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Proposed Revisions to Ozone Depleting Substances RULE (40 CFR PART 82)

Overview

In a proposed rule issued on November 2, 2015, USEPA announced its intent to make sweeping changes to the underlying regulations which govern the recycling and emission reduction requirements for commercial, industrial and comfort cooling refrigerants (40 CFR Part 82, Subpart F). The proposed rule affects all facilities across the US that use refrigerants anywhere in their facilities or campuses, including some of those who are not currently required to be regulated under this law. The proposed rule, if promulgated, will cause owners to adhere to the monitoring, repair and documentation requirements of Part 82, as well as employ certified technicians (as define by Part 82) to work on their equipment, regardless of the type of refrigerant being used.

The Clean Air Act, specifically §608(c), prohibits the knowing release of ozone-depleting and substitute refrigerants during the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration. Existing regulations under Subpart F require that persons servicing or disposing of air-conditioning and refrigeration equipment observe certain service practices that reduce emissions of ozone-depleting refrigerants. This proposed rule would update those existing requirements as well as extend them to non-ozone-depleting substitute refrigerants, such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). In addition to expanding the list of substances addressed under this regulatory program, the proposed changes also seek to strengthen the existing program by incorporating more stringent applicability thresholds and incorporating certain industry best practices for a wider range of appliances, as summarized below.

Summary of Proposed Major Changes

Among the more prominent changes proposed by USEPA are:

  • Expanding the definition of refrigerant to include non-exempt, non-ozone-depleting substitute refrigerants (substitutes), in addition to previously-regulated class 1 and class 2 ozone-depleting substances (ODS) and clarification of the requirements of the de minimis exemption as it applies to both ODS and substitutes.
  • Reduction of allowable leak rates between repair events:
    • From 35 percent to 20 percent for commercial refrigeration appliances and industrial process refrigeration
    • From 15 percent to 10 percent for comfort cooling appliances.
  • Implementation of a two-year leak limit, which would restrict appliances containing 50 or more pounds of ODS or substitute refrigerant from leaking more than 75 percent of the appliance’s full charge in each of two consecutive 12-month periods. This restriction will “encourage owners or operators of appliances to more comprehensively repair or retire them when leaking such a substantial amount of refrigerant for two consecutive years.”
  • Requirement to conduct leak inspections annually for appliances with a full charge of 50 or more pounds and quarterly for appliances with a charge of 500 or more pounds. Leak inspections can be avoided by installing automated leak detection systems.
  • The remaining proposed changes to the rule would establish recordkeeping requirements for the disposal of appliances containing five to 50 pounds of refrigerant, extend sales restrictions to substitute refrigerants, and update the technician certification program.

Contact:
Matt Traister
Matt.Traister@obg.com
(315) 569-7882



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