Workshop X Complying with the Major Changes in the U.S. EPAs - PDF document

Workshop X Complying with the Major Changes in the U.S. EPA’s Refrigerant Management Program Tuesday, March 27, 2018 3:30 p.m. to 4:45 p.m.

Biographical Information Kirk P. Lowery, P.E., Northeast Regional Director Trinity Consultants, 110 Pulsar Place, Suite 200, Westerville, Ohio 43082 614.433.0733 klowery@trinityconsultants.com Kirk Lowery is the Director of Trinity Consultants’ Northeast Region as well as the company’s expert on refrigerant management requirements. He leads Trinity’s refrigerant compliance services through the execution of compliance audits and the development of compliance management programs driven by 40 CFR 82 regulations. Kirk has assisted with the implementation of leak rate tracking programs for refrigerant-containing appliances with full charge of 50 pounds or more and has dealt with all facets of 40 CFR 82 compliance, including classification/phase-out, import/export, transformation/destruction, motor vehicle air conditioners (MVACs), labeling, and halon requirements. Kirk is the author and primary instructor of Trinity’s half day refrigerant regulatory workshop that has been provided across the nation since 2005 as well as several recent presentations and webinars on the new rules. Kirk also oversaw the implementation of the refrigerant compliance program for The Boeing Company’s Wichita, Kansas facility during his five plus years managing the air quality program for the facility. Kirk is a certified Professional Engineer in the states of Kansas and Ohio and a member of the Air & Waste Management Association. He received a Bachelor’s degree in aeronautical & aerospace engineering and a Master’s degree in environmental engineering, both from Purdue University. Sherry L. Hesselbein Group Counsel – Environmental, Safety & Security Law Marathon Petroleum Company LP, 539 South Main Street, Findlay, Ohio 45840 419-421-4616 shesselbein@marathonpetroleum.com Sherry Hesselbein is Group Counsel of the Environmental, Safety and Security group in Marathon Petroleum’s Legal Department. She joined the group in 2010 as the remediation attorney. She then counseled refining on environmental compliance and served as the Legal Department’s subject matter expert on the Clean Air Act. Sherry has also advised the company on fuels compliance and product quality matters before assuming her current role. Sherry has held multiple temporary assignments including Environmental Supervisor at the Catlettsburg Refinery. Prior to joining Marathon, Sherry was an associate in the Columbus office of Ulmer & Berne LLP practicing in the areas of environmental and construction law and an assistant attorney general with the Ohio Attorney General's Office Environmental Enforcement Section. Marathon Petroleum is a member of the American Petroleum Institute (API), the American Fuel and Petrochemical Manufacturers (AFPM), the National Association of Manufacturers and other trade associations. Part of Sherry’s role is to represent Marathon Petroleum on the legal committees of these associations. Sherry holds a J.D. from The Ohio State University Moritz College of Law and a B.S. in earth, atmospheric and planetary science from the Massachusetts Institute of Technology. She is a member of the Association of Corporate Counsel and the Ohio State Bar Association. She is also a past Secretary and member of Women for Economic and Leadership Development (WELD).

27 th Annual Business & Industry’s Sustainability and Environmental, Health & Safety Symposium Workshop X – Complying with the Major Changes in the U.S. EPA’s Refrigerant Management Regulations Kirk Lowery, Trinity Consultants Sherry Hesselbein, Marathon Petroleum Company LP March 27, 2018

Workshop X Overview  Introduction to refrigerant rules and basic refrigerant types  Refrigerant phase out or phase down  EPA’s Significant New Alternatives Policy (SNAP) Program  Montreal Protocol  Appliance servicing requirements  EPA’s 11/18/2016 rule revisions  Tips for facilities and HVAC/R contractors  Q&A

Introduction to Environmental Requirements for Refrigerants  International treaty – established in 1987 in response to hole in ozone Montreal Protocol layer that forms over Antarctica  Targets ozone depleting substances (ODSs)  Amended several times using “worst first” approach; recently amended to target Clean Air non‐ODSs Act,  U.S. law or statute – gives EPA Title VI authority to develop rules to implement Montreal Protocol  EPA rule – what you have to comply 40 CFR with on day ‐ to ‐ day basis Part 82

Basic Refrigerant Types (1 of 2)  CFCs – chlorofluorocarbons (e.g., R ‐ 11, R ‐ 12)  1st generation refrigerants  Class I ODSs with ozone depletion potential (ODP) > 0.2  Production phased out since 1996  HCFCs – hydrochlorofluorocarbons (e.g., R ‐ 22, R ‐ 141b, R ‐ 142b)  2nd generation refrigerants  Class II ODSs with ODP < 0.2  Production being phased out by 2020 (R‐22 phase out started in 2010)

