EPA’s Final Rule on Refrigerant Delisting Presents Significant Challenges
Earlier this summer, the EPA published its final rule on refrigerant delisting (Federal Register Vol. 80 No. 138, July 20, 2015, 42870-42959). The rule, which was the latest move under the EPA’s significant new alternatives policy (SNAP), put to rest much speculation about how far-reaching the impacts would be to the commercial refrigeration industry.
When the original proposal was published on August 6, 2014, it created quite a stir in commercial refrigeration. Among other things, it proposed changing the status of three of the most commonly used refrigerants: R-404A, R-507A and HFC-134a, all typically found in stand-alone, reach-in and walk-in units, as well as traditional rack refrigeration systems. Soon after, many industry constituents called for caution, making their opinions known via the EPA’s NOPR (Notice of Public Rulemaking) commenting process.
Based on the nature of the final ruling, it’s clear the industry’s collective caution contributed to a less severe delisting timeline than what was originally proposed.
As expected, high-GWP, HFC refrigerants R-404A and R-507A are planned for phase-out in certain end uses — although, as previously referenced, the timeline is less aggressive than originally proposed. For example, in supermarket racks, the R-404A/R-507A ban was pushed from 2016 to 2017.
An important distinction of the EPA’s final rule regarding service of existing systems is worth noting: “Existing systems may continue to be serviced and maintained for the useful life of that equipment using the original refrigerant.”
Stand-alone applications — which include low- and medium-temperature, reach-in and walk-in units — now have some wiggle room to comply. In low-temperature, stand-alone systems, several new (and natural) refrigerants are approved for use, including: R-448A, R-449A, R-290 and R-744 (CO2). HFC-134a is still allowable in low-temperature systems, although new refrigerant blends R-450A and R-513A represent viable alternatives. Some of these refrigerants have high compressor discharge temperature issues; others have low capacity problems.
It is also worth noting that R-448A and R-449A, while recently SNAP-approved in most commercial refrigeration applications, were not approved for medium-temperature, stand-alone applications. Medium-temperature, stand-alone systems face the challenge of having to design with low-capacity refrigerant blends or move to hydrocarbons (or hydrocarbon blends), which are charge-limited flammable gases.
This blog is a summary of the article “Delist, Delay, Decipher” from our recent edition of E360 Outlook. Click here to read it in its entirety and learn more about the impacts of the EPA’s final ruling on refrigerants.