WHICH REFRIGERANT ICE RINKS - Natural refrigerants face off with HFO blends - shecco publications
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ICE RINKS
WHICH
REFRIGERANT
IS BEST?
Natural refrigerants
face off with
HFO blends
AMERICA
LEARN.
#GoNatRefs
CONNECT.
ENGAGE.
JUNE 17-18, 2019
ATLANTA
Editor's Note // 3
The Truly Green Option
— by Michael Garry
A
ccelerate America focuses separately and in combination, serve ice E nv iro n m e nt Ag e n c y ( UB A) wa r ns
much of its attention on natu- rink owners better than any synthetic that T FA could contaminate fresh
ral refrigerant-based refrigerant, including HFO blends. water supplies.
HVAC&R systems used in the
food industry, especially by supermar- From an environmental perspective, the I agree with Janos Maté, a senior con-
kets and cold storage facilities. But this HFO blends R449A and R513A – like their sultant for Greenpeace, who urges that
technology has a broader reach – which halogenated predecessors – fall short. the large-scale uptake of HFOs should
we also cover – from residential homes First, because they combine high-GWP be avoided until there is a full compre-
and motor vehicles to commercial/insti- HFCs with the low-GWP R1234yf, their hension of the impact of peak-produc-
tutional buildings and sporting arenas, overall GWP remains high, particularly tion levels. I also endorse his sugges-
and more. for R449A (1,282). This makes it bad for tion that HFOs should be listed in the
the environment and ultimately subject Annex of Controlled Substances of the
This issue’s cover story (page 34) exam- to regulation. Even R513A’s GWP (573) Kigali Amendment, enabling accurate
ines ice rink refrigeration systems. It is nearly 600 times that of CO 2 . accounting of the amount being pro-
was inspired by the National Hockey duced, consumed and released into
League’s decision in May to par tner Moreover, the Kigali Amendment, an the atmosphere.
with Chemours in promoting the use extension of the Montreal Protocol,
of the chemical producer’s HFO blends will start phasing down HFCs next year For ice rinks and other HVAC&R applica-
R 4 49A and R513A in r inks ac ross in many countries – not a good pros- tions, natural refrigerants are the truly
North America. Notably, the NHL and pect for any refrigerant that depends green option.
Chemours said that this partnership on them.
supports the league’s “Greener Rinks
Initiative,” dedicated to sharing sustain- Then there’s the fact that R1234yf read-
able practices with community rinks. ily degrades in the atmosphere into tri-
fluoroacetic acid (TFA), a very durable
While this partnership pertains specif- chemical that is brought down to ground
ically to the ice rink industry, it really level in the form of “acid rain.”
relates to all users of HVAC&R equip-
ment. That’s because it raises general TFA is also produced naturally in the
questions about looking at HFO blends environment, and at current levels is not
as “green alternatives” when unques- regarded as a threat to the environment
tionably green natural refrigerant alter- or human health. The key phrase here is
natives are available. “at current levels”; if HFO products pro-
liferate, they will produce orders of mag-
At shecco, publisher of Accelerate nitude more TFA, with future impacts
America, we consider sustainability to be not yet understood.
about conserving the environment for
current and future generations as well Already a number of studies are sound-
as delivering regulation-proof business ing the alarm. A 2017 report commis-
solutions that save money and perform sioned by the Norwegian Environmental
well over time. In both of these regards, Agency pointed to a number of “knowl-
as delineated in the cover story, the edge gaps” about TFA’s ultimate envi-
natural refrigerants ammonia and CO 2 , ronmental effects; the German Federal Michael Garry
Editor
November - December 2018 // Accelerate America
4 // Table of Contents
In this issue
03 Editor's Note
The Truly Green Option
18 Build Credibility for NatRefs
via Energy Analysis
A proper energy comparison
// Opinion
between a natural refrigerant and
06 About Us
About Accelerate America/
an HFC system needs to include
ambient conditions, load, heat recov-
ery, an updated baseline and good
Editorial Calendar
commissioning. By Klas Berglöf
08 Letters to the Editor
22 Paying Attention to Leaks
10
Food retailers in the EPA’s GreenChill
Infographic
// Trends
program explain how investing in
America’s Pledge: 10 detection technology and focusing
Climate-Action Strategies, on maintenance can dramatically
Including HFC Reduction cut refrigerant leaks, saving dollars
and helping the environment.
12 Events Guide
Major industry events in
26
December, January and February
New HC Charge Limit Nears
Final IEC Vote
14
A proposed increase in the IEC’s
Event Preview
hydrocarbon charge limit to
AHR Expo Returns to Atlanta 500 g from 150 g got approval
to go to a final vote, which is
expected in mid-March.
16 America in Brief
28 Three New Governors to Join
U.S. Climate Alliance
Evers of Wisconsin, Pritzker
of Illinois and Whitmer of
Michigan will enter group
committed to cutting HFCs.
30
29 U.S. States Oppose EPA
Proposal on HFC Leaks
Fifteen states and the District of
// Policy
Columbia urge the agency to stick
with Obama-era rule extending
ODS leak repairs to HFCs.
30 Chillventa Reflects Europe’s
NatRef Leadership
// Event
The giant German trade show features
advances in heat pumps and chillers
along with new CO 2 condensing units.
Accelerate America // November - December 2018
Table of Contents // 5
34
44
34 Ice Rinks: Which Refrigerant
is Best?
// Cover Story
The National Hockey League has part-
nered with Chemours to promote HFO
blends R449A and R513A as green refrig-
erants for North American ice rinks. But a
more sustainable choice would be natural
refrigerants ammonia and/or CO 2 , industry
stakeholders told Accelerate America.
44 Hussmann Debuts
Self-Contained Propane Cases
OEM’s microDS line, coupled with
a water loop, can serve a store’s
complete refrigeration footprint.
46
46 Low-Charge Ammonia: Packaged
// Technology
or Central?
The development of low-charge
ammonia in North America is heading
in two directions – packaged units
and central systems; two case studies
from Canada show the differences.
50 Editorial Corner
November - December 2018 // Accelerate America
6 // About Us
NOVEMBER-DECEMBER 2018
Accelerate America
November-December 2018
// Volume 5, Issue #40
A D VA N C I N G H VA C & R N A T U R A L LY A M E R I C A
Publisher
Marc Chasserot
marc.chasserot@shecco.com
Editor
Michael Garry
michael.garry@shecco.com
Contributing Writers
Pilar Aleu
Marie Battesti
Dario Belluomini
Jan Dusek
Anti Gzikelis
Eda Isaksson
Charlotte McLaughlin
About Accelerate America Klara Zolcer Skacanova
Andrew Williams
Brought to you by shecco, the worldwide
Devin Yoshimoto
experts in natural refrigerant news, Accelerate
America is the first news magazine written
Ad Coordinator
for and about the most progressive business
Silvia Scaldaferri
leaders working with natural refrigerant
solutions in all HVAC&R sectors.
