On January 1, 2019, new regulations that have been at the center of a recent review by the EPA, will go into effect.
The EPA has confirmed that they will not be making changes to the rules before the end of the year, so it’s time to understand the requirements and plan to understand what is required. Here are the three most significant changes:
1. New - HVAC/R Maintenance
The EPA refrigerant management regulations categorize HVAC/R appliances into four main categories: industrial process refrigeration (IPR), commercial refrigeration, comfort cooling, and other.
The category your appliance falls under determines the applicable leak rate threshold. Also, be aware of knowing how much refrigerant is in all your systems.
2. New - Refrigerant Leak Rates
Refrigerant Leak Rate Thresholds in 2019
Industrial Process Refrigeration: 30% (cooling things in production)
Commercial Refrigeration: 20% (cooling food)
Comfort Cooling: 10% (Cooling people)
Other: 10% (anything else, like data centers,
Before you think these are small changes, realize that if one of your appliances surpasses the threshold, then you are subject to mandatory leak inspections.
Mandatory Leak Inspection Requirements
Commercial Refrigeration and IPR Systems (Federal)
With 500 or more pounds of full charge: Once every three months until you can demonstrate through leak rate calculations that the leak rate has not exceeded the applicable limit for four quarters in a row.
With 50 or more pounds but less than 500 pounds of full charge: Once per calendar year until you can demonstrate through leak rate calculations that the leak rate has not exceeded the applicable limit for one year.
Comfort Cooling and Other Systems
With 50 or more pounds of full charge: Once per calendar year until you can demonstrate through leak rate calculations that the leak rate has not exceeded 10% for one year.
3. New – Reporting & Record Keeping
Although most attention is being paid to medium and large systems, the new regulations affect all systems down to the smallest system, because now you will have to keep records on when you dispose of any system and keep a record of where the refrigerant went. Just saying that the salvage company took your AC unit away won’t be enough, the AC company will now have to provide you with documentation and records on how much and what they took – you need to keep these records for three years.
What to Do About the Changes in 4 Steps
To comply with these changes to the refrigerant management regulations, begin with these three steps:
1. Track your activity.
Know who is working on which appliance(s) and what is going where. Also, Make sure to collect all the dates needed for each service event (Regulations clearly define the dates and requirements)
For example, it's important to know how much refrigerant is being used and/or added to your equipment for each service event. And if all the steps to perform proper maintenance were completed, we can no longer follow the “fix it & forget about it” maintenance process
2. Conduct periodic reviews of your systems.
The frequency of these reviews depends upon the size of the systems; the following Best Practice is recommended:
Large systems (which contain 500 lbs. of refrigerant or more) — Conduct Quarterly reviews. But keep in mind that a large system in most of the country follows the federal regulation which is classified as 500 Lbs and larger, but in California, a large system is 2000 Lbs and larger.
(Note: In the state of California, an automatic leak detection system is required for large systems if (1) the refrigerant circuit is located entirely within an enclosed building or structure, or (2) The compressor, evaporator, condenser, or any other component of the refrigeration system(s) with a high potential for a refrigerant leak is located inside an enclosed building or structure. § 95385.)
Medium systems – Conduct quarterly reviews. How a medium sized system is categorized varies depending on where you are located, the federal definition is 50-499 lbs. of refrigerant in a system. (California small systems contain 200 lbs but less than 2,000 lbs of refrigerant). * (*Note: Required in California)
Smaller systems – Conduct Yearly Reviews. Again, here, the definition of a small system at the federal system is between 5-50 Lbs of refrigerant – and is commonly referred to as the “5 to 50 Lbs class” (which contain more than 50 lbs. but less than 200 lbs of refrigerant Required in California)
3. Report your refrigerant leak rates accurately & Document the results.
What are the leak rates of your HVAC systems? Knowing the answer to this question is critical for you to comply with the 2019 refrigerant leak rate changes.
Unsure of how to calculate your leak rate? We're here to help you achieve refrigerant compliance. That's why we offer you a free refrigerant leak projection to just how much money and energy you're wasting from leaks.
4. Perform the Required Maintenance.
Primarily this relates to leak Inspections and follow up service, and it can start easily once you know your equipment size (based on refrigerant) & type. So, start with an inventory and then keep in mind that the system charge is not just a nameplate, but in many cases it is also the inside unit, the outside unit and the lines that connect them – a rule of thumb is that if the unit has an inside and outside system that the nameplate is about 40% of the full charge. Even sending a piece of equipment to scrap is now considered a maintenance action, so have a plan for this process as well.
You now have less than two weeks to prepare for changes in your HVAC/R documentation, maintenance and planning strategy over the last year we have been providing resources and guides to help get you started.
These four steps are a great place to start.
If you have any questions about the new EPA refrigerant management regulations, please feel free to give us a call at (888) 834-0233, send us an email, or connect with us directly through our live chat window in trakref.com
Want a fast and easy way to refresh yourself on the all the major requirements in the EPA 608 Update? Check out our free presentation slides:
(In these free slides, find out what the EPA 608 Update requires of you!)