Target of this article is creating a debate, comparing two different ways of seeing the refrigeration future. After interviewing Davide Sabbadin, Senior policy officer for climate EEB, and Marco Mancini, Fgas Legambiente manager, we listen to the opinion by Carmine Marotta, General Gas Managing Director
The market of refrigerating gases is under pressure: what is the current situation?
The market of refrigerating gases is living a transition phase ruled by the application of the European Regulation N° 517/2014. In the commercial refrigeration, the first centralized plants operating with mixtures of HFO refrigerant gases, characterized by GWP <150, are under construction.
The same have been chosen as alternative to centralized transcritical plants with CO2 for their better energy efficiency, their lower cost of the lifecycle and the better value of TEWI (Total Equivalent Warming Impact, corresponding to the sum of the direct emissions generated by the leaks of refrigerant gas in the environment and of indirect CO2 emissions deriving from the electric energy consumption). The better environmental characteristics and the lower lifecycle cost let us hope that such plant engineering solutions can soon arouse interest in the big distribution during next years.
In the environmental conditioning, chillers and heat pumps operating with R-454B, R-32 or R-1234ze have instead become integral part of plant manufacturers’ offer; concerning the market of splits/multi-splits, systems charged with R32 are increasingly taking hold, with a gradual decrease of R-410 market share.
How well has the combined Regulation 517 + DPR 146 worked and is it working?
The European Regulation N°517/2014 is working efficaciously, by decreasing year by year the mean GWP of refrigerating gases used in the European market and by reducing the GWP share according to what demanded by the Regulation itself.
The programmed decrease of the GWP share provided for by the Regulation has proven to be well-pondered to allow the production/import of what required by the European market.
The Regulation implementation proved instead to be absolutely inadequate in the control of illegal imports, as sufficiently efficacious control tools have not been provided in their check.
The draft of the Regulation 517 review has been just issued: what positive comments?
A first reading of the review proposed by the European Commission lets us hope that the necessary control tools to avoid the illegal imports of refrigerating gases can be foreseen and implemented in the definitive version of the review, with all stakeholders’ contribution.
The draft of the Regulation 517 review has just been issued: what negative comments?
The review proposed by the Commission provides for a cut of the GWP share in 2024 corresponding to 50%, referred to the share used in the 2021-2023 period, versus a 31% cut in the current version of the Regulation. In 2017 the cut would increase, rising the residual share to a 10% value of the 2015-reference share, against a residual 24% value foreseen by the present version of the Regulation. And finally, the cut carried out in 2030 on the proposed review would bring the residual share to 5% of the 2015-reference value, against an expected 22% value forecast by the current version of the Regulation.
EPEE, AREA and the European Heat Pump Association (EHPA) already expressed their opinion about the proposal some days ago:
i) The review proposed by the Commission is absolutely non-sustainable and non-compatible with the European Green Deal’s targets, goals that provide for the carbon neutrality reached in 2050 and a 55% decrease of CO2 released into the atmosphere; such targets need the transformation of fossil fuel boilers into heat pumps. If the share cut remains at the values proposed in the review submitted by the Commission, there will not be sufficient quantities of refrigerating gases to charge the necessary heat pumps.
ii) The value of the available share indicated in the Regulation currently in force is just sufficient to supply both the manufacturers of refrigeration and conditioning appliances and of heat pumps, and their service centres. A further share decrease would make the quantity of available refrigerating gases insufficient to ensure the production of what the market demands and of the plants existing on the market. We remind that the number of plants existing on the market is about 20-times the quantity of plants introduced into the market in one year.
Another negative aspect of the proposed review consists in the insufficient clarity in providing simple and precise indications about what it is possible to do and it is impossible to do in the management of refrigerants’ lifecycle end. Confusion remains in defining a simple precise waste management procedure, which does not give rise to misleading interpretations.
The refrigerant discharged from a plant to carry out a maintenance or to dispose the plant itself is a refrigerant characterized by the following problems: unspecific chemical composition, presence of oil and sludge, presence of humidity and non-condensable gases, presence of solid particulate, presence of high-boiling products.
That refrigerant, if it is charged as such in a refrigeration/conditioning plant, will generate significant decreases of the refrigeration/heating power delivered, decrement of the energy efficiency, possible failures of the compressor or of control devices. A plant charged with a refrigerant having such features consumes more electric energy and therefore it generates a bigger quantity of CO2 released into the environment.
Therefore, it would be necessary to fix some simple clear rules, providing for a regeneration of the refrigerants discharged from plants so that they can recover the purity required by the international AHRI700 standard, international quality standard that grants the highest possible energy efficiency. Moreover, we should also state clearly that a simple recycling operation carried out on board of the plant by means of recuperators adapted to recycling does not ensure the purity demanded by AHRI700 and then it does not assure the energy efficiency of the plant charged with recycled refrigerant.
How will the rising cost of electric energy influence operational choices?
In the market of the commercial and industrial refrigeration, the operation costs deriving from the use of electric energy in a plant operating with a HFO Low GWP refrigerant are on average lower that operation costs of transcritical plants operating with CO2 in the variable percentage from 20% to 35%, depending on environmental operation temperatures and the plant engineering configurations chosen.
It is easy to imagine how such percentage differences of costs remain unchanged when the cost of the kilowatt hour varies; the absolute difference of such costs is instead constantly rising in these months, incrementing by 3 or 4 times if we compare March 2022 with March 2021.
Therefore, increasingly investing in plant engineering solutions with high energy efficiency will become necessary. From such point of view, plant engineering solutions that exploit HFO Low GWP refrigerants are favoured in comparison with solutions that provide for the use of CO2, given their better energy efficiency.
