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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)

Copeland Hermetic CS Compressors Rated for Lower-GWP Refrigerants

VarunGarg_Blog_Image Varun Garg | Manager, Product Management – Refrigeration

Emerson Commercial & Residential Solutions

The Copeland™ Hermetic CS compressor line has been extended for use with leading alternative refrigerants. To learn more about this important update, read our recent E360 product spotlight.

Copeland Hermetic CS compressors are commonly used in self-contained and remote walk-in coolers, as well as in ice, soft serve and frozen carbonated beverage applications. Most recently, we’ve updated this industry-standard compressor platform to qualify for use with modern refrigerant alternatives — which include R-407A, R-448A and R-449A — to offer lower glower warming potential (GWP) while providing the same reliable performance.

Found in a wide range of commercial refrigeration applications, R-404A is one of the most commonly used hydrofluorocarbon (HFC) refrigerants. In recent years, HFCs like R-404A have been targeted for phase-down via global, federal and state regulatory efforts to limit the use of high-GWP refrigerants. Throughout the industry, many operators are actively seeking lower-GWP options to help them achieve regulatory compliance and meet corporate sustainability initiatives.

Many factors must be taken into account when considering how to transition to a lower-GWP alternative refrigerant, including service, maintenance and operational requirements. It’s no surprise that many operators are hesitant to transition to an option that will force them to overhaul their current refrigeration architecture or introduce a new compression platform. Emerson is helping those familiar with the Copeland Hermetic CS compressor line move from R-404A to one of these approved alternatives — without introducing new system complexities.

For those seeking to comply with regulatory targets or meet sustainability objectives, Copeland Hermetic CS compressors are qualified to use R-407A, R-448A and R-449A in medium-temperature applications. This will enable significant GWP reductions compared to R-404A.

R-404A 3,922 GWP
R-407A 2,107 GWP
R-448A 1,273 GWP
R-449A 1,282 GWP

GWP by refrigerant

Retrofit vs. new: considerations
With these new refrigerant qualifications, operators now have the option to retrofit their legacy Copeland Hermetic CS compressors. It’s important to understand that R-407A, R-448A and R-449A are not considered true “drop-in” replacements.

Even though operators can keep the same compression platform, switching from R-404A to one of these lower-GWP options requires adherence to Emerson’s Refrigerant Changeover Guidelines to help ensure optimum system performance. Expansion valve adjustments, proper lubrication and filter changes must be followed per the application engineering bulletin.

For new applications, this newly qualified Copeland Hermetic CS line of compressors grants operators the flexibility of determining which replacement options are best suited to meet their external regulatory requirements and/or internal sustainability initiatives. Emerson recommends consulting its application engineering bulletin or a certified compression expert to help better understand the performance characteristics of each low-GWP refrigerant option.

To learn specific performance ratings of these new refrigerants, please visit the Copeland Online Product Information (OPI) tool. R-448A and R-449A data will be published in February 2019.

 

Refrigerant Rulemaking in 2019

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

Emerson Commercial & Residential Solutions

While the phase-down of hydrofluorocarbon (HFC) refrigerants is underway globally, federal regulatory uncertainty and state-level actions in the U.S. continue to raise many questions in our industry. Our latest E360 Webinar presented the latest developments in this dynamic area in hopes of clearing up some of the confusion. View the webinar in its entirety.

Along with my Emerson colleague, Jennifer Butsch, regulatory affairs manager of air conditioning, I recently presented the latest information on refrigerant regulations and rulemaking. The primary objective of these activities is to reduce the use of HFC refrigerants with high global warming potential (GWP), and at the same time, introduce lower-GWP alternatives. For those of us in the commercial refrigeration and AC industries, this transition impacts many of our most common applications.

Here’s a summary of our discussion.

Kigali Amendment takes effect

To put these matters into their proper context, it’s important first to understand the global regulatory driver of the HFC phase-down, the Kigali Amendment to the Montreal Protocol. This proposal was agreed upon at a meeting of 197 countries in 2016, and has since been ratified into law by more than 65 countries, including European members, Canada and Mexico.

While the U.S. has yet to ratify the Kigali Amendment, its phase-down guidelines went into effect for participating countries as of Jan. 1, 2019. However, this doesn’t necessarily mean its impacts are not being felt in the U.S., particularly in state-level initiatives to meet environmental targets.

