### Date: May 6, 2015 By: Joe Sanders



# SNAP

— Rule 20

Proposal to prohibit certain
high

- GWP HFC alternatives

Implications for small and large CRE manufacturers



# Topics

 Terms and Definitions

 Summary

- Rule 20

 Refrigerant Options

 System Component Availability

 Agency Certification

 Energy Implications

 Recommendations

 Contact Information

## Implications
SNAP Rule 20 Page 2



# Terms and Definitions

Stand

- Alone or Self

- Contained Refrigeration Systems (1)(2) Integrate all refrigerating components within their structures

Low charge sizes 0.150

- 0.750 kg (5

- 30 oz)
Most often containing HFC

- 134a, or R

- 404A 

### Remote Refrigeration Systems

Condensing Unit Systems (1)(3)Consist of one or two compressors, one condenser, and one receiver assembled into the condensing unit system; linked to one or moredisplay case(s) in the sales area through a piping network.
Most often containing R

- 134a, or R

- 404A
Refrigerant charges from 0.5

- 20 kg (1

- 40 lb)


### Multiplex Rack Systems

Remote refrigeration systems consisting of racks of multiple compressors contained typically in a machinery room; linked to multiple display cases in the sales area through extensive piping. Condensers are usually remotely located, such as on the roof above the machinery room.


### End Use Applications
New Equipment
Commercial refrigeration equipment (CRE) designed and assembled by an originalequipment manufacturer (OEM) and offered for sale as “new”. The end product generally conforms to applicable safety (UL471), sanitation (NSF

- 7) and energy conservation 10 CFR Part 431, Subpart C standards.



### Retrofit
Used and currently in

- service commercial refrigeration equipment where the original refrigerant as designed has been replaced by an EPA SNAP approved acceptable alternative. The retrofit may be initiated based on economical or service (down or inoperable equipment) needs.



### Note:
(1) Scope of analysis is limited to Stand

- Alone and “simple” Remote Condensing Unit Systems only. (2) DOE Equipment Class, “condensing unit configuration”

- (SC). (3) DOE Equipment Class, “condensing unit configuration”

- (RC). 

### Stand

- Alone Equipment



## R

- 134a

### Page 3



## Proposal to prohibit certain high

- GWP HFC alternatives



# Summary

— Rule 20

This action proposes to change the status of a number of substitutes that were previously listed as acceptable, based on information showing that other substitutes are available for the same uses that pose lower risk overall to human health and/or the environment. Specifically, this action proposes to modify the listings for certain hydrofluorocarbons refrigerants (R

- 134a and R

- 404A) in various end

- uses including refrigeration. The current proposal has the following implementation schedule:

 R

- 404A New & Retrofit Equipment Stand

- Alone & Remote 1/1/2016

 R

- 134a New Equipment Only Stand

- Alone Only 1/1/2016



# Refrigerant Options

— Current

ASHRAE 34

- 2014 

### A1 A1 A2L A3

Refrigerant Designation Non

Flammable

Non

- Toxic Non

Flammable

Non

- Toxic Mildly

Flammable

Non

- Toxic Highly

Flammable

Non

- Toxic

Refrigerator

Designation: HFC, R

- 134a HFO, R

- 450A HFO, R

- 1234yf HC, R

- 600a HC, R

- 290

GWP: 1430 approx. 604 4 3 3

SNAP Status: Final Rule

4/18/1994 Notice 29

10/21/2014 In Process ? Rule 19 4/10/2015 Rule 17

12/20/2011

Freezer

Designation: HFC, R

- 404A HFO, R

- 448A HFO, HDR110 HC, R

- 290

GWP: 3922 approx. 1300 <150 3

SNAP Status: Final Rule

4/18/1994 In Process ? ASHRAE #?

SNAP? Rule 17

12/20/2011

Design Restrictions

Charge Limit: None None 500 grams (17.64 oz) 150 grams (5.29 oz)

Enhanced Component Safety Requirements: None None Switches Compressor

Heaters
Controls Switches

Compressor

Heaters
Controls

Extra Safety Testing: None None UL471

- SB UL471

- SB

Service Technicians

Training: No Special

Training No Special

Training Requires

Special Training Requires

Special Training

## Implications
SNAP Rule 20 Page 4



# System Component Availability

Basic Stand

- Alone System

Compressor:



###  Three primary US manufacturers / private labels.



###  Limited R

- 290 model selection above 1/2 HP.



###  No compressor availability
for “HFO” blends.



###  No documentation available for R&D of systems using a HFO refrigerant.
Evaporator:



###  Evaporator coils require redesign for each CRE modelusing a HFO blend refrigerant in order to maintain optimum energy efficiency. Reconfiguration is complex. Expansion Valves and Capillary Tubes, etc...:



###  Expansion valves and capillary tubes require resizing for all alternative refrigerants to maintain energy efficiency, Sizing and configuration are complex.



