                     0.065
HCFC-22 (CHF2Cl) 
Chlorodifluoromethane
                                    75-45-6
                                     12.0
                                     0.055
HCFC-124 (CF3CHFCl)	
2-Chloro-1,1,1,2-tetrafluoroethane
                                   2837-89-0
                                      5.8
                                     0.022
HCFC-123 (CHCl2CF3)		
1,1-Dichloro-2,2,2-trifluoroethane
                                   306-83-2
                                      1.3
                                     0.02
HCFC-225cb (CF2ClCF2CHClF)
1,1,2,2,3-pentafluoro-1,3-dichloropropane
                                   507-55-1
                                      2.1
                                     0.033
HCFC-225ca (CF3CF2CHCl2)
1,1,1,2,2-pentafluoro-3,3-dichloropropane
                                   422-56-0
                                      5.8
                                     0.025
            [a]ODP values are taken from the Montreal Protocol (UNEP 2003b).
        Box 3-1: Summary of Common HCFCs and their End-Use Applications
      *      HCFC-141b - historically used as a blowing agent in rigid polyurethane foams and integral skim foams and in aerosol solvent cleaning applications. Production and consumption phased out in 2003 except for exemption production for specific applications.
      *   HCFC-22 - used as a refrigerant in several applications such as unitary air conditioners, cold storage, retail food refrigeration equipment, chillers, and industrial process refrigeration; see Section 4 for further information. Also used (in smaller quantities) as a blowing agent for certain foam applications and as a component of some sterilant mixtures. Production and consumption phased out in 2010 except for servicing appliances manufactured before January 1, 2010.
      *   HCFC-123 - used in centrifugal chillers and as a blend in portable fire extinguishers.
      *   HCFC-124 - used in sterilant mixtures and as a component in some replacements for CFCs as a refrigerant or for halon as a fire suppressant. Replaces CFC-114 in some heat pumps and special air conditioning equipment. HCFC-124 (combined with HCFC-142b) is also a component of some blends (e.g., R-409A, R-414B), which are primarily used as a retrofit alternative to CFC-12 and R-500 in refrigeration applications. Use of HCFCs as a sterilant is being phased out in 2015 by the Clean Air Act.
      *   HCFC-142b - historically used as a blowing agent in extruded polystyrene boardstock. Also used in small quantities in refrigerant blends as a retrofit refrigerant for applications such as motor vehicle ACs that previously used CFC-12 and other refrigeration applications that previously used CFC-12 and R-500. Production and consumption phased out in 2010 except for servicing appliances manufactured before January 1, 2010.
      *   HCFC-225ca/cb - used as a solvent, an aerosol solvent, and in small quantities in the adhesives, coatings, and inks sector. HCFC-225 ca/cb is a mixture of the two isomers HCFC-225ca and HCFC-225cb typically in a 45/55% by weight ratio. Use of HCFCs as a solvent is being phased out in 2015 by the Clean Air Act.
  Table 3-1: HCFC Atmospheric Lifetime (Years) and Ozone Depletion Potential
                                     HCFC
                                 Chemical Name
                                  CAS 
Number
                         Atmospheric
Lifetime (years)
                                    ODP[a]
HCFC-141b (CH3CFCl2)
1,1-Dichloro-1-fluoroethane
                                   1717-00-6
                                      9.2
                                     0.11
HCFC-142b (CH3CF2Cl)		
1-Chloro-1,1-difluoroethane
                                    75-68-3
                                     17.9
                                     0.065
HCFC-22 (CHF2Cl) 
Chlorodifluoromethane
                                    75-45-6
                                     12.0
                                     0.055
HCFC-124 (CF3CHFCl)	
2-Chloro-1,1,1,2-tetrafluoroethane
                                   2837-89-0
                                      5.8
                                     0.022
HCFC-123 (CHCl2CF3)		
1,1-Dichloro-2,2,2-trifluoroethane
                                   306-83-2
                                      1.3
                                     0.02
HCFC-225cb (CF2ClCF2CHClF)
1,1,2,2,3-pentafluoro-1,3-dichloropropane
                                   507-55-1
                                      2.1
                                     0.033
HCFC-225ca (CF3CF2CHCl2)
1,1,1,2,2-pentafluoro-3,3-dichloropropane
                                   422-56-0
                                      5.8
                                     0.025
            [a]ODP values are taken from the Montreal Protocol (UNEP 2003b).

Section 3 is organized into three subsections. Section 3.1 provides a brief discussion of projected servicing need of HCFCs, including estimates in ODP-weighted metric tons. Section 3.2 presents an overview of the HCFC servicing need in the AC and refrigeration sector. Section 3.3 presents an overview of the HCFC servicing need for nonresidential fire suppression.
Projected HCFC Servicing Need 
Servicing need is projected for the following HCFCs: HCFC-22, HCFC-142b, HCFC-123, and HCFC-124. An overview of the use limitations, applications, and projected servicing need for these HCFCs is included in Table 3-2.

Table 3-2: Overview of HCFC Use Limitations, Applications, and Projections for 2015 to 2025
                                     HCFC
                            Regulatory Limitations
                                 Applications
                       Is Need Projected for 2015- 2025?
                      Notes on Servicing Need Projections


                                    Ref/ AC
                       Non-Residential Fire Suppression


HCFC-22
Production and import limited January 1, 2010 to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2010.
                                       
                                      --
                                       
   *  Estimated based on EPA's Vintaging Model
HCFC-142b

                                       
                                      --
                                      --
   *  For 2015 and beyond, the Vintaging Model projects no HCFC-142b servicing need, although other data suggests that HCFC-142b is still in use 
   *  HCFC-142b is a component of some blends (e.g., R-409A*), which are primarily used as a retrofit alternative to CFC-12 and R-500 in refrigeration applications
HCFC-123
Production and import will be limited beginning January 1, 2015, to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2020.
Virgin HCFC-123 and HCFC-124 can also be used for nonresidential fire suppression purposes between 2015 and 2020.
                                       
                                       
                                       
   *  Estimated based on Vintaging Model and other sources
   *  HCFC-123 is used as a refrigerant and as a constituent of the Halotron I blend used in fire suppression applications 
HCFC-124

                                       
                                      --
                                       
   *  Sterilant use no longer allowed
   *  Projections based on Vintaging Model 
   *  HCFC-124 is used in several SNAP-approved refrigerant blends (e.g., R-401A, R-401B, R-409A*, R-414A, R-414B, and R-416A)
*R-409A is not modeled in the Vintaging Model.

Figure 3-1 demonstrates projected HCFC servicing need in 2015 and 2020; as shown, HCFC-22 servicing needs constitute over 95% percent of all HCFC servicing need in 2015 and about 97% of HCFC servicing need in 2020.
 
Figure 3-1: Total Projected HCFC Servicing Need for Refrigeration, AC, and Fire Suppression 
                                 (Metric Tons)
                                       
                                        

HCFC Use in Refrigeration and Air-Conditioning
Historically, CFCs were extensively used as refrigerants in the AC and refrigeration industries; by the 1970s, HCFC-22 and R-502 (a blend of CFC-115 and HCFC-22) were also well established refrigerants. On January 1, 1996, the production and import of CFC refrigerants, classified as Class I controlled (ozone-depleting) substances under the CAA Amendments of 1990, were phased out in the U.S. and other industrialized countries. HCFC refrigerants, which deplete the ozone layer to a lesser degree and are classified as Class II controlled substances under the 1990 CAAA, were found acceptable as substitutes for the controlled CFCs in some end use applications. 

Air-Conditioning End-Uses

AC equipment can be categorized as either mobile or stationary. Figure 3-2 below illustrates these categories and identifies those AC end uses for which supply and servicing need projections are estimated in this report.

Mobile air-conditioning systems include all forms of AC that provide cooling to passenger compartments in all types of moving vehicles. This category can be further broken down into motor vehicle air-conditioning for light-duty vehicles and other mobile air-conditioning systems. 

   * Motor vehicle air-conditioning (MVAC) includes AC in the passenger compartments of light duty vehicles -- both cars and trucks (e.g., pick-up trucks, minivans, sport utility vehicles). A variety of refrigerant blends, some of them including HCFCs, are approved for use in the United States by EPA as replacements for CFC-12 in MVACs. However, these blends have not been endorsed by vehicle or system manufacturers for such use, thereby capturing only a small and declining share of the retrofit market, which consists mainly of HFC-134a. HFC-134a is not an ODS; therefore, the light-duty MVAC sector is not considered further in this analysis. 
   * Other mobile air-conditioning includes AC in the passenger compartments of both buses (including school, transit, and tour buses) and trains (including heavy, light, and commuter rail, and Amtrak trains). Although most bus AC systems converted directly from CFC-12 to HFC-134a, the majority of the existing fleet of transit buses, tour buses, and trains are projected to continue to use HCFC-22 in their AC systems.

Stationary air-conditioning includes a wide variety of equipment, further categorized into the following six categories. 

         *       Unitary air-conditioners and heat pumps include both split systems and packaged units and are designed for air circulating, cooling, cleaning, and dehumidifying and sometimes heating in residential and small and large commercial applications. While HCFC-22 systems are still in use, new systems are largely charged with HFC-134a, R-410A, and R-407C refrigerant blends.
         *       Chillers regulate the temperature and humidity in offices, hotels, shopping centers, and other large buildings. There are two major categories of chillers -- centrifugal and positive displacement. Centrifugal chillers are centralized air conditioning systems typically used in larger buildings (e.g., offices, hotels, shopping centers, and other large buildings). Positive displacement chillers are smaller and may be water-cooled or air-cooled. There are three principle types of positive displacement chillers -- 1) reciprocating, 2) screw, and 3) scroll -- each of which is named for the type of compressor employed. HCFC-22 and HCFC-123 chillers are still in use, though a portion of the market is transitioning to R-410A, R-407C, and HFC-134a refrigerants. Historically, these chillers used CFC-12, CFC-11, CFC-114, and R-500 refrigerants. 
   * Dehumidifiers are mechanical refrigeration systems designed to remove moisture from the air by drawing air first over cold evaporator coils and then warm condenser coils, causing the moisture in the air to condense onto the cold coils. Examples include indoor pool dehumidifiers and portable units used to dehumidify basements. Existing dehumidifiers still use HCFC-22 and new systems have transitioned to HFC-134a and R-410A.
   * Water and ground source heat pumps use fluid circulated in a common piping loop as a heat source/sink to cool and heat air. Water-source heat pumps typically use water pumped from a well, lake, or stream as a heat source/sink. Direct expansion geothermal heat pumps circulate refrigerant through piping in the earth. Water and ground source heat pumps historically used HCFC-22; new systems are charged with HFC-134a, R-410A, and R-407C.
   * Window units, also known as room air-conditioners, are small appliances used to condition the air in one room. Window units historically used HCFC-22; new systems are charged with R-410A.
   * Packaged terminal units are ACs or heat pumps that are mounted through the wall. They are often used in hotel rooms, dormitories, or classrooms, and historically used HCFC-22; new systems are charged with R-410A.
   
                 Figure 3-2: Types of Air-Conditioning Systems[a]
                        Air-Conditioning (AC) Equipment
                               Motor Vehicle AC
                          Stationary Air-Conditioning
                                   Water and
                           Ground Source Heat Pumps
                                 Dehumidifiers
                                  Residential
                               Small Commercial
                               Large Commercial
                                Other Mobile AC
                            Mobile Air-Conditioning
                                 Window Units
                      Packaged Terminal AC and Heat Pumps
                                  Centrifugal
                                   Chillers
                                   Positive 
                                 Displacement
                                 Reciprocating
                                     Screw
                                    Scroll
                           Unitary AC and Heat Pumps
                        Air-Conditioning (AC) Equipment
                               Motor Vehicle AC
                          Stationary Air-Conditioning
                                   Water and
                           Ground Source Heat Pumps
                                 Dehumidifiers
                                  Residential
                               Small Commercial
                               Large Commercial
                                Other Mobile AC
                            Mobile Air-Conditioning
                                 Window Units
                      Packaged Terminal AC and Heat Pumps
                                  Centrifugal
                                   Chillers
                                   Positive 
                                 Displacement
                                 Reciprocating
                                     Screw
                                    Scroll
                           Unitary AC and Heat Pumps





  








   
   
   
   

[a]EPA assumes HCFC refrigerants are not used in MVACs (dashed box); shaded end-uses are those for which supply and servicing need projections are estimated in this report.

Refrigeration End-Uses

Refrigeration equipment can be broken down into four categories: domestic refrigeration, refrigerated transport, industrial process refrigeration, and commercial refrigeration. Figure 3-3 below illustrates these categories and identifies those end uses for which supply and servicing need projections are estimated in this report.

Domestic refrigeration includes household refrigerators, household freezers, combination refrigerator/freezer units, and water coolers. For the majority of these equipment types, the refrigerants used do not typically include HCFCs or blends containing HCFCs. Older household freezers sometimes employed HCFC-22; however, because these units are viewed as a minor part of the domestic refrigeration market, this end-use is not further analyzed in this report. 

Refrigerated transport includes refrigeration used in equipment that moves products from one place to another and includes refrigerated ship holds, truck trailers (i.e., reefer trucks), railway freight cars, and other shipping containers. Refrigerated transport units have historically used R-502 (an HCFC-22 blend), but have transitioned to HFC-134a and R-404A.

Industrial process refrigeration (IPR) systems are complex, customized systems used to cool process streams in the chemical, food processing, pharmaceutical, petrochemical, and manufacturing industries. This sector also includes industrial ice machines, equipment used directly in the generation of electricity, and ice rinks. IPR systems with HCFC-22, HCFC-123, and HCFC-124 (as R-401A) are still in use though a portion of this market has transitioned to HFC-134a, R-404A, R-410A, and R-507A. IPR systems historically used CFC-11 and CFC-12.

Commercial refrigeration can be further broken down into three end-uses: 

   * Cold storage warehouses are refrigeration systems with varying designs and charge sizes. They are used to store meat, produce, dairy products, and other perishable goods before and after food processing. Cold storage units historically used CFC-12, R-502, and HCFC-22 refrigerants; new systems are charged with R-404A and R-507A.
   * Retail food systems are used to refrigerate food in commercial retail establishments, such as grocery stores. These systems can be classified as either centralized systems, condensing units, or self-contained units. Centralized retail food systems, also known as remote systems, consist of a series of compressors located in a remote machinery room, providing a cooling medium to display cabinets and cold storage rooms in other parts of the building. The most common form of centralized systems circulate refrigerant throughout the store. Alternatives to these types of systems include secondary loop and distributed systems that largely use HFC refrigerant blends. These large retail food systems historically used CFC-12 and R-502 refrigerants; new systems have transitioned to R-404A, R-507A, and R-407A. Condensing units are large- or small-size refrigeration equipment with one or two compressors and a condenser installed on the roof or in a small machine room. Examples include walk-in refrigerators, coolers, and freezers. Condensing units historically used HCFC-22; new systems are charged with R-404A, HFC-134a, and R-507A refrigerants. Self-contained retail food units, also referred to as stand-alone systems, are factory produced with all the components integrated. Examples include roll-in refrigerators/freezers, under-counter refrigerators/freezers, reach-in refrigerators/freezers, wine and beer coolers, ice cream machines, beverage vending machines, and a variety of stand-alone upright or horizontal display cases (e.g., beverage merchandisers, deli cases). Self-contained refrigeration units historically used CFC-12 refrigerants and have transitioned to HFC-134a, R-404A, R-507A, and CO2 refrigerants. HCFCs were never used in this application.
   * Ice makers are factory-made units used in commercial establishments to produce ice for consumer use (e.g., in hotels, restaurants, and convenience stores). Ice makers are not further analyzed in this report because they do not typically employ HCFCs or blends containing HCFCs. Ice makers moved directly from CFC-12 to HFC-134a.
      
   
                 Figure 3-3: Types of Refrigeration Systems[a]
                            Refrigeration Equipment
                            Refrigeration Equipment


                            Refrigerated Transport
                            Refrigerated Transport
                           Commercial Refrigeration
                           Commercial Refrigeration
                       Industrial Process Refrigeration
                       Industrial Process Refrigeration
                            Domestic Refrigeration
                            Domestic Refrigeration


                            Household Refrigerators
                            Household Refrigerators
                                 Water Coolers
                                 Water Coolers
                              Household Freezers
                              Household Freezers
                                 Retail Food 
                                 Retail Food 
                                  Ice Makers
                                  Ice Makers

                                 Cold Storage
                                 Cold Storage
  [a]S
  
  
  [a]Dashed boxes cover end-uses that are assumed to not use HCFC refrigerants; shaded end-uses are those for which supply and servicing need projections are estimated in this report.  

Table 3-3 presents projected estimates of HCFC refrigerant servicing need for the refrigeration and AC industries. As shown, HCFC-22 represents the majority of the refrigeration and AC market for 2015 to 2025. The Vintaging Model also projects continued use through 2020 for HCFC-124 and through 2025 and beyond of HCFC-123 as a refrigerant in, or to provide service to, equipment manufactured prior to January 1, 2020. Although the Vintaging Model does not project servicing need for HCFC-142b in the 2015-2025 timeframe, other information suggests that HCFC-142b is still in use in niche refrigerant blends. More detail on the projected use of each HCFC in refrigeration and AC applications is provided in the following table.
                                       
Table 3-3: Projected HCFC-22, HCFC-123, HCFC-124, and HCFC-142b Need for 
Refrigeration and Air-Conditioning, 2015-2025 (Metric Tons)[a]
                                     HCFC
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
HCFC-22
                                                                         46,100
                                                                         41,600
                                                                         36,700
                                                                         32,300
                                                                         27,700
                                                                         22,500
                                                                          5,500
HCFC-123
                                                                          2,200
                                                                          2,200
                                                                          2,200
                                                                          2,200
                                                                          2,300
                                                                            600
                                                                            500
HCFC-124
                                                                              5
                                                                              5
                                                                              5
                                                                              4
                                                                              4
                                                                              4
                                                                              -
HCFC-142b
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
                                                                              -
Source: Based on modeling assumptions from EPA (2012).
[a] Changes to assumptions in the Vintaging Model since the 2009 Servicing Tail Report have increased projected servicing need. For more detail on the changes, please see Appendix C.
                   
