EPA Targets High-GWP Refrigerants in SNAP Proposal
R-134a, -404A, and -507 Face Proposed Use Restrictions in 2016
The government is proposing to restrict the use of hydrofluorocarbon (HFC) refrigerants R-134a, -404A and -507 in certain new and retrofit retail food applications.
On Aug. 9, the U.S. Environmental Protection Agency (EPA) published “40 CFR Part 82 Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program; Proposed Rule” in the Federal Register.
The rule deems certain HFC refrigerants unacceptable in specific applications on or after Jan. 1, 2016. If implemented, the ruling would impact:
• R-507 and -404A for “new and retrofit retail food refrigeration (including stand-alone equipment, condensing units, direct supermarket systems, and indirect supermarket systems) and new and retrofit vending machines.”
• R–227ea, –407B, –421B, –422A, –422C, –422D, –428A, and –434A for “new and retrofit retail food refrigeration (including direct supermarket systems and indirect supermarket systems).”
• R-134a “and certain other HFC refrigerant blends for new stand-alone retail food refrigeration and new vending machines.”
A Proposal for Now
The proposal is just that — a proposal. The agency is accepting comments through Oct. 6, after which it would issue a final ruling. The proposal is based on concerns about the perceived high-global warming potential (GWP) of the listed refrigerants. All are used within the retail food sector, where leak rates for equipment can be as high as 30 percent, although that sector has made significant strides in recent years to reduce those rates.
The proposal is also based on the EPA’s contention that acceptable alternatives are available. These include low-GWP HFCs, hydrocarbons (HCs), and CO?.
In general, the industry is responding favorably to addressing the issue of high-GWP HFCs, although a number of companies are concerned about the speed of the 2016 target and how the EPA is going to implement it.
Coming up in support of the proposal was Jay Kestenbaum, senior vice president of sales and purchasing, Airgas Inc., who said, “The EPA proposal is reasonable and proper, given the environmental push to attempt to speed up the elimination of more environmentally harmful refrigerants and push industry toward less harmful alternatives.”
That position was echoed in a statement from Honeywell Intl. Inc., which, in part, said, “The EPA’s action will not only benefit the environment, but will also position America as a leader in eliminating potent greenhouse gases by adopting next-generation materials that reduce climate impact by more than 99.9 percent in some cases.”
While many favor the EPA’s actions in addressing GWP issues, there are concerns about the EPA’s approach and timing. “While we support a shift toward environmentally friendly, low-GWP refrigerants, we also recognize the pressure it puts on the retail food refrigeration industry because of the compressed timeline that’s been proposed,” said Rajan Rajendran, vice president, engineering services and sustainability, Emerson Climate Technologies Inc.
Mark Menzer, director of public affairs — North America, Danfoss, said, “The EPA’s ‘de-listing’ proposal would use regulatory methods rather than an orderly market-based approach, and the proposed deadline is unrealistic, considering the time it would take manufacturers to redesign product lines and the time needed to change state and local building and fire codes to accommodate new low-GWP refrigerants. More collaboration is needed among the EPA, manufacturers, and codes and standards bodies to establish reasonable timelines.”
Gordon McKinney, vice president and COO, ICOR Intl. Inc., has similar beliefs. “There are a number of concerns with the proposed SNAP rules aimed at delisting high-GWP refrigerants, and those concerns are shared by Europeans as they roll out recently passed f-gas regulations,” McKinney said. “The primary concerns are with safety, economic impact, enforcement, and the time frame for implementation.
“With so many critical factors to consider, these rules should not be rushed through until the EPA has done its due diligence. It is very apparent the EPA is working overtime to expedite new regulations in support of the administration’s Climate Action Plan, and that puts the entire rulemaking process into question.”
Brad Halford, director of marketing and sales, Polar Technology, said, “The EPA is looking at this from too narrow of a perspective. The agency is just looking at the leak value of refrigerants and not the energy conservation or the use of the equipment. Because of this, there will be a ton of unnecessary retrofits that could actually increase economic costs because of high energy costs.”
Contractors must be aware of this proposal and be prepared to adjust.
“In some segments, such as residential air conditioning, the proposal would have no real effect. In others, it will change the nature of the refrigerants and equipment that customers seek,” said Debra Goodge, refrigerants reclaim manager, DuPont Refrigerants.
“The EPA’s intent is to avoid any stranding of equipment, and the proposed rule would not affect service in any way. It will only apply to new equipment or retrofits. Contractors should review the proposed rule in detail and begin to discuss potential changes with customers.”
Maureen Beatty, vice president of operations, National Refrigerants Inc., said: “It is important for contractor’s to realize that the EPA is not proposing to, nor do they have plans to, ban the use of these refrigerants to service the installed base of equipment (that is in place as of Jan. 1, 2016). The affected refrigerants will be available for a long time to come, which will permit the continued servicing of (pre-2016) equipment throughout its useful life.”
Matthew Ritter, director of government activities, Arkema Inc., said: “Contractors should anticipate a busy 2015 season with R-404A and R-507A. After Jan. 1, 2016, there are no more new installations of R-404A or -507. Also, contractors should be aware that nine of the current retrofit refrigerants are proposed for a change of status, which would leave only 10 (HFC) refrigerants authorized for retrofit.”
For now, most supermarket refrigeration contractors are working with HFCs, but more and more are converting to low-GWP refrigerants, which are readily available through a number of manufacturers. Other contractors are looking at ways to reduce all HFC charges in stores and have been teaming up with OEMs in installing secondary and distributed systems. Other approaches now being used include use of CO2 in transcritical systems and the use of the HC propane for reach-in coolers.
Rick Rogers, owner, Rogers Refrigeration Service, Monroe, North Carolina, was involved in a supermarket project where glycol was used in a secondary-loop approach to reduce the amount of HFC needed in the store. He called the specific approach he used which involved a Hillphoenix Second Nature Compact Chiller, “a way to steer clear of HFCs,” and “the most effective way to reduce the amount of HFC in a supermarket.”
Publication date: 9/15/2014