Regulatory Updates: Refrigerant Rulemaking in 2019E360 Webinar • February 26, 2019
Jennifer ButschRegulatory Affairs Manager, Air ConditioningEmerson
Dr. Rajan RajendranV.P., Systems Innovation Centerand SustainabilityEmerson
Speakers
Dr. Rajan Rajendran is the vice president, systems innovation center and sustainability at Emerson. He has worked at Emerson since 1990 in various capacities. Rajan is also the director of The Helix, Emerson’s research and innovation center located on the University of Dayton’s campus. He represents Emerson in its communications with various policy and industry organizations, such as the U.S. Environmental Protection Agency and the U.S. Department of Energy, among others. Rajan earned a bachelor’s degree in mechanical engineering from the University of Madras. He earned his master’s and doctorate degrees in mechanical engineering from Iowa State University and has an M.B.A. from Wright State University.
Dr. Rajan RajendranVice President, Systems Innovation Center and Sustainability — The Helix Innovation CenterEmerson
Jennifer has been involved in regulatory affairs across multiple industries for more than 15 years. In her current role, she is responsible for managing activities related to policies, regulations, codes and standards as they apply to the air conditioning and heat pump market. She is involved in several industry organizations, including AHRI and ASHRAE. Jennifer earned her bachelor’s degree in biomedical engineering from Wright State University and has an M.B.A. from the University of Phoenix.
Jennifer ButschRegulatory Affairs Manager — Air Conditioning, Emerson
This presentation is intended to highlight changing developments in the law and industry topics. The law is frequently evolving and information and publications in this presentation may not reflect the latest changes in the law or legal interpretations. The statements and information provided in this presentation should not be construed as legal advice or legal opinion regarding any specific facts or circumstances, but is intended for general informational purposes only. The views and statements expressed during this presentation are the personal opinions of the presenter and do not represent those of Emerson Climate Technologies, Inc. or its affiliated companies. You should consult an attorney about your situation and specific facts and you should not act on any of the information in this presentation as the information may not be applicable to your situation. Although all statements and information contained herein are believed to be accurate and reliable, they are presented without warranty of any kind. Information provided herein does not relieve the user from the responsibility of carrying out its own tests and experiments. Statements or suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patents. This presentation may not be copied or redistributed without the express written consent of Emerson Climate Technologies, Inc.
Disclaimer
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Kigali Amendment to Montreal Protocol — October 15, 2016
4
• Global agreement on HFC phase-down1
• Ratified by 65+ countries, including E.U. countries, Canada and Mexico2
• Still under consideration by the U.S. government
– Ratification in the U.S. could lead up to 33,000 additional manufacturing jobs and increased global market share3
Entered into effect January 1, 20191 http://conf.montreal-protocol.org/meeting/mop/mop-28/final-report/English/Kigali_Amendment-English.pdf2 https://kigali-amendment.openclimatedata.net3 http://www.alliancepolicy.org/downloads/press-releases/Kigali_Economic_Report.pdf
0
20
40
60
80
100
120
2010 2015 2020 2025 2030 2035 2040 2045 2050 2055
GW
P W
eigh
ted
CAP
(% o
f Bas
elin
e)
A2 Countries(U.S., Canada, etc.)
A5 CountriesGroup 1
A5 Countries, Group 2(India, Iran, Pakistan, Iraq, GCC)A2 Countries
(Belarus, Russian Federation, Kazakhstan, Tajikistan, Uzbekistan)
2024 Freeze
2028 Freeze
Europe and Canada HFC Phase-down Quotas and Application Limits
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E.U. F-gas phase-down more aggressive than Kigali. Canada following Kigali phase-down steps.