###  Valve and other related part manufacturers lack documentation for sizing components for use with HFO blends.



###  Limited R

- 290 selections, no HFO availability,



###  Currently limited or no application help available.

Condenser:



###  Condenser coils may require redesign for each CRE model using R

- 290 as refrigerant to deal with a limited maximum refrigerant charge of 150 grams (5.29 oz).



### Remote Refrigeration Systems

Condensing Unit Systems



###  Design and component availability are typical of the stand

- alone system from above.



### Note:

Vendors to commercial refrigeration equipment OEMs appear to be ill

- prepared for any transition from current HFC refrigerants to approved alternatives. (i.e. HFO
blends, R

- 450A & R

- 448A) Most have indicated that they will lack commerciallyavailable product into much of the 2016 year and will also lack significant R&D support for most of 2015. Vendors appear willing to only service their larger customers. Evaporator Condenser

Compressor

TXV or Cap. Tube Drier

### Page 5



## Proposal to prohibit certain high

- GWP HFC alternatives



# Agency Certification

All new or revised (major design change) cabinet
models must be evaluated for conformance to the applicable safety, performance, sanitations and energy conservation standards for the authority having jurisdiction. All Basic Models must be tested under the direct supervision of the certifying agency.



### Test Standards for Evaluating Commercial Refrigerators and Freezers

ANSI/UL471

- 2014, Standard for Safety

ANSI/NSF 7

- 2014, Performance / Sanitation

ASHRAE 72

- 2014, Energy

In addition to the standard tests listed above, refrigerators and freezers should be evaluated for satisfactory customer performance in end use applications. This includes the following:

1) Life Testing of both Cabinets and Components

2) Suitability of Equipment for Application

3) Agency Approval of Vendor Components

Testing is a long and complex operation and requires four to eight weeks per Basic Model. For companies without an accredited laboratory, the task can become costly and time consuming with limited industry

recourses.

## Implications
SNAP Rule 20 Page 6



# Energy Implications

Impact Analysis of DOE’s March 28, 2017 Final Rule

All refrigerant changes affect the operating efficiency of the systems using the new gas. Some systems require engineering time to bring those efficiencies back to par or better, but all require work as there is no such thing as a true “drop

- in”.
Because of the possibility for DOE Enforcement Testing and the margin of error being so small to attain compliance, all products transitioning from HFC refrigerants to an approved alternative will require validation testing to ensure compliance to applicable energy efficiency specifications.

Some Affected Equipment Classes

2010

- 2017

VCT.SC.M VCT.RC.M

VCT.SC.L VCT.RC.L

VCS.SC.M VCS.RC.M

VCS.SC.L VCS.RC.L
Refrigerator / Freezer

How do the proposed and final federal regulations affect CRE manufacturers:



###  SNAP Rule 20 affects nearly 100% of the models comprising the available products for sale by the CRE industry. Of the affected products, All Stand

Alone models using HFC R

- 134a and R

- 404A will require redesign and testing. Nothing is a given despite claims of interested parties.



###  DOE 2017 affects a subset of the models available for distribution and sale in commerce from the CRE industry. This subset is derived from the fact that not all models are regulated by DOE, but that nearly all models using a HFC refrigerant will require redesign.

The sheer magnitude of a project scope;1) to conform to Department of Energyefficiency specifications by 3/28/2017 and 2) effect a refrigerant change compliant to the proposed SNAP rule by 1/1/2016, are beyond the available resource levels of companies both small and large. More time is needed for compliance. DOE’s regulations are final, EPA’s SNAP Rule 20 is currently only a proposal.

### Page 7



## Proposal to prohibit certain high

- GWP HFC alternatives



# Recommendations



# REFRIGERATION

1) R

- 404A New & Retrofit Equipment

Stand

- Alone & Remote 1/1/2020

2) R

- 134a New Equipment Only

Stand

- Alone Only 1/1/2022

3) Define “Lower GWP Limit” and hold for 10 years past HFC phase out date.
a) Refrigerators Set at 650 GWP

Hold till 2032.

b) Freezers Set at 1350 GWP

Hold till 2030.

4) Provide SNAP Approval “Acceptable” for
a) “HFO” Blends R

- 448A and R449A.
b) “HFO” Blend R

- 1234yf.

The CRE Industry is Not Ready for this Transition

### Traulsen

- ITW Food Equipment Group, LLC

4401 Blue Mound Road Fort Worth, TX 76106 

## Mary Dane Joe Sanders
Agency Approval Engineer Principal Engineer (800) 825

- 8220 x6741 (817) 625

- 9671 x6537 Cell: (817) 458

- 2165 Cell: (817) 528

- 3762 mdane@traulsen.com jsanders@traulsen.com