New 2019 Updates To EPA Refrigerant Regulations

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In 2016, the U.S. EPA issued a rule updating and revising the refrigerant management requirements under 40 CFR part 82. Among other things, previously exempt substitute refrigerants (e.g., HFCs, HFOs, and PFCs) are subject to Section 608 of the rule, and while the regulation took effect on January 1, 2017, some provisions had compliance dates of January 1, 2018 and January 1, 2019.

Revised Section 608

Under the 608 regulatory requirements, facilities are required to track appliances containing any type of substitute refrigerants with a full charge of ≥ 50 pounds. The rule contains provisions that affect both the owners/operators of the appliances and the technicians who service them.

Even if you are already in compliance with previous dates, compliance is not static at all and you might need to keep up with the requirements that got started on January 1, 2019.

Refrigerant Management Rule - 2019 Updates

Critical requirements of the rule that went into effect on January 1, 2019 include:

Lowering the Leak Rate Threshold for Equipment

Those thresholds are categorized by appliance type (industrial process refrigeration, commercial refrigeration, comfort cooling and all other appliances) and the requirements mandate the owners and operators to take corrective action when an appliance (with a full charge of ≥ 50 pounds) is discovered to be leaking ozone depleting refrigerant at a rate that exceeds the applicable trigger rate. Leaks must be repaired such that the rate is brought below the applicable.

The following trigger leak rates apply for a 12-month period:

  • Industrial process refrigeration: 30% - lowered from 35%

  • Commercial refrigeration: 20% - lowered from 35%

  • Comfort cooling: 10% - lowered from 15%

  • All other appliances: 10% - lowered from 15%

New Mandatory Leak Inspection Requirements - Corrective Action

Owners and operators of an appliance that exceeds the applicable leak rate are subject to initial and follow-up verification tests for leak repairs at the end of each repair effort. Therefore, if your appliance exceeds the applicable allowable leak rate threshold, you must perform a mandatory leak verification test conducted by a certified technician to demonstrate that leaks have been successfully repaired. In general, you must either:

  • Repair leaks within 30 days from when the leak was discovered.

  • Develop a plan to retrofit or retire an appliance and schedule for the completion of the retrofit or retire plan within one year.

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The frequency of leak inspection is determined as follows:

Commercial Refrigeration and Industrial Process Refrigeration (IPR)

  • Once every three months for appliances containing ≥ 500 pounds refrigerant, until the owner or operator can demonstrate, through leak repair calculations that the leak rate has not exceeded 20% (for commercial refrigeration), or 30% (for IPR) for four quarters in a row.

  • Once per year for appliances containing 50-500 pounds refrigerant, until the owner or operator can demonstrate through the leak repair calculations, that the leak rate has not exceeded 20% (for commercial refrigeration) or 30% (for IPR).

Comfort Cooling

  • All appliances containing ≥ 50 pounds refrigerant must perform inspection once per year until the owner or operator can demonstrate, through the leak repair calculations, that the leak rate has not exceeded 10% for one year.

Important note: Quarterly or annual leak inspections are not required for appliances (or portions of appliances) that are continuously monitored by an automatic leak detection system that is audited and calibrated annually.

Chronically Leaking Appliances

Owners or operators must report to EPA in the event that any appliance leaks 125% or more of the full charge in one calendar year. The report must document effort to repair the appliance and is due by March 1st of the subsequent year.

Recordkeeping Requirements

Owners or operators must maintain the hard or electronic copies of the following:

  • Records documenting the full charge of appliances.

  • Records (such as invoices) of services performed showing when service or maintenance of appliances is performed, when refrigerant is added or removed, and when verification tests are conducted.

  • If owners or operators are using an automatic leak detection system for an appliance or parts of an appliances, they must provide documentation that the system is installed and calibrated annually, and records of when the system identifies a leak as well as the location of the leak.

  • Any retrofit and/or retirement plans.

  • Any reports of requests submitted to EPA to extend the repair or retrofit deadlines.

  • Documentation of when a system was “mothballed” (temporarily taken out of service) to suspend a deadline, and when it was brought back on-line.

  • Records to demonstrate seasonal variance.

  • Reports of appliances identified as leaking 125% or more of their full charge within a year.

The EPA’s updated refrigerant management requirements create new compliance obligations for owners or operators of refrigerant appliances and require proper refrigerant management practices of air-conditioning and refrigeration equipment. KERAMIDA’s Environmental Compliance consultants are ready with the right information and tools in place to help you meet compliance. Contact us today or call (800) 508-8034 to talk to one of our experts.

Additional EPA Resources:
Update to the Refrigerant Management Requirements Final Rule: www.epa.gov/section608/revised-section-608-refrigerant-management-regulations

Blog Author

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Anastasia Kyrmanidou, Ph.D.
Senior Project Manager
KERAMIDA Inc.

Contact Anastasia at akyrmanidou@keramida.com.