A2 Countries
(US, Canada)
0
20
40
60
80
100
120
2010 2015 2020 2025 2030 2035 2040 2045 2050 2055
GW
P W
eigh
ted
CAP
(% o
f Bas
elin
e)
2024 Freeze
2028 Freeze
A5 CountriesGroup 1
A2 Countries(Belarus, Russian Federation,
Kazakhstan, Tajikistan, Uzbekistan)EU F-Gas
A5 Countries, Group 2(India, Iran, Pakistan, Iraq, GCC)
Domestic refrigeration
1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0517&from=EN2 http://www.gazette.gc.ca/rp-pr/p2/2017/2017-10-18/html/sor-dors216-eng.html
1
2
U.S. EPA Continues to Roll Back Previous Regulations
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• SNAP Rules 20/21– Rule 21 remains in litigation; EPA currently not enforcing HFC delistings1
• Clean Air Act Section 608– Proposal to exclude HFCs from Section 608 of Refrigerant Management Program (RMP)2
• Would still apply to ozone-depleting substances– Appliances with 50 or more pounds of refrigerant would no longer be subject to:
• Conduct leak rate calculations when refrigerant is added to an appliance• Repair an appliance that leaks above a threshold leak rate• Conduct verification tests on repairs• Conduct periodic leak inspections on appliances that exceed the threshold leak rate• Report to EPA on chronically leaking appliances• Retrofit or retire appliances that are not repaired• Maintain related records
New EPA regulations forthcoming in early 20191https://www.regulations.gov/document?D=EPA-HQ-OAR-2003-0118-16412https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations
California Leads State Efforts in Reducing HFC Emissions
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• California adopts SNAP Rules 20 and 21 into state law– Effective Jan. 1, 2019
– Manufacturers cannot sell equipment or products which use prohibited HFCs that are manufactured after their respective prohibition dates and must provide a written disclosure to the buyer as part of the sales transaction and invoice
– Allows CARB to list or delist refrigerants, regardless of status, at a federal level
• New York, New Jersey, Maryland, Connecticut, Washington and Vermont have also announced plans to adopt SNAP Rules 20 and 21.
Industry favors consistent approach across all stateshttps://leginfo.legislature.ca.gov/faces/billStatusClient.xhtml?bill_id=201720180SB1013
U.S. Climate Alliance Membership Increasing
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• States committed to leading on climate change initiatives, including reduction of HFCs
• 21 members and growing– Wisconsin, Michigan, Illinois
and New Mexico have joined this year
Now make up 49 percent of population and more than 50 percent of GDPhttps://www.usclimatealliance.org/publications/2019/2/12/wisconsin-governor-tony-evers-joins-us-climate-alliance
Pending CARB Rulemaking: SLCP Proposals to Reduce HFCs to Fill Gap
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AC will begin first; board meeting and final regulation scheduled for December – GWP<750: Stationary air conditioning — effective 2023– No additional rulemaking for chillers — will rely on SNAP Rule 21 now in place, per SB 1013
Commercial refrigeration will follow; board meeting and final regulation scheduled for March 2020– GWP<150: Stationary refrigeration >50 lbs — effective 2022
Sales Restrictions on Refrigerants– No production, import, sales, distribution or entry into commerce of refrigerants with
GWP≥1,500 effective in 2022– Open to use of reclaim for service, proposed sales exemption for R-410A
AC stakeholder meeting scheduled for March 6https://ww2.arb.ca.gov/resources/documents/workshop-hydrofluorocarbon-emission-reduction-measureshttps://ww2.arb.ca.gov/resources/documents/stationary-air-conditioning-rulemaking-march-06-2019
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CARB Modified March 2018 — EPA SNAP Rule 20 California Adopted Into Law Sept. 13, 2018 —EPA SNAP Rule 21
Supermarket Central Systems Remote Condensing Unit Stand-Alone
Refrigerant GWP (AR4) New Retrofit New Retrofit
MT <2,200 BTU/hr and Not Contain
Flooded Evap (New)
MT <2,200 BTU/hr
With Flooded
Evap (New)
MT >2,200 BTU/hr With or Without Flooded
Evap (New)
LT (New)
LT and MT
(Retrofit)
Refrigerated Food
Processing and
Dispensing Equipment
Cold-StorageWarehouses
(New)
Ice Machines
(New)
Very Low-Temp
Refrigeration (New)
Positive Displacement
Chillers
R-404A/R-507A
3,922/3,985 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 1-Jan-19 1-Jan-21 1-Jan-23 OK OK —
