PREPARE FOR A SAFE REFRIGERANT TRANSITION BY STEPHEN YUREK AND JOHN GALYEN
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or the past 10 years, the HVACR industry in the United States has advocated for a global structure to phase down the use of high-global warming potential refrigerants, chief among them hydrofluorocarbons (HFCs). That effort culminated in 2016 with the Kigali Amendment to the Montreal Protocol. The phase down initiative was undertaken in part to bring order to what was a country-by-country, region-by-region approach to a refrigerant transition that had the potential to cause disruption in the global HVACR marketplace, raising manufacturing and distribution costs, causing confusion among consumers and stymying the ability of manufacturers, distributors and contractors to properly plan for the future. More than 90 nations having ratified the Amendment and it is now in effect around the world. The fact that the United States has not ratified the agreement, however, has created a policy vacuum that is being filled state-by-state, creating a domestic version of the very situation industry had tried to avoid with the global agreement. In the absence of a federal framework, a handful of states are pursuing their own HFC regulations, following SNAP Rules
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This state-by-state patchwork of regulations with various implementation timelines is creating challenges for equipment manufacturers that supply products not to individual states, but to a national market. 20 and 21, the EPA refrigerant regulations that were vacated by the DC Circuit Court of Appeals in Mexichem Fluor v. EPA on the grounds that EPA did not have Congressional authority to regulate non-ozone depleting refrigerants. This state-by-state patchwork of regulations with various implementation timelines is creating challenges for equipment manufacturers that supply products not to individual states, but to a national market. And given that many of the most promising new low-GWP refrigerants, compared to their HFC predecessors, have different flammability characteristics and require updated building codes, this transition must be managed in an orderly manner to prevent serious consequences for the manufacture-distribution-installation-consumer chain.
CALIFORNIA’S PROPOSED REGULATIONS The California Air Resources Board (CARB) is charged with developing
regulations to reduce HFC emissions 40 percent by 2030 compared to a 2013 baseline (SB 1383). Thus, California is writing HFC phasedown rules that go beyond those laid out in SNAP Rules 20 and 21 and at a pace even ahead of the Kigali phasedown schedule. In terms of the residential and light commercial AC market, CARB is currently proposing the following: • A ban on AC systems using refrigerant with GWP greater than 750 GWP by January 1, 2023. • A ban on servicing existing equipment with refrigerant with a GWP greater than 1,500 by January 1, 2022. o Potential exemptions for reclaimed refrigerants and R-410A remain an option. Bearing in mind that these are, at present, just proposals, for most stationary cooling applications, this may require the use of A2L (lower flammability) or A3 refrigerants (higher flammability).
FLAMMABLE REFRIGERANTS Flammable refrigerants are new to the U.S. air conditioning market — but not to the world. As categorized by ASHRAE, A2Ls are the class of low-GWP refrigerants expected to replace HFCs in many applications and while new to the U.S. market, A2Ls have been used safely in other parts of the world for years. Today, more than 8 million mini-split systems around the world are using the A2L refrigerant R-32 and 80 percent of new cars sold in the U.S. use A2Ls in their air conditioners. A3 refrigerants, such as R-290 (propane), on the other hand, are highly flammable and restrictions on their use are already included in U.S. and global safety standards. Some of the restrictions include: no more than 150g per refrigerant loop, no nearby sources of ignition and no use near points of egress. Some manufacturers of refrigerant equipment and small-charge room air conditioners have redesigned their products to safely use flammables by reducing refrigerant charge sizes and the potential for leaks. One manufacturer reports that 6,000 commercial propane ice machines are operating with no problems. A2Ls and A3s are new to the United continued on page 14
HVACR BUSINESS MAY 2020
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