   * HCFC-22 -- Projected HCFC-22 servicing need from 2015 onward is for AC and refrigeration applications. AC applications include window units, packaged terminal units, residential and commercial unitary AC, chillers, dehumidifiers, water and ground source heat pumps, and non-light duty mobile AC in buses, trains, etc. Refrigeration applications include refrigerated transportation, industrial process refrigeration, and commercial retail food. HCFC-22 is used as both a stand-alone refrigerant as well as a component in refrigerant blends.
   * HCFC-123 -- HCFC-123 is used in the refrigeration and AC sector mainly in centrifugal chillers for industrial process refrigeration and commercial comfort AC. The production and import of virgin HCFC-123 is scheduled for phaseout in 2020 for use in new AC and refrigeration equipment, and in 2030 for use in AC and refrigeration equipment manufactured before January 1, 2020.
   * HCFC-124 -- HCFC-124 is minimally used as a refrigerant; its primary use as a refrigerant is in blends, mainly R-401A, in industrial process and transport refrigeration equipment, as well as R-409A and R-414B in commercial refrigeration applications. As a stand-alone refrigerant, it has found some niche applications that reach high condensing temperatures as well as an alternative for CFC-114 in some naval chillers. Starting in 2020, virgin HCFC-124 can no longer be used in new AC and refrigeration equipment. Starting in 2030, virgin HCFC-124 can no longer be produced or imported to service existing AC and refrigeration equipment. However, its use in blends R-401A, R-401B, R-409A, R-414A, R-414B and others is constrained because those blends also contain HCFC-22. Starting in 2020, HCFC-22 will not be produced or imported for use in these blends. HCFC-124 is also a component of R-416A, which does not contain any other ODS. While feedback from several industry sources indicates there are a minimal number of legacy systems still in use, the number is declining (U.S. HCFC Manufacturer Representatives 2013). 
   * HCFC-142b -- HCFC-142b is used as a constituent of a few refrigerant blends that have historically served as replacements for CFC-12 and R-500 (a blend containing CFC-12 and HFC-152a) medium-sized refrigeration equipment. Based on refrigerant sales data collected by the California Air Resources Board (see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board's Refrigerant Management Program in the docket) and information provided by stakeholders, R-409A (composed of HCFC-22, HCFC-124, and HCFC-142b) and R-414B (composed of HCFC-22, HCFC-124, HCFC-142b and R-600a) are the most common refrigerant blend using HCFC-142b. Although servicing need for R-409A, R-414B and some other niche refrigeration needs are not currently modeled in the Vintaging Model, these sources indicate there is continuing, albeit decreasing, servicing need for HCFC-142b refrigerant blends.
                   
Box 3-2: Summary of Several HCFCs Used in Refrigerant Blends
Often refrigerants are formulated with several substances, such as hydrofluorocarbons (HFCs) or hydrocarbons (e.g., propane, butane, isobutane). Table 3-4 presents the composition of some of the more common refrigerant blends containing HCFCs. 
 Table 3-4: Compositions of Common HCFC Refrigerant Blends (Percent by Weight)
                                     Blend
                                    HCFC-22
                                   HCFC-124
                                   HCFC-142b
                                   HCFC-123
                                     Other
R-401A
                                      53%
                                      34%
                                       
                                                                               
13% HFC-152a
R-402A
                                      38%
                                       
                                       
                                                                               
60% HFC-125, 2% propane (R-290) 
R-409A
                                      60%
                                      25%
                                      15%
                                                                               

R-502
                                     48.8%
                                       
                                       
                                                                               
51.2% CFC-115
                                       
End-uses in which these refrigerant blends containing HCFCs are currently used are presented in the Table 3-5. 
           Table 3-5: HCFC-Containing Refrigerant Blends by End-Use
                         Refrigeration Equipment Type
                               Refrigerant Type
                                       
                                    R-401A
                                    R-402A
                                    R-409A
                                     R-502
Retail Food 
                                       x
                                       x
                                       x
                                       x
Cold Storage
                                       x
                                       x
                                       
                                       x
IPR
                                       x
                                       
                                       
                                       
Transport Refrigeration
                                       x
                                       x
                                       
                                       x
                                       

         Box 3-2: Summary of Several HCFCs Used in Refrigerant Blends
Often refrigerants are formulated with several substances, such as hydrofluorocarbons (HFCs) or hydrocarbons (e.g., propane, butane, isobutane). Table 3-4 presents the composition of some of the more common refrigerant blends containing HCFCs. 
 Table 3-4: Compositions of Common HCFC Refrigerant Blends (Percent by Weight)
                                     Blend
                                    HCFC-22
                                   HCFC-124
                                   HCFC-142b
                                   HCFC-123
                                     Other
R-401A
                                      53%
                                      34%
                                       
                                                                               
13% HFC-152a
R-402A
                                      38%
                                       
                                       
                                                                               
60% HFC-125, 2% propane (R-290) 
R-409A
                                      60%
                                      25%
                                      15%
                                                                               

R-502
                                     48.8%
                                       
                                       
                                                                               
51.2% CFC-115
                                       
End-uses in which these refrigerant blends containing HCFCs are currently used are presented in the Table 3-5. 
           Table 3-5: HCFC-Containing Refrigerant Blends by End-Use
                         Refrigeration Equipment Type
                               Refrigerant Type
                                       
                                    R-401A
                                    R-402A
                                    R-409A
                                     R-502
Retail Food 
                                       x
                                       x
                                       x
                                       x
Cold Storage
                                       x
                                       x
                                       
                                       x
IPR
                                       x
                                       
                                       
                                       
Transport Refrigeration
                                       x
                                       x
                                       
                                       x
                                       

Box 3-2 presents a brief summary of HCFCs used in refrigerant blends.    

HCFC Use in Nonresidential Fire Suppression
Fire-extinguishing applications can be divided into two categories: portable fire extinguishers (i.e., streaming applications) that originally used Halon 1211, and total flooding applications that originally used Halon 1301 or Halon 2402 (EPA 2006). To replace Halon 1211 in streaming applications, the Significant New Alternatives Policy (SNAP) program has listed the use of in-kind substitutes (e.g., CO2, HCFCs, HFCs, fluoroketones) and not-in-kind substitutes (e.g., water, dry chemical, foam) as acceptable. While the SNAP list includes HCFC-123, HCFC-124, and certain HCFC blends for streaming applications, only HCFC-123 and HCFC-124 are used as streaming agents in practice (EPA 2012). HCFC-123 is the primary constituent in Halotron I (also referred to as HCFC Blend B in EPA regulations). Specifically, the blend Halotron I is used in commercial/industrial, maritime, and military applications in the United States (Halotron 2008). HCFC-124 has some niche fire protection applications for specialty marine systems (pleasure boats) from the 1990s that may still be in use but are not modeled by the Vintaging Model. HCFC-124 was primarily used in Europe for fire suppression applications (Hughes Associates, Inc., 2012). This analysis considers fire suppression applications using HCFC-123 only.

In December 2011, House Resolution (HR) 1540 was signed into public law. Section 320, Fire Suppression Agents, amends section 605(a) of the Clean Air Act to allow HCFCs to continue to be used after 2015 for nonresidential fire suppression purposes. Production and import of HCFCs for fire suppression can continue until January 1, 2020, when Article 2F of the Montreal Protocol limits any continued consumption of HCFCs to servicing of refrigeration and AC equipment only. Table 3-5 presents projected servicing need estimates for HCFC-123 for fire suppression systems. 

Table 3-5: Projected HCFC-123 Need for Fire Suppression, 2015-2025 (Metric Tons)
                                     HCFC
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
HCFC-123
                                                                            190
                                                                            200
                                                                            200
                                                                            210
                                                                            210
                                                                           210*
                                                                           210*
Source: EPA (2012).
* In 2020 through 2025, HCFC-123 demand is reported for charging portable fire extinguishers with recycled HCFC-123 based blends.
                   
Alternatives to HCFCs in the fire extinguishing industry include the in-kind gaseous agent substitutes listed above for Halon 1211 including CO2, HFCs such as HFC-236fa, and fluoroketones (C6-perflouroketone also known as Novec(TM) 1230) (EPA 2012).


Projected HCFC Scenarios 
Section 4 presents projections of the number of HCFC-containing units of equipment and the associated servicing needs for 2015 through 2025. Scenarios were developed by investigating various trends that are expected to affect future market needs. Such trends include changes in charge sizes, the transition to alternative refrigerants, changes in refrigerant recovery and reuse practices, and HCFC economics. 

   * Section 4.1 summarizes the projected market size of equipment and the servicing need for HCFC-22 beyond 2015 in the United States.
   * Section 4.2 summarizes the projected market size of equipment and servicing need for HCFC-123 beyond 2015 in the United States.
   * Section 4.3 summarizes the projected market size of equipment and servicing need for HCFC-124 beyond 2015 in the United States.
   * Section 4.4 provides discussion on anticipated HCFC-142b servicing needs based on stakeholder feedback.
   * Section 4.5 discusses the various sources of HCFCs that can be used to meet servicing need, including recycled, reclaimed, and imported (used) HCFCs as well as interpollutant transfers of allowances.
   * Section 4.6 provides projections of servicing need that can be met by reuse and recovery based on three different recovery scenarios.
   * Section 4.7 discusses factors that may affect projections of servicing need and recovery, including: certain equipment specification requirements, the transition to alternative refrigerants, and the stockpiling of refrigerant.
   
Appendix B presents further detail on the estimates provided in Section 4, disaggregating HCFC-22, HCFC-123, and HCFC-124 containing equipment and overall servicing need estimates into end-use specific projections.
HCFC-22
The HCFC-22 equipment and servicing need estimates provided below were developed using EPA's Vintaging Model (EPA 2012). Appendix A provides more detail on the methodology used to develop these projections. Appendix B provides projections disaggregated by end-use.
HCFC-22 Equipment Used Beyond 2015 
The only HCFC-22 equipment that is projected to be in use (i.e., within the installed base) from 2015 onward will be used for refrigeration and AC applications, including window units, packaged terminal units, residential and commercial unitary AC, chillers, dehumidifiers, water and ground source heat pumps, non-light duty mobile AC in buses and trains, retail food, industrial process refrigeration, and transport refrigeration equipment. As presented in Table 4-1, approximately 95.8 million units of AC equipment will be in use in 2015, decreasing from 2015 levels by about 79 percent by 2020, and by over 99 percent by 2025. Approximately 976,600 units of refrigeration equipment will be in use in 2015. The installed base of refrigeration equipment is projected to decrease from 2015 levels by about 52 percent by 2020 and 85 percent by 2025. 
         Table 4-1: Projected Number of HCFC-22 Units (2015-2025)[a,b]
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total AC
                                                                     95,814,200
                                                                     81,732,700
                                                                     67,286,500
                                                                     52,551,500
                                                                     37,024,700
                                                                     20,592,800
                                                                        330,100
Total Refrigeration
                                                                        976,600
                                                                        852,700
                                                                        734,000
                                                                        639,300
                                                                        549,900
                                                                        467,500
                                                                        145,600
Total
                                                                     96,790,800
                                                                     82,585,400
                                                                     68,020,500
                                                                     53,190,800
                                                                     37,574,600
                                                                     21,060,300
                                                                        475,700
[a] Including units that use blends containing HCFC-22. 
[b] Because the estimates for cold storage warehouses are expressed in cubic feet, this equipment type is not included in this table. 
Source: Based on modeling assumptions using EPA (2012). 
Projected HCFC-22 Servicing Needs
Refrigeration and AC equipment commonly requires servicing, which may include adding refrigerant to account for refrigerant losses that occur over time. While the production and import of HCFC-22 was banned for use in new appliances in 2010, it may be permitted for servicing and maintenance purposes until January 1, 2020. Table 4-2 presents projected HCFC-22 servicing need (including that used in blends) for servicing equipment in 2015, 2020, and 2025. 

As shown in Table 4-2, approximately 46,100 metric tons of HCFC-22 are projected to be required to service AC and refrigeration equipment in 2015, of which the majority -- 27,900 metric tons (61%) -- will be used to service AC systems. EPA projects that servicing need for HCFC-22 in AC and refrigeration equipment will decrease to 22,500 metric tons by 2020 and 5,500 metric tons by 2025. The 2015 projections of servicing need exceed the U.S. consumption cap for virgin HCFCs; however, a portion of the servicing needs can be met by using recovered refrigerant, thus decreasing the need for virgin HCFC-22.

     Table 4-2: Projected HCFC-22 Servicing Need (2015-2025) (Metric Tons)
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total AC
                                                                         27,900
                                                                         24,900
                                                                         21,600
                                                                         18,400
                                                                         14,900
                                                                         11,100
                                                                            360
Total Refrigeration
                                                                         18,200
                                                                         16,700
                                                                         15,100
                                                                         13,900
                                                                         12,700
                                                                         11,400
                                                                          5,200
Overall Total
                                                                         46,100
                                                                         41,600
                                                                         36,700
                                                                         32,300
                                                                         27,700
                                                                         22,500
                                                                          5,500
Box 4-1: Sensitivity Analysis on Key Assumptions Affecting HCFC-22 Servicing Demand
System Charge Sizes: This sensitivity analysis explores the impacts of a lower 4 kg charge size for 13 SEER HCFC-22 residential unitary AC equipment rather than the current assumption of approximately 4.8 kg. This change reduces HCFC-22 servicing need by about 2-7 percent per year from 2015 to 2023.
Leak Rates: Leak rates for residential unitary AC, large and medium retail food refrigeration, and cold storage units may be lower as a result of partnership programs such as GreenChill and more careful servicing. Lower loss rates can reduce HCFC-22 servicing need by about 10-23 percent per year between 2015 and 2025. 
Lifetimes: The ban on HCFC-22 in new equipment manufactured after 2010 and price increases for HCFC-22 are likely to have prompted some end-users to transition away from HCFC-22 equipment earlier than the end of the equipment's lifetime. This sensitivity analysis explores the impact on servicing need if 20 percent of residential unitary AC, industrial process refrigeration units, and retail food equipment transitions out of HCFC-22 five years earlier. These changes can reduce HCFC-22 servicing need by 9-14 percent per year between 2015 and 2025.



Box 4-1: Sensitivity Analysis on Key Assumptions Affecting HCFC-22 Servicing Demand
System Charge Sizes: This sensitivity analysis explores the impacts of a lower 4 kg charge size for 13 SEER HCFC-22 residential unitary AC equipment rather than the current assumption of approximately 4.8 kg. This change reduces HCFC-22 servicing need by about 2-7 percent per year from 2015 to 2023.
Leak Rates: Leak rates for residential unitary AC, large and medium retail food refrigeration, and cold storage units may be lower as a result of partnership programs such as GreenChill and more careful servicing. Lower loss rates can reduce HCFC-22 servicing need by about 10-23 percent per year between 2015 and 2025. 
Lifetimes: The ban on HCFC-22 in new equipment manufactured after 2010 and price increases for HCFC-22 are likely to have prompted some end-users to transition away from HCFC-22 equipment earlier than the end of the equipment's lifetime. This sensitivity analysis explores the impact on servicing need if 20 percent of residential unitary AC, industrial process refrigeration units, and retail food equipment transitions out of HCFC-22 five years earlier. These changes can reduce HCFC-22 servicing need by 9-14 percent per year between 2015 and 2025.



Source: Based on analysis using EPA (2012). 
Note: Totals may not sum due to independent rounding.
While assumptions in EPA's Vintaging Model are continually updated to refine inputs, the projections of future servicing needs for HCFC-22 can be affected by outside factors that are not fully reflected in the estimates. In addition, as HCFC use decreases and the phaseout approaches, modeling with precision becomes more difficult. In recognition of these challenges, sensitivity analyses on the impact of key assumptions on HCFC-22 servicing need were conducted in response to information from stakeholders. As described in Box 4-1, altering assumptions about system charge sizes, leak rates, and lifetimes can modestly to significantly decrease projected servicing need. For example, more careful servicing practices that result in lower loss rates can reduce servicing need by up to 23 percent per year past 2020. Additional details on these sensitivity analyses are presented in Appendix D. 

Figure 4-1 displays the breakdown of HCFC-22 servicing need by AC and refrigeration equipment type for 2015 and 2020. As shown, residential AC, retail food refrigeration equipment, and IPR are projected to account for over 90 percent of HCFC-22 servicing need in 2015. By 2020, these three end-uses are still projected to account for 90 percent of HCFC-22 servicing need although IPR's portion of servicing need is slightly higher than 2015 and residential AC is slightly lower. This trend is partly the result of the modeled lifetimes for these end uses; EPA assumes an average lifetime for residential AC of 15 years, while IPR systems are assumed to last 25 years. Differences between modeled average lifetimes and practiced lifetimes can impact actual servicing need for residential and AC equipment, as examined further in Box 4-1.

Figure 4-1: HCFC-22 Need for Servicing Refrigeration and Air-Conditioning Equipment, 
                                 by End-Use[a]
                                     2020
                  Total Consumption for Servicing: 22,500 MT
                                     2015
                  Total Consumption for Servicing: 46,100 MT
                                     2020
                  Total Consumption for Servicing: 22,500 MT
                                     2015
                  Total Consumption for Servicing: 46,100 MT
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       










[a] Other Equipment" includes window units, packaged terminal units, water and ground source heat pumps, other mobile AC, and refrigerated transport.
Source: Based on data analysis using EPA (2012). 

