First published in Frozen & Refrigerated Buyer Magazine September 2014
What’s legal, and what’s not, under EPA’s proposed new rule? Will 134a be banned? Do you have to use natural refrigerants as of 2016? Here are the answers — well, at least some of them.
A few weeks ago, the EPA proposed a new rule that would make it illegal as of 2016 to use R-404A and R-507A in new commercial refrigeration systems and retrofits. The rationale behind this proposal is that there are numerous other HFCs that can be used, all of which have less global warming impact. These HFCs, like 407A, 407F, and 134a are readily available, and their use instead of 404 and 507 is a no-brainer. Or so I thought.
CONFUSION REIGNS
I have been inundated with calls ever since the EPA issued its proposal. Most of the calls focus on the confusion generated by the wording of the proposal and the errone-ous belief that 134a would not be allowed in commercial systems as of 2016. That is easy enough to clear up. As of 2016, you may use 134a; in fact, of all the HFCs that may be used, 134a is one of the best choices from the perspective of just the global warming potential of the refrigerant.
You may also choose any number of natural refrigerants for new systems. Though the natural refrigerant choices for R-22 retrofits are not yet well developed, retrofits that convert R-22 equipment into a CO2 cascade system with just small amounts of 134a or a 407 as the primary refrigerant have been carried out successfully.
Some of the other calls are more troubling. I’ve heard from supermarkets that have been scared by chemical manufacturers into thinking that this rule means you must use a natural refrigerant in commercial refrigeration systems as of 2016. I’ve heard that it is impossible for supermarkets to make this switch. I’ve heard that various equipment manufacturers would face incredible hardships to change their manufacturing processes to comply with this mandate. I’ve heard that service techs cannot deal with this change. I’ve heard that this is just another attempt to kill American businesses.
These calls baffle me.
First of all, if you are in this industry and you did not suspect that this was coming, you haven’t been paying attention.
With regards to the misinformation that might or might not be coming from very knowledgeable and informed industry stakeholders, I can only assume it is based on innocent misunderstandings. If you rely on people other than the EPA to explain EPA proposals, rules, and such, please be sure that these people have their facts straight. Try to find a source of information that does not have an economic interest in your decisions. The best source of info about EPA proposals and regulations is the EPA. I know it can seem scary to voluntarily call the EPA and ask questions, but I can assure you that many who work there are very eager to explain things to you. Really. I promise.
The point about this switch from 404 and 507 being impossible for supermarkets, systems manufacturers, and service techs is contradicted by the number of supermarkets that switched years ago to lower GWP alternatives for new systems and retrofits. In fact, supermarkets led the charge toward lower GWP HFCs in 2009 and 2010.
Delhaize America worked directly with the EPA’s GreenChill Partnership to get 407A approved for use in commercial refrigeration by EPA’s SNAP Program, the program responsible for evaluating and regulating substitutes for ozone-depleting chemicals in all end uses. According to Wayne Rosa, Energy & Maintenance Manager at Delhaize America, the company made the decision to switch its standard to 407A due to all the leaks they incurred with R-507 conversions and because the high global warming impact of 507 “was not the right direction for the company or the environment.”
An added benefit of that decision was that retrofitting existing systems from R-22 to R-407A reduced the amount of work needed by the refrigeration contractor and reduced the cost of conversions per system. Among the many other companies that have already moved away from 404 and 507 for new systems and retrofits are Walmart, Target, Whole Foods, Sprouts, Supervalu, Pub-lix and Weis Markets. The general consensus seems to be that there is little downside to switching to lower GWP HFCs, and the environmental benefits of the switch are a major upside.
Estimates from the nation’s main systems manufacturers show that anywhere from about 40-60% of the commercial systems sold in 2014 were for lower GWP HFCs, mainly 407A. According to Dustan Atkinson, supermarket systems product manager at Kysor Warren, “In recent years, we have seen a substantial shift from R-404a and R-507 to the various R-407 blends. Today, R-407 variants account for nearly half of our total business and that percentage is steadily increasing.”
These numbers are backed up by information from major commercial refrigeration service contractors. Sean Patrick, director of field operations at The AMS Group, states that “to date, 100% of our conversions have been to a 407 variant.” He agrees with others that occasionally there may be capacity constraints for R-22 retrofits to systems where capacity is tight, but these situations are rare.
Bryan Beitler, chief engineer at Source Refrigeration, reports that seven of 15 of Source’s major supermarket accounts already made the switch to lower GWP refrigerants for new stores. He estimates that about 50% of the firm’s new installs use 407A. As far as R-22 retrofits are concerned, “Most are using R407 for this activity. It’s been awhile since we have done any retrofits with R404A or R507, as there were too many things to change.”
Bill Almquist, president and CEO at Almcoe Refrigeration, mentions that the climate impact of the increased energy consumption of some of the lower GWP refrigerants has to be counted against the climate benefits of the refrigerants themselves.
What about the final issue: that EPA is out to destroy American business? I could write an entire article about this. At some point in time, I’m sure I will do that. For now, I’ll just say that this seems to be a question that is both asked and answered based on one’s politics, rather than facts. Whether you believe that EPA should be done away with or you think that EPA doesn’t do nearly enough to protect the environment, I doubt that anything I can write will change your mind.
I’m a pretty practical person. I try to concentrate on areas where I can be of help. What I am going to focus on in relation to EPA’s proposed rule are the questions that I think are the ones we should be asking.
GOOD QUESTIONS What is the definition of a “new” system? If you double the size of your store during a remodel and you double the size of your refrigeration system, can you add new 404A racks onto an existing 404A system? Or does EPA consider the whole system now to be a “new” system, due to the “new” racks being added to the “existing” racks?
Is the EPA going to propose a phaseout of the use of 404A and 507 in existing systems at a later date, only to have us go through yet another series of retrofits?
Is the EPA going to restrict the supply of 404 or 507, so that the prices of these refrigerants increase enough that no one can afford to buy it for existing systems?
Is the EPA going to wait a few years and then restrict the use of 407 refrigerants and/or 134a?
And finally, are we ever going to find a solution to the environmental harm caused by refrigerants, so that it’s not necessary for EPA to regulate them anymore?