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Refrigerant Regulations: 2020 Update

RajanRajendran2 Rajan Rajendran | V.P., System Innovation Center and Sustainability

Emerson Commercial & Residential Solutions

For several years, the regulatory landscape regarding the governance of refrigerants has been constantly shifting. Already in 2020, we’ve seen developments, both on the state and federal levels in the U.S., which will have significant impacts on the commercial refrigeration and air conditioning sectors for years to come. We recently published an E360 article that lays out these regulatory developments in detail; this blog is a condensed summary of its key points.

Global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP) and replacing them with lower-GWP options. But while emerging refrigerants — such as natural alternatives and new synthetic blends of HFCs and hydrofluoroolefins (HFOs) — offer environmental improvements, they are not without their operational caveats. Making the transition to these new alternatives will impact refrigeration architectures and raise concerns about performance and safety.

This dynamic combination of factors creates a complex regulatory mix that industry stakeholders have been actively working to resolve. To better understand the full context, we’ve summarized the major regulatory developments in the U.S. and abroad.

Update on EPA SNAP Rules 20 and 21

In 2017, the U.S. District Court of Appeals for the D.C. Circuit ruled to vacate the Environmental Protection Agency’s (EPA) Significant New Alternative Policy (SNAP) Rule 20 — ruling that the EPA did not have authority to require those who had already moved out of ozone depleting substances (ODS) to phase down to lower-GWP HFCs under its Clean Air Act (CAA). Subsequently, the EPA published a “Notification of Guidance,” stating that it would not enforce any of the HFC restrictions set forth in SNAP Rules 20 and 21 when drafting future regulations.

The Natural Resources Defense Council (NRDC) filed a lawsuit claiming that the 2018 Guidance was overly broad because it did not distinguish between ODS and HFC replacements, and that the EPA had not followed proper public notice-and-comment procedures to seek stakeholder input.

On April 7, 2020, the Court of Appeals granted the NRDC’s petition, stating that the EPA guidance was procedurally inappropriate. The court agreed that the initial 2017 decision required only a partial vacatur — not entirely eliminating the requirements SNAP Rules 20 and 21.

It’s important to remember that the industry had already made great strides toward meeting the mandates of SNAP Rule 20 after its passing in 2015, but these ongoing legal entanglements have left the U.S. without a clear path forward in terms of a unified refrigerant strategy. While the majority of the industry still supports the move toward a more sustainable and environmentally friendly future, court rulings around SNAP Rules 20 and 21 have created many questions about what the path forward will look like.

HFCs excluded from refrigerant management requirements

In response to the 2017 Court of Appeals ruling, the EPA also has rolled back other HFC-related regulations. Specifically, it excludes HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA. Other beneficial provisions of Section 608 — including the certified technician program and the refrigerant recovery and reclamation rules — are still in effect.

California continues to set the pace

The passing of California Senate Bill 1383 (the Super Pollutant Reduction Act) in 2016 called for Californians to reduce F-gas emissions (including HFCs) by 40 percent by 2030. Since then, the California Air Resources Board (CARB) had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. The subsequent passing of California Senate Bill 1013 (the California Cooling Act) in 2018 mandated the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017; the law is currently in effect.

To meet HFC reductions of 40 percent by 2030, CARB continues to hold public workshops and invited industry stakeholders to comment on the details of its second phase of proposed rulemaking, which currently states:

 

  • Refrigerants with a GWP greater than or equal to 150 will not be allowed in new stationary refrigeration systems charged with more than 50 pounds, effective Jan. 1, 2022.
  • Existing food retail facilities with refrigeration systems charged with more than 50 pounds must collectively meet a 1,400 GWP average or 55 percent greenhouse gas emission potential (GHGp) reduction over 2018 levels by 2030.
  • Refrigerants with a GWP greater than or equal to 750 will not be allowed in new stationary air conditioning equipment, effective Jan. 1, 2023.
  • Refrigerants with a GWP greater than or equal to 750 will not be allowed in chillers (including process chillers) greater than -15 °F and ice rinks, effective Jan. 1, 2024.
  • Refrigerants with a GWP greater than or equal to 2,200 will not be allowed in new chillers ranging from
    -15 °F through -58 °F, effective Jan. 1, 2024.

