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EPA Updates Ozone Depleting Substances Regulation

In November of 2016, EPA finalized changes to Section 608 of their Refrigerant Management Regulations. These changes will affect professionals and facilities that utilize refrigerants. These changes took effect on January 1st, 2017 and currently remain in place. Unlike many other regulations, these are NOT likely to be canceled or delayed because these specific changes took effect before January 20th. These changes are summarized below:

• Starting January 1, 2018, uncertified technicians must pass a certification exam updated to reflect these new rules and offered by an approved certification program in order to maintain, service, repair or dispose of appliances containing ODSs or substitute refrigerants. Technicians must maintain a copy of their certificates at their workplace for at least three years after they cease technician work.

• The requirements of the Refrigerant Management Program have been extended to also cover substitute refrigerants, such as HFCs. Note that EPA has previously exempted some substitutes from the Section 608 venting prohibition through previous rules. Such substitutes are also exempt from the requirements of this rule.

• New recordkeeping requirements have been added to EPA’s requirements for owner/operators:

o Documentation of the full charge of appliances.

o Records of when maintenance is performed, when refrigerant is added or removed, when leak inspections are conducted, and when verification tests are conducted.

o Automatic leak detection systems users must document that the system is installed and calibrated annually and record leaks identified by the monitoring system, including the time and location of the leak.

o Retrofit/retirement plans

o Requests submitted to EPA to extend repair/retrofit deadlines.

o Documentation of when a system was temporarily taken out of service to suspend a repair deadline, if applicable. Corresponding documentation must be maintained when refrigerant is added back into the appliance and it is brought back on-line.

o Records to demonstrate a seasonal variance.

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

• The new rules lower the leak rate thresholds that trigger the need to conduct inspections and change the requirements for resultant reports and repair. These new thresholds are applicable to equipment containing 50 or more pounds of refrigerant.

o Thresholds are moving from 35% to 30% for industrial process refrigeration (IPR)

o Thresholds are moving from 35% to 20% for commercial refrigeration equipment

o Thresholds are moving from 15% to 10% for comfort cooling equipment

o Quarterly/annual leak inspections or continuous monitoring devices are required for the refrigeration and air-conditioning equipment that have exceeded the threshold leak rates described above.

o Owners/operators must submit reports to EPA if systems containing 50 or more pounds of refrigerant leak 125% or more of their full charge in the duration of one calendar year.

o Verification tests must demonstrate that leaks were successfully repaired. If either verification test fails, owners/operators may conduct as many additional repairs and verification tests as needed within the allotted 30 day repair period, period extended to 120 days if an industrial process shutdown is required.

o Beginning January 1, 2019 owners/operators perform and document both an initial and follow-up verification test of leak repairs. An initial verification test must be performed before any additional refrigerant is added to the appliance. A follow-up verification test must be performed only after the appliance has returned to normal operating characteristics and conditions. Timing for the verification tests are required as described below:

• For commercial refrigeration and industrial process refrigeration: Appliances with 50-500lbs of charge must be inspected once per calendar year until the owner/operator can demonstrate compliance through leak rate for four quarters in a row. Appliances with more than 500 pounds of charge require inspection once every three months.

• Comfort cooling: All appliances containing 50 pounds or more of charge must per inspected once per calendar year, until the owner/operator can demonstrate compliance through leak rate calculations.

o If the leak rate still cannot be brought below threshold, owners/operators must create a retrofit or retirement plan for the appliances

• The changes extend prior sales restrictions on ODS onto HFC’s and other non-exempt substitutes as well, with the exception of small cans containing 2 pounds or less of non-exempt substitutes for motor vehicle air conditioner servicing.

• As of January 1, 2018, technicians must use certified recovery/recycling equipment to evacuate ODS’s or substitute refrigerants to levels specified in the regulations.

• As of January 1, 2018, Technicians must keep a record of refrigerant recovered during system disposal from systems with a charge size from 5–50 lbs.

The link below is an EPA press release that summarizes these changes and how they affect the public at large:

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