Homeless in Arizona

The $5 trillion mistake

Rogelio A. Maduro and Bob Holzknecht

Machine Design on Jan. 24, 1994

The global ban on chlorofluorocarbons (CFCs) will cost governments and consumers a total of $5 trillion. The scientific community does not have a general consensus on CFCs, and the effects of the ban on humans, society and industry have not been fully considered. Industrial processes are undergoing radical changes, with engineers redesigning machinery and processes to replace supposed ozone-depleting refrigerants, solvents and fire-fighting agents. Increased prices, a lower standard of living and no significant improvement in the environment make people wonder if the benefits are worth the cost.

The $5 trillion mistake

Rogelio A. Maduro and Bob Holzknecht,/h4>

Machine Design. 66.2 (Jan. 24, 1994): p53.

The global ban on chlorofluorocarbons (CFCs) will cost governments and consumers a total of $5 trillion. The scientific community does not have a general consensus on CFCs, and the effects of the ban on humans, society and industry have not been fully considered. Industrial processes are undergoing radical changes, with engineers redesigning machinery and processes to replace supposed ozone-depleting refrigerants, solvents and fire-fighting agents. Increased prices, a lower standard of living and no significant improvement in the environment make people wonder if the benefits are worth the cost.

Last summer this scene was repeated over and over in auto repair shops across the U.S. Unwary customers bringing their cars in for a quick fix for their air conditioners were stunned when they got the bill. A $25 repair two years ago now cost $250. For many consumers, this was the first real taste of what the government's ban on chlorofluorocarbons (CFCs) could mean for them: higher prices, a lower standard of living, and no discernible improvement in the environment.

Meanwhile, engineers are feverishly redesigning machinery and manufacturing processes to replace the use of time-tested and reliable refrigerants, solvents, and fire-fighting agents. This is the most radical and far-reaching change that has ever occurred in the industrial processes used in manufacturing, transportation, and refrigeration. And it is a change being driven not by the discovery of new, improved technologies, but by government edict, whereby more expensive, technologically backward, and inefficient alternatives are being forced on manufacturers and consumers under the guise of saving the ozone layer. Driving this "devolution" of modern production methods is the theory that CFCs and other man-made chlorinated compounds deplete the ozone layer. But there is no accepted consensus among the scientific community on this theory. And while the public has been bombarded with tales of potential devastation from ozone depletion, little has been said about the consequences the CFC ban will have on humans and society. Some estimate the worldwide ban will cost consumers and governments $5 trillion.

Engineering a shortage

Government taxes and dwindling supplies already have pushed the price of CFCs from 50-60|cents~ per lb in 1991 to $16 per lb in 1993, and that price is expected to soar to $40 per lb by this summer. One effect of this dramatic increase is that promoters of the CFC ban can now claim that substitutes cost TABULAR DATA OMITTED only a little more than CFCs themselves.

A fundamental problem being created by the CFC phase-out is what to do with the more than one billion pieces of equipment that currently rely on them to function. So far there are no "drop-in," alternative substances that can replace CFCs without extensive retrofitting. In initially capitulating to the proponents of the ban, the refrigeration and air conditioning industry had planned on a phaseout date in 2000, allowing time to develop alternatives, and with the understanding that there would be plenty of CFC supplies in the form of stored reserves and recycled CFCs. The Senate and President Bush, however, advanced the phaseout date to 1995, and recycling hasn't created a reservoir of usable CFCs. Over the next several years, 46 to 73 million lb of CFCs will be needed annually to service existing equipment, according to an estimate made last April by the Congressional Research Service (CRS). Most of this equipment has a useful lifetime of 20 to 30 years. When CFCs are no longer available, however, the equipment will have to be scrapped or retrofit.

