How Does the California Refrigerant Management Program Relate to SB 260?
California often leads the way in environmental policies, including policies around ESG and through the California Refrigerant Management Program. SB 260, otherwise known as the Climate Corporate Accountability Act, is currently going through the state’s senate which would require reporting to the California Air Resources...Read More
California often leads the way in environmental policies, including policies around ESG and through the California Refrigerant Management Program. SB 260, otherwise known as the Climate Corporate Accountability Act, is currently going through the state’s senate which would require reporting to the California Air Resources Board on Scope 1, 2, and 3 emissions.
SB 260 would require the state board to adopt policies where business making more than $1 billion in revenue to report on Scope 1, 2, and 3 emissions. These disclosures must be easy to understand and accessible to residents of California. Furthermore, they must be audited and ensured by a third party.
This is the first legislation of its kind. While there is rulemaking in the SEC to make publicly-owned companies report on their emissions, this would be the first time any company making a certain amount of revenue would be required to report in a specific state – and they would be required to report all emissions, not just those made in California. The purpose is to make disclosures relevant and accurate.
As they prepare, companies need to be looking at their refrigerant emissions. They are often overlooked, but need tobe reported on for Scope 1, 2, and 3 emissions. If you’re already operating in California, though, you may be familiar with the California Refrigerant Management Program. Now is the time to refresh your memory of it if you aren’t as familiar, since it will allow you to have information on hand about your emissions and refrigerant activities. While SB 260 isn’t refrigerant specific, information about refrigerant emissions are still relevant to what you will need to report. Following California’s refrigerant management program will give you a starting point to audit your systems when the time comes to report on emissions.
While SB 260 and the refrigerant management program are two separate things, it’s important to understand how one leads into the other. Read on to understand the refrigerant management program and ensure you’re on top of what California is requiring from an operational level before sustainability elements also come into play.
What Refrigeration Systems Need to Comply with the Refrigerant Management Program
The ability to promptly repair leaks, using a reporting tool, and other requirements under the refrigeration management program falls to non-residential refrigeration equipment. Furthermore, it applies specifically to stationary refrigeration systems. Companies must also make prompt leak repairs, keep service records on site, and have service practices that minimize refrigerant emissions. The program also phases down HFC use since they have high global warming potential.
California defines a stationary refrigeration system as a system that it is installed in a building, structure or facility. It must be attached to a foundation or reside at a location for more than 12 consecutive months. It can also be located at the same single location on a permanent basis and operate at that location at least three months each year.
Furthermore, the stationary refrigeration must have a full charge of more than 50 pounds of high GWP refrigerant in order to fall under the program and need to perform periodic leak inspections among other service practices.
All stationary refrigerant systems must be registered with CARB’s Executive Officer. This must be done on March 1 of the calendar year after the calendar year when the system began operating at the facility. This was slowly phased in for various stationary sources, but now they all must be registered.
When registering, the company must include information on the facility and refrigerant system information. If there is a change of ownership, the person selling the system must make sure that the system is free of leaks through a leak inspection certified by a technician. Then, a change of ownership notification must be sent to the Executive Officer.
In addition to the registration of refrigeration systems containing high GWP refrigerant, the CARB regulations implement fees.
There is an initial implementation fee paid upon registration of a system. Each year, there is an annual implementation fee for larger systems as well. This is paid by the owner or operator of a facility with a refrigerant system with a full charge greater than or equal to 200 pounds of GWP refrigerant.
While many facilities are subject to these fees, there are a few that are exempt.
One exemption is for facilities that are not new but are using refrigerants with zero ozone-depleting chemicals, only using refrigerants found acceptable by SNAP, and achieve an average HFC full charge equal to or less than 1.25lb of refrigerant per 1000 Btu per hour total evaporator cooling load. The owner or operator must attest that they meet this criteria to be exempt.
Another exemption is for newer facilities. If they are using refrigerants with zero ozone-depleting potential, only use refrigerants found acceptable by SNAP, and achieve an average HFC full charge equal to or less than 1.25lb of refrigerant per 1000 Btu per hour total evaporator cooling load, they can receive an exemption. Again, the owner or operator must officially swear that they meet the criteria to be exempt.
CARB put certain leak detection requirements in place to reduce emissions. These requirements fall into one of two categories – year-round operation and non-year-round operation.
Systems with year-round operation must follow a strict set of leak detection requirements. These break down by charge size.
Full Charge Greater or Equal to 2000 Pounds
The largest system in the program must install an automatic leak detection system if the refrigerant circuit is located entirely within an enclosed building or structure, or if the compressor, evaporator, condenser, or any other component is prone to leaks. If these parts are not entirely enclosed, then the owner or operator must perform a leak inspection once every three months.
Between 200 and 2000 pounds
For these systems that are smaller but still somewhat large, the owner or operator must conduct a leak inspection once every three months.
Between 50 and 200 pounds
For these smaller systems, the owner or operator must conduct an annual leak inspection.
When Refrigerant is added to a system greater than 50 pounds
When refrigerant is added to these systems, the owner or operator must conduct a leak inspection if the charge is equal to or greater than five pounds or one percent of the system full charge.
