EPA Meeting

Commercial Refrigeration 

Equipment

19 September 2014
Agenda

 Introductions

 Industry concerns – Commercial refrigeration products

– Why January 1, 2016 is not practical

– Why CO2 and HCs are not ideal solutions for standalone 

products

– Why we need more alternatives

– Unintended consequences

 Other business

 Adjournment
Design Time for Refrigerant 

Changeover
1 year

• Refrigerant Review and Choice

2 years

• Compressor and Component Redesign

1 year

• Risk Assessment

5 years

• Prototype and Testing (agency, energy, life)

1 year

• Manufacturing Floor Redesign

1 year

• Training of Employee & Service Techs Handling

Flammable Choices

Total = 11 years
2 years

• Refrigerant Choices Availability

2 years

• Component Redesign

3 years

• Prototype and Testing (Agency, Energy, Life)

Non-Flammable Choices

Total = 7 years
 Redesign refrigeration circuit for different refrigerant

 Redesign circuits and components to be spark proof

 Life testing of new compressors and other parts for internal 

approval

 Field testing of units in actual kitchen applications

 Risk assessment for safety/occupational risks

Differences in Design Time
Case Studies
Standalone and remote case study

 231 models – all use R134a or R404a

– 129 self-contained (standalone)

– 102 remote

 Only 26 cases can use R290 – single system 

 ice cream hardening (-40F) freezers cannot use any EPA 

approved refrigerant in remote or self-contained

 48 open air cases – R290 systems will not fit

 CO2 will not pass DOE energy tests

 85 models will require UL/NSF testing – all require energy 

testing
Upright freezer closer look 

 19 self-contained models produced

– Single R290 refrigeration system – 6

– Dual R290 refrigeration system – 4

– Triple R290 refrigeration system – 5

– Quad R290 refrigeration system – 4

– CO2 systems will not meet DOE energy

 19 remote models must use R407A which has very high 

discharge temperature (~30F higher than R404A) so case 

applications will have to be limited. Also ~5% less efficient.
 In specific low-charge applications, supermarkets should be able to 

operate with a higher GWP refrigerants (including those delisted in the 

proposed rule)

– Specifically, in the primary loop of a secondary loop or cascade refrigeration system

 EPA should consider EU f-gas law encouraging secondary loop systems

– From Annex III of EU law: 

“Multipack centralised refrigeration systems for commercial use with a rated capacity of 40kW or more 

that contain, or whose functioning relies upon, fluorinated greenhouse gases with GWP of 150 or more, 

except in the primary refrigerant circuit of cascade systems where fluorinated greenhouse gases with a 

GWP of less than 1500 may be used”

 Secondary loop / cascade systems:

– Greatly reduced charge size

– Less leakage

– Result in a equivalent CO2 leak potential that is far less than a traditional rack system 

operating with the suggested substitutes

Supermarket Secondary Loop Systems
Comparison

 Traditional DX rack system operating with R-407A

– 3,000 lb charge = 6,321,000 lb CO2 equivalent

– Typical leak rate: 15 – 30%

– Annual direct LCCP: 948,150 – 1,896,300 lb CO2 equivalent

 Secondary loop / cascade system – R-404A / CO2

– Primary loop: 1,000 lb = 3,922,000 lb CO2 equivalent

– Secondary loops (MT/LT): 1,500 lb CO2

– Typical leak rate: 2% – 5% 

– Annual direct LCCP: 78,470 – 196,175 lb CO2 equivalent

Supermarket Secondary Loop Systems
Frozen, Stand-alone Propane Applications

 Maximum capacity 2000 Btu/h for 150 grams

 Suitable for single door, frozen vertical case

 6-door case would require 6 condensing units

– Allow reasonable capacity at startup and pull-down after defrost

– Requires control integration to synchronize condensing units defrost

– 6 times likelihood of condensing issue/maintenance

– Significant increase in assembly and test labor

– Greater level of difficulty in diagnosing problems caused by a single 

condensing unit

 May not be able to fit door cases (tall) through doors

– Much more difficult to remove and replace multiple condensing units

 Customer need for stand-alone case in remote condensing store

– Long refrigerant line runs are required for specific location of case

– Mobility required for the case (seasonal locations, product emphasis, etc.)

– Merchandising trials

– Customer prefers same refrigerant as their remote condensing
Testing and Certification 

Requirements
Testing and Certification Requirements When a 

Refrigeration System is Modified – Self Contained (SC)

 Changes to a refrigeration system (SC) will require that the 

manufacturer test and submit reports for safety and sanitation listings.

 Additional testing with a new system – reliability of the new parts, 

performance, and energy consumption (DOE).

