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Posts tagged ‘EPA’

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)

Refrigerant Management: How Changes to Section 608 Impact Our Industry

JohnWallace_Blog_Image John Wallace | Director of Innovation, Retail Solutions

Emerson Commercial & Residential Solutions

I was recently interviewed for an article in ACHR’s The News magazine, “EPA’s Proposed Changes to Section 608 Cause Concern in the Industry,” where I provided my perspective on the current state of leak detection, repair and other provisions.

Refrigerant leak response and repair regulations have placed our industry in uncertain waters. As you may know, the Environmental Protection Agency (EPA) has proposed a new rule that rescinds some provisions of its Section 608 mandate, affecting equipment with 50 lbs. or more of hydrofluorocarbons (HFCs) or other substitute refrigerants. These best practices were developed in consultation with the HVACR industry to ensure safety, establish proper reclaim and recycling processes, and of course, reduce carbon emissions.

In November 2016, the EPA extended the scope of Section 608 — from refrigerants containing ozone-depleting substances (ODS) to nonexempt substitute refrigerants such as HFCs. Because the Court of Appeals ruled in 2017 that the EPA could not ban HFCs, the agency has decided that it also did not have the authority to regulate these refrigerants under Section 608.

Establishing best practices

Awareness of the importance of leak detection has grown exponentially in recent years. Today, most companies understand that implementing a leak response and repair program is simply a best practice. And for those companies that have already taken steps to comply with Section 608, the vacating of this rule will have little impact.

I stated in the article: “These procedures not only benefit the environment but also help ensure HVACR equipment operates at peak efficiency, including at the lowest overall cost. One of the benefits of the existing regulations has been to raise the awareness of best practices related to HVACR maintenance. Increased awareness generally leads to broader adoption by those in the industry, regardless of whether regulations are in place.”

Simply put, leak detection and repair programs make good sense, regardless of the regulations in place or the type of refrigerant being used. However, with the reversal of Section 608, equipment operators will no longer be under federal mandate to follow these widely adopted refrigerant management best practices:

  • Conducting leak rate calculations when refrigerant is added to an appliance
  • Repairing an appliance that leaks above a threshold leak rate
  • Conducting verification tests on repairs
  • Conducting periodic leak inspections on appliances that exceed the threshold leak rate
  • Reporting to the EPA about chronically leaking appliances
  • Retrofitting or retiring appliances that are not repaired
  • Maintaining related records
  • Overseeing technicians’ use of certified equipment and the reclamation process

These procedures are already considered to be the optimal standard practice, and end users who are focused on operational excellence are likely doing many (or most) of them today.

Maintaining other key program elements

The absence of a federal mandate for responsible HFC management creates a quandary for our industry. Currently, the EPA is seeking comments about the remaining provisions of Section 608, raising concerns about the potential for overturning other benefits of programs — specifically, guidelines for refrigerant reclaim procedures and technician certification and training programs.

Proper refrigerant reclamation reduces the likelihood of introducing impurities, which could lead to premature failures and increased maintenance costs for owners of HVACR equipment. What’s more, the certification program provides the vital information on how to deal with the ever-growing number of refrigerants. As I stated in the article: “One benefit of certification is that wholesalers are able to sell refrigerants to technicians who have a sufficient background and understanding of their liability under the Clean Air Act.”

Path forward

Already, several states are adopting standards for leak detection and control. Again, as I noted in the article, “We are already seeing some states such as California enact regulations that adopt many of the requirements in Section 608. Other states will likely step in, which may create more headaches for the industry. This could create problems for the industry and lead to a patchwork of inconsistent regulations that would be challenging for manufacturers and service providers to navigate.”

As always, Emerson will help you stay informed about further changes to Section 608. Regardless of the regulatory decisions, we’ll continue to provide guidance and expertise on how to design and implement refrigerant management programs.

Refrigerant Leak Detection Technology Saves $$ and the Environment

I recently wrote an article featured in Contracting Business discussing the importance of refrigerant leak detection as an essential service for retailers and HVACR contractors.

Refrigerant leaks have long been viewed as an inevitable part of operating a retail refrigeration system.  Retailers often wrote these leaks off as the cost of doing business, but the impact of refrigerant leaks goes beyond what most may expect. The true costs of refrigerant leaks are often underestimated, and contractors who understand this impact will be more valuable partners for their clients.

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According to the EPA’s GreenChill research, the average supermarket loses about 25 percent — or about 875 pounds — of its refrigerant supply because of leaks. When you multiply this across many stores in a grocery chain, the costs can be significant — not only in terms of the cost of the refrigerant, but with associated labor costs. There is also a potential loss of business because of food disruptions and food quality issues that may arise.

Refrigerant leaks also have an environmental impact. Most commonly used refrigerants are greenhouse gases and some are ozone-depleting substances. Assuming a leak rate of 20 percent across a chain of 100 typical supermarket stores, the amount of refrigerant leaked annually is equivalent to the emissions of 24,000 cars or 10,600 homes.

The EPA has had regulations in place for a number of years as part of the Clean Air Act. Now, the EPA has proposed an update to those regulations governing most refrigerants that could impact both contractors and retail operators. Contractors who keep up with how these regulations are changing can be better retailer partners by aligning their services to meet these changes. An effective leak detection program can help retailers manage and properly repair refrigerant leaks and avoid costly EPA settlements.

The goal should be not only to establish proper leak detection response protocols, but also to institute proactive measures that minimize or eliminate leaks altogether. A zero-tolerance policy for leaks is ideal. Accurate detection methods, reliable notifications and continuous monitoring are the key elements needed for effective leak detection programs.

To learn more about refrigerant leak detection for contractors, read the full Contracting Business article here.

 For more than 20 years, Emerson Retail Solutions has been helping businesses like yours safeguard food, reduce energy consumption, protect the environment and optimize business results. To learn more about our technology solutions and services for retailers, visit our website.

 John Wallace
Director of Innovation
Emerson Climate Technologies Retail Solutions

The Rubber Meets the Road

Final rulings signify start of next phase of transition

 For two years, the commercial refrigeration industry has been reeling from a one-two regulatory punch from the Department of Energy and the Environmental Protection Agency. This convergence of aggressive regulations was unprecedented for our industry.

217-I-E360_Rubber_Meets_theRoad

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