Changes to the Refrigerant Recycling and Emissions Reduction Rule

On Friday, November 18, 2016, the final revisions to 40 CFR Part 82, Subpart F, Recycling and Emissions Reduction were published in the Federal Register.  As noted in our October 2015 blog, U.S. EPA continues to reassess its Ozone Depleting Substances (ODS) regulations, proposing revisions to the rule in both December 2010 and November 2015.  The final rule will be effective on January 1, 2017 and incorporates the November 2015 changes as well as several additional revisions.  Per the November 2015 revisions, the rule updates and extends existing requirements, as appropriate, to non-ozone depleting substitute refrigerants [i.e., hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and hydrofluoroolefins (HFOs)].  The rule also establishes new recordkeeping requirements for the disposal of appliances containing five to 50 pounds of refrigerant. 

There were several notable changes to the final rule compared to the version proposed in November 2015.  The new revisions include (but are not limited to):

• Revising leak rates [i.e., 30% for industrial process refrigeration (IPR), 20% for commercial refrigeration appliances, and 10% for comfort cooling and other appliances];
• Reporting requirements for exceeding 125% of the leak limit for systems containing 50 pounds or more of refrigerant;
• Annual/quarterly leak inspection only if a leak rate has been exceeded in the absence of an automatic leak detection system; and
• Changes to the leak rate calculation methodology. 

Following these changes and interpreting the new requirements that may apply to your appliance(s) is more difficult compared to the original rule.  Wondering how the final revisions to 40 CFR Part 82, Subpart F will affect your Facility?  Give me a call at (610) 933-5246 (ext. 135) or send an email to cgiannascoli@all4inc.com.