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Why Refrigerant Leak Repair Still Matters

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

Proactive refrigerant management isn’t just good for the environment. It is also sound business practice. I was recently interviewed by ACHR’s The News magazine on the Environmental Protection Agency’s (EPA) partial rollback of Section 608 provisions for appliance leak repair and maintenance. You can read the full article here  and more on our perspective below.

Why Refrigerant Leak Repair Still Matters

In February, the EPA eliminated leak repair and maintenance requirements on appliances containing 50 or more pounds of substitute refrigerants, such as hydrofluorocarbons (HFCs). As a result, equipment owners are no longer required to:

  • Repair appliances that leak above a certain level
  • Conduct verification tests on repairs
  • Periodically inspect for leaks
  • Report chronically leaking appliances to the EPA
  • Retrofit or retire appliances that are not repaired
  • Maintain related records

But just because these leak repair provisions are no longer required doesn’t mean food retailers should ignore these best practices. There is a price to pay for refrigerant leakage that extends far beyond environmental damage. Detecting, repairing and even proactively reducing refrigerant leaks will help operators avoid a variety of associated costs.

The high cost of refrigerant leaks

The rollback of legal penalties for refrigerant leaks does not change the math on the operational costs. An average food retail store leaks an estimated 25 percent of its refrigerant supply each year, which can quickly add up to thousands of dollars in lost refrigerant. In addition, retailers must consider the maintenance and equipment costs. Persistently low levels of refrigerant can cause:

  • Excess compressor wear and tear
  • Reduced compressor and system capacities
  • Premature system failures
  • Double-digit efficiency losses

Left unchecked, even minor leaks can eventually lead to equipment failure. When this occurs, emergency repair costs are often only the tip of the iceberg. Operators may also be looking at revenue loss from food waste, business disruptions and reputational damage.

Proactive refrigeration management

So what can operators do to prevent leaks, even in the absence of federal requirements?

In the near term, they can — and should — implement rigorous leak detection and repair programs. Refrigerant leaks can occur anywhere in a system. Thus, an effective refrigerant leak detection program will combine monitoring, detection and notification.

Multiple technologies are available to support these efforts, including active and passive devices for monitoring and detection. Internet of things (IoT) capabilities allow for remote monitoring, enabling operators to focus on more pressing tasks. And with the integration of data analytics platforms, operators can uncover trends, identify persistent problem areas, and make informed choices about equipment upgrades and replacement options.

Over the longer term, operators can adopt refrigeration architectures that reduce the potential for refrigerant leakage in the first place. Legacy, centralized direct-expansion rack systems are high leak-rate offenders. That shouldn’t be a surprise; with thousands of feet of pipe, hundreds of joints and large refrigerant charges, there are many opportunities for leaks to occur.

In contrast, distributed micro-booster, indoor distributed and outdoor condensing unit (OCU) architectures experience lower leak rates by design. As an added benefit, they offer more options for lower-GWP alternative refrigerant use. This is a crucial advantage for operators who want to position their business for future regulations.

Sustainable best practices

The EPA’s Section 608 leak repair provisions were good for the environment. They are also part of a larger body of best practices for optimizing HVACR equipment. As states take the lead in adopting standards for leak detection and control, operators may find the rollback of these regulations to be short-lived.

Emerson is proud to take a lead in developing sustainable and cost-effective refrigeration systems and supporting technologies. Operators and original equipment manufacturers count on us to deliver strategies and solutions that anticipate emerging trends and regulations. From pioneering refrigeration architectures to refrigerant leak detection tools, we are committed to providing operators with the capabilities to meet their sustainability and operational goals today and into the future.

 

 

 

Court of Appeals Ruling Questions the Elimination of EPA SNAP

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

Emerson Commercial & Residential Solutions

On April 7, the U.S. District Court of Appeals for the District of Columbia ruled that the Environmental Protection Agency (EPA) had improperly suspended the limits on the use of hydrofluorocarbon (HFC) refrigerants in its 2018 guidance. ACHR The NEWS interviewed Jennifer Butsch, Emerson’s regulatory affairs manager of air conditioning, and me to discuss the implications of this ruling and what it means to our industry. View the full article here or read a summary of its contents in this blog.

To put this latest development into context, we must go back to 2017, when the Court of Appeals ruled to vacate the EPA’s Significant New Alternative Policy (SNAP) Rule 20. The ruling was based on the assertion that the EPA did not have the authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS). The EPA had interpreted the Court’s 2017 decision by suspending the requirements of SNAP Rule 20, which then allowed current users of ODS to freely switch to HFCs.