 

CARB is planning to finalize these rulemaking proposals this summer and is still seeking industry input.

More states join U.S. Climate Alliance

In 2017, a coalition of 16 states and Puerto Rico emerged to form the U.S. Climate Alliance, with a shared commitment of reducing short-lived climate pollutants (SLCPs) and HFCs. Since then, the Alliance has grown to 25 members — comprising more than 55 percent of the U.S. population and an $11.7 trillion economy. Several states have announced plans to follow California’s lead on HFC phase-downs.

Refrigerant safety standards and codes under review

Meeting the targeted emissions reductions in California likely will require the use of low-GWP refrigerants. But many of these low-GWP, HFO refrigerants are classified as A2L, or mildly flammable. The natural A3 refrigerant R-290 (propane) also is becoming more widely used in low-charge, self-contained commercial refrigeration applications. Currently, national and global governing agencies are evaluating the standards that establish allowable charge limits and the safe use of these A2L and A3 refrigerants.

Per a 2019 update from the International Electrotechnical Commission (IEC) to IEC60335-2-89, A2L and A3 charge limits have been increased for commercial refrigeration systems:

  • A2Ls — from 150g to 1.2kg
  • A3s — 500g for factory-sealed systems, and will remain at 150g for split systems

Similar efforts to raise A2L and A3 charge limits also are taking place in the U.S. The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and Underwriters Laboratory (UL) are working to establish new charge limits and mitigations for the use of A2L and A3 refrigerants with support from industry and various stakeholders.

Once adopted, these standards will serve as the bases for codes that govern building, fire and other local authorities having jurisdiction (AHJ). It’s important to remember that building codes vary from state to state; thus, the adoption of flammable refrigerants ultimately may take place on local levels and may take years to accomplish.

Kigali Amendment not ratified in U.S.

In 2016, 197 member countries of the Montreal Protocol met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. The Kigali Amendment required ratification from at least 20 countries to take effect. To date, 92 countries (including many countries in the E.U., but not including the U.S.) have ratified it; it has been in effect for participating countries since Jan. 1, 2019.

According to industry estimates, ratifying the Kigali Amendment could create up to 33,000 jobs in the manufacturing sector by 2027 and have a positive impact on the U.S. economy. For these reasons, industry advocates are in favor of ratification and have demonstrated this through letters of support to both the Senate and the White House.

New HFC bills introduced in the U.S.

The U.S. Senate and the House of Representatives have each penned new bills that would put the EPA in alignment with the Kigali Amendment and restore the EPA’s authority to phase down the production and consumption of HFCs over a 15-year period.

  • Senate: American Innovation and Manufacturing Act of 2019 (S2754)
  • House: American Innovation Leadership Act of 2020 (HR5544)

While the future and timing of these new bills are uncertain, they offer the potential to re-establish a federal standard for HFC management, including guidelines for servicing, recovery, recycling and reclamation.

Industry appeals for consistency

Industry advocates, including the Air-conditioning Heating and Refrigeration Institute (AHRI) and the NRDC, have appealed for states to be consistent in their approach to adopting CARB’s rules. Establishing a unified framework for future refrigerant regulations would provide the certainty needed to help the industry and regulatory bodies move forward with a consistent approach. At Emerson, we’re actively involved in helping the HVACR industry evaluate and steer these proposals — in industry committees, stakeholder meetings and public comments.

 

[Webinar Recap] 8 Keys to Understanding the Ongoing Refrigerant Transition

RajanRajendran2 Rajan Rajendran | V.P., System Innovation Center and Sustainability

Emerson Commercial & Residential Solutions

The transition to more environmentally friendly refrigerants in commercial refrigeration and air conditioning applications is underway all around the globe. In the United States, ever-evolving state and federal regulations are forcing industry stakeholders to pay close attention to the developments taking place in their regions. Regardless of your specific location or operational requirements, the use of hydrofluorocarbon (HFC) refrigerants is being phased down in favor of alternatives with lower global warming potential (GWP).

