REFRIGERATION, POLITICS, AND “THE DONALD EFFECT”

Presented by:

Bruce I. Nelson, P.E., M.AIRAH

IIAR

• Founded in 1971

• Founders recognized need for ammonia refrigeration:

– Education

– Advocacy

– Best Practice Guidelines and Standards

• IIAR has grown to 2,800 members worldwide

• Scope of activities now include all natural refrigerants

IIAR/ANSI Standards

• IIAR 1 – 2012: Definitions and Terminology Used in IIAR Standards

• IIAR 2 – 2014: Safe Design of Closed-Circuit Ammonia Refrigeration Systems.

• IIAR 3 – 2012: Ammonia Refrigeration Valves

IIAR 4 – 2015: Installation of Closed-Circuit Ammonia Refrigeration Systems

• IIAR 5 – 2013: Start-up and Commissioning of Closed-Circuit Ammonia Refrigeration Systems

• IIAR 7 – 2013: Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems

• IIAR 8 – 2015: Decommissioning of Closed-Circuit Ammonia Refrigeration Systems

IIAR/ANSI Standards Under Development

• IIAR 6 – 20xx: Working Title: Maintenance and Inspection of Closed-Circuit Ammonia Refrigeration Systems

• IIAR 9 – 20xx: Working Title: Recognized and Generally Accepted Good Engineering Practices for Closed-Circuit Ammonia Refrigeration Systems

• IIAR C2 – 20xx: Working Title: CO2 Refrigeration

Other IIAR Publications

• PSM/RMP Guidelines

• Ammonia Data Book

• Ammonia Piping Handbook

• CO2 Handbook

• Various Best Practice Guidelines

Academy of Natural RefrigerantsParticipants in the Certificate Program will demonstrate an understanding of IIAR safety design standards and guidance documents.

IIAR suite of standards will be offered first and then move into additional courses of study to address Ammonia RMP, PSM , and more specific courses of study in engineering plant facilities design and operation.

Background

• 1970’s atmospheric research highlighted:

– CFC and HCFC refrigerants and ODP

– GWP of HFC refrigerants

• ‘Natural Refrigerants’ recognized by Lorentzen, Kruse, Pearson, and others as environmentally benign alternatives:

– Zero ODP

– Zero or very low GWP

– Highly efficient

– Low cost

Background

• Refrigeration and AC industry in the USA driven by two quite different political forces:

1. Climate change, and

2. Health and safety laws

Politics of Climate Change

• 1974 – Roland and Molina atmospheric ozone study

• 1984 – British Antarctic Survey documented loss of ozone

• Montreal Protocol agreed to in 1987 and put into force 1989

• USA Clean Air Act (1970) amended in 1990 to include Title VI – “Stratospheric Ozone Protection”

USA Clean Air Act

• Title VI enforced by EPA with fines up to USD37,500/day(!)

• Section 608 of Title VI established National Recycling and Emission Reduction Program to:

– Prohibit release

– Reduce use and emission

– Maximize recapture and recycling

– Ensure safe disposal

Section 608• Users of regulated refrigerants (CFC,

HCFC, HFC) must comply with and document:– Technician certification

– Recovery and recycling equipment

– Leak mitigation

– Sales restrictions

– Recordkeeping

– Safe disposal

– Reclamation

– Service practices

• Enforcement has been aggressive…

EPA Fines under Section 608Year Entity Fined Penalty Comments

2010 City of Tacoma, WA $525,000 Releasing CFCs from appliance disposal service.

2011 Seafood processor, OR

$27,000 Failing to keep proper records for HCFC equipment.

2011 Food manufacturer, MA

$108,320 Failing to repair leaks, conduct follow up tests, and keep service records for R-22 equipment.

2012 Two Seattle-based seafood companies

$700,000 Required to improve shipboard refrigeration systems at cost of $9 million related to improper release and illegal import of ODS.

2013 Safeway Corp. $600,000 Required to implement $4.1 million plan to reduce ODS emissions at its 659 grocery stores.

2014 Costco Wholesale Corp.

$334,000 Fix leaks and make repairs at 274 stores totaling $2 million. Failure to keep service records also cited.

2015 E.I. DuPont $531,000 Improper maintenance and repair of two large refrigeration units.

2015 U.S. Navy $83,900 Not performing leak rate calculations when servicing AC units at Norfolk Naval Station.

2016 Trader Joe's Company

$500,000 Also agreed to spend $2 million to reduce leaks and improve compliance at 453 grocery stores.

Section 612 - SNAP

• Reviews refrigerant substitutes within comparative risk framework.

• Periodically issues final rules defining acceptable refrigerants for use in various applications.

• Final Rule 21 (1 Dec 2016) enforces Kigali Amendment restrictions by changing most HFC and blends to “unacceptable” as early as 2021.

