On September 26, 2016 the EPA issued a new Final Ruling updating the regulations for handling refrigerants. Don’t panic, there is plenty of time to prepare. For technicians, the first important enforcement date is not until January 1, 2018 and some parts do not take effect until January 1, 2019. However, you do need to prepare. There are more changes than I can list in a short blog post, but I will provide an overview and plenty of links to the information.
Mostly about Global Warming
Most of the changes have to do with limiting global warming by reducing the use and release of HFC refrigerants. Some of the more significant changes include requiring certification to purchase and handle HFC refrigerants, reducing the allowable leak rate for ozone depleting and global warming refrigerants, specifying regular leak inspection for equipment which has exceeded the allowable leak rate, and requiring record keeping when disposing of systems with more than 5 pounds of refrigerant.
Technician Certification
Staring January 1, 2018 technicians must be certified to purchase and handle nearly all refrigerants, not just ozone depleting ones. One curious exception is that sales of small cans of refrigerant for use in car air conditioning systems will not require certification. The cans will be required to have a valve, but sales to the general public will still be allowed.
Leak Rates Lowered
Starting January 1, 2019, the leak rates will all be lowered and will apply to HFC and replacement refrigerants as well as ozone depleting refrigerants. A few specific refrigerants are exempted from the venting prohibition and the leak requirements. These exempted refrigerants include carbon dioxide, nitrogen, water, ammonia, chlorine, hydrocarbons, and R441A. The leak trigger rates which require repair are now 30% for industrial process refrigeration, 20% for commercial refrigeration, and 10% for air conditioning and “other” uses. Note that the refrigerant charge level for these trigger rates remains at 50 pounds or more.
Leak Inspection
Beginning January 1, 2019, the new rules require regular leak inspection for systems that have reached the “trigger rate” requiring leak repair. The frequency of the required inspections is determined by the type of system and the size of the system charge. Quarterly inspections are required for commercial refrigeration and industrial process cooling systems which hold 500 pounds or more refrigerant. Commercial refrigeration and industrial process cooling systems holding at least 50 pounds of refrigerant but less than 500 pounds require an annual leak inspection. Air conditioning systems holding at least 50 pounds require annual leak inspections. When leaks are repaired, an initial system tightness verification is required before adding refrigerant. A second system tightness verification is required after the system is up and operating. Records of all of these tests are required.
System Disposal Record Keeping
Starting January 1, 2018 technicians disposing of systems with at least 5 pounds of refrigerant must keep records regarding the equipment and the refrigerant charge. Specifically, you must keep
The location, date of recovery, and type of refrigerant recovered for each disposed appliance
The quantity of refrigerant, by type, recovered from disposed appliances in each calendar month;
The quantity of refrigerant, and type, transferred for reclamation or destruction, the person to whom it
was transferred, and the date of the transfer. Note that you are not required to report the quantity of refrigerant recovered from each individual system, but rather, the cumulative quantity of refrigerant recovered each month.
Links to EPA Documents
This is just an overview. To really understand all the details you should consult the information published by the EPA. Here is a list of links to some of that information.
Advance Copy of Final Rule
https://www.epa.gov/sites/production/files/2016-09/documents/608_final_rule_pre-publication_copy.pdf
Subpart F—Recycling and Emissions Reduction
http://www.ecfr.gov/cgi-bin/text-idx?SID=085a41355598f2919b6655098a466757&mc=true&node=sp40.21.82.f&rgn=div6
Fact Sheet on New Regulations
https://www.epa.gov/sites/production/files/2016-09/documents/608_fact_sheet_technicians_0.pdf
EPA Page on Revised Regulations
https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations
EPA page on leak requirements
https://www.epa.gov/section608/stationary-refrigeration-leak-repair-requirements
Friday, September 30, 2016
Friday, September 23, 2016
HFCs not Going Anywhere
HFCs are not going away any time soon. I am sure you have all hear about the push to reduce or eliminate HFC refrigerants because of their global warming potential. This past weekend at Comfortech 2016 I sat in on a very informative session by Rob Yost on refrigerants. One big point was that low GWP replacement candidates for R410A are all rated at 2 or 2L for flammability. The reason is pretty straight forward. To be non-flammable a chemical must be relatively stable. However, that stability means it lasts longer in the atmosphere, which increases its global warming potential. In other words, low flammability and low global warming potential are somewhat opposites in terms of chemical properties.
