## MEMORANDUM

To: Margaret Sheppard, U.S. EPA

CC: Rachel Schwartz, Sally Hamlin, Rebecca von dem Hagen, Bella Maranion, Cindy Newberg, U.S.

EPA

From: Kasey Knoell, Becky Ferenchiak, Jenny Tanphanich, Ed Carr, Mark Wagner, ICF International

Date: February 24, 2014

Re: Assessment of the Potential Impact of Hydrocarbon Refrigerants on Ground Level Ozone

Concentrations (EPA Contract Number EP

‐ W

‐ 10

‐ 031 Task Order 305, Task 01)

In response to technical direction received from EPA, ICF has prepared an assessment of the potential

impact on ground level ozone concentrations caused by release of hydrocarbon refrigerants across

refrigeration and air conditioning end uses. Refrigerant emissions were modeled from the U.S. EPA’s

Vintaging Model (VM_IO file_V4.4_11.6.12) and their impacts on ground level ozone were modeled

using the CMAQ model (version 4.7.1). Releases of isobutane and propylene were modeled in Los

Angeles, Houston, and Atlanta under three emissions scenarios: 1) all refrigeration and air conditioning

(ref/AC) end

‐ uses, 2) ref/AC excluding motor vehicle air

‐ conditioners (MVACs), and 3) ref/AC excluding

MVACs and chillers. A final scenario was modeled, in which limitations on the properties of

hydrocarbons (e.g., flammability) are considered to determine which end

‐ uses were likely to transition

to hydrocarbon refrigerants. The remainder of this memorandum summarizes the results of this

assessment. A quantitative analysis of the uncertainty levels can also be performed by undertaking

additional CMAQ simulations if requested by the EPA TOCOR.

Please contact Mark Wagner at 202

‐ 862

‐ 1155 with any questions or comments.2 

# Potential	Impacts	of	Hydrocarbon	Refrigerants

on	Ground‐Level	Ozone	Concentrations

1 Executive Summary

Hydrocarbons are increasingly being considered for use in a number of refrigeration and air

‐ conditioning

(ref/AC) end

‐ uses. Although hydrocarbons have a low global warming potential (GWP) and are thus

desirable alternatives to commonly used hydrofluorocarbons (HFCs), there is concern that use of

hydrocarbons could negatively impact local air quality due to their high maximum incremental reactivity

(MIR) values.

In order to evaluate their potential impact, three conservative hydrocarbon emission scenarios and one

more realistic scenario were analyzed. The first three evaluate emissions of propylene and isobutane

first from the entire refrigeration and air conditioning sector, second excluding motor vehicle air

conditioning, and third excluding motor vehicle air conditioning and chillers. A fourth scenario,

evaluating emissions of a mix of propylene, isobutane, and propane, was developed based on SNAP

hydrocarbon applications and UL Standards and represents a more realistic transition to hydrocarbons.

The hydrocarbon emissions from these scenarios were estimated based on U.S. EPA’s Vintaging Model,

and their potential contributions to ozone concentrations were assessed using U.S. EPA’s Community

Multiscale Air Quality (CMAQ) model.

CMAQ modeling was performed for April through the end of September, as these months presented the

largest releases of hydrocarbon refrigerant as well as weather conditions favorable for ozone

formation. The ozone concentrations were estimated for the Atlanta, Houston and Los Angeles regions,

due to their distinctive geographic setting and chronic high levels of ground level ozone, and then scaled

for national emission estimates. The results of the CMAQ modeling indicated that hydrocarbon

refrigerants under the most conservative scenario could potentially increase ground level ozone by up to

9% compared to the national ozone standard, but less than a 0.2% increase under the most realistic

scenario.

The analysis performed is based on several assumptions and projections that cannot be known with

certainty at this time. These limitations are associated with both the unknown market penetration of

alternatives and climate conditions, among other factors.



## 2 Introduction

Ozone

‐ depleting substances (ODS) such as CFC

‐ 12, R

‐ 502, and HCFC

‐ 22 were historically used across the

refrigeration and air

‐ conditioning sector. Since identifying the damaging nature of CFCs and HCFCs, EPA

moved swiftly to transition to alternatives. The phaseout of CFCs in 1996 and continued phasedown of

HCFCs, has led the U.S. EPA Significant New Alternatives Policy (SNAP) program to review and approve a

number of potential substitutes to these ODS. In particular, hydrocarbon refrigerants, which have zero

ODP and low GWP, have already been recently approved for smaller refrigeration applications (e.g.,

domestic refrigeration, small retail food refrigeration, and vending machines) and have the potential to

be used more broadly across the refrigeration and air

‐ conditioning sector. Compared to the HFCs and

HCFCs currently in use, which have high GWPs, hydrocarbons have the potential to significantly reduce

climate impacts from the refrigeration and air conditioning sector.