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I recently co-hosted an E360 Webinar with Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, to discuss the latest regulatory developments and industry trends driving this transition. For those who could not attend this informative session, you can view the webinar in its entirety. And if you need a primer for quickly understanding this transition, I developed the following list to highlight the key points of our discussion:

  1. The refrigerant transition is not new — In the 1980s, scientists discovered that chlorofluorocarbon (CFC) and hydrochlorofluorocarbon (HCFC) refrigerants — such as R-22 — were contributing to the depletion of the ozone layer. The Montreal Protocol Treaty was enacted in 1987 to ban the use of refrigerants with ozone depletion potential (ODP); since then, the hole in the ozone layer has steadily recovered. But the ban on these refrigerants led to the introduction of HFCs — such as R-404A and R-410A — which were then proven to cause global warming. As a result, the Kigali Amendment to the Montreal Protocol was established in 2016 to phase down the use of HFCs; it went into effect in 2019 for its 20 participating member countries.
  2. The transition is a global effort — Even before the Kigali Amendment went into effect, other global regions and countries established their own HFC phase-down regulations. The European Union’s F-Gas regulations, which went into effect in 2014, has led the way on establishing a framework for rulemaking. Environmental Canada enacted its own HFC rulemaking in 2017; many of its requirements went into effect this year.
  3. California takes initiative in the U.S. — In the absence of federal regulations, the California Air Resources Board (CARB) has introduced its own HFC phase-down measures, starting with the adoption of the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rules 20 and 21. In addition, it is currently working with industry associations and stakeholders to develop proposals to achieve additional GWP reductions by 2030. Many in the industry consider CARB’s proposals among the most ambitious in the world.
  4. States are joining the charge — Following California’s lead, many states have also committed to introduce climate change initiatives, including the reduction of HFCs. Currently, 25 members have joined the U.S. Climate Alliance, which now represents more than 55% of the U.S. population and an $11.7 trillion economy. A few member states have also adopted SNAP Rules 20 and 21 into law; however, each of these states has set forth varying implementation timelines, which will only add complexity to the national regulatory landscape.
  5. New federal regulations are on the horizon — To restore federal guidance pertaining to HFC phase-down regulations, both the Senate and the House have recently introduced new bills, respectively: The American Innovation and Manufacturing Act of 2019, and the American Innovation and Manufacturing Leadership Act of 2020. Both bills align with the HFC reduction goals established in the Kigali Amendment and would authorize the EPA to once again regulate HFCs and establish standards for HFC
    management (servicing, repair, recovery, recycle, reclaim, etc.). The general consensus throughout the industry is that a standardized federal approach would minimize compliance complexities created by a potential patchwork of state regulations.
  6. The next generation of refrigerants is already here — Many low-GWP alternative refrigerants not only have been developed already, they are being designed to replace HFCs commonly used in specific applications today. These refrigerants offer varying GWP ranges and cover the spectrum of refrigerant safety classifications, from A1 (non-flammable) to A2L (mildly flammable) to A3 (highly flammable) and B2L (toxic, mildly flammable). It’s important to point out that many of the lowest-GWP alternatives are classified as A2L, and thus will require equipment and facility redesigns to meet application and safety standards.
  7. Safety standards and codes are evolving — With the industry moving toward the use of flammable refrigerants, the technical committees and governing bodies who provide guidelines on how to safely use these refrigerants are actively updating safety standards. While these activities are ongoing, it’s important to remember that once established, these standards will take several years to make their way into both model and local codes needed to permit the widespread use of flammable refrigerants. The industry still has more work to do before that becomes a reality.
  8. System architectures are changing — This transition is ushering in a new era of system architectures. To utilize low-GWP refrigerants, reduce refrigerant charges and the potential for leaks, look for the commercial refrigeration industry to shift from traditional centralized systems toward more distributed approaches. Natural refrigerant architectures — such as CO2 transcritical booster and R-290 integrated cases — will also continue to expand. Manufacturers are utilizing familiar booster technologies and components to help end users transition to lower-GWP A1s today and even lower-GWP A2Ls in the future. In trials, these systems have provided significant energy savings with reduced installation costs and refrigerant charges.

