Update to CAA: How the EPA's Refrigerant Management Program Has Changed

How the EPA’s
Refrigerant Management
Program Has Changed
Update to CAA:

Meet Your Moderator
Sylvia Leaphart

During this Webinar
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Meet Your Presenter
Rick Foote

Agenda
Overview of the National Refrigerant Management
Program
Highlight of Specific Changes
Outcomes of the Rule
Q&A

National Recycling and Emission
Management Program
The purpose of this program is to:
• Prohibit the release of CFCs, HCFCs, their
blends, and substitute refrigerants during service,
maintenance and repairs, and at end of life
• Reduce the use and emission of CFCs and
HCFCs
• Maximize the recapture and recycling of CFCs
and HCFCs
• Ensure the safe disposal of CFCs, HCFCs, and
their blends

Technician
Certification
Refrigerant
Sales
Restriction
Service
Practices
Recovery &
Recycling
Equipment
Recordkeeping
Repairing
Refrigerant
Leaks
Appliance
Disposal
Refrigerant
Reclamation

Phase Out of HCFCs
• Through the Montreal Protocol on substances
that deplete the ozone layer, the U.S. has
committed to a collaborative international effort
to end use of ozone-depleting substances.
• The U.S. phased out CFCs and halons in the
mid 1990s.
• EPA is currently in the process of reducing
HCFC production and import.

Timelines for Phase Out
January 1, 2010
• Banned production, import, and use of HCFC-22 and HCFC-
142b, except for continuing servicing needs of existing
equipment, achieving 75% of reduction goal.
January 1, 2015
• Ban on production, import, and use of all HCFCs, except for
continuing servicing needs of refrigeration equipment,
achieving 90% of reduction goal.

Which Refrigerants are Affected?
• Ozone-depleting refrigerants (i.e., CFCs and HCFCs)
 Currently subject to the Section 608(c) venting prohibition
 Currently subject to the existing regulatory standards and requirements
• Substitute refrigerants (e.g., HFCs, HFOs, and PFCs)
 Includes any substitute refrigerant not specifically exempted*
 Currently subject to the Section 608(c) venting prohibition
 Will be subject to the regulatory standards and requirements starting 2017,
2018, or 2019
• Exempt substitute refrigerants (e.g., ammonia and CO2)
 Not subject to the venting prohibition in specific end-uses
 Not subject to the regulatory standards and requirements in those uses
 May be subject to other requirements (e.g., OSHA)

Exempt
Refrigerants
End-Use and Application
Household
Refrigerators
Retail
refrigerator
stand-
alone
Vending
VeryLowTemp
Ref
HeatTransfer
Self-contained
Commercial
IceMachines
WaterCoolers
IPR/processing
RoomAC-
Self-
contained
Alluses
CO2, N2, H2O          
Ammonia  
Hydrocarbons,
Chlorine

Propane        
Isobutane   
R-441A    
Ethane  

Changes to Technician
Certification
• You must be a Section 608 certified technician to open HFC appliances (starting
1/1/18)
• EPA is not requiring recertification of current technicians at this time
 EPA is not changing the types of certifications
 EPA is developing an updated test bank for certifying new technicians
• Certifying organizations must post a list of new technicians certified after 1/1/17
(starting 1/1/18)
 Individual technicians can opt out
• EPA is removing the requirement that technicians certify that they own certified
recovery equipment (starting 1/1/17)

Changes to Sales Restriction
• You must be a Section 608 certified technician
to purchase HFC refrigerants (starting 1/1/18)
• Refrigerant distributors may only sell HFC
refrigerants to certified technicians and must
maintain records for those sales (starting
1/1/18)
• Small cans (under 2 pounds) of refrigerant for
motor vehicle air conditioners (MVACs) are not
subject to the sales restriction or
recordkeeping requirement

Changes to Services Practices
• Technicians must use certified recovery and/or recycling equipment
when opening an HFC appliance (starting 1/1/18)
• Technicians must evacuate to the specified levels of vacuum when
opening HFC appliances (starting 1/1/18)
• Newly manufactured or imported recovery and/or recycling
equipment models must be certified for use with HFCs (starting
1/1/17)
• EPA is adopting UL flammability standard as part of the certification
to ensure the safe use of recovery equipment designed for
flammable refrigerants (starting 1/1/17)

