ASHRAE's Refrigerant Standard and what it says about hydrocarbon refrigerants
Proposed Addendum d to ASHRAE Standard 15-2013 - Public comment period closes January 18, at midnight EST.
The ASHRAE 15 committee continues to update their refrigerant standard: ASHRAE/ANSI Standard 15-2013. A3 refrigerants (propane, for example) are already included in the standard. This draft includes a ‘new’ category for A2L refrigerants. ASHRAE's 2L working group has issued an Advisory Public Review Draft in which they offer how A2Ls should be treated. This draft has a comment deadline of January 18th. Information on how to comment is available here.
Though the focus of addendum d is the new A2L category, the proposed draft also addresses higher flammability refrigerants like hydrocarbons, which are A3 refrigerants. This addendum continues a ban on hydrocarbon refrigerants, except:
- If there is approval from the authority having jurisdiction (AHJ)
- In laboratory and industrial application
- In systems with charge sizes below 150g
And here's the problem: The 150g charge limit on hydrocarbon systems currently restricts the economic and practical viability of these refrigerants, despite all of their desirable traits. Those traits include extremely low global warming potential (GWP), improved energy efficiency compared to HFCs, and proven success and safety with larger charge sizes in Europe. The standard, as written, is in conflict with the intention of EPA SNAP rule 19. More importantly, at some point we expect EPA to approve higher charge limits for hydrocarbons. When that happens, they will be in violation of Standard 15, unless, of course, this draft under consideration is revised. In addition, UL approved equipment often relies on ASHRAE 15 for building regulations, so if this addendum is finalized as is, it would effectively prohibit UL approval of systems with more than 150g of hydrocarbons.
Ask ASHRAE to reconsideration how it refers to charge limits. Help open the door for higher charge sizes in the future
Some suggestions to help guide your comments to ASHRAE. When you submit your comments, you should:
- Strongly encourage ASHARE to revise the current text to allow the installation of all listed equipment (i.e. if EPA SNAP has approved equipment, than it should automatically fall within the requirements of Standard 15.
- Encourage a more efficient standards process, whereby standard 15 does not limit the decision making capabilities of EPA's SNAP program or UL. The SNAP program goes through a rigorous evaluation before listing refrigerants as acceptable, or acceptable subject to use restrictions -- ASHRAE does not need to build in redundancies by explicitly limiting charge size.
- Provide any data or experiential evidence your company has to support your comments.