Despite widespread business and HVACR industry objections to overturn the Court of Appeal’s decision, the Supreme Court declined to hear the HFC case in 2018. Vacating EPA SNAP 20 halted years of regulatory progress in one of the world’s leading governing bodies on HFCs — and left the U.S. without a clear path forward in terms of a unified refrigerant strategy.

The April 7 Court of Appeals ruling was in response to a lawsuit introduced by the National Resources Defense Council (NRDC) and a coalition of states led by New York. The court ruled on both procedure and substance of the EPA’s 2018 guidance, stating:

  • The decision was made without going through proper public notice-and-comment procedures.
  • The agency had improperly suspended the limits on the use of HFC refrigerants.

As a result, the Court of Appeals requested that the EPA restore its prohibition on transitioning from refrigerants with ozone depletion potential to HFCs with a higher global warming potential. In essence, the EPA did not need to completely eliminate the requirements of SNAP Rules 20 and 21.

Implications to commercial refrigeration equipment

If you are a supermarket owner or operator wondering which refrigerants you will be permitted to use moving forward, we suggest referring to the original SNAP Rules 20 and 21 if you are considering replacing refrigeration equipment that still uses an ODS refrigerant such as R-22.

As I stated in the article: “If you’ve got an existing piece of equipment that’s running on R-22, you can continue to use it and service it with reclaimed R-22. That has not been taken away. If you have an R-22 system, and you’re looking to replace it with a newer system, I would look at the SNAP 20/21 list and find someone who can provide a refrigerant that’s on that list.” It’s also important to remember that states such as California have already adopted SNAP Rules 20 and 21, so choosing new equipment that is compatible with SNAP rules is still required in those states.

As Jennifer pointed out in the article, this Court of Appeals ruling does not clear up the regulatory uncertainty that’s prevalent in our industry.

“The exact impact of the decision is unclear, and further guidance from the EPA is necessary. This ruling also underscores the need for congressional action on federally regulating HFCs to deliver the certainty the industry needs,” she said.

Newly proposed legislation, such as the American Innovations and Manufacturing (AIM) Act, would give clear authority to the EPA on what they can and cannot do with respect to the HFC refrigerant phase-down. As I stated in the article, “We need the AIM Act now more than ever.”

Rest assured that as we gain more clarity on this quickly changing regulatory climate, we will continue to keep the industry informed of the latest developments.

Regulatory Uncertainty Impacts Refrigerant Decisions

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

Emerson Commercial & Residential Solutions

I was recently asked to contribute to an ACHR The NEWS article about the uncertainty surrounding the dynamic regulations governing the use of refrigerants. The article provided perspectives from several industry stakeholders, and I was happy to discuss Emerson’s views on the short- and long-term implications of the situation. Read a summary of the article below and view it here in its entirety.

For the last two years, the commercial refrigeration industry has been in a period of uncertainty regarding the regulations that govern the use of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP). Since the U.S. DC Court of Appeals ruled that the Environmental Protection Agency (EPA) did not have the authority to phase down HFCs, the EPA’s role in the national HFC phase-down has been unclear.

R-22 phase-out is still in effect

For the time being, the EPA’s authority covers only the transition from ozone-depleting substances, such as the chlorofluorocarbon (CFC) R-22. So, even though the HFC rules have been vacated, the EPA still has the authority to phase out R-22, which is scheduled to take place on Jan. 1, 2020.

While there’s plenty of discussion about the fate of HFCs, it would be unwise to presume that the 2020 R-22 phase-out won’t have significant impacts. In fact, it may surprise some to learn that there are still many operators with older refrigeration systems currently charged with R-22. But after Jan. 1, they must either retrofit their systems with lower-GWP refrigerants or continue to recover and reuse R-22 until their supplies run out — with the understanding that the latter choice is not a permanent solution.

HFC phase-down continues in California and other states

The absence of a federal mandate to phase down common HFCs is not deterring California from taking its own steps. Per a recent ruling by the California Air Resources Board (CARB), R-404A and R-507A are no longer allowable in many new commercial refrigeration applications.