Although the use of hydrocarbons could potentially mitigate greenhouse gas (GHG) emissions, it could

also potentially contribute to increased levels of ground level ozone. Hydrocarbons have high MIR3 values, and may influence local air quality if emitted in sufficiently high quantities. Table 1 provides a

summary of the propensity of these refrigerants to form tropospheric ozone. 1

Table 1: Propensity of Refrigerants to Form Tropospheric Ozone

Compound North America Maximum Incremental

Reactivity (MIR) Scale

(g

‐ O 3 /g

‐ substance) Europe POCP Scale a

(Relative Units)

HCFC

‐ 22 <0.1 0.1

HFC

‐ 134a <0.1 0.1

Propylene 11.57 112

Ethane a 0.28 12

Isobutane 1.34 31

Propane 0.56 18

Ethylene 9.07 100

Source: IPCC 2005

a The POCP value is the ozone creating potential of a compound relative to ethylene (ethene), expressed as

an index where ethylene

= 100.

b EPA uses the reactivity of ethane as the threshold for determining whether a compound has negligible

reactivity. Compounds that are less reactive than, or equally reactive to, ethane under certain assumed

conditions may be deemed negligibly reactive and therefore suitable for exemption from the definition of

a VOC (EPA 2012).

It should be noted that EPA is currently considering exempting certain hydrocarbons in certain end

‐ uses

from the ban on venting of refrigerant under §608 of the Clean Air Act. In order to evaluate the potential

impact of the release of hydrocarbons during disposal, ICF modeled conservative and realistic

hydrocarbon emission scenarios from the refrigeration/AC sector and assessed their impacts on ground

‐

level ozone, taking into consideration this revision to the end

‐ of

‐ life management requirement.

The remainder of this report summarizes the methodology used and results in the following order:

 Section 3: Hydrocarbon Emission Scenarios

 Section 4: Impact on Ground

‐ Level Ozone Concentrations

 Section 5: Analysis Limitations

 Section 6: Summary of Findings

 Section 7: References

1 Reactivity scales rank the propensity of organic compounds to form ozone. The MIR scale assesses their

contributions to the photochemical ozone formation in urban plumes and is reflective of its use in North America,

where ground

‐ level ozone formation is considered an urban issue. In contrast, the POCP scale addresses long

‐

range trans

‐ boundary formation and transport of ozone and was developed for use in Europe, where ground

‐ level

ozone formation occurs on the regional scale in multi

‐ day episodes (IPCC 2005). As the MIR scale is more

applicable to conditions within the United States, the remainder of this report references the MIR scale.4 

## 3 Hydrocarbon Emission Scenarios

Under this analysis, isobutane and propylene were each modeled under three conservative emissions

scenarios for the refrigeration and air conditioning sector. A fourth, more realistic emissions scenario

was also modeled, which considered more likely transitions to a variety of hydrocarbon refrigerants (i.e.,

isobutane, propylene, and propane) by end

‐ use in the sector. The four emission scenarios considered

are as follows:

1) Scenario 1: the entire ref/AC sector : chillers, motor vehicle air conditioners (MVACs) (i.e., light

‐ duty trucks and vehicles, trains, transit buses, school buses, and tour buses), residential and light

commercial AC and heat pumps, 2 retail food, 3 cold storage warehouses, industrial process

refrigeration, refrigerated transport, and household refrigeration and freezers;

2) Scenario 2: the ref/AC sector excluding MVACs ;

3) Scenario 3: the ref/AC sector excluding MVACs and chillers; 4 and

4) Scenario 4: the ref/AC sector for end

‐ use applications in which a SNAP submission has been

received for a hydrocarbon or in which a UL Standard addressing flammable refrigerant is in

place. See Appendix B for more information on the end uses included in this scenario.

In order to estimate their potential impact on ground

‐ level ozone concentration, the national scale

hydrocarbon emissions from each scenario were estimated using EPA’s Vintaging Model (VM). 5 These

national emissions were then proportionally scaled to each urban area by population by county. For Los

Angeles, three counties were used representing about 4.4% of the U.S. population; for Houston, eight

counties representing about 2.0% of the U.S. population were used; and for Atlanta, ten counties

representing about 1.4% of the U.S. population were used. These county level emissions were then

spatially allocated to each emission grid cell based on population density. The remainder of this section

provides a summary of the methodology used to estimate the national inventory of hydrocarbon

emissions, as well as a description of each scenario considered.



### 3.1 Methodology for Emissions Estimates

The year 2030 was chosen as the analysis year for all scenarios, in order to conservatively estimate the

impact of hydrocarbons. The majority of non

‐ hydrocarbon equipment will have been retired by the year,

due to the lifetimes of equipment (i.e., 5 to 27 years). In addition, a 2030 nationwide emission inventory

was available for other emission sources and was used to estimate the baseline ozone concentration

(without hydrocarbon refrigerants). It was assumed that the hydrocarbon refrigerants would enter the

market in 2012, and reach 100% market penetration in 2030. Output from the VM is provided on an

annual basis; for the purposes of this analysis, the annual data was weighted on a monthly basis, and

2 The residential and light commercial AC and heat pumps end

‐ use includes the following applications: window AC

units, residential unitary AC, small commercial unitary AC, large commercial unitary AC, packaged terminal AC and

heat pumps (PTAC/PTHP), and water and ground source heat pumps.