HCFC-123
The HCFC-123 equipment and servicing need estimates provided below were developed using EPA's Vintaging Model (EPA 2012). Appendix A provides more detail on the methodology used to develop these projections. Appendix B provides projections disaggregated by end-use.

HCFC-123 Equipment Used Beyond 2015
HCFC-123 is used in the refrigeration and AC sector mainly in centrifugal chillers for industrial process refrigeration and commercial comfort AC. The production and import of virgin HCFC-123 can be continued for use in refrigeration and AC equipment manufactured prior to 2020; by 2020 its remaining permissible use is for the servicing of this equipment until 2030, when all production and import is banned. A 2011 amendment to section 605(a) of the Clean Air Act also allows HCFC-123, a component of Halotron I, to be used for nonresidential fire suppression applications. Halotron I is used for commercial/industrial, maritime, and military applications in the United States (American Pacific 2008). Stakeholders indicated that they plan to sell extinguishers with virgin material until 2019 and to continue selling extinguishers with recycled material in 2020 and beyond. 

Alternatives to HCFC-123 used in fire suppression include the in-kind gaseous agent substitutes listed by SNAP for Halon 1211 including CO2, HFCs (e.g., HFC-236fa), and fluoroketones (C6-perflouroketone, also known as Novec(TM) 1230) (EPA 2012). A new chemical streaming agent, 2-bromo-3,3,3-trifluoropropene (2-BTP), has been recently submitted for review to SNAP and EPA's New Chemicals Program under the Toxic Substances Control Act. According to a recent report of the UNEP Technology and Economic Assessment Panel, "if the development of [2-BTP] proves commercially successful, owing to its fire extinguishing characteristics being closer to Halon 1211 and it having a low environmental impact, it would be the natural replacement for [HCFC-123] and Halon 1211  -  particularly in the aviation industry" (UNEP 2013).

As presented in Table 4-3, approximately 47,600 units of AC equipment using HCFC-123 are estimated to be in use in 2015. The number of HCFC-123 AC units is projected to decrease from 2015 levels by 16 percent by 2025. Approximately 12,600 units of HCFC-123 refrigeration units are estimated to be in use in 2015, decreasing by approximately 5 percent by 2025. EPA estimates 1,422,100 HCFC-123 (essentially Halotron I) fire suppression units in use in 2015, which is expected to decrease to 871,100 by 2025. This estimate for fire suppression is similar to the estimated of number of units provided by a stakeholder in the industry. 

Table 4-3: Projected Number of HCFC-123 Refrigeration, Air-Conditioning, and Fire Suppression Units (2015-2025)
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total AC
                                                                         47,600
                                                                         48,900
                                                                         50,400
                                                                         50,900
                                                                         51,400
                                                                         49,500
                                                                         39,800
Total Refrigeration
                                                                         12,600
                                                                         13,300
                                                                         13,900
                                                                         14,400
                                                                         14,800
                                                                         14,300
                                                                         12,000
Fire Suppression
                                                                      1,422,100
                                                                      1,464,800
                                                                      1,508,700
                                                                      1,554,000
                                                                      1,600,600
                                                                     1,487,800*
                                                                       871,100*
Total
                                                                      1,482,300
                                                                      1,527,000
                                                                      1,573,000
                                                                      1,619,300
                                                                      1,666,800
                                                                      1,551,600
                                                                        922,900
Source: Based on analysis using EPA (2012). 
* Estimates of fire suppression units do not include units charged with recycled material. 
Projected HCFC-123 Needs
Table 4-4 presents projected HCFC-123 need for charging and servicing equipment before 2020 and for servicing equipment only after 2020. Table 4-4 also provides the projected HCFC-123 servicing need for nonresidential fire suppression systems from 2015 to 2020. In 2015, approximately 2,200 metric tons of HCFC-123 will be required for servicing and charging refrigeration, AC, and fire suppression units, of which the majority -- 1,200 metric tons (55%) -- will be used to service AC systems. Servicing need for HCFC-123 in AC and refrigeration equipment is projected to decrease to 470 metric tons by 2025. The Montreal Protocol prohibits the production and import of virgin HCFCs for fire suppression beginning January 1, 2020; however, stakeholders have indicated that new extinguishers with recycled material will continue to be sold after this date. Servicing needs for HCFC-123 fire extinguishers sold with recycled material is modeled as 210 metric tons from 2019 onwards. 

Table 4-4: Projected HCFC-123 Refrigeration, Air-Conditioning, and Fire Suppression Servicing Need (2015-2025) (Metric Tons)
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total AC
                                                                          1,200
                                                                          1,200
                                                                          1,200
                                                                          1,200
                                                                          1,200
                                                                            220
                                                                            180
Total Refrigeration
                                                                            770
                                                                            800
                                                                            830
                                                                            850
                                                                            860
                                                                            370
                                                                            290
Total Fire Suppression
                                                                            190
                                                                            200
                                                                            200
                                                                            210
                                                                            210
                                                                           210*
                                                                           210*
Overall Total
                                                                          2,200
                                                                          2,200
                                                                          2,200
                                                                          2,200
                                                                          2,300
                                                                            800
                                                                            700
Numbers may not add up due to independent rounding.ting a placeholder here in the meantime.t the same valueseparate analysis.2) Source: Based on analysis using EPA (2012). 
* In 2020-2025, HCFC-123 demand is projected for charging portable fire extinguishers with recycled HCFC-123 based blends.
Note: Numbers may not sum due to independent rounding.
HCFC-124
HCFC-124 servicing need is projected by the Vintaging Model through 2020 (EPA 2012). Appendix B provides projections disaggregated by end-use.
HCFC-124 Equipment Use Beyond 2015
HCFC-124 is used in the refrigeration sector mainly in industrial process refrigeration and medium retail food refrigeration (small condensing units). The production and import of virgin HCFC-124 can be continued for use in refrigeration equipment manufactured prior to 2020; by 2020 its remaining permissible use is for the servicing of this equipment until 2030, when all production and import is banned. 

As presented in Table 4-5, approximately 27,400 units of refrigeration equipment using HCFC-124 are estimated to be in use in 2015. The number of HCFC-124 refrigeration units is projected to decrease to zero by 2025. 

    Table 4-5: Projected Number of HCFC-124 Refrigeration Units (2015-2025)
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total Refrigeration
                                                                         27,400
                                                                         26,500
                                                                         25,200
                                                                         23,500
                                                                         21,400
                                                                         18,900
                                                                              -
Total
                                                                         27,400
                                                                         26,500
                                                                         25,200
                                                                         23,500
                                                                         21,400
                                                                         18,900
                                                                              -
Source: Based on analysis using EPA (2012). 
Projected HCFC-124 Needs
Table 4-6 presents projected minimal HCFC-124 need for charging and servicing equipment before 2020 and for servicing equipment only after 2020. In 2015, approximately 4 metric tons of HCFC-124 will be required for servicing and charging refrigeration units. Servicing need for HCFC-124 in AC and refrigeration equipment is projected to decrease to zero metric tons by 2025. 

Table 4-6: Projected HCFC-124 Refrigeration Servicing Need (2015-2025) (Metric Tons)
                                Equipment Type
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
Total Refrigeration
                                                                              5
                                                                              5
                                                                              5
                                                                              4
                                                                              4
                                                                              4
                                                                              -
Total
                                                                              5
                                                                              5
                                                                              5
                                                                              4
                                                                              4
                                                                              4
                                                                              -
Source: Based on analysis using EPA (2012). 

While the Vintaging Model predicts minimal servicing need for HCFC-124, feedback from stakeholders and refrigerant sales data collected by the California Air Resources Board indicates the servicing need may be higher than projected (see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board's Refrigerant Management Program in the docket). This difference is in large part a result of servicing need for R-409A and R-414B in refrigeration applications, which is not modeled in the Vintaging Model.	
HCFC-142b
HCFC-142b is predominantly used in refrigerant blends that serve as replacements for CFC-12 and R-500 medium-sized refrigeration equipment. The production and import of virgin HCFC-142b is allowed until 2020 for servicing refrigeration equipment manufactured prior to 2010. 

The Vintaging Model projects that servicing need for HCFC-142b will be zero after 2015 (EPA 2012); however, the Model does not include servicing need for some niche HCFC-142b blends such as R-409A. According to refrigerant sales data collected by the California Air Resources Board, R-409A equipment is still in use (see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board's Refrigerant Management Program in the docket). HCFC manufacturers have also indicated that there will be continued, declining need for HCFC-142b in niche refrigerant blends beyond 2015.

HCFC Sources
Since January 1, 2010, only existing sources of HCFC-22 and a controlled quantity of virgin HCFC-22 (limited through allowance allocations distributed by EPA) are available to the AC and refrigeration industry to meet servicing need. Virgin HCFC-123 and HCFC-124 will be permitted for use in appliances manufactured prior to January 1, 2020 and virgin HCFC-142b will be permitted for use in appliances manufactured prior to January 1, 2010. Beyond 2020, only existing sources of HCFC-123 and HCFC-124, and a controlled quantity of virgin HCFC-123 and HCFC-124 (limited through allowance allocations distributed by EPA), will be made available to meet servicing need. Existing sources of HCFCs for servicing equipment include: 

         1.    HCFC refrigerants that are recovered and either recycled or reclaimed before reuse. Under EPA regulations at 40 CFR 82.156, refrigerants containing HCFCs must be recovered. After the recovery process, the refrigerant held in the storage container may be:
         a.	Recycled (i.e., cleaned through the use of recycling equipment) and recharged back into the equipment from which it came;
         b.	Recycled and used in other equipment of the same owner; or
         c.	Reclaimed (shipped to an EPA-certified reclaimer) prior to resale to a new owner.
         2.    Import of used HCFCs that companies can acquire, if the import is preauthorized by EPA, through a petition process.
         3.    The conversion of allocations from other chemicals to HCFCs as allowed under the final allocation rules.

Each of these existing sources of HCFCs is described in more detail below. 
Recycled HCFC Refrigerants
Recovered HCFC refrigerants are often recycled prior to being used again in equipment. The recycling process cleans the refrigerant for reuse without meeting all the requirements of reclamation, discussed further below. HCFC refrigerants are commonly recovered from a piece of equipment, adequately cleaned, and then recharged into the same piece of equipment using a recycling device (EPA 2003b).

EPA regulations allow for the recharge of used refrigerant without subsequent reclamation for refrigerants that are recovered and charged back into the same appliance or to another appliance if those appliances have the same owner. Several companies, such as supermarket chains, employ recycling plans through which the refrigerant is recovered when dismantling or converting one establishment's equipment and reused to service equipment at another facility with the same ownership. Stakeholder feedback has indicated that recovery and direct reuse is a widespread practice amongst supermarkets in large retail food equipment (ICF 2011). Some supermarkets have sufficient recovered HCFC-22 in-stock for servicing such that there is no anticipated need for virgin material before their equipment is retired (ICF 2011). EPA does not collect quantitative data on the amount of HCFC-22, HCFC-123, HCFC-124, or HCFC-142b that is recycled.
Reclaimed HCFC Refrigerants
Refrigerants that are resold to be used in other equipment must be reclaimed to a standard level of purity based on the AHRI Standard 700. EPA certified reclaimers are approved to reprocess used refrigerant to at least the purity level based on the AHRI 700 Standard.

In 2012, the amount of HCFC-22 reclaimed by EPA-certified reclaimers totaled approximately 4,264 metric tons, or 9.4 million pounds (EPA 2013). Reclamation of HCFC-22 increased by approximately 13 percent between 2011 and 2012; the higher price of HCFC-22 is a likely factor in encouraging increased reclamation of the refrigerant. Fewer quantities of the refrigerant blend R-502, composed of 48.8 percent HCFC-22 and 51.2 percent CFC-115, are also being reclaimed, with only 14 metric tons, or 30,748 pounds reported for 2012 (EPA 2013). The amount of HCFC-123 reclaimed in 2012 totaled approximately 143 metric tons, or 316,340 pounds (EPA 2013). Reclamation data from 2003 to 2012 is presented in Table 4-7.  
       Table 4-7: Reclaimed HCFC-22 and HCFC-123 by Year (Metric Tons) 
                                       
                                     2003
                                     2004
                                     2005
                                     2006
                                     2007
                                     2008
                                     2009
                                     2010
                                     2011
                                     2012
HCFC-22
                                                                          1,976
                                                                          3,280
                                                                          2,800
                                                                          3,872
                                                                          3,716
                                                                          4,556
                                                                         3,422 
                                                                         3,622 
                                                                         3,776 
                                                                          4,264
R-502
                                                                             41
                                                                             48
                                                                             25
                                                                             52
                                                                             34
                                                                             40
                                                                             62
                                                                            13 
                                                                            19 
                                                                             14
HCFC-123
                                                                            50 
                                                                           114 
                                                                           145 
                                                                           144 
                                                                           103 
                                                                           124 
                                                                           198 
                                                                           165 
                                                                           154 
                                                                            143
  Note: HCFC-124 and HCFC-142b reclamation data is not available.
  Source: EPA (2013).

As 2015 approaches, both the price of HCFC-22 and reclamation of HCFC-22 may increase. Stakeholders report reclamation capacity of 19,700 MT or more that can be mobilized to meet service need, should the price of HCFC-22 increase or the availability of HCFC-22 decrease sufficiently to provide increased market incentive for recovery and reclamation (ICF 2011). A more detailed discussion on HCFC-22 economics and recovery and reuse practices is provided in Section 4.5, "Factors Affecting Projections."
Imports of Used HCFCs 
Unlike virgin HCFCs, used HCFCs are not subject to Montreal Protocol or Clean Air Act restrictions on consumption or use. However, in creating the allocation system for the use of HCFCs, EPA developed a shipment-by-shipment petition process for importing used HCFCs as described in 40 CFR 82.24 (EPA 2003a).The petition process ensures that HCFCs have been used (and were not newly produced) prior to import. For each shipment of used HCFC greater than five pounds, the importer needs to petition EPA at least 40 working days before the shipment is to leave the country of export. EPA reviews and verifies data in the petition and issues either an objection notice or a non-objection notice to the prospective importer. The projections in this report do not specifically include the potential future quantities obtained from the import of used HCFC-22, HCFC-123, HCFC-124, or HCFC-142b. 
Interpollutant Transfers of Allowances 
Another source of HCFCs can result from allowance holders transferring their allowances from one HCFC to HCFC-22, HCFC-123, HCFC-124, or HCFC-142b which is permitted on an annual and ODP-weighted basis. Section 607 of the Clean Air Act permits year-by-year inter-pollutant transfers of production and consumption allowances. Section 607(b) requires that EPA's rules are to permit "a production allowance for a substance for any year to be transferred for a production allowance for another substance for the same year," plus a 0.1 percent offset to benefit the environment. For example, converting 10,000 allowances of HCFC-124 (with an ODP of 0.022) would result in 3,996 allowances of HCFC-22 (with an ODP of 0.055). Allowance holders have converted their allowances to meet market needs historically; this practice is expected to continue, however, the projections in this analysis do not quantitatively assess the potential future quantities that could be obtained from converted allocations.
Meeting Refrigeration and AC Service Need 
Although limited production of virgin HCFCs may be allowed to service appliances until 2020 and 2030 through production and consumption allowances, this analysis indicates that, with industry effort, a significant portion of the need for HCFCs for servicing can be met with previously used refrigerant that is recovered and then recycled or reclaimed. Increased amounts of recovered HCFCs are a source made available as a result of the venting prohibition EPA has established under Section 608 of the CAA (EPA 2004a). 

To determine the potential amounts of used refrigerant available to service equipment, EPA used its Vintaging Model to develop three theoretical scenarios, representing low, baseline and high recovery, to estimate: 1) the amount of recovered HCFCs potentially available to meet servicing need of other equipment still in use; and 2) the subsequent remaining quantity needed to satisfy servicing need. The three scenarios investigated are summarized in Table 4-8. Because no servicing need is projected in the Vintaging Model for HCFC-142b, no recovery scenarios are modeled for this HCFC. 

As shown, for HCFC-22, different recovery rates are modeled for the baseline, lower, and higher recovery scenarios. For HCFC-123 and HCFC-124, the recovery rate modeled by the Vintaging Model is used for all three scenarios. The baseline recovery rates for HCFC-123 and HCFC-124 are significantly higher (90 percent for HCFC-123 and between 80 and 90 percent for HCFC-124) than for HCFC-22, given HCFC-123 and HCFC-124's primary use in larger systems, including chillers, IPR, and medium retail food. 

                   Table 4-8: Summary of Recovery Scenarios
                                   Scenario
                           Assumptions for 2015-2025

                                   HCFC-22 
                            HCFC -123 and HCFC-124
Lower Recovery
35 percent of refrigerant from retired or retrofitted equipment is recovered and available for reuse in equipment (i.e., a 35 percent recovery rate). The remaining 65 percent is not available for reuse.
The percentage of refrigerant from retired or retrofitted equipment that is available for reuse in equipment is equal to the recovery rate modeled by EPA's Vintaging Model (approximately 80 to 90% industry-wide).
Baseline Recovery
The percentage of refrigerant from retired or retrofitted equipment that is available for reuse in equipment is equal to the recovery rate modeled by EPA's Vintaging Model (approximately 50% industry-wide).

Higher Recovery
65 percent of refrigerant from retired or retrofitted equipment is recovered and available for reuse in equipment (i.e., a 65 percent recovery rate). The remaining 35 percent is not available for reuse.

Note: HCFC-123 has a recovery rate of 90% and HCFC-124 has a baseline recovery rate of 80%.

