EPA

EPA

Towards the end of May the Environmental Protection Agency announced their latest proposed Significant New Alternative Policy (SNAP) rule. At this time the rule is just proposed and not finalized. That being said, this rule will definitely have an impact on the industry and the future of air conditioning within the United States.

This time it is a bit different then what we usually see from the EPA. In the past these new rules typically label certain refrigerants for specific applications as no longer acceptable. However, this latest proposed rule does the opposite. This SNAP Rule 23 moves a number of refrigerants to acceptable depending on the use conditions and others have had their use restrictions lessened. Let’s take a look at the changes:

Air Conditioning

The first change focuses on residential and light commercial air conditioning and heat pumps. The following refrigerants has now been added as acceptable in these applications: R-452B, R-454A, R-454B, R-454C, R-457A, and R-32. They are all are subject to use restrictions. Each one of these refrigerants have something in common. They are ALL rated as A2L from ASHRAE. For those of you who aren’t aware, the A2L rating indicates that the refrigerant is slightly flammable. This is the same rating that the popular HFO 1234yf refrigerant that we see used in our cars has.

This A2L label indicates refrigerants having a lower flammability limit of more than 0.10 kilograms per cubic meter or 0.0062 pounds per cubic foot at 21° Celsius (69.8° Fahrenheit) and 101 kPa (14.6488 pounds of force per square inch.) and a heat of combustion of less than 19 Kilojoule/Kilogram or 8.168 BTU/Pounds. Sorry for all of the conversions here but I wanted to cover my bases. I converted these using online tools but if you see something incorrect please reach out to me.

What this means folks is that flammable refrigerants COULD be approved in traditional split system air conditioners. I say could as this rule is still preliminary, but if the EPA does finalize it then we will begin to see new systems with these refrigerants being rolled out to residential and commercial applications. To me, the big story here is that R-32 is being considered. R-32 has been becoming wildly popular over in the European Union as a more climate friendly alternative to the HFC R-410A.

While both of these refrigerants are HFCs R-32 has a significant lower GWP then R-410A. R-32 comes in at six-hundred and seventy-five where as R-410A Puron is at two-thousand and eighty-eight. So, more then double that of R-32. This is why we have begun to see the use of R-32 in newer home/commercial air conditioners in Europe and also why it is now seriously being considered within the United States marketplace.

While R-32 caught my attention I will have to admit that I wasn’t as familiar with the other refrigerants named in the proposed rule. I looked these up and found that they are all varying HFC/HFO refrigerant blends that are all rated as A2L flammability.

  • R-452B – Blend of R-32, R-125, and R-1234yf with a GWP of 675.
  • R-454A – Blend of R-1234yf and R-32 with a GWP of 239.
  • R-454B – Blend of R-1234yf and R-32 with a GWP of 467.
  • R-454C – Blend of R-1234yf and R-32 with a GWP of 146.
  • R-457A – Blend of R-32, R-1234yf. and R-152a with a GWP of 139.

Now as I mentioned earlier each one of these flammable refrigerants would be subject to use conditions. In other words, it would not be free reign or the Wild West. There would still be some restrictions and regulations. Instead of me rehashing all of these specific requirements I’ll instead just provide some direct text straight from the EPA’s proposed SNAP rule. Feel free to click on the sources as well to view the text for yourself:

    1. “This refrigerant may be used only in new equipment specifically designed and clearly identified for the refrigerants (i.e., none of these substitutes may be used as a conversion or ‘‘retrofit’’ refrigerant for existing equipment designed for other refrigerants).” – Source Page 21
    2. These substitutes may only be used in air conditioning equipment that meets all requirements in UL 60335–2–40.123 In cases where this appendix includes requirements more stringent than those of UL 60335–2–40, the appliance must meet the requirements of this appendix in place of the requirements in UL 60335–2–40.” – Source Page 21
    3. The charge size for the equipment must not exceed the maximum refrigerant mass determined according to UL 60335–2–40 for the room size where the air conditioner is used. The following markings must be attached at the locations provided and must be permanent:” (Click here and go to page 21/22 to read the text on the markings, it was too long to include in here.) 
    4. The equipment must have red Pantone Matching System (PMS) #185 or RAL 3020 marked pipes, hoses, or other devices through which the refrigerant passes, to indicate the use of a flammable refrigerant. This color must be applied at all service ports and other parts of the system where service puncturing or other actions creating an opening from the refrigerant circuit to the atmosphere might be expected and must extend a minimum of one (1) inch (25mm) in both directions from such locations and shall be replaced if removed.” – Source Page 22

Retail Food Refrigeration

These changes aren’t as big of a story as the previously mentioned air conditioners, but they are still worth mentioning. These focus on the retail food refrigeration industry specifically on medium temperature stand alone units. There were three additional refrigerants that would be deemed as acceptable with this new EPA rule: R-448A, R-449A, and R-449B. It is also worth mentioning that these were refrigerants were NOT rated as A2L from ASHRAE but instead just the standard A1 that we see with the current HFC refrigerants we use today such as R-134a, R-410A, and R-404A. So, this isn’t as big of a change.

