Refrigerant Regulations
Preparing for Stronger
Refrigerant Regulations
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
The U.S. Environmental Protection Agency’s expanded refrigerant regulations that take effect in 2018 and 2019 will affect virtually every commercial and governmental operation in the United States. The new requirements for documentation, record-keeping and reporting will affect facility owners and managers, environmental managers, contractors and certified technicians. In this eBook, we discuss the changes and what they mean for your operations so that you can gauge your organization’s state of preparedness and take action in the coming months and years.
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OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
The State of Refrigerants Today At no time in history has refrigerant management been so important. Initially, just focusing on ozone depleting substances (ODS) regulations still provided for curbing emissions of non-ODS refrigerants (i.e., hydrofluorocarbons like R-134a in our cars, refrigerators, and chillers) with the prohibition on intentional venting of substitute refrigerants. While a good start, the venting ban was not enough in that it did not mandate repair of leaking systems or limit “topping off” like the ODS rules. Since the initial ODS rules of the 1990s, climate change research has revealed that all refrigerants have a global warming potential (GWP)—they trap heat, just as methane and CO2 do, but much more so. Refrigerants have GWPs that are hundreds to thousands of times more than CO2. The international community has recognized this with approvals to amend and expand the Montreal Protocol on Substances That Deplete the Ozone Layer, targeting high GWP refrigerants for phase-out by midcentury. Individual countries have amended their own refrigerant regulations to meet the new treaty provisions, with the U.S. EPA including HFC refrigerants in the leak repair requirements of Section 608 of the Clean Air Act and the European Union F-Gas Regulations, which ban HFCs and focus on “natural refrigerants” like CO2, propane and ammonia.
What’s Driving this Change? The main drivers for the global refrigerant transition are climate change, energy and economics. On the climate front, NASA has shown data that historical CO2 levels have risen dramatically beyond normal cyclical concentrations. At 40 gigatons per year, human activities are responsible for producing more CO2 than all the volcanoes on earth, and the rate of emissions is increasing. The last time earth experienced such high levels of CO2 was 3 million years ago during the Pliocene period with atmospheric CO2 levels 5 times higher than today.
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PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Unfortunately, trees alone can’t absorb the excess CO2.. One study calculated that if you wanted to remove just 4 gigatons of CO2 out of the atmosphere by planting trees, you’d need to cover an area the size of the United States with forests … and then plant an area the size of New York once a year for 50 years. Nor can the oceans take it all. Studies have shown that warming oceans can no longer absorb CO2 at the same rate because they’re getting saturated and more acidic. With carbonic acid oceans, it’s no wonder why coral reefs are getting bleached to death and dissolving. Mankind is desperate for solutions. How do we reduce greenhouse gas emissions? How do we curb the output of the biggest, most potent polluters? CO2, methane and refrigerants represent most of the world’s carbon footprint. Many concepts for mitigation have been conceived and tested with scalability and cost limiting their success. A recent New York Times best seller, “Drawdown: The Most Comprehensive Plan Ever Proposed to Reverse Global Warming” evaluated “the 100 most substantive solutions to reverse global warming, based on meticulous research by leading scientists and policymakers around the world.” The book weighs the cost vs. the return on investment for the most promising initiatives to reverse global warming. That bears repeating. Reverse. Global. Warming. (Not just reduce the rate of increase). It turns out that 90 percent of refrigerant emissions occur at the end of life. Old systems leak more often, and irresponsible handling of disposed air conditioners and refrigerators at landfills and metal recyclers leads to massive refrigerant emissions. The “Drawdown” findings indicate that 87 percent of refrigerants that are likely to be released over 30 years, if
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contained, could avoid emissions equivalent to 89.7 gigatons of CO2. With responsible removal of refrigerants at the time of disposal, we can significantly reduce—even reverse—global warming. Just with refrigerants. Additionally, with the recent Kigali Amendment to the Montreal Protocol, which phase out HFC refrigerants by midcentury, 25 to 78 gigatons of CO2 equivalent can be removed. This is already set in motion and is in addition to the “Drawdown” estimates. Timing is critical. The number of air conditioning systems is growing exponentially worldwide. A recent study by the Lawrence Berkeley National Laboratory estimated by 2030 700 million air conditioning units will be online worldwide. Some estimates are as high 1.6 billion AC units by 2050. The world’s standard of living is improving, and global poverty is at record lows. More homes and businesses are air conditioned than ever before. In the span of 15 years, China went from having AC in a small percentage of homes and buildings to 100 percent saturation. Mexico went from 13 percent to more than 70 percent in roughly the same time span. With all those air conditioners coming online, it begs the question: Will they be disposed of responsibly? Or will we face a literal tsunami of refrigerants hitting our atmosphere? Recall that refrigerants have very high global warming potential when compared to CO2 or methane.
