First published in Frozen & Refrigerated Buyer Magazine April 2015
Special interests want to expand Section 608 refrigerant leak regulations. But what it needs is a major overhaul.
The Alliance for Responsible Atmospheric Policy, a Washington, D.C., special interest group, petitioned the EPA last year to expand Section 608 refrigerant leak repair regulations to include HFC refrigerants. The EPA’s Section 608 regulations currently apply only to ozone-depleting refrigerants, and since HFC refrigerants do not harm the ozone layer, they do not now fall under its scope.
INEFFECTIVE REGULATION
The petition from the Alliance has many in the supermarket industry shaking their heads. Expanding Section 608 to include HFCs just takes an ineffective regulation and adds more stuff to it. The regulation already contains everything and the kitchen sink, including several provisions that most agree are pretty useless.
In addition, the petition does nothing to solve the real problem that Title VI of the Clean Air Act is meant to address: our nation’s enormous refrigerant leak problem. The current Section 608 does not mandate that a supermarket leak less — it simply says that once a supermarket leaks 35% of its refrigerant charge, records must be kept to show that leaks are repaired within 30 days of discovery. In fact, it’s perfectly legal for a supermarket to double its leak rate every year. You can leak 10,000 pounds of refrigerant every year and still be fully in compliance.
Many in the supermarket industry are pretty clear on the actions they should be taking to try to solve this problem. At the risk of sounding like Captain Obvious, the solution to supermarkets’ refrigerant leaks is leak prevention. Leak prevention is possible, affordable, and readily available to every supermarket. Today.
The EPA in 2008 started a program to encourage supermarkets’ investment in refrigeration technologies that prevent leaks: GreenChill’s Store Certification Program. The program gave platinum, gold, and silver awards to stores that achieved very significant refrigerant emissions reductions. After three years, the program had over-performed beyond anyone’s hopes. It wasn’t just reducing refrigerant emissions; it was preventing them.
Every store that GreenChill had certified as platinum had a 0% leak rate. Let me say that another way: these stores had never leaked a pound of refrigerant since they started operating. The companies behind these stores had completely changed the way they managed refrigeration, investing up front in technology that used very little refrigerant and then leaked nothing during years of operation. Some of the stores used only a few hundred pounds of refrigerant, compared to a typical store which uses about 3,500 pounds. One store even operated on less than 100 pounds.
Gold-certified stores averaged a leak rate of 0.5%. Silver-certified stores leaked just 3.8%, compared to a typical store in the United States that leaks 25% of its very large charge size.
While the Store Certification Program proved that certain refrigeration technology options are better at preventing harmful leaks, namely those that use modular chiller units, CO2 cascade systems, and natural refrigerant technologies like CO2 transcrit-ical systems, every type of technology in operation in the country was able to achieve some level of certification. Even centralized DX systems, which use thousands of pounds of refrigerant and are notoriously leaky, could be greatly improved if designed to the certification standards. At minimum, they reduced their charge by 50% and achieved very low leak rates, attaining silver and gold certification awards.
A GOOD QUESTION
So if solutions to the nation’s leak problem are possible, affordable, and readily available right now, why isn’t the Alliance petitioning the EPA to incorporate these solutions into their regulations? Could it be because a regulation that mandated large reductions in charge sizes and technologies that prevent leaks would result in Alliance members selling significantly less refrigerant every year? I’ll let you decide.