US EPA has finalized its Section 608 rule requirements in September 2016. Four new fact sheets summarizing EPA’s compliance dates are available for the following categories: Technicians; Supermarkets and Property/Facility Managers; Refrigerant Distributors and Wholesalers; and Reclaimer. https://www.epa.gov/section608/revised-608-rule-fact-sheets
The U.S.EPA has recently revised their list of refrigerants acceptable for use in new and retrofit refrigeration systems. Most pertinently, R-404A and R-507A are no longer acceptable for use in new and retrofit systems in retail food refrigeration. The EPA Rule includes restrictions of other refrigerants and uses also, including cold storage. For additional information and specific dates when the restrictions go into effect, please see their Fact Sheet.
Refrigerant Management Program (RMP)
Technicians and Contractors
Service technicians play a vital role in assuring their clients are in compliance with law.
California law regulates the use of many newer refrigerants including R-404A, R-507 and many others due to their high-Global Warming Potential (high-GWP). Ozone depleting substances used as refrigerants such as CFC-11, CFC-12, HCFC-22 are also considered high-GWP and affected by the law.
The California Refrigerant Management Program (RMP) affects technicians and contractors who service refrigeration and air conditioning equipment using those high-GWP gases. California's required service practices for these refrigerants include having a current, valid U.S. EPA certificate; no venting; and using proper recovery and disposal procedures to prevent fugitive emissions.
Businesses with non-residential refrigeration systems have requirements that vary with the size of the largest system at each facility. Requirements include registration with the RMP, annual reporting of service events and refrigerant usage, and compliance with service practices such as conducting regular leak inspections, leak repair within 14 days of detection, and more.
Technicians must have a valid U.S. EPA certification:
Technicians must also work under a CSLB contractor's license:
- California State Licensing Board (CSLB)
- How to apply for a CSLB contractor's license (video)
- CSLB C38 Classification Definition (Refrigeration)
- CSLB C20 Classification Definition (HVAC)
are questions frequently asked by technicians about the RMP.
you have any additional questions that need to be answered,
please contact Refrigerant
Management Program Staff at (916) 324-2517.
affected facility required to do?
What equipment or appliances are subject to the rule?
What refrigerants are subject to the rule?
If a facility uses a chiller with more than 50 pounds of high-GWP refrigerant for both air conditioning and process cooling, are they subject to the rule?
How do I determine the size category of a facility’s system?
When are leak inspections required?
Is there a specific method of leak detection required by the new rule?
For automatic leak detection systems, how many and where should monitors be installed?
When should a leak be repaired?
Who can repair leaks?
What should I do with empty refrigerant cylinders?
What is an affected facility required to do? (back to top)
- Conduct periodic leak inspections. (Starting January 1, 2011)
- Promptly repair leaks (Starting January 1, 2011)
- Keep records onsite of inspections, repairs, and high-GWP refrigerants purchased and shipped. (Starting January 1, 2011)
- Register and report to ARB (Starting March 1, 2012, for large facilities; 2014 and 2016 for smaller facilities)
What equipment or appliances are subject to the rule?(back to top)
It depends on if you are a facility owner or a service contractor/techincian. Required service practices (section 95390) of the rule apply to any person performing any installation, maintenance, service, repair, or disposal of a stationary appliance. “Appliance”, as defined in the rule, means any device which contains and uses a high-GWP refrigerant, including any air conditioner, refrigerator, chiller, freezer, or refrigeration system.
Facility owners or operators are subject to the rule if all of the following apply:
- it is a non-residential facility,
- if the largest single refrigeration system in the facility has a refrigerant charge greater than 50 pounds or greater,
- if the system uses a high-GWP refrigerant.
The types of businesses that commonly use the applicable refrigeration systems include but are not limited to supermarkets, cold storage warehouses, food processing plants, and industries with process cooling operations.
What refrigerants are subject to the rule? (back to top)
High-GWP refrigerants include all commonly used chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) with a global warming potential greater than 150. The rule also includes all ozone-depleting refrigerants regardless of GWP regulated under Federal Rule 608. Refrigerants that are not covered under the new California rule include ammonia, carbon dioxide and HFC-152a, which has a GWP less than 150 and is also non-ozone-depleting.