SPOILER ALERT: Coming in at the top of the list , far ahead of wind and solar, is Refrigerant Management.
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
HCFC & HFC GWP 5000
GWP
4000 3000 2000 1000 0 R-123
R-22
R-414B
R-416
R-134a
R-404A
R-407C
R-410A R-507
R-422D
Refrigerants
Note that CO2 is the “measuring stick” for GWP at a value of 1.0. As the chart shows, refrigerants are thousands of times more potent than CO2—and much better at trapping heat. Good for air conditioning—bad for the planet. R&D departments at refrigerant manufacturers continue to develop lower GWP alternatives. Many new blends have come out with significantly lower GWPs. HFO refrigerants, hydrofluoroolefins, have very low GWPs and can be blended with other HFC refrigerants to get lower combined GWPs in the blend. Natural refrigerants such as CO2, hydrocarbons and ammonia are being promoted worldwide. The ultimate goal is to develop a refrigerant that has no GWP, ODP, toxicity or flammability. Stay tuned.
5
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Energy and economics are the remaining two drivers for the global refrigerant transition, and they are intertwined with the climate change issue. Mandates for improved energy efficiency in air conditioning and refrigeration systems will have a twofold positive effect. First: using less energy, they will cost less to run, improving facility operating costs. Second: using less energy, they require less centralized energy production and therefore reduced air emissions.
ROI: Refrigerant management of leaking systems has a return on investment. Leaking systems or improperly charged systems operate inefficiently. Studies have shown and yielded a rule-of-thumb that, for each percentage that a refrigerant charge is off, the energy usage is increased by the same amount. Accurately determining and then closely monitoring systems’ refrigerant charges can reduce energy waste and improve the bottom line. ROI: Failures are more frequent in improperly charged systems. Refrigerants and lubrication oils are mixed, or entrained, with refrigerants cooling the motor (in most systems) and oils keeping things from seizing up. Costly system crashes such as bearing failure, compressor burnouts or pressure relief valve releases are more common if the charge is off. The useful life of systems can be shortened with failures like those described, which could have an effect on capital budgets if systems must be replaced ahead of their projected lifespans. ROI: System failures can be costly with lost production or productivity. 6
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
Rule Changes: What to Expect Changes to refrigerant regulations phase-in from 2017 to 2019 and effect every technician, facility manager, environmental manager, contractor, refrigerant reclaimer and refrigerant distributor. The highlights are listed below:
2017 2017: Industry standards for refrigerant reclamation of HFCs were formalized with regulations requiring that HFCs be reclaimed to AHRI 700-2016 (updated) standards for purity. (In reality, the industry has already been doing this, but the change formalized it.) 2017: Refrigerant recovery equipment will no longer have to be registered with the EPA via the Recovery Device Acquisition Certification form. (This obsolete requirement was from the early 1990s when recovery units were new, not common and expensive). Units must still be Air-Conditioning, Heating & Refrigeration Institute (AHRI) or UL approved and labeled.
2018 2018: The documentation and recordkeeping bar was raised—by lowering it. The goal is to address the refrigerant emissions at the end of life, (as “Drawdown” referred to). Disposed systems, or circuits, that contain 5 to 50 pounds will require documentation by the technician showing refrigerant quantities recovered when disposing of the system. Records must be maintained for the disposition of the used refrigerant. Did it go into the facility’s inventory? Did the contractor take it for drop-off at the refrigerant supplier? Did it go to a refrigerant reclaimer for reclamation, destruction or disposal, or was it returned to the owner? Owners will keep records for refrigerant disposals, reclaims and returns, as will the contractors, supply house and reclaimer. That’s a lot of records to be generated, monitored and managed.
2019 2019: The most profound changes to refrigerant regulations since their inception HFCs will fall under the leak rate and leak repair requirements, just like CFCs and HCFCs have been regulated since the 1990s. Systems or circuits with 50 or more pounds of refrigerants like R-134a, R-410A, R-404A, R-507, R-422 and “ODS substitutes” will have to be monitored for leakage with the new, lower-leak rate thresholds and repaired within required time frames. The new, lower-leak-rate thresholds represent less “wiggle room” for each leak event. Leaks will have to be addressed more quickly. Refrigerant quantities added to operating systems must be promptly factored into a leak-rate calculation. Why “promptly”? That’s a great question! The answer is that once the allowable leak rate threshold has been exceeded, the leak(s) must be repaired within 30 days (or go to contingency plans for mothballing or retrofit/replacement. More on that later.). It’s important to crunch the numbers as soon as possible as you could need every one of those 30 days to repair the leaks. Equally important is getting the documentation from the technician or contractor--within 24 hours—so leak rates can be “promptly” calculated. Don’t wait for the invoice because by then it might be too late. Regardless of which leak rate calculation formula is used, “Annualized” or “Rolling Average,” the math must be right. That starts with the full charge of the system or circuit. If the full charge information is inaccurate or unknown, then the math won’t be right. Detailed documentation on the refrigerant quantities added, and recovered, get plugged into the equation. Leak rates are calculated on the net difference between the amounts recovered and added. If the documentation you receive is incomplete in terms of recovered amounts, then now is the time to address it. The margin of error is getting slimmer!
