REPLACEMENT OF HCF REFRIGERANT R22 EXECUTIVE SUMMARY 1. R22 is becoming scarce and expensive, and this trend is expected to continue. 2. Refrigeration service companies have a differing ability to supply R22 because they have different allocations depending on their historical use. 3. Drop-in refrigerants are available at a cost about 30% higher than R22, but they cause a small drop in system capacity and are prone to exacerbating system leakage. 4. Some used R22 refrigerant may be imported in future if there is sufficient demand, but it would be likely to be sold at a high price reflecting the local shortage. 5. Some companies will keep systems running by re-using refrigerant from other systems, with or without first re-processing it. Overall, retaining R22 can only be seen as a ‘Holding’ position. DEALING WITH EXISTING SYSTEMS 1. It is recommended that existing systems are surveyed for their current condition, and a decision made whether to: • Keep them in use and instigate a strict management programme to minimize refrigerant loss. • Replace parts of them with new components using a new refrigerant. • Replace them with a new system. 2. Where a building contains a number of similar systems that are in good condition, consider carrying out trial conversions to an HFC refrigerant on one or two systems, to provide a contingency plan if R22 becomes unavailable. 3. Ask your maintenance contractor to provide an update say every 6 months on the price of R22 and their ability to provide it within their allocation, and to advise immediately if any sudden change occurs. SELECTION OF A NEW REFRIGERANT • The choice of refrigerant for a new system will depend on several factors: • The choices offered by the equipment manufacturers. • The expected long-term availability of the refrigerant. • The expected long term cost of the refrigerant. • The relative energy-efficiency of the system with each refrigerant. HFC refrigerants such as R134a, R407C and R410A are in very widespread use, but there are real long-term questions about their price and availability because of their relatively high Global Warming Potential. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 1 For now, the market has generally settled on the following alternatives to R22 for new plant. Small Air Conditioning Splits & Rooftop Packages R410A Chillers R134a or R407C, R410A or Ammonia Small commercial refrigeration R134a, R404A or other HFC’s Large commercial or industrial refrigeration Ammonia, carbon dioxide or R134a primary system with glycol secondary system. For large chillers and refrigeration systems, close consideration should be given to using natural refrigerants such as ammonia, carbon dioxide or hydrocarbons for their efficiency, expected long life and low cost. As with all new and complex technology success or failure in the use of new refrigerants will depend on the level of attention to detail in design, installation and commissioning work. It is more important than ever to forge a strong relationship with very competent designers who are regularly receiving information on industry developments, who can help you to decide when to commit to a new type of system or refrigerant and who can prepare fully-detailed designs. BACKGROUND INFORMATION Refrigerants can be categorised according to two characteristics – their Ozone Depleting Potential or ODP, and their Global Warming Potential or GWP, as tabulated below. Of course these effects only occur if the refrigerant escapes from the refrigeration system. Group Typical refrigerants ODP GWP CFC R11, R12, R502 High High HCFC R22 Low Moderate HFC R134a, R407C, R410A Zero Quite high Natural Hydrocarbons, ammonia, carbon dioxide Zero Very low Because of their ozone-depleting potential a phase-out programme for CFC’s was set up under the Montreal Protocol in 1987 and the importation of new CFC’s has now been fully phased out. A phase-out programme was also set up under the Montreal Protocol for HCFC refrigerants and this has been given effect in New Zealand under the Ozone Layer Protection Regulations 1996 as tabulated below. This principally applies to R22 which is a very efficient refrigerant very widely used in air conditioning systems and coolstore refrigeration. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 2 PHASE-OUT SCHEDULE FOR HCFC’S 1996 A base-line allowance was established by the issue of Import Permits for new HCFC’s to existing users based on their previous usage. 2000 The amount allowed to be imported was reduced by 33% of the original allowance. 2001 A special entitlement was provided through wholesalers to supply new users. This is an ongoing entitlement to be distributed by the wholesalers at their discretion. 1 Jan 2010 The amount allowed to be imported under the Original and Special permits was reduced to 25% of the original allowance. This equated to a reduction of about 62% in the amount allowed to be imported in 2009. The total amount of entitlement able to be converted into import permits reduced from 26.8 ODP tonnes to 11.7 ODP tonnes. An ODP tonne is a non-substance specific measure referring to ozone depleting potential as compared to CFC-11 (R11refrigerant) which has an ODP of one (1.0). 