RPI Industries, Inc. 

Statements provided by Steve McGrath and James Dold 

Presented to the Environmental Protection Agency 

Date October 2, 2014 

Subject: 

Protection of the Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the 

Significant New Alternative Policy Program 

Docket ID: EPA-HQ-OAR-2014-0198 
RPIIndustries Inc. would like to thank the Environmental Protection Agency (EPA) for t he opportunity to 

appear before you today. 

RPI Industries, Inc. (RPI) is a manufacturer or refrigerated display cases and open air screen style 

merchandisers for the commercial and institutional food service industry. RPI's facility is located in 

Medford, New Jersey, approximately 15 miles southeast of Philadelphia, PA. RPI has enjoyed steady 

growth for the last ten years and has continued to support the local economy by increasing its work 

force each year. 

ISSUE 

During the summer of 2014, the Environmental Protection Agency (EPA) under the auspices of the 

Significant Alternatives Policy Program (SNAP) issued a directive to eliminate a class of certain 

refrigerants currently being used by manufacturers of self contained and remote open air refrigerated 

merchandisers, similar to 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 overall energy 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 or valve changes. In absence of these 

alternatives, we are left with basically two options; Propane and I or C02 

Propane: 

o Propane presents significant safety problems because of its flammability. It would not work in 

the majority of RPI's current systems due to the product's currently allowable charge limit. 

Increasing this charge or charge limit has not been pursued by testing laboratories such as 

Underwriters Laboratories (UL) so it cannot be considered a viable option. 

o Because of propane's flammability, it becomes a safety concern while handling in a shop 

environment and would also require significant training of service 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 of this concern, a flammable 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 of the systems. These 

units would also need to undergo new testing and recertification procedures for UL, NSF and 

DOE. 

o Changes as listed above would also increase overall energy consumption levels, potentially 

placing them over the limits established by the DOE several years back. These increased energy 

levels would also have a negative impact on the GWP, which is the intent this new rule is trying 

to prevent. 
o Although not flammable, 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 of current systems in use as would propane. 

o Also, although not flammable, 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 of these systems require heavier material thicknesses which are 

expensive for manufactures to produce, so many choose not to 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% of our 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 of thousands of dollars to accomplish. 

• The potential job losses across this entire segment of the commercial food service and 

hospitality industry would be devastating, not just the effects at RPI. 

• If the product RPI produces and distributes would not be available; customers and food service 

retailers who rely on this type of unit 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 of sale operators. 

POSSIBLE SOLUTIONS 

• There are several refrigerantscurrently submitted (thru the SNAP process) for approval. Some 

have been tested by RPI and other manufacturers and have produced very good results; many 

that are non-flammable and have produced lower energy consumption results. Although it 

would be difficult to have any one of these alternatives implemented prior to January 1, 2016, 

they could be implemented significantly faster than propane or C02 . 

./ Some of these alternatives would require compressor and valve changes, others would 

not. 

• The date for implementation needs to be extended. An initial proposed time frame for such a 

conversion of approximately 18 months is simply not adequate time. Such a conversion would 

take several years to implement. RPI would request reconsideration of the time line 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 of ten 
years to realistically implement, provided the O.E.M. sources of refrigerants and refrigeration 

components are readily available. 

• If the current plan of implementation (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 impact to all parties, without any clear benefit. 

Thank you for your consideration to these concerns.