New DOE Regulations for Refrigeration Products

With the EPA issuing of its final rule on delisting select HFC (hydrofluorocarbon) refrigerants on July 2, 2015 many questions are being asked:

  • What direction are equipment manufacturers and distributors are taking and when to comply with the new ruling?
  • What is the timeline of complying with the new EPA ruling?
  • What about servicing existing equipment with a refrigerant that is being delisted?
  • What is the system I am installing classified as in the EPA’s final rule?

These are just a few of the questions we are hearing around the industry at this time. We have provided the FAQ’s provided by Heatcraft and an informative webinar led by Dr. Rajan Rajendran. Heatcraft (BOHN) Refrigeration EPA Final Rule FAQ will be very helpful for customers to quickly get informed of the recent changes coming. The FAQ also breaks down key timelines for compliance, as well as equipment definitions for new installations and retrofit installations.

To better help our customers understand these new regulations, and how they will affect their business, cfm will continue and compile the best resources from our partners, equipment suppliers, and HVAC/R industry associations. It comes highly recommended that all refrigeration customers become familiar with the EPA’s SNAP Program Fact Sheet! You can find this EPA SNAP Program Fact Sheet on the EPA Website at http://www.epa.gov/ozone/snap/index.html.

What is the Rulemaking?

On June 3, 2014, the Department of Energy (DOE) issued a final rule establishing energy conservation standards for Walk-In Coolers and Freezers (WICF) (10 CFR, Part 431, Docket Number EERE–2008–BT–STD–0015). Minimum efficiency levels for both the walk-in enclosure (doors and panels) and the associated refrigeration equipment were defined.

What is the scope of the Rulemaking?

The ruling includes enclosed walk-in coolers and freezers used for general storage which can be walked into, with a floor space of 3,000 ft2 or less. The ruling also includes unit coolers used for walk-ins attached to multiplex refrigeration systems serving multiple refrigeration loads, as are frequently used in grocery stores.

What refrigeration equipment/applications are not covered?
  • Equipment intended solely for scientific, medical or research purposes.
  • Condensing units solely designed and marketed to serve multiple WICFs or other pieces of refrigeration equipment (e.g., FlexPak).
  • Water cooled condensing units or systems.</li><li>WICF with floor space in excess of 3,000 ft2.
  • Compressorized racks that serve multiple refrigeration loads.
  • Remote air-cooled condensers and fluid coolers not used for WICF.
What is the effective date?

The effective date of the final rule was August 4, 2014. All equipment manufactured on or after June 5, 2017, must be compliant.

What has changed?

In reviewing the original rulemaking, the refrigeration industry identified a number of technical and procedural errors in DOE’s analyses that resulted in unreasonable and, in some equipment, unachievable minimum efficiency standards for refrigeration equipment. On April 2, 2015, the refrigeration industry, including Lennox/Heatcraft, filed a legal challenge against DOE requesting the errors be corrected, new refrigeration efficiency standards be established and a new compliance date set. On July 29, 2015, the DOE agreed to a settlement vacating portions of the original rulemaking related to refrigeration equipment standards and to work with the industry in defining new energy efficiency standards and a new enforcement date.

What does “vacating” of a rulemaking mean?

Vacating means the requirement to achieve the minimum energy efficiency targets by June 5, 2017, are no longer in effect and sent back to DOE to reestablish new minimum efficiency standards and a compliance date.

What are the key provisions of the settlement agreement?
  • The four (4) refrigeration standards for condensing units operating at medium temperature will remain at the original values, but will have their compliance date delayed;
  • The four (4) refrigeration standards for condensing units operating at low temperature are vacated;
  • The two (2) refrigeration standards for multiplex condensing units (evaporators) operating at medium and low temperatures are vacated;

The nine (9) standards and compliance date for panels and doors used in walk-in coolers and freezers remain unchanged.

What are the next steps in the process?
  • DOE will convene a negotiated rulemaking through an Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) Working Group with a targeted completion date of January 2016. Lennox/Heatcraft will participate in this effort.
  • DOE will align WICF enforcement dates by issuing an executive branch policy making clear that it will not enforce the remaining WICF refrigeration standards until January 1, 2020, provided the negotiated rulemaking delivers proposed standards to DOE by January 22, 2016.
When the new standards are determined what will be the enforcement date?

The new enforcement date has not yet been defined. However, it is likely that this date will be on or after January 1, 2020.

What about the standards for WICF doors and panels?

The WICF standards for doors and panels are not affected by this settlement and must be compliant by the original ruling date of June 5, 2017.

When the new ruling gets finalized and goes into effect, what are my responsibilities as wholesaler or installing

The DOE requires that the equipment manufacturer certify to DOE all equipment meeting the minimum efficiency regulations.

The individual who selects or installs this equipment must only use equipment which has been certified compliant by the DOE.

Does this regulation impact replacement equipment?

Yes, it will impact all equipment manufactured on or after the new enforcement date for both new and replacement applications.

Does the DOE ruling impact cold storage applications?

The DOE ruling only applies to WICF with a floor space of 3,000 ft2 or less. Cold storage applications with floor space of 3,000 ft2 or less will require compliant products. Cold storage applications with a floor space in excess of 3,000 ft2 will not be impacted.

What is the efficiency metric used by the DOE?

The efficiency will be measured with the Annual Walk-in Energy Factor (AWEF). AWEF is a measure of the annual efficiency of the refrigeration system and includes the impact of seasonal temperature changes, as well as, different WICF box loads. It is the ratio of annualized capacity divided by input power (BTUH/Watts).