1 Jan 2015 All imports of new HCFC refrigerant will be illegal. REVIEW OF PHASE-OUT BY MINISTRY OF ECONOMIC DEVELOPMENT In 2009 the MED carried out a survey of the refrigeration industry and drew the following conclusions about the phase-out programme. The full report can be seen on their website med.govt.nz under International Trade, Environmental agreements, Ozone Layer Protection, HCFC Imports 2010 www.med.govt.nz/templates/Page____41145.aspx 1. Wholesalers were comfortable with the phase-out process and had, in fact reduced the amount of R22 imported by over 40% since 1996 – i.e. in excess of the ‘Phaseout reduction’. 2. There was some expectation that the price would increase after 1 Jan 2010, and that there may be an increase during the course of each year as the allowable imports were sold, but the extent was unclear. 3. There is real concern that if a levy is imposed on the HFC refrigerants intended to replace R22 under the Emissions Trading Scheme that this will slow the reduction in use of R22. R22 is still substantially cheaper than the HFC replacements, at around $80 per cylinder compared with $300. 4. There is strong demand for spare parts and R22, indicating that owners are repairing their systems rather than replacing them with those using HFC’s before the end of their normal life. This information is now somewhat out of date, as described below. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 3 FUTURE AVAILABILITY OF R22 We cannot be certain how long R22 will continue to be available, or what its price will be, but there are some pointers to future supply: 1. Anecdotal evidence from wholesalers is that there is a shortage of R22 and it is expected to continue. Prices have approximately doubled over the last year, and this trend is also expected to continue. Also, individual refrigeration companies are allowed different allocations of R22 depending on their historical use, so some will find it easier than others to continue sourcing R22. 2. According to the MED report recycled HCFC’s are not covered by the Montreal Protocol, so there is nothing to prevent the importation of recycled R22 that has been removed from refrigeration systems. The world supply of new R22 seems to be assured, as developing countries such as India and China are not subject to the same phase-out schedules as developed countries. As existing R22 systems are replaced with new systems in NZ and elsewhere their refrigerant is generally collected and destroyed, but it could be re-processed and used in other systems if there is a demand for it. The MED report states that the cost of recycled R22 is about twice that of new refrigerant at present, which is still substantially cheaper than HFC refrigerants. We expect that recovered R22 will be increasingly retained rather than destroyed, and used to keep systems operating. Ideally it should be reprocessed first, but we expect that some companies will simply use it as is, especially if they know that the system it was recovered from did not have a history of operational problems. 3. The MED report states that the regime also allows for Wholesaler Permits where a maximum of 2.5 ODP tonnes is divided equally on an annual basis between HCFC wholesalers who distribute nationwide. There are currently 4 wholesalers and all are in the refrigeration and air-conditioning servicing sector. These permits do not have a phase-out date which means they are able to be used past 2015 however the amount available will place New Zealand in non-compliance in 2010. (It is not clear what the implication of this statement is). 4. An important feature of the Permit system is that the MED may cancel or reduce an entitlement if it remains unused for a period of two years. In fact the entitlement holder must not only apply for a permit, but must also show actual importing activity against that permit, or else they may transfer all or part of the entitlement to another party. This appears to mean that the allowable amount of imports will be modified to match actual usage. On balance, it seems as though R22 is becoming scarce and expensive and will continue to do so. Some used refrigerant may be imported in future if there is sufficient demand, but it would be likely to be sold at a high price reflecting the local shortage. Some companies will keep systems running by re-using refrigerant, or by using drop-in replacements. Overall, these actions can only be seen as a ‘Holding’ position. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 4 CONVERSION OF R22 SYSTEMS TO OTHER REFRIGERANTS 1. Drop-in replacement refrigerants are available that are compatible with the original lubricating oil. They are not quite as efficient as R22, so the system‘s capacity will be a little reduced (up to 5%), but with many systems this will not matter. The cost of one drop-in replacement we checked – Du Pont M099 - is about 30% higher than the price of R22 and its GWP is also about 25% higher than that of R22. Also, there are reports that it tends to leak through existing system imperfections such as minor holes or hard O-ring seals, so it does not offer a simple solution. 