U.S.

Environmental Protection Agency

Mobile Air Conditioning (MAC)
Regulatory Landscape
Karen Thundiyil
United States Environmental Protection Agency
Bogot, Colombia

Agenda
1.
1.MAC
MACRegulatory
RegulatoryOverview
Overview

2.
2. New
New Alternatives:
Alternatives: SNAP
SNAPProgram
Program
3.
3. MAC
MACServicing:
Servicing:Section
Section609
609
4.
4. MAC
MACDisposal:
Disposal: Section
Section608
608
5.
5.On
Onthe
theHorizon
Horizon

MAC Regulatory Overview

New
Operation and
Alternatives
Servicing
Allow the safe use
of non-ODS
refrigerants

Section 609

Disposal
Section 608

Several opportunities to reduce unnecessary

MAC refrigerant emissions

Significant New Alternatives

Policy (SNAP) Program
U.S. Clean Air Act directs EPA to evaluate and list
substitutes for ODS that reduce overall risk to human
health and the environment
EPA reviews substitutes in 8 industrial sectors,
including the mobile air conditioning (MAC) sector.
Substitutes can be found acceptable, acceptable with
use conditions, acceptable with narrowed use limits or
unacceptable.

SNAP Program
MAC substitute list available at:
http://epa.gov/ozone/snap/refrigerants/lists/mvacs.html

Some MAC refrigerants are explicitly banned

Proprietary blends of HCs
Some refrigerants are only allowed in New
MAC systems; some refrigerants are allowed in
New and Retrofit MAC systems.

SNAP Program
Recently, EPA found R152a acceptable with
use conditions in new MAC systems
EPA proposed to find R744 acceptable with
use conditions in new MAC systems
Safe use guidance document issued with
recent EPA GHG ANPR
Currently reviewing low GWP alternatives

SNAP MAC R744 Guidance

ANPR
ANPR Guidance
Guidance Document
Document

Engineering strategies and/or devices must be

incorporated into the system to prevent
foreseeable leaks into the passenger
compartment do not result in concentrations
greater than the CO2 STEL of 3% over 15
minutes.

NEW MAC SYTEMS ONLY

SNAP MAC Final Rule

R152a
R152a Use
Use Conditions
Conditions

Engineering strategies and/or devices must be

incorporated into the system such that
foreseeable leaks into the passenger
compartment do not result in R152a
concentrations of 3.7% v/v or above in any
part of the free space inside the passenger
compartment for more than 15 seconds when
the car ignition is on.

NEW MAC SYTEMS ONLY

Flammability is Not All the Same

When is the fluid flammable?
Lower Flammability Limit (LFL)
Upper Flammability Limit (UFL)

What is the ignition source?

Flame vs. spark
Minimum ignition energy

What are the consequences?

Temperature, energy, byproducts, etc.

Flammability is Not All the Same

Fluid

LFL
UFL
Auto[%v/v] [%v/v] Ignition
Temp [C]

Heat of
Combustion
[Btu/lb]

methane

4.8

16.3

540-705

ethane

2.9

13.0

510-630

propane

2.0

10.1

450-510

21,625

n-butane

1.5

10.3

405-510

21,281

isobutane

1.0

10.0

420-530

21,195

hydrogen

4.0

75.0

520

~55,000

R-152a

3.7

20.2

455

7,266

Definition of Flammable
ASHRAE Standard 34, ISO Standard 817
dont define flammable
But they do classify refrigerants based on
flammability under standard tests (e.g.,
ASTM E681)
- ASHRAE Standard 34 classifies refrigerants as 1, 2 or 3
based on LFL and HOC
- ISO 817 draft suggests classification of 1, 2L, 2H or 3
based on LFL, HOC and burning velocity
- Auto-ignition temperature is NOT a criterion

Use of Flammable Refrigerants

CFC days
HCs in centrifugal chillers in petrochemical plants
Wide use of ammonia in various refrigeration and air
conditioning applications
HCs in some modern refrigerators
HCs in a small percentage of chillers, room ACs, etc.
Illegal, unadvised use of HCs in MACs in U.S.,
Australia, elsewhere

Flammable Refrigerants Can Be Safe

Engineering and Training allow for safe use
- Workers in petrochemical plants deal with flammable fluid regularly
- Ammonia often located in isolated locations (e.g., by use of
secondary loops) to reduce risk of general consumer exposure
- HC refrigerators use sealed or non-sparking electrical
devices, avoid brazing on charged systems, protect
refrigerant systems from damage to help avoid leaks, etc
- Consumer MACs may be designed for R152a use
- No consumer MAC has been designed to use HC refrigerant

Accidents Have Occurred

Beer cooler incident in Australia
Converted Porsche using Enviro-Safe in U.S.
Demonstration in Australia resulting in hospital
trip
U.S. Department of Justice reports:
10/19/95, Orange County, CA: charging while engine was still hot
8/18/96, Gulfport, MS: low pressure hose from evaporator blew off
9/27/96, Danville, AR: torch used on truck AC unit after venting
refrigerant

