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SNAP, CAP and all That: Feedback From the Recent EPA Meeting on HFCs

During the past several months, the Significant New Alternatives Policy (SNAP) program hosted a series of sector-specific workshops and a broad stakeholder meeting. In February, I participated in the EPA’s broad stakeholder meeting on possible future actions and direction concerning hydrofluorocarbons (HFCs) under the SNAP program and the Climate Action Plan (CAP).

The purpose of the February 2014 meeting was to promote a dialogue between stakeholders and the EPA on possible next steps and effective approaches to meet the president’s goals under CAP. At the meeting, the EPA announced plans for two separate SNAP rule-making proposals this year:

Expanding the list of low-GWP refrigerants for air conditioning and refrigeration applications — under consideration are ethane, iso-butane, propane, R-441A (HC blend) and HFC-32. All of these refrigerants (except HFC-32) have a GWP of less than 10. Since these refrigerants are also flammable, the EPA is planning to adopt safety standards and propose specific uses for each refrigerant. The EPA expects to move on this in spring 2014.

Changing the approval status of certain high-GWP HFCs in specific applications — the EPA is not expected to issue any across-the-board GWP limits, but instead will consider the end use and target-specific applications where viable options already exist and are being used. For instance, a high-GWP refrigerant in one application may be considered in the low- to mid-range for another. In addition, servicing existing equipment will not be impacted to help prevent stranding capital.

The five proposed specific application and HFC status changes include:

  • Vending machines and stand-alone, reach-in bottle coolers — changing the status (banning the use) of R-134a and blends with a higher GWP
  • Multiplex supermarket refrigeration — banning the use of R-404A, R-507A, and blends with a higher GWP. Retaining R-407A/C/F and R-134a or any approved refrigerant with a GWP lower than R-404A and R-507.
  • Motor vehicle air conditioning — banning the use of R-134a
  • Non-medical and non-technical aerosols — banning the use of R-134a, HFC-227ea and HFC-125. Retaining HFC-152a.
  • Various foam blowing — banning the use of R-134a and higher-GWP refrigerants

The EPA expects to move on this in summer 2014.

We believe these proposals are a logical approach to CAP and welcome additional clarity to HFC action in the industry. However, these measures will not be accomplished without significant investments by our industry in equipment and training, and these investments need to be considered in conjunction with the recent U.S. Department of Energy’s proposed improved energy efficiency standards for commercial refrigeration equipment.

Stay tuned for further details including effective dates as the actual proposals are targeted for release this spring and summer. Emerson will continue to be involved in the process and provide feedback when appropriate to the EPA. We are open to arranging discussions around this topic and look forward to your thoughts on these proposals.

Rajan Rajendran, Ph.D.
Vice President, Engineering Services and Sustainability
Emerson Climate Technologies

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