Basic Refrigerant Types (2 of 2)  HFCs – hydrofluorocarbons (e.g., R ‐ 134a,R ‐ 407C, R ‐ 410A)  3rd generation refrigerants  non‐ODS, but several have high global warming potential (GWP)  Production targeted for future phase down  Next generation refrigerants  Non‐ODS and low GWP  Hydrocarbons ‐ e.g., R‐290 (propane), R‐600a (isobutane)  Hydrofluoroolefins (HFOs) – e.g., R‐1234yf  HFC/HFO blends ‐ e.g., R‐448A, R‐449A

How Do EPA’s Refrigerant Rules Impact Facilities and HVAC/R Technicians/Contractors? 1. Phase Out of Specific 2. Required Practices Refrigerants When Working on AC Units (Subparts A, C, G, & I) (Subparts B & F)*  Technician certifications  CFCs phased out of production in 1996 (e.g., R ‐ 11, R ‐ 12)  Evacuation & recovery (no venting)  HCFCs being phased out of production (e.g., R ‐ 22) by 2020  Disposal requirements  HFCs now targeted for phase down  Sales restrictions  SNAP Program  Leak repair provisions for units approves/disapproves substitutes with full charge ≥ 50 lbs  Reduces supply and increases cost  Promotes recovery, recycling, & reclamation *Commonly referred to as Clean Air Act Section 609 (mobile) and Section 608 (stationary) provisions

1. Developments in Refrigerant Phase Out Schedules

HCFC Phase Out is Here HCFC production phase out schedule   2015 = 90% 2020 = 99.5% overall and 100% for R‐22 & R‐142b  2030 = 100%   R ‐ 22 quandary  EPA production allocations = 13 million lbs (2017), 9 million lbs (2018), & 4 million lbs (2019)  EPA estimates recycle/ reclamation < 10 million lbs/year in 2016  Represent only a fraction of the ~200 million lb/year service need in the U.S.  Costs for R ‐ 22 have already risen 10x since 2006

HFCs are the New Target  HFCs (e.g., R ‐ 134a, R410A), which are the most common replacement for HCFCs, are the new target since they are potent GHGs  HFC targeting mechanisms  EPA’s SNAP Program  Kigali Amendment to Montreal Protocol  Expansion of 40 CFR 82, Subpart F (i.e., CAA Section 608) provisions to non‐ODS substitutes (will cover in Section 2)

HFCs are the New Target – SNAP Program  Stems from former President Obama’s Climate Action Plan, 6/2013  Obtained significant private sector commitments to reduce reliance on HFCs from HFC producers, appliance manufacturers, and other end‐users  Avoids >700MM metric tons of CO 2 e emissions  EPA removed SNAP approval of several HFCs in specific end ‐ uses  SNAP Rules 20 (2015) and 21 (2016)  Court vacated Rule 20 on 8/8/2017 (appeal has been filed)

HFCs are the New Target – Kigali Amendment  HFC phase down within Kigali Amendment to Montreal Protocol, 10/15/2016  2019 ‐ 10%  2024 ‐ 40%  2029 ‐ 70%  2034 ‐ 80%  2036 ‐ 85%  Relative to 2011‐2013 HFC baseline + 15% of HCFC/CFC baseline  Trump Administration expected to ratify since has industry backing?

How Should Facilities Prepare for Impending Refrigerant Phase Outs?  Facility managers must develop inventory of appliances (age, size, refrigerant type) to quantify exposure to expected rise in refrigerant costs  Watch for availability of next generation refrigerants (e.g., HCs, HFOs, HFO/HFC blends)  Obtain input from appliance manufacturers and HVAC/R contractors  Analyze new AC/R unit installations and retrofits based on available cost data and unit lifetimes  If R‐410A is facing an impending phase down, does it make sense to switch your R‐22 unit to R‐410A?

2. Developments in Required Work Practices when Servicing Refrigerant Containing Appliances

Subpart F Matrix by Appliance & Refrigerant Type (prior to rule revision) Venting Sales Evacuation Technician Disposal Leak Repair Category Prohibition Restrictions Req’s Certs Req’s Provisions Appliances w/ Yes No No No No No Non-ODS (unless listed as Substitutes exempt) Small Appliances Yes Yes Yes Yes Yes No ( ≤ 5 lbs ODS) (specific) (specific) Medium Yes Yes Yes Yes Yes No Appliances (no explicit (> 5 lbs & records) < 50 lbs ODS) Large Appliances Yes Yes Yes Yes Yes Yes ( ≥ 50 lbs ODS)