Comment Log Display

Thanks to everyone that participated in the SLCP-Public Workshops. 
As a Refrigeration and Air Conditioning distributor we work very
closely with facility operators and mechanical contractors.  Over
the last decade I have conducted hundreds of educational meetings
talking about the HCFC phase out and the importance of moving to
(Non-ODP) HFC refrigerants.  Although there has been some pushback,
the industry as a whole has embraced this change and work is being
done on a daily basis to achieve this goal.  
The sheer number of facilities that this affects, the technical man
power required and the cost associated with a refrigerant retrofit
has required companies to adopt a gradual conversion programs, with
2020 being the target date for completion.  
When HFC's were first identifies as having High GWP, some companies
simply stopped their retrofit efforts.  Clearly making a change now
with yet another change on the horizon had many concerned; should
they to stay the course, convert their facilities to new unfamiliar
and costly technology or wait for yet another retrofit solution? 
As I am sure you are aware, all of these scenarios are being played
out.
With respect to HFC’s in general; I am not trying to argue the
science, but one area I question in your presentation was the
impact our industry has on the HFC usage as whole.  Prior to 2010,
the majority of HFC’s, particularly R134A were used in Foams,
Aerosols and Automotive AC.   Now that most of those industries
have been or are being converted to other materials,
AC-Refrigeration is the predominant share, of what remains.  You
also indicated that HFC use in the AC-Ref sector was on the rise. 
With the HCFC conversion still underway, that would only make
sense.    
Our industry has proven that we will work to comply with whatever
is legislated. Beyond the retrofit activity, system designs and
service practices have lowered both the refrigerant charge and the
service leak rates.  I don’t have statistics, but it seems we have
been able to make progress with minimal economic impact.   
There are arguments both pro and con on the direction our industry
should go.  Natural refrigerants like Co2 are certainly viable, but
there is some question whether energy efficiency, and by extension
water consumption would be negatively affected in high ambient
(+95F) Climates.  Even if they are able to make an energy neutral
design, the initial cost of these systems in well over $1,000,000
per location so a rapid move by even the most  well-funded
Supermarket chains would be difficult at best.  
In Europe they are moving in part to self-contained refrigeration
cases using natural refrigerants including hydrocarbons.  All of
these fixtures would need to be water cooled, which given our
current state, could present an additional challenge.  Also, the
adoption of Hydrocarbon refrigerants like Propane or Butane,  are
strictly limited by UL and the municipal fire and building codes.  
So, despite their popularity in EU, they would not be easily
adopted in the US.
With Respect to HFO technology; Unlike the Foams, Aerosols and
Automotive industries the development of HFO refrigerants was not
considered a priority until the recent move to retire HFC’s . 
These products are just now becoming commercially available and
although they have slightly higher GWP values than naturals, they
perform well in existing system with, in some cases improved energy
efficiency.  Keep in mind that pure HFO’s have lower GWP values
than even C02 (based on ICCP -5 data).  The limiting factor is
their A2L flammability level.  These are much lowers those
A3-hydrocarbons, but still prohibited by current codes.  The
coordination of the various regulatory agencies should really be
considered before a decision is made.
To summarize; Moving from a gradual HCFC to HFC conversion protocol
to a rapid HFC to ???, conversion is likely to have far reaching 
consequences.   I would encourage you to review the timelines that
you have outlined and consider a more gradual conversion goal.  It
would be a shame to jump to a new technology that would not only
required significant investment but could ultimately, require more
energy and result in a higher TEWI (total equivalent warming
impact).

Thank you

Gary Parker
Refrigerants Product Manager
Refrigeration Supplies Distributor
gparker@rsd.net