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SNAP! – It’s Out With the Old and In With the New 

The refrigerant rules are in an ongoing state of change as new legislation becomes effective and the list of acceptable substitutes is ever-evolving under the Significant New Alternatives Policy (SNAP).

Section 612 of the Clean Air Act (CAA) authorizes the SNAP program, which does not simply provide a static list of alternatives. Instead, EPA evaluates the environmental and human health impacts of proposed substitutes in an effort to maintain viable refrigerant options that pose less overall risk to human health and the environment. Section 612 goes on to require that EPA prohibit the use of a substitute if there is another substitute available that is more beneficial in terms of overall risk.

The EPA has also approved changes to Section 608 regulations on Refrigerant Management Requirements regarding leak repair and recordkeeping, that went into effect January 1, 2017. The rule updates strengthen:

  • Leak repair requirements
  • Recordkeeping requirements for disposal of certain appliances
  • Revisions to technician certification.

It also extends requirements to certain non-ozone depleting substitute refrigerants, such as hydrofluorocarbons.

While the alternative refrigerants often have a lower global warming potential, the safety requirements that accompany their use may be quite different than the refrigerants commonly in use now.

In light of all these changes, end-users need to begin their evaluation efforts now in order to determine how their existing programs and policies will need to be revised to accommodate the significant changes in the future purchase, use, management, and disposal of refrigerants.

Do the New Rules Apply to Me?

The number of individuals or industries potentially affected by the updated regulations is quite large.

Those who own, operate, maintain, service, repair, recycle or dispose of refrigeration and air-conditioning appliances and refrigerants need to be aware of the new regulations. Also those entities that manufacture or sell refrigerants, products or services for the refrigeration and air-conditioning industry may be affected.

For a list of Potentially Affected Entities by Category or NAICS code, click here.

What Impact Will Proposed Changes to Section 608 Have on Refrigerant Management?

A number of changes to the National Recycling and Emission Reduction Program are proposed.

Industry proposed ‘best practices’ are defined, including:

  1. Lowering the leak rate threshold above which owner/operators of refrigeration and air-conditioning equipment normally containing 50+ lbs. of refrigerant must repair leaks:
  2. lower from 35% to 30% for industrial process refrigeration (IPR)
  3. lower from 35% to 20% for commercial refrigeration equipment, and
  4. lower from 15% to 10% for comfort cooling equipment
  5. Quarterly or annual leak inspections only for appliances that have exceeded the applicable leak rate. Owners or operators can forgo leak inspections if they install, continuously operate, and maintain automatic leak detection systems.
  6. Owners or operators of appliances that leak 125 percent of their full charge in a calendar year must submit a report to EPA detailing their repair efforts. The report must be submitted no later than March 1 following the calendar year of the ≥125 percent leak.
  7. Non-exempt substitute refrigerants may only be sold to technicians certified under sections 608 or 609 of the Clean Air Act.
  8. In the case of MVAC refrigerant, EPA is exempting the sale of small cans of non-ODS substitutes to allow the do-it-yourself (DIY) community to continue servicing their personal vehicles.
  9. EPA is requiring that small cans of non-exempt substitute refrigerant be outfitted with self-sealing valves by January 1, 2018.
  10. Requiring technicians to keep certain records during system disposal from systems with a charge size from 5–50 lbs.
  11. Records include the company name, location of the appliance, date of recovery, and type of refrigerant recovered for each appliance.
  12. Instead of finalizing the proposed requirement to keep records indicating the amount of refrigerant recovered from each appliance, EPA is finalizing a requirement to record the total amount of refrigerant, by type, recovered from all appliances disposed of over a calendar month.
  13. Extending the requirements of the Refrigerant Management Program to cover substitute refrigerants, such as 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.

Servicing Air Conditioning Systems Under Section 608

Under Section 608, there are numerous requirements to ensure proper servicing of air conditioning systems to maximize the recovery and recycling of ozone-depleting substances (ODS). A brief snapshot of some of the requirements include:

  1. Section 608 certification in order to service refrigeration and air-conditioning equipment containing HCFCs.
  2. As a best practice, locate and repair leaks instead of “topping-off” leaking systems.
  3. Intentional release of any refrigerant when servicing, repairing, or maintaining equipment is an illegal act.
  4. In most cases, refrigerant recovery equipment must be used during service, maintenance, or repair.
  5. Written certification to your EPA Regional Office that EPA-certified refrigerant recovery and recycling equipment is and will be properly used.
  6. In some cases, it is permissible to recharge equipment with recovered HCFC refrigerants.
  7. If the refrigerant is being charged back into the same appliance or to another appliance owned by the same person, the used refrigerant does not need to be recycled or reclaimed.
  8. Recovered refrigerant cannot be sold to a new owner; instead, it must be sent to an EPA-certified reclaimer prior to sale.

The main regulatory requirements for Section 608 are outlined below in a graphic available from the EPA website at Section 608 Regulatory Requirements Summary.

What Do Section 612 and EPA’s SNAP Program Mean to Me? 

EPA uses a comparative risk framework to review substitutes used in the following industrial sectors:

The program is designed to:

  • Look for substitutes for historically-used ODS
  • Evaluate the overall risk of both existing and new substitutes
  • Keep the public informed about potential environmental and human health impacts of substitutes.

In evaluating proposed substitutes, EPA considers ozone depleting potential, global warming potential, toxicity, flammability, occupational/consumer health and safety as well as air quality and ecosystem impacts.

