# RPI Industries, Inc.

Statements provided by Steve McGrath and James Dold Presented tothe Environmental Protection Agency Date October2, 2014
Subject: Protection ofthe Stratospheric Ozone: Change of Listing StatusforCertain Substitutes underthe Significant NewAlternative Policy Program Docket ID: EPA-HQ-OAR-2014-0198RPIIndustries Inc. would like to thank the Environmental Protection Agency (EPA) forthe opportunity to 

### appear before you today
. RPI Industries, Inc. (RPI) is a manufacturer or refrigerated display cases and open air screen style merchandisers forthe commercial and institutional food service industry. RPI's facility is located in Medford, NewJersey, approximately 15 miles southeast of Philadelphia, PA. RPI has enjoyed steady growthforthe last ten years and has continued to supportthe local economy by increasing itswork force each year. 

### ISSUE During the summer of2014, the Environmental Protection Agency (EPA) under the auspices ofthe SignificantAlternatives Policy Program (SNAP) issued a directiveto eliminate a class ofcertain refrigerants currently being used by manufacturers ofselfcontained and remote open air refrigerated merchandisers, similarto those being produced at RPI. This is being done to reduce the amount of HFC's being emitted and their effects on the Global Warming Potential (GWP). RPI supports the effort to reduce overallenergy consumption and the effects these products impose on the GWP

. 

### PROBLEM
• In years past, when refrigerants have been phased out for use in normal production (R12, R22), there have been acceptable and readily available alternatives that could be used in existing applications that typically required no compressor orvalve changes
. In absence ofthese alternatives, we are leftwith basically two options; Propane and 

## I or C02 Propane:
o Propane presents significant safety problems because ofits flammability. It would notwork in the majority ofRPI's current systems due to the product's currently allowable charge limit. Increasing this charge orcharge limit has not been pursued by testing laboratories such as Underwriters Laboratories (UL) so it cannot be considered a viable option. o Because ofpropane's flammability, it becomes a safety concern while handling in a shop environment and would also require significanttraining ofservice and technical personnel as well as in house employees to accommodate this concern. o Many of RPI's products are manufactured for use in public buildings including public school buildings. Because ofthis concern, aflammable product is simply not a viable option. o In addition to compressors and valves, additional items including electrical safety components would need to be introduced to the cases, requiring a complete redesign ofthe systems. These units would also need to undergo newtesting and recertification proceduresfor UL, NSF and DOE. o Changes as listed above would also increase overall energy consumption levels, potentially placing them overthe limits established by the DOE several years back. These increased energy levels would also have a negative impact on the GWP, which is the intentthis new rule is trying to prevent.o Although notflammable, 

### C02 is not as efficient as propane. The use of

### C02 and its inefficiency would likely violate DOE energy consumption allowances. o 

### C02 would also require a complete redesign ofcurrent systems in use as would propane. o Also, although notflammable, 

### C02 runs at significantly higher pressure than other refrigerants which presents safety concerns as well. This would also require retraining on the shop floor as well as service technicians in the field. And, due to these higher pressure requirements for 

### C02 systems, manufacturers ofthese systems require heavier material thicknesses which are expensive for manufactures to produce, so many choose notto do so. These heavier materials thicknesses also have a direct negative impact on the GWP considering the inherent issues necessary to produce such systems. 

### IMPACTS
• For RPI, it is estimated that 60 to 70% ofour product line, specifically but not exclusively our open air merchandisers would be affected by this new rule. • Although not completely defined, redesign, engineering and testing of new systems would cost tens ofthousands ofdollars to accomplish. • The potential job losses across this entire segment ofthe commercial food service and hospitality industrywould be devastating, notjustthe effects at RPI. • Ifthe product RPI produces and distributeswould not be available; customers and food service retailers who rely on this type ofunit or product would also experience a significant drop in revenue. Stand alone open refrigerated air screens and products like this have become a significant component for point ofsale operators.


### POSSIBLE SOLUTIONS
• There are several refrigerantscurrently submitted (thru the SNAP process) forapproval. Some have been tested by RPI and othermanufacturers and have produced very good results; many that are non-flammable and have produced lower energy consumption results. Although it would be difficultto have any one ofthese alternatives implemented priorto January 1, 2016, they could be implemented significantly fasterthan propane or 

### C02
. ./ Some ofthese alternatives would require compressor and valve changes, others would not. • The date for implementation needs to be extended. An initial proposed time frame forsuch a conversion ofapproximately 18 months is simply not adequate time
. Such a conversion would take several years to implement. RPI would request reconsideration ofthe timeline to implement this proposal understanding that such a re-design Ire-engineering procedure would impact 350 to 400 model numbers. A process of this magnitude would require a minimum oftenyears to realistically implement, provided the O.E.M

. sources of refrigerants and refrigeration components are readily available. • Ifthe current plan ofimplementation (January 2016) stays in place, without a thorough realistic evaluation of the engineering as well as cost impacts, then companies such as RPI would have immediate hardship to our business. Additionally, these proposed changes will have a much higher cost impactto all parties, without any clear benefit.
Thank you foryour consideration to these concerns.