Many Oppose the EPA’s Proposed Revisions to Section 608 Refrigerant Management Rules

In our last post we discussed the EPA’s recent proposed revisions to the Section 608 Refrigerant Management Rules. These revisions would eliminate requirements for leak repair maintenance in stationary refrigerants and air conditioning equipment containing HFCs. The EPA accepted public comments on these proposed revisions and other possible rule revisions through November 15th, 2018. In total, there were 285 comments submitted through the EPA’s regulations.gov site. Dynatemp International submitted comments asking that the EPA not revise their leak repair provisions or the other possible revisions. A quote from our comments regarding HFC Certification rescission:

 Speaking with many HVAC wholesalers, the HFC certification rescission may have negative impacts on their liability and business. The benefit of certification is that wholesalers are able to sell refrigerants to a technician which has sufficient background and understanding of their liability of the Clean Air Act. Without EPA’s direct enforcement, requiring the wholesaler to verify certification acts as a local check on bad actors willing to buy refrigerants.

You can find our full comments here.

In addition to Dynatemp International’s opposition to the rule revisions, 15 US state Attorney Generals and the District of Columbia sent a letter to the EPA “strongly opposing” it’s proposed rule.

At the HARDI conference, Jeremy Arling, Lead Environmental Protection Specialist at US EPA, indicated that the EPA would release their decision on their proposed rule revisions around the beginning of 2019.  We will keep you informed as new information becomes available.

EPA Sends SNAP Change of Listing Status Rule to Office of Management and Budget

OMBWASHINGTON, D.C., April 24, 2015 – The SNAP change of listing status (de-listing) rule proposed in July 2014 was submitted by EPA to the Office of Management and Budget (OMB) on April 22 and received by OMB on April 24.  This initiates an Executive Order 12866 review by OMB’s Office of Information and Regulatory Affairs, which can last up to 90 days.

EPA Adds New Refrigerants to SNAP

Venting approved for new refrigerants, except R-32

March 2, 2015, WASHINGTON – As part of President Obama’s Climate Action Plan, the U.S. Environmental Protection Agency (EPA) is increasing the options for refrigerants used in various kinds of refrigeration and air conditioning equipment in the United States that offer better climate protection without harming the ozone layer. This final action addresses refrigerants under the Climate Action Plan that calls on EPA’s Significant New Alternatives Policy (SNAP) Program to identify and approve additional climate-friendly chemicals.
EPA
“Today’s rule is an example of how we can turn the challenge of climate change into an opportunity to innovate our way to a better future,” said EPA Administrator Gina McCarthy. “By working together, businesses and EPA are bringing new, climate-friendly refrigerants to market that better protect our health and the environment.”

Under the authority of the Clean Air Act, EPA’s SNAP Program evaluates substitute chemicals and technologies that are safe for the ozone layer. This final rule expands the list of SNAP-approved substitutes to include more low-global warming potential (GWP) alternatives that can replace both the ozone-depleting substances and high-GWP hydrofluorocarbons (HFCs). The approved substitutes have GWPs that range from 3 to 675 and can replace older compounds with GWPs between 1400 to 4000.

After receiving input from industry, environmental groups, and others, EPA is approving additional low-GWP hydrocarbon refrigerants, subject to use conditions, in the following refrigeration and air conditioning applications:

* Ethane in very low temperature refrigeration and in non-mechanical heat transfer;
* Isobutane in retail food refrigeration (stand-alone commercial refrigerators and freezers) and in vending machines;
* Propane in household refrigerators, freezers, or combination refrigerators and freezers, in vending machines, and in room air conditioning units;
* The hydrocarbon blend R-441A in retail food refrigeration (stand-alone commercial refrigerators and freezers), in vending machines and in room air conditioning units; and
* HFC-32 (difluoromethane) in room air conditioning units. HFC-32 has one-third the GWP of the conventional refrigerants currently being used in room air conditioning units.

These refrigerants are already in use in many of these applications in Europe and Asia.

In addition to adding these climate-friendly alternatives, EPA is also exempting all of these substances, except HFC-32, from the Clean Air Act venting prohibition, as current evidence suggests that their venting, release, or disposal does not pose a threat to the environment.

Learn more about EPA’s SNAP Program and this rule:http://www.epa.gov/ozone/snap/index.html

EPA Petitioned to Promote Recycling of HFC Refrigerants

Arlington, VA (February 3, 2014) – The Alliance for Responsible Atmospheric Policy (Alliance) submitted a petition for rulemaking to Environmental Protection Agency Administrator Gina McCarthy on Friday, January 31, 2014. The request seeks to include hydrofluorocarbons (HFCs) under the provisions of Title VI, Section 608 of the Clean Air Act intended to reduce refrigerant gas emissions. Including HFCs under Section 608 would reduce the emissions of these important compounds that provide safe and effective refrigeration and air conditioning services but are also greenhouse gases. Section 608 already includes requirements for chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs).

The Alliance estimates that the inclusion of HFCs under Section 608 could reduce HFC emissions by 15-20% in the United States. The primary goal of Section 608 is to minimize the loss of refrigerant to the atmosphere by improving the practices utilized during the servicing of air conditioning and refrigeration appliances. It sets certain leak and recovery standards and requires enhanced certification of equipment and technicians.

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