NOTE: A new provision will allow more than 30 days to repair the leak if parts are not available. Dated documentation provided by the supplier must be kept with leak repair records. Any other leaks must be repaired and documented while waiting for parts. 7
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
New Leak Rate Thresholds for Duty Types Industrial Process Refrigeration (IPR) goes from 35% down to 30%. Remember that IPR is only for systems directly applied to creating a product, an integral part of the manufacturing process. Commercial Refrigeration gets the biggest cut from 35% down to 20%. This sector is typically food-related refrigeration such as grocery stores and food distribution warehouses. Comfort Cooling and Other Cooling goes from 15% down to 10%. The tightest threshold is reserved for cooling people and machines (computer rooms, motor control centers and, switch gears).
Leak Detection Leak inspections will be required once a system has exceeded its allowable leakage threshold and (presumably) has been repaired. For the entire following year, EPA-certified technicians will have to physically check the system for leaks using a variety of detectors to verify the system is no longer leaking. The other option is to use Automatic Leak Detection systems. (More on this later.) Either way, since the system has proven itself to be a “leaker,” extra diligence is needed. You have to monitor the system more closely.
ACTION ITEMS: Every facility should revisit and confirm their 50-plus pound system inventory. •Be sure the refrigerant type is identified (R-22, R-134a, R-123, R-410A, etc.) • Is the full charge data accurate? • As a best practice, label the system with this information. • Validate the Duty Type assigned to the system. Is it correct? • Assign the appropriate leak-rate threshold • Confirm and apply the leak-rate-calculation formula for your facility The schedule for leak inspections depends on the refrigerant charge and Duty Type: Quarterly: Industrial Process Refrigeration (IPR) and Commercial Refrigeration with a 500-plus pounds charge Annual: Industrial Process Refrigeration (IPR) and Commercial Refrigeration with a 50 to 500 pounds charge Annual: Comfort Cooling/Other Cooling with a 50 or more pounds charge Frequent leak inspections have historically been the domain of preventive maintenance. These days, leak inspections are for environmental purposes, too—getting an early warning on leaks and achieving refrigerant emission reduction, control and prevention. 8
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
Repair Verification Tests
Reporting
Tests are to be conducted by EPA-certified technicians to verify that leak repairs were successful. They decide which method to use based on sound professional judgment. Their experience will dictate whether to use soap bubbles, deep vacuum, electronic or ultrasonic leak detectors.
The EPA wants to know about your worst “leakers.” If a system has leaked more than 125 percent of its full charge in a calendar year, it must be reported to EPA by March of the following year. In a hypothetical scenario, a system could lose its full charge because of a cracked refrigerant line, so that’s 100 percent. Then, in the same calendar year it could have a small leak repaired with 25 percent refrigerant loss. That would be reportable in the following year. Monitoring year-to-date leakage within a calendar year and reporting is a whole new challenge for documentation and record-keeping systems.
Double check leak repairs • First, the Initial Leak Repair Verification test. If this test shows the repair to be successful, then the technician is allowed to add refrigerant to the system’s full charge and start the system. (One point of confusion is the word “initial.” Some incorrectly think that is how they initially found the leak). • Second, the Follow-up Leak Repair Verification Test. Within 30 days of the system returning to normal operating temperatures and pressures, a technician must be scheduled by management to conduct the test. Selecting from their methods, technicians will make sure that the repairs hold up with the system operating normally under a load. (In some cases, due to system design or safety factors, the technician might determine the repairs would be better verified with the system not operating. This is allowed under the rules.)
NOTE: Year-to-date leakage is not the same as Leak Rates, but they both require accurate refrigerant charge data.
