1

Hall-Jordan, Luke

From: Hall-Jordan, Luke

Sent: Monday, May 12, 2014 5:14 PM

To: 'Gallagher, Glenn@ARB'

Subject: RE: R-22 Data for California

Thanks, Glenn. I just wanted to make sure I was reading it properly. ☺

Talk to you soon, 

Luke 

From: Gallagher, Glenn@ARB [mailto:ggallagh@arb.ca.gov] 

Sent: Monday, May 12, 2014 3:53 PM 

To: Hall-Jordan, Luke 

Subject: RE: R-22 Data for California 

Luke, 

Yes, I am stating that the stored amount is the amount banked in equipment in use, so the term “charged amount” or 

“amount currently in use in equipment” is a better description. (There is no estimate on the unused amount in 

inventory in my e-mail, hopefully, I did not communicate that incorrectly.) 

I was using an estimated 10 percent annual leak rate against all equipment – very rough estimate, but the lower AC leak 

rates balance out the higher refrigeration leak rates. 

Glenn Gallagher 

ARB Research Division 

 

e-mail: ggallagh@arb.ca.gov

phone: (916) 327-8041 

From: Hall-Jordan, Luke [mailto:Hall-Jordan.Luke@epa.gov] 

Sent: Monday, May 12, 2014 11:57 AM 

To: Gallagher, Glenn@ARB 

Subject: RE: R-22 Data for California 

Thanks, Glenn, for taking the time to walk me through this today and for helping with my question last week. I have one 

additional follow-up question on this email. When you write “The annual emissions may represent only about 10 

percent of the stored amount of R-22 used in refrigeration and AC systems in California. The stored amount of R-22 in 

California alone may therefore exceed 100 million pounds in use currently,” you’re referring to R-22 that is in use in 

existing equipment, not stored R-22 that is sitting unused in inventory, correct? It also appears you’re assuming a 10% 

annual leak rate for all modeled equipment, correct? 

Thanks, 

Luke 

Luke Hall-Jordan 

Stratospheric Protection Division 

U.S. Environmental Protection Agency 
2

1200 Pennsylvania Ave, NW (6205J) 

Washington, DC 20460 

hall-jordan.luke@epa.gov

(202)343-9591 (o) 

(202)230-7589 (c) 

From: Gallagher, Glenn@ARB [mailto:ggallagh@arb.ca.gov] 

Sent: Monday, May 12, 2014 1:00 PM 

To: Hall-Jordan, Luke 

Subject: FW: R-22 Data for California 

Luke, 

Here’s the same e-mail sent to Mr. Williams of New Era Group, Inc. 

Caveats on data: The following R-22 data is self-reported by distributors and reclaimers operating in

California, and has not been verified for accuracy. ARB estimates that between 70 and 80 percent of all 

refrigerant distribution in California is being reported, but this estimate has also not been verified. 

Data reported by Distributors Reporting in California 

Year R-22 Purchased or 

received (lbs.) 

R-22 sold or 

distributed (lbs.) 

R-22 received and shipped 

for reclaim, re-use, or 

destruction (lbs.) 

2011 6,859,511 7,386,352 277,283 

2012 7,249,358 5,677,406 221,534 

2013 4,722,116 4,484,304 352,920 

Data reported by Reclaimers Reporting in California

Year R-22 Received by 

Reclaimers 

R-22 Reclaimed 

in CA (lbs.) 

R-22 Shipped 

out of CA for 

Reclaim (lbs.) 

R-22 Shipped out 

of CA for 

Destruction (lbs.) 

2011 185,283 120,839 90,820 820 

2012 388,481 364,861 96,000 0 (zero) 

2013 202,865 267,843 41,551 41,489 

It is difficult to establish trends with only three years of data, however, we do see that the amount of R-22 

received by reclaimers has decreased approximately 186,000 pounds, or 48% between 2012 and 2013. This

decrease of R-22 received by reclaimers is greater than the decrease in purchases (-35%), and decrease in 

distribution (-21%). However, in the same timeframe of 2012 to 2013, the amount of R-22 shipped by 

distributors for reclaim did increase by 131,000 pounds, or 59%. 

Further note that for all reporting years, the large difference between the amount of refrigerant distributed, and 

the amount recovered for reclamation. For example, in 2013, the total amount of recovered R-22 reported was 

approximately 556,000 pounds (distributors plus reclaimer reports), compared to 4.48 million pounds of R-22 

distributed, indicating that almost 90 percent of refrigerant distributed is not recovered, and is assumed to be 

emitted. 

Other R-22 estimated emissions in California. 

Please note that R-22 emissions have also been estimated using an additional approach (other than sales and 

reclamation data reported to us) where we consider the many different sources of R-22. For the year 2013, we 
3

estimate that approximately 11.7 million pounds of R-22 were emitted in California from commercial 

refrigeration and AC and residential AC, with a smaller amount (0.2 million pounds) from lesser sources, 

including bus and ship/marine vessel AC, and insulating foam. Using a global warming potential value (GWP) 

of 1810, this is equivalent to 9.8 million metric tonnes of carbon dioxide equivalents (MMTCO2E). For 

comparison, the 9.8 MMTCO2E emissions from R-22 by itself represents 21 percent of all fluorinated gas 

emissions in California, and would be almost 2 percent of all GHG emissions in California (448 MMTCO2E 

total in 2011), if ozone-depleting substance emissions were included in the inventory, which they are not 

because ODS are phased out as part of the Montreal Protocol. For further perspective, 9.8 MMTCO2E in 

emissions is equivalent to the greenhouse gas emissions of: 

1.3 million homes’ electricity use for an entire year 

2 million passenger vehicles for an entire year 

Burning 1.1 billion gallons of gasoline 

Burning 10.5 billion pounds of coal 

Estimates from the U.S. EPA Greenhouse Gas Equivalencies Calculator at: 

 http://www.epa.gov/cleanenergy/energy-resources/calculator.html. 

The annual emissions may represent only about 10 percent of the stored amount of R-22 used in refrigeration 

and AC systems in California. The stored amount of R-22 in California alone may therefore exceed 100 million 

pounds in use currently. 

Hope this is useful. As I stated earlier, CARB does not have any official comment/outlook/position on the R-22 

allocation at this time. 

Glenn Gallagher 

ARB Research Division 

 

e-mail: ggallagh@arb.ca.gov