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Chair Mary Nichols
California Air Resources Board
1001 I Street
Sacramento, CA 95812
CC: Elizabeth Scheehle, Michael FitzGibbon, Pamela Gupta, Richie Kauer
Re: <150 GWP Refrigerants for Ice Rink Refrigeration Systems
Dear Chair Nichols,
The Environmental Investigation Agency (EIA) and International Institute of Ammonia Refrigeration (IIAR) submit this letter, with the support of companies and organizations listed below. Together, we support enacting pragmatic regulations to reduce emissions of hydrofluorocarbons (HFCs) and encourage low-global warming potential (GWP) refrigerants in ice rinks and other stationary refrigeration equipment.
Our organizations share a concern that a 750 GWP threshold for new ice rink refrigeration systems outlined in the current proposed HFC rulemaking would lead to unnecessary displacement of existing ice rinks using refrigerant with zero climate impact by systems using HFC-blend refrigerants with GWPs above 600 and lower energy efficiency. This would result in an emissions increase from ice rinks and lock-in higher GWP refrigerants for the 25-year lifetime of new equipment, making it more difficult to meet the state’s 2030 HFC reduction target and net zero emission goals.
We therefore strongly support a revision of the proposed HFC regulation to reduce the GWP prohibition from 750 down to under 150 for new refrigeration systems in new and existing ice rinks. This is consistent with the proposed HFC regulation’s treatment of other types of stationary refrigeration systems where <150 GWP alternatives are already widely in use. California’s policies as a climate leader on reducing HFC emissions hold great importance to setting precedent across the United States and around the world. This proposed regulation marks the first of its kind globally that specifically targets a GWP threshold for refrigerants in ice rink refrigeration systems and as such would send a strong signal on the direction of the global market for ice rinks.
Two existing refrigerants under 150 GWP are widely available and sufficient to meet the needs for new equipment in both new and existing ice rinks: ammonia and CO2. Ammonia, with a zero GWP, has been used in the vast majority of ice rinks in California and around the world. More than 80% of known ice rinks in California use ammonia refrigerant. CO2, with a GWP of 1, is also growing in use. Over the past 10 years, over 75 CO2 ice rink systems have been installed in North America. Ammonia or CO2 systems for ice rinks have a first cost that is often comparable to systems utilizing HFC alternatives, and deliver energy benefits that further reduce the total cost of ownership. Under 150 GWP HFO-based refrigerants have also been identified that could be used in future.
As follows are specific points supporting the technical feasibility, cost-effectiveness, and climate benefits of enacting a 150 GWP threshold for ice rinks:
- Of the more than 100 ice rinks in California, fewer than 20 ice rinks are registered in the Refrigerant Management Program (RMP) database due to their use of >150 GWP refrigerants. More than 80% of California ice rinks already use refrigerants with a GWP of less than 150. If the HFC Regulation allows the use refrigerants having GWP as high as 750, as systems age, these systems which currently use ammonia could be replaced with R-513a thus significantly increasing the GWP footprint of ice rinks. This displacement would occur not because of a lack of other available options or a technical superiority of HFC-based refrigerants, but due to paid marketing of these refrigerants inaccurately labelling them as ‘low-GWP’ and ‘environmentally friendly’, claims that CARB’s 750 GWP threshold would only reinforce. These marketing campaigns often also make exaggerated or misleading statements about hurdles to using ammonia or CO2 systems.
- Virtually every ice rink uses an indirect system (a primary refrigerant cools a brine or glycol solution in a ‘chiller’). These can be easily retrofitted with any refrigerant package, making it easy to replace most of the small percentage of existing HFC- or HCFC-based systems with an ammonia or CO2 chiller. Typical ice rinks require from 80 - 300 TR (Tons of Refrigeration) and this can be accomplished with approximately 2 pounds of ammonia per TR, thus limiting most ice rink chillers to 160 - 600 pounds of ammonia contained within the chiller package located within the utility room.
- Ammonia systems are only about a 5% cost premium when compared to R-513a systems. This additional cost is typically paid back in fewer than 5 years based on ammonia’s superior energy performance and typically increases the operational longevity of the equipment as well.
- In addition to having a >600 GWP, R-513a and other HFC-blends are medium temperature refrigerants and require roughly 30% more energy than ammonia at conditions required for ice rink refrigeration systems. Ammonia systems also use a flooded chiller, which are more efficient versus a direct expansion chiller typically used with HFC-based refrigerants.
- R-513a, Ammonia, and CO2 systems can all use air-cooled condensers to reduce water consumption. There is no inherent increase in water consumption as a result of using ammonia or CO2.
- Federal and state regulations and fire-safety and mechanical codes allow and enable safe use of ammonia, including in a range of facilities located in and around urban areas. In fact, California’s state fire and mechanical codes reference robust safety standards developed by the IIAR. IIAR has an entire suite of standards that regulate ammonia refrigeration from initial design, through construction, operation, maintenance and eventually decommissioning. Beyond publishing industry standards, IIAR also publishes model programs for risk management and offers training and certification programs for workers in the industry. No other refrigerant has a level of infrastructure support that even remotely compares to what is available to support the safe use of ammonia. EPA and OSHA both have General Duty clauses, which require that a facility provide a safe working environment for employees and the community. In brief, this means that any facility with a regulated chemical, (ammonia), under the “threshold” quantity, (10,000 pounds for ammonia), must nonetheless have a management program. IIAR developed and maintains a “Low Charge Ammonia Refrigerant Management Guideline” that provides easy guidance for developing, implementing and maintaining a management program at a facility.
- Technology available to ensure the safety of ammonia systems has continued to evolve significantly, including:
a. Lower charge systems using up to 80% less refrigerant over traditional systems
b. Water dispersion tanks – neutralize ammonia refrigerant
c. Transfer systems – a system that senses refrigerant leaks and automatically pumps refrigerant to a secure vessel
- It must be noted that if arguments are still made about safety as a concern for ammonia, two of three known safety incidents involving fatalities from ice rinks were from systems using synthetic refrigerants with similar properties to R-513a.
- Training for design, operation, and safety of ammonia and CO2 systems is widely available from our strongly affiliated group of non-profit associations:
- The IIAR Academy of Natural Refrigerants online learning management system provides training courses for IIAR’s safe design standards, for Ammonia Refrigeration Management Guidelines, and training videos on basic ammonia refrigeration.
- ASTI (Ammonia Safety and Training Institute) provides safety management support through effective use of Prevention, Mitigation, Preparedness, Response and Recovery training that teaches industry users, firefighters, and other first responders how to prevent and respond to ammonia leaks.
- RETA (Refrigeration Engineers and Technicians Association) provides online and in person refrigeration technician and operator certification courses plus training for ammonia refrigeration, refrigeration system controls, and safe practices when operating and maintaining ammonia and CO2 refrigeration systems.
- Several contractors in California specialize in servicing natural refrigeration systems. There are many options and systems available to obtain a competitive solution that fits specific needs.
Based on the aforementioned points, we strongly urge the California Air Resources Board to limit refrigerants in new ice rink systems to those with GWP less than 150. The overwhelming majority of ice rinks already use refrigerants with GWP of 1 or less. It would, hence, be a major step backwards for California to enact a law that allows replacement of climate-friendly ice rinks with >600 GWP refrigerants. This would increase HFC emissions in California and hold the state back in meeting its ambitious climate goals.
Thank you for considering and we would be happy to discuss any points in this letter in further detail upon request.
Sincerely,
Alexander von Bismarck, Executive Director
Environmental Investigation Agency
www.eia-global.org
Gary Schrift, President
International Institute of Ammonia Refrigeration
www.iiar.org
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