In developing the scenarios using the Vintaging Model, EPA projected the amount of recovered HCFC based on the quantity available from decommissioned or retrofitted equipment. While refrigerant recovered from equipment during servicing can also be available for reuse in other equipment, this potential source is not included in these scenarios for several reasons. First, it is projected to be minimal in net terms (i.e., refrigerant recovered during service would likely be returned to the same equipment from which it was recovered). Also, according to industry sources, refrigerant recovered during service events primarily originates from commercial and industrial equipment (i.e., equipment with relatively large charges). Refrigerant is rarely recovered during the servicing of small equipment because these units tend not to be overcharged or leaking (Home Energy Center 2006, Airgas 2006). Additionally, only a small portion of all servicing events conducted on commercial and industrial equipment involve the refrigerant circuit, and when recovering refrigerant to perform repairs is necessary, often only a section of the refrigerant charge is isolated and recovered, not the entire charge.

To estimate refrigerant recovery and reuse, EPA assumed that a certain percentage of refrigerant is recovered from decommissioned or retrofitted equipment. It is important to note that not all refrigerant is assumed to be recovered. While EPA has regulations prohibiting intentional venting, for the purposes of this analysis it is appropriate to create scenarios that assume less than the full charge of refrigerant is recovered at equipment end-of-life. For example, in many instances, equipment is disposed of after a catastrophic failure, which might have resulted in a large or even complete loss of the refrigerant. Also, when equipment is removed from service, there can be losses associated with previous leaks and during attempts to recover the remaining refrigerant. It is also possible that owners or technicians disposing of a piece of equipment might not comply with the regulations and might vent the refrigerant. 

This analysis then assumes that the entire pool of recovered refrigerant re-enters the market (see Appendix A for more details) and can be used to meet a portion of the servicing need for HCFCs. The results of the three recovery scenarios are presented in the sections that follow.
Servicing Need and Recovery Projections for HCFC-22
Table 4-9 to Table 4-11 summarizes the projections for HCFC-22 under each recovery scenario. Table 4-9 shows that modeled HCFC-22 supplied from recovery or reuse that is available under a Lower Recovery Scenario would meet 32 percent of servicing need in 2015, 72 percent in 2020, and 100 percent of servicing need by 2023. Under this scenario, the quantity of recovered HCFC-22 projected to be available before 2023 is inadequate to meet all of the projected servicing need. Given the ban on remaining production and import of virgin HCFC-22 in 2020, these modeling results suggest that industry may face a shortfall for 2020, 2021, and 2022. Shortfalls in 2015 and 2016 also exist based on limits set under the Montreal Protocol (see Section 4.6.4). 

For the Baseline Recovery Scenario (Table 4-10) and Higher Recovery Scenario (Table 4-11), the modeled amount of recovered material is sufficient to meet total servicing need for HCFC-22 equipment starting in 2020 and 2019, respectively. In the Baseline Recovery and Higher Recovery Scenarios, the amount of recovered material is more than double the servicing need starting in 2024 and 2023, respectively. 

As noted in Section 4.1.2, the sensitivity analyses conducted on key modeling assumptions suggests that HCFC-22 servicing need could be marginally to significantly less than what is presented in the following tables, depending on the extent to which leak rates, charge sizes, and equipment lifetimes are lower than what the Vintaging Model currently assumes. Information provided by stakeholders indicates that increasing prices for HCFC-22 may have motivated servicing technicians to be more careful with refrigerant and equipment owners to move more rapidly to alternatives. While the impact of these sensitivity analyses on HCFC-22 recovery or reuse has not been explicitly modeled, the results suggest that the need for virgin HCFC-22 may also be less than what is presented in the following tables.

Table 4-9: Lower Recovery Scenario: 35% Recovery Rate
Summary of Projected HCFC-22 Supply and Servicing Need (Metric Tons)[a]
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                    2025[b]
Total HCFC-22 Servicing Need 
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500
Modeled HCFC-22 Supplied from Recovery or Reuse 
                                    14,600
                                    14,000
                                    14,700
                                    14,400
                                    15,000
                                    16,200
                                    14,300
                                    12,100
                                    10,900
                                     9,500
                                     4,800
Estimated Supply Needed to Satisfy Remaining Servicing Need
                                    31,500
                                    27,500
                                    22,000
                                    18,000
                                    12,700
                                     6,300
                                     3,600
                                     1,700
                                       0
                                       0
                                      800
% of Total Servicing Need Supplied by Modeled Recovery/Reuse
                                      32%
                                      34%
                                      40%
                                      44%
                                      54%
                                      72%
                                      80%
                                      88%
                                   >100%
                                   >100%
                                      86%
[a] Based on analysis using EPA (2012).
[b] The values presented for 2025 do not take into account the possibility of carrying over surplus HCFC-22 from 2023 and 2024. The carryover of surplus HCFCs could help meet the total servicing need for HCFC-22 in 2025. 

                  Table 4-10: Baseline Recovery Rate Scenario
    Summary of Projected HCFC-22 Supply and Servicing Need (Metric Tons)[a]
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Total HCFC-22 Servicing Need 
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500
Modeled HCFC-22 Supplied from Recovery or Reuse 
                                    21,300
                                    20,800
                                    21,800
                                    21,100
                                    21,800
                                    23,100
                                    20,700
                                    18,100
                                    17,000
                                    15,600
                                    10,800
Estimated Supply Needed to Satisfy Remaining Servicing Need
                                    24,800
                                    20,700
                                    14,900
                                    11,300
                                     5,900
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
% of Total Servicing Need Supplied by Modeled Recovery/Reuse
                                      46%
                                      50%
                                      59%
                                      65%
                                      79%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
[a] Based on analysis using EPA (2012).
Note: Totals may not sum due to independent rounding.

Table 4-11: Higher Recovery Scenario: 65% Recovery Rate 
Summary of Projected HCFC-22 Supply and Servicing Need (Metric Tons)[a]
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Total HCFC-22 Servicing Need 
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500
Modeled HCFC-22 Supplied from Recovery or Reuse 
                                    27,200
                                    26,100
                                    27,300
                                    26,700
                                    27,800
                                    30,100
                                    26,500
                                    22,400
                                    20,200
                                    17,700
                                     8,900
Estimated Supply Needed to Satisfy Remaining Servicing Need
                                    18,900
                                    15,500
                                     9,400
                                     5,700
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
% of Total Servicing Need Supplied by Modeled Recovery/Reuse
                                      59%
                                      63%
                                      74%
                                      83%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
[a] Based on analysis using EPA (2012).
Note: Totals may not sum due to independent rounding.
Need and Recovery Projections for HCFC-123
Table 4-12 summarizes the projections for HCFC-123 under the Baseline Recovery rate scenario. HCFC-123 need is modeled for both servicing and initial charging of new AC equipment and fire suppression systems; however, only servicing need is assumed to be able to be met by recovered material. The table provides the modeled servicing need for HCFC-123, the amount of HCFC-123 servicing need that can be met by recovery/reuse, as well as additional need for new equipment.

As shown in Table 4-12, the projected amount of recovered and reused HCFC-123 will meet total servicing need needs starting in 2020. Chillers and IPR equipment have high baseline recovery rates (90%), thus larger volumes of refrigerant can be reused for servicing. Unlike HCFC-22, HCFC-123 servicing need is not expected to decrease significantly over the 2015 to 2025 timeframe.
 
Table 4-12: Baseline Recovery Rate Scenario 
Summary of Projected HCFC-123 Supply and Servicing Need (Metric Tons)[a]
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Total Servicing Need (MT)
                                      610
                                      600
                                      590
                                      600
                                      610
                                      580
                                      560
                                      540
                                      520
                                      490
                                      470
Additional Servicing Need for Charging New Equipment (MT)[b]
                                     1,600
                                     1,600
                                     1,600
                                     1,600
                                     1,700
                                      210
                                     210  
                                     210  
                                     210  
                                     210  
                                     210  
Anticipated HCFC-123 Supplied from Recovery or Reuse (MT)
                                      330
                                      330
                                      330
                                      820
                                      920
                                     970 
                                    1,020 
                                    1,030 
                                    1,040 
                                    1,050 
                                    1,060 
Estimated Supply Needed to Satisfy Remaining Servicing and New Equipment Need
                                     1,900
                                     1,900
                                     1,900
                                     1,400
                                     1,400
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
% of Total Servicing Need Supplied by Anticipated Recovery/Reuse
                                      15%
                                      15%
                                      15%
                                      36%
                                      40%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
[a] Based on analysis using EPA (2012). 
[b] Servicing Need for Charging New Equipment" refers to need associated with new refrigeration and AC units (before 2020) and charging fire suppression systems. Starting on January 1, 2020, the HCFC-123 need is reported for charging portable fire extinguishers with recycled HCFC-123 based blends.
Note: Totals may not sum due to independent rounding.

Servicing Need and Recovery Projections for HCFC-124
Table 4-13 summarizes the projections for HCFC-124 under the Baseline Recovery rate scenario. HCFC-124 need is modeled for servicing of new refrigeration equipment. The table provides the modeled servicing need for HCFC-124 and the amount of HCFC-124 servicing need that can be met by recovery/reuse.

As shown, the projected amount of recovered and reused HCFC-124 will meet total servicing needs starting in 2020. Medium Retail Food and IPR equipment have high baseline recovery rates (80%), thus larger volumes of refrigerant can be reused for servicing. 

                  Table 4-13: Baseline Recovery Rate Scenario
   Summary of Projected HCFC-124 Supply and Servicing Need (Metric Tons)[a]
                                       
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Total HCFC-124 Servicing Need 
                                       5
                                       5
                                       5
                                       4
                                       4
                                       4
                                       3
                                       2
                                       1
                                     <1
                                       -
Modeled HCFC-124 Supplied from Recovery or Reuse 
                                     <1
                                       1
                                       1
                                       1
                                       2
                                       9
                                      17
                                      14
                                      11
                                       7
                                       4
Estimated Supply Needed to Satisfy Remaining Servicing Need
                                       4
                                       4
                                       4
                                       3
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
% of Total Servicing Need Supplied by Modeled Recovery/Reuse
                                      8%
                                      16%
                                      24%
                                      31%
                                      41%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                   >100%
                                       -
[a] Based on analysis using EPA (2012). As mentioned previously, feedback from stakeholders and CARB data indicate this number is low.
Note: Totals may not sum due to independent rounding.

Summary of HCFC-22, HCFC-123, and HCFC-124 Servicing Need and Recovery Projections
Figure 4-2, Figure 4-3, and Figure 4-4 illustrate the projected supply of recovered refrigerant available to meet servicing need under the Lower Recovery Scenario, the Baseline Recovery Scenario, and Higher Recovery Scenario, as well as its subsequent importance in meeting future servicing need. These figures display servicing need and supply projections of HCFC-22, HCFC-123, and HCFC-124 summed together and expressed in ODP-weighted quantities to compare to the ODP-weighted HCFC consumption cap for the United States. The solid line indicates the total HCFC projected servicing need between 2015 and 2025 while the dotted line indicates the U.S. HCFC consumption cap (the value of the HCFC consumption cap does not change between the three scenarios). Shading in the figures represents supply. The dark grey shading indicates the portion of projected supply that is available through recovered and reusable HCFCs under the scenario in question. The remaining portion of servicing need that cannot be met is shaded a lighter grey to represent virgin supply that would be required to meet modeled servicing need.

Figure 4-2 illustrates that a virgin supply that exceeds the U.S. HCFC consumption cap would be necessary to meet modeled servicing need during some years between 2015 and 2025, given the amount of material recovered under this scenario. Virgin HCFCs are needed to meet modeled servicing need under the Lower Recovery Scenario through 2022 and in 2025. 

Figure 4-3 and Figure 4-4 illustrate that, between 2015 and 2020, the projected supply from recovered HCFCs combined with a smaller supply from virgin material that is below the U.S. cap is sufficient to meet modeled HCFC servicing need under the Baseline Recovery and Higher Recovery Scenarios. In addition, beyond 2019, the projected supply from recovered HCFCs exceeds the HCFC servicing need projections. 

       Figure 4-2: Total Projected HCFC Demand, Lower Recovery Scenario
                                       
       Figure 4-2: Total Projected HCFC Demand, Lower Recovery Scenario
                                       


















  
  
  
  
  Note: In 2025, HCFC-22 recovery is not projected to fully meet service need under this scenario.


      Figure 4-3: Total Projected HCFC Demand, Baseline Recovery Scenario
                                       
      Figure 4-3: Total Projected HCFC Demand, Baseline Recovery Scenario
                                       






























       Figure 4-4: Total Projected HCFC Demand, Higher Recovery Scenario
                                       

       Figure 4-4: Total Projected HCFC Demand, Higher Recovery Scenario
                                       






















Factors Affecting Projections 
Several market dynamics affect the projections of future servicing needs for HCFCs. Certain equipment specification requirements, the transition to alternative refrigerants, surplus inventory of refrigerant, as well as equipment manufactured with HCFCs for sale after the phaseout can all potentially alter the projected servicing scenarios. Each of these issues is discussed further below. 
Transitioning to Alternative Refrigerants
A wide range of alternative refrigerants found acceptable under EPA's SNAP program are available in the AC and refrigeration sector. Hydrofluorocarbon (HFC) alternatives, including HFC-134a, R-410A (composed of HFC-32/HFC-125), R-407C (composed of HFC-32/HFC-125/HFC-134a), R-404A (composed of HFC-125/HFC-143a/HFC-134a), and R-507A (composed of HFC-125/HFC-143a), are most widely used in refrigeration and AC equipment. Other alternatives -- found acceptable under EPA's SNAP program for specific end-uses, and sometimes with use conditions -- are not only ozone-friendly but also climate-friendly, including hydrocarbons, carbon dioxide, ammonia, and lower-GWP fluorinated refrigerants, such as HFO-1234ze(E). The pace of transition to equipment using these alternatives has varied by industry and type of equipment. 

Production and import of new refrigeration/AC equipment using HCFC-22 has been prohibited in the United States as of January 1, 2010. Several AC and refrigeration equipment manufacturers had discontinued production of new equipment using HCFC-22 well before this phaseout date (Hill Phoenix 2009; Hussmann 2009; Kysor/Warren 2009; Johnson Controls 2009). Such actions were consistent with those taken in the mid-1990s, when the refrigeration and AC industries phased out CFC refrigerants from new production chillers, refrigerators, motor vehicle air conditioners, and other products two or more years before the 1996 CFC consumption phaseout.

Feedback from numerous points in the supply chain has indicated that sales of alternative refrigerants have increased dramatically since 2011. As the phaseout progresses, the percentage of HCFC-22 servicing need met by retrofit refrigerants is expected to rise, thereby further reducing the need for HCFC-22 and adding to the potential inventory of recovered refrigerant.
Air-Conditioning Industry
HFC-134a, R-410A, and R-407C are replacing HCFC-22 in new stationary and mobile AC equipment. Some mobile AC equipment has been using alternatives since the early 1990s, with some buses and trains using HFC-134a, and some heavy rail cars using R-407C (WMATA 2005; Amtrak 2005; Motorcoach Training 2005; Greyhound 2005; Carrier Corporation 2005b). Stationary AC equipment using R-410A has been commercially available since 1996 (HARDI 2004), and is the standard refrigerant in all systems installed after 2009 in the U.S. residential market (J.P. Morgan 2011). Manufacturers of R-410A saw significant growth in 2010 driven by the conversion to R-410A from HCFC-22 in the U.S. Between 2009 and 2010, R-410A residential AC units as a percentage of all condensing unit shipments rose from 55% to 90% due to the phaseout of HCFC-22 (J.P. Morgan 2011). 
 
Since January 1, 2010, new appliances charged with HCFC-22 could no longer be sold on the market; however, dry-shipped replacement parts (e.g., condensing units, compressors) are still allowed. Consumers have the option of selecting to repair existing HCFC-22 units rather than switching to alternatives. A replacement compressor would cost $1,800 to $2,000, approximately 40 percent of the cost of an R-410A system replacement (J.P. Morgan 2011). This analysis does not take into account the possibility that repairs may extend the lifetime of existing HCFC-22 appliances but the impact of extended equipment lifetime due to dry-shipped replacement parts is considered in Appendix D. EPA's assumption that residential AC typically lasts for 15 years is consistent with the U.S. Department of Energy (DOE)'s estimates for the average life of a system, which is estimated at 15-20 years (DOE 2012). 
Refrigeration Industry
Advanced refrigeration technologies (e.g., distributed systems and secondary loop systems) represent an estimated 40% of new equipment sales and are generally charged with HFC refrigerants (Hill Phoenix 2009; Hussmann 2009). The current trend in the supermarket industry is to use HFC refrigerant blends, particularly R-407A. There has been a shift from R-404A towards blends with lower GWPs, such as R-407A and R-407C (Verisae 2009). Carbon dioxide has been used as a secondary fluid in supermarkets since 2006 and more recently as a primary refrigerant. It is anticipated that the use of carbon dioxide as a primary refrigerant will become increasingly common in commercial and industrial applications (Shecco 2012).

Based on an industry survey, HCFC-22 accounts for approximately 40% of the refrigerants (by weight) still used by supermarkets (Garry 2012). Of the 2,445 retailers surveyed, most did not plan to fully replace HCFC-22 until 2015 or 2020 (Garry 2012).
Recovery and Reuse Practices
As indicated in the total projected servicing need scenarios presented in Section 4.4, recovered HCFC-22 and HCFC-123 that is recycled, inventoried, or reclaimed will likely need to increase to satisfy future servicing needs that cannot be met through virgin supplies. Key findings from this analysis include:
HCFC-22
* In 2015, the amount of recovered HCFC-22 refrigerant is projected to range from 21,300 to 27,200 metric tons, depending on the percentage of total available refrigerant from retired or converted equipment that is recovered and reused.
* Since virgin production of HCFC-22 for domestic use stops in 2020, recovery would have to be at approximately the baseline recovery scenario rate (51 percent) or higher to meet estimated servicing need (assuming no existing inventory, and not considering the assumptions in the sensitivity analyses).
* In 2025, the availability of recovered HCFC-22 refrigerant under the baseline and higher recovery scenarios would provide adequate supplies to meet estimated servicing need. In the lower recovery scenario, servicing need could potentially be met if surplus HCFC-22 from previous years is carried over.
HCFC-123
* In 2015, the amount of recovered HCFC-123 refrigerant is projected to be 330 metric tons, based on a baseline refrigerant recovery rate of 90 percent.
* Starting in 2020, recovered HCFC-123 refrigerant is expected to meet estimated servicing need.
HCFC-124
* In 2015, the amount of recovered HCFC-124 refrigerant is projected to be less than 1 metric ton. 
   By 2020, the availability of recovered HCFC-124 refrigerant would provide adequate supplies to meet estimated servicing need.