3 The retail food end

‐ use includes the following applications: ice makers, small retail food systems, medium retail

food systems, and large retail food systems.

4 Chillers are large

‐ scale air conditioning systems for large commercial and institutional buildings, such as for office

buildings, hotels, hospitals, and the like.

5 EPA’s Vintaging Model estimates the annual chemical emissions from industry sectors that have historically used

ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. Within these industry sectors, there

are over 60 independently modeled end

‐ uses. The model uses information on the market size and growth for each

end

‐ use, as well as a history and projections of the market transition from ODS to alternatives. The model version

used in this analysis is VM_IO file_V4.4_11.6.12.5 assumed that 11.9% of annual emissions occurred during each month from April to August. Emissions of

refrigerant are reasonably anticipated to occur primarily during the warmer spring and summer months,

when air conditioning equipment is increasingly used. Emissions due to servicing MVACs are also

expected to be higher during the spring and summer, with up to 80% of emissions due to repairs

occurring April through August (MACS 2009). Furthermore, refrigerant emissions from servicing motor

vehicle air conditioning systems were estimated at 47% of annual refrigerant emissions from motor

vehicles (EPA 2008). This assumption was also applied for all scenarios to all stationary AC end

‐ uses

based on the assumption that seasonal emissions would follow similar patterns. Emissions of refrigerant

from refrigeration equipment were assumed to occur equally year

‐ round.

Smaller end

‐ uses (i.e., end

‐ uses with a charge size less than 200 kg) were assumed to have a 100%

release of refrigerant upon disposal. Disposal release rates for larger end

‐ uses (i.e., chillers, industrial

process refrigeration systems, and large retail food systems) and servicing release rates for all end

‐ uses

were assumed to remain consistent with current VM assumptions, due to the assumed regulations and

financial incentives for the end

‐ user.

Each state implements individual emission and VOC regulations that inhibit venting. For example,

Regulation 7:27

‐ 16.1a for New Jersey (which is a nonattainment area) requires the use of reasonably

available control technology for equipment. Venting would violate this regulation. Maryland implements

a regulation that states that a person may not cause or permit the discharge of VOC from any

installation constructed on or after November 15, 1992 in excess of 20 pounds (9.07 kilograms) per day

unless the discharge is reduced by 85 percent or more overall. In addition to state regulations, industry

standards also restrict venting. Under OSHA regulations, facilities are required to demonstrate that 25

percent of the lower flammability limit (LFL) would not be exceeded at any point during venting of

hydrocarbon refrigerants. Chillers and other large charge size commercial refrigeration systems do not

currently implement the proper engineering controls that would be needed to allow for safe venting.

The use of flares, stacks, or rapid emission controls may likely be required to meet these industry

standards. Equipment would have to be modified to incorporate these controls, or venting would not be

allowed. Furthermore, assuming 100% is vented during servicing of equipment is unrealistic from an

economic perspective. Even with a low cost refrigerant, such as propane or isobutane, venting a charge

size of over 1,000 grams still represents a significant cost and provides an incentive to collect refrigerant,

which also is in keeping with good maintenance and technician practices.

The reader is referred to Appendix A for a summary of detailed assumptions used in this analysis.



### 3.2 Conservative Emissions Scenarios

Hydrocarbons are currently being proposed for use in a wide range of ref/AC end

‐ uses. To estimate the

most conservative impact that releases of hydrocarbons could have on ground

‐ level ozone, the first

scenario considered under this analysis assumes release from the entire ref/AC sector. However, due to

the characteristics associated with hydrocarbons (e.g., flammability), this may not be realistic. To assess

more realistic, but still conservative scenarios, two additional scenarios were considered. All three

scenarios assume that the end

‐ uses would be replaced with either propylene or isobutane. Propylene

exhibits the highest MIR of hydrocarbons, and therefore represents the most conservative estimates.

Propylene is also a proxy for the hydrocarbon blend R

‐ 443A, a substitute refrigerant under evaluation

for use in residential air conditioning, because that blend contains more than 50% propylene. Isobutane

has the highest MIR of the saturated hydrocarbons under evaluation and was used as a conservative

proxy for isobutane, propane, and the hydrocarbon blend R

‐ 441A. R

‐ 441A contains more than 50%

propane, as well as isobutane and other saturated hydrocarbons.6 Table 2 presents the monthly emissions in 2030 which were assumed under Scenarios 1, 2, and 3. Under

each scenario, 100% of the emissions were assumed to occur from either isobutane or propylene. In

other words, the impact on local ozone concentrations were evaluated for six total CMAQ modeling

scenarios.

