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Get rid of CFCs—if you can afford to
If your building doesn’t have CFC refrigerants, or if they’re easily eliminated, then you’re in position to easily earn this prerequisite.
Even If your base building systems do use CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer., you can still earn this prerequisite. You’ll need to either implement a five-year CFC phase-out plan or show that both conversion and replacement of your equipment is not economically feasible.
How old is your equipment?
CFC production was banned in the U.S. in 1996, so although you should not rely on that date as a clear...
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47 Comments
Backup Unit
I am working on a project where the main unit is new and thus in compliance but there is a backup unit which uses CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer.. I am assuming the replacement of a backup unit would be economically infeasible and thus we will only have to ensure that leakage is minimized. Is this correct?
You will still need to conduct an assessment of the economic feasibility of both converting and replacing that backup unit and provide the results as your documentation for the prerequisite.
Tenant owned chiller with R-11?
I am working with a large building in New York. This building has a tenant that has their own chiller that utilizes R-11 refrigerant. Since the property team has no control over the tenants chiller, and therefore cannot conduct studies, implement refrigerant plans, etc., can we exempt the tenant's equipment, or would this still have to fall under the 10% multi-tenant exemption rule? Has anyone run into similar situations?
That's a tricky one. It's tough to say whether the chiller in question would be considered base-building equipment or not. Typically, the prerequisite should address all refrigerants in the building, but if you have a non-cooperative tenant who is unwilling to participate in this process, you may be able to speak to GBCI to arrange some alternative compliance path.
Phase Out Plan
EA credit 5 - Enhanced Refrigerant Management is currently denied in our project for the Refrigerant Impact per ton value exceed the allowable 100. We are implementing a phase out plan for the project, but we still don't know what characteristics a phase aout plan have. Where can we take basis on how to fill this plan? What characteristcs does a plan like this have?
Thank you!
Paola, it is important to understand that the CFC phase out plan is more important for the documentation for EAp3, Fundamental Refrigerant Management. If the calculations for EAc5 show that the refrigerant impact per ton is greater than 100 during the performance period, it will not change the measured outcome of that credit if you submit a CFC phase out plan during your final review.
However, a CFC phase out plan may be necessary depending on the analysis you performed for EAp3 - was that prerequisite also denied during your preliminary review? Essentially, if your building uses CFC-based refrigerants and the required economic analysis for EAp3 shows that it will be economically feasible to either convert or replace the existing equipment with an alternative that does not use CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer., THEN you are required to provide a plan that shows how your will phase out those CFC-based refrigerants within 5 years. The requirements of the phase-out plan are described on pages 146-148 of the 2009 Edition of the Reference Guide.
Jason, first of all thank you for helping us.
I believe the situation we described is not so clearly exposed. In our project we are using the refrigerants R-22 and R-407c. The prerequisite for this credit is earned, however the credit is denied for the Refrigerant Impact per ton value exceeds the allowable. We intend to also earn this credit, this is why we are planning to provide a phase out plan, and some piece of equipment which uses R-22, change for the R-134a use, then the Refrigerant Impact per ton value would decrease. Do you believe this situation is feasible? Or should we try something else?
Hi Paola,
Thanks for clarifying, but unfortunately, my response still holds true. The documentation for EAc5 is based on the observed performance in your project building during your defined performance period and the performance period may not be extended for this particular credit. You are correct in stating that the refrigerant impact per ton would decrease if you replaced or converted the equipment that is currently using R-22, but your EAc5 documentation for this certification project must be based on actual performance during the performance period and not on a promise to modify the refrigerant inventory at some future point. I'm sorry to say it, but you should consider this credit to be unachievable for this current project, and look ahead to a future re-certification project while considering any potential retrofits to your chiller equipment to ensure that you will be able to meet the requirements at that time.
Hi Jason,
Again, thanks for answering us so fastly.
You have just confirmed what one of our project team members said. We will not try to earn this credit for this project anymore, but this serves as a lesson, and for a future re-certification we are going to start planning since now what we are going to do.
Once again, thank you for your help !
Refrigerant Management Plan
Does anyone know of a good resource to use as a template for developing a refrigerant management plan for a building? I am currently working with multiple projects that do have cfc-based refrigerants.
Vending Machines
Vending Machines are considered small appliances with greater than 0.5 pounds of refrigerant. Would these be required inputs?
This credit addresses only base-building HVAC equipment. Portable equipment that is not permanently installed in the building, including standard refrigerators and vending machines, may be excluded.
CFC-Based Refrigerant Annual Leakage Rate
I'm hoping for some insight on the annual leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). calculation, the reference guides reference to EPA Clean Air Act, Rule 608, and the Refrigerant Management Plan.
