The U.S. Environmental Protection Agency’s (EPA’s) final rule, announced July 2 and published in the Federal Register on July 20 (Federal Register Vol. 80 No. 138, July 20, 2015, 42870-42959), will — among other things — change the listing for certain refrigerants used for retail food refrigeration. The three main categories of equipment affected by the rule are stand-alone equipment, remote condensing units, and supermarket systems. The new rule has eliminated some uncertainty in the refrigerants industry because many were wondering what the EPA was going to do. Now we know.
The new rule is a part of the EPA’s efforts to reduce emissions by 26 to 31 million metric tons of carbon dioxide equivalent in 2020. In addition, the EPA could achieve more emission reductions if Section 608 of the Clean Air Act is extended to put HFCs under the willful venting rules, and if people take measures to control leaks during the equipment’s lifetime and properly perform recovery and reclamation at the end of life.
In anticipation of a lower global warming potential (GWP) world, we have seen increased interest in natural refrigerants such as carbon dioxide (CO2) and propane. Eliminating R-404A and R-507A from new supermarket refrigeration systems, remote condensing units, and from some stand-alone equipment will continue the movement towards lower GWP refrigerants. The new lower GWP refrigerants such as R-448A, R-449A, R-450A, and R-513A all have less than half the GWP of the candidates they are replacing. While the rule identifies dates for the prohibition of certain refrigerants in “new” and “retrofit” equipment, it states “existing systems may continue to be serviced and maintained for the useful life of that equipment using the original refrigerant.”
The substitute refrigerant options and applications are likely to challenge the industry. When we went from HCFC-22 to R-410A in air conditioning, and from HCFC-22 to R-404A and R-507A in refrigeration, the transition took many years of effort. This change will be much more difficult because now it’s not going to be just two new refrigerants like R-404A and R-507A — it’s going to be more than a dozen refrigerant options. Component and equipment manufacturers, distributors, contractors, and technicians are all looking at a large menu of refrigerants for each application in refrigeration.
Of the three equipment categories, the stand-alone equipment segment is likely to face more challenges because they must design equipment to meet the new efficiency standards that the Department of Energy has proposed for 2017, and also change refrigerants to meet these new requirements. In particular, without R-448A and R-449A approval, equipment that uses R-404A or R-507A in medium-temperature stand-alone applications will probably move to a flammable refrigerant such as propane, or a high pressure refrigerant such as CO2, or could go to lower GWP, lower pressure alternatives that have been approved, such as R-450A or R-513A. In all cases, complete redesign of equipment accompanied by performance and agency qualification work will be required. In low-temperature stand-alone equipment, high compressor discharge temperatures are likely to pose problems in some instances where new refrigerant options such as R-448A and R-449A have been approved.
As is often the case with regulations, whether they are efficiency or refrigerant-related, where “the rubber meets the road” is with the contractors. They’re going to be dealing with a lot more refrigerants and must be careful to apply them correctly. For the contractor base, the next five or 10 years are going to be a very intense period of education and learning.
So, ultimately, I think the elimination of the uncertainty about the terms of the final rule will help the refrigerant world by providing a clear direction. Now everyone knows what they are dealing with, and the known is always easier to face than the unknown.
We at Emerson are constantly working with all of our customers to help navigate through these complex issues. We held a webinar on the EPA regulations on August 18, and it is archived and available for viewing on our website at www.emersonclimate.com/E360-Webinars.