Refrigerant Management for the 21st Century Written by Mark Harbin Abstract

This article is the latest in a series of updates on management challenges facing facility owners, man- agers, and environmental professionals. In the current business climate, nearly every business is being impacted by issues like refrigerant phase-outs or rising prices that can directly affect your refrigerant management program.

Is Your Program Stuck in a 90’s-Era CFC-Mode? Refrigerant management is re-emerging as a pivotal issue for organizations because of the ever-changing regulatory landscape around greenhouse gas emis- sions. Failure to properly address these challenges could expose your company to risks and operational costs that could reach all the way to the bottom line.

In addition, businesses are being asked to publicly disclose performance for all environmental-related concerns, including refrigerant management. For instance, the U.S. Securities and Exchange Com- Your Refrigerant Management mission (SEC) now recognizes that is Program Needs Updating If: a material concern and that publicly traded compa- nies should disclose related risks.1, 2 • You do not know how many HFC systems you own and their full operating charge These challenges are becoming urgent concerns for facility managers because they impact the cost and • You cannot quantify the refrigerant used/leaked availability of . Along with broader con- by HFC systems. cerns about environmental, health, safety (EHS) and sustainability issues, companies now regard refriger- • The last time your technicians had refrigerant ant management as a key operational concern at all compliance training was when they were EPA levels of the organization. certified.

Previously, refrigerant management was regarded as • Your technicians have not been trained and a facility level compliance concern. Today air condi- provided tools for safe use and handling of the tioning and refrigeration programs now affect many high-pressure R-22 substitute, R-410a. other areas—including EHS, IT, finance, risk man- agement and more. All levels of the organization are • You cannot readily produce records for all refrig- affected: CEOs to technicians, board erant purchases, usage, disposal, and inventory room to the back shop, and purchasing managers to on hand. contractors. • Your policies and procedures only reference CFCs Because of the rapidly changing regulatory and and HCFCs, but not HFCs or flammable refriger- market landscape, organizations of all sizes urgently ants need effective refrigerant programs to control risks and costs. In order to meet those objectives, facility • You do not have any written refrigerant policies or owners and managers need the capability to closely procedures monitor and manage refrigerant-related information, with key performance indicators to proactively identify • You maintain records on paper or in spread- and fix problems before they affect operations. sheets

2 3 Ozone Protection Rules: Refrigerant Costs and Responsibilities During the past few years, prices for all refrigerants Refrigerant Phase-outs have steadily climbed, with the new wholesale price point per pound resolutely pushing past the $10 and New Refrigerants mark.

Step-by-step, 197 nations have made progress Refrigerants are assets that are both valuable and toward their goals of reducing stratospheric ozone dangerous. In order to prevent market fluctuations depletion, in part because of global treaties, including from harming an organization’s bottom line, compa- the U.N. , which eliminated the use nies must exercise tighter tracking and management of CFC and HCFC refrigerants and the 2016 Kigali re- of refrigerant supplies than ever before. Detailed re- visions for the use of HFC refrigerants that have high cords should be accessible from automated systems global warming potential (GWP). for all refrigerant purchases, inventory, usage, and disposal.

Regulations Drive Phaseout of R-22 In addition, how refrigerants are stored can affect Effective January 1, 2010, the Montreal Protocol inventory control. Industry best practices call for re- treaty and resultant amendments to the U.S. Clean frigerant supplies to be locked with limited access to Air Act, and Environmental Protection Agency (EPA) inventory storage areas. They should be well ventilat- regulations prohibited the sale or manufacture of ed, weather-protected areas. Flammable refrigerants R-22 air conditioning or refrigeration systems in should be kept separate from non-flammable refriger- the United States.3 ants per the NFPA. These efforts will help reduce risk to workers and to the organization. As of 2020, service providers are prohibited from producing or importing virgin R-22 gas for servicing Climate Change Rules Focused existing HVAC equipment. Reclaimed R-22 supplies on GHGs have proven sufficient to meet demand with no sud- den price fluctuations affecting service providers and On April 17, 2009, the EPA ruled that greenhouse facility owners. gases, GHGs, pose a significant threat to public health, and as of September 30, 2011, the agency Many facilities may be evaluating their refrigerant required organizations to comply with its GHG Manda- usage and wonder whether onsite or third-party recla- tory Reporting Rule (MRR) that affects approximately mation will work for them. 10,000 facilities that are believed to be responsible for 85 percent of GHG emissions nationwide. Under Challenges have arisen for some facilities, though, GHG MRR, companies are required to report their because they have difficulty obtaining reliable data for inventory of these GHG emissions:5 refrigerant usage, recovery, disposal, and inventories. In fact, dated or non-existent record keeping systems • Carbon dioxide (CO2) have hampered the good intentions of numerous • Methane (CH4) facility and environmental managers. That’s why more • Nitrogen Oxide (N2O) organizations are implementing best practices for • Sulfur hexafluoride (SF6) refrigerant management, including implementation of • Hydrofluorocarbons (HFCs) electronic record keeping systems that can empower • Perfluorochemicals (PFCs) facility and environmental managers to identify and • Other fluorinated gases, such as nitrogen mitigate problems before significant risks and costs trifluoride and hydrofluorinated ethers (HFEs) are incurred.