The newest low GWP blends being developed are actually blends of both HFOs and HFCs. The highest pressure HFO developed at this time is very similar in pressure to 134a. Obviously that won’t replace 410A. However, mixing it with some higher pressure HFC refrigerants yields a much lower global warming potential than 410A at working pressures that are similar to 410A. However, this mixture will be flammable.
The current building codes in the US don’t allow flammable refrigerants inside buildings in most circumstances, so none of the refrigerants presently being studied can be used under the current building codes. The next revision for building codes is due out in 2018. However, the window for incorporating exceptions for lower flammability refrigerants into the 2018 code has already passed – and no exceptions or conditions for the use of 2L flammable refrigerants are in the upcoming 2018 code. That makes 2021 the closest date that flammable refrigerants could possibly be used inside buildings. Even though that is only a little over four years from now, we can be reasonably sure that no mass extinction of HFC refrigerants will occur any time soon.
Before we transition out of 410A to something else, the issue of using lower flammability refrigerants inside buildings will have to be addressed, and even then, it is likely that HFC refrigerants will be some of the components in the next generation of refrigerants.
The newest low GWP blends being developed are actually blends of both HFOs and HFCs. The highest pressure HFO developed at this time is very similar in pressure to 134a. Obviously that won’t replace 410A. However, mixing it with some higher pressure HFC refrigerants yields a much lower global warming potential than 410A at working pressures that are similar to 410A. However, this mixture will be flammable.
The current building codes in the US don’t allow flammable refrigerants inside buildings in most circumstances, so none of the refrigerants presently being studied can be used under the current building codes. The next revision for building codes is due out in 2018. However, the window for incorporating exceptions for lower flammability refrigerants into the 2018 code has already passed – and no exceptions or conditions for the use of 2L flammable refrigerants are in the upcoming 2018 code. That makes 2021 the closest date that flammable refrigerants could possibly be used inside buildings. Even though that is only a little over four years from now, we can be reasonably sure that no mass extinction of HFC refrigerants will occur any time soon.
Before we transition out of 410A to something else, the issue of using lower flammability refrigerants inside buildings will have to be addressed, and even then, it is likely that HFC refrigerants will be some of the components in the next generation of refrigerants.
Friday, September 16, 2016
Are You Keeping Up?
Technology is changing the HVACR industry so quickly that many techs get vertigo from the dizzying changes. It is tempting to try and “opt out” of the technological revolution and stick to the old familiar technologies you are comfortable with. However, your lack of participation will not slow the train, you will simply be left behind.
Before heat pumps were common in the southeast, I remember many techs declaring that they would not work on heat pumps. Today, any tech in Georgia who does not work on heat pumps does not work very much. I remember another time an older tech telling a story of how he retrofitted a system with a stack control and threw away that electronic junk. So the customer ended up paying a lot to downgrade their system because the tech did not understand it. Worse, it did not work well afterwards.
I know many techs today are leery of communicating control systems, variable refrigerant flow systems, electronically controlled compressor motors, and WiFi thermostats – just to name a few things. These things are not going to go away. Customers like them. They like the energy efficiency and convenience these products bring. If you don’t sell and service them, someone else will. The only logical course of action is to educate yourself on the emerging technologies found in the HVACR industry. This is a lifelong process. This year is not the same as last year, and there will be more to learn next year. I am older than most practicing HVACR techs, but I do not long for the “good old days.” I am too busy having fun with the new toys, there is just so much I need to learn.
Before heat pumps were common in the southeast, I remember many techs declaring that they would not work on heat pumps. Today, any tech in Georgia who does not work on heat pumps does not work very much. I remember another time an older tech telling a story of how he retrofitted a system with a stack control and threw away that electronic junk. So the customer ended up paying a lot to downgrade their system because the tech did not understand it. Worse, it did not work well afterwards.
