What are EPA Refrigerant Regulations 2019 and Now?
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 recordkeeping, leak rate calculations, equipment leak thresholds, timelines to repair leaks, retrofit and retirement timelines, mandatory leak inspection requirements, and reporting for chronically leaking appliances. 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.
Trakref is always staying on top of the latest for our software – we want our users to feel comfortable knowing that as they are using our product, they are compliant. We wanted to share our knowledge about leak rate information and other Section 608 information with you – so here’s our latest dive into it.
Compliance Still Matters
Before we delve into Section 608 regulations, though, you might be thinking – shouldn’t we be more focused on ESG elements, such as reducing emissions from refrigeration and industrial process, as well as working to phase out ozone depleting refrigerants? It is true that ESG is the latest talking point in the HVAC/R industry, but compliance still matters.
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.
Section 608 – Basic Regulations
Section 608 defines recordkeeping, 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 recordkeeping for commercial refrigeration equipment. These records must be kept for 3 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
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.
Chronically Leaking Appliances
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.
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.
Recordkeeping 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
Trakref Helps with EPA Refrigerant Regulations
Keeping track of all the regulations you need to follow can be difficult, even for the most organized facilities manager. Using spreadsheets and basic logs is no longer enough – to stay on top of Section 608 and other refrigerant management regulations, you need a sophisticated rules engine.
This is where Trakref comes in. We have stayed on top of Section 608 since our founding, and make sure that our software easily guides technicians and managers through regulations. We know that reducing leak rates and better managing assets for environmental sustainability requires being able to follow regulations without needing to memorize every step.
Trakref also wants to make sure that you have the right ESG information in your hands. This is where our Scope 1 emissions module comes in. It was built to bridge the gap between compliance regulations, like Section 608, and sustainability. As technicians work in the field, making sure that they are staying compliant with EPA refrigerant regulations, executives in the C-suite can pull information about Scope 1 emissions. It makes sure the building blocks are in place for more advanced analysis that is needed for investors and other stakeholders.
If you want an easy-to-access document of these regulations, download our EPA refrigerant regulations handout.
Gavin is the Lead Writer at Trakref.