At its most recent stakeholder meeting (below), Ecology focused on the draft rule language regarding commercial refrigeration, asking end users to weigh in on how the new regulations could potentially impact their businesses.

New Deadline

At the meeting, Linda Kildahl, HFC rulemaking lead of the rules and planning unit at the Department of Ecology, went over some of the changes made to the draft rule language since the last meeting in March. One of the biggest changes concerned the new effective date for most commercial refrigeration equipment to comply with the 150 GWP limit, which is now January 1, 2025 instead of January 1, 2024 (see Table 1). The reason for that, she explained, is that GWP thresholds cannot be adopted before 24 months following the adoption of the new safety standards in the Washington state building code.

“The State Building Code Council has adopted the new standards for air conditioning but not for refrigeration,” she said. “We are trying to work with them on their dates for the refrigeration update, so these dates are not set in stone. They may not change if the codes are changed as they need to, but if not, then they will have to lag by 24 months.”

Kildahl noted that the 150-GWP limit applies only to new commercial refrigeration equipment, so new stores being built would have to purchase the equipment containing the low-GWP refrigerant. Existing stores could keep using their equipment until it needed to be replaced, and then any new equipment purchased would have to comply with the GWP threshold of 150. Given the connected nature of most supermarket refrigeration systems, rulemaking personnel hoped this meeting could clarify whether or not this strategy could work.

“We understand that it could be a chain reaction because components have different lifespans — they don't all die at the same time,” said Kildahl. “So we want to learn more about that.”

Current draft language states that replacement of a refrigeration component in an existing facility as part of normal maintenance is exempted from the rule if the cumulative replacement within any three-year period does not exceed 50% of the capital cost of replacing the entire refrigeration system or equipment, excluding the cost of refrigerated display cases.

Michael Dellecave, manager of mechanical services at The Kroger Co., noted that this type of calculation would be difficult, given the rising costs of equipment. He said it would be a lot easier to identify when half of a store’s compressors are replaced as opposed to half the cost of the compressors being replaced.

“This would take the subjectivity of costs out of it, because our costs are different than the cost structure for another company,” he said.

Barriers to Adoption

Tamara Dumitrescu, HFC technical lead at the Department of Ecology, asked stakeholders about the most significant barriers to transitioning to low-GWP refrigerants on a store- and company-wide level, and most participants said that cost was the biggest barrier. Right now, CO₂ is the only available refrigerant with a GWP of less than 150, and it requires that a whole new system be installed, said Glenn Barrett, engineering manager at DC Engineering in Coeur d’Alene, Idaho.

“Going to CO₂ from an HFC or synthetic refrigerant is very doable in terms of a large retrofit, but it's very, very expensive and very complex,” said Barrett. “It’s also disruptive to the store, so you couldn't expect a large chain to change out all of its stores to CO₂, because it's just not feasible from a first cost standpoint to the manpower to install it to finding all the equipment. It would be impossible.”

The availability of qualified technicians to install and service a CO₂ equipment is also a concern to Dellecave, who noted, “CO₂ is a significantly different type of operating system with quite dangerous operating pressures. Training is needed to be able to properly and safely maintain that type of system. And quite honestly, the technician base out there is not up to speed for wide use of those systems yet. There's a learning curve.”

Aaron Larson, technical services manager at Gensco Inc., noted that retrofitting to a CO₂ system would also result in significant downtime for the store.

“With CO₂, pressures can run two to three times higher than current refrigerants, so it's likely that the entire racking system, the evaporators, and the piping across the entire system would have to be replaced,” said Larson. “This could result in downtime lasting weeks, or possibly months, depending on supply chain issues.”

Leonard Machut, HFC unit supervisor at the Department of Ecology, sought to understand the downtimes associated with a retrofit, asking, “Couldn’t you flip the layout, so that half the store's getting retrofitted to new coolers? So the coolers normally on the left would be flipped to the right, or am I oversimplifying it?”

In a planned replacement, that type of scenario could possibly work, said Dellecave. But if it's an unplanned replacement, there will likely be significant downtime, which could include whole sections of the store being shut down, he said.

“Going to a 150 GWP or less system requires all new equipment,” said Dellecave. “If we don't shut the store down temporarily for a month or two to do this, then we have to find a place for that new equipment to sit while the other equipment stays up and running. So you have to phase in all this equipment, and quite honestly, in a lot of these stores, there's just not space to do that. Unless you go to the roof, which adds significant costs, reinforcing rooms and there's not a lot of real estate for us to expand that store maybe. So, that's where a lot of that difficulty comes in. You have to have a place to start, and a lot of these stores don't have spare space.”

Ecology personnel were receptive to the input from stakeholders, with Machut noting that the goal of the meeting was to “find the happy middle ground where we can be converting these systems and achieving some of the target admissions reductions that the state is looking for, while not having every grocery store pulling their hair out.”

The next stakeholder rulemaking meeting will take place on July 6, and interested parties can register here.