Section 608 EPA: What To Know
While states often tackle different elements of industrial process refrigeration and commercial refrigeration through state refrigerant management programs, such as in California and now Washington, the EPA has their own overarching federal regulations.
These are outlined in Section 608, and are updated periodically to address leaking ozone-depleting refrigerant, leak repair, and other aspects of refrigeration assets.
Section 608 started in the 1990s with the Clean Air Act. It defines record-keeping, leak rate calculations, equipment leak thresholds, timelines to repair leaks, retrofit and retirement timelines, mandatory leak inspection requirements, and reporting for chronically leaking appliances.
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While it has been on the books since then, putting certain regulations in place for leak repair requirements and refrigerant management regulations, some major updates were made in 2016 and 2020. These address technician certification, refrigerant recovery and recycling, recordkeeping, disposal, reclamation, comfort cooling, and service practices.
Some other terms you might hear associated with Section 608 EPA are:
- Universal certification
- Low pressure appliances
- High pressure appliances
- Proper refrigerant handling techniques
- EPA certification
- Certification exam
- EPA 608 certification
- EPA approved certifying organization
- Service repair or dispose
- Refrigeration systems
- Federal Clean Air Act
- EPA approved test
- Certified technician
Here, we’re going to cover what you need to know about EPA 608 right now.
Compliance continues to matter (it always will)
Compliance regulations like Section 608 make sure that you know what kind of equipment you’re working with. They ensure that you’re following trigger leak rates, maintaining systems, and keeping proper documentation. Without this information, it’s impossible to properly assess your systems’ environmental impact. The first step towards sustainability is ensuring that you have compliance elements under control. Only then can you begin to assess what you need to do to reduce emissions.
While it may seem that the conversation is pivoting, it is still crucial to know compliance measures and ensure that you are following them. It will make it easier to assess ESG performance and ensure that you can make progress in fighting climate change.
The basic regulations of EPA 608
Section 608 defines record-keeping, leak rate calculations, equipment leak thresholds, timelines to repair leaks, retrofit and retirement timelines, mandatory leak inspection requirements, and reporting for chronically leaking appliances. Being compliant with Section 608 allows you to better understand your inventory and the state of your appliances.
Section 608 puts forth specific record-keeping for commercial refrigeration equipment. These records must be kept for three years and be available in case the EPA asks for them in an inspection.
For appliances with 50 or more pounds of refrigerant, reporting must identify the location of appliances within a site, state the owner and operator, show the address of the site where the appliance is located, and state the full charge of the appliance as well as any changes to the full charge value and date of change and method used.
For work carried out on appliances of 50 or more pounds, records must document the date and type of service. There must be an invoice or other documentation showing the amount and type of refrigerant added. For follow-up verification tests, the date, type, and result need to be recorded.
For appliances with five or more pounds of refrigerant where refrigerant is being removed, the owner or operator must keep records on the date of recovery, type and quantity of each refrigerant recovered, the person to whom the refrigerant was transferred, and the fate of the refrigerant reclamation or destruction.
Leak rate calculations
Under Section 608, owners and operators must recalculate the leak rate for equipment every time a technician adds refrigerant. The EPA approves two methods.
The first is the annualizing method. With this method, the leak rate equals pounds of refrigerant added divided by pounds of refrigerant in a full charge, multiplied by 365 days divided by the shorter of the number of days since refrigerant added, multiplied by 100%.
The second is the rolling average method. In this method, the leak rate equals pounds of refrigerant added over the past 365 days divided by pounds of refrigerant in a full charge multiplied by 100%.
Leak rate threshold
For industrial refrigeration, there are specific leak rate thresholds for when air conditioning equipment and refrigeration equipment must be repaired, retrofitted, or retired. If the amount of refrigerant added exceeds the applicable allowable leak rate, a repair, retrofit, or retirement must be made.
The thresholds are as follows:
- For industrial process refrigeration – 30%
- For commercial refrigeration – 20%
- For comfort cooling – 10%
Retrofitting and retirement is required when leak rate thresholds can’t be met, since ozone depleting substances will be leaked into the environment without these plans. Plans are due within 30 days of the decision and all work must be completed within one year.
Leak repair time frames under EPA 608
In addition to requirements for retrofitting, repair, and retirement, there are also requirements for when a leak must be made. For commercial applications, a leak repair must be completed within 30 days. For industrial process refrigeration, the repair must be made within 120 days.
The repair must include inspection, repair, initial verification of repair, and follow up verification tests. The records for these repairs must be kept on site in case of annual inspections.
Leak inspection requirements
While leak repairs must be made in a timely manner, refrigerant management requirements also dictate leak inspections on a timeline determined by appliance size.