Different is the comparison between the energy efficiency of the plants operating with HFO Low GWP and the energy efficiency of plants operating with R-290-propane refrigerant. The energy efficiencies of the plants operating with R290 are similar to the energy efficiencies of the plants operating with HFO Low GWP.
The difference moves to the flammability and explosion risk, being R-290 a strongly flammable A3 with high explosion risk against an A2L classification of HFO Low GWP, mildly flammable products with negligible explosion risk.
In the market of conditioning and of heat pumps, the need of choosing plant engineering solutions with high energy efficiency remains and, therefore, once more solutions operating with HFO Low GWP refrigerants like R-1234ze, R-454B and R32. In this sector as well, plant engineering solutions that work with R-290/propane are characterized by similar energy efficiencies; the flammability and the explosion risk remain very high.
The ecologic component is clear, as well as the energy one: to what extent are we facing the safety variable?
Very little. Or, at least, they have made very questionable choices from our point of view, such as the increment of the maximum admissible charge of either R-290 or R-600a, in sealed refrigeration systems, from 150g to 500g. Perhaps, very few people have seen the consequences of the explosion of a container housing 500 grams of R-290 – propane; perhaps the web might help in this.
Certainly, in the future it will be necessary to adopt a labelling that informs users about the safety level of refrigerating equipment, distinguishing safer appliances from less safe ones, as today the label makes a distinction between a more energy-efficient one and a less efficient one. Allow me a joke: since I know well the explosion risk of 500 grams of R-290, I assure you that in the next future I will feel the need of knowing whether, entering a restaurant, the owner will make me sit in front of a showcase having a R-290 charge corresponding to 500 grams instead of to 150 grams … Perhaps it is not precisely a joke.
Going back to the safety issue, we believe that we will still have to work hard at the training of the staff entrusted with the maintenance of appliances containing both flammable gases (A3, A2 and A2L) and both toxic (NH3) or asphyxiating (CO2 or A1) gases.
A F-Gas Regulation exists: when a N-Gas Regulation?
We hope as soon as possible. Our suggestion is drawing up a single regulation that contains the guidelines concerning the use of all refrigerating fluids in production and maintenance.
Moreover, we hope that such regulation adopts guidelines not only in terms of refrigerating gases’ GWP but also in terms of minimal energy efficiency of the plant engineering solutions adopted and of sector players’ training.
How much competence is needed to face this transition? Does this competence exist? And if it does not exist, how can we implement it?
The topics faced by the European Regulation and by reference Regulation need in-depth interdisciplinary competences. The road to be followed is certainly sector players’ constant continuous training: designers, installers and maintenance technicians.
We do not believe that the achievement of a simple certification is sufficient to make the necessary competence gained forever. Training courses in safety, efficiency, refrigeration efficiency and energy efficiency should be organized in such a way as to constantly update the competences demanded.
Is the GWP choice as main parameter for the phase-down sufficient to meet sustainability targets?
The GWP (Global Warming Potential of the refrigerant molecule, measured in kg of CO2 equivalent) measures the contribution of 1 kg of refrigerant in the greenhouse effect generation compared with the contribution to the greenhouse effect generation of 1 kg of CO2.
Therefore, the GWP of a refrigerant multiplied by the quantity of refrigerant that is dispersed into the environment owing to the leaks existing in a refrigeration/conditioning plant, measures the Direct Emission of CO2 equivalent into the environment generated by such plant.
Such contribution is equal to 2/4% of the Indirect Emission into the environment of CO2 equivalent generated for the production of the electric energy used by the plant (considering the coefficient of kilowatt hour transformation – CO2 generated that we have in Italy today).
The addition of Direct Emission (function of the used refrigerant’s GWP) + the Indirect Emission (function of the analysed plant’s Energy Efficiency) is equal to TEWI (Total Equivalent Warming Impact). Therefore, we hope that a review of the European Regulation adopts TEWI to identify the best possible technology in order to minimize the Total Emission of CO2 into the environment.
The current version of the Regulation, considering only the GWP of the refrigerant used, risks of imposing the use of more polluting technologies in terms of Total Emissions of CO2 into the environment. (Direct Emissions (GWP) + Indirect Emissions (Energy Efficiency)).
How can we implement the targets of emission reduction according to TEWI?
As explained at item 9. TEWI considers both Direct Emissions (deriving from refrigerant leaks into the environment) and Indirect Emissions (deriving from how the electric energy is used > Energy Efficiency of the Plant). Therefore, the plant engineering choices optimized according to the Total Emissions of CO2 into the environment will have to be made by favouring plant engineering solutions having the following features:
• Lower leaks in environment,
• Use of refrigerants with low GWP,
• High Energy Efficiencies.
Out of the three characteristics, the High Energy Efficiency preponderantly weighs (from 98% to 80%).
We remind that Direct Emissions (deriving from refrigerant’s leaks) weigh by 2 / 3 % on Total Emissions in case of refrigerants with Low GWP (R-455A, R-454C, R-454B, R-454A, etc.) and by 20% on Total Emissions in the case of refrigerants with Mean GWP (R-448A, R-449A, etc.).
How is the refrigerant market you would like?
The choice for each application of the best plant engineering technology in terms of environmental impact and safety.
Today this possibility exists, and there is the possibility of making such choice by using design tools aimed at that target and user-friendly guidelines to be followed. Therefore, it is always possible to choose the best plant engineering solution characterized by the minor value of TEWI and by sustainable costs for the market.
Certainly, this choice modality is a bit more complex than the simple choice of the refrigerant on GWP basis. It is anyway a possible choice by using user-friendly design and assessment software. Basically, the possibility of safeguarding the quality of the environment that we will leave to our children is certainly worth some further attention