Table 2: 2030 National Refrigerant Emissions under Scenarios 1, 2, and 3

Month Scenario1 Emissions (MT)

(All Ref/AC) Scenario 2 Emissions (MT)

(No MVAC) Scenario 3 Emissions (MT)

(No MVAC or Chillers)

Isobutane or Propylene Isobutane or Propylene Isobutane or Propylene

January 8,065 5,894 5,793

February 8,065 5,894 5,793

March 8,065 5,894 5,793

April 13,404 9,356 9,140

May 13,404 9,356 9,140

June 13,404 9,356 9,140

July 13,404 9,356 9,140

August 13,404 9,356 9,140

September 8,065 5,894 5,793

October 8,065 5,894 5,793

November 8,065 5,894 5,793

December 8,065 5,894 5,793

Note: Emissions of isobutane and propylene are equivalent; shaded months indicate those used in the analysis.7 Figure 1 presents the percent contribution of isobutane and propylene emissions by end

‐ use under

Scenarios 1 through 3. As illustrated in these charts, residential AC end

‐ uses presented the most

significant source of emissions across all three scenarios.

Figure 1. Percent Contribution of End

‐ Use to Total Emissions under Scenarios 1

‐ 3

Note: Emissions under the residential and light commercial AC and

heat pumps end

‐ use (Res and Comm AC) consists of 43% from

residential unitary AC, 4% from window AC, 2% from small

commercial unitary AC, 0.2% from large commercial unitary AC, 0.2%

from PTACs, and 0.1% from water and ground source HPs (relative to

total emissions in Scenario 1). Emissions under the MVAC end

‐ use

consists of 15% from light

‐ duty vehicles, 14% from light

‐ duty trucks,

0.3% from school and tour buses, 0.1% from transit buses, and 0.1%

from trains (relative to total emissions in Scenario 1). Note: Emissions under the residential and light commercial AC and

heat pumps end

‐ use (Res and Comm AC) consists of 61% from

residential unitary AC, 6% from window AC, 3% from small

commercial unitary AC, 0.3% from large commercial unitary AC, 0.3%

from PTACs, and 0.2% from water and ground source HPs (relative to

total emissions in Scenario 2). Retail Ref

4%

Household

Ref

1%

IPR

4% Transport

Ref

9%

Dehumidif

ers

0% MVAC

30% Chillers

2% Res and

Comm AC

50% Cold

Storage

0% Scenario 1

Retail Ref

5%

Household

Ref

1%

IPR

6% Transport

Ref

13%

Dehumidif

ers

0% Chillers

2% Res and

Comm AC

72% Cold

Storage

1% Scenario 28 Note: Emissions under the residential and light commercial AC

and heat pumps end

‐ use (Res and Comm AC) consists of 63%

from residential unitary AC, 6% from window AC, 3% from small

commercial unitary AC, 0.4% from large commercial unitary AC,

0.3% from PTACs, and 0.2% from water and ground source HPs

(relative to total emissions in Scenario 3).



### 3.3 Realistic Emissions Scenario

In addition to the three end

‐ use scenarios, a fourth more realistic scenario (i.e., Scenario 4) was

developed in which hydrocarbons were only modeled in refrigeration and air conditioning equipment

for which a SNAP submission was received or for which there is a UL Standard in place regulating

flammable refrigerants. Furthermore, the type of hydrocarbon (i.e., isobutane, propylene, or propane)

or blend likely to be used in each end

‐ use was also considered. The reader is referred to Appendix B for

additional information regarding the assumptions used under this scenario. Estimated emissions for the

most realistic scenario are shown in Table 3.

Table 3: 2030 National Refrigerant Emissions of under Scenario 4

Month Scenario 4 Emissions (MT)

(“Most Realistic Scenario”)

Propane Isobutane Propylene

January 1,266 78 183

February 1,266 78 183

March 1,266 78 183

April 1,373 84 207

May 1,373 84 207

June 1,373 84 207

July 1,373 84 207

August 1,373 84 207

September 1,266 78 183

October 1,266 78 183

November 1,266 78 183

December 1,266 78 183

Note: Shaded months indicate those used in the analysis Retail Ref

5%

Household

Ref

1% IPR

7%

Transport

Ref

13%

Dehumidif

ers

0% Res and

Comm AC

73% Cold

Storage

1% Scenario 39 Figure 2 presents the percent contributions of each refrigerant and each end

‐ use to the total emissions

under the Scenario 4.

Figure 2. Percent Contribution to Total Emissions under Scenario 4

Note: Emissions under the residential and light commercial AC and

heat pumps end

‐ use (Res and Comm AC) consists of 67% from

window AC and 3% from PTACs (relative to total emissions in the

Scenario 4).



## 4 Impact on Ground Level Ozone Concentrations

Using EPA’s CMAQ photochemical model version 4.7.1, a simulation of the potential ground

‐ level ozone

impacts under the hydrocarbon emission scenarios summarized in the previous section was performed.

The remainder of this section describes the methodology and results of the CMAQ modeling, followed

by a comparison of the results to the national standards of ambient air quality.



### 4.1 Methodology

The projected emissions of isobutane and propylene under Scenarios 1, 2, and 3, and the mix of

isobutane, propylene, and propane under Scenario 4 described in Section 3 were input into the CMAQ

to predict impacts on the local air quality. Concentrations were only modeled from April through the

end of September, as these months presented the largest releases of hydrocarbon refrigerant (see Table

2 and Table 3), as well as warmer air temperature and longer period of sunlight which increase the

potential for ozone creation.