The CRS report warns that some observers predict a state of near chaos in late 1995 and the first several years after the CFC production phaseout is complete. Thousands of building operators, tens of thousands of businesses, and millions of auto owners will have no stockpiles of CFCs, but will have equipment needing service for which there are no drop-in replacements. The Environmental Protection Agency (EPA) is hopeful there will be drop-in replacements available, but some industrial sources claim the candidate replacements all have serious problems such as reduced energy efficiency, reduced cooling capability, or inadequate lubricants.

Some consequences can be foreseen, according to the CRS. When CFCs are unavailable at any price, there will be a mad rush to retrofit existing equipment, for example. The report questions whether the retrofit industry will be able to supply the amount of equipment required. It adds that "the retrofit industry, like CFC holders, will be able to raise prices -- maybe even name their own prices almost without restraint... cries of price gouging will resound across the land... and some of those cries would be well-founded to the extent that this situation would allow some opportunists to raise prices well beyond those which would yield a reasonable return."

Impact on industries

The automotive industry has been one of the first affected by the CFC ban. Manufacturers are being forced not only to redesign auto air conditioners and engine compartments, but to retool production lines and institute provisions to ensure the safety of their production workers. Auto repair shops and owners of cars with air conditioners are also affected.

An enormous number of Americans will feel the impact. There are 150 million auto air conditioners in use in the U.S. While many 1993 models still use CFC-12, car-makers intend to make a substantial changeover to substitutes in the 1994 and 1995 model years.

Leakage of CFCs from mobile air conditioning units require that 25% of the total amount of CFCs used in cars be replaced annually. Most leakage comes from slow leaks, usually from the compressor shaft seal, threaded fastener joints, and hoses. In most cases, a refill rather than a repair is needed.

This means that from 30 to 50 million pounds of CFCs will be required to recharge car air conditioners annually if these cars are to continue using their air conditioners. Soon, these CFCs will not be available, which means that most of these air conditioning units, with useful lives of 10 to 12 years (equivalent to the car's life), will need to be junked. They will be replaced by expensive new units using HFC-134a at a cost of $275 to $1,800. In total, consumers will pay well in excess of $100 billion to keep cool in their cars. In one of the most sweeping changes, more than half of all auto repair shops have already been driven out of the air conditioning repair business. General repair shops (and do-it-yourselfers) without substantial numbers of air conditioning repairs cannot afford the additional equipment mandated by the regulators. Nor can they justify the retraining and certifications required. And they are unwilling to risk stiff fines and jail sentences because of inadvertent or accidental noncompliance with the mountain of ambiguous new federal and state regulations.

Refrigeration. Another industry that will be widely affected by the ban on CFCs will be household and commercial refrigeration. Approximately 150 million domestic refrigerators are now in service in the U.S., all using CFC-12. The domestic refrigeration industry is presently undergoing a massive retooling, at a cost of $200 billion to $300 billion. These costs will be passed on to the consumer in the form of higher prices for refrigerators, freezers, and other household appliances. Even with such enormous expenditures, however, most refrigerators being produced through 1994 and perhaps into 1995 will still be based on CFC-12.

There are also several million commercial refrigeration systems. These have very high leakage rates, averaging 22-25% annually. Since they now contain more than 50 million lb of CFCs, they will require 11 million to 12 million lb of CFCs for servicing annually.

The average cost to retrofit or replace cold storage display cases has been estimated at $100,000 per supermarket. Since retail food stores tend to operate on a very small margin of profit, it is expected that this expense will drive independent supermarkets and small chains out of business.

Buildings. More than 80,000 buildings in the U.S. use centrifugal water chillers for climate control. These units air-condition large office buildings, hospitals, schools, universities, and so on. Present capacity to manufacture new chillers and retrofit existing ones is limited. Only 3,000 large chillers were produced for domestic consumption last year by the five major manufacturers. Another 1,800 were produced for export. By the time the full ban goes into effect, an estimated 67,000 CFC-using chillers will need to be replaced or retrofit.

