Armstrong International
Armstrong International is a thermal integrator improving utility systems in the industry.
ID: 536924050216-19
Lobbying Activity
Response to Action plan on accelerating Heat Pump market and deployment
22 May 2023
The current public focus on heat pumps is almost exclusively about residential, commercial and mobile applications these are small units (< 70 kW), which take heat from ambient air. On the other side of the spectrum, there is a growing interest for very large heat pumps (> 10 MW), mainly for district heating (sewage or geothermal heat sources) or large industrial sites (petrochemical, paper, sugar, etc.). Importantly, in the middle there are 30 000 light industrial sites in Europe that could replace their current steam and hot water boilers with high-temperature heat pumps (HTHPs) from 0.1 to 10 MW thus recovering their own low-grade waste heat < 100°C, a free and decarbonized source of energy that is locally available. This could contribute both to decrease the EUs dependency on imported energy; and to decarbonize its energy systems, while saving costs. The alternative is to use renewables to run industrial boilers, just to continue wasting 65% of this energy as waste heat released to atmosphere. Recovering low-grade waste heat offers the opportunity to decrease European natural gas consumption by 1 000 TWh/year the equivalent of 30% of EU 2022 gas imports to be replaced by only 350 TWh of (renewable) electricity. The resulting avoided CO2 emissions of 150 million tons/year represent almost 5% of current EU total. Reaching this goal would require about 100 Bn investment at light industrial sites (food & beverage, pharma, household & personal products, chemicals). Current installations represent < 1% of the total 100 GW of HTHPs needed to upgrade 500 TWh of low-grade waste heat. There are 2 main barriers that are specific to the development at scale of HTHPs: 1. Information barrier: the size and scope of the industrial low-grade waste heat opportunity is absent from current EU policies, such as REPowerEU. An excellent basis to change this is the ADEME 2017 Excess Heat report that quantified industrial waste heat in France: https://librairie.ademe.fr/energies-renouvelables-reseaux-et-stockage/1447-excess-heat.html. The industrial waste heat opportunity should be explicitly mentioned in EU policies and initiatives for example, a specific goal could have been added in the REPowerEU plan. This would have recognized the strategic importance of HTHPs to improve significantly industrial energy-efficiency and decarbonization (through the use of renewable electricity). 2. Regulatory and policy framework: the main threat to the deployment at scale of HTHPs in the EU comes from the currently debated F-Gas regulation and PFAS proposal. Indeed, both threaten to ban the use of all HFO/HCFO refrigerants even the ones having GWP < 10 and TFA degradation < 2%. The alternative refrigerants ammonia, hydrocarbons and CO2 need to be highly pressurized to achieve temperatures > 80°C (and are not even at TRL 9 for temperatures > 100°C, based on IEA HTP Annex 58). Their inherent safety issues of toxicity and flammability are amplified by these high pressures. By using EN378 to perform risk assessments, a very large majority of industrial sites (and their insurance companies) eventually refuse these alternative refrigerants as their deployment conflicts with the safety first rule and the civil responsibility of site managers. In most cases, these alternative refrigerants dont offer any positive Scope 3 environmental impact, as they are produced at scale by fertilizing plants (ammonia) and oil refineries (CO2 and hydrocarbons, which are fossil fuels). The metal volume and thickness needed to contain these high pressures increase the Scope 3 impact. HTHPs using water as refrigerant < 100°C and < 1 MW are not expected before 2030 (their Scope 3 impact will not be significantly lower). A technology-neutral approach (as proposed by the Green Deal Industrial Plan) allowing for the use of both fluorinated gases and alternative refrigerants is needed to ensure the deployment at scale of HTHPs.
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