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call (630) 775-2063 this leading-edge knowledge is brought to you by web thecampbellinstitute.org the campbell institute email [email protected] 1012 900001825 ©2012 national safety council Refrigerant Management for the 21st Century Is Your Program Stuck in a 90’s-era CFC-mode?
This article is the latest in a series of updates on refrigerant management challenges facing facility owners, managers, and environmental professionals. In the current era of refrigerant phase-outs, rising prices, and regulatory expansion due to climate change virtually every organization across the globe has been affected.
Evolving from a stratospheric ozone depletion focus, refrigerant management is re-emerging as a pivotal issue for organizations due in large part to expanding awareness and action for global climate change legislation. Indeed, it was recently reported that the An IHS White Paper by SEC said public companies should disclose to investors the risk, or Mark Harbin, CEA rewards, related to climate change.
Forward-looking organizations implementing sustainability strategies are including refrigerant management as an area of focus. However, many have found large gaps in their CFC-centric record keeping systems and practices that don’t encompass the ozone-safe, yet global warming HFC refrigerants.
The need for refrigerant-related critical information and key performance indicators has never been higher. Many areas overlap when it comes to air conditioning and refrigeration systems: Energy, Environment, Safety, Finance – Capital and Operating budgets, and Risk. All levels in the organization are affected: CEOs to AC technicians, Board Room to the back shop, and Purchasing to Contractors. Act amendments, no new R-22 air conditioning How to tell if your refrigerant management or refrigeration systems may be manufactured program needs updating: or sold in the US. Existing inventories of • If you do not know how many HFC refrigeration 2009-manufactured systems may be sold. systems you own and their full operating charge.
• You cannot quantify the refrigerant used/leaked by B. R-22 shortages predicted, cost increases HFC systems. expected • If the last time your technicians had refrigerant DuPont announced in January 2009 that compliance training was when they were EPA shortfalls in R-22 supplies, related to EPA certified. allocation rulings, should be expected in 2010. They encouraged facilities to avoid potential • If your technicians have not been trained and provided tools for safe use and handling of the high negative impact to their operations and intensify pressure R-22 substitute, R-410a efforts to conserve R-22 supplies through reclamation of used refrigerant and retrofitting • You cannot readily produce records for all refrigerant systems to newer, more plentiful alternative purchases, usage, disposal, and inventory on hand. refrigerants. • If your policies and procedures only reference CFCs and HCFCs, but not HFCs Thomas Pickrell, Facilities Manager for Clark • If you do not have any written refrigerant policies or County Government in Las Vegas, Nevada, procedures knows all to well, from his experience with the
• If your record keeping methods are only paper- CFC shortages of the 90’s. “We’re not going based or spreadsheet to get caught in any refrigerant shortages with our proactive program”, Pickrell stated. Using historical data, such as, frequent repairs and Stratospheric Ozone Rules just the refrigerant leaks, Clark County has initiated a beginning…but not being expanded to program to eliminate HCFC’s from it’s inventory. cover the HFC refrigerants By retrofitting or removal of HCFC equipment, In November of 2009, the meeting of delegates “It will save Clark County money in man of countries signatory to the Montreal Protocol hours, repair costs, refrigerant cost and most yielded no expansion of the current ozone- importantly, energy.” depleting substance (ODS) focus to cover greenhouse gas (GHG) concerns for non- Despite conservation efforts such as leak ODS refrigerants, like HFCs. The consensus detection and repair, recycling and reclamation, appeared to be one of waiting for the R-22 prices have continued to skyrocket and December 2009 United Nations climate change many facilities are starting to stockpile reserves meetings in Copenhagen and for the Kyoto and buy while prices are “low”. Protocol’s 2012 renegotiation, which already has provisions that address HFCs. Some facilities like Beale Air Force Base near Sacramento, California have implemented site- A. Phase outs of R-22 in new equipment based reclamation for their used R-22, saving Starting January 1, 2010, as part of the thousands of dollars in avoided new purchases. Montreal Protocol treaty and US EPA Clean Air Many facilities are starting to evaluate their Under the Mandatory Greenhouse Gas Report own refrigerant usage and whether reclamation Rule, reports must include applicable emissions will work for them. Challenges have arisen for of these GHGs: some facilities, though, on obtaining