California Air Resources Boardâ??s Satapana Buthken talks regulatory changes regarding refrigeration and refrigerants.
California Air Resources Board’s Satapana Buthken talks regulatory changes regarding refrigeration and refrigerants.

As California goes, so goes the rest of the country. That adage has often proven true, especially when it comes to refrigerant- and refrigeration-related regulations. The aggressive environmental and regulatory positions in Sacramento have caused the rest of the U.S. to monitor policymaking and enforcement out West. And, more often than not, those policies have ended up as the blueprint for federal regulations.

Individuals from throughout the U.S., Canada, and several other countries who attended the most recent RSES International Conference in Long Beach, California, heard the latest during a seminar on the Refrigerant Management Program of the California Air Resources Board (CARB).

Large Systems, Inflated GWPs

Satapana Buthken, air resources engineer, CARB, noted regulatory developments related to refrigeration systems that use more than 50 pounds of high-GWP (global warming potential) hydrofluorocarbon (HFC) refrigerant.

“Cold-storage warehouses, distribution facilities, ice rinks, supermarkets, oil/gas production sites, and manufacturing facilities are affected,” he said. “Bars, restaurants, and gas stations are generally not impacted by this rule [due to smaller charges].”

He noted the need for registration of such equipment with the state. Further, technicians at these facilities are required to conduct periodic leak inspections, repair leaks within 14 days of detection, keep records of service and refrigerant transactions, and follow required service practices.

Proper maintenance focuses on the need for an automatic leak detector for larger systems — greater than a 2,000-pound charge — and quarterly leak inspections while medium size systems — 200-1,500 pounds — require quarterly leak inspections and small systems — 50-199 pounds — need annual leak inspections.

He warned service technicians “not to add an additional refrigerant charge to any appliance known to have a refrigerant leak” until the leak is repaired.


The issue of how to enforce such regulations was discussed by Bradley McClung, an inspector for the South Coast Air Quality Management District. He noted that his district is one of 35 such authorities in California monitoring compliance.

Facilities need to register air conditioning systems every two years and refrigeration facilities every year, he said. In addition to aspects noted by Buthken, McClung said managers should consider implementing “retirement” plans for equipment.

Regarding preparation for inspections, he encouraged a verification of the system be performed before any refrigerant is added. Failure to use recovery and recycling equipment is a violation, and manifests should be maintained for transportation and disposal of refrigerants.


Jenna Latt, office of ombudsman, CARB, said, “We [CARB] want to reduce emissions of refrigerants with a high GWP, create a level playing field, and deter future noncompliance. That’s why this sort of regulation is necessary and why it’s enforced.”

The office of ombudsman was created, she said, to help businesses deal with regulatory expectations.

“There are resources, such as permitting assistance, financial assistance, and training courses for those interested,” she said. “Compliance to these regulations will help save money annually on refrigerants, save energy, increase energy efficiency, help reduce greenhouse gas emissions that contribute to climate change, and ensure compliance with the law.”

She also noted the ongoing issue in which the U.S. Environmental Protection Agency (EPA) was proposing to decertify within its Significant New Alternatives Program (SNAP) a number of perceived high-GWP HFC refrigerants, most for refrigeration applications.

She also drew attention to a growing list of what she described as alternative refrigerants with a GWP of less than 150. These included R-744 (carbon dioxide); R-717 (ammonia); and hydrocarbons (HCs) R-290 (propane), R-600a (isobutene), R-1270 (propylene), and R-170 (ethane).

Latt cited a number of considerations when dealing with such refrigerants:

• There is no drop-in, one-size-fits-all solution;

• Carbon dioxide systems — particularly transcritical CO2 systems — are being used more frequently;

• Ammonia is energy efficient and has zero impact on both climate change and the ozone layer, though the toxicity factor should be considered; and

• HC systems are limited to 150 grams. (Editor’s Note: This was at the time of the presentation, but the EPA has been considering raising that limit to 300 grams.)

Publication date: 3/2/2015

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