# National and Global Regulatory Update February 18, 2016 Drusilla Hufford, Director Stratospheric Protection Division U.S. Environmental Protection Agency

###  

## Background on HFCs  

## Climate Action Plan  

## Domestic Regulatory Activity  

## Significant New Alternatives Policy (SNAP) Program  

## Section 608 Refrigerant Management Regulations  

## Federal Procurement  

## International Activity  

## Questions 

# OverviewUNEP 2011 

# Why Are HFCs a Concern?

 HFCs are synthetic fluorinated greenhouse gases (GHGs)  Use and emissions of HFCs are growing rapidly, because they are replacement for ozone - depleting substances (ODS) being phased out under the Montreal Protocol  Without action, U.S. HFC emissions were expected to double from current levels by 2020, and triple by 2030  HFCs are used in:

– Air Conditioning (A/C)

– Refrigeration

– Foam Blowing

– Fire Suppression

– Aerosols

– Solvents

# Climate Action Plan: HFCs

 Continue international diplomacy

– Lead negotiations under the Montreal Protocol to phase down HFCs • Global phase - down could reduce more than 90 gigatons of CO 2 eq by 2050, equal to roughly two years worth of current global GHG emissions

– Work with partners in the Climate and Clean Air Coalition to reduce short - lived climate pollutants to: • promote climate -friendly alternatives to high - GWP HFCs • address technical standards • reduce emissions from HFC use  Address HFCs through domestic actions

– Use existing Clean Air Act authority of SNAP Program to approve climate - friendly chemicals , prohibit some uses of most harmful

– Provide federal leadership by purchasing cleaner alternatives to HFCs whenever feasible and by transitioning to equipment using safer, more sustainable alternatives

– Apply refrigerant management requirements to HFCs

# Private Sector Commitments

 

## The private sector is also moving forward  

## The White House announced private commitments at events in October 2015 and September 2014

– Actions would reduce global GHG emissions by 1 million metric tons CO 2 

### equivalent by 2025

– Equal to taking 210 million cars off the road for a year 

###  

## Companies are going above and beyond the regulations through GreenChill and RAD• Acceptable — those that reduce overall risk to human health & environment • Acceptable with use restrictions — if needed to ensure safe use • Unacceptable 

### Evaluates alternatives and lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire Suppression; Adhesives, Coatings, Inks, etc. 

### Sectors include:

• Ozone - Depleting Potential • Global Warming Potential • Flammability • Toxicity 

### Considers (among other factors):

###  

## SNAP rules consider individual end uses  

## No across the board GWP cutoffs; no “bright lines”  

## No prohibition on HFCs as a whole, or in any one sector  

## New HFCs or HFC blends may be listed if risk not greater than other available substitutes  

## We recognize that timing is a critical dimension and that each end use has unique considerations  

## Status change actions will be issued through notice and comment rulemaking 

# Guiding Principles 

### Issued two acceptability notices adding alternatives  

### Issued new rule adding five low- GWP flammable refrigerants with use conditions  

### Published Status Change Rule prohibiting certain HFCs in certain end uses  

### HFC Emissions Reductions: 54–64 MMT CO 2 

### eq in 2025 Near- term changes can provide both nearand long -term benefits. 

# Recent ActionsR-450A (HFC/HFO blend) RefAC GWP: ~604 compared to HFC - 134a: 1430 1233zd(E) heat transfer & flexible PU foams GWP <7 compared to alternatives:1070–4000 CO 2 refrigerated transport GWP: 1 compared to alternatives: ~1400–4000 Methylal foam blowing end uses GWP <3 compared to alternatives: 725– 1430 HFO - 1336mzz(Z) foam blowing end uses GWP: ~9 compared to alternatives: 725– 1430 Powdered Aerosol D fire suppression GWP <25 compared to alternatives: 0–3500 R-450A (HFC/HFO blend) RefAC GWP: ~604 compared to HFC - 134a: 1430 R-448A (HFC/HFO blend) RefAC GWP: 1387 compared to R - 404A: 3922 R- 513A (HFC/HFO blend) RefAC GWP: 630 compared to HFC - 134a: 1430 R-449A (HFC/HFO blend) RefAC GWP:1397 compared to R - 404A: 3922 HFO - 1336mzz(Z) foam blowing end uses GWP: ~9 compared to HFC - 245fa: 1030 MPHE RefAC, solvent cleaning aerosols and adhesives/coatings GWP <3 compared to alternatives: 0–3500 October 2014 July 2015 