SNAP - Rule 21 Details

• Most HFC and HFC blends listed as unacceptable for chillers, cold stores, retail food refrigeration as early as 2021.

• Propylene and R443A unacceptable in residential and light commercial AC and heat pumps, cold stores, and chillers a/o 2017.

• A number of flammability Class 3 (HC and HC blends) refrigerants unacceptable for residential and light commercial AC and heat pumps a/o 2017.

• Propane listed as acceptable in new commercial ice machines, new water coolers, and new very low temp refrigeration equipment a/o 2017.

SNAP – What’s left?

• End users are left to choose between natural refrigerants which are

– Cheap and energy efficient, but

– May have toxicity and flammability issues

• And an increasingly complex set of HFC, HFO, and HFC/HFO blends which are

– Not yet proven in equipment,

– Very expensive,

– Less energy efficient,

– May pollute the environment

Ammonia and CO2

• Ammonia SNAP approved for cold stores since 1996.

• CO2 SNAP approved for most refrigeration applications since 2009.

• Application of these two natural refrigerants – alone and in combination –is accelerating.

• Trump’s surprising victory

• Recognition of Rural America impact

2016 Elections

Congress Remains Republican

Senate: 52R, 46D, 2I

House: 241R, 194D

• Over 4000 positions to be filled

• Most do not require Senate confirmation

• Senate focused on confirming Trump nominees

• 11 Cabinet level nominees confirmed so far

Trump Transition

• Confirmed by the Senate

• Former AG of Oklahoma

• Had taken on EPA with multiple challenges

• One of two AGs to write EPA with concerns about RMP rule

• Skeptical on climate change

Scott Pruitt - EPA Administrator

• Withdraw from Paris Climate Agreement

• Cancel U.S. payments to United Nations

• WAIT – Ivanka and Jared intervene to strike language regarding COP21 from pending Executive Order…

• No indications yet on SNAP Rule 21

Trump Climate Policy

• Increase defense spending by $54 billion

• Major reductions to many domestic

programs

• Indications that EPA could be cut by 25%

– Reduce from $8.1 billion to $6.1 billion

– Reduce workforce from 15,000 to 12,000

Trump Budget Blueprint

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USA EPA Budget and Workforce History

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Workforce

EPA Budget and Workforce History

Politics of Public Safety

• Because ammonia is considered toxic and flammable (B2L), systems with >10k lbsare regulated by:

– EPA (PSM)

– OSHA (RMP)

– DHS (CFATS)

• For systems with < 10k lbs “General Duty Clause” allows simplified PSM/RMP.

Ammonia Regulatory Summary

Ammonia and Building Codes

• IIAR-2 has recently been adopted by US building codes for ammonia.

• ASHRAE 15 will soon refer to IIAR-2 whenever ammonia is used.

• IIAR-2 has become the de facto industry standard for ammonia installations.

Low Charge Ammonia

• The 10k lbs threshold has driven intense interest in low charge systems in the US.

• Direct expansion allows large charge reductions vs pumped ammonia:

– As much as 75% in system charge

– As much as 95% in evaporator charge

Direct Expansion Ammonia

• Unique properties of ammonia at low temperatures must be addressed:

– Separation of phases (stratified flow)

– Thermodynamic effect of water

– Fouling of tubes by oil

• Technologies are available to address each issue.

• Many medium and large size low charge DX NH3 are in operation in USA and Australia.

Low Charge Ammonia Case Study

• Preferred Freezer Services, Richland, Washington

• Project Description:

– Largest PRW in North America

– Fully automated storage and retrieval

– Low oxygen fire suppression system

– Floorspace/Volume: 42,270 sq m / 1.1 million cu m

– Type of Building: Rack supported 35 m tall

– Number of Pallet Positions: 117,000

– Total Refrigeration Load: 4 MW

• -5 deg F Freezer @ 3.2 MW

• +45 deg F USDA Room and Loading Dock @ 844 kW

– Total ammonia charge: 8,000 lbs (2,636 kg)

Construction Phase

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Construction Phase

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Construction Phase

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Completion and Startup

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Carbon Dioxide• A1 Classification (ASHRAE Std 33)

• Subcritical operation offers high efficiency.

• Low critical point forces transcriticaloperation in warm climates

– Increased complexity

– Reduced efficiency

– Higher costs

• Increased interest and uptake of both transcritical and cascade CO2 systems.

Hydrocarbons• Extremely restrictive safety standards

and regulations are severely limiting commercial applications.

• 150g charge limit for propane.

• Recent SNAP Rule21 further restricts flammable refrigerants.

• Interest within IIAR in development of more reasonable HC safety standards.

Conclusions

• The politics of climate change has driven the phase-out of HFCs by EPA SNAP rule.

• The politics of public safety still limits application of ammonia and hydrocarbons.

• The “Donald Effect” on regulations and/or enforcement is unclear.

• Low charge technology has expanded applications for ammonia.