The maximum increase in 8

‐ hr ozone concentrations were estimated for the Atlanta, Houston and Los

Angeles regions. These three cities were chosen based on their distinctive geographic setting and

continuing and chronic problem with high levels of ground level ozone. Local refrigerant emissions were

scaled from the national emission estimates to estimate reasonable conservative impacts.

The simulation was performed using 2005 hourly meteorological data at 36

‐ km horizontal resolution

with 14 vertical layers to model the maximum increase in 8

‐ hour ground level ozone concentrations. The

model used the carbon bond 05 chemical mechanism which explicitly includes 156 chemical reactions

(EPA, 2010). The 2030 nationwide emission inventory (NHTSA, 2012), as previously mentioned, was

readily available and used to estimate the baseline ozone concentration (i.e., without hydrocarbon

refrigerant). Retail

Food

6%

Transport

Ref

22%

Househol

d Ref

2% Res and

Comm AC

70%

By End

‐ Use

Propane

83% Isobutan

e

5%

Propylen

e

12% By Refrigerant10 Split factors for use in the carbon bond 05 chemical mechanism for isobutane, propylene, and propane

were determined from the Emit Worksheet in the emitdb.xls workbook form. 6 The split factors and

related parameters used in processing the refrigerant emissions are presented in Table 4 below.

Table 4. Mass Fractions of CB05 Species per gram of Emitted Compound (g/g)

Compound Paraffin

(PAR) Molecular

Weight (g/mole) Olefins

(OLE) Molecular

Weight

(g/mole) Unreactive

(UNR) Molecular

Weight

(g/mole)

Isobutane 1.0 14.54 0.0

‐‐ 0.0

‐‐

Propylene 0.34 14.03 0.668 28.06 0.0

‐‐

Propane 0.5 14.70 0.0

‐‐ 0.5 14.7

Note: Paraffin compounds are saturated hydrocarbons. Paraffinic compounds consist only of hydrogen and carbon

atoms; all bonds are single bonds, and the carbon atoms are not joined in cyclic structures, but instead form an

open chain. Olefins are unsaturated chemical compounds containing at least one carbon

‐ carbon double bond.



### 4.2 CMAQ Results

Table summarizes the maximum increase in 8

‐ hour ground

‐ level ozone from the four scenarios for the

Los Angeles, Houston, and Atlanta regions.

Table 5. Maximum Increase in the Daily 8

‐ hour Ground Level Ozone from Hydrocarbon Refrigerants in

2030 for Three US cities

Refrigerant Type and Use

Scenario Cities

Los Angeles

8

‐ hr O 3 Maximum

Change

(ppb) Houston

8

‐ hr O 3 Maximum

Change

(ppb) Atlanta

8

‐ hr O 3 Maximum

Change

(ppb)

Isobutane

Scenario 1 0.72 0.15 0.05

Scenario 2 0.50 0.10 0.03

Scenario 3 0.49 0.10 0.03

Propylene

Scenario 1 6.61 0.96 0.56

Scenario 2 4.47 0.67 0.39

Scenario 3 4.37 0.66 0.38

Combination of Isobutane, Propylene and Propane (Scenario 4)

Scenario 4 0.15 0.03 0.01

ppb

= parts per billion; O 3 = ozone

In Los Angeles, isobutane under Scenario 1 resulted in a maximum increase in the 8

‐ hr ozone

concentration of 0.72 ppb. Propylene, as anticipated due to its high MIR, resulted in the most significant

increases of ground

‐ ozone concentrations; under Scenario 1, results for the Los Angeles region show

6 The Emit Worksheet in the emitdb.xls form is available at: http://www.engr.ucr.edu/~carter/emitdb/

.11 that the maximum increase in the 8

‐ hr ozone concentration is 6.61 ppb. Releases of isobutane and

propylene under Scenarios 2 and 3 each show similar patterns to Scenario 1, but with smaller increases.

Scenario 4 (i.e., the “most realistic” scenario) resulted in a peak 8

‐ hr ozone increase of just 0.15 ppb for

Los Angeles. These relatively small increases in ozone are about 75% associated with the use of

propylene as a refrigerant and 21% from propane under this scenario (this is true of Scenario 4 under all

locations). For all four scenarios, Los Angeles showed the largest ground

‐ ozone concentration increases

of all three cities. Figure 3 shows the maximum increases and spatial extent of the 8

‐ hour ozone

concentration increase for isobutane Scenario 1, propylene Scenario 1, and Scenario 4 for Los Angeles.

In these figures, yellow, orange, and red shading represent modeled changes in ozone concentrations.

