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Federal Register / Vol. 86, No. 86 / Thursday, May 6, 2021 / Rules and Regulations
Honeywell states that the definition of new system should require the installation of new refrigerant piping, tubing or linesets and later stated that the tubing must be replaced, or at least inspected and reinforced to meet proposed requirements under ASHRAE
15.2. They said that existing tubing was not likely to meet minimum safety regulations. Trane said basing the proposed use conditions on ASHRAE 15
and ASHRAE 15.2 incorporates appropriate piping guidance and avoids the potential of unnecessary and costly restrictions.
Response: After consideration of these comments, EPA concludes that the use of existing piping that is consistent with the use conditions finalizedsuch as adherence to the UL 60335240
Standard and the inclusion of markings and labels as requiredand the safety protocols mentioned should not pose additional risk. We have clarified this in section II.B.5.a and likewise in the text of the corresponding footnote in section II.B.1.b of this final rule by not including refrigerant tubing in the description of new equipment in this final action. As such, existing piping does not need to be replaced for the equipment to be considered new while a new compressor, evaporator, and condenser are all required to be considered new. We believe this preamble text sufficiently indicates our intention and so have not included additional discussion in the regulatory text.
As noted by other comments, discussed elsewhere in this final rule, the UL Standard 60335240, which is incorporated by reference through this rule, addresses the situations where existing tubing might be used when installing a new system using a refrigerant in this rule. Consistent with the use conditions established in this rule, EPA finds that this standard provides appropriate criteria by which an installer would decide when exiting tubing may be used or needs to be replaced. Accordingly, EPA concludes it is not necessary or appropriate to define a new system to require installation of new refrigerant piping, tubing or linesets. If the existing tubing and linesets do not meet existing regulations separate from the UL Standard and our other use conditions, e.g. applicable building codes, other regulations or other authorities may require installation of new refrigerant piping, tubing or linesets. EPA also does not find it appropriate to adopt proposed requirements, including those proposed in October for ASHRAE 15.2, as those have not been finalized and neither commenters nor EPA can know
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the future content of a standard for certain until it is finalized.
Comment: Carrier brought up the possibility that an outdoor condensing unit using a non-flammable refrigerant e.g., HCFC22 or R410A might illegally be replaced with one of the six refrigerants in the listings in this final rule. Carrier urged EPA to work with the industry concerning the replacement of all components, e.g. including the indoor unit, as these instances will exhibit inspection and enforcement challenges.
Response: EPA notes that the final listings of these six refrigerants require they be used in a new system, including the replacement of the indoor unit of an existing HCFC22 or R410A system when the corresponding outdoor unit is replaced. We support education and training across the industry to improve awareness of and compliance with the requirements of this final rule. EPA
intends to continue to work with industry towards these goals.
Comment: Carrier and Chemours sought clarification where EPA stated in footnote 33 that the use condition for new equipment meant a completely new circuit. Chemours noted that a literal translation of that might be to require that an entire system be replaced, even if in the future a repair was being conducted on a system using one of the six A2L refrigerants in this final rule.
Response: EPA acknowledges Carriers and Chemours comments pointing out this potential misinterpretation of the use condition.
Under the use conditions finalized in this rule, EPA intends that once systems using these A2L refrigerants are installed, technicians, using proper safety procedures, may service the equipment similarly to servicing current day equipment using A1 refrigerants.
This intention to allow servicing and not strand equipment prematurely is consistent with prior SNAP decisions, as well as with approaches that we have taken under other provisions of Title VI
of the CAA to achieve a smooth phaseout and transition to safer alternatives. Such service would include replacing components including the condensing unit, and other adjustments. In those cases where one of the heat exchangers needs replacing, EPA recommends that outdoor units and indoor units be properly matched, including for instance replacing a functioning indoor A2L evaporator unit if warranted when the original A2L
outdoor unit is replaced with a higherefficiency outdoor unit using that same A2L refrigerant.

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iii. Labels Comment: AHRI, the Alliance, Carrier, Chemours, Daikin, Johnson Controls, Lennox, and Rheem suggested that EPA rely on the labeling requirements found in UL 60335240, including the font size requirement in the standard. Carrier held that the 18inch font size specified in the standard is easily readable and further noted that visual icons and flammability symbols are required by the standard.
Lennox felt this size, which is half the size required in other EPA listings e.g., 80 FR 19454, April 10, 2015, was justified given the refrigerants proposed have lower flammability A2L whereas the referenced listings were for higher flammability refrigerants A3.
Chemours stated that using a larger font disproportionally emphasizes flammability versus other safety aspects including electrical or pressure requirements. Rheem said that diverging from the UL Standard adds unnecessary complexity and Johnson Controls held that the introduction of new, unique requirements could lead to confusion in the field and thus increase safety risks. EIA, on the other hand, strongly supports the labelling requirements . . . outlined on the proposed rulemaking.
Response: As in other regulations promulgated under CAA section 612, EPA concludes that the proposed labeling requirement to use 14-inch fonts provides for an easier-to-read label than the 18-inch fonts in the standard;
hence, the large font size provides an extra layer of risk mitigation for technicians, consumers, retail store owners, building owners and operators, first responders, and those disposing of the equipment to readily understand the possibility that the equipment contains a flammable refrigerant. Accordingly, EPA is finalizing the larger text size as proposed.
The only differences to the actual text of the label between UL 60335240
and the requirement proposed and finalized in this rule are to the labels on the indoor unit, where for instance the minimum installation height in meters m and feet ft is to be referred to in the format X m Y ft rather than X m and Y ft as in the UL Standard, with X and Y calculated per the standard 85 FR 35881, June 12, 2020.
EPA believes the format is appropriate and would help avoid possible confusion if an installer were to interpret the label as called for in the UL
Standard to mean X meters plus Y feet i.e., 4.28 times Y feet or 1.305 times X
meters. Likewise, we proposed and are finalizing the same change in text
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