Weekly Compliance Digest - EPA Refrigerant Management Rule

September 30, 2016

In this edition of the Weekly Compliance Digest, we cover changes to the EPA’s refrigerant management program.

Revised Section 608 Refrigerant Management Regulations

What is it?

On September 26, 2016, the U.S. EPA announced a final rule strengthening the refrigerant management program under Section 608 of the Clean Air Act and extending the regulations to non-ozone depleting substitutes such as hydrofluorocarbons (HFCs) and other substitutes. The objective of the rule is to reduce emissions by lowering the leak rate at which large air conditioning and refrigeration appliances must be repaired, and incorporating industry best practices such as verifying repairs and conducting regular leak inspections on leaking appliances.

Section 608 of the Clean Air Act prohibits the knowing release of refrigerant during the maintenance, service, repair, or disposal of air-conditioning and refrigeration equipment. The EPA requires proper refrigerant management practices by owners and operators of refrigeration and air-conditioning systems, technicians, and others. The final rule updates existing requirements related to ozone-depleting substances (ODS), such as CFCs and HCFCs, and extends them to substitutes such as HFCs.

Who is affected?

Supermarkets and property and facility managers are affected by new requirements of the final rule. Specifically, the leak repair regulations apply to industrial process refrigeration (IPR), commercial refrigeration, and comfort cooling appliances containing 50 pounds or more of ODS or substitute refrigerant.

What are the requirements?

The final rule includes the following provisions for owners and operators of refrigeration and air-conditioning systems at facilities:

  • Owners/operators must identify and repair leaks that exceed 30% for industrial process refrigeration (IPR), 20% for commercial refrigeration, and 10% for comfort cooling within 30 days of when the ODS or substitute refrigerant is added.
  • Owners/operators must create a retrofit or retirement plan within 30 days of an appliance leaking ODS or substitute refrigerant above the applicable leak rate if:
    • The owner/operator intends to retrofit or retire rather than repair the leak; or
    • The owner/operator fails to identify and repair the leak; or
    • The appliance continues to leak above the applicable leak rate after required repairs and verification tests.
  • Owners/operators must conduct quarterly or annual leak inspections for appliances that have exceeded the applicable leak rate.
  • Owners/operators must submit reports to the EPA if any appliance leaks 125% or more of its full charge in one calendar year. This report must describe efforts to identify leaks and repair the appliance.
  • Owners/operators must maintain hard or electronic copies of certain types of records, such as:
    • Records documenting the full charge of appliances.
    • Records, such as invoices, showing when service or maintenance is performed, when refrigerant is added to an appliance (or removed, in the case of disposal), when a leak inspection is performed, and when a verification test is conducted.
    • Retrofit and/or retirement plans.

What is next?

A pre-publication version of the revised 608 refrigerant management rule was made available on September 26, 2016. The requirements from the final rule will take effect on January 1, 2019.

Visit Enablon Insights again next Friday for a brand new Weekly Compliance Digest!

To learn more about EHS, Sustainability and Risk trends, we encourage you to read the NAEM 2016 Trends Report: Planning for a Sustainable Future, which presents the ideas and issues that will shape EHS and Sustainability Management in 2016 and beyond.

NAEM 2016 Trends Report: Planning for a Sustainable Future