To learn more details about any of these points, please view this informative webinar in its entirety.

Why Contractors Need to Prepare Now for the Coming CO2 Refrigerant Revolution

DonGillis Don Gillis | Technical Training Specialist

Emerson Commercial & Residential Solutions

CO2 is an emerging natural refrigerant alternative, but it poses a sharp learning curve for technicians in the U.S. I recently authored an article in RSES Journal that explains why contractors will need to start enhancing their knowledge and adapting their skillsets now to prepare for future servicing needs. You can read the full article, “Fundamentals of CO2 Refrigeration,” here.

Why Contractors Need to Prepare Now for the Coming CO2 Refrigerant Revolution

Why Contractors Need to Prepare Now for the Coming CO2 Refrigerant Revolution

As the drive to replace hydrofluorocarbon (HFC) refrigerants with lower-GWP (global warming potential) alternatives heats up, CO2 (or refrigerant R-744) is a proven natural option that is experiencing wider adoption in the U.S. — particularly in large centralized systems.

Natural refrigerants — so named because they occur naturally in the environment — also include both propane and ammonia. But for larger-format supermarket operators seeking an all-natural, environmentally friendly option, CO2 checks all the boxes. It’s nonflammable and nontoxic. It presents no threat to the ozone layer. And it meets every current and known future regulatory requirement. In addition, whereas R-404A has a GWP of 3,922, CO2 has a GWP of 1.

While CO2 refrigeration architectures have been successfully deployed in European commercial and industrial settings for nearly two decades, they are a relative newcomer to the U.S. That’s set to change as more operators face regulatory mandates or have stated sustainability objectives.

This will pose a sharp learning curve for many refrigeration contractors and service technicians, especially those who aren’t familiar with the peculiarities of CO2, or the transcritical CO2 booster architecture they’re most likely to encounter soon.

Understanding CO2’s unique properties

When servicing transcritical CO2 booster systems, technicians will need to account for factors that they have never needed to consider with HFC systems. CO2 has a much lower temperature at atmospheric pressure than HFCs. It also has a higher saturation point, as well as higher operating and standstill pressures. Understanding how these characteristics impact system operation servicing requirements and system performance is essential:

  • Low critical point. CO2’s very low critical point (at 1,056 psig or 87.8 °F) determines its modes of operation; the system will operate in subcritical mode at low ambient temperatures and transcritical mode at higher ambient temperatures.
  • High triple point. At 61 psig, CO2’s triple point — where the refrigerant’s solid, liquid and vapor phases coexist — is very high. If system pressures reach the triple point, the refrigerant will turn to dry ice, which affects system performance and presents a potential safety hazard.
  • Rapid pressure rise. During power outages, CO2 pressures can rise quickly. Pressure-relief valves will release the refrigerant charge when it exceeds acceptable pressures, but this can increase the risk of product loss. To prevent system evacuation, CO2 systems often are designed with an auxiliary cooling system.
  • Vapor to liquid charging. CO2 systems typically use both liquid and vapor to charge, requiring careful coordination to prevent the formation of dry ice.

Transcritical CO2 systems are specifically designed to manage its high pressures and maximize its full potential. Because this system design represents a completely different approach than typical HFC systems, specialized training is required to service these systems and understand their supporting technologies, which typically include high-pressure controllers, electronic expansion valves, pres­sure transducers and temperature sensors.

