The EPA Works to Finalize its Allocation and Production Rights for HCFC-22 for 2012-2014

There has been much recent discussion regarding the market for HCFC-22 in 2012, as the EPA works to finalize its allocation and production rights for 2012-2014. Here are some basic facts HARDI wanted to communicate to our membership.
 

1.)    There is an ongoing EPA rulemaking concerning the allocation of refrigerants, including R-22 for 2012-2014. The EPA has suggested a reduction of allocation rights of R-22 between 11% and 47% in each year (2012-2014), in addition to the annual 10% reduction each of those years set by the 2009 Allocation Rule. EPA’s proposed reduction was not unexpected, and is supported by some industry stakeholders.

2.)    Since the current rule is not final, it is illegal for a company with 2011 allocation rights to produce or imports HCFCs into the United States until receipt of a “non-enforcement” letter from EPA which was expected by many companies to arrive the first week of January; however this letter was delayed until Friday, January 20. Thereby, 15 work days had passed where no refrigerant production or importation occurred.

3.)    In this “non-enforcement” letter, EPA stated that production and importation should be limited to approximately 17% of a company's 2011 baseline until the rulemaking is complete. If, when the rulemaking is completed, the final reduction is less than 17% of the 2011 baseline, a company will be allowed to increase production and importation to their allocated limits. HARDI does not expect this rulemaking to be completed by the beginning of summer.

4.)    From 2005-2010 (2011 data is not yet available), only 77% of Consumption Allowances for HCFC-22 were used. These figures along with comment from stakeholders to the EPA, regarding the oversupply of R-22 in the marketplace and concerns of stockpiling, have led EPA to consider a more aggressive phasedown.

5.)    In 2011, EPA sought comment from the Alliance for Responsible Atmospheric Policy, of which HARDI and all major refrigerant producers are members, regarding a suggestion for a more aggressive reduction in R-22. The Alliance formally submitted a suggestion for a 20% reduction in Consumption Allowances.   

HARDI’s Refrigerants & Refrigeration Council is currently accepting member comments on what the annual reduction should be in this rule. 

Eco-friendly car refrigerant 'turns into deadly gas it vehicle catches fire'

By Henry Samuel, Paris

7:34PM GMT 17 Jan 2012

A new "eco-friendly" car refrigerant expected to become the industry standard turns into a deadly gas if the vehicle housing it catches fire and should be shelved, it has been claimed.

The coolant for car mobile air conditioning systems, called HFO-1234yf, has been approved for use in the US, Japan and Europe and Toyota and Suburu have started fitting their cars with the substance.

It was chosen as it is produces 98 per cent less climate damaging that its predecessor, R134a.

However, a German expert on the compound has warned that it is should be scrapped as it is much more flammable than the current coolant and when heated above 500C (932F) releases hydrogen fluoride, a highly toxic gas. Temperatures in car fires can easily reach twice that heat.

"You have 600g of this cooling agent per car, which if it burned completely would produce 200g of hydrogen fluoride at a level of concentration that is very high. For a human just one gram is deadly – either inhaled in gas form, through the skin or when dissolved in water," warned Prof Andreas Kornath, an inorganic chemistry professor at Munich University who has been studying the substance for 20 years.

The odourless gas has no instant effect but once inside the body a person dies within a day or so in terrible pain due to internal burns and muscle failure.

"This product should not be on the market. There is a real risk every time a car catches fire, which happens 30,000 times per year in Germany alone," he told the Daily Telegraph.

Prof Kornath issued his warning at the European Parliament in Strasbourg.

Honeywell, which produces the product, has refuted the claims.

"The risk of HF formation is not higher than with R134a – and this refrigerant has been used for decades without any recorded incident," said Honeywell's Sabine Chmielewski.

SAE International Cooperative Research Program, which comprises leading automakers, found HFO-1234yf to offer "superior environmental performance" to CO2 while having "the lowest risk for use in mobile air conditioning systems in meeting environmental and consumer needs."

But Prof Kornath alleged the product had been mainly approved on the basis of tests compiled by the chemical makers, not the findings of independent research.

BAM, Germany's Federal Institute for Materials Research and Testing, for instance, had warned of the risks of using it, he said.

He recommended using carbon dioxide as a coolant, as the fire risks and toxic hazards were nil.
Toyota confirmed it would start using the new refrigerant in new models starting this year.
The car maker’s spokesman Jean-Yves Jault said: “We think the new refrigerant is as safe, yet much more environmentally friendly, as the previous one. This was confirmed by the SAE CRP investigation whose outcome we support.”

"We undertook flammability tests and risk assessment with an independent third party institute, and the results confirmed the safety of the new refrigerant.”

He said that that the phenomenon of hydrogen fluoride gas is “not new", and that concentration of fluorine atoms was “actually much higher” in the historic refrigerant, R134a.