• Key compliance elements: Scheduling, accurate documentation and recordkeeping
Automatic Leak Detection (ALD) Watching for leaks, not waiting. Pro-active, not reactive. The American Society of Heating, Refrigeration, Air-Conditioning Engineers (ASHRAE) Standard 15-1994 called for refrigerant leak detectors in confined mechanical rooms for worker safety. Now, leak detectors and leak inspections are for environmental purposes, too—getting an early warning on leaks and achieving refrigerant emission reduction, control and prevention. There are several manufacturers of ALDs in the U.S. and abroad. Systems can range from direct, active “sniffers” to indirect monitors that send out alerts when there are sudden pressure
drops or temperature fluctuations. Records must be kept foreach system, its sensors, associated appliances, calibrations and repairs. All facilities should consider evaluating their appliance inventory to determine which might be candidates for ALDs. Some appliances might already be monitored well enough from existing building automation systems or native controls to support this effort. Appliances that aren’t good candidates for monitoring will have to rely on the good old-fashioned leak inspections by a certified technician.
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PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Hear the Call to Action With added layers of documentation and recordkeeping at our doorstep, each facility must re-evaluate their methods for capturing refrigerant-related activities and for retaining proof of compliance with the new requirements. Log books and spreadsheets will likely prove to be too cumbersome to meet electronic recordkeeping and annual reporting obligations. Think about your operation and all the refrigerant-related activities performed by contractors and in-house technicians—new installations, disposals, leak repairs and conversions—that can be a lot for any organization to manage.
By the Book Many will have to revisit and rewrite their Refrigerant Compliance Plans (aka CFC Plans) and upgrade them to a Refrigerant Management Plan. What’s the difference? A compliance plan implies that you’re just meeting the requirements, not doing anything beyond what is mandated in black and white. It contains the “what” of what is required, but maybe not the “how” of how you’re going to get it done. A management plan is broader in scope as it will include “how” things like best practices for sustainable methods, reduced consumption of resources and the means to minimize waste. An example of this would be requiring leak repairs on systems with charges of less than 50 pounds. While not required by U.S. EPA regulations, fixing leaks on smaller systems would reduce energy and refrigerant costs. Likewise, downtime of an AC system, or one that is not cooling properly, affects the productivity of workers. Itall falls under energy and economics again. Refrigerant Management Plans can incorporate safety items from ASHRAE, AHRI, DOT 49 CFRs, OSHA 29 CFRs, and NFPA guidelines for storage, labeling, and transportation of refrigerant cylinders and drums. Where you store refrigerant inventories, how you mark them and how you handle them can have a big impact on operations in terms of risk and compliance. A good Refrigerant Management Plan is kept current with new regulations, refrigerants, technologies and techniques. It is customized for your specific operations, whether they are dominated by industrial process refrigeration or comfort cooling, contracted or in-house. It changes with organizational shifts and personnel reassignments to ensure continuity and accountability for all affected parties. Self-audit checklists for ongoing compliance are recommended.
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Getting documentation for all that work, routing it for review and handling recordkeeping all within the mandated time limits is no easy feat! Most organizations will have to revamp their documentation and recordkeeping methods in the coming months and years. Standardized forms have always been helpful, but now more than ever. Requirements now call for electronic databases to allow for continuous monitoring of every system—alerting on leakage, prompting action, tracking disposals and instantly reporting any vital data.
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
It is evident that most organizations will need to revisit and revamp their refrigerant management initiatives to address required practices, documentation methods, electronic recordkeeping and reporting. Facilities and contractors will need to communicate more quickly and with more detail to address leaking systems and appliance disposals. If your contractor isn’t a good “compliance partner” with good documentation and communication, then it might be time for a change. With fines at $37,500 per day per violation and supplemental environmental projects costing millions of dollars, the risk is too great. And don’t we want to save the planet?
Mark Harbin has been helping clients implement refrigerant compliance initiatives since 2000. His 15-year career in commercial HVAC prior to that served as the foundation for environmental consulting. As a Certified Environmental Auditor, he has been instrumental in the assessment and support of organizations’ refrigerant compliance initiatives, providing solutions at hundreds of clients’ locations across the world with a variety of services including but not limited to compliance analysis, project management, EPA technician certification, management training and certification, and software implementation services.
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About Sphera For more than 30 years, Sphera has been committed to creating a safer, more sustainable and productive world by advancing operational excellence. Sphera is the largest global provider of Operational Excellence software and information services with a focus on Environmental Health & Safety (EH&S), Operational Risk and Product Stewardship. The Chicago-based company serves more than 2,500 customers and over 1 million individual users across 70 countries. Sphera is a portfolio company of Genstar Capital, a leading middle-market private equity firm focused on the software, industrial technology, financial services and healthcare industries.
www.sphera.com For more information contact us at: sphera.com/contact-us/ ®2018 Sphera. All Rights Reserved.