Art Director
Charlotte Georis
http://acceleratena.com
Accelerate America publisher shecco's network Graphic Designer
spans the globe with offices in Brussels, Tokyo, Mehdi Bouhjar
New York and Sydney.
Photographers
Ben Beech
Scott Chasserot
Ted Gartland
WANT TO ADVERTISE?
/ Ad Sales The views expressed by the contributors are not
necessarily those of the Publisher. Every care is
Silvia Scaldaferri
taken to ensure the content of the magazine is
silvia.scaldaferri@shecco.com
accurate but we assume no responsibility for any
+39 331 961 3956
effect from errors or omissions.
Published by shecco SPRL. All rights
reserved. Reproduction in whole or in
GOT A STORY IDEA? part is prohibited without prior written
permission of the copyright owner.
/ Editor
Michael Garry
michael.garry@shecco.com
203-417-0767
Accelerate America // November - December 2018
Editorial Calendar // 7
EDITORIAL CALENDAR
40
Accelerate America is published 10 times per year by shecco ISSUE#
America. All issues are available in digital form at acceleratena.
com. Printed copies are mailed to end users and other key HVAC&R
industry players, and distributed at key industry events.*
VOLUME 5
// ISSUE #41 // ISSUE #44 // ISSUE #47
January 2019 April 2019 August 2019
FOCUS: FOCUS: FOCUS:
Hydrocarbons in Refrigeration and AC Heat Pumps Air Conditioning
PUBLICATION DATE: PUBLICATION DATE: PUBLICATION DATE:
January 30 April 29 August 6
AD DEADLINE: AD DEADLINE: AD DEADLINE:
January 25 April 25 August 2
DISTRIBUTION: DISTRIBUTION:
NAFEM (Orlando, 2/6-9) NRA Show (Chicago, 5/18-21),
// ISSUE #48
// ISSUE #42 // ISSUE #45 September 2019
February 2019 May 2019 FOCUS:
FOCUS: FOCUS: Food Retail
Low-Charge Ammonia (Central) Policy & Standards Update PUBLICATION DATE:
PUBLICATION DATE: PUBLICATION DATE: September 3
February 26 May 29 AD DEADLINE:
AD DEADLINE: AD DEADLINE: August 30
February 22 May 24 DISTRIBUTION:
DISTRIBUTION: DISTRIBUTION: FMI Energy & Store Development
IIAR Natural Refrigeration & Global Cold Chain Expo (Chicago, Conference (Dallas, September 8-11)
Expo (Phoenix, 3/3-6) June 10-12), ATMOsphere America
(Atlanta, June 17-18)
// ISSUE #43 // ISSUE #46 // ISSUE #49
March 2019 June-July 2019 October 2019
FOCUS: FOCUS: FOCUS:
Low-Charge Ammonia (Packaged) Accelerate America Awards CO 2 in Industrial Refrigeration
PUBLICATION DATE: PUBLICATION DATE: PUBLICATION DATE:
March 27 July 10 October 22
AD DEADLINE: AD DEADLINE: AD DEADLINE:
March 22 July 3 October 18
* Publisher reserves the right
to modify the calendar.
November - December 2018 // Accelerate America
8 //
LETTERS TO
THE EDITOR
CO 2 IS CHANGING INDUSTRIAL
REFRIGERATION
In regard to “Taking on Transcritical in Cold Storage”
KEEP HFC LEAK REPAIR RULES
(Accelerate America, October 2018), I have had the pleasure
of not only knowing Pete Lepschat of Henningsen Cold In response to “EPA Proposes to Rescind Leak Repair Rules for HFC
Storage for many years but also visiting the Grandview, Equipment” (Accelerate America, October 2018), I view the exclusion of
Wash., transcritical CO 2 facility just prior to pulldown. As HFCs from Section 608 as a step in the wrong direction. Since these
usual, the Henningsen facility was well thought out and refrigerants carry a very high global warming potential, and play a signif-
planned not only for current business but future business icant role in many current commercial refrigeration systems, including
expansion as well. HFCs in the regulations was logical.
Five or six years ago, if someone had told me that tran- Many high-volume refrigerant users, like grocery retailers, have already
scritical CO 2 refrigeration had a place in industrial refrig- invested significantly in refrigerant leak-reduction programs that include
eration, I would have been highly skeptical. However, HFCs; changing back would create confusion. In addition, expenses
three or four years ago my friend Bob Hampson told me related to refrigerant leaks and leak repair are one of the highest
that he had just installed a system in a facility in Quebec maintenance cost categories that a grocery retailer faces, and many
(Canneberges Becancour) and couldn’t have been happier have seen the benefit of employing a thorough and responsible leak-
with the results. I accepted Bob’s invitation to visit the reduction program.
facility. After my visit, it was obvious that this technology
merited a “deeper dive.” Section 608 requirements support the need to establish these programs.
With some of the recent scientific reports that have been published on
Since this first visit, I’ve traveled throughout Nor th climate change, it seems appropriate that HFCs continue to be included
America visiting other sites and hearing similar accolades in regulations going forward.
from owners and contractors alike. I’ve been working on
Bryan Beitler
a white paper on this subject for well over a year, and have
Vice President, Chief Engineer
had to stop and reset several times due to the rapidly
Coolsys, Brea, Calif.
evolving technological advances in this area.
The evidence for transcritical CO 2 has been extraordi-
narily positive in virtually every category including total
cost of ownership (TCO). As noted in one of the article’s
LETTERS ARE WELCOMED!
sidebars, it is clear that there are major investments being
made to further improve the technology by many compa- Accelerate America invites readers to submit letters to the edi-
nies, both large and small. It is not hard to imagine that tor at michael.garry@shecco.com. They can be about a recent
we are only at the precipice of a major shift in our thinking article; an industry issue that readers would like us to cover in
when it comes to industrial refrigeration systems. greater detail; or the value of Accelerate America and ATMOsphere
America in educating the industry about natural refrigerants,
Terry L. Chapp
including what we can do better. Letters may be edited for clarity
Nor th American Business Development Manager
or length.
Danfoss Industrial Refrigeration, Baltimore, Md.