How will the DOE ruling impact the cost of products I purchase?

It is too early to predict. Heatcraft will focus on minimizing the cost impact while still attaining the DOE minimum efficiency levels.

Is the ruling based on the date of sale, installation or date of manufacture?

The ruling is based on the date of manufacture. All products manufactured by commercial refrigeration equipment manufacturers after the new enforcement date must comply with the ruling.

How will this impact what I sell to my customer?

As the original ruling has been vacated there will be no impact to your business until the new enforcement date goes into effect. We predict a new enforcement date to be on or after January 1, 2020.

I am based outside the US and buy directly from Heatcraft. Will this impact what I buy?

The DOE ruling only impacts products sold and installed in the United States. As such, products sold to Canada, Mexico, Latin America or other regions outside of the United States are not required to comply with the DOE ruling. However, Natural Resources Canada (NRCan) has published a proposed efficiency rulemaking that will establish minimum efficiency standards for Walk-In Cooler &amp; Freezers that align with the DOE regulation.

How do we determine the energy efficiency on a field built system?
  • For systems that are selected as independently matched condensing units and unit coolers, the DOE WICF efficiency standard allows for certification of the unit cooler and condensing unit as independent components of a refrigeration system.
  • Each model of unit cooler and condensing unit impacted by the standard must meet the minimum AWEF standard to be used in the covered applications.
  • The manufacturer of the unit cooler or condensing unit is responsible for the equipment’s AWEF certification.
  • The appropriateness of the match of the field built system will be the responsibility of the contractor/distributor just as it is today.
Do the standards require a matched unit cooler and condensing unit selection with a specified expansion device?
  • No, the DOE standard only stipulates that the impacted unit cooler and condensing units have manufacturer’s AWEF certification. The standard does not require a specific expansion device for certification.
  • The control scheme of the condensing unit (reduced head pressure for example) may require changes in how the expansion device is sized or the style of expansion device.
How do we evaluate efficiency on a system with variable operating conditions and critical varying load?
  • The AWEF calculation for outdoor equipment is based on an average range of ambient conditions (i.e., bin data) as prescribed by DOE.
  • Indoor equipment is rated at typical indoor rating points as specified in the WICF standard.
Does the new DOE WICF standard require moving to a packaged system?
  • While packaged systems used in walk-ins are impacted by the standard and would be evaluated as a pre-matched system, the DOE standard does not mandate use of packaged systems. The standard allows for use of split systems with separate unit coolers and condensing units that meet the minimum AWEF values.
  • The AWEF calculation is similar for independent components, and there is no AWEF advantage to preselecting matched or packaged systems versus rating them as individual components.
Does the new DOE WICF standard require the use of specific refrigerants?
  • While the DOE WICF standard is based on the use of R-404A in the calculations, the standard does not enforce or require the use of this refrigerant exclusively.
  • As a result, the application of other refrigerants in the system is allowed and does not change the DOE AWEF rating.

What is the EPA SNAP Program?

The U.S. Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) is a program to evaluate and regulate ozone-depleting and high global-warming potential (GWP) chemicals as authorized by the Clean Air Act (CAA). As part of the SNAP program, the EPA both approves new and delists (i.e. deems unacceptable for use) existing refrigerants used in various end-use applications, including the food retail and food service sectors.

What is the SNAP Refrigerant Delisting Final Rule?

On July 2, 2015, the EPA issued its final rule on the delisting of certain hydrofluorocarbon (HFC) refrigerants for use in specific end-use refrigeration applications and communicated alternative refrigerants approved for use. The final rule will become effective on August 19, 2015.

Is this an official ruling from the EPA?

Yes, this is the final rule and was published in the Federal Register on July 20, 2015.

If I am installing a condensing unit that is serving a walk-in cooler/freezer in a supermarket application, must I be in compliance by January 1, 2017?

The January 1, 2017, date only applies to components tied to a multiple-compressor rack serving supermarket applications. The application described would need to comply with the Remote CDU date listed of January 1, 2018.

What if I am using a multi-compressor rack in a convenience store application, by which date must I be in compliance?

If the multiple-compressor rack is serving a food-service or food-retail function, the application falls under the supermarket end-use category and needs to comply by January 1, 2017.

Does the compliance date listed reflect the manufacture date, date of installation or date of commissioning?

The compliance date refers to the date the equipment is commissioned. Heatcraft strongly encourages all customers and concerned parties to become familiar with the rulemaking to better understand the potential impact on your business. For additional details on the final rule including a Fact Sheet created by the EPA summarizing the ruling, log onto the EPA’s SNAP Program website at http://www.epa.gov/ozone/snap/index.html.

Heatcraft Rulemaking FAQ
Heatcraft EPA SNAP Program FAQ
EPA Final Refrigerant Ruling Webinar

To help keep our customers, and other involved parties, informed we are sharing this webinar hosted by:

Dr, Rajan Rajendran
Vice President
System Innovation Center & Sustainability
Emerson Climate Technologies

- See more webinars and information at: http://www.emersonclimate.com/en-us/About_Us/industry_stewardship/E360/Pages/e360-webinars.aspx#sthash.wNntLGXb.dpuf



Click to view the original FAQ provided by Heatcraft and download the pdf files.

Have more Questions that didn’t get answered?  Let us know in the comment section, or Call Us Toll Free @ 1-800-322-9675

Pat Thomas
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