More big changes are coming in January to Section 608 of the Clean Air Act, the law that regulates stationary refrigeration practices. While 2018 compliance dates brought new requirements for technician certifications, record keeping and asset disposal, the 2019 changes will overhaul leak rate thresholds and the consequences for exceeding them. To avoid hefty fines and repercussions, facilities managers will be required to meticulously track, report and monitor refrigeration equipment. Are you ready?
Starting January 1, 2019, leak rate thresholds for all ozone-depleting substances and substitute cooling fluids will be lower. Exceeding these thresholds can trigger mandatory testing, inspections, expensive repairs and fines. The new leak rate thresholds are:
If a commercial or industrial process refrigeration unit exceeds its leak rate threshold, it must be repaired and will be subject to the following series of inspections:
If a comfort cooling unit with 50 or more lbs. of refrigerant exceeds its leak rate threshold, following repair, it must be inspected annually by a certified technician until the leak rate has remained below 10% for one year.
Facilities managers are required to provide specific documentation on servicing, leak rates, repairs and more for units that exceed their threshold. In addition to regular inspections, the equipment owner must demonstrate through leak rate calculations that the unit has been successfully repaired. Leak rates must be calculated initially with a verification test before refrigerant is added, as well as once the unit has returned to normal operating conditions.
The fines associated with violating any Section 608 rule can total $37,500 per day, plus expensive repair and replacement costs. The EPA regularly responds to tips about violations and performs random inspections. In recent years, the Agency has pursued cases that resulted in millions of dollars in fines.
The best way to remain compliant with Section 608 is to implement a comprehensive platform that does the work for you. With the stringency of the new requirements, calculating and reporting on paper or using a hodge-podge of disparate software products could leave you vulnerable to serious consequences.
In September 2018, the EPA issued a proposed rule titled Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes. According to the EPA, "this action proposes to revisit the Agency’s recent approach to regulating appliances containing substitute refrigerants such as hydrofluorocarbons (HFCs) by proposing to rescind the November 18, 2016 extension of the leak repair provisions to appliances using substitute refrigerants." The proposal also requested public comment on rescinding additional provisions to substitute refrigerants including how they are purchased, removed and reclaimed.
A public hearing was held on October 16th, 2018 and the comment period closed on November 15th, 2018.
For the latest updates on the proposed revision, check back here.
Nuvolo’s Facilities EAM platform provides out-of-the-box solutions that deliver the configurability required in today’s dynamic regulatory environment, from modifying workflows to automating the tracking and reporting mandated by Section 608. Nuvolo has overhauled outdated facilities management platforms to ensure they remain compliant with Section 608.
Examples of Nuvolo’s capabilities include:
Contact us to learn more about how Nuvolo can help you navigate Section 608.