Accelerate America // November - December 2018
Ready, set,
chill. pansion
4 Condenser 3 2
Pressure
(P)
r
so
pa
res
mp
Co
5 Evaporator 1
Enthalpy (H)
With the NEW Evapcold packaged chillers, you
can get your low charge ammonia refrigeration
system (and your ice rink) up and running faster—
safer—and more affordably—than ever before.
Choose from more than 150 plug-and-play models,
all designed to EVAPCO’s industry-leading perfor-
mance and safety standards. Then customize your
system with time and money saving innovations,
like our waste - heat-recovery defrost (or ice melt)
system, factory mounted circulation pumps, and
enclosure packages. The result is an industrial
strength chiller solution that can be mounted
virtually anywhere, and for any refrigeration
application.
Talk to your local EVAPCO representative or visit
evapco.com to learn more. We are EVAPCO—the
team you can count on for life.
for LIFE
Since 1976 | An Employee-Owned Company
Commercial HVAC | Process Cooling | Industrial Refrigeration | Power
10 // Infographic
AMERICA’S PLEDGE
10 Climate-Action Strategies,
Including HFC Reduction
1 Double down on
renewable energy
targets 2 Accelerate the
retirement of coal
power 3 Encourage residential
and commercial building
efficiency retrofits
4 Electrify
building
energy use 5 Accelerate
electric vehicle
adoption 6 PHASE DOWN
SUPER-POLLUTING HFCS
Reduce HFC emissions by an additional
5% beyond current policies by 2025 via:
» Implementing HFC-reduction at all 16
state members (and growing) and
Puerto Rico in the U.S. Climate Alliance;
» Broadening EPA GreenChill program;
» Extending HFC-reduction to aerosols
Reduce HFC emissions by an additional
7
16% beyond current policies by 2025 via :
8
Stop methane Reduce methane
leaks at oil and » Enhanced engagement (40% reduction
leaks in urban gas from 2013 levels by 2030 in U.S. Climate
gas facilities distribution Alliance states and Puerto Rico).
Base
9 Develop regional strategies
for carbon sequestration on
natural and working lands 10 Form state
coalitions for
carbon pricing
Accelerate America // November - December 2018TRANSFORMING
TORONTO WITH CO2
Toronto Ontario has a bold vision to become the most To learn more about
environmentally sustainable city on the planet. As part of the CIMCO ice solutions,
Transformation TO program, the city wanted to create more contact our experts today.
outdoor skating paths deep within the urban environment of
downtown Toronto. As a mandate on all projects, Toronto engages
with residents and businesses to build amenities for a healthy,
1-800-456-2653
equitable and prosperous world-class city.
So for Toronto, CIMCO’s CO2 solution was the natural choice to
provide environmental, safety and economical advantages. Today,
Toronto has several CO2 rinks for their citizens, including the first
CO2 skate path in the world. CIMCOrefrigeration.com12 // Events Guide
DEC –JAN 12.11-12
Bitzer 2-Day Natural Refrigerants
Seminar,
Oakwood, Ga.
Day 1 will cover CO 2 and Bitzer Reciprocat-
ing Compressors. Day 2 will cover NH 3 and
Bitzer OS Open-Drive Screw Compressors
01.12-16
ASHRAE 2019 Winter Conference,
Atlanta, Ga.
The ASHRAE Winter Conference technical
program includes refrigeration, HVAC&R
fundamentals and applications, systems
and equipment, common system mis-
applications, and achieving high-perfor-
mance building operation after design.
https://bit.ly/2AinpVK
https://bit.ly/2Bv9Wvq
@BITZERGroup
@ashraenews
12.12-13
Emerson Natural Refrigerants 01.14-16
Training,
Brantford, Ontario AHR Expo,
Training will cover major trends in C0 2 , Atlanta, Ga.
NH 3 , and R290; terminology; mapping Co-sponsored by ASHRAE and AHRI, the
a CO 2 system; best practices in servic- AHR Expo bills itself as the world’s largest
ing; charging of CO 2 systems; start-up HVACR event, with more than 2,100 exhib-
and shutdown sequences; and more. itors and over 120 educational sessions.
Attendees include OEMs, engineers, con-
tractors, facility operators, architects, ed-
https://bit.ly/2DLzg1Z ucators and other industry professionals.
@Emerson_News https://ahrexpo.com
@ahrexpo
01.10
Danfoss Natural Refrigerant Semi-
nar And Live CO2 Demo,
Baltimore, Md.
Free seminar on natural refrigerant appli-
cations in supermarkets, geared to food
retailers, service contractors and environ-
mental stakeholders. Agenda includes:
incentives for low-GWP refrigerants;
refrigerant regulations at the international,
federal, and state level; and a live demon-
stration of a CO 2 transcritical system.
https://bit.ly/2TDzjSZ
@Danfoss_US
Accelerate America // November - December 2018Events Guide // 13
JAN – FEB
01.15 2PM 01.30-31
EPA GreenChill Webinar: Super- Emerson CO2 Learning Sessions,
market Experiences with Mi- Orlando, Fla.
cro-Distributed Systems, Designed for service technicians, manu-
Online facturers and end users, this event covers
Webinar featuring Rich Gilles of terminology, mapping of casacade and
Hussmann and Paul Anderson and transcritical systems, efficiency optimiza-
Charlie Wernette of HEB Grocery. tion in warm ambient climates, and more.
https://bit.ly/2FGErmp https://bit.ly/2P0maQf
@EPAgreenchill @Emerson_News
01.16-17 02.07-09
Emerson CO2 Learning Sessions, The NAFEM Show,
Atlanta, Ga. Orlando, Fla.
Designed for service technicians, manu- Every-other-year event for foodservice
facturers and end users, this event covers operators features more than 500 exhibits
terminology, mapping of casacade and by equipment and supplies manufactur-
transcritical systems, efficiency optimiza- ers and myriad educational sessions.
tion in warm ambient climates, and more.
https://bit.ly/2FC1lLz
https://bit.ly/2P0maQf
@TheNAFEMSHow
@Emerson_News
01.29 2PM 02.12 2PM
EPA GreenChill Webinar: Market EPA GreenChill Webinar: Benefits
Trends for Carbon Dioxide, Ammo- of Partnering with GreenChill for
nia and Hydrocarbon Refrigerants Small and Independent Grocers,
in North America, Online
Online Webinar features Rene Tanner and Scott
Webinar features Klara Zolcer Ska- Marble of the Port Townsend Food Co-op.
canova and Marc Chasserot, shecco.
https://bit.ly/2S8csNy
https://bit.ly/2DIF77T
@EPAgreenchill
@EPAgreenchill
November - December 2018 // Accelerate America14 // Events
AHR Expo
Returns to Atlanta
The giant trade show will take place in the
Georgia capitol – near several manufacturers of
natural refrigerant equipment – for the first time
since 2001
– By Michael Garry
T
he AHR E xpo, which bills itself as the The following educational sessions are related to natural refrigerants:
world’s largest HVACR marketplace, will
return to Atlanta, Ga., for the first time since Trends in the Global HVAC Market, Jan.14, 9-11 am, room B312. BSRIA
2001 for its 2019 event, January 14-16 at executives will present the latest global trends from HVAC markets,
the Georgia World Congress Center. including a detailed look at the U.S.