# Acceptability Notices 

### Use conditions required to address flammability  

### New equipment only

* End uses are in addition to those previously listed by EPA, including those listed in 2011. Refrigerant GWP 

### End Use and Application*HouseholdRefrigeratorsRetailRefrigeratorStand-aloneVendingVery Low-TempRef.Heat TransferRoom ACSelf-contained
Ethane 6 √ √ Isobutane 8 √ √ Propane 3 √ √ √ R - 441A (HC blend) <5 √ √ √ HFC - 32 675 √ 

# 2015 Low- GWP Refrigerants Rule

# July 2015 Change of Status Rule

 HFC - 125 — January 2016  HFC - 227ea and Blends — July 20, 2016  HFC - 134a — July 20, 2016/January 1, 2018  HFC - 134a in New Light - Duty Systems — MY 2021  HCFC and HFC - Containing Blends in New Light Duty Systems — MY 2017
 New Supermarket Systems — January 2017  New Remote Condensing Units — January 2018  New Vending Machines — January 2019  New Stand -Alone Units (small medium -temp, large medium -temp, low -temp) — January 2019/January 2020  Retrofitted Retail Food Refrig . Equipment and Vending Machines — July 20, 2016  All End Uses, Except Rigid PU Spray Foam — Various Dates Between January 2017– January 2021 

### Motor Vehicle Air Conditioning Aerosols

Retail Food Refrigeration and Vending Machines Foams

## The EPA is considering a future proposed rule that could include:  

### Listing of acceptable alternatives with use conditions

– Use conditions would mitigate risks, e.g., flammability, exposure limits  

### Listing of unacceptable alternatives

– Where risks cannot be mitigated sufficiently, e.g., flammability, toxicity, air quality impacts, climate  

### Change of listing status from acceptable to unacceptable

– EPA contemplating changes for equipment categories not addressed in July 20 th final rule

– End uses based on stakeholder comments and EPA analysis could include: • Refrigeration and A/C: e.g., chillers, refrigerated food processing and dispensing, household refrigerators and freezers, cold storage warehouses • Rigid PU spray foam; fire suppression 

# September 2015 Stakeholder Meeting

### Purpose of Section 608 of Clean Air Act: Reduce emissions of ozone - depleting substances (ODS) and substitute refrigerants during the maintenance, service, repair and disposal of appliances Current requirements include:  

### Prohibition against knowingly venting ODS and substitute refrigerants  

### Service practices (ODS)  

### Safe disposal requirements (ODS)  

### Leak repair and prevention for larger appliances (ODS) 

# National Refrigerant Management ProgramService Practice Requirements Technician Certification Refrigerant Recovery and Recycling Equipment Refrigerant Leaks Refrigerant Sales Restrictions Major Recordkeeping Requirements Safe Disposal Requirements Reclamation 

# Overview of Current Requirements

# Goals of 608 Updates

 

## Larger Context:

– Climate Action Plan

– Industry petition to create a level playing field for commonly used refrigerants

– Continue to reduce emissions of ozone - depleting refrigerants 

###  

## Immediate Goals:

– Extend Section 608 requirements to HFCs and other substitutes that are not exempt from the venting prohibition (“non - exempt substitutes”)

– Decrease leaks from large appliances

– Enhance clarity and ease of compliance

– Strengthen incentives that support careful management of refrigerants

## If finalized, the proposal would*:  Lower applicable leak rates

– From 35% to 20% commercial and industrial process refrigeration

– From 15% to 10% for comfort cooling appliances 

###  If leak rate exceeds applicable leak rate, owner/operator must:

– Conduct leak inspection

– Repair all identified leaks within 30 days and verify repairs are successful • Time extensions available

– If leaks cannot be repaired, develop retrofit/retirement plan within 30 days

– Complete appliance retrofit/retirement within one year 

###  Require periodic leak inspections  Establish a two -year leak limit of 75%  Update recordkeeping requirements 

# Proposed Changes: Appliance Maintenance and Leak Repair

* The proposed requirements on this slide would only be applicable to appliances with 50 or more pounds of refrigerant charge . 