 Reliability testing for a new compressor/condensing units can take 

several months but can be done concurrently with other testing 

(assumption is it would pass reliability testing requirements). 

Minimum requirements are 3000 – 4000 hour endurance test and 

minimum 6 month field trial.

 Testing must be done per standards – UL-471, NSF-7, ASHRAE-72, etc. 

These standards define specific test cell and SC case preparation 

requirements. Test cell temperatures, RH, air flow, case simulator 

temperatures, thermocoupling, etc. are defined in these standards.
Testing and Certification Requirements When a 

Refrigeration System is Modified – Self Contained (SC)

 Prepping the case for performance testing will vary 

depending on the size and style of case (1- 3 days)

 A good performance test to validate the charge and 

condensing unit size. (3 – 10 days)

 Compliance with NSF sanitation requirements. (2-5 days)

 Compliance with DOE requires that the case temperatures 

be adjusted to meet AHRI-1200 conditions. (2 – 5 days)

 Compliance with UL safety requirements. (5 – 10 days)

 Testing duration could range from “best case scenario” 2 

weeks to more realistic scenario of 3-4 weeks or beyond.
Testing and Certification Requirements When a 

Refrigeration System is Modified – Self Contained (SC)

 Dedicated resources (technician, engineer, test cell) must be assigned to 

complete work. A company that builds 150 self contained cases (smaller 

company) would experience the following (assuming an average of three 

weeks to complete each model):

 2250 days of testing for 150 SC models. This amount of time will consume a 

technician, engineer, and test cell. This time is dedicated to maintaining EPA 

compliance – no R&D work or customer development work.

 Customers with multiple test cells, technician, and engineers have an 

advantage in that they can throw more resources at EPA compliance. 

However this further impacts R&D work and customer development 

opportunities. 

 No new strides in efficient products will be made with the above resources 

during the time these resources are being consumed for EPA compliance. 

 Not all companies have access to internal test cells for this purpose.

 Third party test cells (UL and Intertek) are finite.

 Third party resources are dedicated to MANY tasks, not just EPA compliance.

 A larger company dedicating three test cells (CTDP or Satellite) and 

manpower to this task would need almost three years to complete just the 

EPA compliance testing.
Unintended Consequences
Unintended Consequences of Allowing Only 

Hydrocarbons and R744 for Standalone Equipment

 Hydrocarbons with multiple condensing units and transcritical

CO2 will draw more energy and be disallowed by the DOE 

eliminating equipment classes between the small capacity unitary 

refrigerators to the large remote supermarket systems.

 Retailors would be forced to buy these equipment classes as 

remote fixtures with condensing units located in another location

 These systems would then be field installed with much larger 

charges than what would be in a self-contained unit

 Leak rates for these field installed systems are around 10% like a 

supermarket system

 Leak rates for factory charged hermetically sealed systems are on 

the order of 0.5%
Unintended Consequences – A Realistic 

Scenario with a Convenience Store

 Small, convenience store with six 

merchandisers

– Two low-temp (LT), glass door vertical cases

– Three medium-temp (MT), open vertical cases

– One medium-temp, open island case

 Currently store chain buys self- contained (a.k.a., stand-alone) cases

 Refrigerant for s/c cases

– R-404A for LT, total charge = 2.6 lb

– R-134a for MT, total charge = 10.5 lb

 Leak rate of s/c cases

– Factory sealed and charged

– Average 0.5 percent leak rate

 Total annual direct emissions for store 

= 126 lb (57 kg) CO2eq

 Store can no longer procure s/c 

equipment or local codes will not allow 

flammable refrigerants—store moves 

to remote condensing system alternate 

 Refrigerant for remote cases (two 

condensing units, 1 LT & 1 MT)

– R-407A for LT, total charge = 20 lb

– R-407A for MT, total charge = 30 lb

 Leak rate of remote condensing system

– Field erected piping

– Average 10 percent leak rate

 Total annual direct emissions for store 

= 10,500 lb (4760 kg) CO2eq

 83 times greater direct emissions

Merchandisers Merchandisers

Merchandiser
 Limited test lab resources 

 Limited component availability

 Lack of experience with flammable refrigerants

 Limited trained service personnel

 Poses occupational and end user risks

 Increased costs to business operators and consumers

 Forces continued use of older, less-efficient repaired/used 

over purchase of newer, more efficient equipment

 Stifles R&D of other potential alternatives due to robbed 

resources

Unintended Consequences for 2016 Deadline
Conclusions
Conclusions

 EPA shouldn’t rush de-listing R-134a and R-404A

– Complex issue that requires redesign and testing of products

– Unintended consequences

 Need more time to comply – 2020 at a minimum

 Need more alternatives for standalone product category
Questions and Answers