f ~ Structural ~ / Concepts· 

Oral Statement of 

Jason Paquette 

Structural Concepts Corporation 

Before the 

Environmental Protection Agency 

On 

Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under 

the Significant New Alternative Policy Program 

Docket 10 No. EPA-HQ- OAR-2014-0198, 

As published in the August 6, 2014 Federal Register 

August27, 2014 

Washington, D.C. 

888 E. Porter Road Muskegon, Ml 49441 p. 231.798.8888 f. 231.798.4960 www.structuralconcepts.com 
Structural Concepts Corporation would like to thank the EPA for the opportunity to 

appear before you today. We are a privately held company with 480 employees located in 

Muskegon MI. We are a producer of remote and stand-alone commercial refrigerated units for 

the retail and food service industry. 80% of our equipment is standalone with the vast majority 

of our cases falling in the% to 3 hp range. We have over 600 active models in our product 

offering. 

sec supports the effort to reduce the overall energy usage and carbon foot print our 

product has on the environment. With each phasedown of refrigerant gases in the past, there 

has been a readily available alternative refrigerant that required no more than a compressor 

and valve change. Today we are left with only flammable refrigerants or a high pressure 

refrigerant with no component availability and reduced efficiency rates at elevated 

temperatures. 

With the current charge limits on flammable A3 refrigerants, only approximately 15% of 

our product line could be converted to a hydrocarbon refrigerant with a single condensing unit. 

The rest of the product offering would need to go to multiple condensing units which would in 

turn increase energy consumption. In addition to compressors and valves, heat exchangers and 

electrical safety components need to be designed into the product to conform to current U.L, 

NSF and DOE regulations. These units would need a complete redesign of the refrigeration 

system and have to be retested and recertified. 

To keep the ·Charge limit down hot gas condensate heaters would need to be replaced 

with electric heaters again increasing overall energy consumption that could potentially put the 
unit over the allowable DOE energy levels. For a 10 year life expectancy, this would result in 

increased energy and an increased overall carbon footprint between 10 and 40% over R404A. 

Many customers have concerns about flammable products placed into their store 

environments. Service companies would need to be trained to handle these refrigerants. Just 

implementing the charging and handling of the flammable refrigerant in a manufacturing 

environment would take several years. 

The only other refrigerant in consideration for standalone refrigerated units is R744. 

Currently there are only a few compressor manufacturers that produce C02 compressors and 

these are primarily for small vending machines and large refrigerated rack manufacturers with 

barely any offerings in between. The major compressor manufacturers of fractional and small 

hp compressors have abandoned the possibility of producing C02 compressors as it is not 

economically feasible for them with the increased material thicknesses due to the high 

pressures and the inherent inefficiency of C02 when ran transcritical. With compressors that 

are double the weight of their HFC counterparts the increased material and increased shipping 

weight again adds to the overall carbon foot print. 

When ran above the critical point of 87.8°F (which would be common as many store 

environments can reach 80°F) the systems consume much more energy than conventional 

systems today. Using data from one C02 compressor manufacturer with a 95°F gas cooler 

temperature, the overall energy increases by 45% from the current R404a compressor. This 

inefficiency would push the case over the allowable energy levels as dictated by the DOE and 

exceed the R404A carbon footprint by approximately 30%. 
Both of these alternative refrigerant choices would leave our customers with more 

costly, less efficient product. The current proposal would force a large percentage of our 

product out of the market due to the charge limits, component availability, regulatory 

limitations and timelines. It will take tens of thousands of hours to redesign and test new 

systems making the January 2016 date unfeasible. 

The EPA cannot just focus on the GWP number for a given refrigerant without taking 

into consideration the overall energy usage and the overall carbon footprint of the equipment 

itself. If the industry is forced to go to only these refrigerants we would find ourselves in a 

situation where we no longer meet the energy requirements set forth by the DOE. This brings 

us to the need for additional low GWP refrigerants. 

Currently SNAP has 30 refrigerants submitted to them for approval. We have tested 

some of these refrigerants with very good results. HFO blends such as R-448A and R-449A have 

1/3 the GWP of R404a and provide up to a 10% energy reduction while still remaining an A1 

nonflammable low pressure refrigerant. We as well as other CRE manufacturers have 

evaluated this refrigerant in our labs and have validated these findings. 

In lieu of this, supermarket systems and condensing units are allowed refrigerants that 

standalone retail systems are not. Standalone refrigeration units should be allowed to use 

refrigerants such as R407 A or R407C just like the supermarket systems. While still not being 

able to meet the January 2016 date these alternatives could be implemented dramatically 

faster than the proposed alternatives. 
With the cost, safety, regulatory and component availability concerns with the current 

proposed alternatives for standalone refrigeration units and the shear amount of time it would 

take to redesign over 600 models we would need 10 to 15 years to implement across all of our 

models. 

If the supermarket refrigerant alternatives that are still on the acceptable list or more 

ideally, the HFO blends could be added to the allowable refrigerant usage list, implementation 

could be done in a much faster timeframe.