California, Quebec plan joint emissions allowance sale

13 Jan 2012 14:27 GMT

Portland, 13 January (Argus) — The Canadian province of Quebec will join California in selling emissions allowances at the first Western Climate Initiative (WCI) allowance auction on 15 August. The remaining members of the WCI held a stakeholder meeting in San Francisco yesterday in which they announced their commitment to the program. Quebec and California are the only partners of the initiative that have approved regulations to participate in the WCI's regional, multi-sector cap-and-trade system, which is due to begin in January 2013. The WCI, a partnership of Canadian provinces British Columbia, Manitoba, Ontario and Quebec and the state of California, aims to reduce greenhouse gas (GHG) emissions to 15pc below 2005 levels by 2020 through a carbon trading scheme. Six US states dropped out of the initiative last year to join an offshoot of the regional climate group that does not have a GHG cap-and-trade program. That group, known as North America 2050, aims to reduce GHG emission through carbon sequestration, sustainable biomass and the development of carbon offset projects. The WCI partners plan to release recommendations for a final offset system this month. Tim Lesiuk, chairman of the WCI's offsets subcommittee, said the initiative aims to come up with a common set of offset protocols that can be adopted across different member jurisdictions. Each member has the choice to adopt all or some of the protocols. “We would like to see four to five offset protocols this year,” Lesiuk said. Quebec plans to adopt offset regulation in spring or summer this year, said Robert Noel de Tilly, senior policy advisor in the climate change office for Quebec's ministry of environment. California has adopted four offset protocols, all based largely on voluntary protocols developed by the non-profit Climate Action Reserve. The state has adopted final offset protocols for US forestry and urban forestry projects and projects that destroy ozone depleting substances and capture and destroy livestock methane. Quebec has not released details of how many allowances it plans to sell at WCI's August auction. The province's cap-and-trade regulation directs its environment minister to make public 60 days before an auction the number and vintage of allowances that it will offer. Jean-Yves Benoit, treasurer economist in the climate change office at Quebec's environment ministry, told Argus the number of allowances the province will auction will not be released until this summer. A potential sticking point to Quebec's participation is the requirement that California submit a rulemaking amendment to the state Air Resources Board that would allow Quebec to link with California's cap-and-trade program. This rulemaking has to take place before Quebec can take part in the auction. Michael Gibbs, deputy secretary for climate change at the Air Resources Board, said it will be a “challenge” to complete this rulemaking in time for the August compliance auction. It is unclear when the other Canadian provinces will have regulations in place to participate in cap-and-trade. Lesiuk of British Columbia said the province is finishing a carbon price analysis of cap-and-trade and did not comment further on when it would be ready to trade allowances. Manitoba still does not have regulations in place to participate in the cap-and-trade program, though it is considering legislation, said Neil Cunningham, director of climate change for Manitoba. Plans to link other regional carbon trading schemes, such as the Regional Greenhouse Gas Initiative, with WCI appear to be off the table. Pat Cummins, WCI's project manager with the Western Governors' Association, said a North America 2050 working group that was working on linking emissions trading programs was not active. He also said the group's offset working group, which is focused on the development and implementation of offsets that can be used in emissions trading programs, is looking at voluntary rather than compliance offsets. Send comments to feedback@argusmedia.com

Summary of Meeting of the Parties to the Montreal Protocol

Halt on gas import

Samisoni Nabilivalu
Friday, December 23, 2011

THE Department of Environment has revealed that a batch of Refrigerant 134A (R134A) sold locally is actually not 100 per-cent R134A.

The imported refrigerant is used in the car air conditioning systems and commercial and domestic refrigeration.

According to the packaging, the cylinder contains R134A but tests conducted by Seru Ramakita, an Ozone Depleting Substances Inspector with Department of Environment, have proven otherwise.

Mr Ramakita made the discovery by accident earlier this year when demonstrating the use of a refrigerant identifier to customs officers at a workshop in Lautoka.

"The R134A I used for the demonstration was not 100 per cent," he said.

"It was cross contaminated with chlorofluorocarbon and hydro chlorofluorocarbons.

"I kept the discovery to myself because it was a big issue.

"I needed more evidence before we could make any moves and I was hoping one of the companies would bring it up as well."

Lincoln Refrigeration Limited director Praveen Singh was the first to approach Mr Ramakita after the processors for some of their fridges kept burning out.

Mr Singh said he suspected the R134A was inferior and Mr Ramakita confirmed his suspicions after he tested the gas.

"We also supply gas and we've never had this problem before.

"We had a shortage of gas, so we bought the R134A from another supplier," Mr Singh said.

Mr Ramakita confirmed all importers, wholesalers, and retailers of the product had been instructed to halt imports and remove the refrigerant from their shelves as investigations continue.

He said many businesses would have suffered unnecessarily if the product had continued to be used.

Mr Ramakita would not identify the manufacturer or local supplier of the product.