2. Systems can be converted to HFC refrigerants which are currently cheaper than the drop-in refrigerants, but that requires replacement of the oil as well as control valves and some seals. The MED report estimates the cost of this work to be $300 $400 for a small system, and up to $3,000 - $5,000 for a large one, and we believe that these estimates are likely to be on the low side. Also, there is some degree of uncertainty as to just how any particular system would perform with a different refrigerant. The cost of HFC refrigerants will also rise sharply if/when the proposed Carbon Charge is applied under the Emissions Trading Scheme, as described below. 3. Promising new refrigerants such as 1234yf are being developed, but they are not likely to be readily available for some years, as they are being introduced cautiously in the face of uncertain demand. None of these options look sufficiently attractive to become common practice. RECOMMENDATIONS FOR DEALING WITH R22 SYSTEMS We do not think that there is any compelling reason to remove R22 systems or to convert them to other refrigerants at present. Although other options are available they are not ideal, and it is likely that new options will emerge over the next few years. If the system doesn’t leak then there is no reason why it cannot continue running on R22 until it is de-commissioned. This would provide the greatest return on the original investment, and would give the longest time for new options to emerge. The following pre-emptive steps should be taken to decide if a system should be retained: 1. Ask whether it is still doing a good job. 2. Establish its age, from as-installed documentation or from physical assessment. 3. Establish the likelihood of refrigerant leakage. There is generally little risk of corrosion of the copper pipes used in refrigeration systems, but failure can occur by abrasion or vibration, so ask the maintenance contractor to: • Thoroughly check the system for signs of leakage, especially oil stains at mechanical joints, and repair any leaks found. • Check for signs of abrasion where the tubes pass through sheetmetal tube-plates on the heat transfer coils. • Check whether the pipes connected to the compressor have been repaired, and if so, whether there is the risk of further failure from excessive vibration and/or insufficient flexibility in the pipework. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 5 • Check the condition of the components that are difficult or expensive to replace – i.e. compressors, finned coils and sheetmetal housings. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 6 ACTIONS FOR RETAINED SYSTEMS 1. Implement a strong maintenance/leak-prevention programme to minimise the loss of refrigerant. If the equipment is located in a plantroom or similar space consider installing refrigerant leak detectors with alarm dial-out to the maintenance contractor. 2. Implement a stringent monitoring/recording programme for all refrigerant used on site, to enforce the leakage-control programme. 3. Where a building contains a number of similar systems that are in good condition, consider carrying out trial conversions to an HFC refrigerant on one or two systems, to provide a contingency plan if R22 becomes unavailable. 4. Ask your maintenance contractor to provide an update say every 6 months on the price of R22 and their ability to provide it within their allocation, and to advise immediately if any sudden change occurs. ACTIONS FOR SYSTEMS THAT CANNOT BE RETAINED AS IS 1. Establish whether part of the system can be retained e.g. for a ducted split air conditioning system, if the outdoor section needs replacing but the indoor section is still in good condition, investigate the possibility of fitting a new outdoor section using R134A, and retaining the indoor section. 2. If it is not practical to retain part of the system plan to replace it with a new system. NEW SYSTEMS The choice of refrigerant for a new system will depend on several factors: • The choices offered by the equipment manufacturers. • The expected long-term availability of the refrigerant. • The expected long term cost of the refrigerant. • The relative energy-efficiency of the system with each refrigerant. HFC refrigerants such as R134a, R407C and R410A are in very widespread use, but there are real long-term questions about their price and availability because of their relatively high Global Warming Potential, as detailed in Appendix 1. For now, the market has generally settled on the following alternatives to R22 for new plant. Small air conditioning splits and rooftop packages R410A Chillers R134a or R407C, R410A or ammonia Small commercial refrigeration R134a, R404A or other HFC’s Large commercial or industrial refrigeration Ammonia, carbon dioxide or R134a primary system with glycol secondary system. For large chillers and refrigeration systems, close consideration should be given to using natural refrigerants such as ammonia, carbon dioxide or hydrocarbons for their Replacement of HCF Refrigerant R22 110517 new logo.docx Page 7 efficiency, expected long life and low cost. For more information on these refrigerants see Appendix 2. As with all new and complex technology success or failure in the use of new refrigerants will depend on the level of attention to detail in design, installation and commissioning work. It is more important than ever to forge a strong relationship with very competent designers who are regularly receiving information on industry developments, who can help you to decide when to commit to a new type of system or refrigerant and who can prepare fully-detailed designs. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 8 APPENDIX 1 EFFECT OF GLOBAL WARMING POTENTIAL OF HFC REFRIGERANTS GWP is a measurement (usually measured over a 100-year period) of how much effect a refrigerant will have on Global Warming compared to Carbon Dioxide which has a GWP = 1. Thus, the lower a refrigerant’s GWP the better. EMISSIONS TRADING SCHEME New Zealand is committed to reducing its emission of Greenhouse Gases under the Kyoto Protocol, and the main mechanism for this is a form of carbon trading currently called the Emissions Trading Scheme. As presently structured this scheme will see the imposition of a carbon price levy on imported HFC refrigerants, commencing on 1 January 2013. The carbon price is based on the equivalent effect that 1kg of released refrigerant would have compared with 1 tonne of released carbon dioxide. For example, R134a has a GWP of 1300, which means that 1kg of R134a is equivalent to 1300kg or 1.3 tonnes of CO2. The price to be imposed per tonne is still unclear, but the likely impact is dramatically shown in the following extract from the Ministry for the Environment report on Emissions Trading from June 2008: The impact of a $30 per tonne CO2 price on average refrigerant prices will be substantial and should lead to some major changes in this sector in the long term. It would be equivalent to a basic price increase (before mark-ups) of $39/kg for R134a, $52/kg for R410A and $98/kg for R404A (compared with respective wholesale prices from Section 2.4 of $12/kg, $17/kg and $15/kg). The full report can be viewed at www.mfe.govt.nz/publications/climate/syntheticgreenhouse-gases-ets-jun08/html/page4.html The quoted value of GWP varies with different sources, but based on the Ministry’s data the GWP and carbon charge for various HFC refrigerants are as follows: Refrigerant 100 year GWP Carbon charge/kg @ $30/tonne CO2-equivalent HFC R134a 1300 $39 HFC R404A 3270 $98 HFC R407C 1600 $48 HFC R410A 1730 $52 HFC/HC R438A drop-in 1900 $57 If prices of this magnitude are imposed on HFC refrigerants they will be severely disadvantaged compared with R22 because as far as we can see there have been no proposals to place a Carbon Charge on R22 even though it has a 100 year GWP of about 1700 - presumably because of the phase-out programme. However, if substantial quantities of recycled R22 were to be imported it would seem that a charge would have to be applied, and on this basis the price would be similar to that of R410A. It is not clear whether a charge would also be applied to re-processed Replacement of HCF Refrigerant R22 110517 new logo.docx Page 9 R22 from existing systems Replacement of HCF Refrigerant R22 110517 new logo.docx in NZ. Page 10 POSSIBLE PHASE-OUT OF HFC’S To complicate the picture, there are strong moves afoot overseas to amend the Montreal Protocol so that HFC’s are also phased out quickly, on the basis that HCFC’s such as R22 should be replaced with natural refrigerants rather than with HFC’s. It remains unclear when/if this will happen, but it does add to the uncertainty surrounding the selection of refrigerants. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 11 APPENDIX 2 NATURAL REFRIGERANTS There is a huge emphasis overseas on developing the use of natural refrigerants such as ammonia, carbon dioxide and hydrocarbons as they are very cheap and efficient, with no ODP and very small GWP. They are widely regarded as being real long-term refrigerants. Lots of new equipment using ammonia and carbon dioxide is coming on the market, especially for large commercial and industrial refrigeration, and should be evaluated for any new proposed system. Ammonia has long been used for industrial refrigeration and has a very good safety record. Modern designs use much smaller quantities and usually confine it to a plantroom, with cooling being distributed by chilled liquids such as glycol/water mixtures. The capital cost can be 20 – 30% higher than for a conventional HFC plant, but the efficiency is similarly increased. Hydrocarbon refrigerants are available, along with suitable components such as compressors, but they are highly flammable so any installation must be designed in accordance with strict safety standards. A few designers in New Zealand have experience in this work, but unfortunately the Tamahere coolstore catastrophe has reduced the likelihood of such skills being developed in the foreseeable future. Once legal proceedings have been finalised it is hoped that lessons will be derived from the Tamahere disaster and used to develop comprehensive procedures so hydrocarbon refrigerants can be used safely. Replacement of HCF Refrigerant R22 110517 new logo.docx Page 12
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