Managing Ozone-depleting Substances in Refrigerating Appliances

Posted on 5/10/2016 by Scott Dunsmore

One critical component of US EPA’s Clean Air Act regulations for stratospheric ozone protection is the rules that address maintenance, service, repair, and disposal of appliances that contain ozone-depleting substances (ODS) and their substitutes. [40 CFR 82, Subpart F] They cover appliances like commercial or residential refrigerators, air conditioners, chillers, and freezers.

Class I and Class II Ozone-depleting Substances

ODS are any substances identified on either the Class I List at 40 CFR 82, Appendix A or Class II List at 40 CFR 82, Appendix B. Class I ODS include numerous chlorinated fluorocarbon substances (CFC), halon, carbon tetrachloride, methyl chloroform, methyl bromide, and other brominated compounds. Class II ODS includes 38 hydro chlorofluorocarbons (HCFC).

Objective of the 40 CFR, Subpart F Standard

In general, the goal of the 40 CFR 82, Subpart F requirements are to prevent the release (knowingly or otherwise) of the regulated substances from the appliance. While most of the standard focuses on the persons performing service, maintenance, and repair (i.e., technicians) and the equipment they use, there are also some administrative requirements that may apply to the owners or operators of the covered appliances.

Clean Air Act Recordkeeping and Reporting

Unless otherwise indicated by the standard, the required records must be retained by the owner/operator for at least three years. [40 CFR 82.166(m)]

The owners/operators of appliances with 50 lbs. or more must keep service records. The records must include date of service, type of service, and quantity of ODS added [40 CFR 82.166(k)].

In general, covered appliances (e.g., refrigeration systems with > 50 lbs. of ODS) that exceed specified leak rates must have those leaks repaired within 30 days. [40 CFR 82.156(i)] However, there are times when the rules allow for an extension to the repair deadline. When these conditions are satisfied, the owner/operator of the appliance must prepare a report and submit it to the EPA with the content specified at 40 CFR 82.166(n). A copy of the report must be retained by the owner/operator.

Retrofitting Appliances Under 40 CFR 82.156(i) 

Similarly, certain appliances are subject to specific timeframes for retrofilling or retiring under 40 CFR 82.156(i). If the covered system is permitted additional time, the owner/operator must prepare a report and submit it to the EPA with the content specified at 40 CFR 82.166(o). A copy of the report must be retained by the owner/operator.

In addition, there are recordkeeping requirements for owners/operators seeking to exclude certain losses from the leak rate determinations or use alternate methods for full charge determinations. [40 CFR 82.166(p) and (q)]

Changes Coming to Clean Air Act Subpart F

On November 9, 2015, the EPA published a proposed rule that would make changes to the 40 CFR 82, Subpart F requirements. Some of the significant proposed changes include:
  • Requiring annual leak inspections (or continuous monitoring) for systems with 50 lbs. or more of ODS refrigerant.
  • Requiring quarterly leak inspections (or continuous monitoring) for commercial refrigeration or industrial process refrigeration systems with 500 lbs. or more of ODS.
  • Extending the refrigerant management program requirements to cover substitute refrigerants, including hydrofluorocarbons (HFCs).
  • Requiring technicians to keep records of refrigerants recovered during system disposal from systems with charge sizes between 5 and 50 lbs.
  • Prohibiting operation of systems with 50 lbs. or more of ODS that have leaked 75% or more of their full charge for 2 consecutive years.
The final rule is expected in August 2016.

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