Dangerous R-134a Contamination Found Worldwide

December 21, 2011

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By aftermarketNews staff

EXTON, Pa. – Neutronics, a provider of gas analysis and gas handling technologies, yesterday issued a warning distributed by the Mobile Air Conditioning Society, advising that all industries using R-134a refrigerant immediately test all cylinders thought to be virgin R-134a (including new 30 pound cylinders) due to reports of widespread contamination.

Several months ago, Neutronics' Refrigerant Analysis Division was engaged by the ocean-going shipping industry to assist with a R-134a refrigerant contamination problem that reportedly resulted in several deaths and a significant interruption to ocean-going transport. During the course of this activity, Neutronics reports that it was discovered that this dangerous refrigerant contamination problem was not isolated to a single industry but had potentially penetrated the R-134a refrigerant supply for applications in many global markets, including automotive.

Much of the contaminated R-134a refrigerant has been shown to contain significant quantities of R-40 (aka Methyl Chloride or Chloromethane). R-40 is extremely toxic, flammable and highly reactive when exposed to aluminum in that it forms a third, highly volatile compound. Neutronics points out that it is critical to note the safety concerns with R-40. It is a harmful and dangerous material that is not suited for use in R-134a refrigeration air conditioning systems. Most, if not all of the contaminated R-134a has been found in counterfeit labeled "virgin" R-134a cylinders. In one instance, Neutronics says it was reported that "thousands" of 30 lb. R-134a refrigerant cylinders have been found to be counterfeits of name-brand product. Other suspect virgin R-134a containers have also been found to contain large quantities of R-22 and R-12 refrigerants.

Neutronics says it has evaluated the performance of both current and legacy refrigerant identifiers to determine their suitability for use in testing cylinders with the suspect R-40 material. To date, all reported cases of "virgin" cylinder contamination have included at least 30 percent to -40 percent R-40 in the cylinder.

No current or previous Neutronics R-134a identifier is/was designed for detection of R40 as a direct contaminant. Not all Neutronics refrigerant identifiers are suitable for safely detecting the presence of R-40 in R-134a (e.g. the "Mini ID R-134a" identifier is not suitable for R-40 detection).

A new reference chart published by Neutronics Refrigerant Analysis is now available on the Neutronics website that details the various Neutronics Identifiers currently in the field and how they should react when exposed to R-40 refrigerant. Interested parties should visit www.refrigerantid.com for more information. This information will be readily available on the home page.

As refrigerant identification equipment is widely used in the automotive service industry, Neutronics has determined that its "DX" model automotive refrigerant identifier that meets SAE J1771 requirements can be used for testing "virgin" R134a cylinders to determine the possible presence of the R-40 contaminant.

Neutronics Vice President Peter Coll commented, "As far as R-134a contaminants are concerned, R-40 is about as bad as it can get. Neutronics Refrigerant Analysis will continue to work closely with SAE, AHR and all other pertinent organizations to help mitigate this very troublesome development."

For additional information, contact Neutronics toll-free at 800-378-2287.

Québec Adopts Regulation Establishing the Cap-and-Trade System for Greenhouse Gas Emission Allowances

Yesterday, Québec's Minister of Sustainable Development, Environment and Parks, Pierre Arcand announced the adoption of the Regulation respecting the cap-and-trade system for greenhouse gas emission allowances, which is based on the rules established by the Western Climate Initiative (WCI).

"Cap-and-trade systems for emission allowances are recognized as one of the most effective and least costly economic tools for reducing greenhouse gas (GHG) emissions. By adopting this regulation, Québec acquires the means to achieve the transition toward a green, sustainable and prosperous economy", declared Minister Arcand.

Québec thus officially steps to the starting line, next to California. The first year of implementation of the system will be a transition year. It will begin on January 1, 2012 and will allow emitters and participants to familiarize themselves with how the system works. Over the course of the year, emitters will also be able to make any adjustments that may be necessary to meet their obligations under the system for capping and reducing GHG emissions, which will come into force on January 1, 2013. 

Industrial establishments subject to the system are those that emit 25 000 tonnes or more of CO2 equivalent per year. Note however that starting in 2015, companies that import or distribute in Québec fuels that are used in the transportation and building sectors (and whose combustion generates an amount of GHGs greater than or equal to 25 000 tonnes of CO2 equivalent per year) will also be subject to the capping and reduction of their emissions. 

For all participating members of the WCI, the adoption of a regulation establishing a cap-and-trade system for GHG emission allowances is the first of two main steps toward the emergence of a regional North American carbon market. The second step will consist of concluding a series of recognition agreements, between the different partners, to link their systems together. 

"The results of the international conference on climate change at Durban show clearly that regional initiatives like the WCI play a key role in efforts to reduce GHG emissions worldwide. Québec is one of the leaders in the fight against climate change, and that is something to be proud of," concluded the Minister. 

More information, including links to the text of the regulation, is available on the website of the Ministère at: 

http://www.mddep.gouv.qc.ca/changements/carbone/Systeme-plafonnement-droits-GES-en.htm