Substances on the way out

Covering the teleconference, Air Conditioning, Heating and Refrigeration News reported: "The sheer numbers of CFC-bearing equipment eligible for conversion or replacement to . . . alternatives are mind-boggling. And, if you divide the number of existing chillers--specifically, the amount of refrigerant they require--by the amount of CFCs available, the numbers can seem downright intimidating. The General Services Administration (GSA) . . . has 650 to 675 chillers cooling 300 million |ft.sup.2~ of office space. It is expected to cost $100 million per year to either replace, retrofit, or contain the refrigerant within them over the next three to five years."

There are no studies of the national cost of replacing or retrofitting all of these chillers. However, extrapolating the GSA figures shows that the total cost will exceed $10 billion per year in the U.S.

Unfortunately, this calamity does not end with retrofits or new units. A large percentage the of new units and retrofits use HCFC-123 as the refrigerant. These chillers require the installation of several refrigerant sensors and alarms to ensure that the building can be quickly evacuated in case the system springs a leak. In addition, building codes may force extensive reconstruction to house chillers in rooms separate from the boilers, with each room having its own independent ventilation system. That's necessary because HCFC-123 turns into a poisonous gas when exposed to an open flame.

Dangerous substitutes

Not only will getting rid of current CFC-based equipment be expensive, the replacements currently available are dangerous and inefficient. Choosing those replacements has also been controversial.

One of the most arbitrary and capricious acts in the CFC ban saga has been the method by which CFC substitutes have been chosen. The EPA has set up a committee that decides which chemicals are allowed to become CFC substitutes. This committee rejected several alternatives to CFCs, mandating the patented HFC-134a as the only replacement allowed for auto air conditioners.

There are several major problems with HFC-134a, including the fact that it is an unsuitable replacement for existing CFC-12-based refrigeration/air conditioning systems. HFC-134a also is already being targeted by Greenpeace and EPA for phaseout as a harmful "greenhouse gas." In addition, there isn't enough manufacturing capacity available to have enough HFC-134a on hand five years earlier than previously planned.

Safety is another problem. CFCs have an unparalleled safety record covering their 50 years. They are useful, efficient, effective, cheap, nontoxic, nonflammable, noncarcinogenic, nonexplosive, noncorrosive, do not damage fabrics or other materials, and do not deteriorate in storage.

Just the opposite can be said of CFC substitutes. They are new and experimental. They have not existed long enough for any conclusive long-range testing. Already they are known to suffer from one, or several, of the following problems: corrosiveness, toxicity, carcinogenesis, combustibility, energy inefficiency, and long-term instability. Furthermore, they require new lubricants and desiccants, and they are very expensive.

DuPont's SUVA family of chemicals, the brand name for the most abundant CFC replacement chemicals now on the market, are very dangerous, according to the industry itself. A DuPont service bulletin, "Safety of SUVA Refrigerants (AS-1)," warns: "Inhaling high concentrations of SUVA refrigerant vapor may cause temporary central nervous system depression with narcosis, lethargy, and anesthetic effects . . . dizziness, a feeling of intoxication, and a loss of coordination. Continued breathing of high concentrations of SUVA vapor may produce cardiac irregularities, unconsciousness, and with gross overexposure, death."

High concentrations, according to DuPont, are 30 parts per million for HCFC-123 (SUVA Centri-LP) and 1,000 ppm for HFC-134a (SUVA Trans A/C), over a period of 8 hours. Anyone who works with refrigerants knows that it is nearly impossible not to encounter these and much higher concentrations during air conditioning and refrigeration work.

Discussing SUVA's combustible and explosive qualities, DuPont reports that HFC-134a has been shown in tests to be combustible at pressures as low as 5.5 psig at 350 |degrees~ F when mixed with air. "SUVA refrigerants should not be mixed with air for leak testing. In general, they should not be used or allowed to be present with high concentrations of air above atmospheric pressure," the bulletin advises. This warning might come too late for some service personnel since leaky automobile air conditioners always contain infiltrated air, even before the leak testing begins.