Leak Rates and Duty to Repair
• Starting 1/1/2019, these modified leak repair requirements will apply to all refrigerants (excluding
exempt refrigerants cited earlier)
 The existing leak repair requirements will continue as is for ODS appliances until 1/1/19
• The leak rate must be calculated every time refrigerant is added to an appliance containing ≥50 lbs.
of refrigerant
 The repair requirements described on the following slides apply starting January 1, 2019, only if
over the threshold
• Revised leak rate thresholds:
 30% for Industrial Process Refrigeration (IPR) (lowered from 35%)
 20% for commercial refrigeration (lowered from 35%)
 10% for comfort cooling (lowered from 15%)
• A certified technician must perform a leak inspection to identify the necessary repairs
• The repair must bring the appliance leak rate below the threshold
 Must be demonstrated when calculating leak rate upon next refrigerant addition

Changes to Leak Repair
Verification tests:
• Must demonstrate that leaks were successfully repaired
• Initial verification tests - done before refrigerant is added back into the repaired
appliance
• Follow-up verification tests - done after the repaired appliance returns to normal
operating characteristics and conditions
• Requirement extended to commercial refrigeration and comfort cooling (currently
required only for IPR)
• If either the initial or follow-up verification test indicates that repairs were not
successful, you may conduct as many additional repairs and verification tests as
needed within the 30-day repair period

Changes to Leak Repair
• Definition of Appliance:
 Clarifies that each independent circuit in a system with multiple circuits is a
separate appliance
• Leak rate calculations:
 Provides that under the “Rolling Average Method” (formerly “Method 2”) in order
to “close out” a leak event the owner or operator must repair all identified leaks
and verify that the repairs have been successful.
• Recordkeeping:
 Technicians must provide owners and operators with invoices (including
amount of refrigerant added), and results of leak inspections and verification
tests
 Electronic recordkeeping encouraged

Changes to Appliance Disposal
• Appliances with 5 pounds of refrigerant or less
 Existing safe disposal requirements extended to HFC appliances (starting 1/1/18)
• Appliances with between 5 and 50 pounds of refrigerant
 New records for the disposal of appliances containing between 5 and 50 pounds of
refrigerant (starting 1/1/18)
 Company name, location of the appliance, date of recovery, and type of refrigerant
recovered for each appliance;
 Amount of refrigerant (by type) recovered from all disposed appliances in each
calendar month; and
 Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the
person to whom it was transferred, and the date
• These records must be maintained by the technician and not the owner or operator of
the appliance

What are the Results of the
Changes?
• By promoting the proper handling of refrigerants, EPA anticipates:
• The annual GHG emissions reduction is equivalent to the annual GHG emissions
of 1.5 million cars
• EPA estimates $44 million in savings from reduced purchases of refrigerant

What are the Results of the
Changes?
• Consistent treatment of commonly used
refrigerants (e.g., ODS, HFCs, blends)
 Incorporating best management
practices to reduce leaks from large
appliances
 Focus on ensuring repairs are effective
 Enhancing clarity of the rules to improve
compliance
 Removing obsolete requirements

Flammable Refrigerants
• EPA has exempted certain hydrocarbon refrigerants from the
venting prohibition when used in specific appliances and, as a
consequence, the Section 608 requirements:
 These are new, self-contained, small appliances specifically
designed to use hydrocarbon refrigerants
 EPA does not anticipate that opening up such appliances for
servicing or recharging will be common
 Such appliances are identifiable by red tubing and other
markings

Flammable Refrigerants
• It is illegal to use hydrocarbon or other flammable refrigerants
(such as R-22a) in existing HCFC/HFC appliances:
 This is true whether the refrigerant is sold to a certified
technician or not
 Some flammable refrigerants are not exempt from the
Section 608 requirements (such as HFC-32) and may only
be purchased by a certified technician
 Recovery and/or recycling equipment for use with such
flammable refrigerants must be certified to ensure safety for
those refrigerants

Thank You For Attending!
Rick Foote:
rfoote@triumvirate.com
Director of Industrial Practice
Triumvirate Environmental
Call Us!
1-888-834-9697
www.triumvirate.com
Triumvirate can help meet your compliance needs.
For more information on our consulting services, visit:
http://www.triumvirate.com/technical-
services/consulting-services

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