If a facility uses a chiller with more than 50 pounds of high-GWP refrigerant for both air conditioning and process cooling, are they subject to the rule? (back to top)
Yes. This facility will fall into the category of “Other refrigeration” and will be subject to the rule. “Other refrigeration” means any stationary, non-residential appliance that is used for an application other than industrial process refrigeration, commercial refrigeration, or air-conditioning, or is used for two or more applications including industrial process refrigeration, commercial refrigeration, or air-conditioning.
How do I determine the size category of a facility’s system? (back to top)
Facilities with applicable refrigeration systems are categorized as:
- Small: refrigeration systems using more than 50 pounds, but less than 200 pounds, of a high-GWP refrigerant.
- Medium: refrigeration systems using more than 200 pounds or more, but less than 2,000 pounds, of a high-GWP refrigerant
- Large: refrigeration systems using 2,000 pounds or more of a high-GWP refrigerant.
Refrigeration systems with multiple circuits connected by a valve or conduit through which a refrigerant could flow, are considered a single system. As an example, if a refrigeration system with two circuits can be charged at a single point, and each circuit has a 150 pound normal operating charge, the total charge of that system would be considered a medium, 300-pound system. If a system has two, 150-pound charged circuits that are completely separate or isolated, then the system would be considered small.
Facilities with multiple refrigeration systems at the same site are categorized only by the single, largest system on site. For example, if a facility has one large and three medium systems, the facility would be categorized as large and the annual fee would be $370 and the facility owner/operator would be subject to the registration and reporting schedule for large refrigeration systems that begin in 2012.
When are leak inspections required? (back to top)
Facility owner or operators are required to conduct leak inspections depending on the size of the refrigeration systems. Beginning 2011, monthly inspections for large systems (continuous monitoring is required beginning 2012), quarterly inspections for medium systems, and annual inspections for small systems. Adding refrigerant to a system, other than for seasonal adjustments and/or detection of visible oil residual would also require a leak inspection be conducted.
Large systems that do not operate year round or have major components outside the building are only subject to quarterly inspections.
Is there a specific method of leak detection required by the new rule? (back to top)
For large systems that are intended to operate year round, automatic leak detection systems must be installed by January 1, 2012, and annually calibrated. Otherwise, portable leak detection devices, bubble tests or other approved methods can be used for medium and small systems. Portable devices should be calibrated to ensure they are functioning properly and sensitive enough to detect leaks.
For automatic leak detection systems, how many and where should monitors be installed? (back to top)
There is no specific number of monitors that must be installed. This provides flexibility for the facility owner based on refrigeration system design and configuration. Sensors or intakes must be placed so that they will continuously monitor the refrigerant concentrations in air in proximity of the compressor, evaporator, condenser, and other areas with a high potential for a refrigerant leak. The intent of this requirement is to detect and repair leaks in a timely manner. For example, if all leak prone components are in one machine room then the sensors can be placed in one room. However, if refrigerant is distributed to several compressors and display cases throughout a facility, more sensors may be needed to effectively monitor any leaks.
When should a leak be repaired? (back to top)
The new statewide rule is more stringent than Federal rule (section 608) and requires any amount of refrigerant leak from an affected refrigeration system to be repaired within 14 days of detection. Additional time may be allowed in certain conditions. Service technicians and contractors should not add refrigerant to any appliance with a known leak (regardless of size and including air conditioning systems).
Who can repair leaks? (back to top)
Repairs can only be made by U.S. EPA certified technicians who also hold an active California contractors license in the C38 (Refrigeration) or C20 (HVAC) classifications. Exceptions for a California contractors license are included in section 95386(h) of the regulation.
What should I do with empty refrigerant cylinders? (back to top)
Non-refillable refrigerant cylinders must be evacuated to a vacuum of 15 inches of mercury (relative to standard atmospheric pressure of 29.9 inches of mercury) before recycling or disposal.
the Refrigerant Management Program email list for updates.
For questions on the rule or to provide feedback, please contact Refrigerant Management Program Staff at (916) 324-2517.