Federal regulations require the gradual phase down of refrigerants with high global warming potential. Are FMs prepared to meet the challenge?
By Regina Ludes
Since the late 1980s, the U.S. has embarked on a gradual phase down of commonly-used refrigerants deemed to be harmful to the earth’s atmosphere. While various federal regulations have outlined target goals and safer alternatives, the transition has been slow and complicated because redesigned equipment needs to be tested and technicians must be trained. As deadlines for these actions loom, FMs are challenged to find cost-effective solutions that will not only help their business but improve the Earth’s atmosphere for the long term.
According to recent Pew Research, 69% of U.S. adults favor the United States taking steps to become carbon neutral by 2050. Those steps began with the Montreal Protocol, approved in 1987, which sought to phase down production and consumption of ozone-depleting substances (ODS) like CFCs and HCFCs.
The next generation of refrigerants — hydrofluorocarbons (HFCs) — had a higher global warming potential (GWP) than their predecessors. The Kigali Agreement, adopted in 2016 by 129 countries (except the United States), called for phasing down production and consumptions of HFCs to a GWP factor of less than 750 by 2026. Since the U.S. has not ratified the Kigali Agreement, some states, such as California and New York, have passed their own regulations to meet the target goals set forth in the Agreement. Further, the U.S. Environmental Protection Agency’s (EPA) AIM Act (American Innovation and Manufacturing Act) called for a reduction of HFCs by 85% by 2036.
Other regulations have impacted the industry. Section 608 of the Clean Air Act provided guidelines on how to track, repair and test for refrigerant leaks. “Small-box stores typically have units that contain less than 50 pounds of refrigerant and were previously exempt from refrigerant tracking,” explained Robbie Drake, Senior Manager of Operations Maintenance with Murphy USA. “The changing regulations will likely require tracking all units that contain refrigerant. We’ve had to change the way we do things. Now we’re keeping better records of our assets to account for any amount of refrigerant leaks.”
Jonathan Tan, Co-founder of Ratio Institute in Santa Cruz, California, said refrigerants aren’t a problem until they leak. He explained that in most applications, systems using refrigerants are in living, breathing environments where people are moving around and interacting with these systems. Even though there is extra care taken to manage these systems so they operate properly, things can happen and leaks can develop over time. Tan advised FMs to analyze the performance of refrigeration equipment, HVAC systems and the refrigerants in use in their locations before making a decision to unilaterally make replacements. “If there are no leaks, it’s not necessary to change refrigerants immediately if the existing system is managed well. If there are leaks, understanding the root causes and the costs associated with managing, repairing and maintaining them will help guide the best decisions long-term. If there are chronic problems, upgrading the equipment and the refrigerant to the most energy-efficient and lowest feasible GWP refrigerant based on the application and the site is advisable,” Tan said.
The Cost of Change
Cost is a primary concern for many FMs. The initial expense of replacing equipment can be costly, but there are long-term financial gains, too. “Once equipment is upgraded, you may gain more energy efficiency over time and get back some of your initial expense,” Drake said. “Also, some utility companies offer incentives or rebates for upgrading to more energy-efficient equipment.”
As older refrigerants are phased out, the cost of replacement may rise. For example, R-22 refrigerant has been legislated out globally and can no longer be manufactured, resulting in decreased inventory. With less supply, the demand for R-22 has pushed the price to more than double what it was 18 months ago, Tan said.
The EPA’s SNAP (Significant New Alternatives Program) outlined refrigerant alternatives that are safer for the environment. Natural solutions, such as ammonia, propane and CO2, are relatively inexpensive and readily available, but they each carry some risk. For example, ammonia is toxic and cannot be used in crowded areas, Tan explained.
CO2 is super-efficient, especially in northern climates, but few technicians know how to work with it. While propane is commonly used in bottle coolers at the store, there’s a limit on the amount of charge per system. When multiple systems are needed in grocery stores, they can be costly, Tan said.
Newer blends, like R-454B, are becoming the option of choice to replace R-410A for several major HVAC companies, such as Johnson Controls Ducted Systems. R-454B boasts a significantly lower GWP than R-410A, but it is more flammable — though the degree of flammability is small, added Chris Forth, Vice President of Regulatory, Codes and Environmental Affairs with Johnson Controls Ducted Systems.
“It’s not like propane or gasoline which are extremely flammable hydrocarbons. It’s more like lighting a match. It will burn for a while but self-extinguish once the flame source is removed,” Forth said. In order for a refrigerant to have a low GWP, it needs to break down in a relatively short time. Unfortunately, this also results in the refrigerant becoming more flammable he added. “Consequently, a refrigerant that doesn’t readily break down can stay in the environment for a longer period of time.”
Impact on the HVAC Industry
While these phase-down policies present opportunities for HVAC manufacturers to develop new equipment for the next generation of refrigerants, the development process is lengthy and complicated. Newly designed equipment must go through many tests to make sure they meet EPA and Department of Energy regulations, Dick Lord, Carrier Senior Fellow and ASHRAE Fellow, said.
New safety standards, building codes, and transportation and storage regulations also will be needed. “Every manufacturer is working at 110% or 120% workload to meet demand,” Lord said.
There are also new efficiency requirements and test procedures that go into effect on January 1, 2023 and January 1, 2024, Lord added. “As part of the redesign and refrigerant changes, efficiency must be verified to comply with ASHRAE 90.1 and Department of Energy requirements, and be certified to AHRI ratings standards. Because the refrigerant changes, in many cases, require use of A2L refrigerants, the unit design must be in compliance with ASHRAE 15 and building codes,” Lord explained.
Another challenge facing the industry is the training of service technicians who must learn how to operate new equipment. “They have to learn the different properties of refrigerants, how to deal with flammable compounds and how to transport and store such materials. Additional safety precautions need to be taken with these newer, mildly flammable refrigerants,” Forth explained.
Johnson Controls is converting its products in the U.S. from R-410A to R-454B, which has a GWP equal to 2,088 to R-454B which has a GWP of 466, a reduction of 78%, Forth said. It’s the lowest SNAP-approved alternative currently on the market for stationary air-conditioning. Forth added. “There’s an urgency to get HFCs out of the environment and transition to alternatives that have a lower environmental impact on the atmosphere,” Forth said. “Contractors, distributors, businesses and homeowners need to be preparing now well ahead of the January 1, 2025 deadline.”
If a business does not comply or has difficulty meeting requirements, there might be fines and penalties, Tan said. But it’s not known at this point what those fines and penalties will be.
While FMs face a long, difficult transition ahead, the work they do is good for their business and for the environment.