The Atlanta area is home to several of the OEMs and DOE Regulations and the HVAC&R Industry, Jan. 14, 10:45-11:05
component makers serving the natural refrigeration am , Theater A- room C101. Nidec Motor will discuss upcoming
industry, including Hillphoenix, Bitzer, Hussmann, changes in Department of Energy regulations and their impact on the
Heatcraft, Nidec-Secop and Carlyle. HVAC&R industry.
The AHR Expo will feature more than 2,100 exhibitors Low-GWP Refrigerants: Components and System Designs, Jan. 14, 11
and over 120 educational sessions, including an over- am-noon, B313a. This seminar will present the performances of a variety
view by shecco of global market and policy trends for of lower-GWP alternatives at various temperatures, and how to adopt
CO 2 and ammonia in refrigeration. The show’s more them in system design. Speakers include Pega Hrnjak, Creative Thermal
than 60,000 attendees include OEMs, engineers, con- Solutions and the University of Illinois; Paul de Larminat, Johnson
tractors, component manufacturers, distributors, and Control Industries; and Craig Bradshaw, Oklahoma State University.
facility operators spanning the commercial, industrial
and institutional sectors. Update on Global Policies and Programs for Best Use of Refrigerants,
Jan. 14, 2:15-3:45 pm, B313b. This session provides updates on global
E xhibitors of fe r ing natural refr ige rant- re late d refrigerant regulations and efforts to support the best use of refriger-
equipment include: Stellar (booth B244), Blissfield ants. Speakers include Antonio Bouza, Department of Energy; Didier
Manufacturing (B851), Tecumseh Products (B1327), Coulomb, International Institute of Refrigeration; Ayman Eltalouny,
Emerson (B2219), Carel USA (B2255), Keeprite UNEP; and Yunho Hwang, University of Maryland.
Refrigeration (B2260), Parker Hannifin (B2349), Carlyle
Compressor (B2931), SWEP North America (B2953), Global Market and Policy Trends for CO 2 and Ammonia in Refrigeration,
Super Radiator Coils (B3735), Modine Commercial Jan. 15, 10:30-11 am, B316. Marc Chasserot, CEO of shecco (publisher of
and Industrial Solutions (B3275), Wieland Copper Accelerate America), will evaluate the key market, technology and policy
Products (B5770), ebm- papst (C5819) Baltimore trends for CO 2 and ammonia, presenting data on the number of installed
Aircoil (C6531) and Embraco North America (C7431). applications and comparing the evolution globally.
In the refrigeration category, the AHR Expo Innovation Low-GWP Alternative Refrigerants for Cooling – Skills, Needs and
Award will go to Emerson for its Copeland Scroll frac- Solutions, Jan. 15, 2:30-4:30, B315. This session will draw from the
tional-horsepower low-temperature compressors, EU’s “Real Alternatives 4 Life,” which provides training materials to
which use liquid injection technology and cooling address the skills barriers to the widespread adoption of natural refrig-
discharge temperatures to reduce compressor stress erants. Speakers include Didier Coulomb, International Institute of
and meet federal regulatory requirements. Finalists Refrigeration; Marco Buoni, AREA Association of European Contractors
include Baltimore Aircoil for its TrilliumSeries adia- and ATF Training; and Graeme Maidment, London South Bank University
batic condenser and DunAn Microstaq for its Silicon and the Institute of Refrigeration. MG
Refrigeration Valve,
For more information, go to: https://ahrexpo.com.
Accelerate America // November - December 201816 // America In Brief
AMERICA IN BRIEF
EPA Announces Bacharach Issues Montreal Protocol
NH 3 Settlements Section 608 Guide Targets CFC-11
Last month the U.S. Environmental Protection HVAC&R instrumentation manufacturer At the 30th Meeting of the Parties to
Agency (EPA) announced seven settlements with Bacharach, New Kensington, Pa., has the Montreal Protocol (MOP 30) in
companies in four New England states for alleged issued a free guide to revisions in the Quito, Ecuador, last month, the 197
violations of chemical accident prevention and U.S. Environmental Protection Agency’s Parties (countries) committed to pro-
repor ting laws. All the cases address the safe Section 608 Refrigerant Recycling and viding all available data on the illegal
use of anhydrous ammonia in refrigeration and Emissions Reduction Program. use and production of ozone-deplet-
cooling units. ing CFC-11.
The revisions are set to take effect in
The companies all cooperated with EPA’s New January. The Montreal Protocol, originally
England regional office. Two of the settlements were signed in 1987, phased out the use
with companies that EPA inspected after ammonia The guide, called “EPA Section 608 2019 of CFC-11 and other ozone-depleting
releases occurred, and five cases were undertaken to Refrigerant Compliance: checklist & substances. Use of CFC-11 would be
prevent such releases. guidelines,” is designed for equipment in violation of the treaty, which in 2016
owners within the food retail sector. added an HFC phase-down under the
Collectively, the seven companies have spent more Kigali Amendment.
than $750,000 to comply with the laws, and will pay Section 608 applies to the maintenance
more than $580,000 in penalties to settle EPA’s claims and leak repair of stationary refriger- T he CFC -11 agreement followed
of alleged violations. ation and air conditioning equipment. th e p rese ntatio n at MOP 30 of
the Environmental Investigation
“These agreements will improve compliance with The free guide can be downloaded at Agency 's (EIA) latest repor t on
impor tant laws that help protect communities https://bit.ly/2G7Re1k. the potential impact of ozone -de -
and provide critical resources for local emergency ple ting CFC -11 use in China on
responders and communities,” said EPA New England Section 608 requirements were revised the ozone layer, called “Tip of the
Regional Administrator Alexandra Dunn. in 2016, extending from ozone-deplet- Iceberg: Implications of Illegal CFC
ing refrigerants to include HFCs as well. Production and Use.” It includes rec-
The settlements were with the following compa- However, the EPA is currently engaged ommendations for action aimed at
nies: Finicky Pet Food, New Bedford, Mass.; McCain in rule-making to rescind the leak repair the meeting’s participants.
