This is the second installment of the EIA Climate Campaign’s blog series on ‘Navigating the Path to Climate-Friendly Cooling.’ The series will focus on the key policy and technology issues related to mitigating hydrofluorocarbons (HFCs)—super greenhouse gases used in refrigeration and air conditioning. We’ll be covering a number of topics, including the progress on state and federal regulations in the United States and the interplay between industry standards and emerging technologies, in the context of the approaching international negotiations on an HFC phase down at the Montreal Protocol. For the first post in this series, Great Expectations for California to Tackle Super Greenhouse Gases, click here.
By Lowell Chandler, EIA Climate Policy Analyst
Walking down the refrigerated aisle of your local supermarket, unless you’re like me, you’re probably not thinking much about the refrigeration system that's working to keep that food cold. What many of us don’t realize is that a typical supermarket refrigeration system in the United States has a refrigerant charge size of nearly 4,000 pounds of synthetic refrigerants known as hydrofluorocarbons (HFCs) – super greenhouse gases. Your average supermarket system leaks about 25 percent annually of that 4,000 pound HFC charge. With more than 37,000 supermarkets in the United States, this is equivalent to the emissions of over 17 coal-fired power plants!* Thankfully, the Environmental Protection Agency (EPA) recently proposed a rule to better regulate and curb these emissions, something EIA has long been advocating.
This proposed rule is a big step in the right direction towards fulfilling the goals outlined by President Obama in his Climate Action Plan and subsequent executive orders and actions, and demonstrates meaningful progress towards tackling HFC emissions in the United States. The rulemaking, if promulgated as proposed by the EPA will reduce HFC emissions in the United States by 7.5 million metric tons CO2 equivalent, or the same as emissions from approximately 1.6 million passenger cars driven for one year.
In the proposed rulemaking, the EPA outlined an extension of provisions on refrigerant management under Section 608 of the Clean Air Act to cover HFCs. Section 608 works to curtail emissions of refrigerants by regulating the allowable refrigerant leakage rates of refrigeration and air-conditioning appliances with charge sizes greater than 50 pounds (think office air-conditioners, convenience store refrigeration systems, supermarkets, breweries, cold storage warehouses, etc.). Additionally, Section 608 develops requirements for appliance repair, recordkeeping and reporting of appliance refrigerant use, safe and proper disposal of appliances, and the refrigerant technician certification program. Section 608 also contibutes to efforts to stop the illegal venting of refrigerants. Prior to the proposed rulemaking, HFCs had not been regulated under Section 608. Under this proposal however, the EPA will now have full authority and ability to control the emissions of these HFCs and monitor compliance.
EIA strongly supports the proposal, and also believes there is room to strengthen certain sections in order to achieve further emissions reductions. One area is in leak rate thresholds, which is the amount an appliance can leak over a one-year period. Lowering the current leak rate threshold from 35 percent to 20 percent for commercial refrigeration appliances and industrial process refrigeration systems is a good step, but the EPA could go further for new commercial refrigeration systems. In new systems, it is possible to bring the allowable leak rate threshold to 10 percent, and EIA advocated for such in our comments to the rulemaking. Already hundreds of stores in the United States achieve this leak rate, particularly those that are GreenChill Certified. With proper regulations it is possible for businesses to lower their leakage rates; for example, in the United Kingdom, ASDA, Walmart’s UK chain, maintains a company-wide annual leak rate of 7.1 percent and has an even lower leak rate in new stores at 3.6 percent.
In addition to leak rate thresholds, EIA is concerned about the EPA’s proposal to create a sales exception for small cans (two pounds or less) of HFC-134a for self-service of motor vehicle air conditioners (MVACs), as this proposal could lead to significant emissions of HFCs. Industry estimates that nearly 14 million small cans are sold each year in the United States, predominately with HFC-134a. If the EPA were to allow this exception, up to 18 million metric tons of CO2 equivalent could potentially be emitted each year.** This is equivalent to nearly five coal-fired power plants. The primary issue is that when individuals, rather than certified technicians, service their MVAC, the system leaks do not get repaired, resulting in a leak and recharge cycle.
Overall, EIA applauds the proposal as a significant step towards cutting emissions of HFCs in the United States. We support the proposed rulemaking and hope it is promulgated with the strongest requirements possible in order to cut emissions of HFCs to the greatest degree. EIA advocates for strong enforcement mechanisms to go into place with the final rulemaking, as effective compliance will be vital to the success and integrity of the rulemaking. With the final rulemaking coming out in the next couple months, EIA looks forward to HFCs finally being covered under Section 608 of the Clean Air Act.
So, the next time you’re strolling through the refrigerated aisles of your supermarket, maybe just maybe, you’ll think about the refrigeration system. Let’s hope that system is under the leak rate threshold or better yet using climate-friendly refrigerants!
Want to know a little more about HFC gases? Watch this video by EIA: