Updates to the Section 608 Refrigerant Management Program

Updates to the Section 608 Refrigerant Management Program

Updates to the Section 608 Refrigerant Management Program National Refrigerant Management Program Technician Certification Refrigerant Reclamatio n Refrigerant Sales Restriction Appliance

Disposal Service Practices Repairing Refrigerant Leaks Recovery & Recycling Equipment Recordkeeping National Refrigerant Management Program What refrigerants are affected? Ozone-depleting refrigerants (i.e., CFCs and HCFCs)

Currently subject to the Section 608(c) venting prohibition Currently subject to the existing regulatory standards and requirements Substitute refrigerants (e.g., HFCs, HFOs, and PFCs) Includes any substitute refrigerant not specifically exempted* Currently subject to the Section 608(c) venting prohibition Will be subject to the regulatory standards and requirements starting 2017, 2018, or 2019 Exempt substitute refrigerants (e.g., ammonia and CO2) Not subject to the venting prohibition in specific end-uses Not subject to the regulatory standards and requirements in those uses May be subject to other requirements (e.g., OSHA) *While these slides highlight appliances containing HFCs, appliances containing other non-exempt substitute refrigerants, including HFOs and HFO blends, are subject to the same requirements. Changes to

Technician Certification You must be a Section 608 certified technician to open HFC appliances (Starting 1/1/18) R-134a, 410a EPA is not requiring recertification of current technicians at this time EPA is not changing the types of certifications EPA is developing an updated test bank for certifying new technicians You must be a Section 608 certified technician to purchase HFC refrigerant (Starting 1/1/18) Refrigerant distributors may only sell HFC refrigerants to certified technicians and must maintain records for those sales (Starting 1/1/18) Throughout this presentation, the term HFC is being used to represent all non-exempt substitutes. Changes to Service Practices

Technicians must use certified recovery and/or recycling equipment when opening an HFC appliance (Starting 1/1/18) Technicians must evacuate to the specified levels of vacuum when opening HFC appliances (Starting 1/1/18) Newly manufactured or imported recovery and/or recycling equipment models must be certified for use with HFCs (Starting 1/1/17) EPA is adopting a UL flammability standard as part of the certification to ensure the safe use of recovery equipment designed for flammable refrigerants (Starting 1/1/17) Changes to Leak Repair Leak Rates and Duty to Repair Starting 1/1/2019, these modified leak repair requirements will apply to all refrigerants (excluding exempt refrigerants cited earlier)

The existing leak repair requirements will continue as is for ODS appliances until 1/1/19 The leak rate must be calculated every time refrigerant is added to an appliance containing 50 lbs. of refrigerant The repair requirements described on the following slides apply starting January 1, 2019, only if over the threshold Changes to Leak Repair Leak Rates and Duty to Repair (Cont) Revised leak rate thresholds: 30% for Industrial Process Refrigeration (IPR) (lowered from 35%) 20% for commercial refrigeration (lowered from 35%) 10% for comfort cooling (lowered from 15%) A certified technician must perform a leak inspection to identify the necessary repairs

The repair must bring the appliance leak rate below the threshold Must be demonstrated when calculating leak rate upon next refrigerant addition Changes to Leak Repair Verification tests Must demonstrate that leaks were successfully repaired Initial verification tests- done before refrigerant is added back into the repaired appliance Follow-up verification tests- done after the repaired appliance returns to normal operating characteristics and conditions Requirement extended to commercial refrigeration and comfort cooling (currently required only for IPR) If either the initial or follow-up verification test indicates that repairs were not successful, you may conduct as

many additional repairs and verification tests as needed within the 30-day repair period Changes to Leak Repair Definition of Appliance: Clarifies that each independent circuit in a system with multiple circuits is a separate appliance Leak rate calculations: Provides that under the Rolling Average Method (formerly Method 2) in order to close out a leak event the owner or operator must repair all identified leaks and verify that the repairs have been successful. Recordkeeping: Technicians must provide owners and operators with invoices (including amount of refrigerant added), and results of leak inspections and verification tests

Electronic recordkeeping encouraged Changes to Appliance Disposal Appliances with 5 pounds of refrigerant or less Existing safe disposal requirements extended to HFC appliances (Starting 1/1/18) Appliances with between 5 and 50 pounds of refrigerant New records for the disposal of appliances containing between 5 and 50 pounds of refrigerant (Starting 1/1/18) Company name, location of the appliance, date of recovery, and type of refrigerant recovered for each appliance; Amount of refrigerant (by type) recovered from all disposed appliances in each calendar month; and Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the person to whom it was transferred, and the date.

These records must be maintained by the technician and not the owner or operator of the appliance Changes to Reclamation EPA is establishing reclamation standards for HFCs and other refrigerants contained in AHRI Standard 700-2016 (Starting 1/1/17) Reclaimers must analyze each batch of reclaimed refrigerant (Starting 1/1/17) Annual reporting to EPA on amounts of refrigerant received and reclaimed includes HFCs (Starting 2018, for refrigerant received starting 1/1/17) Outcomes of 608 Update Consistent treatment of commonly used refrigerants (e.g., ODS, HFCs, blends) Incorporating best management practices to reduce leaks

from large appliances Focus on ensuring repairs are effective Enhancing clarity of the rules to improve compliance Removing obsolete requirements Outcomes of 608 Update By promoting the proper handling of refrigerants, EPA anticipates: Annual GHG Reduction (MMTCO2eq) Annual ODS Reduction (ODP-weighted MT) Annual Incremental

Compliance Cost (millions) 7.3 114 $24.5 The annual GHG emissions reduction is equivalent to the annual GHG emissions of 1.5 million cars EPA estimates $44 million in savings from reduced purchases of refrigerant GHG: Greenhouse gas MMTCO2eq: Million metric tons carbon dioxide equivalent ODP: Ozone depletion potential MT: Metric tons

Flammable Refrigerants EPA has exempted certain hydrocarbon refrigerants from the venting prohibition when used in specific appliances and, as a consequence, the Section 608 requirements These are new, self-contained, small appliances specifically designed to use hydrocarbon refrigerants EPA does not anticipate that opening up such appliances for servicing or recharging will be common Such appliances are identifiable by red tubing and other markings It is illegal to use hydrocarbon or other flammable refrigerants (such as R-22a) in existing HCFC/HFC appliances

This is true whether the refrigerant is sold to a certified technician or not Some flammable refrigerants are not exempt from the Section 608 requirements (such as HFC-32) and may only be purchased by a certified technician Recovery and/or recycling equipment for use with such flammable refrigerants must be certified to ensure safety for those refrigerants Reporting on all appliances greater than 5 pounds Technicians are now responsible and held accountable Contractors (including scrapers) must collect data and must be able to report monthly

YOUR IMPACT Scrapers must provide make, model, serial number or ID to the service technician for all removed equipment. Wholesalers must provide docs for all recovery cylinders to contractors who must tie each pound back their recovery. Reclaimers must provide documentation down the chain Every Rapid Recovery Tech is EPA Certified. All Rapid Recovery proprietary recovery equipment is already certified for HFCs as well as CFCs and HCFCs. Rapid Recovery documentation exceeds all EPA

requirements. Rapid Recovery does not recover hydrocarbon or other flammable refrigerants (such as 22a). The use of these refrigerants in existing Type II HCFC/HFC appliances is illegal. Rapid Recovery is the solution to this Contractor and Technician challenge. From recovery to documentation, we address it all. OUR IMPACT STAY IN COMPLIANCE WITH RAPID RECOVERY 877.372.7732 |

www.raprec.com

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