FMJ - May/June 2017

Environmental Stewardship & Refrigerant Legislation

Brian S. Smith 2017-05-12 04:00:39

The last few years have seen a whirlwind of activity around environmental regulations and efforts to mitigate the emission of greenhouse gases (GHGs). When focusing on a facility’s role in reducing net emissions, the energy efficiency of heating, ventilation, air conditioning and refrigeration (HVACR) equipment plays a significant role. The global warming potential (GWP) of refrigerants used in HVACR equipment is considerably less impactful. In fact, changing to refrigerants with lower GWP could have unintended detrimental consequences. Where only low GWP options are flammable, yield lower capacity or are less efficient, facilities are likely to incur higher first cost, operating costs, or both. THE RELATIONSHIP OF ENERGY, REFRIGERANTS AND THE ENVIRONMENT Compared to the ozone depletion issue, climate change is more challenging because of the variety and nature of GHG sources. Climate change involves sectors of the economy beyond the HVACR industry. According to the U.S. Environmental Protection Agency (EPA), burning fossil fuels to produce electricity is the largest source of carbon dioxide (CO2 ) emissions in the United States.1 Consequently, the most immediate and impactful way to reduce GHG emissions is to focus on improving energy efficiency. Energy efficiency is directly linked to reducing the demand for fossil fuels, and therefore, CO2 emissions, which can represent more than 95 percent of equipment net CO2 emissions. In fact, the contribution of energy consumption to the carbon footprint by a facility’s HVACR equipment can be more than twenty times greater than the refrigerant selected for use in that equipment. This huge difference indicates why the answer to climate change is so complicated. Eliminating the effect of refrigerant is negligible compared to reducing energy consumption by improving efficiency. Yet, there remains a fervor over the global warming potential of the refrigerant. So, what steps can or must be taken to reduce net CO2 emissions? KIGALI AGREEMENT TO THE MONTREAL PROTOCOL In 2016, 196 countries came together in what some observers consider the second most significant landmark agreement on the environment: The Kigali Amendment. It uses the structure of the 1987 Montreal Protocol, a treaty that phased-out chlorofluorocarbon (CFC) and hydrochlorofluorocarbons (HCFC) refrigerants to protect the ozone layer. At Kigali, the focus was on GHG reductions and climate change. Unlike the elimination of CFC and HCFC refrigerants, the Kigali Amendment targets a reduction in HFC refrigerants down to 15 percent of baseline over the next few decades. The 15 percent allows for continued use for servicing indefinitely. The baselines will be set in future years between 2020 through 2026 for developing countries depending on the group. For developed countries (e.g., the United States, Australia, Canada, the European block), the baseline is set on the average of 2011 through 2013, plus 15 percent of the 2011 to 2013 average of HCFCs. Note that this evaluation is done on net CO2 equivalence. This evaluation basis will likely affect higher-GWP refrigerants in applications (i.e. foam, propellants, transportation, refrigeration, solvents) that are more prone to leaks or are used directly in the atmosphere. PREEMPTIVE ACTIONS TO REDUCE CO2 EMISSIONS Some countries acted prior to the Kigali Amendment. These actions were significant in two ways: First, they provided leadership to urge other nations to act. Second, they provide examples of the different approaches that are likely to be taken by different countries in how they mitigate GHGs. Under the Kigali Amendment, each country is free to implement their measures to reduce CO2 emissions in a way best suited for their national interests and capabilities. While a global GHG agreement is important, there remain challenges with implementation due to where GHGs derive. The most commonly known and major contributors to climate change include CO2 , methane, nitrous oxide, industrial chemicals and hydrofluorocarbons, in that order. Of global sources adding to GHGs, CO2 contributes 84 percent. Figure 1 shows a breakdown of these gases.2 The challenges in reducing net GHGs are not as simple as eliminating ozone depleting substances. GHGs are linked to the world economies in electric power generation and in the world’s food supply in agriculture. In the United States, electric power generation represents the largest portion and is the main source of atmospheric CO2 .3 TWO-PRONGED APPROACH TO GHG REDUCTION IN EUROPE In 2014, the European Union passed stronger fluorinated gas (F-gas) regulations. This was a major step in addressing some higher-emitting applications, including commercial refrigeration and vending machines, and small charge systems. The next step is to address energy consumption through “eco-design,” which prescribes measures to lower energy consumption. F-gas actions include mobile air conditioning transitioning to mostly near-zero-GWP R-1234yf refrigerant and some to CO2 . This results in an early and significant drop in European CO2 equivalent emissions. The eco-design standards evaluate the net energy consumption, not just at design conditions, and prescribe minimum energy-efficiency limits by application. Refrigerants that yield lower energy efficiency draw more power, and hence, increased indirect CO2 emissions through electric power generation. While renewables have seen a tremendous surge in adoption as a percentage, they represent approximately 25 percent of the total power production; the balance of CO2 emissions is due to burning fossil fuels, such as coal.4 OBAMA ADMINISTRATION LEVERAGES EXECUTIVE ORDERS AND THE EPA TO TACKLE CLIMATE CHANGE In 2016, late in the Obama administration’s term, a number of significant actions began to address climate change in the power sector and the fluoro-chemical industry. The most significant actions affecting refrigerants were the Significant New Alternatives Program (SNAP) rules 20 and 21. Rule 20 restricted uses of HFCs in certain industrial sectors by date targeting automotive, foam and commercial refrigeration applications where