Although there is the potential for supply tightness the closer it gets to 2020, proper maintenance practices during the lifetime of equipment, recovery practices at the time of equipment disposal or decommissioning, and the full penetration of reclaim and reuse practices can greatly reduce the likelihood of future shortfalls. 

The use of recovery procedures during the lifetime of equipment and at the time of decommissioning reduces potential emissions of refrigerant and increases the available supply of refrigerant. End-users of AC and refrigeration equipment must have equipment installed by trained technicians. They must also have their equipment properly maintained to reduce incidences of major leaks. Service technicians must take efforts to isolate components or recover refrigerants prior to service as venting (releasing) HCFC (and CFC and HFC) refrigerant when making repairs is illegal. Service practices that involve locating and repairing leaks in lieu of "topping off" leaking systems further ensure future supplies of HCFC refrigerant. As with servicing procedures, the venting of refrigerant during decommissioning is illegal. The AC and refrigeration community, including end-users, service technicians, and all affected stakeholders, must position itself for approaching phaseouts of HCFCs by using proper recovery techniques and complying with regulations that are in place to promote the growth of HCFC recovery and reuse.
Recycling, Reuse, and Managing Inventory
With proper storage tanks, a reserve of recovered HCFC-22 can be collected, stored, and accessed to service equipment owned by the same company years later, when HCFC-22 is expected to be less affordable and less available. A report released in 1995 by the Food Marketing Institute (FMI) included a survey issued to supermarket operators on the use of refrigerant management plans (RMPs) as a strategy to ensure an adequate supply of CFC refrigerants for use after the December 31, 1995, CFC production phaseout. Of those surveyed, 52 percent were banking recovered CFC refrigerant, an activity adopted primarily by store operators with 11 or more stores (FMI 1995). 

Industry sources suggest that recovery and direct reuse is a widespread practice amongst supermarkets in large retail food equipment; however, the extent can vary significantly between chains, depending largely on the extent to which supermarkets are converting their HCFC-22 equipment to alternatives (ICF 2011). Some supermarkets who have converted a substantial proportion of their HCFC-22 equipment indicated that they have sufficient recovered HCFC-22 in-stock for servicing such that they do not anticipate a need to purchase any more virgin material in the future (ICF 2011). 

Feedback from industry sources indicates there was a significant amount of HCFC-22 in the supply chain leading into 2012 (ICF 2011). Additionally, EPA collected data on HCFC-22 inventory from nine companies in early fall, 2013 using Clean Air Act section 114 authority. Additional discussion of HCFC-22 inventory levels is included in Appendix E. Some of the pre-2012 inventory was consumed in 2012 to meet servicing needs but both anecdotal feedback and inventory data continue to indicate that there is a significant amount of inventory that can help meet servicing need in 2015 and beyond. 
HCFC-22 Economics
Another factor that affects the projections of HCFC-22 servicing supply and need is the cost of virgin and reclaimed HCFC-22. Prior to 2012, the price of HCFC-22 remained low. The relatively low cost of virgin HCFC-22 in the market, and the costs associated with sending recovered HCFC-22 to reclaimers, decreased the incentives to properly manage HCFC-22 in existing systems (e.g., fixing leaks, recovering and recycling refrigerant, etc.).
 
As the allowed production and import of virgin HCFC-22 decreased in 2012 and 2013, HCFC-22 price increased. As a result, interest in and demand for recovery and reuse, reclamation, and retrofit options increased significantly. As the supply of virgin HCFC-22 continues to decrease, demand for recovered and reclaimed refrigerant and demand for HCFC-22 alternatives is expected to increase. All of these factors could affect realized lifetimes for equipment, which could decrease future servicing need. A sensitivity analysis shows that shortening realized lifetimes by five years in 20 percent of equipment could result in a 9 to 14 percent decrease in HCFC-22 service need between 2015 and 2025. Additional details can be found in Appendix D.
Increasing Seasonal Energy Efficiency Ratio (SEER)
In 2001, the DOE set a stricter seasonal energy efficiency ratio (SEER) standard for residential unitary ACs and heat pumps. The minimum efficiency standard of residential unitary ACs and heat pumps was raised by 30 percent to a 13 SEER for all such units manufactured for sale on or after January 23, 2006 (DOE 2001; DOE 2004). These increased SEER requirements are reflected in the Vintaging Model. The projections provided in this analysis do not consider the need for HCFC-22 to service higher efficiency residential AC equipment installed after 2015 because all new HCFC-22 systems were banned starting in 2010 (see Appendix A for more details). 

The Vintaging Model currently assumes that the 13 SEER vintage of HCFC-22 residential unitary AC equipment uses a charge size of approximately 4.76 kg. Appendix D presents an analysis that examines the potential effects on service need of a lower charge size of 4 kg for HCFC-22 13 SEER residential unitary AC equipment. This change results in a 2 to 7 percent decrease in total HCFC-22 service need across all refrigeration and AC end-uses between 2015 and 2023. As modeled, all HCFC-22 residential unitary AC equipment has reached end-of-life by 2023, so there is no longer servicing need for that end-use after 2023.
Lower Loss Rates 
EPA's GreenChill program is committed to reducing refrigerant emissions by lowering equipment leak rates or eliminating leaks entirely within the commercial refrigeration industry. Approximately 20 percent of U.S. supermarkets participate in GreenChill. Increased participation in this program can lower the industry-wide leak rate for HCFC-22 equipment and therefore further decrease HCFC-22 servicing need. Since 2008, the average commercial refrigeration emissions rate across GreenChill partners has been 13 percent, which is nearly half the national average of 25 percent. In addition, the ban on HCFC-22 in new equipment manufactured after 2010 (and the resultant increase in price for virgin and reclaimed HCFC-22) may also prompt service technicians to be more careful during servicing and encourage end-users to have leaks fixed more frequently, particularly for larger equipment, where the financial benefits of leak-tightness are more apparent. 

Both of these factors can affect projections of future servicing needs for HCFC-22, particularly in residential unitary AC, large retail food, medium retail food, and cold storage. Reducing HCFC-22 loss rates was found to result in a 10 to 23 percent reduction in HCFC-22 servicing needs. Details on this sensitivity analysis are presented in Appendix D.


Conclusion
On January 1, 2015, production, import, introduction into interstate commerce and use of HCFCs are banned except for on-going refrigeration and AC service needs for equipment manufactured on or before December 31, 2019 and for nonresidential fire suppression. To support development of the allocation levels that will allow the U.S. to comply with the Montreal Protocol's 2015 and 2020 reduction steps, this report provides projections on the quantity of HCFC-22, HCFC-123, and HCFC-124 needed for (a) servicing AC and refrigeration equipment manufactured before January 1, 2020; (b) charging new AC and refrigeration equipment between 2015 and 2020 (HCFC-123 only); and (c) nonresidential fire suppression applications before January 1, 2020.
 
Under the Baseline and Higher Recovery scenarios developed in this analysis, future HCFC servicing needs can be met by using recovered refrigerant and an amount of virgin refrigerant allowable under the United States' Montreal Protocol cap. If recovery and reuse is lower than expected (i.e., the lower recovery rate scenario), the refrigeration and AC industry could face the potential risk of a shortage of HCFC-22 starting in 2015, however, this is unlikely. Alternatively, if leak rates, practiced equipment lifetimes, and charge sizes are lower than what the Vintaging Model currently assumes -- as considered in the sensitivity analysis in Appendix D -- servicing need, as well as the need for virgin supply, could be significantly lower than what is presented below. 

The tables below summarize total projected HCFC-22, HCFC-123, and HCFC-124 servicing need in 2015, 2020, and 2025 compared to the ODP-weighted HCFC consumption cap. The percentage shown in parentheses is the percent of servicing need met by either recovered or virgin HCFCs. Concluding points are also provided on the implications of the three recovery and reuse scenarios. 

   *    In 2015, the projected servicing need for HCFC-22, HCFC-123, and HCFC-124 is equal to 2,580 ODP-weighted MT. As shown in Table 5-1, under a higher recovery scenario, 58 percent of this need could be met with recovered refrigerant; and 45 percent of servicing need can be met at the baseline recovery rate. Only 31 percent of the total servicing need can be met under the lower recovery rate scenario, leading to a potential shortage of about 244 ODP-weighted metric tons in 2015.

Table 5-1: Comparison of HCFC Servicing and New Equipment Servicing Need Projections and Necessary Supply Projections by Source (ODP-Weighted Metric Tons and Percent), 2015
2015
                             Lower Recovery Rate 
                            Baseline Recovery Rate 
                             Higher Recovery Rate 
Cap[a]
                                     1,524
Servicing Need
                                     2,580
Necessary Supply 

  Recovered
                                   812 (31%)
                                  1,177 (46%)
                                  1,502 (58%)
  Virgin
                                  1,524 (59%)
                                  1,402 (54%)
                                  1,078 (42%)
Shortfall
                                   244 (10%)
                                    0 (0%)
                                    0 (0%)
        [a] HCFC consumption cap expressed in ODP-weighted metric tons.
              Source: Based on modeling assumptions using EPA (2012).

* In 2020, the HCFC consumption cap is reduced to 0.5 percent of the baseline, or 76.2 ODP-weighted metric tons. Projected servicing need for 2020 is 1,255 ODP-weighted MT. As shown in Table 5-2 under the baseline and higher recovery scenarios, sufficient supplies of recovered material will be available to meet servicing needs, and no shortage is expected. For the lower recovery scenario, 73 percent of the total servicing need can be met by recovered and reused material, resulting in a shortage of at least 269 ODP-weighted metric tons. EPA regulations prohibit consumption of HCFC-22 and HCFC-142b in 2020, but allow consumption of HCFC-123 and HCFC-124. While this analysis projects that all servicing need for HCFC-123 can be met from recovered supplies, it is worthwhile to note that the total projected HCFC-123 servicing need of 580 metric tons (11.6 ODP-Tons) is 15% of the total HCFC cap.

   Table 5-2: Comparison of HCFC Servicing Need Projections and Necessary Supply Projections by Source (ODP-Weighted Metric Tons and Percent), 2020
2020
                              Lower Recovery Rate
                            Baseline Recovery Rate 
                             Higher Recovery Rate
Cap[a]
                                     76.2
Servicing Need
                                     1,255
Necessary Supply 

  Recovered
                                   910 (73%)
                                 1,289 (100%)
                                 1,673 (100%)
  Virgin
                                   76.2 (6%)
                                    0 (0%)
                                    0 (0%)
Shortfall
                                   269 (21%)
                                    0 (0%)
                                    0 (0%)
              [a] HCFC consumption cap expressed in ODP-weighted metric tons.
              Source: Based on modeling assumptions using EPA, 2012.
             
   *    In 2025, HCFC servicing need is projected at 318 ODP-weighted MT (Table 5-3). There is no projected shortfall in any of the scenarios considered. For the lower recovery scenario, recovered and reused supplies can meet 89% of the total servicing need. The remaining need can be met with virgin materials without exceeding the consumption cap. No virgin material is expected to be needed for the baseline and higher recovery scenarios. While the Clean Air Act allows consumption of HCFC-123 and HCFC-124 until 2030, EPA has not yet proposed allowances for the 2020-2029 timeframe. While this analysis projects that all servicing need for HCFC-123 can be met from recovered supplies, it is worthwhile to note that the total projected HCFC-123 servicing need of 680 metric tons (13.7 ODP-Tons) is 18% of the total HCFC cap.
     
Table 5-3: Comparison of HCFC Servicing Need Projections and Necessary Supply Projections by Source (ODP-Weighted Metric Tons and Percent), 2025
2025
                              Lower Recovery Rate
                            Baseline Recovery Rate
                             Higher Recovery Rate
Cap[a]
                                     76.2
Servicing Need
                                      318
Necessary Supply 

  Recovered
                                   284 (89%)
                                  616 (100%)
                                  509 (100%)
  Virgin
                                   34 (11%)
                                    0 (0%)
                                    0 (0%)
Shortfall
                                    0 (0%)
                                    0 (0%)
                                    0 (0%)
        [a] HCFC consumption cap expressed in ODP-weighted metric tons to represent allocations of HCFC-22 and HCFC-123.
        Source: Based on modeling assumptions using EPA, 2012.

   *    Although no servicing need for HCFC-142b is projected from 2015 to 2020, stakeholder feedback and industry data from California indicate that there is still equipment using HCFC-142b and that there will be continued, but limited, refrigerant servicing need beyond 2015. 

Projections of future HCFC supply and servicing need vary depending on various market trends as addressed in this report. More rapid equipment transitions, reductions in loss rates through careful servicing and programs such as GreenChill, and lower charge sizes in more efficient equipment may result in lower service need, and consequently lower need for virgin supply. The projections in this report provide only some of the information necessary for taking initial steps in determining post-2015 servicing needs for HCFC-22, HCFC-123, HCFC-124, and HCFC-142b equipment.

 Appendix A: Methodology Used to Calculate Projected Servicing Needs
This appendix outlines the methodology used to calculate the projected servicing and new chemical need of AC, refrigeration, and fire suppression equipment using HCFC-22, HCFC-123 and HCFC-124. This appendix contains two sections:
   * Section A.1 provides an overview of EPA's Vintaging Model (EPA 2012), which was used to establish the estimates of units of equipment using HCFC-22 and HCFC-124 for servicing need beyond 2015 and HCFC-123 for new equipment and servicing beyond 2015. 
   * Section A.2 discusses the limitations to the servicing projections presented in this report.
    A.1 EPA's Vintaging Model
          Box A-1: Developing and Maintaining EPA's Vintaging Model

The Vintaging Model synthesizes data from a variety of sources, including:
   *      EPA's ODS Tracking System and submissions to the SNAP program, both maintained by the U.S. EPA Stratospheric Protection Division;
   *      Published literature from the United Nations Environment Programme (UNEP) Technical Options Committees, the Alternative Fluorocarbons Environmental Acceptability Study (AFEAS), and those provided in industry-related and EPA conference proceedings; and
   *      Numerous representatives at companies and trade associations, such as the Alliance for Responsible Atmospheric Policy, the Air-Conditioning Heating and Refrigeration Institute (AHRI), the Association of Home Appliance Manufacturers (AHAM), and the Alliance of Automobile Manufacturers. 

In some instances the unpublished information that EPA uses in the model is classified as Confidential Business Information (CBI). The annual emissions inventories of chemicals are aggregated in such a way that CBI cannot be inferred. 

The Vintaging Model is continually updated to improve assumptions and modeling techniques and refine inputs based on information received from these sources. EPA shares the revised assumptions and results of model improvements with industry through publications such as this one as well as through presentations, such as those given at the April 2007 Spring Meetings of AHRI. 

Since 2009, the refrigeration and air-conditioning sectors of the Vintaging Model have been updated multiple times. In 2012, an update to the large, medium, and small retail food end-uses had an impact on the projected service, leak, and new chemical demand, as well as disposal recovery. In addition, changes to the small commercial and residential unitary AC end-uses also affected the service demand of HCFC-22.
          Box A-1: Developing and Maintaining EPA's Vintaging Model

The Vintaging Model synthesizes data from a variety of sources, including:
   *      EPA's ODS Tracking System and submissions to the SNAP program, both maintained by the U.S. EPA Stratospheric Protection Division;
   *      Published literature from the United Nations Environment Programme (UNEP) Technical Options Committees, the Alternative Fluorocarbons Environmental Acceptability Study (AFEAS), and those provided in industry-related and EPA conference proceedings; and
   *      Numerous representatives at companies and trade associations, such as the Alliance for Responsible Atmospheric Policy, the Air-Conditioning Heating and Refrigeration Institute (AHRI), the Association of Home Appliance Manufacturers (AHAM), and the Alliance of Automobile Manufacturers. 

In some instances the unpublished information that EPA uses in the model is classified as Confidential Business Information (CBI). The annual emissions inventories of chemicals are aggregated in such a way that CBI cannot be inferred. 

The Vintaging Model is continually updated to improve assumptions and modeling techniques and refine inputs based on information received from these sources. EPA shares the revised assumptions and results of model improvements with industry through publications such as this one as well as through presentations, such as those given at the April 2007 Spring Meetings of AHRI. 

Since 2009, the refrigeration and air-conditioning sectors of the Vintaging Model have been updated multiple times. In 2012, an update to the large, medium, and small retail food end-uses had an impact on the projected service, leak, and new chemical demand, as well as disposal recovery. In addition, changes to the small commercial and residential unitary AC end-uses also affected the service demand of HCFC-22.
EPA's Vintaging Model was developed as a tool for estimating the annual chemical emissions from industrial sectors that have historically used ODS in their products. Emissions are estimated from the following end-use sectors: 1) Air-Conditioning and Refrigeration; 2) Foams; 3) Aerosols; 4) Solvents; 5) Fire-Extinguishing; and 6) Sterilants. Within these sectors, there are over 60 independently modeled end-uses. The model requires information on the market growth for each of the end-uses, as well as a history and projection of the market transition from ODS to alternatives. As ODS are phased out, a percentage of the market share originally filled by the ODS is allocated to substitutes.
The model, named for its method of tracking the emissions of annual "vintages" of new equipment that enter into service, is a "bottom-up" model. This means it models the consumption of controlled ozone-depleting substances and their substitutes based on:
   1)      Estimates of the quantity of equipment or products sold, serviced, and retired or retrofitted each year, and 
   2)      The quantity of the chemical required to manufacture and/or maintain the equipment. 