Figure 3. Maximum 8

‐ hour Ozone Increase for Los Angeles in 2030

(Clock

‐ wise from Left: Scenario 1 Isobutane, Scenario 1 Propylene, and Scenario 4)12 In Houston, isobutane under Scenario 1 resulted in a maximum increase in the 8

‐ hr ozone

concentration of 0.15 ppb. For the propylene Scenario 1, results for the Houston region show that the

maximum increase in the 8

‐ hr ozone concentration is 0.96 ppb. Releases of isobutane and propylene

under Scenarios 2 and 3 each show similar patterns to Scenario 1, but with smaller increases. Scenario

4 (i.e., the “most realistic” scenario) resulted in a peak 8

‐ hr ozone increase of just 0.03 ppb for

Houston.

Figure 4 shows the maximum increases and spatial extent of the 8

‐ hour ozone concentration increase

for the isobutane Scenario 1, the propylene Scenario 1, and Scenario 4 for Houston. In these figures,

yellow, orange, and red shading represent modeled changes in ozone concentrations.

Figure 4. Maximum 8

‐ hour Ozone Increase for Houston in 2030

(Clock

‐ wise from Left: Scenario 1 Isobutane, Scenario 1 Propylene, and Scenario 4)13 In Atlanta, isobutane under Scenario 1 resulted in a maximum increase in the 8

‐ hr ozone

concentration of 0.05 ppb. For the propylene Scenario 1, results for the Atlanta region show that the

maximum increase in the 8

‐ hr ozone concentration is 0.56 ppb. Releases of isobutane and propylene

under Scenarios 2 and 3 each show similar patterns to Scenario 1, but with smaller increases. Scenario

4 (i.e., the “most realistic” scenario) resulted in a peak 8

‐ hr ozone increase of just 0.01 ppb for

Atlanta.

Figure 5 shows the maximum increases and spatial extent of the 8

‐ hour ozone concentration increase

for the isobutane Scenario 1, the propylene Scenario 1, and Scenario 4 for Los Angeles. In these figures,

yellow, orange, and red shading represent modeled changes in ozone concentrations.

Figure 5. Maximum 8

‐ hour Ozone Increase for Atlanta in 2030

(Clock

‐ wise from Left: Scenario 1 Isobutane, Scenario 1 Propylene, and Scenario 4)



### 4.3 Comparison to National Ambient Air Quality Ozone Standard

The current national ambient air quality 8

‐ hour average ozone standard (NAAQS) is 75 ppb. The

maximum change in ozone concentrations caused by each refrigerant across all scenarios and locations,

and comparison to the national standard, is summarized in Table 6.14 Table 6. Comparison of Maximum Increase in 8

‐ hour Ozone Concentration Relative to the NAAQS

Refrigerant Type (Scenario) Maximum

8

‐ hr O 3 Increase (ppb) Percent Increase over

75 ppb 8

‐ hr National Ambient Air

Quality Ozone Standard

Isobutane (Scenario 1) 0.72 1%

Propylene (Scenario 1) 6.61 9%

Most Realistic Mix (Scenario 4) 0.15 0.2%

ppb

= parts per billion; O 3 = ozone

With the exception of Los Angeles, all of the three regions are forecast to be in attainment of the

current 8

‐ hr 75 ppb ozone standard by 2030. Currently, the South Coast is demonstrating attainment by

2023 for the 1997 8

‐ hr standard of 85 ppb. The deadline for demonstrating attainment of the 75 ppb

standard is December 2015 and regions must show compliance by 2032.



## 5 Limitations of this Analysis

The analysis described above is based on numerous assumptions and projections that cannot be known

with certainty at this time. The following discussion recognizes these uncertainties and indicates various

factors that have potential to impact and change the results of this analysis.



### 5.1 Market Modelling

 The market penetration assumptions used for this analysis assume hydrocarbons will be the sole

replacement for HFCs across the refrigeration and air

‐ conditioning sector. However, the

introduction of additional substitutes could potentially lower the penetration of hydrocarbons

into the market, thus decreasing the emissions and ground level ozone impacts of

hydrocarbons.

 EPA’s Vintaging Model provides emissions estimates up to 2050. However, projected estimates

are based on assumptions developed using current data and expert opinion regarding the near

future, and cannot be reasonably expected to reflect future emissions with 100% accuracy.

Changes that may occur in the distant future (i.e., post

‐ 2020), such as regulatory measures and

market events, will likely impact future emissions.

 Scenarios 1 through 3 in EPA’s Vintaging Model does not account for reductions in emissions

that may occur as a result of using hydrocarbons as a replacement for HFCs. Factors such as

refrigerant price, charge size restrictions, and advancements in leak

‐ tightness of ref/AC systems

are not adjusted for in the modeling. Consequently, hydrocarbon emission projections are

considered to be conservative.

 Although 2030 was chosen at the analysis year for this assessment because the hydrocarbon

refrigerants were assumed to reach maximum market penetration by this time, some larger

pieces of equipment with long lifetimes (i.e., lifetimes larger than 18 years) would not yet have

reached end

‐ of

‐ life by 2030. Therefore, the effects of the disposal emissions from these pieces

of equipment are not factored into this analysis. It should also be noted, however, that the

remaining refrigerant charge in these large pieces of equipment are also more likely to be

recovered given its economic value.



