Webinar Wrap-Up: Preparing for the EPA’s Proposed SNAP Refrigerant Rule Changes
In my recent Making Sense Webinar “Staying Ahead of Rulemaking Proposals on Acceptable Refrigerants,” I explored the implications of the EPA’s recent significant new alternatives (SNAP) policy on supermarket and foodservice refrigeration applications. On August 6, the EPA also issued a notice of public rulemaking (NOPR) in the Federal Register, giving all stakeholders 60 days to comment on SNAP’s proposed delisting of refrigerants. The moves are a follow-up to the EPA’s recent stakeholder meetings to discuss the global warming potential (GWP) of HFC-based refrigerants, and explore which ones could be delisted and what their replacements might be.
While the EPA’s rulemaking on refrigerants is still undecided, it seems inevitable that two of our industry’s most common refrigerants — R404A and R507A — are likely to be delisted. Stakeholders can prepare now by educating themselves and getting engaged. Here are three important considerations to help you find solid ground amidst this very fluid situation:
- How will your application be affected? Each new alternative refrigerant presented for approval has very specific application parameters. For example, retail food refrigeration and vending machine application will require different alternative refrigerants. Make sure you know what the impacts will be on your application. Here’s the EPA’s official SNAP website: http://www.epa.gov/ozone/snap/index.html.
- Comment on the NOPR through October 6. If you have concerns, unique equipment and application requirements, or disagree with the proposed delistings, make sure your opinions are made known to the EPA by commenting on the NOPR. http://www.gpo.gov/fdsys/pkg/FR-2014-08-06/pdf/2014-18494.pdf. Failure to comment may be interpreted as tacit agreement with SNAP rulings.
- Carefully evaluate the alternatives. When considering replacement refrigerants, we must evaluate their key characteristics to minimize unintended consequences. This holistic view encompasses safety (toxicity, flammability, pressures), performance (physical properties, capacity, energy efficiency), economics (technology and equipment impacts, TCO) and of course, environment (regulatory requirements and life cycle climate performance).
As a component manufacturer, Emerson Climate Technologies is doing everything it can to stay ahead of proposed rulemaking by closely evaluating the viability of alternatives. In my webinar, I was fortunate enough to be joined by distinguished spokespersons from major chemical companies formulating the next generation of synthetic refrigerants. Patti Conlan, Fluorochemicals Market Manager from Arkema, Samuel Yana Motta, Refrigerants R&D Leader from Honeywell and Barbara Minor, DuPont Fellow from DuPont provided updates on the performance and GWP potential of each company’s future refrigerants. Since Emerson Climate has been participating in the EPA’s discussions for quite some time, we have already identified a class of viable synthetic and natural refrigerant alternatives — from R407A/F and CO2 to R290 — and are preparing in advance for product qualification.
There’s no question that the path before us is a challenging one. Low GWP options will have implications on safety, performance, economics and the environment. And finding options that strike a balance between all these factors will be the key to adhering to SNAP’s requirements in all applications.
If you’d like to hear my recent Making Sense webinar in its entirety, you may listen to it and other archived webinars on our website. Stay tuned for further updates on this dynamic topic as we Make Sense of the issues that matter most in commercial refrigeration.
Rajan Rajendran, Ph. D.
Vice President, System Innovation Center and Sustainability
Emerson Climate Technologies