“I don’t think I’ve ever seen a subject area where so many of the
strategic questions are being sorted out in the field,” said Robert
Cavey, a partner with Praxis Inc., in kicking off Danfoss’ 30th
EnVisioneering Symposium, Refrigerants2Sustainability, which was held
Sept. 27 in Orlando, Florida.
The symposium, convened to explore the forces and ideas driving
commercial refrigeration strategy, brought together leaders from across
stakeholder communities to discuss the probabilities, possibilities,
timelines, and new lights by which market players can gain greater
clarity, build effective collaborations, and learn which paths will help
them best meet their business and societal goals.
Cavey said the event was designed as a conversation around a dinner
table in which the knowledge and expertise of the faculty and the
student body were equal, and he urged the attendees to take advantage of
the opportunity.
“We have a very diverse group of people here today who don’t
typically have a chance to sit together and have a dialogue; that
dialogue and discussion among the participants is really the heart of
this program,” added Lisa Tryson, director, corporate communications and
public relations, Danfoss.
Tryson pointed out that refrigerant regulations and the recent
District of Columbia District Court ruling on the fate of
hydrofluorocarbons (HFCs) under the U.S. Environmental Protection
Agency’s (EPA’s) Significant New Alternatives Policy (SNAP) program are
creating disruption and uncertainty in the industry.
“I think most of us in the room still see the end game as low-global
warming potential [GWP] technologies, and equipment manufacturers and
end users are going to continue to look over the horizon at how we
achieve low-global warming potential and energy efficiency in our
systems,” Tryson said. “These changes are going to impact supermarkets
and commercial refrigeration equipment — how it’s designed, installed,
and maintained.”
The event covered regulations, safety, climate, and consumer
expectations in presentations by Mark Menzer, director of public
affairs, Danfoss; Glenn Gallagher, senior air quality scientist,
research division, California Air Resources Board (CARB); Xudong Wang,
director of research, Air-Conditioning, Heating, & Refrigeration
Institute (AHRI); Peter Dee, sales director, Danfoss; KC Kolstad, lead
mechanical engineer, refrigeration, Target Properties Management; Brad
Morris, senior manager of engineering and energy, Giant Eagle Inc.;
Aaron Daly, global director for energy management, Whole Foods; and Dr.
Marcel Christians, chief technology officer, Ice Energy.
Among the topics of conversation:
The future of SNAP — Menzer discussed how a recent
lawsuit, Mexichem Fluor and Arkema v. U.S. EPA, raised the issue of
whether the EPA has the authority to make manufacturers move away from
non-ozone depleting potential (non-ODP) chemicals such as HFCs based on
their GWP.
A district court determined that the EPA lacked the statutory
authority to mandate the phasedown of non-ODP substances, placing a
cloud over the future of SNAP HFC regulation. The ruling sent the 2015
SNAP rule back to the EPA for a rewrite. What exactly the EPA will do
and whether the decision will be appealed to the Supreme Court remains
to be seen. For now, the court’s decision raised the specter of stranded
investments and fueled a good deal of confusion in the marketplace.
The power of states — Individual states are not
pre-empted by federal authority in the regulation of the relevant
chemicals for GWP purposes. So, the possibility emerges of states moving
ahead with delisting HFCs while the federal government either sorts out
the next steps or backs away from regulation of non-ODP refrigerants.
For example, Gallagher explained that California is moving forcefully
to develop regulations to phase out the use of high-GWP chemicals.
California Senate Bill 1383 (2016) requires a 40 percent reduction in
HFC emissions below 2013 levels by 2030. State officials emphasize that
despite the court ruling sending the rule back for recrafting, EPA SNAP
rules remain in effect for now.
Gallagher noted that CARB’s Short-Lived Climate Pollutant Strategy
puts sales restrictions on very high-GWP refrigerants with 100-year GWPs
of 2,500 or greater, prohibits high-GWP refrigerants in new stationary
refrigeration and stationary air conditioning equipment, and provides
financial incentives for new low-GWP systems.