4 California Global Warming Solutions Act of 2006

Even as EPA implemented reporting requirements for GHGs, some U.S. states implemented their own GHG rules for regulating HFC refrigerants.

The most prominent state regulation for lower- GWP stationary refrigerants is a provision of the California Global Warming Solutions Act of 2006 (AB 32), which requires organizations to fix leaks within 14 days of detection, and upload annual reports to the state with records for all leak repairs, leak inspections, and Because CO2 is non-flammable, plentiful, and so low other servicing of commercial/industrial refrigeration on the relative GWP scale at 1.0, CO2 (R-744) refrig- systems, including receipts of refrigerant purchases. eration systems have been rapidly expanding. Carrier Systems that use ammonia or carbon dioxide as Corporation and Ingersoll Rand/Trane has installed refrigerants are not subject to the rule. CO2 refrigeration systems in hundreds of grocery stores and industrial applications in Europe and the Often, these kinds of requirements may be an indica- US. Johnson Controls markets a CO2/ Ammonia tionof what is to come from other jurisdictions. Some freeze package. fear a patchwork of varying regulations from state to state leading to confusion and inconsistencies, and Appliance manufacturers have shifted to freezers and ultimately non-compliance. refrigerators that use low GWP hydrocarbons such as propane or isobutane as a refrigerant. For exam- European Union ple, General Electric and Ben and Jerry’s Ice Cream announced they would team up to develop a greener freezer concept around hydrocarbon refrigerators and European Union F-Gas regulations are designed to 8 minimize emissions by phasing out fluorinated refrig- ice cream coolers for U.S. markets. The leading ice erants, F-gases, replacing them with low-GWP and cream maker has implemented hydrocarbon coolers natural refrigerants. that use propane and butane to chill food. Propane (R-290) has a GWP of 3, no ODP, and is already wide- EU leak repair and leak inspection requirements for ly used in Europe and Australia, and now the US. HFC refrigerants affect contractors and equipment owners alike.

EU regulations require the elimination of ozone de- pleting refrigerants in systems through enforcement of usage bans. For example, if a system leaks its HCFC-22 refrigerant charge, it is illegal to refill that system with HCFC-22 or any other ozone- depleting refrigerant. That system must be converted to a sub- stitute refrigerant or be replaced with a new system (which might contain an HFE or even a flammable hydrocarbon.)

5 Is Your System Up to The Challenge? There are a wide variety of automated tools, ranging from basic desktop, stand-alone systems to globally deployed, web-based powerhouses that support efficient carbon emission management. Certain key functions are a must for organizations seeking to fully monitor, optimize, and demonstrate their refrigerant conservation initiatives.

Can your system

• Standardize data capture methods with service work orders to become the entry point for environmental record keeping?

• Provide automatic alerts when a leak occurs, so users can respond promptly to fix a leak before noncompliance occurs?

• Track conservation activities like refrigerant recovered/recycled from systems (not vented to the atmosphere)?

• Account for legal losses to the atmosphere, which are associated with trace charges of refrigerant used for leak detection and repair verification?

• Identify and document conversion of systems to less harmful refrigerants?

• Account for replacement or retirement of obsolete systems?

• Document transition to “greener” systems using less energy and low GWP refrigerants?

