If there’s one word that can produce chills in the refrigeration industry, it’s “regulation.” Our industry is well-regulated already, particularly when it comes to areas such as energy efficiency and refrigerants, and further regulations are all but certain. Let’s take a look at how recently approved and pending regulatory actions related to refrigerants are affecting us here in the U.S.
A GLOBAL PERSPECTIVE
It seems as if hydrofluorocarbons (HFCs) had barely arrived on the scene before they were under siege for their relatively high global warming potentials (GWPs). Efforts to combat climate change through chemical regulation have largely focused on this property. While some would like to see all synthetic refrigerants banned regardless of their GWPs, others prefer to focus on what they believe to be more practical and achievable solutions. Still, others bemoan what they perceive as yet another round of chemical obsolescence along with the associated costs and the prospect of even more refrigerants to contend with.
For the last several years, proposals have been put forth to amend the Montreal Protocol to include a phasedown — not a phaseout — of HFCs on a GWP-weighted basis. The North American 2015 HFC Submission (see Figure 1 on Page 28) is composed of a series of stepdowns that would start in 2019 for developed (non-A5) countries with an ultimate target of reducing the GWP weighting of these products to 15 percent of the cap for all involved, including A5 parties (developing countries). While these proposals have not yet achieved global consensus, support has been steadily growing and it is becoming more likely that this amendment, or something close to it, will become a reality in the near future. Should this come to pass, further regulation at the national level will undoubtedly follow.
Those future regulations will surely focus on the GWP of HFC refrigerants. Therefore, it’s useful to establish a baseline of comparison for future discussions. Figure 2 shows the GWPs of some of the more commonly used HFC refrigerants in air conditioning and refrigeration applications. In order to significantly reduce the GWP footprint of HFCs, our industry will certainly need to transition away from refrigerants such as R-404A and R-507A wherever possible. However, even the relatively lower GWPs of products such as R-134a and R-407C are already considered too high for certain end uses.
CLOSER TO HOME
The U.S. Environmental Protection Agency (EPA) has been very active on the refrigerants front. Several recent regulatory actions are worth noting, as they will significantly impact the future of the refrigerants market. Rapidly approaching implementation dates will shape the market, as well.
The EPA’s “Final Rule – Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy (SNAP) Program” was finalized in the summer of 2015. This action will change the status of many higher-GWP HFC refrigerants (such as R-404A and R-507A) to unacceptable in a variety of new equipment and retrofit applications over the next several years. Much of the rationale for these changes is the fact that environmentally safer (i.e., lower-GWP) refrigerant alternatives have been developed and are available for use. Stationary HVACR system types affected by this rule include supermarket systems, remote condensing units, stand-alone retail food refrigeration equipment, and vending machines. Table 1 lists an abridged summary of the stationary end-use applications impacted as well as some of the better-known HFC refrigerant substitutes affected and the effective dates.
The implications of this ruling are extensive. First, to be clear, higher-GWP HFC refrigerants are not being banned outright. Existing installations can still use their original refrigerants for servicing over their useful life. Refrigerant retrofitting and new system installations, on the other hand, are another matter entirely.
In the U.S., we’re deep in the midst of an R-22 phaseout with the allocation of R-22 being further reduced each year. Many R-22 systems, such as those in supermarkets, will undergo a refrigerant retrofit in the coming years. However, a number of the currently approved higher-GWP HFC alternatives will no longer be acceptable retrofit options in the near future. Fortunately, there are several other widely used HFC refrigerant alternatives (for example, R-407A or R-407F) available that have lower GWPs.
Similarly, R-404A and R-507A will be unacceptable for new supermarket installations in 2017. As the supermarket industry has been steadily migrating away from these refrigerants to products such as R-407A and R-407F over the last several years, this is unlikely to become a disruptive issue for this market segment. Additionally, even lower-GWP alternatives — for example, HFC/hydrofluoroolefin [HFO] blends — are making their way into the marketplace.
For smaller systems, such as new stand-alone units or vending machines, the change in status may prove more challenging. Not only will higher-GWP refrigerants, such as R-404A and R-507A, be unacceptable mid-range GWP products, such as R-134a, R-407A, R-407F, and R-410A, are also being delisted for some of these applications. This will require OEMs to investigate lower-GWP alternatives, such as hydrocarbons (HCs), CO2, HFOs, and HFC/HFO blends. Some of these options may require significant equipment redesign.
At first glance, some might view the large list of refrigerants being delisted with great trepidation. However, end-uses targeted by these applications generally have viable alternatives in place. Two recent EPA Notices of Acceptability (Notices 29 and 30) have allowed for the use of new lower-GWP refrigerants in a variety of air conditioning and refrigeration applications. These products are primarily HFC/HFO blends that are positioned as replacements for R-134a, R-404A, and R-507A and have significantly lower GWPs — a third as much as the HFC refrigerants they are replacing, in some cases. Table 2 provides a brief summary of some of the new refrigerant/end-use combinations that have been approved by these actions.
Finally, the EPA recently issued a notice of proposed rulemaking that would update the refrigerant management requirements of Section 608 of the Clean Air Act. This proposal would extend requirements for ozone-depleting refrigerants to HFCs, lower leak-rate thresholds on industrial process and commercial refrigeration systems, and require regular leak inspections or continuous monitoring devices for refrigeration and air conditioning systems containing 50 or more pounds of refrigerant. It would also require technicians to keep records of refrigerant recovery during system disposal for systems containing 5-50 pounds of refrigerant.
When looking at the sum total of these actions, it’s clear our industry is being driven toward lower-GWP refrigerant alternatives, and that is going to be the regulatory trend for years to come. These regulations will present us with many challenges and opportunities as our industry works to help promote a more sustainable future.
Publication date: 3/7/2016