### Currently: Technicians working on equipment containing ODS refrigerants must be certified and follow servicing practices, such as recovering refrigerant from an appliance before servicing  

### Proposal extends requirements to apply to HFCs and other non - exempt substitutes  

### Proposal would also require technicians to keep records of refrigerant recovered when disposing of appliances between 5–50 pounds

– Current gap in recordkeeping requirements for equipment between 5 and 50 pounds

– Recordkeeping includes the amount of refrigerant recovered at disposal and the final disposition of refrigerant removed from appliances 

# Servicing and Disposal Practices

# Other Proposed Changes to 608 Extend to Substitutes  All non - exempt refrigerants in small appliances, MVACs must be recovered before disposal  Technicians must be certified to purchase all non - exempt substitutes, with exemption for small cans
 Tech certification companies must publish lists of who they certify (prospective, with opt - out for privacy)  Remove reporting requirement for ownership of recovery equipment; require use of recovery equipment instead  Restructure to better group requirements and improve language clarity 

### Simplify, Improve

 Update AHRI 700 reclamation standard used  Update AHRI 740 recovery equipment standard used, add safety parameters for flammable refrigerants (UL 1963, supplement SB) 

### Update Standards

### If finalized as proposed, the rule would result in: 

# Benefits
Annual GHG

Reductions (MMTCO 2eq) Annual ODS Reductions (ODP -weighted MT) Annual Incremental Compliance Cost (millions) 

### 7.5 116 $63
 7.5 MMTCO 2 

### eq of GHG emissions reductions is the same as taking about 1.6 million cars off the road for a year  We anticipate the regulated community would also experience $52 million in cost savings related to reduced purchases of refrigerant

### Outreach/Stakeholder Engagement in Rule Development Phase  

### November 2014 stakeholder meeting, 50+ participants  

### More than 50 meetings with industry, environmental groups, trade associations, states Next Steps  

### November 9 — Proposed rule published in Federal Register (80 FR 69457)  

### January 25 — Deadline to submit written comments  

### Currently reviewing comments and crafting a final rule 

# Outreach and Next Steps

# HFCs and the Federal Sector

 

## U.S. government is a large purchaser of goods and services

– Fleet inventory (owned/leased): > 635,000 vehicles 1



### – Buildings (owned/leased): >353,000 buildings 2



### – Spending on supplies and equipment: nearly $ 191 billion each year

– $222 million on refrigeration and AC 3 

###  

## In 2010, federal agencies reported HFC emissions of nearly 2.2 MMTCO 2 

## e 4 1 U.S. General Services Administration (GSA) 2013. Index of Data, Federal Fleet Report

for FY 2013 . 2 U.S. GSA 2013 . FY 2013 Federal Real Property Profile (FRPP) Summary Data Set . 3 Federal Procurement Data System 2007 . Federal Procurement Report FY 2007 . 4 Data.gov. 2011. FY2010 Federal Government Greenhouse Gas Inventory by Agency.

# Federal Actions Addressing HFCs

 

### FAR proposed rule (May 11, 2015) addressed HFCs by directing the government to procure alternatives to high - GWP HFCs:

– Where feasible, substitute acceptable alternatives as identified by SNAP program

– Vendor reporting on use of HFCs (i.e., refrigerants)

– Final rule expected in 2016 

###  

### EO 13693 (March 19, 2015) — Planning for Federal Sustainability in the Next Decade

– Direct GHG emissions reduced by at least 40 % by 2025

– Agencies to purchase sustainable products and services identified by EPA Programs, including alternatives to ODS and high - GWP HFCs , where feasible, as identified by SNAP

##  

## Revamped EPA SNAP website

– http://www.epa.gov/snap

– Enhanced user friendliness for federal consumers to learn about acceptable alternatives 

##  

## Federal HFC emissions accounting tool  

## Fact sheets

– General: HFCs used by federal agencies

– Sector- specific: HFC uses and alternatives 

##  

# Case studies

– Commercial refrigeration system at Lackland Air Force Base Commissary (San Antonio, TX) 

# Support Materials Available

# International Activities

 

## Since 2009, the United States, partnering with Canada and Mexico, have been pursuing an amendment to phase down HFCs under the Montreal Protocol

– Proposals would phase DOWN, not OUT, global HFC production and consumption 

###  

## In Nov. 2015, parties reached an agreement on the Dubai Pathway to work to an amendment in 2016

– An amendment would achieve substantial greenhouse gas reductions and could avoid up to 0.5 degrees Celsius of warming by 2100 

###  

## Amending the Montreal Protocol would pave the way for all countries to transition away from using high - GWP HFCs

# Thank You!

DISCLAIMER Although all statements and information contained herein are believed to be accurate and reliable, they are presented without gu arantee or warranty of any kind, expressed or implied. Information provided herein does not relieve the user from the responsibility of car rying out its own tests and experiments, and the user assumes all risks and liability for use of the information and results obtained. Stateme nts or suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patents. The user should not assume that all toxicity data and safety measures are indicated herein or that other measures may not be required. 

