Is this legal - new R22 condenser and R22 evap coil?

[Slowrider5]

Yes, it's legal. Is it smart? No. Dry ship condensers are not considered "equipment" anymore, they are classified as replacement parts.

All up to interpretation, but as noted earlier the manufacturer has determined it's not legal as noted in the system technical specs.

Page 3: https://www.younits.com/media/wysiwy..._Tech_Spec.pdf
Note: EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil).

[lkapigian]

All up to interpretation, but as noted earlier the manufacturer has determined it's not legal as noted in the system technical specs.

Page 3: https://www.younits.com/media/wysiwy..._Tech_Spec.pdf
Note: EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil).

That's good, I misread that you would gladly purchase for 10 years, my bad- None the less you will be overpaying the utility if their work is not spot on...........So don't forget to work that avenue of their "Improper Install" which has no real definition in their books....Insist on ACCA 5

[HVAC/Stud]

Where are you getting its against epa rules to install a R-22 system? Its against the EPA to manufacture a R-22 system, with R-22 in the system. Manufacturing found a loop hole in the rule, and can ship dry units to distribution centers.
Like I said if you can find a complete R-22 system in a wearhouse, barn or garage, you can install it all day long.
Back to first thread, no its not illegal to.install a R-22 systems.

[lkapigian]

Where are you getting its against epa rules to install a R-22 system? Its against the EPA to manufacture a R-22 system, with R-22 in the system. Manufacturing found a loop hole in the rule, and can ship dry units to distribution centers.
Like I said if you can find a complete R-22 system in a wearhouse, barn or garage, you can install it all day long.
Back to first thread, no its not illegal to.install a R-22 systems.

He is quoting this line on the PDF Note: EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil). .............. But this is still considered a repair not a system

[Slowrider5]

The contract says First American will replace the evap coil “to maintain compatibility and operating efficiency as required by the manufacturer of the replacement condenser”.

The only way to determine what the condenser manufacturer requires for matching the evap coil to the condenser is by looking at the condenser technical specs. For every condenser tech specs document I've looked at, the manufacturer only provides compatibility and efficiency ratings using their own evap coils.

In this case, Aire-flo does not provide a list of matching evap coils for the 13HPD in the technical specs. The tech specs clearly say this is because “EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil)”.

Therefore, it is impossible for First American to provide a R22 evap coil that meets the manufacturer specs because the manufacturer does not provide any specs! The manufacturer states in the tech specs document that they do not provide matching evap coil info because matching both pieces together constitutes a "system", and installing a "system" is illegal.


Obviously, Aire-flo is owned by a large conglomerate and there are identical documents for the same model branded Armstrong and AirEase. "Allied Air Enterprises LLC, a Lennox International Inc. Company". I'm pretty sure Lennox has some good lawyers. Their opinion is good enough for me and gives me the leg to stand on that I needed.

[lkapigian]

The contract says First American will replace the evap coil “to maintain compatibility and operating efficiency as required by the manufacturer of the replacement condenser”.

The only way to determine what the condenser manufacturer requires for matching the evap coil to the condenser is by looking at the condenser technical specs. For every condenser tech specs document I've looked at, the manufacturer only provides compatibility and efficiency ratings using their own evap coils.

In this case, Aire-flo does not provide a list of matching evap coils for the 13HPD in the technical specs. The tech specs clearly say this is because “EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil)”.

Therefore, it is impossible for First American to provide a R22 evap coil that meets the manufacturer specs because the manufacturer does not provide any specs! The manufacturer states in the tech specs document that they do not provide matching evap coil info because matching both pieces together constitutes a "system", and installing a "system" is illegal.


Obviously, Aire-flo is owned by a large conglomerate and there are identical documents for the same model branded Armstrong and AirEase. "Allied Air Enterprises LLC, a Lennox International Inc. Company". I'm pretty sure Lennox has some good lawyers. Their opinion is good enough for me and gives me the leg to stand on that I needed.

Keeps us informed of how this works out for you since the EPA has changed Condensing Unit from "Equipment" to Component" If you can get this deemed illegal you are doing something Carrier and the other Big Boy's could not........

[beenthere]

You had a working system that stopped working. Now, two repair parts are being installed.

You did not contract with a company to have a new system installed.

Therefore it is not considered a new system.

It is a new system. Since the indoor is being changed at the same time as the new outdoor unit. Its the same as installing a new A/C or heat pump on an existing furnace.

EPA prohibits it from being charged with virgin R22. It may be recharged with reclaimed R22 though.

[timebuilder]

If they had replaced the lineset and the furnace, it would be a new system.

But that is just one man's opinion. I'm sure others will differ.

If I recall, I was the lone voice that said dry R22 condensers would be available as replacement parts, and everyone said, "oh, no. EVERYONE will have to switch to 410a."

I then explained that it would hit commercial retail spaces like a capital expense tsunami.

Suddenly, dry charge units are legal to install.