### 5.2 Air Quality Modelling15  The air quality modeling used in this study was at 36

‐ km resolution, as used in the Corporate

Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2017–2025,

Final Environmental Impact Statement (NHTSA, 2012). In Appendix E: Air Quality Modeling and

Health Impacts Assessment for Proposed Corporate Average Fuel Economy Standards for

Passenger Cars and Light Trucks: Model Years 2017–2025

, the model performance evaluation is

discussed stating that, "EPA evaluated CMAQ model performance for the 2005 base year as part

of the air quality modeling analysis to support the rulemaking for light

‐ duty vehicle greenhouse

gas emissions standards for MYs 2012

‐ 2016 (EPA, 2010). Overall, the performance for the 2005

modeling platform was similar to that for other national

‐ and regional

‐ scale applications, and

the model was able to reproduce historical concentrations of ozone and PM2.5 with low bias

and error results." All meteorological and emission inventory files were taken directly from the

NHTSA study. The only modification was to include the emission changes due to refrigerants, as

discussed in Section 2. Higher grid resolution (i.e., smaller grid cell) may potentially show higher

ozone concentrations due to the mixing of air at the coarser resolution, however most

refrigerant emissions are widely dispersed over a grid cell, so the effect of this limitation on the

overall modeling results is likely minimal.

 Further climate change impacts will result in region

‐ specific changes that may impact ozone

production rates. For example, increase (or decrease) in local cloud cover would lead to

decrease (increase) local photolysis rates, resulting in reduced (increased) ozone production.

 It is possible that larger impacts of VOC concentrations could have been noted if additional VOC

‐

limited areas in the U.S. were modeled (e.g., Chicago). However, it is very unlikely that impacts

for those areas would exceed that for Los Angeles. While the higher ozone concentrations

observed in Los Angeles (8

‐ hour ozone [2008] design value is 112 ppb; Chicago is 77 ppb)

depends upon the local VOC

‐ to

‐ NO

x ratio, it tends to be more sensitive to a given change in VOC.

Therefore, while it is possible that a higher ozone value may have occurred in Chicago than Los

Angeles on a given day, it is more likely that the Los Angeles area will have experienced a

greater change in ozone due to increased VOCs over the course of the ozone season.

 The changes in standards for other pollutants such as air toxics or criteria pollutants could affect

the ozone precursor emissions. For example, EPA recently lowered the 1

‐ hour NO 2 standard to

100 ppb and could potentially lower this value again in the future to 80 ppb as initially proposed.

In order to meet this standard, significant NO

x emission reductions may be required, thus

impacting the potential production of ground level ozone. The ozone air quality standard may

be lowered in the future (historically the standard has been lowered a number of times) and

would require additional reductions of ozone precursor emissions, which could increase the

importance of hydrocarbon refrigerants to the production rate for ozone. 7



## 6 Summary of Findings

From the analysis summarized in the previous sections of this report, it is concluded that non

‐

attainment resulting from hydrocarbon refrigerant emissions is not likely to be a major concern for local

air quality. Hydrocarbon refrigerants could potentially increase ground level ozone by less than 1%

7 In August 2012, EPA published their first external draft policy assessment for the review of the ozone standard

which suggested some potential lowering of the ozone standard; however no final action has occurred on a new

primary ozone standard.16 under Scenario 4, but up to a 9% increase on a given day for the most reactive hydrocarbons (propylene)

in the most extreme case. However, in most cases this upper bound level of increase is not likely, as

most ozone nonattainment areas are not VOC

‐ limited (i.e., the formation of ozone in these areas are

not by limited by VOC emissions, but by other compounds such as nitrogen oxides [NO

x ]). In fact,

Scenario 4, the “most realistic” scenario for hydrocarbon refrigerant emission usage, showed a less than

0.2% increase in ground level ozone for the most extreme case. Future changes that could alter these

findings include: changes in cloud cover from global warming which could increase or decrease ground

level ozone production; and future emission reduction measures that may be required to reduce ozone

precursors which would could increase the relative importance of the hydrocarbon refrigerants on the

production of ground level ozone.



## 7 References

Intergovernmental Panel on Climate Change (IPCC). 2005. Safeguarding the Ozone Layer and the Global

Climate System: Issues Related to Hydrofluorocarbons and Perfluorocarbons. Available at:

http://www.ipcc.ch/publications_and_data/ _safeguarding_the_ozone_layer.htm

.

MACS. 2009. Email communication between Elvis Hoffpauir, MACS and Karen Thundiyil, EPA. 10 March.

National Highway Traffic Safety Administration (NHTSA), 2012. Final Environmental Impact Statement,

Corporate Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2017–2025,

Appendix E: Air Quality Modeling and Health Impacts Assessment. NHTSA, July 2012.

United States Environmental Protection Agency (EPA). 2008. Vintaging Model, Version VM IO File v4.2

10

‐ 07

‐ 08.

United States Environmental Protection Agency (EPA). 2010. Operational Guidance Document CMAQ

4.7.1 Available at www.cmascenter.org.

United States Environmental Protection Agency (EPA). 2012. “Air Quality: Revision to Definition of

Volatile Organic Compounds—Exclusion of trans

‐ 1,3,3,3

‐ tetrafluoropropene.” Final Rule. 40 CFR Part 51.