Let’s take a look at these refrigerants:

  • R-448A – Blend of R-32, R-125, R-134a, R-1234ze, and R-1234yf.
    • GWP of 1,387
    • A1 Safety Rating from ASHRAE
  • R-449A – Blend of R-134a, R-1234yf, R-125, and R-32
    • GWP of 1,282.
    • A1 Safety Rating from ASHRAE
  • R-449B – Blend of R-32, R-125, R-134a, and R-1234yf
    • GWP of 1,296
    • A1 Safety Rating from ASHRAE

Also, like before with the air conditioners these new refrigerants would have use restrictions.  The difference here is that these refrigerants are almost seen as a last resort. See below from the EPA’s fact sheet:

“Acceptable only for use in new medium temperature standalone units where reasonable efforts have been made to ascertain that other alternatives are not technically feasible due to the inability to meet Americans with Disabilities Act (ADA) requirements.” – Source

Conclusion

As I stated a few times in this article this rule is NOT approved or finalized yet. It is still preliminary and it very well may change. If you would like to voice your opinion on the topic it is open to public comments for forty-five days from when the rule was published in the Federal Register. If you are thinking about making a comment I suggest you do it soon. If this rule does come to fruition we will be looking at a whole new demand for flammable refrigerant training for ALL of the residential and commercial contractors and technicians.

Thanks for reading,

Alec Johnson

RefrigerantHQ

Sources:

Last week the United States Senate announced a bi-partisan bill that would give the Environmental Protection Agency the power to phase out HFC refrigerants over a fifteen year period. This bill is in response to the Trump Administration’s inaction on the Kigali Amendment. Back in 2016 the Obama Administration pledged their support of the Montreal Protocol amendment but when it came time for ratification the Trump Team sat on it and has not passed it to the Senate for review.

Over the past few years of there was a double blow to phasing out HFC refrigerants across the Untied States. Not only did Trump refuse to ratify the Kigali Amendment but we also saw the overturning of the EPA’s HFC phase down regulations. The EPA had planned a scheduled phase down and eventual phase out of popular HFC refrigerants such as R-404A and R-134a. This plan was announced back in 2015 but it was challenged in the courts by the MexiChem corporation.

The premise was that the EPA was using the Clean Air Act and the Montreal Protocol for their authority. The Clean Air Act was designed to phase out CFC and HCFC refrigerants due to the Chlorine that they contained. There was not a mention of HFC refrigerants in the law, only Chlorine Ozone damaging substances. The EPA’s SNAP Rule 20 was overturned by the courts and the proposed HFC phase down laws were erased.

The bill introduced last week is known as the American Innovation and Manufacturing Act. It was introduced by Democrat Senator Tom Carper of Delaware and Republican Senator John Kennedy of Louisiana. Fourteen other senators announced their support for the bill as well.

The bill itself aims at phasing down and eventually out HFC refrigerants over a fifteen period. The bill was written with the consultation of various industry experts so that a fair timeline could be established for businesses for the phase down.

Déjà Vu

I feel like this new bill is déjà vu. We’ve seen this before. In fact, back in February of 2018 a bill was introduced by the same two Senators with the exact same name. (Source) They even referenced the same job report and economic numbers as they did previously. With this new bill Senators are promising an addition of one-hundred and fifty-thousand jobs and thirty-nine billion dollars of growth for our economy.

I just don’t see it folks. First of all, this bill isn’t going anywhere. It’s going to die in the Senate. Even if it did get to the House and by some miracle they passed it then Trump would veto it and we would be back where we started. Secondly, I am very skeptical of those job numbers economic growth.

What are these jobs? Manufacturing and plant workers? HVAC installations and retrofits? Is there going to be that much more demand for these new refrigerants? If so, what is happening to the existing systems? Is this new economic growth number the result of business owners and home owners being forced to upgrade or retrofit their systems? If this is the case then I wouldn’t call a government mandated purchase ‘economic growth.’  Instead, it is forcing business owners into compliance and causing a burden, especially on small business owners. This ‘growth’ has to come from somewhere.

Don’t get me wrong folks, I am not entirely against phasing out HFC refrigerants… but I’m not a fan of the way they are selling this to the legislators and to the people. They already tried this once with the EPA through a loophole, they got caught, and now they are trying to push a bill through with false/hopeful promises. It’s left a bad taste in my mouth.

Getting back to the topic on hand though, I do not see this bill going anywhere. The only chance that there is to pass a full scale HFC phase down law is to wait until after the 2020 election and see what the new incoming Congress and President are like. If things stay the same then there will not be a Federal HFC phase down for quite a while within the United States.

Instead, we will be left with a spattering of States adopting their own HFC phase downs with each one being just a little bit different. If this trend continues I might have to get into consulting…

For more information on the bill check out our ‘Sources’ section below.

Thanks for reading,

Alec Johnson

RefrigerantHQ

Sources: