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# 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.

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8 E. Porter Road Muskegon, Ml 4944 1 p. 231.798.8888 f .231.798.4960 www.structur alc

oncepts.comStructural Concepts Corporation would like to thank the EPA forthe 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% ofour equipment is standalone with the vast majority ofour 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 ofthe 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 ofthe 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 theunit overthe allowable DOE energy levels. For a 10 year life expectancy, this would result in increased energy and an increased overall carbon footprint between 10and 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 implementingthe charging and handling ofthe 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 ofC0 2 when ran transcritical. With compressors that are double the weight oftheir HFC counterparts the increased material and increased shipping weight again adds to the overall carbon foot print. When ran above the critical point of87 .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 ofthese alternative refrigerant choices would leave our customers with more costly, less efficient product. The current proposal would force a large percentage ofour product out ofthe market due to the charge limits, component availability, regulatory limitations and timelines. It will take tens ofthousands 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 ofthe equipment itself. Ifthe indu stry is forced to go to only these refrigerants we would find ourse lves in a situation where we no longer meet the energy requ irements 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 ofthese 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 ofthis, supermarket systems and condensing units are allowed refrigerants that s

tandalone retail systems are not. Standalone refrigeration units should be allowed to use refrigerants such as R407A 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 oftime it would take to redesign over 600 models we would need 10 to 15 years to implement across all ofour models. Ifthe 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.