On page 145 of the reference guide it state, "If CFC-based refrigerants are maintained in the building, reduce annual leakage to 5% or less using EPA Clean Air Act, Title VI, Rule 608 procedures governing refrigerant management and reporting, and reduce the total leakage over the remaining life of the unit to less than 30% of its refrigerant charge."
A building considering LEED had refrigerant added 6 months ago, according to the annual leakage rate calculation using Te, around 8%. Since the leak was detected and refrigerant was added and issue repaired, the building has experienced no leaks and 0 lbs of refrigerant has been added. They have implemented a Refrigerant Management Plan per EPA Clean Air Act, Rule 608, and have REDUCED their leak to "0" %. We feel that they have met the intent of this prerequisite since they have effectively reduced the leak to 0, followed the Standard reference in the requirement (which, btw when read closely allows 15% annual leakage rate, not the 5% in the requirement) and implement the plan with the purpose of reducing their leakage rate.
The language used is unclear if implementing a management plan to reduce to 5% is acceptable, or if a bad purge valve 6 months ago will continue to haunt us until a full year has passed and the refrigerant added is no long relevant. Oh, and as Chris Munn mentioned above, the credit doesn’t even require you to upload this calculation, so how hard and fast is this 5% cutoff? It doesn’t seem right that just waiting a year will give us the green light if we have made the corrective actions already and 0 refrigerant has been added since. Any help?
I haven't seen this situation before, but based on how the requirements are presented in the RG, at some point you would be able to move on from your leaky history and use more current, post-fix leakage data. Since at this point you have 6 months of leak free data, it seems you could establish that the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). is now (or better, at the end of the performance period), still zero.
However, since this is a prereq, it might be worth getting a clear path forward from GBCI so that you don't run into trouble during the review phase.
Standard path vs alternative compliance approach?
How do I decide which one to pick?
Danielle, I think how you approach this credit depends a lot on your building. Are you looking at a situation with an economic feasibility question? Can you give a few more particulars?
Sorry Tristan for the late response. I was unable to login for a while for some unknown reason. This is an existing building (Non profit org) and we are trying to get them LEED certified. There's one big refrig with HCFC. All the other eqt (window A/C) have less than 0.5 lbs refrig and are exempt. LEED online asks to explain why an alternative path is used vs standard. I have not seen that in any manual. Thanks if you can help.
Danielle, it doesn't seem that you would need to use an alternative compliance path. If you only have one piece of equipment that has more than 0.5 pounds of refrigerant, and that equipment does not use a CFC-based refrigerant, then you would simply use the standard compliance path and indicate that the building does not use CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer.. Note that HFCs and HCFCsHydrochlorofluorocarbons (HCFCs) are refrigerants that cause significantly less depletion of the stratospheric ozone layer than chlorofluorocarbons. are a different class of refrigerants than CFCs, and have a reduced environmental impact.
Does the 10% exclusion rule apply to this credit?
Does the 10% exclusion rule apply to this credit? We have a multi-tenant high rise without CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer., but one restaurant (5% of floor spce) does have an isolated CFC-based system (yes, greater than 0.5 pounds of refrigerant). Can we simply exclude this area, or must we perform the economic analysis?
If the restaurant is under separate management control than the rest of the building and the equipment in question is used only for the restaurant, then, yes, it could be excluded from EAp3. Make sure you note this in Table PIf3-1 on Project Information Form for PIf3.
No Manufacturer and No Model Name.
Our project is a multi tenant space and consist few restaurant. we unable to identify the manufacturer and model name of the refrigerator but we able to know the type of refrigerant used. in LEED template, can i ignore the "manufacturer" and "model" column? i have about 15 types of refrigerator without this details.
as long as you include a narrative explaining the situation and describe the steps you took to try to track down the manufacturer and model name, this should be fine.
I would also suggest uploading photos of the existing equipment so the reviewer can get an idea of what's in the building.
CFCs vs HCFCs
Are HCFCsHydrochlorofluorocarbons (HCFCs) are refrigerants that cause significantly less depletion of the stratospheric ozone layer than chlorofluorocarbons. considered to be CFC based?
Zachary, the fourth bulletin above under "Checklists" breaks this down very well. But in short, HCFCsHydrochlorofluorocarbons (HCFCs) are refrigerants that cause significantly less depletion of the stratospheric ozone layer than chlorofluorocarbons. can be considered a acceptoable CFC substitute for the purposes of this preprequisite.