Refrigerant Regulations
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
The U.S. Environmental Protection Agency’s expanded refrigerant regulations that take effect in 2018 and 2019 will affect virtually every commercial and governmental operation in the United States. The new requirements for documentation, record-keeping and reporting will affect facility owners and managers, environmental managers, contractors and certified technicians. In this eBook, we discuss the changes and what they mean for your operations so that you can gauge your organization’s state of preparedness and take action in the coming months and years.
2
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
The State of Refrigerants Today At no time in history has refrigerant management been so important. Initially, just focusing on ozone depleting substances (ODS) regulations still provided for curbing emissions of non-ODS refrigerants (i.e., hydrofluorocarbons like R-134a in our cars, refrigerators, and chillers) with the prohibition on intentional venting of substitute refrigerants. While a good start, the venting ban was not enough in that it did not mandate repair of leaking systems or limit “topping off” like the ODS rules. Since the initial ODS rules of the 1990s, climate change research has revealed that all refrigerants have a global warming potential (GWP)—they trap heat, just as methane and CO2 do, but much more so. Refrigerants have GWPs that are hundreds to thousands of times more than CO2. The international community has recognized this with approvals to amend and expand the Montreal Protocol on Substances That Deplete the Ozone Layer, targeting high GWP refrigerants for phase-out by midcentury. Individual countries have amended their own refrigerant regulations to meet the new treaty provisions, with the U.S. EPA including HFC refrigerants in the leak repair requirements of Section 608 of the Clean Air Act and the European Union F-Gas Regulations, which ban HFCs and focus on “natural refrigerants” like CO2, propane and ammonia.
What’s Driving this Change? The main drivers for the global refrigerant transition are climate change, energy and economics. On the climate front, NASA has shown data that historical CO2 levels have risen dramatically beyond normal cyclical concentrations. At 40 gigatons per year, human activities are responsible for producing more CO2 than all the volcanoes on earth, and the rate of emissions is increasing. The last time earth experienced such high levels of CO2 was 3 million years ago during the Pliocene period with atmospheric CO2 levels 5 times higher than today.
3
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Unfortunately, trees alone can’t absorb the excess CO2.. One study calculated that if you wanted to remove just 4 gigatons of CO2 out of the atmosphere by planting trees, you’d need to cover an area the size of the United States with forests … and then plant an area the size of New York once a year for 50 years. Nor can the oceans take it all. Studies have shown that warming oceans can no longer absorb CO2 at the same rate because they’re getting saturated and more acidic. With carbonic acid oceans, it’s no wonder why coral reefs are getting bleached to death and dissolving. Mankind is desperate for solutions. How do we reduce greenhouse gas emissions? How do we curb the output of the biggest, most potent polluters? CO2, methane and refrigerants represent most of the world’s carbon footprint. Many concepts for mitigation have been conceived and tested with scalability and cost limiting their success. A recent New York Times best seller, “Drawdown: The Most Comprehensive Plan Ever Proposed to Reverse Global Warming” evaluated “the 100 most substantive solutions to reverse global warming, based on meticulous research by leading scientists and policymakers around the world.” The book weighs the cost vs. the return on investment for the most promising initiatives to reverse global warming. That bears repeating. Reverse. Global. Warming. (Not just reduce the rate of increase). It turns out that 90 percent of refrigerant emissions occur at the end of life. Old systems leak more often, and irresponsible handling of disposed air conditioners and refrigerators at landfills and metal recyclers leads to massive refrigerant emissions. The “Drawdown” findings indicate that 87 percent of refrigerants that are likely to be released over 30 years, if
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contained, could avoid emissions equivalent to 89.7 gigatons of CO2. With responsible removal of refrigerants at the time of disposal, we can significantly reduce—even reverse—global warming. Just with refrigerants. Additionally, with the recent Kigali Amendment to the Montreal Protocol, which phase out HFC refrigerants by midcentury, 25 to 78 gigatons of CO2 equivalent can be removed. This is already set in motion and is in addition to the “Drawdown” estimates. Timing is critical. The number of air conditioning systems is growing exponentially worldwide. A recent study by the Lawrence Berkeley National Laboratory estimated by 2030 700 million air conditioning units will be online worldwide. Some estimates are as high 1.6 billion AC units by 2050. The world’s standard of living is improving, and global poverty is at record lows. More homes and businesses are air conditioned than ever before. In the span of 15 years, China went from having AC in a small percentage of homes and buildings to 100 percent saturation. Mexico went from 13 percent to more than 70 percent in roughly the same time span. With all those air conditioners coming online, it begs the question: Will they be disposed of responsibly? Or will we face a literal tsunami of refrigerants hitting our atmosphere? Recall that refrigerants have very high global warming potential when compared to CO2 or methane.
