Myths and Realities Re: New Refrigeration Rules

Last July, the Environmental Protection Agency (EPA) released a series of new rules prohibiting certain refrigerants because of their high global warming potential (GWP). The announcements, however, started a flurry of rumors, worries and myths in the foodservice community because of the confusion about which refrigerants would be banned and how that might affect existing equipment and future selections.

This article is meant to dispel some of those myths and clear up the confusion around which refrigerants are acceptable and which are slowly being phased out. There are several things operators can do — and do not have to do — before the new rules takes effect. We caught up with Scott Mitchell, J.D., P.E., senior engineer at the Technology Test Centers of Southern California Edison (SCE), for guidance.

Myth: The new EPA rules came out of the blue.

Reality: Under Section 612 of the Clean Air Act (CAA), EPA’s Significant New Alternatives Policy (SNAP) program has been evaluating various commercial refrigerants and making proposals and rulings about which are acceptable for different uses for the last 20 years, according to Mitchell.

Over that period, the EPA has been consistently researching and evolving the list of alternative refrigerants with less harmful impact on the environment. Previous actions tended to focus on high ozone depletion potential (ODP) refrigerants. The EPA has also stated that it is concerned about toxicity, flammability, occupational and consumer health/safety, local air quality and ecosystem effects. The EPA evaluates these factors when considering which refrigerant alternatives are acceptable. This past year, that focus has shifted to high GWP refrigerants.

“When refrigerants leak, they escape into the atmosphere, so the EPA has been looking at the global warming potential of these refrigerants,” says Mitchell. “Some of the commonly used ones can be up to 4,000 to 11,000 times as detrimental as carbon dioxide.”

Myth: The EPA has de-listed all hydro-fluorocarbon (HFC) refrigerants used in commercial settings.

Reality: The EPA’s SNAP has de-listed commonly used HFCs in certain applications, including R134A, R404A and R507 as well as other special refrigerants used in self-contained refrigeration and compressors (more on that later). However, the EPA has suggested more environmentally friendly alternatives.

Newly acceptable refrigerants include R-448A, R-449A, R-450, propane and isobutane, according to Mitchell. Propane, butane and isobutane belong to a family of refrigerants called hydrocarbons (HCs), which are naturally occurring substances that have been used as refrigerants in Europe for years and are now acceptable for use in commercial and residential refrigeration in the U.S. These limitations are subject to refigertion charge limits, however.

Back in 2010, the EPA had already phased out various other HCFC refrigerants, including HCFC-22, HCFC-142b and blends containing HCFC-22 or HCFC-142b, which now may only be used to service existing appliances. HCFCs were introduced decades ago to replace CFCs, which were phased out due to the environmental damage they caused, but then it was discovered that HCFCs are cause for concern as well. While HCFCs may not cause as much damage to the ozone layer as CFCs, they are still greenhouse gasses far more potent than CO2, Mitchell notes.

Myth: Operators will need to change out all of their equipment immediately.

Reality: The EPA will phase out certain HCFC refrigerants out over the next four years. The current ruling focuses on four equipment areas: large-scale supermarket systems, remote condensing units, self-contained refrigeration equipment such as freezers and coolers, and vending machines.

The equipment impacted by these changes includes walk-in refrigerators and freezers, reach-in coolers and freezers, display cases, prep tables, vending machines, remote condensing units and rack systems, according to Mitchell. The equipment not impacted by these changes includes blast chillers, ice machines (unless connected to supermarket systems), very low-temp refrigeration, and food and beverage dispensing systems. There is speculation that the EPA may make similar changes in the HVAC space in the near future.

It’s important to note that existing equipment can remain in service throughout its lifetime and the EPA regulations only need to be adhered to during a retrofit or replacement. “But operators are likely budgeting for upgrades anyway, so this is the time to consider more natural refrigerants and other alternatives outlined by the EPA,” says Mitchell. Any retrofit of existing equipment completed after July 20, 2016, must comply with the new rules. The compliance dates for new equipment are as follows: January 1, 2017, for supermarket systems, remote condensing units and vending machines; January 1, 2019, for small stand-alone medium-temperature units; and January 1, 2020, for large stand-alone medium-temperature units.

Additionally, the California Air Resources Board has proposed limiting stationary commercial refrigeration systems to low-GWP refrigerants starting in 2021. This proposal is still in the early stages but could have significant impact on operators in that state.