Foods USA, Easton, Maine; Twenty-Five Commerce, and maintenance requirements for HFC
Nor walk , Conn.; Guida -Seiber t Dair y Company, equipment. It is not known whether a Under the agreement, each Party will
New Britain , Conn.; The Maine Wild Blueberr y new rule will be finalized before January. take measures to ensure the phase-
Company, Machias, Maine; New England Spor ts MG out of CFC-11 in their countries is
Management Corporation, Marlborough, Mass.; maintained, and to share information
and High Liner Foods (USA), Por tsmouth, N.H. on any illegal use or production of
MG CFC-11 to the relevant bodies of the
Montreal Protocol.
Daikin acquires AHT Cooling Systems For its part, China contended that it
has “taken action to investigate and
In another sign of its interest in the natural refrigerants AHT already has over one million pro- enforce its laws regarding Ozone
sector, Japanese multinational air-conditioning giant pane-based cabinets operating world- Depleting Substance (ODS) produc-
Daikin has announced the acquisition of Austrian wide. “We think propane is the best tion and use,” said Zeng Rong, spokes-
commercial refrigeration firm AHT Cooling Systems solution on the market for supermar- person for the Chinese embassy in
for $999 million. ket units,” Reinhold Resch, AHT’s vice the United Kingdom, in an open letter
president for R&D, said last year. to The Guardian, a U.K. newspaper.
Daikin, the world’s largest manufacturer of air condi-
tioning equipment, expects to complete the acquisi- In North America, where it is based A l s o a t M O P 3 0 , t wo d e ve l o p -
tion in January 2019. The Japanese firm said the deal in Ladson, S.C., AHT has signficantly ing countries that are still phas-
would enable it to “propose total systems that cover grown sales of its propane self-con- ing down HCFCs – Cameroon
the entire cold chain,” while also expanding its refrig- tained commercial display cases. an d C hile – exp resse d inte res t
eration business in the U.S. and Asia. in leapfrogging HFCs by adopt-
L as t Fe b r uar y, Daik in Eu ro p e N V ing natural refr ige rants. " T he re
Having opted for propane in the 1990s, AHT remains com- acquired Spanish CO 2 system devel- is definitely ver y high interest in
mitted to this natural refrigerant as a means of reducing oper Tewis. AW n a tu r a l r e f r i g e r a n ts i n A f r i c a ,”
the energy consumption and environmental impact of its said a delegate from Cameroon.
refrigerated and frozen food display cabinets. MB
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18 // Opinion
Build
Credibility Normalized energy signatures
for NatRefs
The following are some examples of major challenges
to evaluating the efficiency of a new solution.
via Energy
First, the ambient conditions before and after a tech-
nology change will never be the same. Therefore, data
must be adjusted to reflect changes in ambient con-
ditions; otherwise results cannot be compared over
Analysis
time or between two locations.
Normalized “energy signatures” with kWh consump-
tion per hour at each ambient temperature for differ-
ent time periods or locations are a powerful tool for
comparing the energy efficiency of two technologies
while considering variation in climate.
A proper energy comparison between a
natural refrigerant and an HFC system There may be a desire to make the test period as short
as possible if it is urgent to reach full commercial-
needs to include ambient conditions, ization. But if relevant factors are not considered
load, heat recovery, an updated baseline and reported, the uncertainty will increase and those
opposing the technology may discredit the test. A
and good commissioning poorly planned and executed test may be worthless.
– By Klas Berglöf
Avoid comparing previous and new equipment at
disparate times during the year if the expectation is
to analyze annual energy consumption. To compare
February and June seldom makes sense for most
locations. The test must cover a representative range
of ambient conditions occurring over a “normalized
A
ll new technologies create uncertainty in the mar- year” to eliminate the impact of normal variations.
ketplace, as there are often strong believers but
also opponents. To reduce this uncertainty, we The load during a pre- and post-installation evaluation
need well-documented field tests that present suf- period, or between two sites, will rarely be the same
ficient system data and can be validated by a third party. as there are no accepted benchmarking methods. But
this can be solved if energy signatures are normalized
In particular, measuring energy efficiency is a key to intro- for significant load factors. Some supermarkets chains
ducing new supermarket-sector technologies such as CO 2 use meter display, while others use the floor area of a
refrigeration. store; no method is perfect but they work well.
Many articles claim high efficiency for CO 2 systems but many A normalized energy signature also requires factors
others report the opposite. In many cases the published test like heat recovery to be taken into account. This is
documentation does not make it possible to evaluate how the particularly true for CO 2 systems where heat recovery
new solution saved energy. often is important for overall efficiency.
Well-documented tests are required to enable a new technol- Controls and commissioning can also have a major
ogy to become accepted as well as to learn how the solution impact on efficiency and reliability. To compare the
can be improved. Field tests are necessary because labora- efficiency of two systems with different controls and
tory tests do not give the full picture, and properly done field levels of commissioning makes little sense.
tests build experience and allow the best use of a technology
in future installations. But there are obvious challenges to In addition, evaluations should identify and quantify
performing real-life tests that allow new systems to be com- what caused a difference in efficiency; otherwise a
pared with HFC technologies. comparison to another system can't be understood .
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ATMO China | 11-12 April 2019 – Shanghai (CN)20 // Opinion
Proper baselines and commissioning as possible from the pilot result so
that corrections to design can be
Historical energy consumption of a plant should not made, and the results can be used
be used as a baseline of comparison without validat- to improve cost effectiveness for
ing details of the plant’s operation. future plants.
Most old plants are not operating as well as they For a transcritical CO 2 or hydrocar-
could. It is of limited value to have a team of engineers bon system at a supermarket, only
make a new solution run better than a bad old system a few more sensors than what is
– maybe they could have improved the old plant. A standard are required to facilitate
baseline performance should be documented and complete performance analyses
understood. If there are faults/inefficient operations, and energy reporting via System
these should be fixed before baseline data is col- Efficiency Index (SEI), a normalized
lected. If a reference plant is not properly described, unit of efficiency.
then any comparison will be discredited.