0.5 lb. Requirement
In the Credit Language:
"Small HVAC&R units (defined as containing less than 0.5 pounds of refrigerant), standard refrigerators, small water coolers and any other cooling equipmentThe equipment used for cooling room air in a building for human comfort. that contains less than 0.5 pounds of refrigerant are not..."
In my reading of this the 0.5 pounds requirement does not apply to standard refrigerators and small water coolers. All of our water coolers serve two fountains and carry a charge of 1.0 pounds. They are R-11. Do these need to be included? We have never recharged these units. Do I assume the 0.5% Lr?
We also have a few larger standard refrigerators with charges over 0.5 pounds. Do we include those?
Yes, small appliances that carry a refrigerant charge over 0.5 pounds, like water coolers and refrigerators, must be included in your inventory and calculations. If there is no recorded leakage over the last 12 months, you must use 0.5% for the Lr value, which represents the low-end of the allowable range as defined in the Rating System language.
So this language has always been perplexing to me and I wonder if Jason can shed light on any recent confirmation from USGBC as to their intent here. The section of the rating system quoted by Laura is grammatically so tortured as to leave the status of something like a standard refrigerator (of over 0.5lbs charge) clearly in question to me. (One could reasonably read that sentence either way.) But the first line of the prerequisite very clearly uses the term 'base building systems'. It seems to me that there's no convincing argument that something like a refrigerator or freezer that is a plug-in appliance which can be easily installed or removed from the building at any time, can be considered part of base building systems, even if it is under direct management control. A water fountain (the other popular example) is perhaps closer to falling under that term, but I'd be interested if anyone has insights as to how a basic kitchen fridge is considered a base building system. I am all for reducing refrigerants anywhere we find them, but this seems like a stretch for the credit language as written.
Thanks -Dan
leakage rate
Do we need to use actual values based on calculations provided for this (p221 of manual) or can we use default of 2% or 0.5% (if specified by manufacturer)?
This issue has always been a little confusing and has become a bit more muddled in light of recent rulings made by GBCI that further defined the allowable values for leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). (Lr). Here's the low-down:
*The "default" value of 2% should never be used. Ever. This is a LEED-NC concept that was never appropriately aligned for the EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. rating system. If a project team is unable to calculate their actual leakage rate for a building that is currently occupied with operational equipment, they would not meet the minimum requirements for the prerequisite. Likewise, do not use manufacturer specifications for anticipated leakage rates. Anything can happen once a piece of equipment is installed and operational, so the manufacturer's estimates may not accurately capture the actual performance.
*Bottom line - always use the actual calculated value for leakage rate of each piece of HVAC equipment in the project building with more than 0.5 pounds of refrigerant. You can calculate these values by tracking how much additional refrigerant has been added during maintenance activities throughout the performance period.
*There is only one caveat to this rule: If the actual measured leakage rate of a piece of equipment is less than 0.5%, you must use the minimum default value of 0.5% in your calculations for Lr. You cannot use 0% in your calculations; if you do, the reviewer will adjust your calculations and report the updated Refrigerant Impact per Ton. This minimum default value is specified in the Rating System language for EAp3, so it's pretty much set in stone. This requirement has recently been enforced much more consistently and the reviewers are on the lookout for incorrect calculations, so make sure you use the correct values.
Jason -
Can you direct me to "the recent rulings" by GBCI that you refer to in this comment stream regarding the allowable values for leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).? I've looked in the addenda (up through 11/3/10), the CIRs, and the reference guide but have not found anything that says you cannot use the 2% leakage rate as a default. On page 223 of the Reference Guide, Sample Calculation 2, describes a scenario that uses actual leakage rate and the 2% default - indicating it would be ok for us to do so as well.
As I understand it, EPA only requires an owner of appliances that contain 50 or more pounds of refrigerant to tracking the amount of refrigerants, which may mean the some organizations will not have this information at their fingers tips and I do not see where it says you should track your leakage rate for the performance period (which as it could be as short as 3 months).
On the other hand, if you have appliances that are less than 50 pounds but more the 0.5 pounds and have not had to put refrigerant in them over the past year, then you could accurately say your annual leakage rate is 0%, but you would use the LEED required minimum of 0.5%
Thanks for providing this valuable information. I guess Im just looking for the actual documentation from GBCI before we head down the actual leakage rate route.
Per page 221 of the LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. Reference Guide, "Refrigerant Leakage RateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). (Lr) must be based on actual leakage rates experienced in the project building..." The suggestion that project teams can use a default of 2% and not even bother tracking leakage from their equipment is misleading and incorrect. I can tell you unequivocally that the review team will send the credit back to you and ask for clarification if you do not use actual leakage rates and provide some documentation substantiating your claim.
