Challenge & Change
1st June 2022
Challenge and Change: Flammable, High Pressure or Toxic
The 2006 F-Gas regulations focussed efforts on reducing emissions through refrigerant leak reduction, whilst also encouraging innovation. The 2014 revision sought to drive innovation through an ambitious phasedown of high GWP HFC refrigerants based on TCO2e/percentage quota (ending with a 79% reduction by 2030.) We are now anticipating a third revision that goes beyond the global Kigali Agreement on the phasedown of synthetic refrigerants. Cynically, I see this as some sort of brinkmanship between policy makers, and a question could be posed as to the relevance of the F-Gas regulations now that we have the Kigali Agreement. The answer to this question is of course we need the regulations, but in my mind the latest revision should provide a framework that focusses on the technicalities of system types & sizes, charge volumes etc., with the phasedown timescale and percentage reductions being identical to the Kigali Agreement.
Back on topic – challenge and change. Whilst best practice and leak reduction should always be key focus areas for our industry, there are two significant issues that currently go above and beyond GWP as we move away from high GWP HFC refrigerants: safety first, then energy. Considering the latter first, the UK has seen astronomical >50% increases in the cost of energy and this impacts everyone, with further increases set for quarter 4.
Many people will have to choose between eating and keeping warm, and end users have a duty to try and mitigate rising costs to help manage escalating levels of inflation by keeping product costs as low as possible for their customers. Prior to the rise in energy costs, a 40,000 sq.ft supermarket would spend in the region of £120,000 per annum on refrigeration. We can now add a further £60,000 (over £1,000 per week, and even more in quarter 4) to their operating costs. For these reasons, I believe that energy consumption of refrigeration systems is a higher priority than GWP, so long as best practice and leak reduction testing and processes are followed.
The Bigger Picture
It is not all doom and gloom though, our industry has some of the very best engineers in the world who are constantly innovating: we can rise to the challenge of the phasedown, but it will take time, resource, and all-round upskilling. Something that we need to do is stop picking sides and having the ‘Natural’ and ‘Synthetic’ camps: it isn’t a case of football where we support one team or another, it is a case of innovating with urgency, based on guiding data and rising to the challenge of the phasedown where we consider safety first, and energy & emissions in equal measure to support our customers refrigeration policies and strategies.
There are of course other challenges: capital cost, maintenance cost (including system simplicity), skill base etc., but as technology evolves these challenges will in the long term be addressed. We are a great industry with lots of talented individuals and organisations, and we need to focus on the challenge at hand and not be swayed by external stakeholders whose only goal is to focus on GWP without considering any other metrics (such as energy and capital cost) that drive strategic technical direction within the framework of the F-Gas regulations.
The Choices – Take Your Pick
Take your pick, or however you want to describe it, our industry faces safety challenges. Low GWP refrigerants that meet the F-Gas regulations, and the Kigali Agreement are either flammable (we have two choices here – very flammable or a little bit flammable, but can cause a fire nevertheless!), high pressure (CO2 either sub-critical the pressures are high, or trans-critical where pressures are significantly high) and/or toxic. Ammonia usually comes to mind when thinking about toxicity in refrigeration, but in the world of a perfect storm many refrigerants can be toxic. Taking CO2 as an example, at 5,000 PPM in atmosphere nausea/dizziness can be encountered, and above 10,000 PPM death – a horrendous prospect. In my opinion anything that causes nausea, dizziness or asphyxiation could be considered toxic.
Rewinding back to the original F-Gas Regulations, the key focus was refrigerant leak reduction. The three ills introduced above will only become a reality when a refrigeration system leaks, hence the P in GWP being ‘Potential’. There is a little bit of irony and cynicism creeping in looking back to 2006 (did we fail, did the regulations fail?), but looking at the positives, regulation is driving innovation and challenging the art of the possible. Regardless of the three choices, the problem at hand is though we have fixed, or at least significantly reduced the risk to the natural environment, an important question is what if a major leak ensues and the risk of flammability, high pressure and/or toxicity is realised in someone’s personal environment? Injury or worse could occur. Looking at it more optimistically, these are worse case scenarios, so the question and focus of this blog will now consider how we safely mitigate these risks.
Risk Mitigation – Leak Detection
First and foremost, I am a strong advocator of fixed leak detection systems, whether it be aspirated or infra-red, both these options have significant benefits. When any refrigeration system is installed, it is done so with containment between the fixtures (display cases/room coolers) and plant. The relatively small cost to install additional small-bore diameter/network services to containment for the purpose of safety has always been a no-brainer to me.
The big cost can be its ‘front end’ but again it is a small price to pay for the sake of safety and mitigating risk. All types of leak detection can interface with the main BMS, so alarms in the event of a leak will be detected. Further considerations when specifying a leak detection system is good control, e.g., if using an A2L (mildly flammable) refrigerant, fixtures would want to be ‘shut-down’ through its solenoid/expansion via, and fans should stop running. Owing to an A2L’s density, design consideration like locating controllers on top of a display case is desirable, as is using ATEX rated lighting/switch gear. A further example is using CO2, it is important that the refrigerant cannot be trapped due to its volatility – its pressure will increase rapidly if entrapped. This brings me on to next stage of mitigation – training!
Risk Mitigation – Training
Specifically relating to the food retail sector, we have seen a significant upskill in technicians working with flammable, high pressure and toxic refrigerants in the past decade. This is largely due to the work of the excellent training providers that we have in our industry. Though away from the food retail sector (and industrial sector), there are significant concerns. The larger portion of our industry is made up of small contractors who provide services to small end users of refrigeration. The problem here is that they do not have significant training and development budgets and there are only so many hours in a day and these are spent on maximising the uptime of their customers equipment. Furthermore, their customers cannot afford to invest in low-GWP technology, and likely have no or very little visibility of the phasedown.
Keeping on the topic of industry challenge and change, in recent weeks I have picked up on an external stakeholder to our industry who have been quick to pick up and criticise what one large end users may or may not be doing and also suggesting ‘fear-mongering’ exists in our industry (please forgive our industry for doing the right thing in taking a cautious and balanced approach to flammable, high-pressure and toxic refrigerants!) Perhaps external stakeholders time would be better spent on lobbying government to ensure that the aims of F-Gas and Kigali can be achieved throughout our industry through incentives (tax breaks etc.) – including large and small end users who have training constraints as raised above. Regarding this retailer, there was no reference to their success of having the lowest leak rate of all their peers, just criticism of a relatively small project that was taking a considered approach to new, low charge air handling equipment that applied a tried and tested refrigerant before expanding the trial to new, low-GWP refrigerants. If external stakeholders took an objective approach they would see and understand the huge strides in innovation made by all food retailers and their supply chain in the last five years. They would also learn about the challenges that we as an industry face – it isn’t just GWP, there are many considerations: safety, capital cost, maintenance (cost and simplicity), skill base, energy and having the ability to change direction if required.
In the current world of challenge and change, there is no silver-bullet refrigerant, we must learn to work with flammable, high-pressure and/or toxic refrigerants. We are faced between trading GWP for energy, whilst our customers are also having to accept capital and maintenance cost increases as the phasedown begins to bite with greater impact. Irrespective of choice, we should seek to maximise energy efficiency and follow best practice and accept that some refrigerants are more efficient than others and depending on application some are more suitable than others – I will pick up on applications in my next blog.
Comments and questions are welcome – I can be contacted by e-mail: firstname.lastname@example.org