• Provide precise cradle-to-grave monitoring of refrigerant inventories for accurate purchase and disposal?

• Record accidental releases due to human error or natural disaster?

• Document sustainability in all ways, including migration to environmentally friendly refrigerants, and through conversion, replacement, or retirement of systems?

6 7 of refrigerants, while simultaneously managing other Effective Refrigerant Management environmental concerns, including GHG and energy Requires Information Management management, as part of a broader enterprise sustain- Support ability management strategy that assures visibility throughout the organization. Spreadsheets and manual recordkeeping process- es don’t have the capability to help organizations keep track of the rising tide of new, complicated regulations. In today’s business environment, facil- ity and environmental managers must be prepared to produce their refrigerant data to a wide array of stakeholders—regulators, investors, local advocacy groups, and even your organization’s leadership—all of whom are demanding information about refrigerant emissions.

Facility and environmental managers need the capa- bility to produce - sometimes on short notice - compli- ance data, including:

• refrigerant purchases and disposals • specific dates for leaks and repairs • follow up repair verification tests, dates, methods • leak inspections, dates, methods • complete inventories refrigerants and appliances • service records for all large systems for the last three years (or perhaps five years if your facility has a Title V air permit)

Timing is critical. A Section 114A letter from EPA al- lows 30 days for a facility to provide detailed records on the items noted above. Delay or failure to meet this demand could leave your organization vulnerable to costly regulatory penalties that could also damage your organization’s hard-earned brand reputation.

Today’s organizations need support from automated information management systems to help them meet that standard and support best practices for effective refrigerant management. Best practices for today’s re- frigerant professionals include adopting systems that help them streamline management of government regulated refrigerant inventory from purchase through usage and final disposal. For larger organizations, these systems can provide efficient management

8 New Regulations Raise the Bar and Uncertainty

Regardless of how emissions regulations and refrig- erant markets evolve, one thing is for certain: HFC refrigerants are now a big part of the vocabulary for facility owners and managers and HVAC contractors.

Changing the focus of HFC refrigerants from a rela- tively unregulated status to one of the most regulat- ed refrigerant types is a big shift for most facilities. HFCs have been the refuge refrigerant from EPA’s strict CFC regulations, with many facilities converting whole fleets of to HFCs–either as a pro-active measure, a corporate directive, or as a supplemen- tal environmental project mandated under an EPA enforcement action.

This seems contradictory to the Clean Air Act prohibi- tion on venting substitute refrigerants which states, “Section 608 prohibits individuals from intentionally venting ODS [ozone-depleting substance] refrigerants (including CFCs [chlorofluorocarbons] and HCFCs [hy- drochlorofluorocarbons]) and their substitutes (such as HFCs), while maintaining, servicing, repairing or disposing of air conditioning or refrigeration equip- In 2016 EPA recordkeeping requirements incorpo- ment.” rated HFC refrigerants, beyond the restriction on intentional venting. As of 2019 leak rate thresholds Adding HFC refrigerant to a system, other than for were tightened from 15 to 10 percent for Comfort design changes or initial startup, constitutes a leak. Cooling systems with 50 or more pounds. Commercial Refrigerant charges in systems are fixed quantities Refrigeration went from 35 to 20 percent. Industrial and if additional refrigerant is needed, it is because Process Refrigeration went from 35 to 30 percent. of loss through leaks, which need repair to stop the This applied to HFC systems as well. (8) leaking. Otherwise, refrigerant added to the systems will eventually leak out. Leaks don’t get better, and That is, until February 26, 2020 when EPA an- they don’t repair themselves. If technicians keep nounced they would rescind the leak repair, inspec- adding refrigerant to a system, is that not, in effect, tion, and reporting requirements for HFCs effective intentionally venting? April 10, 2020.

9 Why So Serious?

• Could owners and managers who instruct technicians to continually add refrigerant to leaking systems—in- structing them to vent refrigerant—be held criminally liable and culpable?

• Adding refrigerant to leaking systems is expensive. Refrigerant can cost anywhere from $10 to $100 per pound.

• Leaking systems use more energy. Studies have shown that for every 1% of refrigerant charge missing, the system uses 1% more energy.

• Leaking systems fail sooner than nonleaking ones. Capital budgets count on 20 years of useful life instead of 12 years.

