Environmental Permitting

Managing Refrigerants—It’s a SNAP!

Many refrigerants have been determined to be ozone-depleting substances (ODS) and have been targeted for phaseout under the Montreal Protocol. Chemicals used in the Refrigeration and Air-Conditioning industrial sector is one group for which the U.S. Environmental Protection Agency (EPA) has reviewed and identified substitutes under the Clean Air Act’s (CAA) Significant New Alternatives Policy (SNAP) program. The purpose of the SNAP program is to allow transition away from ODSs by identifying substitutes that offer lower overall risks to human health and the environment. Today we will look at recent refrigerant substitutes under SNAP, and tomorrow, we will review a recent refrigerant enforcement case.

Note: Just because a refrigerant can be used as a substitute for an ODS under the SNAP program does not mean that it is not regulated at all. For example, we have heard a lot lately about problems with ammonia releases. Ammonia can be used as a substitute for ODSs in commercial or industrial process refrigeration or in absorption units. However, anhydrous ammonia is regulated by both OSHA and the EPA, with an emphasis on preventing releases.

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Back to SNAP

The EPA does not test refrigerants under the SNAP program. Rather, it reviews information submitted by manufacturers and independent testing laboratories.
Lists of acceptable and unacceptable substitutes are updated by the EPA several times each year. These lists include substitutes that are either:

  • Acceptable, which means that they may be used without restriction in specific end uses;
  • Acceptable subject to narrowed use limits, which means that a substitute may be used only within certain specialized applications within a sector end use, and may not be used for other applications within an end use or sector. For example, some alternative fire suppressants may be used as total flooding agents in normally unoccupied areas, but not in occupied areas; or
  • Acceptable subject to use conditions, which means that a substitute is acceptable only if used in a certain way. For example, a substitute may be acceptable provided it is used with unique equipment fittings.

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President Obama’s Climate Action Plan called on the EPA to encourage private sector investment in low-greenhouse gas (GHG) emissions technology by identifying and approving climate-friendly chemicals under the SNAP program. According to the EPA, the use of hydrofluorocarbons (HFCs) is rapidly increasing because they are the primary substitutes for ODSs, especially in the largest end uses. The administration maintains that though they represent a small fraction of current total GHG emissions, their global warming potential (GWP) is hundreds to thousands of times higher than that of carbon dioxide and other GHGs.

In a final rule in April, the EPA approved five flammable refrigerant substitutes as
acceptable, subject to use conditions, in several refrigeration and air-conditioning end uses. The substitutes and end uses are:

  •  Ethane in very low temperature refrigeration and in nonmechanical heat transfer;
  •  Isobutane in retail food refrigeration (stand-alone commercial refrigerators and freezers) and in vending machines;
  •  Propane in household refrigerators, freezers, or combination refrigerators and freezers, in vending machines, and in room air-conditioning units; 
  •  The hydrocarbon blend R-441A in retail food refrigeration (stand-alone commercial refrigerators and freezers), in vending machines, and in room air-conditioning units; and
  •  HFC-32 (difluoromethane) in room air-conditioning units. HFC-32 has one-third the GWP of the conventional refrigerants currently being used in room air-conditioning units.

In the same final rule, the EPA has also exempted all of these substances, except HFC-32, from the CAA venting prohibition. The venting prohibition prohibits the knowing venting or release of refrigerants or substitute as a result of maintaining, servicing, repairing, or disposing of appliances. There are exceptions for some chemicals for specific end uses.

Note: Isobutane and R-441A were previously listed as acceptable, subject to use conditions, in household refrigerators, freezers, and combination refrigerators and freezers, and propane was previously listed as acceptable, subject to use conditions, in retail food refrigerators and freezers (stand-alone units only).This latest rule added more end uses for these three chemicals.

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