R-452A 2,141 — — OK OK — — — — — — — — — —
R-410A 2,088 OK — OK — 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 — 1-Jan-21 1-Jan-23 OK OK 1-Jan-24
R-407A R-407CR-407F
2,107 1,774 1,825
OK OK OK OK 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 OK 1-Jan-211-Jan-23(R-407A)R-407C/F
OK R-407C Only —
By 2022 No Sale of Refrigerant >1,500 GWP
R-407H 1,500 — — OK OK — — — — — — — — — —
HFC134a 1,430 OK OK OK OK 1-Jan-19 1-Jan-20 1-Jan-20 OK OK OK 1-Jan-23 OK — 1-Jan-24
R-448A R-449A
1,3871,397 OK OK OK OK
Neither SNAP
approved nor banned
Neither SNAP
approved nor banned
Neither SNAP
approved nor banned
OK OK OK — OK — —
R-513A R-450A
631604 OK OK OK OK OK OK OK OK OK OK — OK R-513A
R-290 3 — — — — OK OK OK OK — — 1-Jan-23 OK OK —
R-744 1 OK — OK — OK OK OK — — OK — — OK —
R-717 0OK (in
primary loop or secondary
system)—
OK (in primary loop or secondary
system)—
OK (in primary loop or secondary
system)
OK (in primary loop or secondary
system)
OK (in primary loop or secondary
system)
OK (in primary loop or
secondary system)
OK (in primary loop or
secondary system)
OK (in primary loop or
secondary system)
— OK — —
https://www.arb.ca.gov/regact/2018/casnap/frocasnap.pdf?_ga=2.218430745.1470580036.1550670229-1794744721.1490616412
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CARB Modified March 2018 — EPA SNAP Rule 20 Stand-Alone MT <2,200 BTU/hr and Not Contain
Flooded Evap (New)
Stand-Alone MT <2,200
BTU/hr With Flooded Evap
(New)
Stand-Alone MT >2,200
BTU/hr With or Without
Flooded Evap (New)
Stand-Alone
LT (New)
Stand-Alone LT
and MT (Retrofit) Refrigerant GWP Central System
New
Central System Retrofit
Remote Condensing
Unit New
Remote Condensing Unit Retrofit
R-404A/R-507A
3,922/3,985 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 1-Jan-19
R-452A 2,141 — — OK OK — — — — —
R-410A 2,088 OK — OK — 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 —
R-407A R-407CR-407F
2,107 1,774 1,825
OK OK OK OK 1-Jan-19 1-Jan-20 1-Jan-20 1-Jan-20 OK
By 2022 No Sale of Refrigerant >1,500 GWP
R-407H 1,500 — — OK OK — — — — —
HFC134a 1,430 OK OK OK OK 1-Jan-19 1-Jan-20 1-Jan-20 OK OK
R-448A R-449A
1,3871,397 OK OK OK OK
Neither SNAP approved nor
banned
Neither SNAP approved nor
banned
Neither SNAP approved nor
banned OK OK
R-513A R-450A
631604 OK OK OK OK OK OK OK OK OK
R-290 3 — — — — OK OK OK OK —
R-744 1 OK — OK — OK OK OK — —
R-717 0OK (in
primary loop or secondary
system)
—
OK (in primary loop or
secondary system)
—
OK (in primary loop or
secondary system)
OK (in primary loop or
secondary system)
OK (in primary loop or
secondary system)
OK (in primary loop or secondary
system)
OK (in primary loop or
secondary system)
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California Adopted Into Law Sept. 13, 2018 — EPA SNAP Rule 21
Refrigerant GWPRefrigerated Food
Processing and Dispensing Equipment
Cold-StorageWarehouses
(New)
Ice Machines (New)
Very Low-Temp Refrigeration
(New)
Positive Displacement
Chillers
R-404A/R-507A 3,922/3,985 1-Jan-21 1-Jan-23 OK OK —
R-452A 2,141 — — — — —
R-410A 2,088 1-Jan-21 1-Jan-23 OK OK 1-Jan-24
R-407A R-407CR-407F
2,107 1,774 1,825
1-Jan-211-Jan-23(R-407A)R-407C/F
OK R-407C Only —
By 2022 No Sale of Refrigerant >1,500 GWP
R-407H 1,500 — — — — —
HFC134a 1,430 OK 1-Jan-23 OK — 1-Jan-24
R-448A R-449A
1,3871,397 OK — OK — —
R-513A R-450A
631604 OK — OK R-513A
R-290 3 — 1-Jan-23 OK OK —
R-744 1 OK — — OK —
R-717 0 OK (in primary loop or secondary system) — OK — —
ANSI/ASHRAE Flammability Classifications
• Class 2L vs. 2 Flammability Classification Based on:– Burning velocity
• Maximum velocity at which a flame propagates in a normal direction relative to unburned gas ahead of it
• Lower burning velocity <10 cm/s = 2L• Higher burning velocity >10 cm/s = 2 or 3
• Class 2 vs. 3 Flammability Classification Based on:– Heat of combustion and lower flammability limit (LFL)
Many of the lower-GWP refrigerants are classified as A2L.1313
Refrigerant Alternatives Trend Toward Lower GWP
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R-410ALike
Capacity
R-404A &R-407/22Like
R-134aLike
GWP Level
400–675
< 1,500
400–600
~300
HFO 1234yfHFO 1234ze
R-410A
R-22, R-407AR-407CR-407F, R-452A
0 500 1,000 1,500 2,000
Pressureor
R-32/HFC/HFOBlends
R-32/HFOBlends
HFC/HFOBlends
HFC134a
CO2
R-404AR-507A
R-290
NH3
A1 – Non-Flammable
A2L – Mildly Flammable
A3 – Flammable
R-123 Like(V. Low Pr.)