I know many techs today are leery of communicating control systems, variable refrigerant flow systems, electronically controlled compressor motors, and WiFi thermostats – just to name a few things. These things are not going to go away. Customers like them. They like the energy efficiency and convenience these products bring. If you don’t sell and service them, someone else will. The only logical course of action is to educate yourself on the emerging technologies found in the HVACR industry. This is a lifelong process. This year is not the same as last year, and there will be more to learn next year. I am older than most practicing HVACR techs, but I do not long for the “good old days.” I am too busy having fun with the new toys, there is just so much I need to learn.
Sunday, September 4, 2016
Primary and Secondary Drain Connections
Have you ever wondered why evaporator coils often have several drain connections? It is not because the manufacturer had extra PVC drain plugs they needed to use. Most coils have both primary and secondary drain connections. Sometimes they have more than one set for convenience, and sometimes they have multiple sets because the coil can be positioned more than one way. It is important to recognize the difference between a primary and secondary drain connection and pipe them correctly.
The secondary drain provides an outlet for the water in case the primary gets plugged up. Since the secondary connection is a backup drain, it is located slightly higher than the primary connection. Sometimes this is done using an internal dam which forces water to go through the primary drain unless it is plugged up.
Most manufacturers recommend that the primary drain be trapped, but the secondary is typically not trapped. The secondary and primary should not run to the same drain line. If the drain line gets plugged up and both drain connections run to it, there is really no point in having a secondary drain connection. Often, the secondary drain line runs very short distance to an overflow drain pan or a condensate pump.
Another way to utilize the secondary drain connection is to install a condensate overflow switch on the secondary drain connection so that the system shuts down if water builds up to that level. I like that because the customer knows there is a problem and calls for a correction. If the secondary drain handles the water without incident it might not be noticed until it stops up as well.
I saw a system this summer which was several years old and had never been piped correctly. The primary and secondary drain connections had been swapped. The primary drain was piped to an overflow drain pan under the unit and the secondary drain was connected to the actual condensate drain line which was completely dry and clean. The overflow pan was full of brown slime, and the drain to that overflow pan had stopped up and the water was now overflowing into the ceiling. The difference in the two drain connections was obvious – the secondary drain connection was located higher. But maybe not so obvious to the installer. Just know that there is a reason for the two connections: one is for your primary drain and the other is to avert disaster. If you get them confused you are creating a future problem.
The secondary drain provides an outlet for the water in case the primary gets plugged up. Since the secondary connection is a backup drain, it is located slightly higher than the primary connection. Sometimes this is done using an internal dam which forces water to go through the primary drain unless it is plugged up.
 |
| Primary drain on the right and secondary drain on the left. Notice the internal dam on the secondary drain connection. |
Most manufacturers recommend that the primary drain be trapped, but the secondary is typically not trapped. The secondary and primary should not run to the same drain line. If the drain line gets plugged up and both drain connections run to it, there is really no point in having a secondary drain connection. Often, the secondary drain line runs very short distance to an overflow drain pan or a condensate pump.
Another way to utilize the secondary drain connection is to install a condensate overflow switch on the secondary drain connection so that the system shuts down if water builds up to that level. I like that because the customer knows there is a problem and calls for a correction. If the secondary drain handles the water without incident it might not be noticed until it stops up as well.
 |
| Overflow switch connected to secondary drain connection on the left. |
I saw a system this summer which was several years old and had never been piped correctly. The primary and secondary drain connections had been swapped. The primary drain was piped to an overflow drain pan under the unit and the secondary drain was connected to the actual condensate drain line which was completely dry and clean. The overflow pan was full of brown slime, and the drain to that overflow pan had stopped up and the water was now overflowing into the ceiling. The difference in the two drain connections was obvious – the secondary drain connection was located higher. But maybe not so obvious to the installer. Just know that there is a reason for the two connections: one is for your primary drain and the other is to avert disaster. If you get them confused you are creating a future problem.
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