Myth: Remote condensing units will no longer be acceptable for use in their current form.

Reality: Effective 2017, the refrigerants that will no longer be acceptable for retrofit into remote condensing units include R-404A, R-407B, R-421B, R422-A, R-422C, R-422D, R-428A, R-434A, R-507 and R-501A.

“Note that there is a limitation of charge size for some of the newly acceptable refrigerants like butane and propane, so operators will have to assess whether those charge levels meet their needs,” Mitchell says. Some remote condensers might require more refrigerant charge than is currently allowed because they have longer pipe runs between the evaporator indoors and condenser outdoors.

Myth: Propane and other natural refrigerants are allowed for use in commercial settings.

Reality: The EPA has begun to allow the use of some natural refrigerants like ammonia, carbon dioxide and hydrocarbons such as butane and propane in commercial foodservice settings. Some of these were not allowed in refrigeration before because of their flammable properties, although they are commonly used throughout Europe in commercial and residential applications, says Mitchell. “There are safety concerns with propane especially, but one of the use conditions that the EPA included is a charge limit,” he says. “Commercial is at 150 grams right now, but there has been some effort to increase that because at that charge size, you’re fairly limited in terms of cooling capacity.”

Historically, ammonia has been used as a refrigerant in large industrial-type plants, where large charges are required. Concerns around leaks have limited its use in restaurants and other commercial settings. However, some new “packaged systems” only use a small ammonia charge (less than 50 pounds), so “now we’re seeing interest in putting more of these ammonia systems in commercial spaces where ammonia hasn’t been used before,” says Mitchell.

Myth: The EPA will fine operators who do not comply with the new refrigeration rules once they take effect.

Reality: While it’s true the EPA does have the authority to fine those who are not compliant, it is unclear how aggressively they’ll enforce the new rules in the early days of compliance.

Operators should also be aware of state-specific rules in this space that are administered by local agencies. California’s Refrigerant Management Program in particular requires locations with systems using more than 50 pounds of refrigerant to file annual reports and be audited or face penalties.

According to Mitchell, the California Air Resources Board proposal to limit stationary refrigeration systems to low-GWP refrigerants could go into effect in 2021, but the state is currently only in the early stages of that proposal. If the low-GWP cutoff is as low as has been discussed, such a proposal could require California businesses to use only natural refrigerants, but that determination is far from final.

Myth: Only supermarkets need to be immediately concerned with the new refrigerant rulings.

Reality: Foodservice Operators can take proactive measures to rethink their refrigeration systems and refrigerants used if they are going through retrofits or new building development currently.

While larger systems like supermarkets face a more urgent need to rethink their refrigeration, commercial foodservice operators still have some time to address the matter, though it’s in their best interest to talk to suppliers and do their research now, especially if they’re planning renovations or new builds, Mitchell says. “Talk to your suppliers about what’s available, especially for self-contained units and remote refrigeration.” Operators can also consult refrigeration contractors for research and assistance.

Myth: Making these changes will be extremely expensive.

Reality: In many cases, natural refrigerants cost the same or even less than chemical-based refrigerants.
Energy impacts and other cost savings may also improve the cost-effectiveness of using natural refrigerants.
Operators are encouraged to look at the life-cycle cost basis when evaluating new equipment. SCE and other electric utilities are developing rebate program offerings focused on these refrigerant-related activities, which will help improve the LCC.

Myth: Manufacturers are doing little to address the issue of refrigerants in a costly manner.

Reality: Many manufacturers have already been investigating EPA-approved refrigerant alternatives and testing them in their product lines. In fact, the EPA pushed the dates of the phaseout ahead primarily to give manufacturers enough time to develop new, compliant equipment, according to Mitchell.

For manufacturers of self-contained refrigeration systems, there is some concern about the availability of components to meet the new rules and dates. “If they haven’t already been designing new equipment, the design period takes a certain length of time, and then once you have design, the equipment still has to go through safety UL certification and other steps to be ready to be sold,” Mitchell says.

One major challenge remains. “There is still some uncertainty in the industry because there is no one-size-fits-all solution when it comes to refrigerants,” Mitchell says. “Certain refrigerants may be better for one application versus another, so it has to be approached in a case-by-case manner.”