U.S. EPA Policy on Flammable

Refrigerants
SNAP Program regulates ODS substitutes in
retrofit and new systems
R152a allowed in domestic refrigerator/freezers
and in new MAC systems designed for R152a
Certain HCs allowed in Industrial Process
Refrigeration (3/18/94)
EPA recommended that HCs be used only at industrial facilities
that manufacture or use hydrocarbons in the process stream

U.S. EPA Policy on Flammable

Refrigerants
Certain HCs specifically prohibited in MACs
(3/18/94)
Information provided did not adequately characterize
risk
Submitted
Response
Four petitions have been
1 Nov 1994
Sept 1995
submitted; all denied
2 Dec 1995
Aug 1996
EPA was sued; EPA
3 May 1998
Nov 1998
decision was backed by
4 July 2003
Jan 2004
court of law

U.S. EPA Policy on Flammable

Refrigerants
All flammable refrigerants specifically
prohibited (6/13/95)
In 2008, exempted R152a
R152a is acceptable for new MAC systems
with use conditions to mitigate risk
Proponents are not selling or suggesting R152a should be used
as a retrofit gas
Industry/EPA/Army cooperative risk assessment
Risk is comparable to new CO2 MAC systems (i.e., if
concentration is below a threshold of concern, risk is low)

Other Considerations
Some States prohibit HC use in MACs
Joint EPA-NHTSA Consumer Warning
Since no valid risk assessment addressing the
safety of HC refrigerants in either type of system
has yet been submitted under the SNAP program,
EPA does not believe that HC refrigerants have
been proven to be a safe substitute for either
CFC-12 or HFC-134a in motor vehicle air
conditioning systems. www.epa.gov

Risk Screen Elements Leaks

Containment reliability
During lifecycle of refrigerant and product manufacture,
transport, use, service, disposal

Exposure to
Service personnel, vehicle occupants, etc.

Leak detection
Background level and noise
Time to threshold level of concern vis--vis identification and
mitigation system activation

Mitigation of concentrations above threshold level

of concern

Risk Screen Elements

Amount of refrigerant used/leaked (charge
size)
Refrigerant properties (LFL, HOC, etc.)
Likelihood of ignition
Consequences of ignition
Mitigation of consequences

See EPA/US Army R152a & R744 Risk

Assessment

Risk Screen Elements

HC contamination of existing systems does
NOT prove safety
Use in other applications does NOT prove
safety
Past and current use does NOT prove safety
Large sales volume does NOT prove safety
Claiming no reported fires does NOT prove
safety

MAC Risk Assessment

September 2006 U.S. Army/EPA risk
assessment available at
www.regulations.gov
Search for:
EPA-HQ-OAR-2004-0488-0025.2

Break

SNAP Review of Alternatives

Have not received a complete submission
for a low GWP refrigerant
New chemical alternatives must undergo
review under both section 612 and section 5 of
Toxic Substances Control Act (TSCA)

SNAP Review of Alternatives

The New Chemicals Program functions as a
"gatekeeper which can identify conditions, up to and
including a ban on production, to be placed on the use
of a new chemical before it is entered into commerce.

http://epa.gov/oppt/newchems/index.htm
Extensive coordination between SNAP and
premanufacture notice (PMN) underway
SNAP defers to PMN on evaluation of toxicity
results and AELs

SNAP Review of Alternatives

SNAP
SNAP criteria
criteria for
for review
review

Atmospheric effects and related health & environmental

impacts
General pop risks from ambient exposure to compounds
with direct toxicity and to increased ground-level ozone
Ecosystem risks
Occupational risks
Consumer risks
Flammability
Cost & availability of the substitute

SNAP Approval Timing

EPA's 90-day review period for SNAP
submissions would begin once EPA receives a
complete submission
As with R152a, approval of any flammable
substitute requires a rulemaking because all
flammable substitutes are prohibited in new &
retrofit MACs

Section 609
Servicing of motor vehicle air conditioners
Applies to any person performing service
on a motor vehicle for consideration
when this service involves the refrigerant
in the motor vehicle air conditioner.

Section 609
Covers all ODS and ODS substitutes
Technician certification
Environmental science, MAC servicing questions
Not a MAC servicing competency test

Equipment certification
Sets up performance standards
All service shops must have certified equipment

Improved Service Equipment

As of this year, require MAC refrigerant
handling equipment manufacturers to build
R/R/R and R/R and R only machines to a
higher improved standard
95% refrigerant recovery w/i 30 minutes
Grandfathered previously certified machines
Large servicing emission savings possible
with full implementation

Technician Certification
On the horizon
Update technician certification to reflect latest
in industry knowledge and to incorporate more
information about new CFC substitutes

Provisions for Alternative

Refrigerant Servicing
Provisions will be made on how alternative
refrigerants are addressed under Section
609

Section 608
Refrigerant venting prohibition
No venting of CFC and their substitutes in
the MAC sector
Disposal of MACs
Must recover refrigerant

Recommended Practices
Least emissive servicing practices
Use of improved refrigerant handling
equipment
Encourage repair, then recharge, no topoffs

Thank you!
For additional information:
Karen Thundiyil
thundiyil.karen@epa.gov