The bulletin also warns that cylinders containing SUVA can explode at temperatures above 257 |degrees~ F. It does not discuss what happens to SUVA in engine compartments where underhood temperatures commonly reach 300 |degrees~ F. Exploding cylinders are not the only threat. "SUVA refrigerants will decompose when exposed to high temperatures from flames or electric resistance heaters. Decomposition may produce toxic . . . compounds," DuPont says. The fact that most household refrigerators are located next to the gas or electric range makes this danger even more obvious.

Although more people will be exposed to HFC-134a than to any other CFC replacement, HCFC-123 may turn out to be the most dangerous substitute. This chemical has been deemed so harmful that one of the largest chiller repair companies in the world, Johnson Controls Inc., announced last July that it would not allow any of its maintenance people to work with any equipment that uses HCFC-123. This decision was attacked by producers of HCFC-123 manufacturing plants. Johnson Controls stood its ground, pointing to the toxicological evidence.

The company's decision follows that of most European countries to ban HCFC-123. European manufacturers first discovered that it turns into poisonous gas when subject to high temperatures. DuPont., the biggest maker of HCFC-123, has refused to halt production, saying that it ensures safety by not selling the chemical to companies that will use it for foam blowing, as a solvent for cleaning electronic components, or in dry cleaning. The question is: how will DuPont control resale of HCFC-123 by independent distributors?

The problems of HCFC-123 do not end there, however. This CFC replacement has been proven to cause tumors in rats.

Where's the testing?

In addition to all this, the toxicity studies have serious shortcomings. The Program for Alternative Fluorocarbon Toxicity Testing (PAFT), the chemical industry consortium that conducted the tests, has not addressed the issue of human exposure. Although toxicity studies on rats are useful, they cannot replace studies of what these chemicals do to humans in real situations. Not to have examined the actual effect on human beings is unconscionable, especially given the number of people exposed to these chemicals. There are more than 600,000 service personnel in the U.S. alone who work with all types of cooling and refrigeration systems.

Even if PAFT had carried out the necessary human exposure studies, there would still be many questions regarding its long-term effects. It may be 15 years before the carcinogenic effects of SUVA and other replacement chemicals start showing up in service personnel.

Furthermore, there has been no testing for synergistic effects of these chemicals. As toxicologists know, two harmless chemicals may become toxic or carcinogenic when combined. Therefore, before high-exposure chemicals are released to commercial use, there usually is at least some testing for synergistic effects. This situation was denounced by refrigeration expert Eli Lieberman. In Air Conditioning, Heating and Refrigeration News, he warns "the problem is greatly complicated in that the refrigeration service engineer will now be exposed to a whole family of newly synthesized refrigerants in addition to the CFCs presently in use. No toxicity testing has been done on the possible synergistic toxic effect of breathing eight to 10 different refrigerants at the workplace over a period of time."

From a moral standpoint, it is outrageous that no synergistic toxicity testing has been conducted. From a legal standpoint, it may be criminal. The 1976 Toxic Substances Control Act (TSCA) mandates that before any new chemical is introduced into commerce, it should undergo testing for "cumulative or synergistic effects." In its zeal to ban CFCs, the EPA has turned a blind eye to possible synergistic toxic effects and also failed to enforce other TSCA requirements. As a matter of fact, EPA itself is violating the law. Reva Rubenstein, the EPA official in charge of toxicity studies, has refused to release any of these studies to the public. Even industry officials who design and manufacture equipment that uses CFC substitutes have been unable to obtain these studies.

Ms. Rubenstein has told some callers that "these studies may confuse you." A product manager for a large auto manufacturer reports that he told her his company needed to obtain the studies because it was liable for any harm caused by SUVA emitted from its cars. "That's your problem, not ours," Ms. Rubenstein replied.

EPA's refusal to provide these studies to the public raises many questions, notably "What are they trying to hide?" There must be some serious issues the EPA is trying to conceal, because refusal to provide these toxicity studies carries not only severe civil penalties under TSCA, but is considered a criminal act.