reliable data for refrigerant usage, recovery, disposal, • Carbon dioxide (CO2) and inventories. Dated or non-existent • Methane (CH ) record keeping systems have hampered 4 the good intentions of numerous facility and • Nitrogen Oxide (N2O) environmental managers. • Sulfur hexafluoride (SF6) C. Refrigerant cost increases • Hydrofluorocarbons (HFCs) Prices for all refrigerants have been steadily • Perfluorochemicals (PFCs) climbing over the last few years, with the new wholesale price point per pound resolutely • Other fluorinated gases, such as nitrogen pushing for the $10 mark. In November of trifluoride and hydrofluorinated ethers (HFEs) 2009 DuPont announced a 10% price increase for R-134a for all applications including Local, Federal, and International focus automobile and stationary air conditioning. The Even as the US EPA enacts reporting cost of raw materials had increased. requirements for GHGs, multiple states in the US have begun drafting their own GHG rules, with Costly refrigerants are valuable assets for HFC refrigerants being included. organizations and demand tighter tracking than ever before. Detailed records should be In October 2007, the California Air Resources accessible from automated systems for all Board implemented an agenda for public refrigerant purchases, inventory, usage, and workshop meetings to begin addressing high- disposal. GWP refrigerants in stationary sources. When completed, California Global Warming Solutions How refrigerants are stored can also affect Act of 2006 (AB 32) will establish registration, inventory control. Locked and limited access record keeping, and reporting requirements for to inventory storage areas is best. They should most major facilities in the state. be well-ventilated, weather-protected areas. These efforts will help reduce losses related to California has led in the adoption of aggressive pilfering or cylinder damage due to weather or regulatory requirements to address climate accidents. change. Often, these requirements may be an indication of what is to come in other jurisdictions. New US Climate Change rules focused on key GHGs including HFC refrigerants European Union On April 17, 2009 the US EPA ruled that European Union Environmental Commission (EC) greenhouse gases endanger public health regulations are designed to minimize emissions and that starting January 1, 2010 reporting by phasing out HFC refrigerants, or F-gases, requirement will affect approximately 10,000 replacing them with low-GWP refrigerants. facilities that are responsible for 85 percent of Starting in 2011, new mobile automobile air GHG emissions in the US. conditioning (MAC) systems will be required or any other ozone-depleting refrigerant. That to use low-GWP refrigerants. One candidate system must be converted to an HFC substitute is known as HFO-1234yf, which was co- refrigerant, or be replaced by a new HFC-based developed by DuPont and Honeywell for system. Europe’s MAC directives. It has a GWP of 4, or four times the heat-trapping ability of CO2. Closer to home Hill PHOENIX, a refrigeration system manufacturer
Because CO2 is so plentiful and so low on the in Conyers, Georgia recently won US EPA SNAP relative GWP scale of refrigerants, CO2 (R-744) (Significant New Alternatives Program) approval refrigeration systems and refrigerant blends for its CO2 refrigeration systems, to replace HCFC that use CO2 as the main component for refrigerants in its systems. In September of 2009, cooling are being introduced worldwide. the company announced installations at two Food
Lion stores. According to Hill PHOENIX, the CO2 Carrier Corporation recently announced the systems have less leakage and when used as a 100th grocery store in Europe to have their secondary refrigerant can enable HCFC system charges to be reduced 60 to 90 percent. CO2 refrigeration systems installed. Johnson
Controls markets a CO2/Ammonia freeze package. Additionally, Visteon and German Food Lion of North Carolina, though now with automakers have committed to a full-scale Brussels Belgium owners, is aiming for Energy implementation of CO2-based R-744 by 2011. Star status for its stores and is one of the largest partners of the EPA Green Chill program – which Leak detection and leak repair requirements encourages energy efficiency and emission are already in place for HFC refrigerants and reductions from store chillers. affect contractors and equipment owners alike. Environmental Commission regulations for Large appliance manufacturers are promoting EU countries require the elimination of ozone- freezers and refrigerators in the US to use low depleting refrigerants in systems through GWP hydrocarbons such as propane or butane enforcement of usage bans. For example, if a as a refrigerant. In September of 2009, GE and system leaks its HCFC-22 refrigerant charge, Ben and Jerry’s Ice Cream announced they would it is illegal to refill that system with HCFC-22 team up to develop hydrocarbon refrigerators and ice cream coolers. Propane (R-290) has a GWP of 3, no ODP, and is already widely used in Europe and Australia.