SPOILER ALERT: Coming in at the top of the list , far ahead of wind and solar, is Refrigerant Management.
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
HCFC & HFC GWP 5000
GWP
4000 3000 2000 1000 0 R-123
R-22
R-414B
R-416
R-134a
R-404A
R-407C
R-410A R-507
R-422D
Refrigerants
Note that CO2 is the “measuring stick” for GWP at a value of 1.0. As the chart shows, refrigerants are thousands of times more potent than CO2—and much better at trapping heat. Good for air conditioning—bad for the planet. R&D departments at refrigerant manufacturers continue to develop lower GWP alternatives. Many new blends have come out with significantly lower GWPs. HFO refrigerants, hydrofluoroolefins, have very low GWPs and can be blended with other HFC refrigerants to get lower combined GWPs in the blend. Natural refrigerants such as CO2, hydrocarbons and ammonia are being promoted worldwide. The ultimate goal is to develop a refrigerant that has no GWP, ODP, toxicity or flammability. Stay tuned.
5
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Energy and economics are the remaining two drivers for the global refrigerant transition, and they are intertwined with the climate change issue. Mandates for improved energy efficiency in air conditioning and refrigeration systems will have a twofold positive effect. First: using less energy, they will cost less to run, improving facility operating costs. Second: using less energy, they require less centralized energy production and therefore reduced air emissions.
ROI: Refrigerant management of leaking systems has a return on investment. Leaking systems or improperly charged systems operate inefficiently. Studies have shown and yielded a rule-of-thumb that, for each percentage that a refrigerant charge is off, the energy usage is increased by the same amount. Accurately determining and then closely monitoring systems’ refrigerant charges can reduce energy waste and improve the bottom line. ROI: Failures are more frequent in improperly charged systems. Refrigerants and lubrication oils are mixed, or entrained, with refrigerants cooling the motor (in most systems) and oils keeping things from seizing up. Costly system crashes such as bearing failure, compressor burnouts or pressure relief valve releases are more common if the charge is off. The useful life of systems can be shortened with failures like those described, which could have an effect on capital budgets if systems must be replaced ahead of their projected lifespans. ROI: System failures can be costly with lost production or productivity. 6
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
Rule Changes: What to Expect Changes to refrigerant regulations phase-in from 2017 to 2019 and effect every technician, facility manager, environmental manager, contractor, refrigerant reclaimer and refrigerant distributor. The highlights are listed below:
2017 2017: Industry standards for refrigerant reclamation of HFCs were formalized with regulations requiring that HFCs be reclaimed to AHRI 700-2016 (updated) standards for purity. (In reality, the industry has already been doing this, but the change formalized it.) 2017: Refrigerant recovery equipment will no longer have to be registered with the EPA via the Recovery Device Acquisition Certification form. (This obsolete requirement was from the early 1990s when recovery units were new, not common and expensive). Units must still be Air-Conditioning, Heating & Refrigeration Institute (AHRI) or UL approved and labeled.
2018 2018: The documentation and recordkeeping bar was raised—by lowering it. The goal is to address the refrigerant emissions at the end of life, (as “Drawdown” referred to). Disposed systems, or circuits, that contain 5 to 50 pounds will require documentation by the technician showing refrigerant quantities recovered when disposing of the system. Records must be maintained for the disposition of the used refrigerant. Did it go into the facility’s inventory? Did the contractor take it for drop-off at the refrigerant supplier? Did it go to a refrigerant reclaimer for reclamation, destruction or disposal, or was it returned to the owner? Owners will keep records for refrigerant disposals, reclaims and returns, as will the contractors, supply house and reclaimer. That’s a lot of records to be generated, monitored and managed.
2019 2019: The most profound changes to refrigerant regulations since their inception HFCs will fall under the leak rate and leak repair requirements, just like CFCs and HCFCs have been regulated since the 1990s. Systems or circuits with 50 or more pounds of refrigerants like R-134a, R-410A, R-404A, R-507, R-422 and “ODS substitutes” will have to be monitored for leakage with the new, lower-leak rate thresholds and repaired within required time frames. The new, lower-leak-rate thresholds represent less “wiggle room” for each leak event. Leaks will have to be addressed more quickly. Refrigerant quantities added to operating systems must be promptly factored into a leak-rate calculation. Why “promptly”? That’s a great question! The answer is that once the allowable leak rate threshold has been exceeded, the leak(s) must be repaired within 30 days (or go to contingency plans for mothballing or retrofit/replacement. More on that later.). It’s important to crunch the numbers as soon as possible as you could need every one of those 30 days to repair the leaks. Equally important is getting the documentation from the technician or contractor--within 24 hours—so leak rates can be “promptly” calculated. Don’t wait for the invoice because by then it might be too late. Regardless of which leak rate calculation formula is used, “Annualized” or “Rolling Average,” the math must be right. That starts with the full charge of the system or circuit. If the full charge information is inaccurate or unknown, then the math won’t be right. Detailed documentation on the refrigerant quantities added, and recovered, get plugged into the equation. Leak rates are calculated on the net difference between the amounts recovered and added. If the documentation you receive is incomplete in terms of recovered amounts, then now is the time to address it. The margin of error is getting slimmer!
