Substitute Refrigerant ALERT: Proposed EPA Revisions

//Substitute Refrigerant ALERT: Proposed EPA Revisions

Substitute Refrigerant ALERT: Proposed EPA Revisions

In November 2018, the EPA issued a final rule updating the refrigerant management regulations. The rule updates strengthened leak repair requirements, recordkeeping requirements for disposal of certain appliances, and revisions to technician certification. It also extended requirements to certain non-ozone depleting substitute refrigerants, such as hydrofluorocarbons. These changes to the Section 608 Refrigerant Management Requirements regarding leak repair and recordkeeping went into effect January 1, 2017, with varied compliance dates of January 1, 2018 and January 1, 2019.

The 2016 rule made the following changes to the existing requirements under Section 608:

  1. Lowered the leak rate threshold that triggers the requirement to repair leaks (applies to owners/operators of refrigeration and air-conditioning equipment that contains 50+ lbs. of refrigerant):
    1. Lowered from 35% to 30% for industrial process refrigeration (IPR)
    2. Lowered from 35% to 20% for commercial refrigeration equipment
    3. Lowered from 15% to 10% for comfort cooling equipment
  2. Required quarterly/annual leak inspections or continuous monitoring devices for refrigeration and air-conditioning equipment that have exceeded the threshold leak rate.
  3. Required owners/operators to submit reports to EPA if systems containing 50 or more pounds of refrigerant leak 125% or more of their full charge in one calendar year.
  4. Extended the sales restriction to HFCs and other non-exempt substitutes, with the exception of small cans (containing 2 pounds or less) of non-exempt substitutes (e.g., primarily HFC-134a) for motor vehicle air conditioner servicing. These small cans can continue to be sold without technician certification so long as the small cans have a self-sealing valve to reduce refrigerant releases.
  5. Required technicians to keep a record of refrigerant recovered during system disposal from systems with a charge size from 5–50 lbs.
  6. Extending the requirements of the Refrigerant Management Program to cover substitute refrigerants, such as HFCs. Note that some substitutes have already been exempted from the section 608 venting prohibition as provided for under section 608 in previous EPA rules; such substitutes would also be exempted from the requirements under this proposed rule.

The EPA is revisiting its approach to regulating substitute refrigerants, as detailed in the September 18, 2018 proposed rule Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes. In this action, EPA is proposing to revise the appliance maintenance and leak repair provisions in 40 CFR 82.157 so they apply only to equipment using refrigerant containing a class I or class II substance and not to substitute refrigerants (see #6 above).

If finalized, appliances with 50 or more pounds of refrigerants would not be required to:

  • conduct leak rate calculations when refrigerant is added to an appliance,
  • repair an appliance that leaks above a threshold leak rate,
  • conduct verification tests on repairs,
  • conduct periodic leak inspections on appliances that exceed the threshold leak rate,
  • report to EPA on chronically leaking appliances,
  • retrofit or retire appliances that are not repaired, and
  • maintain related records.

Additionally, EPA is proposing to extend by six to twelve months the January 1, 2019 compliance date for when appliances containing only substitute refrigerants subject to the venting prohibition must comply with the appliance maintenance and leak repair provisions.

EPA is accepting written comments on the proposed revisions. Comments must be received by November 15, 2018. Comments must be identified by Docket ID No. EPA-HQ-OAR-2017-0629, and submitted online at www.regulations.gov.

 

2019-05-20T21:33:18+00:00
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