• Leaking systems don’t perform to specification, which can lead to product defects, perishables perishing, comfort cooling not adding comfort, deteriorating and electronics overheating and failing.

• Leaking systems are dangerous. Exposure to refrigerant vapors can cause asphyxiation, heart arrhythmia, frostbite and even brain damage. Technicians and building occupants could be at significant risk.

• The majority of systems installed in the United States and abroad contain HFC refrigerants. New systems sold in the U.S. contain HFCs with some low global warming potential refrigerant choices becoming avail- able, like hydrofluoroolefin and hydrofluoroether refrigerants, but where is the incentive to transition to them when companies are allowed to run leaky HFC systems?

• The International Organization for Standardization (ISO) requires environmental and safety compliance in accordance with international treaties to allow companies to trade internationally. If U.S. companies are venting HFCs and European Union companies are not, isn’t there a commercial disadvantage where compa- nies skirt repairs, regulations and treaty obligations? Could this lead to a reduction in international demand for U.S. products?

• Which treaty? The Montreal Protocol was updated and approved in 2016 by all signatory nations, including the United States. The 2016 Kigali Amendment included commitments to reduce emissions of HFCs and phase down use in new systems in the coming years. The Montreal Protocol is legally binding with mandato- ry targets for countries.

• HFC refrigerants are among the most potent greenhouse gases with high global warming potentials that are

hundreds to thousands of times more potent than CO2 or methane. One pound of R‑404A from a freezer is

comparable to almost 4000 pounds of CO2. Fixing leaks is one of the easiest ways to address global warm- ing and climate change.

• European-owned facilities in the United States follow EPA regulations. But if those regulations allow leaking HFC refrigerants, isn’t that contradictory to EU F‑Gas refrigerant regulations?

10 Summary

In the face of regulatory uncertainty and disruption, organizations need to revisit, revamp, and expand their refrigerant management initiatives, practices, and improve record keeping systems. They need to address increasing cost of operations and offset refrigerant costs related to the changing landscape of climate change regulations. CFC- and HCFC-focused programs from the 90’s era regulations need an overhaul to encompass HFC refrigerants, which are now widely in use.

Rising operating costs related to air conditioning and refrigeration – including energy, refrigerants, labor, and materials – may soon compel organizations to evaluate their operations for areas of potential improvement. Im- plementing automated record keeping systems and proactive compliance practices can help reduce the effect of climate change on your operations.

Facility owners, environmental and facility managers, and contractors have the methods and tools within their grasp to make a change for the better. Organizations that are motivated to broaden their sustainability programs to encompass refrigerants will help reduce their carbon footprint, as well as reduce risk and reduce operating costs related to energy and cost of operation.

Ultimately, this leads to a safer, more sustainable, and productive world.

References About the Author

• 1. Broder, John M. “S.E.C. Adds Climate Risk MARK HARBIN, CEA has more than 35 years of to Disclosure List.” The New York Times. 27 experience in commercial and industrial environ- Jan. 2010 mental systems. As Director of Refrigerant Com- pliance Software and Services, and a Certified En- • 2. Environmental Leader “SEC: Publicly Trad- vironmental Auditor (CEA), he is actively involved ed Firms Must Disclose Risks from Climate in assisting clients in meeting their operational Change.”.28 Jan. 2010 and environmental goals. • 3. “Environment News Service, “Climate Ac- tion Under Ozone Treaty on Hold for Copenha- Mark was also a licensed HVAC contractor who gen Deal.11 Nov. 2009 has participated in numerous energy and mod- ernization retrofit projects, CFC contain- • 5. “EPA Finalizes the Nation’s First Green- ment/conversions, and refrigerant reclamation house Gas Reporting System/Monitoring to services. He is experienced in EPA Clean Air begin in 2010.” Environmental Protection Act Title VI, Section 608 and 609 refrigerant Agency. 22 Sep. 2009 regulation compliance, DOT refrigerant cylinder • 6. California Environmental Protection Agen- safety requirements, ASHRAE Standard 15 for cy, Refrigerant Management Program safety and design, and OSHA https://ww3.arb.ca.gov/cc/rmp/rmprule.htm safety standards for HVAC technicians. He can be • 8. https://www.epa.gov/section608/ reached at [email protected] revised-section-608-refrigerant-manage- ment-regulations

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