NOTE: A new provision will allow more than 30 days to repair the leak if parts are not available. Dated documentation provided by the supplier must be kept with leak repair records. Any other leaks must be repaired and documented while waiting for parts. 7
PREPARING FOR STRONGER REFRIGERANT REGULATIONS
New Leak Rate Thresholds for Duty Types Industrial Process Refrigeration (IPR) goes from 35% down to 30%. Remember that IPR is only for systems directly applied to creating a product, an integral part of the manufacturing process. Commercial Refrigeration gets the biggest cut from 35% down to 20%. This sector is typically food-related refrigeration such as grocery stores and food distribution warehouses. Comfort Cooling and Other Cooling goes from 15% down to 10%. The tightest threshold is reserved for cooling people and machines (computer rooms, motor control centers and, switch gears).
Leak Detection Leak inspections will be required once a system has exceeded its allowable leakage threshold and (presumably) has been repaired. For the entire following year, EPA-certified technicians will have to physically check the system for leaks using a variety of detectors to verify the system is no longer leaking. The other option is to use Automatic Leak Detection systems. (More on this later.) Either way, since the system has proven itself to be a “leaker,” extra diligence is needed. You have to monitor the system more closely.
ACTION ITEMS: Every facility should revisit and confirm their 50-plus pound system inventory. •Be sure the refrigerant type is identified (R-22, R-134a, R-123, R-410A, etc.) • Is the full charge data accurate? • As a best practice, label the system with this information. • Validate the Duty Type assigned to the system. Is it correct? • Assign the appropriate leak-rate threshold • Confirm and apply the leak-rate-calculation formula for your facility The schedule for leak inspections depends on the refrigerant charge and Duty Type: Quarterly: Industrial Process Refrigeration (IPR) and Commercial Refrigeration with a 500-plus pounds charge Annual: Industrial Process Refrigeration (IPR) and Commercial Refrigeration with a 50 to 500 pounds charge Annual: Comfort Cooling/Other Cooling with a 50 or more pounds charge Frequent leak inspections have historically been the domain of preventive maintenance. These days, leak inspections are for environmental purposes, too—getting an early warning on leaks and achieving refrigerant emission reduction, control and prevention. 8
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
Repair Verification Tests
Reporting
Tests are to be conducted by EPA-certified technicians to verify that leak repairs were successful. They decide which method to use based on sound professional judgment. Their experience will dictate whether to use soap bubbles, deep vacuum, electronic or ultrasonic leak detectors.
The EPA wants to know about your worst “leakers.” If a system has leaked more than 125 percent of its full charge in a calendar year, it must be reported to EPA by March of the following year. In a hypothetical scenario, a system could lose its full charge because of a cracked refrigerant line, so that’s 100 percent. Then, in the same calendar year it could have a small leak repaired with 25 percent refrigerant loss. That would be reportable in the following year. Monitoring year-to-date leakage within a calendar year and reporting is a whole new challenge for documentation and record-keeping systems.
Double check leak repairs • First, the Initial Leak Repair Verification test. If this test shows the repair to be successful, then the technician is allowed to add refrigerant to the system’s full charge and start the system. (One point of confusion is the word “initial.” Some incorrectly think that is how they initially found the leak). • Second, the Follow-up Leak Repair Verification Test. Within 30 days of the system returning to normal operating temperatures and pressures, a technician must be scheduled by management to conduct the test. Selecting from their methods, technicians will make sure that the repairs hold up with the system operating normally under a load. (In some cases, due to system design or safety factors, the technician might determine the repairs would be better verified with the system not operating. This is allowed under the rules.)
NOTE: Year-to-date leakage is not the same as Leak Rates, but they both require accurate refrigerant charge data.