With proper instrumentation, it is
It is also often taken for granted by those involved in a possible to follow per formance
new solution that it will be operating well since every- dynamically over time and detect
thing is new and state-of-the-art. Commissioning of deviations in performance before
plants is often done before the plant is in full opera- they result in increased energy
tion and often at one ambient condition. This does consumption or failures. SEI and
not result in good efficiency, and often things happen sub efficiencies for compressor,
during the test period that reduce efficiency without condenser and evaporator are
causing alarms. powerful tools for visualizing per-
formance and detecting changes
It is important to monitor relevant data points to eval- in a refrigeration or air condition-
uate performance of a plant in real time during com- ing plant.
missioning tests. Deviations can then be detected to
avoid valuable test time being destroyed by mistakes Finally, do not neglect the impor-
in commissioning or while faults are occurring. tance of good commissioning of
controls for all operating condi-
For example, in a Bonneville Power Authority (BPA) tions. Many existing and new plants
test, a pressure sensor became defective, causing operate with poorly adjusted con-
excessive energy consumption at the evaluated plant. trols, causing excessive energy con-
Without proper instrumentation and continuous mon- sumption and premature failures.
itoring, this excess energy consumption would have
destroyed the evaluation of the new technology. In most cases the focus has been
on maintaining a set temperature.
Early detection of faults is always cost effective and Poor setup and erratic operation
prevents long test periods from becoming useless. caused by controls poorly adjusted Klas Berglöf is managing
The period over which the faulty sensor operated to the conditions and requirements director of ClimaCheck Sweden.
can be removed from an evaluation since it was not of a par ticular plant frequently He has been active since 1984
related to the technology under consideration. increases energy consumption in the Swedish refrigeration,
20%-30% and systems operate with air conditioning and heat
It is good advice to do your homework and ensure excess start-stop without anyone pump industry. In 2004, he
that operation of your plant is well understood and considering it a “fault.” started ClimaCheck to develop
efficiency is maintained over the test period. performance analysis methods
These problems might not show up for RAC systems.
The cost of executing a test is significant, but mea- during commissioning conditions,
suring and validation are a minor expense. Most of and the cost in energy efficiency
the required sensors are installed as standard prac- and failures caused by start and
tice, but not all; so it’s necessary to analyze what stop in plants seem to be almost
sensors are needed. It's important to learn as much neglected in the industry. KB
Accelerate America // November - December 201822 // Trends
PAYING T
he best way large users of refrigerants
like supermarkets can help the environ-
ment is to switch to natural refrigerants
that don’t contribute to climate change
ATTENTION
or deplete the ozone layer.
Short of that, food retailers that continue to use
synthetic refrigerants can take steps to reduce
TO LEAKS
how much leaks into the atmosphere. To that end,
the GreenChill Partnership, a decade-old voluntary
program run by the U.S. Environmental Protection
Agency,, has helped numerous chains significantly
cut their leak rates. About 11,000 U.S. supermar-
kets operated by 45 companies from all 50 states
are in the program, representing about 29% of
Food retailers in the EPA’s GreenChill program U.S. stores.
explain how investing in detection technology The GreenChill recipe for success is disarmingly
and focusing on maintenance can dramatically simple. “It’s really all about focus – just paying
attention,” along with setting corporate leak-rate
cut refrigerant leaks, saving dollars and helping goals, said Tom Land, GreenChill’s program man-
the environment ager, at a session on leak reduction at the Food
Marketing Institute’s Energy & Store Development
– By Eda Isaksson and Michael Garry Conference in September. He was joined by rep-
resentatives of two GreenChill partner retailers,
Meijer and Food Lion, who shared strategies for
cutting leaks. At a GreenChill-hosted webinar ear-
lier in September, executives of Kroger ran through
their approach.
GreenChill’s retail partners’ leak rates averaged
12.9% in 2017 – far below what is thought to be the
industry rate of 25%. Eleven companies cut their
leak rates to below 10%. “The ‘under 10% club’ con-
tinues to grow,” said Land.
Leak reduction gives a decided boost to retailers’
bottom lines. The average annual replacement
cost for refrigerants that leak at a 25% rate is
$8,000, but that drops to $2,500 when the rate is
12.9%, said Land.
KROGER’S LEAK DETECTION
SYSTEMS
Leak detection technology has helped Cincinnati,
Ohio -based Kroger – the largest supermarket
chain by revenue in the U.S. – cut its refriger-
ant emissions by 44% in 43 stores that use the
devices compared to 78 without them, said Jerry
Rumple, manager of maintenance during the
GreenChill webinar.
From left: Tom Land, EPA; Wayne Rosa, Food Lion, receiving an EPA
GreenChill 2018 Superior Goal Achievement award for reaching leak-
Leak detection systems, which are integrated into
reduction goal
the building automation system, are standard now
for remodels, expansions and new stores, he noted.
Photography by: Ted Gartland
The chain uses both stationary and portable leak
detection devices.
Accelerate America // November - December 201824 // Trends
The detection systems used by Kroger come in downtime or temperature issues. Detecting has down
both electronic and infrared versions. The less to 1 ppm, the device alerts a technicians at 3 ppm and
sophisticated electronic devices are less accu - sounds an alarm at 5 ppm.
rate and are susceptible to false alarms; they also
require calibration. In Meijer’s preventative maintenance program, all
store racks are checked for leaks every quarter with
By contrast, infrared devices, which identify specific hand-held devices. “PMs are automatically generated
gas molecules, are “extremely accurate, self-cali- through the refrigerant management system,” said
brating and have no false alarms,” said Rumple, who Flanigan.
has over 30 years of experience working in commer-
cial building maintenance. Infrared systems should The chain keeps small refrigerant stocks in every
be set at very low ppm – they detect as little as store, and conducts an inventory every quarter in
1 ppm of a gas – “to find the smallest of leaks.” order to track its refrigerant usage.
To improve detector operation, Rumple recommended To cut the amount of refrigerant charge in a store by
understanding the air patterns in a store by using 35%, in 2010 Meijer began a switch from a central rack
"smoke testing." design to distributed systems, installing six per store,
he said. The design also cut leaks by 41%.