The model makes use of this market information to build an inventory of in-use stocks of equipment and quantities of ODS/ODS substitutes in each of the end-uses. 

Emissions are estimated by applying annual leak rates, service emission rates, and disposal emission rates to consumption data for each vintage of equipment. Emissions from AC and refrigeration equipment are split into two categories: emissions during equipment lifetime and disposal emissions. The first category includes the amount of chemical leaked during equipment operation and the amount of chemical emitted during service. Consumption required to service or refill equipment is driven by the need to replace such losses, and therefore, emissions during the lifetime of equipment are equal to consumption for servicing (since it is assumed that all leaked refrigerant is eventually replaced). Emissions, and therefore, consumption from leakage and servicing can be expressed as follows:
     
     Esj = (la + ls) x Σ Qcj-i+1 for i=1-->k 
     Where:
     Es = 	Emissions from Equipment Serviced. Emissions in year j from normal leakage and servicing of equipment.
     la = 	Annual Leak Rate. Average annual leak rate during normal equipment operation (expressed as a percentage of total chemical charge).
     ls = 	Service Leak Rate. Average leakage during equipment servicing (expressed as a percentage of total chemical charge).
     Qc = 	Quantity of Chemical in New Equipment. Total amount of a specific chemical used to charge new equipment in a given year by weight.
     i = 	Counter, runs from 1 to lifetime (k).
     j = 	Year of emission.
     k = 	Lifetime. The average lifetime of the equipment.

The assumptions used in this calculation range by equipment, refrigerant, and vintage, reflecting that as new technologies replace older ones, improvements in their leak, service, and disposal emission rates are assumed to occur.

For the purpose of this analysis, the following data from EPA's Vintaging Model were compiled and summarized for the AC and refrigeration sector:
   1) Consumption for Servicing, which is equal to the need to service (i.e., refill) existing equipment. These data are back-calculated using service and leak emissions because the quantity emitted during the lifetime of equipment drives the need to replace such losses. These estimates are further distinguished between consumption of virgin and recycled/reclaimed chemical. The model assumes that a certain percentage of refrigerant, which varies by end-use, is recovered from discarded equipment. The model then assumes a "best-case" scenario in which all recovered and re-usable refrigerant re-enters the market. See Section A.2 for further discussion on this "recovery pool."
   2) Need for New Equipment, which is equal to the amount of chemical needed to fill new equipment. This estimate is further distinguished between consumption of virgin and recycled/reclaimed chemical.
   2)  Number of Units of Equipment, which is equal to, for "year X"', the number of units existing in "year X-1" plus the number of new units produced in "year X" minus the number of units disposed in "year X". 
      For example:
            No. of Units in 1999 = No. of Units in 1998 + New Units in 1999  -  Units Disposed in 1999

Estimates from EPA's Vintaging Model are often cross-checked with actual historical data from EPA's ODS Tracking System, which tracks actual ODS production and consumption (including import and export) by U.S. companies. The Model's virgin manufacture parameter is considered to be most comparable to the Montreal Protocol's definition of consumption (i.e., production plus imports minus exports). In EPA's Vintaging Model, the Virgin Manufacture parameter is calculated to be any need for consumption (either for new equipment or servicing) that cannot be met through recycled or recovered material; no distinction is made in the Vintaging Model between whether that need is met through domestic manufacturing or imports. As shown in Figure A-1, estimates from the model generally align to actual consumption from 1993 to 2011.


  Figure A-1: Comparison of EPA's Vintaging Model Estimates for Virgin Manufacture
             and ODS Tracking System Data for HCFC-22 Consumption
                                       

Table A-1 presents the input assumptions used to develop the projections in this report. The loss rates represent the percent of the total charge that leaks in a given year plus the amount, on an annual basis, emitted at service, expressed as a percentage of total chemical charge. Because the amount lost from leaks and servicing is annualized, equipment is assumed to reach the end of its lifetime with a full charge. EPA's Vintaging Model then applies a "recovery rate," which refers to the percent of total charge of the equipment that is recovered and reused at the time of disposal. These recovery rates represent averages, intended to capture the range of possible practices occurring at disposal. 
Growth rate assumptions are also provided in Table A-1. The growth rates refer to the growth of the equipment market for each end-use as a whole and are not specific to the refrigerant. When the transition to different equipment and different refrigerants occur, the input assumptions are adjusted to account for these changes. 
               Table A-1: Input Assumptions, Years 2015 to 2025
                              Current Refrigerant
                              Equipment Type and
                           Original ODS Refrigerant
                                Charge Size[a]
                                   Loss Rate
                                Growth Rate[b]
                                 Recovery Rate
                               Lifetime (Years)
                               Manufactured From
                                 AC Equipment
                                       
                                    HCFC-22
HCFC-22 Residential Unitary A/C 
                                       3
                                      14%
                                     0.8%
                                      35%
                                      15
                                   1992-2005
                                    HCFC-22
HCFC-22 Residential Unitary A/C 
                                       5
                                      14%
                                     0.8%
                                      35%
                                      15
                                   2006-2009
                                    HCFC-22
HCFC-22 Small Commercial Unitary AC
                                       8
                                      11%
                                     0.8%
                                      40%
                                      15
                                   1992-2009
                                    HCFC-22
HCFC-22 Large Commercial Unitary AC
                                      15
                                      10%
                                     0.8%
                                      40%
                                      15
                                   1992-2009
                                    HCFC-22
HCFC-22 Water & Ground Source Heat Pumps
                                       4
                                      5%
                                     0.8%
                                      57%
                                      20
                                   1992-2009
                                    HCFC-22
HCFC-22 Dehumidifiers
                                       0
                                      1%
                                     0.2%
                                      50%
                                      11
                                   1985-2009
                                    HCFC-22
HCFC-22 Packaged Terminal Units
                                       1
                                      5%
                                     0.8%
                                      35%
                                      12
                                   1992-2009
                                    HCFC-22
HCFC-22 Window Units
                                       1
                                      1%
                                     5.0%
                                      50%
                                      12
                                   1985-2009
                                    HCFC-22
CFC-12 School & Tour Buses
                                       5
                                      10%
                                     2.6%
                                      50%
                                      12
                                   1994-2006
                                    HCFC-22
HCFC-22 Transit Buses
                                       8
                                      44%
                                     2.6%
                                      50%
                                      12
                                   1985-2008
                                    HCFC-22
CFC-11 Centrifugal Chillers
                                      700
                                      14%
                                     0.5%
                                      80%
                                      25
                                   1991-1995
                                    HCFC-22
CFC-11 Centrifugal Chillers
                                      700
                                      5%
                                     0.5%
                                      80%
                                      25
                                   1996-2009
                                   HCFC-123
CFC-11 Centrifugal Chillers
                                      440
                                      1%
                                     0.5%
                                      90%
                                      25
                                 1993-Present
                                    HCFC-22
CFC-12 Centrifugal Chillers
                                      721
                                      8%
                                     0.5%
                                      80%
                                      27
                                   1991-1995
                                    HCFC-22
CFC-12 Centrifugal Chillers
                                      721
                                      5%
                                     0.5%
                                      80%
                                      27
                                   1996-2009
                                   HCFC-123
CFC-12 Centrifugal Chillers
                                      453
                                      1%
                                     0.5%
                                      90%
                                      27
                                 1993-Present
                                    HCFC-22
Reciprocating Chillers
                                      230
                                      6%
                                     0.2%
                                      80%
                                      20
                                   1993-1998
                                    HCFC-22
Reciprocating Chillers
                                      230
                                      1%
                                     0.2%
                                      80%
                                      20
                                   1999-2009
                                    HCFC-22
Screw Chillers
                                      300
                                      1%
                                     0.5%
                                      80%
                                      20
                                   1996-2009
                                    HCFC-22
Scroll Chillers
                                      240
                                      1%
                                     0.5%
                                      80%
                                      20
                                   1996-2009
                                    HCFC-22
R-500 Chillers
                                      926
                                      11%
                                     0.5%
                                      80%
                                      27
                                   1991-1995
                                    HCFC-22
R-500 Chillers
                                      926
                                      5%
                                     0.5%
                                      80%
                                      27
                                   1996-2009
                                   HCFC-123
R-500 Chillers
                                      582
                                      1%
                                     0.5%
                                      90%
                                      27
                                 1993-Present
                            Refrigeration Equipment
                                       
                                    HCFC-22
CFC-12 Cold Storage
                                   <0.01
                                      20%
                                     2.5%
                                      80%
                                      20
                                   1990-2009
                                    HCFC-22
HCFC-22 Cold Storage
                                   <0.01
                                      22%
                                     2.5%
                                      80%
                                      20
                                   1985-1992
                                    HCFC-22
HCFC-22 Cold Storage
                                   <0.01
                                      20%
                                     2.5%
                                      80%
                                      20
                                   1992-2009
                                     R-502
R-502 Cold Storage
                                   <0.01
                                      25%
                                     2.5%
                                      80%
                                      20
                                   1985-1995
                                    HCFC-22
R-502 Cold Storage
                                   <0.01
                                      20%
                                     2.5%
                                      80%
                                      20
                                   1990-2009
                                    HCFC-22
CFC-12 Large Retail Food
                                     1,800
                                      30%
                                     0.8%
                                      80%
                                      18
                                   1991-1999
                                    HCFC-22
CFC-12 Large Retail Food
                                     1,360
                                      30%
                                     0.8%
                                      80%
                                      18
                                   2000-2009
                                    HCFC-22
R-502 Large Retail Food
                                     1,800
                                      30%
                                     0.8%
                                      80%
                                      18
                                   1990-1999
                                    HCFC-22
R-502 Large Retail Food
                                     1,800
                                      30%
                                     0.8%
                                      80%
                                      18
                                   1995-1999
                                    HCFC-22
R-502 Large Retail Food
                                     1,360
                                      30%
                                     0.8%
                                      80%
                                      18
                                   2000-2009
                                    HCFC-22
HCFC-22 Large Condensing Units (Medium Retail Food)
                                      25
                                      15%
                                     0.9%
                                      80%
                                      20
                                   1985-2009
                                    R-402A
HCFC-22 Large Condensing Units (Medium Retail Food)
                                      25
                                      15%
                                     0.9%
                                      80%
                                      20
                                   1995-2005
                                    HCFC-22
HCFC-22 Small Condensing Units (Medium Retail Food)
                                       3
                                      8%
                                     0.9%
                                      80%
                                      20
                                   1985-2009
                                    R-402A
HCFC-22 Small Condensing Units (Medium Retail Food)
                                       3
                                      8%
                                     0.9%
                                      80%
                                      20
                                   1995-2005
                                    R-401A
HCFC-22 Small Condensing Units (Medium Retail Food)
                                       3
                                      8%
                                     0.9%
                                      80%
                                      20
                                   1995-2005
                                    HCFC-22
CFC-12 Small Retail Food
                                       1
                                      8%
                                     0.8%
                                      35%
                                      20
                                   1990-2008
                                    HCFC-22
CFC-11 Industrial Process Refrigeration
                                      952
                                      10%
                                     2.5%
                                      80%
                                      25
                                   1991-2009
                                   HCFC-123
CFC-11 Industrial Process Refrigeration
                                      598
                                      5%
                                     2.5%
                                      90%
                                      25
                                   1992-2004
                                   HCFC-123
CFC-11 Industrial Process Refrigeration
                                      598
                                      5%
                                     2.5%
                                      90%
                                      25
                                 2005-Present
                                    HCFC-22
CFC-12 Industrial Process Refrigeration
                                      992
                                      10%
                                     2.5%
                                      80%
                                      25
                                   1991-2009
                                   HCFC-123
CFC-12 Industrial Process Refrigeration
                                      623
                                      5%
                                     2.5%
                                      90%
                                      25
                                   1992-2004
                                   HCFC-123
CFC-12 Industrial Process Refrigeration
                                      623
                                      4%
                                     2.5%
                                      90%
                                      25
                                 2005-Present
                                    R-401A
CFC-12 Industrial Process Refrigeration
                                      850
                                      5%
                                     2.5%
                                      90%
                                      25
                                   1995-1999
                                    HCFC-22
HCFC-22 Industrial Process Refrigeration
                                     9,100
                                      16%
                                     2.5%
                                      80%
                                      25
                                   1985-1992
                                    HCFC-22
HCFC-22 Industrial Process Refrigeration
                                     9,100
                                      12%
                                     2.5%
                                      80%
                                      25
                                   1992-2009
Source: VM IO File_v4.4_11.6.12
[a] Charge size presented in kilograms. Cold storage charge size presented in kilograms/cubic foot.
[b] The growth rate applies to new consumption/virgin manufacture for products entering the market. For example, in the window units market, any year's consumption for new equipment is five percent greater than the previous year's consumption.

Table A-2 presents the assumptions used to model the transition from HCFC-22, HCFC-123, and HCFC-124 to alternatives for each end use. Only those end-uses that have been using HCFC-22, HCFC-123, or HCFC-124, or have in whole or in part transitioned to use HCFC-22, HCFC-123, HCFC-124, are shown. The first column of the table presents the HCFC-22, HCFC-123, and HCFC-124 equipment types by the refrigerants that they originally used. The second column presents the refrigerants that enter the market and are used in new equipment in place of HCFC-22, HCFC-123, or HCFC-124. These refrigerants begin to enter the new-equipment market in the year presented in the third column and fully penetrate this market by the date presented in the fourth column, after which they continue to make up that portion of the market. The final column indicates the percent of the HCFC-22, HCFC-123, and HCFC-124 new-equipment market that the given substitute refrigerant replaces by the transition end date. All transitions are assumed to occur linearly between the transition start and end dates. Each row represents a different vintage of equipment that can have different properties (e.g., charge size or leak rate) in addition to start date for the transition to the substitute, the end date to reach assumed market penetration, and assumed market penetration from the other vintages of equipment. By combining multiple transitions to different refrigerants and over different time periods, the Vintaging Model mimics actual, non-linear transitions that may occur.

         Table A-2: Transition to Alternatives Assumptions of EPA's 
Vintaging Model for HCFC-22, HCFC-123, and HCFC-124 Refrigeration and AC Equipment[a]
                                       1
                                        2
                                        3
                                        4
                                        5
                  Equipment Type and Original ODS Refrigerant
                                    Substitute
                                   Start Date
                                   End Date[b]
                      Market Penetration of Substitute[c]
HCFC-22 Residential Unitary AC
   R-410A[d]
   2000
   2005
   5%
   
   
   2000
   2006
   5%
   
 
   2006
   2006
   20%
   
   
   2007
   2010
   20%
   
   
   2010
   2010
   50%
HCFC-22 Small Commercial Unitary AC
   R-410A
   1996
   2000
   3%
   
   
   2001
   2005
   18%
   
   
   2006
   2009
   8%
   
   
   2009
   2010
   71%
   HCFC-22 Large Commercial Unitary AC
   R-407C
   2006
   2009
   1%
   
   
   2009
   2010
   5%
   
   R-410A
   2001
   2005
   5%
   
   
   2006
   2009
   9%
   
   
   2009
   2010
   81%
HCFC-22 Water & Ground Source Heat Pumps
   R-407C
   2000
   2006
   5%
   
   
   2006
   2009
   3%
   
   
   2009
   2010
   23%
   
   R-410A
   2000
   2006
   5%
   
   
   2006
   2009
   5%
   
   
   2009
   2010
   41%
   
   HFC-134a
   2000
   2009
   2%
   
   
   2009
   2010
   18%
   HCFC-22 Dehumidifiers
   HFC-134a
   1997
   1997
   89%
   
   R-410A
   2007
   2010
   11%
   HCFC-22 Packaged Terminal Units
   R-410A
   2006
   2009
   10%
   
   
   2009
   2010
   90%
   HCFC-22 Window Units
   R-410A
   2008
   2009
   10%
   
   
   2009
   2010
   90%
   CFC-12 Tour Buses
   HFC-134a
   2006
   2007
   100%
   HCFC-22 Transit Buses
   HFC-134a
   1995
   2009
   100%
   HCFC-22 Trains
   HFC-134a
   2002
   2009
   50%
   
   R-407
   2002
   2009
   50%
   CFC-12 Cold Storage
   R-404A
   1996
   2010
   75%
   
   R-507A
   1996
   2010
   25%
   HCFC-22 Cold Storage
   R-404A
   1996
   2009
   8%
   
   
   2009
   2010
   68%
   
   R-507A
   1996
   2009
   3%
   
   
   2009
   2010
   23%
   R-502 Cold Storage
   R-404A
   1996
   2010
   38%
   
   R-507A
   1996
   2010
   12%
   
   Other
   1996
   2010
   50%
CFC-11 Industrial Process Refrigeration
   HFC-134a
   1995
   2010
   100%
   CFC-12 Industrial Process Refrigeration
   HFC-134a
   1995
   2010
   15%
   
   R-404A
   1995
   2010
   50%
   
   R-410A
   1999
   2010
   20%
   
   R-507A
   1995
   2010
   15%
HCFC-22 Industrial Process Refrigeration
   HFC-134a
   1995
   2009
   2%
   