California’s regulatory stance is a reminder that a retailer’s geographic location is an important factor in the development of their refrigerant strategy. While California is currently taking the lead on U.S. HFC reductions, there are currently

As retailers evaluate their future refrigerant options, state-specific environmental regulations will factor prominently in their decision processes. For example, operators in California are well aware of the efforts to phase down HFCs and most likely have alternative refrigerant plans in place. These operators are either planning for retrofits or trialing new alternative refrigerant architectures.

Strategies for moving forward

Fortunately for operators, component and equipment manufacturers have continued developing solutions that feature a wide range of lower-GWP refrigerant alternatives. These solutions are helping retailers align their sustainability objectives with their refrigeration architectures, and include the following strategies:

  • Retrofit using lower-GWP HFOs — Moving from R-404A to R-448A or R-449A may require adding compressor cooling and other relatively minor system changes but can help operators preserve their existing system investments. Deploying energy optimization best practices will also help them reduce indirect emissions, which lessens their overall carbon footprint.
  • Transition to a new and/or natural refrigerant system — Natural architectures offer maximum carbon footprint reductions and are considered by many as the only true future-proof solutions available today. These systems can be installed in new locations or in parallel with an existing system, allowing the retailer to slowly transition to the natural solution.

Emerson is continuing to develop a variety of alternative refrigerant solutions designed to help operators and equipment manufacturers reduce their carbon footprints. Regardless of the regulations in your specific region, we’re here to support the commercial refrigeration supply chain as it transitions to lower-GWP refrigerant alternatives.

California HFC Phase-down Schedule Continues

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

The state of California and the California Air Resources Board (CARB) have taken steps to phase down hydrofluorocarbons (HFC) beginning in 2019. I recently presented this topic during Emerson’s January E360 Breakfast at the AHR Expo where I spoke about this and how it may influence refrigerant regulations in other states. Read Accelerate America’s article, “California Starts HFC Bans — with More to Come.”

As we had discussed in late 2018, the Environmental Protection Agency (EPA) indicated that in the wake of the vacating of SNAP Rule 20, it will no longer enforce HFC refrigerant delistings and has proposed to roll back further HFC-related regulations. This decision has a left a void in the regulatory landscape — one in which California and other U.S. Climate Alliance member states are vowing to fill.

In particular, many are looking to California to lead industry efforts on reducing high-GWP HFC refrigerants in commercial, industrial and residential refrigeration and AC applications. With the adoption of SNAP Rules 20 and 21 into state law, California appears to be embracing this role. As of Jan. 1, R-404A and R-507A are no longer permitted in new and retrofit supermarket central systems, remote condensing units, and low- and medium-temperature retrofit stand-alone units — all of which can be legally enforced in California under the authority of the California Cooling Act (Senate Bill 1013).

January 1 also marked the onset of bans for R-404A, R-507A, R-410A, R-134 and R-407A/C/F in new medium-temperature, stand-alone units with a compressor capacity of less than 2,200 BTU/hr and not containing a flooded evaporator. These actions mirror the now vacated EPA SNAP rules and are all part of an HFC phase-down schedule that will continue in California in the coming years.

The California Cooling Act also prohibits manufacturers from selling equipment or products that use banned HFCs manufactured after their respective prohibition dates. It’s important to understand this phase-down in the context of even larger and more ambitious state-wide environmental initiatives.

The California Air Resources Board plans to enact further restrictions on HFCs via its SLCP (Short-Lived Climate Pollutant) strategy, which was approved in March 2017. These actions are all intended to help California reduce HFC emissions 40 percent below the levels it recorded in 2013 by 2030, as stated in Senate Bill 1383 (aka the Super Pollutant Reduction Act).

CARB’s SLCP strategy is based on a multipronged approach in which they have proposed:

  • Limiting the GWP of refrigerants used in new stationary air-conditioning equipment to below 750 starting in 2023
  • Imposing prohibitions on refrigerants (more than 50 pounds) with a GWP of more than 150 for new stationary refrigeration beginning in 2022
  • Calling for a blanket ban on all production, import, sales, distribution or entry into commerce of refrigerants with a GWP of 1,500 or more, effective in 2022, with possible exemptions for R-410A for use in AC and reclaimed refrigerant.

We anticipate CARB to announce a final regulation on these SLCP initiatives in December for AC and March 2020 for commercial refrigeration. In the meantime, we encourage stakeholders to engage CARB in one of the many public meetings they’re planning throughout 2019.

As other states watch closely to see how California’s pending environmental regulations take shape, we believe it’s important that our industry continues to push for consistency in our approaches. Dealing with state-by-state mandates on what’s acceptable and what’s not acceptable would only introduce unnecessary complexity. To see my comments on this matter, please read the full article here.