Kroger technicians look for leaks in coolers, freez-
ers, prep rooms and compressor systems in enclosed
FOOD LION RATES TECHNICIANS
spaces, among other spots. In addition to leaks, they
target safety and code compliance. Salisbur y, N.C.- based Food Lion , which joined
GreenChill at its inception in 2007, slashed its leak
A preventative maintenance (PM) program is also rates over the next decade by 23.4%, said Wayne
in place throughout the company, said Michael Rosa, director of maintenance for Food Lion, at the
Dellecave, manager of mechanical services at Kroger, FMI Energy Conference. “GreenChill brings out a com-
during the webinar. This includes semi-annual visual petitive spirit” among partners with respect to leak
inspection focused on system operation, tubing reduction, he noted.
condition, filters, settings and reporting via building
automation. When it comes to sustainability initiatives, Food Lion,
a division of Ahold Delhaize, decided years ago to “be
On an annual basis, Kroger inspects and replaces good at the basics – energy consumption and leak
line end filters and moisture filters, and uses a prod- rates,” Rosa said.
uct that simulates halogen gas to test gas pick-up
and notifications. To that end, the 1,029-store chain tracks all refrig-
erant use, even equipment with less than 50 lbs
MEIJER’S AGGRESSIVE APPROACH of refrigerant.
Grand Rapids, Mich.- based Meijer, which joined Food Lion employs more than 100 in-house refrig-
GreenChill in 2012, slashed its leak rate from 19% eration technicians. Technicians are evaluated on
in 2009 to 8.5% in 2017, said Jason Flanigan, the “score cards,” which incorporate leak rates and lbs of
chain’s senior mechanical engineer, at the FMI Energy refrigerant use. Their bonus structure is based on the
Conference. “We’re very proud of that.” results. “It gives them an incentive to control leaks,”
said Rosa.
During that period, Meijer, which runs 242 supercenter
stores in six states, reduced the amount of refrigerant The chain does quarterly inventory and leak checks
it purchased by 19% despite growing by 12%, he said. and annual compressor room checks.
Meijer takes an aggressive approach to leak preven- Food Lion also does “condition-based maintenance,”
tion and maintenance. “We don’t consider the EPA tracking receiver levels in racks. “If there’s any diver-
leak threshold when addressing leaks; we fix all leaks gence from what it should be, an alarm is sent out to
regardless of the leak size,” said Flanigan. do a leak check,” said Rosa. The accuracy rate of the
alarms has been in the upper 90 th percentile.
Meijer employs infrared leak detection systems in
about 119 stores, with plans to complete a chain-wide In 2017, Food Lion added leak detection systems in
rollout, said Flanigan. The precision of the devices motor rooms “where larger leaks occur,” said Rosa.
gives Meijer the opportunity to find leaks and fix them “It’s rare there will be a large loss on the sale floor.”
before they become significant enough to cause EI & MG
Accelerate America // November - December 201826 // Policy
NEW HC CHARGE
a meeting in Busan, South Korea, where
the subcommittee analyzed comments
received from the national committees
LIMIT NEARS
during the CDV stage.
In the FDIS phase, the charge-limit doc-
FINAL IEC VOTE
ument is circulated to the national com-
mittees for a two-month voting period.
An FDIS is approved if at least a two-third
majority of P (Participating)-members
vote positively, and less than 25% of
A proposed increase in the IEC’s hydrocarbon charge limit votes are negative. If the document is
approved, it progresses to the final pub-
to 500 g from 150 g got approval to go to a final vote, lication stage and could be published in
which is expected in mid-March the first half 2019; if it is not approved, it
is referred back to a technical committee
– By Marie Battesti and Michael Garry or subcommittee to be reconsidered.
In
Four-year process
a move that could widen the
use of hydrocarbons as natu- It is commonly accepted by experts that
ral refrigerants worldwide, the 150 g limit does not allow manufac-
the International Elec tro - turers and end users to fully exploit the
technical Commission (IEC) in October safe application of hydrocarbon refrig-
approved advancing to a final vote on erants in this sector.
whether to increase the charge limit for
A3 (flammable) refrigerants like pro- To address the charge limit issue, in
pane in commercial refrigeration equip- 2014 Subcommittee SC61C created a
ment to 500 g from 150 g under the IEC working group (WG4)., which comprises
standard 60335-2-89. experts from major global manufactur-
ers like AHT, Epta, True Manufacturing,
The final vote, expected by mid-March Emerson and Hussmann, among others.
2019, represents the last step in a
lengthy standards process that will At the Busan meeting, “most of the
determine whether the higher charge CDV c o m m e nts p ro p ose d by WG 4
limit is ultimately employed throughout were accepted, except the maximum
the world. charge of A2L, which will remain 1.2 kg,”
said Zgliczynski.
The final vote under IEC rules is called
the Final Draft International Standard Standards from the IEC, a worldwide
(FDIS) phase. The FDIS vote had been body that proposes rules governing how
expected by the end of 2018 but “is to use electrical, electronic and related
not ready yet,” said Marek Zgliczynski, technologies, influence the develop-
Embraco’s manager of commercial ment of the market by providing manu-
refrigeration product engineering, who facturers and customers with guidelines
chairs the IEC SC61C subcommittee. “It as to what is safe to use and buy. “But to
Marek Zgliczynski, chair of IEC's SC61C will go to IEC's Central Office for trans- be mandatory, [the standard] has to be
subcommittee lation and editorial revision by mid-De- adopted by region,” said Zgliczynski.
cember. So the vote will happen proba-
bly in mid- March, not earlier than this.” In the European Union, CEN/CENELEC
tends to harmonize their standards
To get to this stage, national commit- with IEC and ISO benchmarks as much
tees in the IEC agreed in July by a 75% as possible.
"yes" vote in what was called the CDV
(Committee Draft for Vote) to increase In the U.S., a new IEC charge limit for
the charge limit to 500 g. (See “HC hydrocarbons in commercial refriger-
Charge - Limit Increase Approved in ation cases would need to be adopted
Interim IEC Vote,” Accelerate America, by standards bodies, including UL ,
August 2018.) ASHR AE and the Environmental
Protection Agency, as well as ICC and
That was followed by the approval from state building codes, before it would go
the SC61C subcommittee in October at into effect. MB & MG
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Ammonia | CO2 | Hydrocarbons28 // Policy
T Three New
hree Democratic governors elected in the
U.S. midterm elections on November 6
have said they plan to join the U.S. Climate
Governors
Alliance, a bipartisan coalition of gover-
nors from 16 states and Puerto Rico committed to
reducing short-lived climate pollutants (SLCPs),
including HFCs.
T he gove r nors are Tony Eve rs of Wisconsin ,
J.B. Pritzker of Illinois and Gretchen Whitmer to Join U.S.
Climate
of Michigan.
The U.S. Climate Alliance formed in 2017 in reaction
to the absence of national leadership on climate
Alliance
change from the Trump administration. Alliance
states are committed to implementing policies that
advance the U.S. goal for the Paris Agreement, set
by the Obama administration, to reduce greenhouse
gas emission by at least 26%-28% below 2005 levels
by 2025.