So, from the same viewpoint, this is not a new system.

[lkapigian]

In the home warranty world. 13 seer coverage simply means they cover 13 seer equipment.... In the OP case he is lucky they said they would give him a coil, this is typically an "up grade" whether it is needed to match the outdoor is mute........I have fought this battle with home warranty and it is why we fire all of our home warranty companies....it is an pea loophole as big as the ozone itself and its not likely the OP will close it, I wish him luck

As a contractor I say, pick and choose your battles, take the cash out from them and upgrade to a better system, have an energy audit done and do it right

Some people like to battle, I choose to walk away, my time is valuable and I do out price on my time, everybody should

[beenthere]

If they had replaced the lineset and the furnace, it would be a new system.

But that is just one man's opinion. I'm sure others will differ.

If I recall, I was the lone voice that said dry R22 condensers would be available as replacement parts, and everyone said, "oh, no. EVERYONE will have to switch to 410a."

I then explained that it would hit commercial retail spaces like a capital expense tsunami.

Suddenly, dry charge units are legal to install.

So, from the same viewpoint, this is not a new system.

Wasn't unusual to install a line set in a new house on a slab in anticipation of an A/c being installed later. So using the old line set doesn't mean its not a new A/C. Same as if they installed a new air handler and condenser, but reused the old line set. its still a new system.

I sold a lot of new A/Cs but used the existing furnace and reused the line set.

[timebuilder]

Like I said, I'm sure there are other opinions.

The home warranty company doesn't have their contractors install new systems. They have them repair existing systems.

[beenthere]

Like I said, I'm sure there are other opinions.

The home warranty company doesn't have their contractors install new systems. They have them repair existing systems.

So a home warranty company never has a contractor replace a furnace?

[lkapigian]

So a home warranty company never has a contractor replace a furnace?

They do, and I think we ALL know what they do is wrong, no doubt I believe we are all on the same page

I still see contactors installing Dry R-22 new furnace and coils, Personally lay some blame on the consumer that simply shop price, don't feel sorry for them all the time, sometimes I do.

When they say "I'll take my chances" I don't feel sorry, when they really fell for a line from a HACK Contractor, I will do everything in my power to help them out

We used to do around 2000 Home Warranty Calls per year, made a lot of great long time customers. The biggest issue is what the homeowners think they bought and what they are really getting, we got tired of defending them.

The OP may get their wish, but it is hush money. I don't think anybody will find a definitive Dry R-22 with Coil- Illegal..........I think we all agree its wrong

[lkapigian]

Bumping this thread...................So can anybody find in the EPA's Info this line "EPA rules prohibit system installations (condensing unit coupled with an air handler or evaporator coil)"

Have a house where someone put in a complete system with dry r-22, would love to quote the EPA

[timebuilder]

So a home warranty company never has a contractor replace a furnace?

I said system. A furnace is not a system, it is a part of a system.

[pecmsg]

This is all fine and dandy but who’s going to inforce it? I doubt permits are pulled, Building Dept is powerless, EPA is nonexistent, Who?

No One!

[vstech]

I think the Homeowner is responsible for inspection... they should call one in, and verify the work is legal, and passes inspection. and that the contractors are legally authorized to perform the work.

[lkapigian]

This is all fine and dandy but who’s going to inforce it? I doubt permits are pulled, Building Dept is powerless, EPA is nonexistent, Who?

No One!

The reason I am bumping is we have a customer that had a complete "System" installed earlier this year with a dry r-22, new coil new furnace...I would like to find somewhere from the EPA that this cannot be done..........I have looked though the EPA Abyss of a web site and cant find anything

[vstech]

the faq on the epa site states that new R22 containing systems not allowed after 2009... but since there is a loophole, I think there isn't anything the EPA can do about skirting the rules with dry ship stuff...

unless the manufacturers stop making them.

[lkapigian]

the faq on the epa site states that new R22 containing systems not allowed after 2009... but since there is a loophole, I think there isn't anything the EPA can do about skirting the rules with dry ship stuff...

unless the manufacturers stop making them.

That is all About all I can find--------------From the MFG

NOTICE
THIS UNIT IS SHIPPED WITH A NITROGEN/HELIUM
HOLDING CHARGE ONLY. UNIT MUST BE EVACUATED
AND CHARGED PER INSTALLATION INSTRUCTIONS
WITH REFRIGERANT LISTED ON SERIAL RATING PLATE.
NOTICE
UNITS SHIPPED WITH A HOLDING CHARGE ARE
INTENDED FOR COMPONENT REPLACEMENT ONLY ON
EXISTING SYSTEMS, AND NOT INTENDED FOR USE IN
NEW SYSTEMS OR NEWLY CONSTRUCTED HOMES.
NOTICE
UNITS MUST ONLY BE USED AS REPLACEMENT
COMPONENTS FOR PRE-2010 INSTALLED SYSTEMS.

Technically it is a new system AND technically it replaced components from a system pre 2010