(3,922)R-32/HFOBlends
R-448A, R-449A, R-449B
R-450A, R-513A
R-444B
R-455AR-454CR-457A
R-32, R-452B, R-454B,
<150
B2L – Toxic, Mildly Flam.
Qualitative — Not to Scale
1
Legacy3 2
Ref Only
Ref Only
Ref/ACRef/AC
HFO 1336mzz(Z)HCFO 1233zd(E)
R-515A
R-466A
Codes and Standards
• Provide guidelines on the safest way to use refrigerants and reduce risks
• Establish common practices for application, installation and repair of equipment when using refrigerants
• Create a legal framework for compliance of local and regional laws
• Provide for a technological baseline that will help advance the state of the art
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Standards
Codes
End Users
• Created by technical committees
• Heavy on technical/scientific issues
• Created by special trade groups
• Heavy on practical aspects
Source: The Alliance for Responsible Atmospheric Policy
Code and Standards Adoption Flow
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Refrigerant Standards
Equipment Standards
Application Standards
Building Codes
(three-year cycle)
Local Codes (may take an
additional 1–8 years)
ASHRAE 34
UL 60335-2-89/UL 60335-2-40
ASHRAE 15
• International Mechanical Code (IMC/UMC)• International Fire Code (IFC)• International Building Code (IBC)
• State, county and local building codes
• Insurance codes• Adoption
ISO817/EN378-1
IEC 60335-2-89/EN 60335-2-89IEC 60335-2-40/EN 60335-2-40
ISO 5149/EN378
National Codes
E.U. U.S.
Source: The Alliance for Responsible Atmospheric Policy
Indirect Systems/Chillers MT
Integrated Display Cases
Micro-Distributed & De-CentralizedFoodservice/Cold RoomsCentralized Racks
Refrigerant Alternatives Drive System Changes in Refrigeration
A2L <150
Hybrid/Cascade
CO2 Booster
R-404A
CO2
Retail-Centralized
Growing/Decreasing
Niche
A2L<150
R-290
Remote Units — Cold Rooms
CO2
HFO A2L<150 R-404A
Packaged Units — Cold Rooms
Likely Refrigerant After 2021
CO2 (LT)CO2 (LT)
CO2?
CO2R-290CO2?
A1 (<50 lbs) <1,500 GWP
A1 (<50 lbs) <1,500 GWPR-290CO2?
A1 (<50 lbs) <1,500 GWP A1 (<50 lbs) <1,500 GWP
Distributed Units <136 MBH (11 Tons or 40 kW)
A2L <150CO2 (LT)
A1 (<50 lbs) <1,500 GWP
R-290R-717 17
R-404A
R-404A
R-404A
R-404A
R-404A
A1 Non-FlammableA2L Mildly FlammableA3 FlammableB2L Toxic, Mildly Flammable
Questions?
DISCLAIMERAlthough all statements and information contained herein are believed to be accurate and reliable, they are presented without guarantee or warranty of any kind, expressed or implied. Information provided herein does not relieve the user from the responsibility of carrying out its own tests and experiments, and the user assumes all risks and liability for use of the information and results obtained. Statements or suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patents. The user should not assume that all toxicity data and safety measures are indicated herein or that other measures may not be required.
Thank You!
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