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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.

 

 

 

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.

 

Earth Day and Refrigerants: A Look Back — and Forward

Jennifer_Butsch Jennifer Butsch | Regulatory Affairs Manager

Emerson Commercial & Residential Solutions

It’s Earth Day, which means we should all take a minute to reflect on how we can do our part to make the planet a greener place. In the world of commercial refrigeration, environmental initiatives and sustainability best practices typically focus on limiting the harmful effects of hydrochlorofluorocarbon (HCFC) and hydrofluorocarbon (HFC) refrigerants. When these refrigerants leak into the atmosphere via direct emissions, their environmental impacts can be measured in terms of ozone depletion potential (ODP) and global warming potential (GWP).

But when considering the total equivalent warming impact (TEWI) of commercial refrigeration systems, direct emissions are only part of the equation. TEWI also considers indirect impacts, or the greenhouse gases generated from the energy consumed to run these systems — estimated to represent as much as 95 percent of the total climate impact. At Emerson, we take both energy efficiency and refrigerant GWP into consideration to evaluate the full lifecycle climate performance (LCCP) of a system and its fluids.

Montreal Protocol to complete R-22 phaseout

Today, most global refrigerant regulations are focused on phasing down high-GWP HFCs. But it’s important to remember that these activities have a precedent that’s more than three decades old. In 1987, the Montreal Protocol treaty aimed to phase out ozone-depleting substances (ODS), such as the commonly used HCFC, R-22. This global treaty was since ratified by 197 countries, including the United States, Canada and Mexico, all of whom have followed its recommended phaseout schedule.

The next step in this process will take place in 2020, when the production and import of R-22 will no longer be allowed under the Environmental Protection Agency’s Clean Air Act. It may come as a surprise to some, but there are still untold operators with older refrigeration systems that are currently charged with R-22. Unlike smartphones and other commodities that we change or upgrade every year,  commercial refrigeration equipment can have a lifespan of 20 to 30 years. This phaseout will likely lead to an increase in system retrofits in the near term, especially as operators exhaust their supplies of R-22.

Thankfully, there’s a good deal of evidence that since the removal of ozone-depleting substances from the environment began, the ozone layer is on the mend. Some estimates state that the ozone hole above Antarctica could close by the 2060s.

HFCs targeted for global warming potential

As the HCFC phaseout began decades ago, the industry transitioned to HFCs with very low ODP. Unfortunately, many of these have since been discovered to have varying degrees of GWP. In fact, the most common HFC used in commercial refrigeration is R-404A, which has a GWP of 3,922 and is considered on the high end of the GWP scale. It’s no surprise then that it was among the first refrigerants to be targeted for phasedown under the EPA’s Significant New Alternatives Policy (SNAP) rules 20 and 21.

But per the 2018 ruling by the U.S. Court of Appeals, the EPA no longer has the authority to regulate the use of refrigerants based on their GWP under the framework of the Clean Air Act. While we expect the EPA to soon provide clarity on the future of its HFC initiatives, there currently is no federal mechanism through which the proposed phasedown of high-GWP refrigerants will take place.

In the meantime, California has adopted the original EPA SNAP framework into law, and as of January 1, R-404A and R-507A are no longer allowable in many new commercial refrigeration applications. California is just one of 23 states or territories in the U.S. Climate Alliance that are making commitments to enforce similar climate protection initiatives. Currently, this growing alliance represents half of the U.S. population and more than 50 percent of the national GWP.

Globally, the Kigali Amendment to the Montreal Protocol seeks to expand the treaty’s scope from just ozone protection to addressing global warming by phasing down short-lived climate pollutants, including HFCs. While this amendment has yet to be ratified by the United States, it has achieved the required ratification of 20 member countries to take force — including Canada and the United Kingdom, among others. For participating countries, the Kigali Amendment took effect on January 1.

Exploring the alternatives

Because regulatory variances occur from state to region to country, there are vastly different levels of environmental awareness throughout our industry. While operators in California are cognizant of the state’s efforts to phase down HFCs, there are many U.S. areas where transitioning to lower-GWP refrigerants isn’t as high of a priority.

Regardless, many top retailers have begun the process of exploring low-GWP refrigerant options as part of their sustainability objectives. Not only do they have retrofit plans in place, some are even trialing alternative refrigerant architectures in their stores — with hydrofluoroolefins (HFOs), HFO/HFC blends and natural refrigerants as leading options.

There are relatively minimal retrofit requirements when moving from R-404A to R-448A/R-449A — both A1 HFC/HFO blends — such as adding compressor cooling and other minor system changes. For a greenfield location or a complete system overhaul of an existing site, operators may consider one of many emerging low-GWP options, including:

  • Low-charge ammonia chillers on the roof
  • A2L (mildly flammable) blends in chillers on the roof and machine rooms
  • Distributed, small-charge systems with both A1 and A2L refrigerants
  • R-290 integrated cases outfitted with micro-distributed systems
  • CO2 transcritical and/or cascade systems using CO2 for low temperatures, and an HFO (or lower-GWP HFC) for medium temperatures

 

Refrigerant management best practices

As always, proper refrigerant management practices are important, regardless of the type of refrigerant used. Operators should start with a documented leak detection plan that includes the necessary tools and early-detection methods to identify and quickly respond to leaks. Leaks are not only bad for the environment; they also degrade refrigeration performance and system energy efficiencies.

With the new class of refrigerants, it’s especially important that technicians are trained to understand proper handling, charging and performance characteristics. In addition, as systems charged with higher-GWP HFCs eventually reach the end of their lifespans, it’s critical that service technicians follow proper recovery and disposal protocols.

Earth Day is a good time to reflect on the environmental progress our industry has made. At Emerson, we’ll continue to support sustainability objectives with compressors, components and systems that are both environmentally responsible and economically viable.

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