The proposed revisions to the F-Gas Regulation make it clear that the industry’s most ubiquitous gas is under threat, says Ray Gluckman
In January 2011 I wrote an article for RAC entitled “Is it time to stop using R404A?” Two years on, I can confirm that R404A will be one of the first HFC refrigerants to be affected by proposed changes to the EU F-Gas Regulation. This refrigerant must be avoided in new systems and many existing systems will need to be converted to alternative refrigerants with lower global warming potential (GWP).
The European Commission has published its firm proposals for changes to the EU F-Gas Regulation. These changes aim to substantially reduce the emissions of fluorinated gases over the next 20 years. F-Gases are powerful greenhouse gases, with GWPs several thousand times higher than CO2. The largest use of F-gases in Europe is for HFC refrigerants – under the new F-Gas Regulation, their use will be severely restricted.
The EC proposal still needs political agreement from member state governments and the EU parliament, but there is already strong support for the draft regulation, which could come into force during 2013. Two of the most important proposals are:
- A phase-down in the EU consumption of HFCs, from a “baseline” – which is the average HFC consumption from 2008 to 2011 – via a series of cuts starting in 2016 (see graph, right). From 2030 only 21 per cent of the baseline consumption will be allowed.
- A ban on the use of “high GWP refrigerants” for the servicing of refrigeration systems from 2020. The proposal specifies that any refrigerant with a GWP above 2,500 cannot be used for maintenance after 2020.
R404A is the most widely used HFC for refrigeration applications. It is the dominant refrigerant in supermarkets/other commercial applications and in transport refrigeration. It is also common in medium and small-sized industrial systems. R404A has a GWP that is two to three times higher than the other commonly used HFC refrigerants (see table on facing page). On a GWP-weighted basis, R404A represents 50 per cent of EU HFC refrigerant consumption in 2012 (see pie chart). The other 50 per cent includes R134a and R410A which are widely used in air conditioning applications.
The high GWP of R404A and R507 put these refrigerants under threat under both of the new F-Gas proposals. To achieve the significant cuts in HFC consumption it will be essential to cut R404A consumption. In many senses it is an easy target, as the GWP is so high (hence every tonne of gas saved makes a bigger contribution to the phase-down target) and also because there are already some very cost effective alternatives. R404A is not a particularly good refrigerant. Not only does it have a very high GWP but it does not deliver the best energy efficiency – especially when used in medium temperature applications (for example, chilled foods at +4 deg C). This makes the case for R404A replacement even more compelling.
If you are about to purchase new refrigeration plant using R404A, you need to think again. After 2020 you will not be allowed to use R404A to maintain existing plant. So it makes no sense to buy new R404A equipment now. There are a number of alternatives that you could consider that could give you better energy efficiency and will definitely avoid problems in 2020. These fall into two groups:
· Ideally you should try and avoid HFCs altogether, using very low GWP alternatives such as ammonia, CO2, hydrocarbons (HCs) or the new HFOs. Ammonia is suitable for large industrial systems. CO2 is growing in popularity, especially in the supermarket sector. HCs are well suited to very small systems. HFOs are not yet commercially available for many RAC applications, but will probably become increasingly important during the next five years.
· For some refrigeration applications it may be difficult to find a cost-effective low GWP option. In particular this applies to small and medium-sized systems that are too large for HCs (because of high flammability) and too small for ammonia. However, that is no excuse to revert to R404A. You can consider HFC refrigerants such as R134a, R407A and R407F. These “medium GWP” alternatives all fall well below the GWP threshold of 2,500 in the proposed servicing ban, so you should be able to use them for much longer than R404A.
Design for low leakage
For all new plants make, sure that your equipment is designed to very low leakage standards. Historically HFC equipment has achieved a poor leakage record – annual leakage of 10 per cent to 20 per cent was common for supermarket systems and industrial plant. There is no need for such high leakage. If you choose to use a medium GWP HFC, don’t forget that the HFC phase-down will put pressure on the available quantities of HFCs and hence on prices. There is plenty of evidence that new systems can be designed for leakage levels of well below 5 per cent per year. If you are choosing a very low GWP refrigerant such as ammonia or CO2, low leakage is essential for safety and practical reasons.
If you already own R404A systems you will need to have taken some action before 2020 to respond to the servicing ban. If the plant is already near the end of its projected life in 2020 then you should consider replacing it with new equipment before that date. The choice of alternative refrigerant need not be decided yet – no doubt there will be lots of new refrigerants on the market by 2020.
If the plant is younger and is projected to have plenty of life left in 2020 then you should consider a retro-fill to a lower GWP refrigerant. The two main options are R407A or R407F. Both of these are well below the service ban GWP threshold and there is already good experience in the supermarket sector for successful conversion of R404A systems to these refrigerants.
If you are operating medium temperature equipment (evaporating temperature above -10 deg C) then do the retro-fill sooner rather than later – you should get a good payback in terms of reduced electricity use. For low temperature systems (e.g. evaporating temperature -30 deg C) the energy efficiency benefits are less clear, although there is some evidence of improvements.
It is essential to keep focus on reducing leakage from existing systems – the new F-Gas Regulation will retain all the current requirements for leak checking and leak repairs. It will also require the on-going use of trained technicians.
Will this really happen?
There is no certainty that the proposals will come into force unchanged. However, there is strong support for the HFC phase-down – it is unlikely that the phase-down proposal will be removed, although the timing and depth of cuts may be altered.
The servicing ban is likely to come under some scrutiny, but is also likely to stay in the new Regulation. RAC will be monitoring the political developments closely over the coming months and will provide updates of any changes.
In the meantime, don’t forget to keep up the good work on leak prevention – it saves money and reduces damaging emissions of high GWP refrigerants.
Ray Gluckman is climate change director at SKM Enviros