refrigerant leakage or exposure to the atmosphere is higher. Rule 21 added a number of other sectors, including HFC chiller production in 2024. In all cases, the SNAP program does not affect refrigerant chemical production; it focuses on reducing the demand for it by limiting equipment production. Operation and servicing of existing equipment is not affected. Going forward, recent indicators from the Trump administration suggest a probable slowdown, if not a reversal, to some of the steps taken in the latter part of the Obama administration. And if recent proposals to cut EPA funding become reality, that slowdown is very likely. Only time will tell which direction this will go. FLAMMABILITY AND ITS CHALLENGES Regardless of how quickly the industry could shift to low-GWP refrigerants due to regulations, the available low-GWP options across the many sectors are limited with few-to-no non-flammable options for commercial applications. This is not a problem for industrial facilities, but is a real challenge for commercial buildings, contractors and owners that are not accustomed to using these types of refrigerants, that cannot afford the added safety considerations, or that are limited by building codes currently prohibiting the use of flammable refrigerants. Low pressure alternatives have non-flammable options available. Medium pressure applications have both nonflammable and flammable options, while high pressure alternatives to R-410A refrigerant are all flammable. R-410A is the leading choice for rotary and scroll compressors used in residential and commercial systems. These applications include systems with direct expansion coils in the conditioned air stream or which could be applied in poorly ventilated areas that could allow an unsafe concentration of the refrigerant to collect in the event of a leak. Safety standards such as the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 15, and its equivalents in other regions, are in various stages of revision to reflect safe ways to apply some of the new refrigerants. We are likely to see special considerations, and possible limitations on the use of flammable refrigerants in some applications. Perhaps the greatest challenge lies not specifically in the design, manufacture or application of the equipment, but in the overall safety standard and building code revision and adoption. While the standards and codes may be revised, historically, the adoption of these standards into local building codes lags their creation. A tabulation of building code status as of 2016 shows more than 85 percent of the states were referencing building codes that were four years or older. The current cycle of revision is underway, and in order to permit the use of some flammable refrigerants, building code adoption of the new texts would need to occur at an unprecedented pace. SAFEGUARDING INVESTMENTS TO ADDRESS UNCERTAINTY HVACR equipment manufacturers are working diligently to come up with the next generation of products using the new low-GWP refrigerants. Products are slowly coming to market, mostly based on existing technologies unoptimized for the new fluids — fluids that are significantly higher cost than today’s refrigerants. With little economic incentive for building owners to transition, the demand for the new refrigerants remains low, despite a high degree of media buzz. The good news is, unlike ozone depletion where near drop-in alternatives for R-22 and R-123 were non-existent and remain to this day, the performance of multiple fluids with similar properties to R-134a and R-410A are becoming more available. This provides more options for future changeover should availability or cost become an issue. Today and for the foreseeable future, economics for commercial applications favor HFC refrigerants, such as R-410A and R-134a. But with low-GWP-refrigerant alternatives to R-134a — like R-450A and R-513A — the future of an R-134a unit today can be protected against obsolescence or significantly reduced capacity. For R-410A, alternatives are not as straightforward due to flammability. Nevertheless, the low-GWP options are attractive from an efficiency and/or capacity standpoint. A COMPLEX BUT SOLVABLE CHALLENGE Within the HVACR industry, the use of refrigerants is just one small part of the greenhouse gas equation. The search for low-GWP refrigerants must strike the right balance of other factors including safety, reliability, availability, affordability and performance. That performance is critical in terms of the environmental view. The good news is that there is time, and governments are considering the needs of end users for reliable, safe and cost-effective solutions. Establishing the ground rules and direction allows investment and innovation to move in an orderly fashion. A smooth transition benefits all stakeholders concerned about capital investments, operating costs and the environment. REFERENCES 1) U.S. EPA. March 20, 2017. 2) U.S. EPA. Global Mitigation of Non-CO2 Greenhouse Gases: 2010-2030, EPA-430-R-13-011. September 2013. Page 1. 3) U.S. EPA. Overview of Greenhouse Gases. March 23, 2017. 4) European Commissions, Eurostat website. July 2016. BRIAN SMITH is director of global marketing for Johnson Controls Corporation. He has spent the past 20 years working for York International/Johnson Controls organizations in various technical and leadership positions in the USA and China, ranging from applications engineering, product management, industrial engineering, product development, project and program management, strategy, business development and marketing. Smith has a Bachelor of Science in engineering science and mechanics from Penn State University, and a Master of Business Administration in management from Eastern University. His involvement in the refrigerant industry includes writing and editing articles in various media, and leading the development of refrigerant strategy. He has attended workshops and symposiums on refrigerants in the United States, Japan and China, including the U.S. EPA, the U.S. Department of Energy, ASHRAE, the United Nations Environmental Program, and the Japan Refrigeration and Air Conditioning Industry Association.

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