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It’s Cool to Keep Service Records

New servicing requirements and proposed phase-down of HFC refrigerants place emphasis on record keeping, financial analysis

For retail facilities managers, the new servicing requirements and proposed production phase-down of hydrofluorocarbon (HFC) refrigerants mean they need to be organized and ready to crunch some numbers.

The Kigali Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer is expected to be ratified by the United Nations and put into effect Jan. 1, 2019. The goal is to prevent about 80 billion metric tons of carbon dioxide from being released into the atmosphere and to avoid up to a 0.5-degree Celsius increase in global temperatures by 2100.

In order to help the United States comply with the amendment, the Environmental Protection Agency is likely to amend its 40 CFR Part 82 regulations to implement the phase-down of HFCs, the third generation of refrigerants commonly used in HVAC systems, freezers, refrigerators and other cooling equipment. Unlike prior generations of refrigerants – chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) – HFCs do not deplete the ozone layer, but like those other refrigerants, they are greenhouse gases that contribute to climate change.

The Montreal Protocol phased out the production of CFCs, which have a high ozone depletion potential, by 1996 and the production of HCFCs, which deplete the ozone layer to a lesser extent, by 2020. As these refrigerants become increasingly scarce, they become more costly to obtain, said Kirk Lowery, Northeast Regional Director for Trinity Consultants, who advises clients on how to comply with environmental regulations.

With HFCs also expected to be phased down, retail companies will have to perform a detailed financial analysis when it comes time to install new cooling equipment or to retrofit their existing systems, Lowery said. The typical retail store has units using either R-22 HCFC refrigerant or R-410A HFC refrigerant, and when it comes time to upgrade from R-22, it might make sense for some retail stores to skip R-410A and go directly to the fourth generation of refrigerants, hydrofluoroolefins (HFOs) such as R-449A, which neither deplete the ozone layer nor contribute significantly to climate change.

“You might have to start looking at what the price of these refrigerants is expected to be and make a decision whether you’re going to go from R-22 to R-410A or whether you’re just going to go from R-22 right to R-449A or one of these fourth-generation HFO-based refrigerants and do an economic analysis that says, ‘When do I need to make that switch?’ ” Lowery said. “You might skip a generation of refrigerants because R-410A now has a target on its back just like R-22 has since 2010.”

Recent changes to the EPA’s 40 CFR Part 82 regulations will also require retail facilities managers to ensure specific work practices are followed when servicing or disposing of equipment that uses HFC refrigerants. Technicians servicing appliances containing HFC refrigerants will have to be EPA certified and use EPA-certified equipment to evacuate refrigerant into a separate recovery cylinder rather than venting refrigerant into the atmosphere.

Previously, these regulations only applied to CFC and HCFC refrigerants. These practices promote the recovery, recycling and reclamation of refrigerants so that existing inventories last longer, Lowery said.

In addition, refrigerant leaks on appliance circuits that contain 50 or more pounds of refrigerant and hit a certain trigger rate (10 percent for comfort-cooling appliances) must be repaired within 30 days. Owners/operators of these larger appliances must keep records documenting the date and type of service as well as the quantity of refrigerant added for a minimum of three years.

“The owner or operator is the one who must maintain the records, but if the maintenance is done by someone else like a contractor, the contractor has the responsibility to provide the information to the owner or operator when they’re done with the service so the owner or operator can maintain those records,” Lowery said. “Facilities managers will have to look at their existing systems for keeping the records and make sure they either already receive this information from their contractors or modify their system to be able to manage the new records they’ll have to keep starting in 2019.”

By: Nick Fortuna                    


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