Kyoto Protocol to be renegotiated The 193-nation UN Copenhagen ODP vs. GWP for refrigerants meetings have recently been finalized materials with the US, China, Brazil, and India each Figure 1 pledging to curb GHG emissions in an historic shift toward global cooperation to affect greenhouse gases related to climate change. How to tell if your system is up to the Challenge: In addition, with this landmark agreement, There are a wide variety of automated tools, developing nations will receive significant ranging from basic desktop, stand-alone funding from industrial nations to implement systems to globally deployed, web-based clean-energy and low-GHG technologies. powerhouses that support efficient carbon emission management. Regardless of the Even though non-binding, the emissions platform, certain key functions are a must for reductions pledged by the accord still organizations seeking to fully monitor, optimize, require each country to establish monitoring, and demonstrate their refrigerant conservation reporting, and reduction regulations. In the initiatives. US, EPA’s recently established GHG reporting requirements may have to be expanded and Can your system: defined for each GHG category, perhaps to • Standardize data capture methods with service work included emissions caps, with pollution credits orders to become the entry point for environmental being traded in the emerging “cap and trade” record keeping? markets. • Provide automatic alerts when a leak occurs, so users can respond promptly to fix the leak before Dated refrigerant tracking methods won’t do noncompliance occurs?
Regardless of how the emissions caps and • Track conservation activities like refrigerant markets evolve, one thing is for certain. recovered/recycled from systems (not vented to the HFC refrigerants are now a big part of the atmosphere)? vocabulary for facility owners and managers, • Account for legal de minimis losses to the atmosphere, and even HVAC contractors. which are associated with trace charges of refrigerant used for leak detection and repair verification? Changing the focus of HFC refrigerants • Identify and document conversion of systems to less from a relatively un-regulated status to one harmful refrigerants? of the most regulated refrigerant types is a big shift for most facilities. HFCs have been • Account for replacement or retirement of obsolete systems? the refuge refrigerant from EPA’s strict CFC regulations, with many facilities converting • Document transition to “greener” systems using less whole fleets of chillers to HFCs – either as a energy and low GWP refrigerants? pro-active measure, or more commonly, as a • Provide precise cradle-to-grave monitoring of supplemental environmental project mandated refrigerant inventories for accurate purchase and under an EPA enforcement action. disposal?
• Record accidental releases due to human error or To date, US EPA record keeping requirements natural disaster? have ignored HFC refrigerants with the only real requirement being to not intentionally • Document sustainability in all ways, including migration to environmentally friendly refrigerants, and through conversion, replacement, or retirement of systems? vent them. Under the current regulations no or all new Kyoto-style HFC regulations are leak rate thresholds (15% or 35%) apply to implemented, many facilities are unprepared to HFC systems, no 30-day repair requirement track leak events or provide the detailed records exists, and service records do not have to be that EPA requires. Log books and spreadsheets retained at all. In the US, countless tons of provide little evidence to inspectors as to the level HFC refrigerants have been added to leaking of compliance with required practices. A modern systems without any leak repair – legally – facility requires automated tracking methods to under the current regulations. be able to retain the required records and readily produce specific reports for given time periods. For many facility managers and owners who Information must be available on short notice breathed a sigh of relief at the relatively low and could include things like dates of refrigerant level of regulatory scrutiny for HFC refrigerants, purchases and disposals, specific dates for leaks those days appear to be numbered. and repairs on large cooling systems, follow up Whether the Montreal Protocol-based CFC repair verification tests, or complete inventories regulations are extended to cover HFCs, and service records for all large systems for the last three years. Or perhaps five years if your How IT solutions for refrigerant facility has a Title V air permit. A Section 114 letter management programs succeed: from EPA allows 30 days for a facility to provide detailed records on the items noted above. In these cases and others, IT solutions play an important role in weaving compliance into daily Not all doom and gloom operations, helping to achieve cost savings as compared to manual or ad-hoc approaches. Heightened compliance requirements do not necessarily mean heightened costs. In fact, the • Alcoa operations at a Tennessee facility report expansion of conservation and containment facility-level savings of more than $160,000 per year requirements can lead to improved energy as a result of reducing third-party inspections and efficiency and reduced cost of operation - the faster discovery of equipment reliability issues. intent of the EPA Green Chill program for grocery • Campbell Soup at the Napoleon, Ohio facility stores. reports having shortened EPA inspection times from days to less than one hour at the 65-acre food Reducing refrigerant emissions (leaks) by checking manufacturing site. for leaks on a more frequent basis can provide a • Volvo reduced water usage by 10 million gallons a year, significant return on investment. along with air emissions and the associated costs.
