The U.S. Environmental Protection Agency (EPA) has released a pre-publication version of a proposal to expand and amend the National Recycling and Emission Reduction Program, also known as the Section 608 program, which governs the handling, use, and sale of ozone-depleting (ODS) compounds used as refrigerants. The proposed changes are intended to reduce the amount of refrigerants (both ODS and non-ODS) that are knowingly vented or released into the atmosphere, update the current technician’s certification program, and enhance enforcement of violations of the venting prohibition.
The proposal would affect the practices and operations of residential and commercial HVACR contractors, distributors, refrigerant reclaimers, and organizations that certify technicians.
Here is a summary of the major changes to the National Recycling and Emission Reduction Program in the proposed rule:
1. Extending the requirements of the Refrigerant Management Program to cover substitute refrigerants, such as hydrofluorocarbons (HFCs). Note that some substitutes have already been exempted from the section 608 venting prohibition as provided for under section 608 in previous EPA rules; such substitutes would also be exempted from the requirements under this proposed rule.
2. Require technicians to keep a record of refrigerant recovered during system disposal from systems with a charge size from 5 to 50 lbs. This would apply to both ODS and non-ODS refrigerants.
3. Lower the leak rate threshold above which owner/operators of refrigeration and air-conditioning equipment normally containing 50+ lbs. of refrigerant must repair leaks as follows:
• lower from 35 percent to 20 percent for industrial process refrigeration (IPR) and commercial refrigeration equipment.
• lower from 15 percent to 10 percent for comfort cooling equipment.
4. Require regular leak inspections or continuous monitoring devices for refrigeration/air conditioning systems as follows:
• annual inspections for systems normally containing 50+ lbs. of refrigerant.
• quarterly inspections for commercial refrigeration and IPR systems normally containing 500+ lbs. of refrigerant.
5. Prohibit operation of systems normally containing 50+ lbs. of refrigerant that have leaked 75 percent or more of their full charge for two consecutive years.
6. Allow the purchase of cans containing two pounds or less of non-ODS refrigerant for motor vehicle air conditioner servicing without technician certification so long as the small cans have a self-sealing valve to reduce refrigerant releases.
7. Require that certifying organizations publish lists or create online databases of technicians that they certify.
8. The EPA will update the technician certification test bank with more questions on handling substitutes, including flammable substitute refrigerants, and on the impacts of climate change.
Once the proposed rule is published in the Federal Register, stakeholders will have 60 calendar days to review and comment. There may be a public hearing on the proposal as well.