Regulations for refrigerant systems that don’t operate year round are not as complex. For these systems, the owner or operate must conduct a leak inspection 30 days after starting operation, and then once every three months until it is shut down.
Leak Repair Requirements
There are requirements for leak repair, specifically around when a leak must be repaired. A leak must be repaired within 14 days of detection, except in extenuating circumstances. For instance, if a technician isn’t available, parts aren’t available, or the leak is so big that it would shut down an entire job site to fix, there are allowances for 45 days or 120 days.
In addition to repairing the leak, there must be an initial verification test and follow-up. If there’s an unsuccessful verification test, the owner or operator must continue to make repair attempts. If something cannot be repaired, a retrofit or retirement plan must be made.
Retrofit and Retirement Plan Requirements
In the case that a repair can’t be made, an owner or operator must create a retrofit or retirement plan for the system. This plan must be kept onsite and needs to include the following information:
- System identification number
- Equipment type
- Equipment manufacturer
- Equipment model or description
- Intended physical location
- Temperature classification
- Full charge
- Type of high-GWP refrigerant used
- The plan to dispose of the system
- A timetable for the retrofit or retirement
In addition to requirements for leaks and retrofitting, the refrigerant management program also requires that companies submit annual reports. What is required in these reports breaks down by the size of the systems.
Greater Than or Equal to 200 Pounds
For systems of this size, a report must be made by March 1 of each calendar year. The report must include information about the refrigerant system (ID number, equipment type, full charge, etc.), service and leak repair, and refrigerant purchases and use information.
Between 50 and 200 Pounds
For smaller systems, companies aren’t required to submit an annual report. However, the Executive Officer can still request that you have the above information. It’s a good idea to know how to pull the proper information and have it on file in case you ever need it.
Required Service Practices
When performing service to any refrigeration systems that fit under the program, there are certain requirements:
- The service can’t disrupt the refrigerant circuit
- The technician must make a recovery attempt using certified refrigerant recovery or recycling before opening the appliance to atmospheric conditions
- The technician can’t add any additional refrigerant to refrigeration or AC appliances during manufacture or service
- The technician can’t add additional refrigerant charge to any appliance known to have a refrigerant leak
- The technician must be certified and use certified procedures and processes
All of these requirements must be met when performing any installation, maintenance, service, repair, or disposal of a system that could leak refrigerant into the atmosphere.
In addition to the requirements in the refrigerant management plan, CARB and the state of California facilitate solutions to phase down HFCs. HFCs, while previously thought to be efficient, are actually destructive to the environment. The phase-out was gradually introduced through 2021, but is now in full effect.
The phase-out prohibits certain HFC substitutes based on their end-uses. The prohibitions specifically affect:
- Supermarket systems
- Remote condensing units
- Stand-alone medium temperature units below 22000 Btu/hr and greater than 22000 Btu/hr
- Stand-alone low-temperature units
- Stand-alone units
- Vending machines
- Refrigerated food processing and dispensing equipment
- AC equipment
- AC and industrial process refrigeration
- Cold storage warehouses
- Ice rinks
For a full overview of the prohibitions, download our handout.
Where SB 260 Comes In
As we mentioned at the beginning of this blog, SB 260 is not refrigerant-specific. It is more focused on Scope 1, 2, and 3 emissions and making sure that companies are reporting accurate information to the state. However, some of this information can come to you through proper maintenance of your refrigeration systems, which the refrigerant management program requires.
As companies prepare for more stringent ESG requirements like SB 260, they must be sure that they are already meeting compliance requirements and have proper inventory on their systems. After all, it’s impossible to report on emissions if you don’t have a proper understanding of what systems and refrigerants you are using.
Compliance is the first step – being sure that you are managing leak rates, reporting to the right agencies, and retrofitting and retiring at the right time is just the beginning of your journey. To have the right information that California will be looking for, companies must go beyond to be able to report on emissions.
Use Trakref to Stay Up-To-Date
California’s refrigerant management program has set the stage for what is expected in refrigerant management on the state level, and that’s being followed up with SB 260 to make sure both compliance and sustainability obligations are met.
The need to understand your leaks, registration requirements, and repair requirements is more important than ever. It’s no longer good enough to simply have this information on slips of paper or in Excel spreadsheets. Companies must become more sophisticated.
Trakref is the perfect solution. Our rules engine guides technicians through regulations and ensures that you are up-to-date on what you need to do, especially in regulated states like California. You’ll also have reports at your fingertips when needed, and you’ll be able to send information directly to CARB through our software.
As more information about SB 260 comes about and is solidified, we will also be updating our software. We already have a Scope 1 emissions module that allows you to track your Scope 1 refrigerant emissions, and we will continue to develop more tools that will keep you compliant with SB 260. In addition, they will help you decrease your carbon footprint and work toward sustainability goals.
To start your journey with us and make sure you’re ready to be compliant in California, both for their refrigerant management plan and and SB 260 emissions reporting, get in touch with us today.
Gavin is the Lead Writer at Trakref.