 

Refrigerant Regulations: 2018 Recap and 2019 Impacts

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

Emerson Commercial & Residential Solutions

The year 2018 brought many changes to refrigerant regulations, with additional activity expected in 2019 and beyond. This blog highlights some of the key developments, which were presented in a recent E360 article. Read the full article here.

 

The regulation of refrigerants continues to be a source of great uncertainty in the commercial refrigeration industry. As global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants in recent years, some in the industry have begun the transition toward alternative refrigerants with lower global warming potential (GWP). But these environmentally friendly options raise additional questions about performance and safety.

All in all, it’s a complex regulatory mix that got even more complicated in 2018. But we’re here to recap recent events and place them into a larger context.

The status of EPA SNAP Rule 20

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. The court ruled that the EPA did not have authority to phase down HFCs under the Clean Air Act (CAA) — which was originally intended to eliminate ozone-depleting substances (ODS) — and thus could no longer enforce its 2015 GWP-based mandates.

In the absence of Rule 20, the commercial refrigeration industry has many questions about what the path toward a more sustainable and environmentally friendly future for refrigerants will look like. Industry calls to overturn the District of Columbia Court of Appeal’s decision were declined by the Supreme Court, which stated it would not hear the HFC case1. Currently, the EPA is drafting new regulations that will clarify its plans to move forward with SNAP. We anticipate details on their position early this year.

EPA rescinds other HFC-related regulations

The EPA has also indicated that it will no longer enforce refrigerant delistings and has proposed to roll back other HFC-related regulations2. In particular, the EPA has proposed excluding HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA.

California adopts Rule 20 as the basis for its initiatives

Regulatory uncertainty at the federal level is not preventing states from adopting their own refrigerant regulations and programs. California Senate Bill 1383, aka the Super Pollutant Reduction Act, was passed in 2016 and requires that Californians reduce F-gas emissions (including HFCs) by 40 percent by 20303. The California Air Resources Board (CARB) has been tasked with meeting these reductions.

Since 2016, CARB had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. Even after SNAP Rule 20 was vacated, CARB moved to adopt compliance dates that were already implemented or upcoming. The passing of California Senate Bill 1013 — aka the California Cooling Act — in Sept. 20184 mandates the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017. The law is currently in effect and does not require additional CARB rulemaking to uphold compliance dates.

CARB is also proposing an aggressive second phase of rulemaking that would further impact commercial refrigeration and AC applications. CARB has held public workshops and invited industry stakeholders to comment on the details of this proposal.

Meanwhile, many other states have announced their plans to follow California’s lead on HFC phase-downs. The U.S. Climate Alliance, formed in 2017 out of a coalition of 16 states and Puerto Rico, is committed to reducing short-lived climate pollutants (SLCPs), including HFCs. Among these alliance states, New York, Maryland, Connecticut and Delaware have announced plans to follow California’s lead on HFC phase-downs.

Refrigerant safety standards and codes under review

Many of the low-GWP, hyrdrofluoroolefin (HFO) refrigerants are classified as A2L, or mildly flammable. R-290 (propane) is also becoming a natural refrigerant option for many low-charge, self-contained 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.

Internationally, the International Electrotechnical Commission (IEC) has proposed increasing charge limits for refrigeration systems in IEC60335-2-89 as follows:

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

These proposals are still under review and will likely be published sometime in 2019.

Kigali Amendment took effect on Jan. 1

The regulatory uncertainty in the U.S. can sometimes obscure international efforts underway to phase down HFCs. The Montreal Protocol has led the way on this effort for nearly a decade5. In 2016, 197 countries met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. Known as the Kigali Amendment, this treaty has been ratified by 53 countries (including the E.U.) and took effect on Jan. 1 for participating countries. The U.S. is still considering ratification.

As we move into 2019, there are many moving pieces on the regulatory chess board, but also some encouraging signs of progress. We will be providing the very latest regulatory updates in our next E360 Webinar. Register now to stay informed.

  1. https://www.achrnews.com/articles/140040-supreme-court-declines-to-hear-hfc-case
  2. https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations
  3. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383
  4. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB1013
  5. https://en.wikipedia.org/wiki/Montreal_Protocol#Hydrochlorofluorocarbons_(HCFCs)_Phase-out_Management_Plan_(HPMP)
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