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With the new year, a new phase of reductions for refrigeration chemicals came into effect. Any company that has an air conditioner or water chiller that uses hydrochlorofluorocarbons (HCFCs) could be affected.
As part of his regular practice in keeping current on regulations Senior Environmental Engineer, Qaiser Baig confirmed “that the regulations on these chemicals are all Federal. The States don’t really get involved.” Section 608 of the Clean Air Act defines EPA’s responsibilities for protecting and improving the nation’s air quality and the stratospheric ozone layer.
The stratospheric ozone layer shields the Earth from the sun’s harmful ultraviolet radiation. Emissions of certain synthetic chemicals – including chlorofluorocarbons (CFCs), halons, and HCFCs – that are commonly used as refrigerants, solvents, and insulating foams destroy the ozone layer. In addition, many of these ozone-depleting substances, are greenhouse gases that contribute to climate change. The U.S. phased out CFCs in the mid-1990s and the EPA is in the process of phasing in reductions of the HCFCs.
As of January 1, 2020, the EPA placed a complete ban on production and import of HCFC-22 and HCFC-142b. Earlier phases, in 2010 and 2015, had allowed these chemicals to continue to be used for servicing existing equipment. The final stage will come in 2030 when the ban will include all production and import of the remaining types of HCFC chemicals.
Baig also expects a final rule very soon on a refrigerant regulation change that EPA proposed in 2018. It will eliminate EPA’s appliance repair and leak testing requirements for “non-exempt substitute refrigerants”. These requirements will continue to apply to appliance containing at least 50 pounds of “class I” and “class II” refrigerants. EPA has identified some substitutes that are exempt from all requirements for the servicing of appliances containing ozone-depleting substances, including those for repair and leak testing. Other substitutes are “non-exempt”, meaning servicing of appliances containing these substitutes are still subject to the same requirements for the servicing of appliances containing ODS, including those for repair and leak testing.
The proposed rule change, once finalized, will remove the requirements for non-exempt substitutes. Currently, no one may knowingly vent or release any refrigerant (including non-exempt substitutes) from an appliance. If the appliance contains at least 50 pounds of refrigerant, repair person must calculate the leak rate when refrigerant is added or removed. If the rate exceeds the regulated amount, the owner is required to repair the leak and conduct inspections. (40 CFR 82.157(c))
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Qaiser Baig, PE, is a Senior Environmental Engineer for Cornerstone Environmental, Health and Safety. He regularly consults with clients in the area of emissions auditing, air permitting (including Title V, MSOP, FESOP and NSR), monitoring and air permit regulatory compliance as well as facility environmental compliance assessments.
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