Finding the right educational resources

Contractors and technicians who want to add CO2 servicing to their qualifications would do well to start educating themselves now. All signs indicate that its adoption in the U.S. will accelerate in the near future. Given CO2’s peculiarities and unique system design strategies, it is imperative that technicians familiarize themselves with the refrigerant and the operation of a CO2 system.

At Emerson, we are leading the industry in CO2 refrigeration system innovation. But we don’t just offer a full suite of CO2 refrigeration system components. We also are dedicated to helping contracting businesses ensure their service technicians understand how to safely install, commission and service these systems. Our Educational Services team offers a comprehensive CO2 training curriculum for contractors seeking to learn more about working with this emerging refrigerant alternative.

 

Evaluate System Lifecycle Performance When Making the Decision to “Go Green”

AndrePatenaude_Blog_Image Andre Patenaude | Director, Food Retail Marketing & Growth Strategy, Cold Chain

Emerson Commercial & Residential Solutions

I recently contributed to an ACR News publication with an article which addressed the topic of “green refrigeration.” The article, entitled A Greener Landscape for Commercial Refrigeration, explored why and how operators are making the transition to more eco-friendly refrigeration systems. View the full article here or read a summary below.

As global and national refrigeration industry dynamics continue to rapidly evolve, more business owners and supermarket operators are seeking new refrigerant and equipment alternatives. Ever-changing refrigerant and energy regulations, combined with an increased awareness of the environmental impacts of legacy refrigeration systems, are prompting more stakeholders to explore the green and growing edges of the refrigeration landscape.

But because commercial refrigeration systems can potentially be in service for decades, end users must carefully consider not only today’s regulatory requirements, but also tomorrow’s potential constraints. This means making the most informed equipment decisions possible with the goal of maximizing the investment throughout the system’s lifecycle. Doing so requires a fundamental understanding of the environmental impacts and financial considerations of a commercial refrigeration system.

Total equivalent warming impacts
While today’s regulations are primarily focused on reducing the global warming potential (GWP) from direct emissions of hydrofluorocarbon (HFC) refrigerants, it’s also important to remember that the total equivalent warming impact (TEWI) also accounts for indirect emissions — or the amount of greenhouse gases generated from the refrigeration system’s energy consumption. It’s estimated that these indirect emissions represent the majority of total climate impacts.

Only by evaluating both energy consumption and refrigerant GWP — including leaks and disposal — over the lifetime of a system can we estimate a system’s full lifecycle climate performance (LCCP).

Environmental and financial sustainability
Operators who are considering going green must also factor in the financial viability and sustainability of new or upgraded refrigeration systems. This means determining not only first costs and installation expenses, but also estimating the long-term maintenance and service requirements.

For manufacturers of these new eco-friendly equipment, components and systems, their task is twofold: 1) utilize lower-GWP refrigerants to meet regulatory requirements, while 2) minimizing ownership and operating costs.

Building a greener future
Like much of the commercial refrigeration industry, Emerson believes that the adoption of environmentally responsible, financially viable refrigeration systems will become more commonplace over the next decade. After all, there is a historic precedent for refrigerant phase-downs, including the ban on ozone-depleting substances which began in the 1990s and is now coming to fruition. Under the authority of the Montreal Protocol and the Environmental Protection Agency’s Clean Air Act, ozone- depleting substances like R-22 will no longer be manufactured or imported into the U.S. as of Jan. 1, 2020.

Today, the global reduction of fluorinated gases (aka F-gases) is being driven by the Kigali Amendment to the Montreal Protocol, which has now been ratified by more than 80 countries. As federal regulations continue to take shape and regional mandates become more prevalent throughout the U.S., it seems inevitable that the industry will eventually make the transition to more eco-friendly refrigeration systems.

Emerson has helped support this transition for many years by working with early adopters of low-GWP refrigerants and supporting technologies. Those operators who are taking proactive steps now will have a head start on this transition and be able to provide insights from which the rest of the industry can learn.