   
   2009
   2010
   14%
   
   R-404A
   1995
   2009
   5%
   
   
   2009
   2010
   45%
   
   R-410A
   1999
   2009
   2%
   
   
   2009
   2010
   18%
   
   R-507A
   1995
   2009
   2%
   
   
   2009
   2010
   14%
   CFC-12 Large Retail Food
   R-404A
   2000
   2000
   14%
   
   
   2000
   2009
   4%
   
   
   2001
   2010
   13%
   
   
   2009
   2010
   29%
   
   
   2010
   2010
   23%
   
   R-507A
   2000
   2000
   6%
   
   
   2000
   2009
   0.4%
   
   
   2001
   2010
   1%
   
   
   2009
   2010
   4%
   
   
   2010
   2010
   2%
   
   R-407A
   2000
   2009
   1%
   
   
   2001
   2010
   0.3%
   
   
   2009
   2010
   2%
   
   
   2010
   2010
   0.4%
   R-502 Large Retail Food
   R-404A
   2000
   2000
   14%
   
   
   2000
   2009
   4%
   
   
   2001
   2010
   13%
   
   
   2009
   2010
   29%
   
   
   2010
   2010
   23%
   
   R-507A
   2000
   2000
   6%
   
   
   2000
   2009
   0.4%
   
   
   2001
   2010
   1%
   
   
   2009
   2010
   4%
   
   
   2010
   2010
   2%
   
   R-407A
   2000
   2009
   1%
   
   
   2001
   2010
   0.3%
   
   
   2009
   2010
   2%
   
   
   2010
   2010
   0.4%
HCFC-22 Large Condensing Units (Medium Retail Food)
   R-404A
   1995
   2000
   30%
   
   
   2008
   2010
   30%
   
   HFC-134a
   1993
   2005
   30%
   
   
   2006
   2006
   10%
HCFC-22 Small Condensing Units (Medium Retail Food)
   R-404A
   1995
   2005
   5%
   
   
   2006
   2006
   25%
   
   
   2008
   2010
   45%
   
   R-507A
   1995
   2005
   10%
   
   
   2008
   2010
   15%
   CFC-12 Small Retail Food
   HFC-134a
   1993
   1995
   85%
   
   R-404A
   1993
   1996
   7.5%
   
   
   2000
   2009
   7.5%
   
   R-507A
   1993
   1996
   2.5%
   
   
   2000
   2009
   2.5%
   
   CO2
   2010
   2010
   5%
   CFC-12 Transport
   HFC-134a
   1995
   1999
   100%
   R-502 Transport[e]
   HFC-134a
   1993
   1995
   55%
   
   R-404A
   1993
   1995
   45%
   HCFC-22 Screw Chillers
   R-410A
   2010
   2020
   36%
   
   R-407C
   2000
   2009
   1%
   
   
   2009
   2010
   9%
   
   
   2010
   2020
   54%
   HCFC-22 Scroll Chillers
   R-410A
   2010
   2020
   36%
   
   R-407C
   2000
   2009
   1%
   
   
   2009
   2010
   9%
   
   
   2010
   2020
   54%
   CFC-12 Reciprocating Chillers
   R-410A
   2010
   2020
   40%
   CFC-11 Centrifugal Chillers
   HFC-134a
   2000
   2010
   100%
   CFC-12 Centrifugal Chillers
   HFC-134a
   2000
   2010
   100%
   R-500 Chillers
   HFC-134a
   2000
   2010
   100%
Source: VM IO File_v4.4_11.6.12
[a] Interim transitions (e.g., from a CFC to HCFC-22 to HFCs) are not shown. For example, the retail food new-equipment market that originally used CFC-12 first transitioned from CFC-12 to R-502 and then to HCFC-22. Then, between 1995 and 2010, 83 percent of the HCFC-22 new-equipment market is assumed to transition to R-404A, 13 percent to R-507A., and the remaining 4% to R-407A.
[b] The end date is January 1 of the year. Transitions are assumed to occur instantaneously on January 1.
[c] The market penetration of the substitute represents the percent of the HCFC-22 new-equipment market that is replaced by the substitute refrigerant.
[d] Multiple vintages of equipment are represented in this table (i.e. Two vintages of R-410A equipment are represented separately. Each vintage has a different charge size and they reach their maximum market penetration a year apart). 
[e] The R-502 transport refrigeration market transitions directly to HFC-134a and R-404A. There is no interim transition to HCFC-22.
[f] Only 13 SEER HCFC-22 equipment is modeled by the Vintaging Model. 
    A.1 Limitations and Caveats
This analysis utilized the best data available from various sources. Nonetheless, when making projections several assumptions are required. The following caveats should be noted.
Recycled or Reclaimed Refrigerant

EPA's Vintaging Model was used to determine the quantities of HCFC-22, HCFC-123, and HCFC-124 from existing (recycled or reclaimed) sources that can meet post-2015 servicing needs. For a given year, the model assumes that a certain percentage of refrigerant, which varies by end-use, is recovered from discarded equipment, while the remainder is emitted. The model aggregates the quantities recovered but does not distinguish the "pool" of refrigerant between quantities that are reclaimed versus those that are recycled. The model then assumes that the entire pool of recovered refrigerant re-enters the market within the same year. The model assumes that any additional need for refrigerant above the estimated amount recovered is met by virgin manufacture. The recovery pool and the remaining virgin manufacture are evaluated only at the most aggregate level, across all end-uses, and not at the end-use level, as the model does not differentiate between virgin and recycled refrigerant when calculating need for each end-use. This model attribute reflects a more realistic scenario in that reclaimers are not likely to only sell back to the end-use market sector from which the used refrigerant originated; rather, reclaimed refrigerant can be retailed to the overall AC and refrigeration industry. 

Under this modeled approach, the model does not consider the quantity of refrigerant that companies send off for destruction after equipment is decommissioned. Although the quantities of destroyed refrigerant are very small, they are not subtracted from the recovered pool, so the quantity available for reuse may be slightly overestimated in the model. Additionally, the model does not account for any stockpiling of recovered refrigerant beyond a one-year timeframe, as discussed in Section 4.3. To the extent that stockpiling has occurred over the last few years, the quantity of recovered refrigerant modeled as re-entering the market may be overestimated in earlier years (i.e., when refrigerant is banked), and the quantity modeled as re-entering the market in later years may be underestimated (i.e., when the accumulated stockpile is accessed as a source). However, EPA has collected data on HCFC-22 inventory from a handful of companies and is using that information to inform the 2015-2019 rulemaking. 

Repairs with Dry-Shipped Appliance Components

While it is illegal to install new HCFC-22 systems, HCFC-22 components (e.g., condensing units, compressors, line sets, etc.) that are shipped without a refrigerant charge are available for repairs of systems installed before 2010. The Vintaging Model assumes that components will continue to be available for usual repairs of existing equipment. A sensitivity analysis was performed to assess the potential impact of dry-shipped appliance components on Vintaging Model projections of HCFC-22 servicing need. The analysis estimated that servicing need could be 7 to 11 percent higher than the Vintaging Model projections when the installation of dry-shipped components is accounted for. Additional details of this analysis can be found in Appendix D. 
Date of Shipment versus Date of Installation of HCFC-22, HCFC-123, and HCFC-124 Units

It is feasible and potentially common for some AC and refrigeration appliances to be manufactured, charged, shipped and/or purchased in one year and installed in another year. Such would be the case, for example, for units designated for construction projects that have received building code approval and entered into a binding contract in one year but are completed in some future year. The Vintaging Model relies on shipment data of new AC and refrigeration equipment to help estimate new units entering the market for a given year. The model does not make adjustments to shipment data to reflect the date of installation since shipment data is the closest and best proxy to installation for the purposes of modeling. Thus, the model assumes the year of installation is the same as the year of shipment. Any equipment modeled as "shipped" in 2014, for example, is therefore assumed to be part of the installed base in that year. In summary, shipment date becomes the modeled installation date. For example, a residential unitary AC system shipped in 2009 would be in service for 15 years from that date, and would be retired in 2024. 

The model assumes that the entire fleet of 2014 HCFC-123 units within a given end-use are being installed and retired in the same year, whereas, in reality some of these units may instead be installed a year or two after shipment, starting their lifetime and servicing need a year or two after the shipment date, and hence, retiring a year or two after the retirement of the rest of the fleet. In this case, the model is not accurately reflecting the actual start and end date for servicing need for this subset of equipment. Instead, the model uses an average lifetime for each unique equipment type. This average is intended to account for units that are used for a few years less than the assumed useful life as well as those that are used well beyond their assumed useful life. Given the use of an average lifetime in the model, variations of a year or two between shipment and installation date should fall within "normal" fluctuations in lifetime seen in actual equipment use. Additionally, the majority of HCFC consumption comes from residential and commercial refrigeration and AC equipment that have lifetimes of 15 years or longer. Thus, any such equipment entering the market after 2015 is assumed to remain in service beyond 2030, when all HCFC consumption will be phased out in the United States. 

HCFC-123 in Fire Suppression

Per an amendment to the Clean Air Act passed in December 2011, HCFC use in fire suppression in nonresidential applications can continue after 2015. The Vintaging Model does not yet reflect the amendment to section 605(a) of the Clean Air Act; however, a scenario was run to estimate the use of Halotron I -- the most widely used fire suppression agent containing HCFC-123 -- assuming production and consumption continued until December 31, 2019. Starting January 1, 2020, it is assumed that servicing needs remain stable at 210 MT, to reflect potential demand for charging portable fire extinguishers with recycled HCFC-123 based blends. Table A-3 presents projected servicing need estimates for HCFC-123. 

Table A-3: Projected HCFC-123 Servicing Need for 
Fire Suppression, 2015-2025, (Metric Tons)
                                     HCFC
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2025
                                   HCFC-123
                                      190
                                      200
                                      200
                                      210
                                      210
                                      210
                                      210

These servicing need estimates were included in the analysis presented in the report. 
 Appendix B: HCFC Projections by End-Use
This Appendix provides estimates of the projected installed base of HCFC equipment by end-use and the projected servicing need of HCFCs for AC and refrigeration equipment. Descriptions of end-uses are provided in Section 3 of the report. For the purpose of this analysis, data on HCFC blend consumption for servicing are divided among the corresponding HCFC constituent(s) of that blend, according to the nominal percent composition. However, to accurately portray the number of units containing HCFC-22, blends are not disaggregated when presenting the number of units of equipment (i.e., a unit running on a blend containing HCFC-22 counts as one unit). 

Tables B-1, B-2, and B-3 present the number of units of equipment using HCFC-22, HCFC-123, and HCFC-124 (or a blend containing these chemicals) respectively that are estimated to be in use in 2010, 2015, 2020, and 2025. These estimates were developed based on EPA's Vintaging Model, which takes into account recent input from stakeholders (EPA 2012). Sections 3.1 and 3.2 provide an overview of these AC and refrigeration end-uses. 

         Table B-1: Estimated Number of HCFC-22 Units in Operation[a]
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Window Units
                                                                    76,181,000 
                                                                     43,444,500
                                                                      4,102,700
                                                                              -
Packaged Terminal Units
                                                                     2,478,800 
                                                                      1,355,100
                                                                        123,100
                                                                              -
Residential Unitary AC 
                                                                    76,099,300 
                                                                     46,893,700
                                                                     14,663,600
                                                                              -
Small Commercial Unitary AC
                                                                     3,092,700 
                                                                      1,887,900
                                                                        751,100
                                                                              -
Large Commercial Unitary AC
                                                                       198,100 
                                                                        127,400
                                                                         53,700
                                                                              -
Chillers
                                                                       443,900 
                                                                        326,300
                                                                        202,800
                                                                         82,600
Dehumidifiers
                                                                     1,282,100 
                                                                        670,200
                                                                              -
                                                                              -
Water & Ground Source Heat Pumps
                                                                     1,393,700 
                                                                      1,104,800
                                                                        695,800
                                                                        247,500
Other Mobile AC (Bus & Train AC)
                                                                        18,800 
                                                                          4,300
                                                                              -
                                                                              -
Subtotal AC
                                                                   161,188,400 
                                                                     95,814,200
                                                                     20,592,800
                                                                        330,100
Retail Food
                                                                     2,112,000 
                                                                        969,100
                                                                        461,870
                                                                        142,100
Industrial Process Refrigeration
                                                                         8,700 
                                                                          7,500
                                                                          5,600
                                                                          3,500
Subtotal Refrigeration
                                                                     2,120,700 
                                                                        976,600
                                                                        467,500
                                                                        145,600
Total
                                                                   163,309,100 
                                                                     96,790,800
                                                                     21,060,300
                                                                        475,700
     [a] Cold Storage is not shown in this table because the model estimates this end-use based on cubic feet of storage, rather than number of units.

          Table B-2: Estimated Number of HCFC-123 Units in Operation
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Chillers
                                                                         40,900
                                                                         47,600
                                                                         49,500
                                                                         39,800
Industrial Process Refrigeration
                                                                          9,200
                                                                         12,600
                                                                         14,300
                                                                         12,000
Fire Suppression[a]
                                                                      1,226,700
                                                                      1,422,100
                                                                      1,487,800
                                                                        871,100
Total
                                                                      1,276,800
                                                                      1,482,300
                                                                      1,551,600
                                                                        922,900
   [a] Units of fire suppression equipment does not reflect units of new equipment charged with recycled HCFC-123 starting in 2020.

          Table B-3: Estimated Number of HCFC-124 Units In Operation
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Industrial Process Refrigeration
                                                                            170
                                                                            170
                                                                            140
                                                                              -
Medium Retail Food
                                                                         27,700
                                                                         27,200
                                                                         18,800
                                                                              -
Total
                                                                         27,800
                                                                         27,400
                                                                         18,900
                                                                              0


Table B-4 presents the metric tons of HCFC-22 estimated to be needed to service AC and refrigeration equipment in 2010, 2015, 2020, and 2025. Table B-5 presents the metric tons of HCFC-123 estimated to be needed to service and charge new and existing AC and refrigeration equipment in 2010, 2015, 2020, and 2025. Table B-6 presents the metric tons of HCFC-124 estimated to be needed to service refrigeration equipment in 2010, 2015, 2020, and 2025. 

           Table B-4: Projected HCFC-22 Servicing Need (Metric Tons)
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Window Units
                                                                            270
                                                                            160
                                                                         <50
                                                                              -
Packaged Terminal Units
                                                                             90
                                                                         <50
                                                                         <50
                                                                              -
Residential Unitary AC 
                                                                         37,900
                                                                         24,400
                                                                          9,500
                                                                              -
Small Commercial Unitary AC
                                                                          2,600
                                                                          1,600
                                                                            600
                                                                              -
Large Commercial Unitary AC
                                                                            300
                                                                            190
                                                                             80
                                                                              -
Chillers
                                                                          3,300
                                                                          1,300
                                                                            720
                                                                            310
Dehumidifiers
                                                                         <50
                                                                         <50
                                                                              -
                                                                              -
Water & Ground Source Heat Pumps
                                                                            290
                                                                            230
                                                                            140
                                                                             50
Other Mobile AC (Bus & Train AC)
                                                                             80
                                                                         <50
                                                                              -
                                                                              -
Total AC
                                                                         44,800
                                                                         27,900
                                                                         11,100
                                                                            360
Cold Storage
                                                                          1,100
                                                                            830
                                                                            570
                                                                            340
Retail Food
                                                                         14,700
                                                                         10,200
                                                                          5,500
                                                                          1,300
Industrial Process Refrigeration
                                                                          8,900
                                                                          7,200
                                                                          5,400
                                                                          3,500
Total Refrigeration
                                                                         24,700
                                                                         18,200
                                                                         11,400
                                                                          5,200
Total
                                                                         69,400
                                                                         46,100
                                                                         22,500
                                                                          5,500
      Note: Totals do not sum due to independent rounding

          Table B-5: Projected HCFC-123 Servicing Need (Metric Tons)
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Chillers
                                      420
                                     1,200
                                      220
                                      180
Industrial Process Refrigeration
                                      260
                                      770
                                      370
                                      290
Fire Suppression
                                      160
                                      190
                                      210
                                      210
Total
                                      850
                                     2,200
                                      800
                                      680
                                       
          Table B-6: Projected HCFC-124 Servicing Need (Metric Tons)
                                Equipment Type
                                     2010
                                     2015
                                     2020
                                     2025
Industrial Process Refrigeration
                                       2
                                       2
                                       2
                                       -
Medium Retail Food
                                       2
                                       2
                                       1
                                       -
Total
                                       5
                                       5
                                       4
                                       -
     Note: Totals do not sum due to independent rounding

 Appendix C: Changes to the Vintaging Model
Table C-1 summarizes the changes that have been made to EPA's Vintaging Model and the HCFCs affected by the alteration since the 2009 Service Tail Report. Changes were made to the model based on industry research and feedback.

        Table C-1: Changes Made to EPA's Vintaging Model (Since 2009)
                                    End Use
                                Change(s) Made
                                HCFCs Affected
Large Retail Food[a] 
Increased 1985 stock assumptions
Charge size reduced
Distributed systems and Secondary Loop Systems (SLS) were introduced (reduced charge sizes)
Increased lifetime from 15 years to 17.5 years
Increased disposal loss rate for DX (20%) and Distributed (18.5%) and decreased disposal loss rate for SLS (14%)
New refrigerants added to end-use (R-402A, R-422A, R-422D, R-407A, R-408A [R-402A and R-408A blends contain HCFC-22])
HCFC-22
Medium Retail Food[a] 
End-Use was split into two end-uses (large condensing units and small condensing units)
Decreased 1985 stock assumptions
Additional refrigerant blends were added (R-401A [containing HCFC-22 and HCFC-124], R-402A, HFC-134a)
Large condensing units have a larger annual leak rate (increased from 6% to 13%)
HCFC-22, HCFC-124
Small Retail Food[a] 
Increased 1985 stock assumptions
Decreased leak and service rate
HCFC-22
Small Commercial Unitary AC
Increased original 1985 stock assumptions
HCFC-22
Large Commercial Unitary AC
Decreased original 1985 stock assumption
HCFC-22
Residential Unitary AC 
Increased original 1985 stock assumptions
Removed transitions to R-407C (all equipment transitions from HCFC-22 to R-410A)
Increased service loss rate (10%)
HCFC-22
[a] ICF, 2011.