# Questions?

# BACKGROUND SLIDES

# Proposed Changes: Leak Repair Action/Topic Current Proposed Change Appliances affected All ODS appliances with full charge of 50 lbs or more All appliances with full charge of 50 lbs or more of non - exempt refrigerants (e.g., ODS, HFCs) Leak rate Leak rate is 35% for refrigeration appliances and 15% for comfort cooling Lower to 20% and 10%, respectively; would exempt seasonal variances from counting toward leak rate When leak rate exceeds trigger rate Repair leaks within 30 days such that the leak rate is brought below the trigger rate Conduct leak inspection and repair all identified leaks within 30 days How to verify repairs Initial and follow - up verification tests required for IPR and federally owned appliances Initial and follow - up verification test required for all affected appliances If owner/operator fails to repair within 30 days Must develop a retrofit/retirement plan Unchanged Timeline for retrofit/retirement plans Appliance must be retrofitted or retired within one year Unchanged28 

# Proposed Changes: Repair Extensions Action/Topic Current Proposed Change Extensions to 30 - day repair timeline If appliance or isolated appliance component is mothballed Unchanged Up to 120 days for an industrial process shutdown Unchanged If federal , state or local regulations prohibit timely repairs (IPR only) Would be extended to all affected appliances If necessary parts are not available (IPR only) Would be extended to all affected appliances but capped at 180 days If appliance is located in an area subject to radiological contamination or where the shutting down of the appliance will directly lead to radiological contamination (federally owned only) Would be extended to all affected appliances Extension request required for all but mothballing and IPR shutdown Unchanged

# Proposed Changes: Retrofit/Retirement Action/Topic Current Proposed change Extensions to the one -year retrofit/ retirement timeline If appliance or isolated appliance component is mothballed Unchanged If federal , state or local regulations prohibit timely retrofit (IPR only) Unchanged If a suitable replacement refrigerant with a lower ozone depletion potential is unavailable (IPR only) Removed If a critical component of a custom - built IPR appliance is not available on time (IPR only) Largely unchanged If complications are presented by the federal agency appropriations and/or procurement process (federally owned only) Unchanged If appliance is located in an area subject to radiological contamination and creating a safe working environment will require more time (federally owned only) Unchanged Up to 18 months if replacement appliance uses an exempt refrigerant

###  

## Establish a two -year leak limit

– Prohibit an appliance from leaking more than 75% of its full charge in two consecutive years

– If leak amount exceeded, appliance would need to be retired or mothballed



## Example

– Appliance leaks 80% of its full charge between Jan. 1 and Dec. 31, 2018

– From Jan. 1, 2019 to Dec. 31, 2019, the appliance could not leak more than 75 % of its full charge

– If above 75% in 2019, appliance would need to be retired or mothballed 

###  

## Taking comment on:

– Whether to allow for retrofit/retirement plan in lieu of mothballing

– Whether to provide an exception for unavoidable catastrophic leaks

– How the time frame should be set up: two consecutive years? Time periods based on calendar year or rolling? 

# Proposed Changes: Leak Limit

###  

### Require regular leak inspections, unless regularly calibrated automatic leak detection equipment installed

– Quarterly for 500+ pound commercial refrigeration and IPR • Annual inspections allowed if no refrigerant has been added in the past 365 days

– Annually for all other appliances with 50 or more pounds

– Proposing lower and higher charge thresholds for annual vs. quarterly 

###  

### Leak inspection would include examination of the refrigerant circuit of an appliance using:

– a calibrated leak detection device

– bubble tests

– visual inspection for oil residue 

###  

### Proposing to allow leak inspections be conducted by staff other than a certified technician 

# Proposed Changes: Leak Inspections

# Proposed Changes: Recordkeeping

 

### Technicians would provide records for owners/operators that include:

– ( 1) the identity and location of the appliance

– (2 ) the date and type of maintenance, service, repair or disposal performed, including the location of repairs and the results of any verification tests or leak inspections (if applicable )

– ( 3) the name and affiliation of the service technician

– ( 4) the amount and type of refrigerant added to and/or removed from the appliance ( if applicable )

– (5 ) the full charge of the appliance

– ( 6) the leak rate and the method used to determine the leak rate  

### Owners/Operators would keep all service records, leak inspection results, full charge calculations, verification test results, retrofit/retirement plans, extension requests, etc.  

### EPA encourages electronic recordkeeping systems