How Emerson Is Taking on Today’s Most Pressing Refrigeration Challenges with Copeland Scroll ™

Phil Moeller | Vice President – Product Management, Refrigeration
Emerson Commercial & Residential Solutions

Since its introduction nearly 30 years ago, the Copeland Scroll has revolutionized the standards for refrigeration performance and reliability. An article from the E360 Product Spotlight provides an overview of Emerson’s recent innovations for the Copeland Scroll. Click here to read the article in its entirety.

How Emerson Is Taking on Today’s Most Pressing Refrigeration Challenges with Copeland Scroll ™

The commercial refrigeration industry has changed drastically in recent years due to new regulations and consumer trends. Operators demand an ever-widening spectrum of applications, from large centralized systems to small walk-in freezers and coolers. Energy efficiency and environmental sustainability have become business priorities. And digital technologies promise connected, predictable visibility to refrigeration systems.

That’s why Emerson’s research and development (R&D) teams for Copeland Scroll have come up with innovative technologies that optimize performance and reliability, helping you take on these emerging challenges.

Innovations that bring more power, flexibility and advanced capabilities to the Copeland Scroll lineup

Wider application and temperature ranges: We’ve expanded the ranges of commercial applications for Copeland Scroll compressors, now spanning fractional ¾ horsepower ZF*KA compressors designed for low temperatures up to the 17 horsepower K5 compressor for low- and medium-temperature applications. You’ll find a variety of solutions within this horsepower range for your low-, medium- and extended medium-temperature applications.

Inherently robust product designs: Minimalistic, fully hermetic Copeland Scroll designs use up to 70 percent fewer moving parts than semi-hermetic, reciprocating compressors. That means they have no complex suction and discharge valves; can start under any system load; eliminate many vibration issues; improve liquid and debris handling; and, with their compact and lighter-weight designs, make servicing easier.

Energy compliance: Original equipment manufacturers (OEMs) rely on Copeland Scroll technology to help meet the Department of Energy’s annual walk-in efficiency factor (AWEF) ratings for walk-in coolers and freezers. Copeland Scroll’s inherent efficiency and reliability are the foundation of AWEF-compliant condensing units in leading OEM equipment design strategies.

Alternative, lower-GWP refrigerants: The Copeland Scroll lineup includes many compressors rated for use with lower-GWP synthetic and natural refrigerant alternatives. We continue to evaluate and test emerging refrigerants to help operators achieve their performance and sustainability goals.

Performance-enhancing technologies: Emerson R&D teams for Copeland Scroll lead the industry in rolling out performance-enhancing innovations, from digital modulation capabilities to liquid- and vapor-injection options and lower condensing operation. These technologies improve system reliability and capacity while meeting today’s demanding regulatory requirements.

Smart diagnostics and protection: Today, many Copeland Scroll compressors are equipped with on-board CoreSense™ Diagnostics. CoreSense provides advanced motor performance monitoring and protection, diagnostics, power consumption measurements and communication capabilities. Other compressors can be retrofitted with our panel-mounted, remote diagnostic systems. This active protection technology is driven by advanced algorithms and fault detection logging and histories, helping enable technicians to quickly diagnose and repair systems.

Product development partnerships: As an Emerson customer of Copeland Scroll, you have access to Emerson’s extensive capabilities to support your own product development efforts, collaborating with us on application engineering; design, testing and certification services; proof of concept; and application development.

Closer ties to the industry’s largest support network: Copeland Scroll compressors are backed by a network of more than 1,000 Copeland-authorized locations and over 600 certified Copeland technical specialists — a base of operations that can quickly deliver the products and technical assistance you need. Our new, fully featured Copeland™ Mobile app connects to the Emerson Online Product Information database for on-the-go access to 30 years of compressor products and specifications. It can help you quickly troubleshoot and diagnose issues and connect to our wholesaler network to check local availability of replacement products.

 

With a legacy of innovation and an eye toward the future, you can be sure that Emerson will continue to evolve to meet today’s rapidly changing commercial refrigeration requirements. To learn more about our innovations and emerging technologies, read the full E360 article.

 

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