On May 3, 2021, the USEPA released a notice of proposed rulemaking to institute a major phasedown in production and consumption of hydrofluorocarbons (HFCs), used in refrigeration and air conditioning systems. The USEPA estimates the phasedown will yield total climate-related economic benefits of $283.9 billion through 2050.
HFCs were encouraged to replace chlorofluorocarbons (CFCs) which are listed as ozone-depleting substances, and ultimately banned globally for that purpose. However, research determined that HFCs are powerful greenhouse gases (GHGs), with global warming potentials (GWPs) thousands of times greater than CO2. While HFCs are not as ubiquitous as CO2, their potency represents a major global climate change risk.
The USEPA’s proposed rule’s goal is to achieve an 85% overall reduction in HFC production and consumption in 15 years. The USEPA would administer an allowance allocation and trading program, assigning GWP values to individual HFCs and allocating production (producers), consumption (importers), and application-specific allowances. Six HFC use types would qualify for application-specific allowances:
• propellants in metered-dose inhalers,
• defense sprays, such as bear spray,
• structural composite preformed polyurethane foam for marine use and trailer use,
• etching of semiconductor material or wafers and the cleaning of chemical vapor deposition chambers within the semiconductor manufacturing sector,
• mission-critical military end uses, and
• on-board aerospace fire suppression.
The USEPA has not yet listed the specific number of allowances in each application-specific use, but proposed overall numbers of allowances, including for production and consumption (million metric tons, CO2 equivalents; percents are of baseline), as follows:
• 2022-2023: 90% (296.1 consumption, 337.5 production)
• 2024-2028: 60% (179.4 consumption, 225.0 production)
• 2029-2033: 30% (89.7 consumption, 112.5 production)
• 2034-2035: 20% (59.8 consumption, 75 production)
• 2036: 15% (44.9 consumption, 56.3 production)
The USEPA intends to revisit its allowance allocation procedures before 2024.
What is a plant manager to do to replace HFCs? For refrigerant systems, one can use “natural” refrigerants, such as propane, isobutane, ammonia, and CO2. CO2? Yes, it is a GHG, but its GWP is 1, much lower than HFCs, whose GWPs are in the thousands, so thus, beneficial. For air conditioning, viable alternatives include installing heat pumps, which transfer heat to or from a large reservoir (ground or air), or systems that use less refrigerant, such as those with variable refrigerant flow systems. Some of these use the same refrigerants as above and many can function well using water to transfer heat.
It may take several months to go through publication and public comment before it becomes the law, but expect this to be promulgated and, if you use HFCs, expect to deal with allowances and, therefore, restrictions and higher costs. Plan now to change your refrigeration or cooling systems to those that do not use HFCs.
CCES has the technical experts to help you manage your operations to minimize your environmental impacts. Contact us today at 914-584-6720 or karell@CCESworld.com.