On 19 November, Rebecca von dem Hagen, the newest member of the EPA’s Greenchill Partnership team, hosted a webinar on the future changes to the National Refrigerant Management Program.
The proposed changes to Section 608 of the Clean Air Act, published on 9 November, aim at reducing emissions of ozone depleting substances (ODS) and substitute refrigerants during the maintenance, service, repair, and disposal of appliances.
Luke Hall-Jordan, team leader of the Stratospheric Protection Division, U.S. Environmental Protection Agency (EPA), highlighted that the use and emissions of HFCs are rapidly increasing. From 2004 to 2008, global HFC emissions increased by about eight per cent every year.
In the U.S., current levels of HFC emissions are expected to double by 2020 and triple by 2030. If this trend continues, HFC emissions could make up 20 per cent of total carbon dioxide emissions by 2050.
“Our number one goal, in terms of immediate goals, is extending Section 608 requirements to HFCs and other substitutes that are not exempt from the vending prohibition (“non-exempt substitutes”). However, none of the requirements would affect the use of natural refrigerants, such as CO2, ammonia or hydrocarbons,” he explained.
With the new rule, the EPA also aims to decrease leaks from large appliances and enhance clarity and ease of compliance while making enforcement simpler. “The leak repair requirements are very cumbersome, so we wanted to simplify the language of these requirements. We wanted to create incentives that support careful management of refrigerants”.
Changes proposed
Appliance repair represents the biggest change to Section 608 as the EPA is suggesting a completely new structure for leak repairs. The proposed rule entitles technicians to calculate leak rate whenever refrigerants are added (applicable to all appliances with full charge of 50 lbs. or more of non-exempt refrigerants).
If the leak exceeds the applicable leak rate, when leak inspection shall be conducted and all identified leaks must be repaired within 30 days. To make these repairs, time extensions might apply in certain cases. Also, the initial verification test must be conducted before adding additional refrigerant and a follow-up verification test must be conducted thereafter.
If the engineer cannot repair the leak, then the retrofit retirement plan must be developed within 30 days of its initial discovery. In this case, the retrofit retirement must be completed within one year but time extensions might be available. For example, the rule allows for up to 18 months if the replacement appliance uses exempt refrigerant such as CO2, hydrocarbons and ammonia.
The allowed leak rate was also lowered from 35% to 20% for refrigeration appliances and from 15% to 10% for comfort cooling.
Mr. Hall-Jordan explained: “We proposed to establish a two-year leak limit. We would prohibit an appliance from leaking more than 75% of its full charge in two consecutive years. If the leak amount is exceeded, the appliance would need to be retired or ‘mothballed’”.
“The final proposed change relates to leak inspections. We wanted to build something that is more proactive”. The proposed rule will require regular leak inspections: quarterly for 227+ kilograms commercial refrigeration and Industrial Process Refrigeration (IPR) (with annual inspections allowed instead if no refrigerant has been added in the past 365 days); annually for all other appliances of 23 or more kilograms.
However, it should be noted that the EPA is proposing to allow that leak inspections be conducted by staff other than a certified technician.
In terms of recordkeeping, technicians would have to provide more detailed records for owners or operators of the appliance. The EPA also encourages electronic recordkeeping systems.
For reporting purposes, the EPA has a new email address (608reports@epa.gov) to send the required reports. Companies would need to notify the EPA if seeking an extension for leak repairs.
With the proposed changes, the EPA expects about 7.5 million metric tons in reductions of carbon dioxide equivalent of greenhouse gas emissions. The EPA also anticipates that the sector regulated by the rule would experience 49 million Euro in cost savings related to reduced purchases of refrigerant.
Next steps
On 4 December, the EPA will organise a small business roundtable, where the companies and other relevant stakeholders will have the possibility to voice their concerns, raise questions or offer recommendations.
The EPA is also inviting companies to submit written comments by 8 January next year.
Luke Hall-Jordan, team leader of the Stratospheric Protection Division, U.S. Environmental Protection Agency (EPA), highlighted that the use and emissions of HFCs are rapidly increasing. From 2004 to 2008, global HFC emissions increased by about eight per cent every year.
In the U.S., current levels of HFC emissions are expected to double by 2020 and triple by 2030. If this trend continues, HFC emissions could make up 20 per cent of total carbon dioxide emissions by 2050.
“Our number one goal, in terms of immediate goals, is extending Section 608 requirements to HFCs and other substitutes that are not exempt from the vending prohibition (“non-exempt substitutes”). However, none of the requirements would affect the use of natural refrigerants, such as CO2, ammonia or hydrocarbons,” he explained.
With the new rule, the EPA also aims to decrease leaks from large appliances and enhance clarity and ease of compliance while making enforcement simpler. “The leak repair requirements are very cumbersome, so we wanted to simplify the language of these requirements. We wanted to create incentives that support careful management of refrigerants”.
Changes proposed
Appliance repair represents the biggest change to Section 608 as the EPA is suggesting a completely new structure for leak repairs. The proposed rule entitles technicians to calculate leak rate whenever refrigerants are added (applicable to all appliances with full charge of 50 lbs. or more of non-exempt refrigerants).
If the leak exceeds the applicable leak rate, when leak inspection shall be conducted and all identified leaks must be repaired within 30 days. To make these repairs, time extensions might apply in certain cases. Also, the initial verification test must be conducted before adding additional refrigerant and a follow-up verification test must be conducted thereafter.
If the engineer cannot repair the leak, then the retrofit retirement plan must be developed within 30 days of its initial discovery. In this case, the retrofit retirement must be completed within one year but time extensions might be available. For example, the rule allows for up to 18 months if the replacement appliance uses exempt refrigerant such as CO2, hydrocarbons and ammonia.
The allowed leak rate was also lowered from 35% to 20% for refrigeration appliances and from 15% to 10% for comfort cooling.
Mr. Hall-Jordan explained: “We proposed to establish a two-year leak limit. We would prohibit an appliance from leaking more than 75% of its full charge in two consecutive years. If the leak amount is exceeded, the appliance would need to be retired or ‘mothballed’”.
“The final proposed change relates to leak inspections. We wanted to build something that is more proactive”. The proposed rule will require regular leak inspections: quarterly for 227+ kilograms commercial refrigeration and Industrial Process Refrigeration (IPR) (with annual inspections allowed instead if no refrigerant has been added in the past 365 days); annually for all other appliances of 23 or more kilograms.
However, it should be noted that the EPA is proposing to allow that leak inspections be conducted by staff other than a certified technician.
In terms of recordkeeping, technicians would have to provide more detailed records for owners or operators of the appliance. The EPA also encourages electronic recordkeeping systems.
For reporting purposes, the EPA has a new email address (608reports@epa.gov) to send the required reports. Companies would need to notify the EPA if seeking an extension for leak repairs.
With the proposed changes, the EPA expects about 7.5 million metric tons in reductions of carbon dioxide equivalent of greenhouse gas emissions. The EPA also anticipates that the sector regulated by the rule would experience 49 million Euro in cost savings related to reduced purchases of refrigerant.
Next steps
On 4 December, the EPA will organise a small business roundtable, where the companies and other relevant stakeholders will have the possibility to voice their concerns, raise questions or offer recommendations.
The EPA is also inviting companies to submit written comments by 8 January next year.
MORE INFORMATION
By hydrocarbons21.com team (@hydrocarbons21)
Nov 25, 2015, 12:23
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