EPA

‐ HQ

‐ OAR

‐ 2010

‐ 0605; FRL

‐ 9679

‐ 2. June 22, 2012. Available online at:

http://www.gpo.gov/fdsys/pkg/FR

‐ 2012

‐ 06

‐ 22/html/2012

‐ 15347.htm17 

## Appendix A

Table A

‐ 1. Scenarios 1, 2, and 3 Isobutane and Propylene Modeling Assumptions

SNAP End

‐ Use Vintaging Model End

‐ Use Size Classification Annual Leak Rate Disposal Release

Rate^

Motor Vehicle Air

Conditioning (MVAC) MVAC Light

‐ duty Vehicle* Small 18% 100%

MVAC Light

‐ duty Trucks* Small 18% 100%

School & Tour Buses* Small 10% 100%

Transit Buses* Small 10% 100%

Trains* Small 2% 100%

Chillers Centrifugal Chillers** Large 2% 10%

Positive Displacement

Chillers** Large 1.5% to 2.5% 10%

Screw Chillers** Large 1% 10%

Scroll Chillers** Large 0.5% 10%

Reciprocating Chillers** Large 1.5% 10%

Industrial Process

Refrigeration Systems Industrial Process

Refrigeration Large 3% to 7.5% 10% to 20%

Cold Storage

Warehouses Cold Storage Large 8% to 16% 10%

Retail Food

Refrigeration Large Retail Food Large 14% to 28% 10%

Medium Retail Food Small 8% to 15% 100%

Small Retail Food Small 1% 100%

Ice Makers Small 5% 100%

Refrigerated

Transport Refrigerated Transport Small 15% to 20% 100%

Household

Refrigerators and

Freezers Refrigerated Appliances Small 1% 100%

Residential

Dehumidifiers Dehumidifiers Small 0.50% 100%

Residential and Light

Commercial Air

Conditioning and

Heat Pumps Window Units Small 0.65% 100%

Residential Unitary AC Small 11% 100%

Small Commercial Unitary

AC Small 9% 100%

Large Commercial Unitary

AC Small 8% 100%

Water & Ground Source

HPs Small 4% 100%

Packaged Terminal

AC/Packaged Terminal

Heat Pumps (PTAC/PTHP) Small 4% 100%

^The assumed disposal release rates are dependent upon the size of the equipment. Equipment that is considered small (i.e.,

with a charge size less than 200 kg) are assumed to have a 100% release of the charge upon disposal. Equipment that is

considered large (i.e., a charge size larger than 200 kg) has a disposal release rate that is consistent with what is currently

assumed in the Vintaging Model for HFC refrigerants.

*Excluded from Scenario 1 and Scenario 2

**Excluded from Scenario 2

## Appendix B

Table B

‐ 1: Scenario 4 Modeling Assumptions

SNAP End

‐ Use Vintaging

Model End

‐

Use HC* Market

Penetration** Charge Size Annual

Leak

Rate Disposal

Release

Rate

Retail Food

Refrigeration Medium

Retail Food Propane 100% 1,500 to 12,500 g 8% to

15% 100%

Small Retail

Food*** Propane 33% 150 g 1% 100%

R

‐ 441A 33% 150 g 1% 100%

Isobutane 33% 150 g 1% 100%

Ice Makers Propane 100% 50 g 5% 100%

Refrigerated

Transport Refrigerated

Transport R

‐ 441A 100% 2,130 g 15% to

20% 100%

Household

Refrigerators

and Freezers Refrigerated

Appliances Isobutane 33% 50 g 1% 100%

Propane 33% 50 g 1% 100%

R

‐ 441A 33% 50 g 1% 100%

Residential

Dehumidifiers Dehumidifiers None None None 0.50% 100%

Residential and

Light

Commercial Air

Conditioning and

Heat Pumps Window

Units R

‐ 441A 33% 1 kg 0.65% 100%

R

‐ 443A 33% 1 kg 0.65% 100%

Propane 33% 1 kg 0.65% 100%

Water &

Ground

Source HPs R

‐ 443A 33% 1 kg 4% 100%

Propane 33% 1 kg 4% 100%

R

‐ 441A 33% 1 kg 4% 100%

PTAC/PTHP R

‐ 443A 33% 1 kg 4% 100%

R

‐ 441A 33% 1 kg 4% 100%

Propane 33% 1 kg 4% 100%

*R

‐ 441A is a blend consisting of propane, n

‐ butane, isobutane, and ethane; R

‐ 443A consists of propylene, propane, and

isobutane. For purposes of this assessment, both R

‐ 441A and R

‐ 443A were considered to only contain the components included

in this analysis, propane, isobutane, and propylene.

**In the absence of market penetration projections, it was assumed that the market was equally divided by the number of

hydrocarbon substitutes available for each end

‐ use.

***Water coolers and vending machines were assumed to be included under small retail food.