• DAK Americas transformed their leak detection and repair (LDAR) program from a compliance cost Cost Avoidance: center into a new profit center. • Refrigerants - fewer leaks means reduced refrigerant costs • Cardinal Glass and Hunter Douglass each cut worker’s compensation costs by over 50% with • Energy – leaking systems cost more to run support from automated data management solutions. • Repairs Rising operating costs related to air conditioning ºº Leaking systems fail more often than and refrigeration – energy, refrigerants, labor, and “tight” systems materials – oblige organizations to evaluate their operations for areas to improve. Implementing ºº Labor and materials automated record keeping systems and proactive ºº Downtime/Lost Production/QC/Spoilage compliance practices can help reduce global • Indoor Air Quality – leaking systems do not warming. dehumidify Facility owners and managers have the methods Summary and tools within their grasp to begin making a Organizations need to revisit, revamp, and change for the better. Organizations that are expand their refrigerant management initiatives, motivated to broaden sustainability programs practices, and record keeping systems to to encompass refrigerants will help reduce their address climate change. CFC- and HCFC- carbon footprint, and costs, related to energy focused programs from the 90’s era regulations and cost of operation. are in need of an overhaul to encompass HFC refrigerants, which are widely in use.
Global climate change initiatives such as the Kyoto Protocol are being boosted by recent participation of the US, India, and China. HFC refrigerants with high GWP are being targeted for phase out in European markets while the US is still transitioning to HFCs.
References
I. Broder, John M. “S.E.C. Adds Climate Risk to Disclosure List.” The New York Times. 27 Jan. 2010
II. “Climate Action Under Ozone Treaty on Hold for Copenhagen Deal” Environment News Service. 11 Nov. 2009
III. “EPA Finalizes the Nation’s First Greenhouse Gas Reporting System/Monitoring to begin in 2010.” Environmental Protection Agency. 22 Sep. 2009
IV. “Mandatory GHG Reporting: What You Need to Know Now.” Enviro.BLR.com. 11 Nov. 2009
V. “SEC: Publicly Traded Firms Must Disclose Risks from Climate Change.” Environmental Leader. 28 Jan. 2010
VI. Taylor, Pamela J. “DuPont Fluoroproducts Increases Price of HFC-134a.” 19 Nov. 2009
As a licensed HVAC contractor, Mark was involved in numerous energy and modernization retrofit projects, CFC chiller containment/conversions, and refrigerant reclamation services. He is experienced in EPA Clean Air Act Title VI, Section 608 and 609 refrigerant regulation compliance, DOT refrigerant cylinder safety requirements, ASHRAE Standard 15 for mechanical room safety and design, and OSHA safety standards for HVAC technicians. He can be reached at [email protected] or (480) 346-5527.
About IHS IHS has been in business for over 50 years, providing critical information and insight to governments and companies in a broad range of industries in 180 countries. IHS offers an integrated platform with powerful tools to help your business manage and communicate GHG data for products, supply chain and facilities from the plant floor to the boardroom. IHS software helps organizations to maintain total compliance with EPA regulations by accurately tracking refrigerant usage, leaks, and disposal. It enables organizations to support data collection and reporting for a verifiable carbon emissions inventory; enable strategy development with powerful business intelligence and analysis tools; and helps users execute carbon strategies with performance metrics, tasking and communications.
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