Worldwide, the total price tag for banning so-called ozone depleters could run to $5 trillion. The question remains, however, does the unproven threat of ozone depletion warrant all the expensive steps being taken?

RETHINKING THE LAW

Faced with differing opinions among the scientific community on whether CFCs really deplete the ozone layer and the looming costs of the CFC ban, legislators are reconsidering the U.S. position. Some politicians feel that the government was panicked into a rash decision to accelerate the phaseout and soon will pay the price for that hasty decision. Some legislators want an airing of the current evidence for and against the CFC ozone-depletion theory so that they can make up their minds on what to do about the currently scheduled CFC phaseout. In August 1992, for example, Rep. William Dannemeyer (R-Calif.) sponsored House Resolution 547 to establish a special presidential commission to review the scientific evidence surrounding ozone depletion and CFCs. It would have been made up of scientists and experts from both sides of the issue. Scientists who contend that manmade CFCs have no effect on the ozone layer, ultraviolet radiation reaching the earth's surface, or the incidence of cancer were excluded from previous review panels. NASA's Ozone Trends Panel, for example, was supervised and directed solely by backers of the CFC ozone-depletion theory. Last October, Rep. John Doolitle (R-Calif.) reintroduced Dannemeyer's bill in Congress. Hearings on this bill, HR-291, are scheduled for February.

THE RECYCLING BOONDOGGLE

Recycling plays a central role in the strategy of those promoting the CFC ban. They assert that more than 30% of all the CFCs still needed after production is banned will come from recycling. This is unlikely, for after two years of mandated recovery and recycling, the amount recovered is negligible.

One problem is that the machinery needed to carry out this mandate is expensive, priced from $1,500 to $50,000, and that does not include installation, filters, and maintenance, or the cost of training and certifying operators. Maintenance personnel must use a recovery/recycling unit whenever servicing CFC-using equipment, with a separate unit needed for each refrigeration gas recovered. Mixing gases damages the recycling unit and the mixed gases become expensive to dispose of legally. Shop owners who do not use these units risk hefty fines and jail time.

Complying with government mandates will require an estimated 375,000 recycling units. That number may double since these fragile machines require constant maintenance. And because shops cannot do business without an operational unit, many will buy three units, two for R-12 and one for R-134a.

Another drawback is that when maintenance workers are called to service a unit because it is no longer cooling, most of the refrigerant has already escaped. To comply with the law, maintenance personnel will have to evacuate empty systems. The only CFCs actually recoverable is the temporary charge used to pinpoint leaks and determine necessary repairs, or when a perfectly operating system is emptied prior to being dismantled.

Reusing what few CFCs can be recycled may not be smart, anyway. Improperly recycled CFCs can contaminate and damage expensive air-conditioning equipment. The only analysis methods capable of determining the purity of recovered CFCs are gas chromatography, nuclear magnetic resonance, and chemical analysis, and these cost between $100 and $300 per sample. For all of these reasons, the calculations on the amount of CFCs available from recovery are vast overestimates.

Rogelio A. (Roger) Maduro has written articles on earth and atmospheric sciences, the environment and environmental law, and new developments in industrial technologies. He studied civil engineering at Washington University, St. Louis, and earned a bachelor of science in geology from City College of New York. He also authored the book The Holes in the Ozone Scare: The Scientific Evidence that the Sky is Not Falling.

Bob Holzknecht owned and operated an auto-air repair shop for 25 years and formed a trade association, Automotive Air Group, of similar businesspersons. He also edited The Accumulator, a monthly technical newsletter covering automotive air conditioning issues. He now serves as the founder and organizer of the Ozone Truth Squad, an organization aimed at countering the one-sided version of the CFC/ozone depletion theory.

Source Citation (MLA 8th Edition)

Maduro, Rogelio A., and Bob Holzknecht.

"The $5 trillion mistake."

Machine Design, 24 Jan. 1994, p. 53+.