The SNAP Effect of HCFC-22 and HCFC-142b Phase-out

The EPA phase-out of commonly used HCFC-22 refrigerant (also known as R-22) looms on the horizon, in spite of the fact that it remains in use in more than 50% of the air conditioning and refrigeration equipment in the United States. However, as of 2020, the manufacture or import R-22 in this country will be illegal.

Phase-out of HCFC-22, most often used in air-conditioning and refrigeration equipment, is accompanied by the phase-out of HCFC-142b, also a refrigerant but used as well for foam blowing or as a propellant in aerosol cans. These two HCFCs are being phased out according to the following schedule:

  • January 1, 2010 - Ban on production, import and use of HCFC-22 and HCFC-142b except for on-going servicing needs of existing equipment
  • January 1, 2020 - Ban on remaining production and import of HCFC-22 and HCFC-142b
  • After 2020, the servicing of systems that use R-22 or blends containing HCFC-22 or HCFC-142b will rely on recovered or stockpiled quantities.

The following Frequently Asked Questions from EPA’s website can provide direction as businesses and technicians evaluate their responsibilities during the phaseout of ODS.

Commercial Refrigeration and Air Conditioning Equipment: Frequently Asked Questions

Am I allowed to continue using equipment that contains hydrochlorofluorocarbon HCFC-22 (also known as R-22)?
Yes.

If I expand an existing HCFC-22 system can I continue to use virgin HCFC-22?
No. Virgin HCFC-22 may not be used in a system that is expanded to increase its cooling capacity. EPA presumes expanded systems to be new systems, and new systems may not use virgin HCFC-22 (or R-22). Only reclaimed or recovered HCFC-22, or an alternative refrigerant, may be used.

More on this concept is covered in a Q & A developed for supermarkets.

How can I ensure that HCFC-22 supplies will be adequate to meet my future needs?
Establish a plan for your company to repair or replace leaking equipment and to recover and reuse the refrigerant from equipment that is discarded. Your company can store recovered HCFC-22 to service any equipment you own.

Reclaimed refrigerant also is available and may continue to be used after the production and import phaseout in 2020. Both new and reclaimed HCFC-22 is likely to increase in price, however, as existing supplies are used up.

When should I convert my company's equipment to an alternative refrigerant?
Many businesses have already transitioned to alternative refrigerants.

Even though there is no immediate need to change, HCFC-22 supply will decline and prices may rise. When you transition, you have three choices:

  1. Convert your existing system
  2. Buy a new one, or
  3. Continue to operate your existing system.

If you choose to convert, confirm with your equipment supplier that the system is retrofitted to use an ozone-friendly, SNAP-approved refrigerant, and that all system components are compatible with the new refrigerant. Buying a new, more efficient system may require more money initially, but may reduce your electricity bill and save money over time. If you choose to continue to operate your existing system, be sure to identify and repair leaks quickly.

Technicians and Contractors: Frequently Asked Questions

SNAP Refrigerant RulesCan existing equipment containing HCFC-22 still be serviced?
Yes, HCFC-22 (also called R-22) can be used to service existing equipment. Servicing includes replacing failed components.

When will HCFC-22 (or blends that contain HCFC-22 and/or HCFC-142b) no longer be available for purchase?
The production and import of HCFC-22 has been restricted since 2010, and will cease in 2020. EPA expects that reclaimed and previously-produced HCFC-22 will be available well after 2020 to service and maintain equipment, but the price and availability may change. EPA anticipates that supplies should allow for a smooth transition to alternative refrigerants. Technicians should properly recover and reclaim HCFC-22 from existing refrigeration and air-conditioning equipment to help ensure the availability of supplies. Keep in mind that recovered refrigerant cannot be sold to a new owner for use as a refrigerant unless it has been reclaimed by an EPA-certified reclaimer prior to sale.

What alternatives to HCFC-22 are acceptable and available?
EPA maintains a list of acceptable substitutes for use in the refrigeration and air-conditioning sector. To help technicians decide which alternatives are most appropriate for specific uses, EPA developed a list of questions to ask before purchasing alternative refrigerants. If substitutes are used in retrofitted equipment, technicians should be trained on proper retrofit installation and servicing techniques. Note that some alternatives are not allowed in retrofits.

Are there any restrictions on the purchase of hydrofluorocarbon (HFC) refrigerants?
Not at this time. But, while HFCs are not ozone-depleting substances, they are potent greenhouse gases that contribute to climate change.

Are there any limitations on the use of HFC refrigerants?
Yes, only specific HFC refrigerants are acceptable substitutes for different end uses. EPA’s SNAP program maintains a list of acceptable refrigerant substitutes. It is also illegal to knowingly vent or release these refrigerants— just as it is for ozone-depleting refrigerants like HCFC-22.

Is EPA technician certification required to service systems that use HFCs?
No, at this time EPA technician certification (EPA Section 608 certification) is not required in order to service stationary refrigeration and air-conditioning systems containing HFCs. However, EPA plans to propose extending the technician certification requirement to cover the use and purchase of HFCs.

A complete listing of Technician and Contractor FAQs can be found at:

https://www.epa.gov/ods-phaseout/technicians-and-contractors-frequently-asked-questions.

Questions or Need Help?

Give us a call at (512) 301-1451 and we’ll be happy to assist in answering your questions.

Additional Useful Links and Guidance –

Industrial Process Refrigeration and the Phaseout of HCFC-22 What You Need to Know –

 

 

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