Your note about using 0.5% Lr when you have not had to recharge any equipment is correct - that is exactly how you should manage that scenario.
Thanks for getting back to me Jason. I really appreciate it. We'll move forward by tracking our leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608)..
Thanks again!
My question is how do you change the default rates to .5%?? The field cannot be edited directly and is based on the refrigerant added and the days since refrigerant last added column.
It looks like if I use .05% of the total refrigerant in the lbs of refrigerant added column and 365 in the days since refrigerant last added colum, the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). changes to .5%. Is this what I should be doing?
refrigerant charge
Based on actual calculations of the refrigerant charge value (lb/ton) some of the values are higher than the "default maximum allowable equipment refrigerant charge" according to table 2 of the manual (p220). This is due to smaller equipment (lower tonnage compared to the refrigerant in pounds). We will enter actual values in the templates but will this be accepted by LEED?
Pablo, good for you for taking actual measurements of your refrigerant values. Please go ahead and use the actual values in your LEED documentation. The table provided on P. 220 of the Reference Guide is simply a design tool to help inexperienced users verify that their refrigerant data is falling within the traditionally accepted ranges. However, actual values should always be used for refrigerant calculations in order to accurately document the conditions at your project building.
We have refrigerant re-charge data for most equipment. However, there are a few new equipment, as well as old refrigerators.
My queries:
1) For the former (new A/C's), we have not yet recharged refrigerants. For the latter (old refs), we have not charged over time. Are we allowed to make assumptions for these?
2) Which assumptions are we allowed to make? - from the LEED EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. manuals?
conversion “and/or” replacement
As stated under "Economic Analysis" in Bird's Eye View, "...the LEED Reference Guide says to analyze conversion “and/or” replacement, many project teams don’t perform a complete analysis and fail to comply with the requirements." So what is the course of action here if we only completed a replacement analysis? Do we need to really have another analysis for conversion?
In a word—yes. That's what we've found, despite the ambiguous reference guide language.
It makes sense to me—if you haven't looked at conversion why should you get a pass on the prereq?
CFC-Refrigerant Submittals
In the requirements of this credit, the reference guide states that if CFC-based refrigerants are maintained in the building, reduce annual leakage to 5% or less, and total leakage over the remaining life to less than 30% of its refrigerant charge.
However, there is no place in the LEED Online form that asks for documentation regarding this. In addition, there are no uploads whatsoever required for this credit. Do you simply have to fill-in the credit form and the table in the form based on the results of the chiller replacement and refrigerant conversion to comply with this credit, even if you use R-11, or will reviewers ask for further documentation of the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).?
Yes, it looks like that's the case. I double-checked both the EAp3 and EAc5 LEED Online credit forms, and they are remarkably simple in just focusing on the equipment inventory. The leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). documentation is a good idea to compile and I would have it in my back pocket in case the reviewer asks for it.
We have 7 HVAC equipment, 6 of them are R-22 and 1 R-410A, is it acceptable for EAp3 and EAc5 requirements? Or we really need to replace all of them under R-410A just to comply on the requirement.
thanks,
R-22 is an HCFC so it will be fine for the prerequisite. There's a chance you could earn EAc5, but it will really depend on your leakage rates over the 12-month period preceding your application submittal.
On page 221 of the LEED Reference Guide it shows the formula for calculating Leakage RateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).....a part that confuses me is the "Days Since Refrigerant Last Added". Is this the number of days between the date last added and the current date, or the date last added and the date last added before that?
Also when entering the data for LR does this only pertain to activities for the last 12 months before submittal? I have over 90 RTUs and only 7 or 8 will have problems in that time span so I would just put the .5% for the rest?
Submittal Inventory Table ?
The building contains no CFC's. For the required submittal inventory table, do I need to list all 250 heat pumps in the building? Or do I only need to include the chiller information?
It seems that you do - the tempate requires that you list all mechanical cooling equipmentThe equipment used for cooling room air in a building for human comfort. serving the building. You may be able to provide this information in clusters if you have the same heat pumpA type of heating and/or cooling equipment that draws heat into a building from outside and, during the cooling season, ejects heat from the building to the outside. Heat pumps are vapor-compression refrigeration systems whose indoor/outdoor coils are used reversibly as condensers or evaporators, depending on the need for heating or cooling. In the 2003 CBECS, specific information was collected on whether the heat pump system was a packaged unit, residential-type split system, or individual room heat pump, and whether the heat pump was air source, ground source, or water source. (same refrigerant, install date, etc...) in portions of the building (under equipment location you might note Floors X-Y) but the expectation is that the template will capture/list all equipment in some form or fashion.
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