Update to the Refrigerant Management Requirements under Section 608 of the Clean Air Act
Refrigeration original equipment manufacturers must comply with the EPA’s significant new alternatives policy (SNAP) rulings on refrigerants and the DOE’s energy reduction mandates. EPA Administrator Gina McCarthy signed a proposed rule on October 15 that would more fully implement the prohibition under section 608 of the Clean Air Act against knowingly venting, releasing or disposing of ozone-depleting and substitute refrigerants.
The revised rule would accomplish this by updating the existing requirements under section 608 that currently apply to ozone-depleting (ODS) refrigerants and then extending, as appropriate, the requirements to non-ozone-depleting substitute refrigerants such as hydrofluorocarbons (HFCs).
In addition, the EPA is proposing numerous changes to the National Recycling and Emission Reduction Program. The major regulatory changes proposed are:
Lowering the leak rate threshold above which owner/operators of refrigeration and air-conditioning equipment normally containing more than 50 lb of refrigerant must repair leaks:
- Lower from 35 percent to 20 percent for industrial process refrigeration (IPR) and commercial refrigeration equipment.
- Lower from 15% to 10% for comfort cooling equipment.
Requiring regular leak inspections or continuous monitoring devices for refrigeration and air-conditioning systems.
- Annual inspections for systems normally containing more than 50 lb of refrigerant.
- Quarterly inspections for industrial process refrigeration and commercial refrigeration systems normally containing more than 500 lb of refrigerant.
- Prohibiting operation of systems normally containing more than 50 lb of refrigerant that have leaked 75 percent or more of their full charge for two consecutive years.
- Allowing the purchase of cans containing two pounds or less of non-ODS refrigerant for motor vehicle air conditioner (MVAC) servicing without technician certification so long as the small cans have a self-sealing valve to reduce refrigerant releases.
- Requiring technicians to keep a record of refrigerant recovered during system disposal from systems with a charge size from 5 to 50 lb.
- Extending the requirements of the Refrigerant Management Program to cover substitute refrigerants such as HFCs. (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.)
On its page dedicated to refrigeration and air-conditioning systems, EPA notes that the choice of refrigerant substitutes for specific industrial process refrigeration system applications depends on ambient and required operating temperatures and pressures. It has published a table of currently acceptable substitutes.
Industrial and commercial refrigeration equipment manufacturers are responding to the proposed rule changes to help processors identify alternatives. One such company that has already developed some resources is Emerson Climate Technologies, which has has commenced research, development and testing programs to help these OEMs achieve compliance. To do so will require coordination of all constituents in the refrigeration supply. For example, component suppliers, equipment manufacturers and test laboratories will need to have resources available to handle the increased workload of the qualification process.