If an appliance exceeds the applicable allowable leak rate stated above, then a leak inspection is due. For commercial refrigeration or industrial applications with greater than 500 pounds of charge, quarterly inspections are required. For applications with a charge size between 50 and 500 pounds, inspections are only required on an annual basis.
Regulations are slightly different for comfort cooling equipment and comfort cooling appliances. If equipment charge is over 50 pounds, inspections are only required on an annual basis.
For all of these regulations, if continuous monitoring devices are installed and calibrated annually, then the regulation does not apply.
An appliance is considered chronically leaking when its leak rates are over 125% of its full charge for 12 months. Once an appliance meets these criteria, it must be reported to the EPA. This report must describe actions to identify leaks and repair them. It must be submitted by March 1 of the subsequent year.
The 2016 update to EPA 608
On November 18, 2016, the EPA issued a final rule that updated Section 608. It kept most regulations mentioned above in place or put them in place for the first time, making sure that these elements of commercial refrigeration and industrial processes would be continuously monitored. It made a few additional key updates as well.
One of the major updates was extending the requirements of the refrigerant management program to cover substitute refrigerants, such as HFCs. Furthermore, it extended sales restrictions to HFCs and other non-exempt substitutes.
Record-keeping requirements were also updated. Now, technicians need to keep a record of refrigerant recovered during system disposal from systems with a charge size from 5-50lbs.
In 2020, the EPA took part in further rulemaking around Section 608. Most of this meant rescinding past rules and making new exceptions that were previously overlooked.
The rulemaking rescinded the extension of leak repair provisions to appliances using substitute refrigerants. It also determined that appliances with 50 or more pounds of substitute refrigerants are no longer subject to the following rules:
- Repairing appliances that leak above a certain level and conducting verification repairs
- Periodically inspecting for leaks
- Reporting chronically leaking appliances to the EPA
- Retrofitting or retiring appliances that are not repaired
- Maintaining related records
Refrigerant management provisions
The EPA made it clear, though, that these new rules did not affect other refrigerant management provisions, including:
- Anyone purchasing refrigerant for use in a stationary appliance or handling refrigerants must be section 608 certified
- When removing refrigerant from an appliance, a technician must evacuate refrigerant to a set level using certified refrigerant recovery equipment before servicing or disposing of the appliance
- The final disposer of small appliances must ensure and document that refrigerant is recovered
- All used refrigerant must be reclaimed to industry purity standards before it can be sold to another appliance owner
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How does Trakref help?
Scope 1 emissions reporting, ESG reporting in general, or social cause reporting are becoming more top-of-mind for companies, but it’s not fully there yet. Companies don’t know how to do it properly, and it falls into poorly-managed, poorly-contextualized processes that use old tech.
Ideally, what you want from any refrigerant management and Scope 1 emission reporting tool is:
- A way to see and understand the data
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There are more bells and whistles that help out, but those are the core things you need to effectively report Scope 1 emissions.
Here’s what Trakref can do:
Refrigerant tracking: Trakref provides a centralized platform for tracking refrigerant use across an organization. This includes tracking the amount of refrigerant used, refrigerant charge, air conditioning, liquid refrigerant, the location of each refrigerant-containing device, and the dates of any maintenance or service activities. By tracking refrigerant use in this way, Trakref can help organizations identify opportunities to reduce their refrigerant use and associated emissions. Think of us as your refrigerant charge BFF. We handle everything about the terms and conditions associated with refrigerant charge. We know all the regulations and protocols that are impacting refrigerant charge calculations in each area, and we bake that into our systems so that you don’t need to worry about it. You can focus on operations.
Emissions calculations: Trakref can calculate an organization’s refrigerant-related emissions based on the type and amount of refrigerant used, as well as other factors such as equipment age and efficiency. These emissions can then be reported as part of the organization’s overall Scope 1 emissions.
Leak detection: Refrigerant leaks are a common source of emissions in many organizations. Trakref can help organizations detect and address refrigerant leaks quickly, reducing the amount of emissions released into the atmosphere.
Compliance tracking: Trakref can help organizations stay compliant with regulations related to refrigerant use and emissions, such as the Environmental Protection Agency’s (EPA) Refrigerant Management Program. By staying compliant with these regulations, organizations can avoid fines and penalties and demonstrate their commitment to sustainability and environmental responsibility. You can do this while keeping the air conditioning on, which is going to please your people.
Reporting: Trakref provides a range of reporting capabilities, including reports on refrigerant use, emissions, leak rates, and compliance. These reports can be used to inform decision-making and to demonstrate progress in reducing emissions and improving environmental performance.
Overall, Trakref can be an important tool for organizations looking to manage their Scope 1 emissions related to refrigerant use. By providing a centralized platform for tracking refrigerant use, detecting leaks, and calculating emissions, Trakref can help organizations reduce their environmental impact and meet their ESG goals.
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Managing and developing ESG and EHS content for Trakref since early 2023.