• Key compliance elements: Scheduling, accurate documentation and recordkeeping
Automatic Leak Detection (ALD) Watching for leaks, not waiting. Pro-active, not reactive. The American Society of Heating, Refrigeration, Air-Conditioning Engineers (ASHRAE) Standard 15-1994 called for refrigerant leak detectors in confined mechanical rooms for worker safety. Now, leak detectors and leak inspections are for environmental purposes, too—getting an early warning on leaks and achieving refrigerant emission reduction, control and prevention. There are several manufacturers of ALDs in the U.S. and abroad. Systems can range from direct, active “sniffers” to indirect monitors that send out alerts when there are sudden pressure
drops or temperature fluctuations. Records must be kept foreach system, its sensors, associated appliances, calibrations and repairs. All facilities should consider evaluating their appliance inventory to determine which might be candidates for ALDs. Some appliances might already be monitored well enough from existing building automation systems or native controls to support this effort. Appliances that aren’t good candidates for monitoring will have to rely on the good old-fashioned leak inspections by a certified technician.
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PREPARING FOR STRONGER REFRIGERANT REGULATIONS
Hear the Call to Action With added layers of documentation and recordkeeping at our doorstep, each facility must re-evaluate their methods for capturing refrigerant-related activities and for retaining proof of compliance with the new requirements. Log books and spreadsheets will likely prove to be too cumbersome to meet electronic recordkeeping and annual reporting obligations. Think about your operation and all the refrigerant-related activities performed by contractors and in-house technicians—new installations, disposals, leak repairs and conversions—that can be a lot for any organization to manage.
By the Book Many will have to revisit and rewrite their Refrigerant Compliance Plans (aka CFC Plans) and upgrade them to a Refrigerant Management Plan. What’s the difference? A compliance plan implies that you’re just meeting the requirements, not doing anything beyond what is mandated in black and white. It contains the “what” of what is required, but maybe not the “how” of how you’re going to get it done. A management plan is broader in scope as it will include “how” things like best practices for sustainable methods, reduced consumption of resources and the means to minimize waste. An example of this would be requiring leak repairs on systems with charges of less than 50 pounds. While not required by U.S. EPA regulations, fixing leaks on smaller systems would reduce energy and refrigerant costs. Likewise, downtime of an AC system, or one that is not cooling properly, affects the productivity of workers. Itall falls under energy and economics again. Refrigerant Management Plans can incorporate safety items from ASHRAE, AHRI, DOT 49 CFRs, OSHA 29 CFRs, and NFPA guidelines for storage, labeling, and transportation of refrigerant cylinders and drums. Where you store refrigerant inventories, how you mark them and how you handle them can have a big impact on operations in terms of risk and compliance. A good Refrigerant Management Plan is kept current with new regulations, refrigerants, technologies and techniques. It is customized for your specific operations, whether they are dominated by industrial process refrigeration or comfort cooling, contracted or in-house. It changes with organizational shifts and personnel reassignments to ensure continuity and accountability for all affected parties. Self-audit checklists for ongoing compliance are recommended.
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Getting documentation for all that work, routing it for review and handling recordkeeping all within the mandated time limits is no easy feat! Most organizations will have to revamp their documentation and recordkeeping methods in the coming months and years. Standardized forms have always been helpful, but now more than ever. Requirements now call for electronic databases to allow for continuous monitoring of every system—alerting on leakage, prompting action, tracking disposals and instantly reporting any vital data.
OPERATIONAL RISK | ENVIRONMENTAL PERFORMANCE | PRODUCT STEWARDSHIP
It is evident that most organizations will need to revisit and revamp their refrigerant management initiatives to address required practices, documentation methods, electronic recordkeeping and reporting. Facilities and contractors will need to communicate more quickly and with more detail to address leaking systems and appliance disposals. If your contractor isn’t a good “compliance partner” with good documentation and communication, then it might be time for a change. With fines at $37,500 per day per violation and supplemental environmental projects costing millions of dollars, the risk is too great. And don’t we want to save the planet?
Mark Harbin has been helping clients implement refrigerant compliance initiatives since 2000. His 15-year career in commercial HVAC prior to that served as the foundation for environmental consulting. As a Certified Environmental Auditor, he has been instrumental in the assessment and support of organizations’ refrigerant compliance initiatives, providing solutions at hundreds of clients’ locations across the world with a variety of services including but not limited to compliance analysis, project management, EPA technician certification, management training and certification, and software implementation services.
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About Sphera For more than 30 years, Sphera has been committed to creating a safer, more sustainable and productive world by advancing operational excellence. Sphera is the largest global provider of Operational Excellence software and information services with a focus on Environmental Health & Safety (EH&S), Operational Risk and Product Stewardship. The Chicago-based company serves more than 2,500 customers and over 1 million individual users across 70 countries. Sphera is a portfolio company of Genstar Capital, a leading middle-market private equity firm focused on the software, industrial technology, financial services and healthcare industries.
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