Federal Register - May 6, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 86 / Thursday, May 6, 2021 / Rules and Regulations
Comment: AHRI read the proposal to be proposing all tubing be red, but thought the intent was to only require such markings for service ports.
Response: EPA did not intend to propose that all tubing in equipment using A2L refrigerants be red and we are not finalizing such a requirement in this final rule. We are finalizing this use condition as proposed and clarifying in section II.B.1.d that where the red markings would be applied depends primarily on the equipment design. The intent in the proposed rule and finalized in this rule is for the red marking to be present at all service ports for equipment that includes such service ports, and for the marking to extend one inch from those ports. Likewise, if connections need to be made in the field as opposed to at a factory, the one-inch red marking is required at those connection points. If, however, equipment is provided without such service ports, the one-inch red marking would be required at the point in the equipment where any service involving the refrigerant, including the evacuation of the refrigerant prior to equipment disposal, would occur. On smaller appliances, we have noted in the past that a process tube is often provided for such service, and that the red marking would be required there. As we have also noted previously, the manufacturer must decide the method of providing the red marking, for instance via paint, plastic sleeve, shrink wrap, tape, etc.
Comment: AHRI described the labeling requirements of the UL
standard for service ports and indicated that use of red markings and the use of red hoses may cause some confusion.
The reason the commenter provided was that typical gage sets currently use red housing for the higher-pressure side, a comment echoed by Carrier.
Response: EPA does not agree that the similarity of color between the gage set and the servicing port would lead to confusion. Given that connections in the gage set also exist for the low-pressure side, we feel that technicians would understand that a red marking of a service port does not mean that only the red hose of a gage set must be connected there. Other EPA requirements, such as the venting prohibition under section 608c of the CAA and technician training requirements, have existed since the early 1990s, and thus EPA
believes technicians will be able to use gage sets without confusion. Further, training on flammable refrigerants which several commenters have pointed to would reinforce the understanding of red service ports and the use of gage sets. Finally, EPA notes that a similar red coloring requirement use condition
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exists for flammable refrigerants, including HFC32, in other end-uses, and we are not aware that such coloring has led to any confusion.
Comment: Chemours stated that the requirement of red markings would be difficult to implement in certain types of residential and light commercial air conditioning equipment. As an example, they indicated that quickrelease Schrader valves may be impossible to get in red color.
Response: EPA does not see evidence that the construction of red-colored Schrader valves is impossible. In fact, Chemours comments may point to the reason why they say such valves are not available. Chemours pointed out that the equipment types where flammable refrigerants are currently acceptable subject to use conditions were selfcontained equipment generally using process tubes rather than Schrader valves. Thus, there may have been no reason to develop them in the past.
However, that does not mean that such valves will not become available if there is demand for such valves in the future.
Although we cannot confirm that such valves do not exist at all, it is important to note that other means of applying the red marking may be used. The regulatory text proposed and finalized in this rule states the red color must be applied at all service ports; hence, items such as a red plastic sleeve or shrink wrap at both sides of the port, rather than the entire port itself, would be acceptable means of meeting this use condition.
d. SNAP Criteria i. Flammability Risks and Safety Comment: AHRI and Lennox pointed to an approximately $7 million research effort with the U.S. Department of Energy DOE, the California Air Resources Board CARB and other stakeholders on the behavior and safe use of next generation refrigerants, including the lower toxicity, lower flammability A2L refrigerants in the proposed rule. Lennox emphasized that such research was used to develop the safety standards and develop training.
Sporlan said this research on 2L
refrigerants is of mature enough nature that they will be able to be safely applied in new systems designed for 2L
flammable refrigerants. AHRI detailed the extensive use of A2L refrigerants in the United States and other countries and noted that it has yet to find incidents related to A2L refrigerants.
Response: The Agency acknowledges AHRIs and Lennoxs support for this proposed listing. EPA acknowledges AHRI and Lennox for providing this
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information and note Sporlans comment, which supports EPAs finding that the flammability risk of A2L
refrigerants can be safely addressed.
After considering all the public comments on this proposal, we are finalizing this listing, as described in section II.B.
Comment: HARDI indicated that the industry is supporting updates to the building, mechanical, and fire codes as well as transportation regulations to allow new equipment to use new refrigerants, including the A2L ones listed in the proposed rule. HARDI is working with the industry to ensure a smooth and safe transition takes place.
Response: EPA acknowledges HARDIs information on their efforts to support the safe use of these refrigerants in residential and light commercial equipment as well as other types of equipment not covered by this final rule.
Comment: Honeywell commented that EPA should update the Risk Screens for R32 and R454B included in supporting documents for the proposed rule. They suggested that because ASHRAE Standard 15 mandates use of a refrigerant concentration limit RCL, and ASHRAE Standard 34 sets the RCL to be 25% of the LFL, EPA
should use that amount rather than the 100% of LFL.
Response: EPA has consistently evaluated alternatives through a risk screen process that begins with a highly conservative worst-case scenario, such as where the entire refrigerant charge of a specific equipment type leaks out rapidly in a specific room size. If a substitutes concentrations remain below 100% of the LFL and relevant toxicity limits in the worst-case scenario with highly conservative assumptions, we do no further assessment. If the substitutes concentrations exceed the LFL or a relevant toxicity limit in the worst-case scenario, then we consider more typical scenarios based on less conservative assumptions. EPAs risk screens indicate that none of the types of equipment in this rule with these refrigerants came close to 100% of the LFL, although they did exceed the 25%
mark under the most conservative scenarios analyzed.
To the extent ASHRAE 15 is incorporated into building codesas Honeywell indicatesthat requirement to adhere to the ASHRAE RCL would provide an additional layer of safety above the use conditions set in this final rule. More generally, the use of risk screens was developed in the original SNAP Rule issued in 1994 and was not meant to incorporate every possible risk factor. In fact, in that rule we stated
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