In addition, the state is continuing work on codes and standards
updates, exploring ways to continue HFC reductions based on the EPA’s
SNAP rules, and developing requirements and timelines for phaseouts.
Flammable refrigerants — If global trends are an
indicator of the direction the U.S. will take, flammable refrigerants
are poised to play a larger role in the overall refrigerant regime.
However, the approval process can be laborious.
According to Wang, today’s projected path for employing flammable
refrigerants has refrigeration systems and equipment meeting ASHRAE, UL,
and ISO safety standards by 2018, creating model building codes by
2021, and crafting state and local codes in 2022 and beyond. AHRI and
ASHRAE are conducting research programs to help make that timeline work,
Wang said. Several studies are complete, including benchmarking risks
of A2L (mildly flammable) refrigerants and HVACR equipment leak
detection of A2L refrigerants. Others are expected to be finished by the
end of 2017, including hot surface ignition testing; flammable
refrigerant handling guidelines; and an effort to explore the grounds
for setting charge limits of A2L, A2, and A3 refrigerants (flammable
including hydrocarbons and HFOs) for various types of products. Other
research projects are slated for 2018 completion.
End users moving beyond HFCs — Kolstad said Target
has set the goal of being HFC-free in food distribution centers and
stand-alone refrigerated display cases by 2020 and is requiring all new
purchases of stand-alone units less than 2,200 Btuh cooling capacity to
use HFC-free refrigerants. Starting in 2016, Target told its suppliers
that it is moving to hydrocarbon R-290 for units less than 2,200 Btuh.
Morris said Giant Eagle is putting the emphasis on general
maintenance, floating head pressure and suction pressure, anti-sweat
control, and the like — where he said a good deal of low-hanging fruit
is available. For new technology, Morris explained how Giant Eagle is
looking to distributed refrigeration controls rather than a centralized
approach. Distributed controls, he noted, can offer 30 percent estimated
energy savings, which justifies the first cost of the controls
investment.
Thermal energy storage — Christians explained how
ice batteries can enable a supermarket or grocery store owner to decide
when to use electricity from the grid to create cooling, offering the
ability to use stored cooling to provide three to 20 tons of cooling for
up to six hours. The basic formula is simple: Use lower cost, off-peak
energy, and tap storage during high-cost peak hours. The time of use
energy cost differential and lower demand charges cover the cost of the
investment within a few years, and improved grid stability justifies
utility incentives.
Financing the paradigm shift — Population growth,
the growth in retail food outlets, an aging grid, and less appetite for
building new generation capacity all point to energy use containment.
Generally speaking, utilities are capitalized to finance the shift.
“Many utilities are sitting on large sums of capital, and they’re
very interested in finding ways to get that capital employed to their
advantage,” Daly said. “In my view, they increasingly need our
assistance in understanding how to do that.”
To that end, he added, understanding each utility that you’re dealing
with and why they want to engage with you is absolutely critical to
success when it comes to leveraging incentives or rate structures and
determining which steps and technologies to employ.
In summary, court-imposed ambiguity, uncertain standards and codes,
and a diversity of technological options and risks complicate the
relevant refrigerant questions.
Recent U.S. regulatory strategy has focused on transforming the
refrigerant sector based on GWP impact, and industry stakeholders have,
therefore, been exploring appropriate new directions and solutions. But,
when the courts recently placed a question mark over EPA’s SNAP
regulations, the issue shifted — this time to questions such as how far
the country would move, what new investments would be genuinely
necessary, and whether the basic strategic issues for refrigerants had
again been put on ice. The resulting uncertainty is causing states,
refrigeration equipment manufacturers, and end users to take individual
actions to move toward low-GWP, energy-efficient technologies that stand
to future-proof business and benefit the bottom line today.
Amidst the uncertainty, however, the overarching facts are clear
enough: there is ample convergence of interest to support a strategic,
industry-wide dialogue, and global refrigerant trends suggest it should
begin sooner rather than later.
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