California adopts SNAP rules, plans further reductions

While the Environmental Protection Agency (EPA) SNAP Rule 20 has been vacated and Rule 21 remains in litigation, California has adopted these rules into law. Effective Jan. 1, R-404A and R-507A are not allowable in many commercial refrigeration applications, including: supermarket central systems, remote condensing units and stand-alone systems. Essentially, this upholds previous SNAP 20 rulemaking and prevents operators in the state from using high-GWP HFCs. But this is just the first of many steps.

California is also adhering to the longer-term HFC phase-down schedule for commercial refrigeration and AC as outlined in SNAP Rules 20 and 21. In addition, the California Air Resources Board (CARB) has been tasked with reducing HFC emissions 40 percent by 2030 from the state’s 2013 baseline level — a target that’s very much in alignment with the Kigali Amendment’s HFC phase-down recommendations for the United States.

Achieving these levels will require new rulemaking in accordance with CARB’s short-lived climate pollutant (SLCP) reduction strategy. CARB is planning on releasing a final rule toward the end of this year. In the meantime, they will conduct a series of public meetings for both AC and commercial refrigeration stakeholders. Emerson strongly encourages you to participate in these meetings to make sure your questions and concerns are addressed.

Other states join the charge

While California appears to be taking the lead on domestic HFC phase-down efforts, there are also many other states making commitments to climate change initiatives, including the reduction of HFCs.

The U.S. Climate Alliance now includes 21 states; combined they make up 49 percent of the U.S. population and 50 percent of the gross domestic product (GDP). We believe that it is in our industry’s best interest for these states to follow a united course of action, rather than a patchwork of individual state mandates.

Other key webinar takeaways

Jennifer and I also discussed many other important developments pertaining to the use of lower-GWP alternatives, including:

  • Applications, availability and GWP ratings of A1, A2L, A3, B2L and natural alternatives
  • Update on refrigerant safety standards of A2L and A3 (flammable) refrigerants
  • How refrigerant standards affect equipment, applications, building codes and local codes
  • Lower-GWP refrigerant impacts on refrigeration architectures

To learn more about these topics, please view this webinar in its entirety.  

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.

[New E360 Webinar] Regulatory Update: Learn the Latest Rulemaking on Refrigerants

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

Emerson Commercial & Residential Solutions

Join us for our next E360 Webinar that will take a look at the latest refrigerant regulations impacting commercial refrigeration and AC applications on Tuesday, February 26 at 2 p.m. EST/11 a.m. PST for this informative update.

One of the greatest sources of uncertainty in today’s commercial refrigeration and AC industries is the topic of refrigerants. Regulations continue to evolve quickly, primarily aimed at phasing down the use of hydrofluorocarbon (HFC) refrigerants with higher global warming potentials (GWP), which are used in many applications. What’s particularly challenging is how these rules can differ from state to country to region, making it difficult to adopt a common standard.

Globally, these efforts are spearheaded by the Kigali Amendment to the Montreal Protocol, an international treaty in which participating countries are working toward a shared goal of HFC phase-down via mutually agreed upon timelines. In the U.S., the regulatory climate continues to be unpredictable, but states such as California are leading the charge on establishing regulatory standards.

With new updates taking place seemingly every month, it’s becoming increasingly difficult to stay informed. That’s why we’re dedicating our next E360 Webinar to clearing the confusion in this turbulent regulatory climate. This webinar will be hosted by Emerson’s leading experts on refrigerant regulations: Rajan Rajendran, vice president, systems innovation center and sustainability; and Jennifer Butsch, regulatory affairs manager, air conditioning. Jennifer will present the latest updates to the refrigerant rulemaking while Rajan will offer his extensive insights on how to prepare for what’s on the horizon.

Attendees will learn:

  • How recent rulings have changed the scope of the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) program
  • How the California Air Resources Board (CARB) continues to leverage the original SNAP ruling as the foundation for its regional HFC refrigerant phase-down efforts
  • An update on the potential for U.S. ratification of the Kigali Amendment to the Montreal Protocol
  • Status of the standards governing charge limits and safe use of A2L and A3 refrigerants, including the potential impacts on building codes
  • How the vacating of SNAP Rule 20 potentially impacts Section 608 in terms of governing leak repair and maintenance requirements
  • Availability of new low-GWP refrigerants

Register now for this informative and free webinar.

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