Evers of Wisconsin, Pritzker of
“When the federal government withdrew the United
States from the Climate Agreement, I called on [then
Illinois and Whitmer of Michigan
Michigan] Governor Snyder to join hundreds of may- will enter group committed to
ors and a dozen governors across the nation in com-
mitting to lowering carbon emissions,” said Whitmer
cutting HFCs.
on her campaign website. “He refused, but I won’t. I
– By Michael Garry
am committed to fighting for our air and water.”
$9 TRILLION ECONOMY
T he U.S. Climate A lliance cur rently includes
California, Colorado, Connecticut, Delaware, Hawaii, The alliance said that strategies to reduce HFC
Maryland, Massachusetts, Minnesota, New Jersey, emissions “promote more energy-efficient systems
New York, North Carolina, Oregon, Rhode Island, that lower costs for businesses and households,
Vermont, Virginia, Washington and Puerto Rico. In support the leadership of U.S. businesses develop-
total, the alliance represents 40% of the U.S. popula- ing alternatives to HFCs, and increase the need for
tion and a $9 trillion economy, greater than the third skilled technicians and system designers.”
largest country in the world.
The action by the states stands in contrast to
A lready, four of the states in the alliance – the unwillingness to date by the Trump admin-
California, New York, Maryland and Connecticut – istration to refe r the K igali A me ndme nt on
have announced plans to reduce HFC emissions. phasing down HFCs to the Senate for approval.
(See “Three States Follow California’s Lead on HFCs, “The only resort we have is to rely on the power
Accelerate America, October 2018.) of states’ rights,” wrote Alec Johnson, in his
RefrigerantHQ.com blog.
California, which has been the leader in this area,
passed a Cooling Act targeting HFCs in August. In addition to the wins at the state level in the mid-
New York, Maryland and Connecticut made their term elections, Democrats gained control of the
announcements in concert with the Global Climate U.S. House of Representatives, where they can
Action Summit in San Francisco in September. exercise oversight of the Environmental Protection
Agency. Newly elected House Democrats include
In June, the alliance committed to reducing emis- Alexandria Ocasio-Cortez of New York, who sup-
sions of SLCPs, including HFCs, which would provide ports transitioning to 100% renewable energy by
“outsized global climate benefits in the near-term, 2035, and Sean Casten of Illinois, who ran on a
along with significant health, agricultural, and eco- platform to fight climate change.
system benefits,” the group said. The alliance also
invited national and subnational jurisdictions, busi- There were electoral setbacks as well, notably
nesses and other actors to bring commitments to the failure of a carbon-tax initiative in Washington
reduce SLCPs to the Global Climate Action Summit. State. MG
Accelerate America // November - December 2018Policy // 29
U.S. F
ifteen U.S. states and the Section 608 update
District of Columbia last
month sent a letter to the The EPA’s proposed rule takes
U.S. Environmental aim at an update to Section 608
States
Protection Agency (EPA) “strongly of the Clean Air Act issued on
opposing” its proposed revisions November 18, 2016. Under the
to updated leak repair and mainte- update, the EPA ex tended the
n a n c e r e g u l a ti o n s t h a t we r e refrigerant management rules
Oppose
extended to HFCs. for supermarkets and industrial
facilities – originally designed
The states, mostly represented by for ozone-depleting substances
their attorneys general, include (ODS) – to common ODS sub -
Massachusetts, Delaware, Illinois, stitutes like HFCs. But in the
EPA
I owa , M a i n e , M a r y l a n d , N e w proposed rule the EPA would
Jersey, New York, North Carolina, revert to the original language of
O re g o n , Ve r m o n t , V i r g i n i a , Section 608, which pertains only
Wa s h i n g to n , a n d C a l i f o r n i a . to leak repair and maintenance of
Proposal
California was also represented ODS equipment.
by its Air Resources Board.
T he agency is also weighing
The states’ letter was issued on whether it should also rescind
November 15, the deadline the a d d i t i o n a l r e q u i r e m e n ts s e t
on HFC
EPA set to receive comments on for th in the 2016 rule per tain-
the proposed revisions. ing to HFCs, such as the pro -
vision requiring purchasers or
All of the states but Illinois, Iowa ha n dle rs to b e S e c tio n 6 0 8 -
Leaks
and Maine belong to the U.S. certified technicians.
Climate Alliance, which is commit-
ted to reducing short-lived climate The letter said the proposed rule
p ollu tants (SLCPs), inclu ding “reflects an arbitrary, capricious
HFCs, in the absence of federal a n d i n a d e q u a te l y e x p l a i n e d
leadership. (Illinois plans to join; departure from EPA’s 2016 Rule.”
see page 28.) Four of the states
in the alliance – California, New The letter also called the EPA’s
York, Maryland and Connecticut proposed rule “unlawful and mis-
– have announced HFC-reduction guided,” adding that the Clean
Fifteen states and the District of plans. (See “Three States Follow Air Act “gives EPA broad author-
Columbia urge the agency to stick C a l i f o r n i a ’s L e a d o n H F C s , ity to promulgate regulations to
Accelerate America, October 2018.) prevent the knowing ventilation
with Obama-era rule extending of both ODS refrigerants and their
ODS leak repairs to HFCs The let ter objected to the substitutes and to reduce ODS
EPA’s September pro - emissions to the lowest achiev-
– By Michael Garry p o s a l , c a l l e d " P r o te c t i o n o f able level.”
Stratospheric Ozone: Revisions
to the Refrigerant Management The letter also said the EPA had
Program’s E x tension to not “adequately analy zed the
Substitutes,” which the letter said costs and benefits of the pro -
would limit the scope of the EPA’s posed rule, including the signifi-
refrigerant management program cant public harm associated with
and “thereby increase emissions of increased emissions of green-
d a n g e r o u s c h e m i c a l s .”(S e e house gases and ODSs.”
“EPA Proposes to Rescind Leak
Repair Rules for HFC equipment,” By contrast, extension of appli-
Accelerate America, October 2018.) ance-maintenance and leak-re-
pair requirements to HFCs pro-
The States instead urged the EPA vides “a sensible and consistent
to withdraw the proposed rule and regulatory scheme that prevents
fully embrace the appliance-main- knowing ventilation and emis-
tenance and leak-repair provisions sions of both ODSs and danger-
that apply to high-GWP HFCs. ous ODS substitutes,” the letter
added. MG
November - December 2018 // Accelerate AmericaYou can also read
