EPA’s new rules change Air Conditioning Refrigerant

With environmental consciousness becoming the watchword of the new millennium, the Environmental Protection Agency (EPA) has taken the leadership in protecting our surroundings from harmful chemicals. Accordingly, the EPA has formulated regulations under the aegis of Section 608 of the Clean Air Act of 1990 that make it mandatory for every establishment that has an air conditioning system to have a refrigerant monitoring and recovery plan in place to register any leakage of harmful gases, and recover them for reuse.

As per the rules, all owners of air conditioning equipment containing more than 50 lbs. of refrigerant need to establish and maintain detailed records of all refrigerant usage and any service work performed, even if contractors are used. Also, maximum leak rates have also been revised downward on systems installed after 1992. Additionally, owners must either repair leaks within 30 days from the date the of discovery or develop a dated retrofit-retirement plan within 39 days and complete actions under that plan within one year from the plan's date.

The regulations also lay great stress on how air conditioning systems are serviced. The main goal is reducing the emissions to the lowest achievable level. An effective recycling program is important to conserve the existing supply of refrigerant and prevent its release to the atmosphere. It is illegal to dispense refrigerant into the air during servicing, with recovery being encouraged to recycle, reclaim, or properly destroy HCFCs in the refrigerant. New EPA regulations mandate facilities to monitor and track recovery rates, either automatically through specialized hardware and software, or manually.

The personnel and equipment performing maintenance and recovery of refrigerant must be properly certified. The equipment must be tested and certified as able to recover refrigerant at legal levels by either the Air-Conditioning, Heating, and Refrigeration Institute or by Underwriters Laboratories. Maintenance personnel must have at least one of the four types of Section 608 certification that apply to different refrigerant handling work - Type I, Type II, Type III or Universal. Moreover, all involved parties must maintain and present records of their certification and handling of refrigerant during all phases of the recovery process.

The latest regulations target the content of the refrigerant itself. Use of refrigerants having hydrochlorofluorocarbons (HCFC) has been severely restricted and will be completely phased out by 2020. As of 1 January 2010, equipment manufacturers are no longer allowed to produce new system components that use HCFCs. The two new rules laid out by the EPA specify the following:

* One rule allocates allowances for the production and import of HCFCs.
* The other rule bans the sale or distribution (including import and export) of pre-charged air-conditioning and refrigeration products and components containing HCFCs.

During the transition period to 2020, owners using air conditioning units having HCFC refrigerants have three options:

(1) convert the existing system,
(2) buy a new system, or
(3) continue to operate the existing system.

For the first option, the owner must confirm with his equipment supplier that the system is retrofitted to use an ozone-friendly refrigerant and that all components are compatible with the new refrigerant. Buying a new, more efficient system may require more money initially, but will reduce electricity consumption and save money over time. If the third option is chosen to continue to operate the existing system, the owner should ensure that leaks are repaired quickly.

Note: The entire text of the Clean Air Act is available online at http://www.law.cornell.edu/uscode/html/uscode42/usc_sec_42_00007671---g000-.html

More information on the 2010 HCFC rules can be found at http://www.epa.gov/ozone/title6/phaseout/rulesoverview.html.

Nowadays, surprise inspections are conducted routinely by the EPA to ensure compliance. Failure to comply can result in fines up to $27,500 per day per violation. Submission of false or misleading information may result in criminal penalties, including imprisonment.

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