 Appendix D: Sensitivity Analyses
Although EPA's assumptions are continually updated to improve and refine the accuracy of the model, future servicing need for HCFC-22 is affected by outside factors that may not be fully reflected. The extent to which the market price of HCFC-22 fluctuates and affects usage patterns and transitions and how HCFC allocations in recent years affect future servicing needs are two examples of market influence that is not captured in the current assessment. 

This Appendix presents analyses performed to determine the effect that different assumptions may have on HCFC-22 service need. The following sensitivity analyses were considered individually (i.e., the effects on HCFC-22 servicing need resulting from each analysis are not additive or cumulative): 

   * Smaller system charge sizes;
   * Lower equipment loss rates;
   * Earlier transitions to alternatives; and
   * Longer equipment lifetimes due to repairs using dry-shipped condensing units. 
    D.1 Smaller System Charge Size
This sensitivity analysis explores the impact on servicing need of a smaller charge size in residential unitary AC equipment. Residential unitary AC accounts for approximately 50 percent of the total servicing need across all refrigeration and AC end-uses for 2015 to 2019. This end-use represents such a large portion of the total servicing need for HCFC-22 in refrigeration and AC equipment due in part to its high installed base, larger equipment charge sizes, long lifetimes, and high loss rates. A large number of residential unitary AC units containing HCFC-22 will continue to be in use through 2023, and they are projected to require a significant amount of HCFC-22 to meet their servicing need. 

In 2001, the U.S. Department of Energy (DOE) set a stricter seasonal energy efficiency ratio (SEER) standard for residential unitary ACs and heat pumps. The minimum efficiency standard of residential unitary ACs and heat pumps was raised by 30 percent to a 13 SEER for all such units manufactured for sale on or after January 23, 2006 (DOE 2001; DOE 2004). These increased SEER requirements are reflected in this report, although earlier SEER requirements are not explicitly reflected. As shown in the Table D-1, the EPA currently assumes that the 13 SEER vintage of HCFC-22 residential unitary AC equipment uses a charge size of approximately 4.8 kg.

Table D-1: Charge Size, Loss Rate, and Lifetime for HCFC-22 Residential AC Equipment
                                    End-Use
                                   Original
                            Residential Unitary AC
                                    13 SEER
                            Residential Unitary AC
                               Charge Size (kg)
                                      3.4
                                      4.8
                               Annual Loss Rate
                                     13.6%
                                     13.6%
                               Lifetime (years)
                                      15
                                      15
                               Manufactured From
                                  1992 - 2005
                                 2006  -  2009
                                       
This analysis examines the potential effects on service need of a smaller charge size of 4 kg for HCFC-22 13 SEER residential unitary AC equipment. This change results in a 2 to 7 percent decrease in total HCFC-22 service need across all refrigeration and AC end-uses between 2015 and 2023, as shown in Table D-2. After 2023, all HCFC-22 residential unitary AC equipment is modeled as having reached end-of-life, so there is no longer servicing need for the end-use. 

Table D-2: HCFC-22 Service Need for Residential AC from Smaller 13 SEER Charge Size, 
                                   2015-2025
                                    End-Use
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Resid-ential Unitary AC
VM Baseline
                                    24,400
                                    21,700
                                    18,900
                                    16,000
                                    13,000
                                     9,500
                                     6,500
                                     3,900
                                     1,800
                                       -
                                       -

Lower Charge
                                    23,200
                                    20,500
                                    17,600
                                    14,700
                                    11,600
                                     8,000
                                     5,400
                                     3,300
                                     1,500
                                       -
                                       -
Total
VM Baseline
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500

Lower Charge
                                    45,000
                                    40,400
                                    35,500
                                    31,000
                                    26,300
                                    21,000
                                    16,800
                                    13,100
                                     9,800
                                     6,900
                                     5,500
Percent Decrease in Total HCFC-22 Need 
(All Ref/AC End Uses)
                                      2%
                                      3%
                                      3%
                                      4%
                                      5%
                                      7%
                                      6%
                                      5%
                                      3%
                                       -
                                       -
Note: Totals may not sum due to independent rounding.
    D.2 Lower Equipment Loss Rate 
This sensitivity analysis explores the impact on servicing need of a lower loss rate for residential unitary AC, large and medium retail food refrigeration, and cold storage units. With the price of HCFC-22 increasing, feedback from stakeholders has suggested that service technicians may now be more careful with the refrigerant, resulting in lower loss rates than those estimated in this report.

Between 2015 and 2021, service need from residential unitary AC, large retail food refrigeration, medium retail food refrigeration (large condensing units), and cold storage together are projected to account for approximately 70 to 80 percent of the total service need across all refrigeration and AC end-uses; by 2025, this proportion drops to 30 percent of total need. These four end-uses represent a large portion of the total servicing need for HCFC-22 in refrigeration and AC equipment due in part to their high installed base, larger equipment charge sizes, long lifetimes, and high modeled loss rates. A large number of units containing HCFC-22 within these end-uses will continue to be in use through 2025, and they are expected to require a significant amount of HCFC-22 to meet their servicing need. 

The annual loss rates for these end-uses (as modeled in the Vintaging Model) are shown in Table D-3. The annual loss rate is equal to the annual leak rate plus the annual emission rate from servicing. 

Table D-3: Annual Loss Rate and Lifetime for HCFC-22 Residential AC, Large Retail Food Refrigeration, Medium Retail Food Refrigeration (Large Condensing Units), and Cold Storage Equipment
                                    End-Use
                      HCFC-22 Equipment Charge Size (kg)
                                   Lifetime 
                                    (years)
                      HCFC-22 Equipment Annual Loss Rate
Residential Unitary AC
                                      3-5
                                      15
                                      14%
Large Retail Food
                                  1,360-1,800
                                      18
                                      30%
Medium Retail Food (Large Condensing Units)
                                      25
                                      20
                                      15%
Cold Storage
                                  <0.01[a]
                                     20-25
                                      20%
  [a] Cold storage charge size presented in kilograms/cubic foot

This analysis examines the potential effects of a lower loss rate for HCFC-22 equipment on service need, by assuming that residential unitary AC, large retail food refrigeration, medium retail food refrigeration (large condensing units), and cold storage units undergo annual leak tightening beginning in 2012. The following specific assumptions are made:

   * Residential Unitary AC: Annual loss rate will decline by 1 percentage point per year until the loss rate equals 10 percent.
   * Large Retail Food: Annual loss rate will decline by 5 percentage points so that the loss rate equals 25 percent.
   * Medium Retail Food (Large Condensing Units): Annual loss rates will decline by 1 percentage point per year until the loss rate equals 10 percent.
   * Cold Storage: Annual loss rate will decline by 1 percentage point per year until the loss rate equals 15 percent.

These changes result in a 10 to 23 percent decrease in total HCFC-22 service need across all refrigeration and AC end-uses between 2015 and 2025, as shown in Table D-4. 

Table D-4: HCFC-22 Service Need for Residential AC, Large Retail Food Refrigeration, Medium Retail Food (Large Condensing Units), and Cold Storage from Lower Annual Loss Rates,
                                   2015-2025
                                    End-Use
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Residential Unitary AC
VM Baseline
                                    24,400
                                    21,700
                                    18,900
                                    16,000
                                    13,000
                                     9,500
                                     6,500
                                     3,900
                                     1,800
                                       -
                                       -

Lower Loss
                                    17,200
                                    15,300
                                    13,300
                                    11,300
                                     9,200
                                     6,700
                                     4,600
                                     2,700
                                     1,200
                                      -  
                                      -  
Large Retail Food
VM Baseline
                                     9,100
                                     8,200
                                     7,200
                                     6,500
                                     5,800
                                     4,900
                                     4,200
                                     3,400
                                     2,600
                                     1,900
                                     1,100

Lower Loss
                                     6,000
                                     5,400
                                     4,800
                                     4,300
                                     3,800
                                     3,300
                                     2,700
                                     2,200
                                     1,700
                                     1,200
                                      700
Medium Retail Food (Large Condensing Units)
VM Baseline
                                      900
                                      800
                                      700
                                      700
                                      600
                                      500
                                      500
                                      400
                                      300
                                      300
                                      200

Lower Loss
                                      700
                                      600
                                      500
                                      400
                                      400
                                      400
                                      300
                                      300
                                      200
                                      200
                                      100
Cold Storage
VM Baseline
                                      800
                                      800
                                      700
                                      700
                                      600
                                      600
                                      500
                                      500
                                      400
                                      400
                                      300

Lower Loss
                                      700
                                      600
                                      500
                                      500
                                      500
                                      400
                                      400
                                      400
                                      300
                                      300
                                      300
Total
VM Baseline
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500

Lower Loss
                                    35,400
                                    31,900
                                    28,300
                                    25,000
                                    21,600
                                    17,700
                                    14,300
                                    11,200
                                     8,400
                                     6,100
                                     5,000
Percent Decrease in Total HCFC-22 Need 
(All Ref/AC End Uses)
                                      23%
                                      23%
                                      23%
                                      23%
                                      22%
                                      21%
                                      20%
                                      19%
                                      16%
                                      12%
                                      10%
Note: Totals may not sum due to independent rounding.

    D.3 Earlier Equipment Transitions to Alternatives
This sensitivity analysis explores the impact on servicing need of an earlier transition of HCFC-22 residential unitary AC, retail food refrigeration, and IPR equipment to alternative refrigerants. Of total HCFC-22 service need from 2015 to 2020, residential unitary AC, retail food refrigeration, and industrial process refrigeration (IPR) together account for approximately 90 percent. As the price of HCFC-22 increased and as equipment reached the end of its useful life, feedback from stakeholders indicates that retrofits and system replacements may have occurred more rapidly than modeled in this report.

New residential unitary AC equipment completed the transition from HCFC-22 to R-410A as of 2010, due to the ban on the use of virgin HCFC-22 to service new refrigeration and air-conditioning equipment. Although no new residential AC systems are manufactured today using HCFC-22, this report assumes that an estimated 50 percent of the residential unitary AC market in the United States was using HCFC-22 through 2009. As a result, servicing need for HCFC-22 is modeled for another 15 years -- through the end of 2023 -- the full 15 year lifetime of these units. 

A significant portion of retail food refrigeration, which consists of large direct expansion (DX) systems, large condensing units, small condensing units, and stand-alone units, were also using HCFC-22 or blends containing HCFC-22 up until 2010; however, transitions away from HCFC-22 to other refrigerants and refrigerant blends (e.g., HFC-134a, R-507, and R-404A) are modeled as early as 1993. In the retail food sector, industry contacts, especially distributors, are suggesting that HCFC-22 sales have dropped off significantly in recent years, and that retrofits or system replacements are undertaken more frequently. 

While historical HCFC-22 use in IPR systems was somewhat limited -- HCFC-22 systems only accounted for approximately 10-15 percent of the total IPR market, some HCFC-22 units continued to be manufactured until 2010 (as modeled in this report). These units have significant charge sizes and a lifetime of approximately 25 years, which contribute to the high service need for these units beyond 2015.

This analysis examines the potential effects of early retirement of HCFC-22 equipment on service need, by assuming that 20 percent of residential unitary air-conditioning, retail food refrigeration, and industrial process refrigeration equipment are retired 5 years earlier than this report assumes, beginning in 2010 (e.g., 20 percent of equipment that would have retired in 2015 is being retired in 2010 instead). These changes result in a 9 to 14 percent decrease in HCFC-22 service need between 2015 and 2025, as shown in Table D-5. 

Table D-5: HCFC-22 Service Need for Residential AC, Retail Food Refrigeration, and Industrial Process Refrigeration from Early Retirement, 2015-2025
                                    End-Use
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Residential
VM Baseline
                                    24,400
                                    21,700
                                    18,900
                                    16,000
                                    13,000
                                     9,500
                                     6,500
                                     3,900
                                     1,800
                                       -
                                       -

Early Transition
                                    21,400
                                    18,700
                                    15,900
                                    13,200
                                    10,400
                                     7,600
                                     5,200
                                     3,100
                                     1,400
                                       -
                                       -
Retail Food
VM Baseline
                                    10,200
                                     9,200
                                     8,000
                                     7,200
                                     6,400
                                     5,500
                                     4,700
                                     3,800
                                     3,000
                                     2,200
                                     1,300

Early Transition
                                     9,300
                                     8,300
                                     7,200
                                     6,400
                                     5,600
                                     4,700
                                     3,800
                                     3,100
                                     2,400
                                     1,700
                                     1,100
IPR
VM Baseline
                                     7,200
                                     6,800
                                     6,400
                                     6,000
                                     5,700
                                     5,400
                                     5,000
                                     4,600
                                     4,300
                                     3,900
                                     3,500

Early Transition
                                     6,800
                                     6,400
                                     6,000
                                     5,700
                                     5,300
                                     5,000
                                     4,600
                                     4,200
                                     3,900
                                     3,500
                                     3,100
Total
VM Baseline
                                    46,100
                                    41,600
                                    36,700
                                    32,300
                                    27,700
                                    22,500
                                    17,900
                                    13,700
                                    10,100
                                     6,900
                                     5,500

Early Transition
                                    41,800
                                    37,300
                                    32,600
                                    28,300
                                    23,900
                                    19,400
                                    15,400
                                    11,800
                                     8,700
                                     6,100
                                     4,900
Percent Decrease in Total HCFC-22 Need
                                      9%
                                      10%
                                      11%
                                      13%
                                      14%
                                      14%
                                      14%
                                      14%
                                      13%
                                      12%
                                      12%
Note: Totals may not sum due to independent rounding.
    D.4 Longer Equipment Lifetimes Due to Repairs Using Dry-Shipped Condensing Units 
This sensitivity analysis explores the impact on servicing need of repairing residential unitary AC systems with dry-shipped condensing units (CUs). Although new HCFC-22 systems were banned in 2010, replacement dry-shipped CUs can be used for repairing systems, potentially extending the lifetime of the AC unit (and servicing need). This analysis assumes existing residential unitary AC units using HCFC-22 are repaired with dry-shipped CUs. Table D-6 shows the percentage of new shipments that EPA assumes are HCFC-22 CUs instead of R-410a CUs. 

Table D-6: Assumptions for Percentage of New CU Shipments Going to HCFC-22 Repairs
 Year
                                     2010
                                     2011
                                     2012
                                     2013
                                     2014
                                     2015
                                     2016
                                     2017
                                     2018
 Percentage of New Shipments 
                                      5%
                                      20%
                                      15%
                                      10%
                                      10%
                                      5%
                                      5%
                                      5%
                                      0%

The analysis further assumes that repairing systems with dry-shipped CUs extends the equipment lifetime by 10 years.

Table D-7 shows the resulting increase in need in the residential unitary AC end-use and the percent increase in service need compared to total need from all refrigeration and air-conditioning end-uses associated with increasing equipment lifetimes by 10 years with dry-shipped CUs. This change results in a 7 to 11 percent increase in HCFC-22 service need between 2015 and 2025.

Table D-7: Additional HCFC-22 Need in Residential Unitary AC from Dry-Shipped CUs, 2015-2025
                                    End-Use
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                                     2025
Baseline Servicing Need for Residential Unitary AC
                                    24,400
                                    21,700
                                    18,900
                                    16,000
                                    13,000
                                     9,500
                                     6,500
                                     3,900
                                     1,800
                                       -
                                       -
Additional Modeled Servicing Need for Residential Unitary AC
                                     3,700
                                     3,900
                                     4,100
                                     2,700
                                     2,700
                                     2,600
                                     1,900
                                     1,300
                                      900
                                      600
                                      400
Total Residential Unitary AC Servicing Need
                                    28,100
                                    25,600
                                    23,000
                                    18,800
                                    15,700
                                    12,100
                                     8,300
                                     5,200
                                     2,700
                                      600
                                      400
Increase in Total Need for All HCFC-22 Ref/AC Servicing
                                      8%
                                      9%
                                      11%
                                      8%
                                      10%
                                      11%
                                      10%
                                      10%
                                      9%
                                      8%
                                      7%
Note: Totals may not sum due to independent rounding.



 Appendix E: HCFC-22 Inventory Estimate
In August 2013, EPA asked questions of up to nine companies about their HCFC-22 inventory and sales. Under section 114(a) of the Clean Air Act, for the purpose of carrying out any provision of the Act, EPA has the authority to ask any person who is subject to any requirement of the Act to establish and maintain such records, make such reports, and provide such other information as the Administrator may reasonably require. Many stakeholders encouraged EPA to use this authority to gather data on HCFC-22 inventory levels in particular. 

EPA used the data received in response to its section 114 request to substantiate what the agency had already heard from many industry representatives: HCFC-22 inventory is still high, and potentially higher than the agency had previously estimated in the fall of 2011. Concurrent with the 2012-2014 Proposed Rule, EPA published Analysis of HCFC -  22 Servicing Needs in the U.S. Air Conditioning and Refrigeration Sector: Additional Considerations for Estimating Virgin Demand ("Adjustment Memo"), which stated that EPA believed HCFC-22 inventory was between 22,700 and 45,400 MT. Based on inventory data from a limited number of companies as of December 31, 2012, as well as other information received by the agency during the development of this proposed rule, EPA knows HCFC-22 inventory is higher than its previous estimate.  

Given that inventory at the end of 2012 was higher than 45,400 MT, EPA expects that a significant amount of HCFC-22 servicing need in 2015-2019 can be met by existing stocks. Since HCFC-22 inventory is quite large, and may even grow in 2013 and 2014, the preamble to the 2015-2019 Proposed Rule states that EPA is proposing to account for up to 10,000 MT of inventory drawdown each year as it considers an appropriate HCFC-22 consumption allocation.   
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