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Refrigerant Management: How Changes to Section 608 Impact Our Industry

JohnWallace_Blog_Image John Wallace | Director of Innovation, Retail Solutions

Emerson Commercial & Residential Solutions

I was recently interviewed for an article in ACHR’s The News magazine, “EPA’s Proposed Changes to Section 608 Cause Concern in the Industry,” where I provided my perspective on the current state of leak detection, repair and other provisions.

Refrigerant leak response and repair regulations have placed our industry in uncertain waters. As you may know, the Environmental Protection Agency (EPA) has proposed a new rule that rescinds some provisions of its Section 608 mandate, affecting equipment with 50 lbs. or more of hydrofluorocarbons (HFCs) or other substitute refrigerants. These best practices were developed in consultation with the HVACR industry to ensure safety, establish proper reclaim and recycling processes, and of course, reduce carbon emissions.

In November 2016, the EPA extended the scope of Section 608 — from refrigerants containing ozone-depleting substances (ODS) to nonexempt substitute refrigerants such as HFCs. Because the Court of Appeals ruled in 2017 that the EPA could not ban HFCs, the agency has decided that it also did not have the authority to regulate these refrigerants under Section 608.

Establishing best practices

Awareness of the importance of leak detection has grown exponentially in recent years. Today, most companies understand that implementing a leak response and repair program is simply a best practice. And for those companies that have already taken steps to comply with Section 608, the vacating of this rule will have little impact.

I stated in the article: “These procedures not only benefit the environment but also help ensure HVACR equipment operates at peak efficiency, including at the lowest overall cost. One of the benefits of the existing regulations has been to raise the awareness of best practices related to HVACR maintenance. Increased awareness generally leads to broader adoption by those in the industry, regardless of whether regulations are in place.”

Simply put, leak detection and repair programs make good sense, regardless of the regulations in place or the type of refrigerant being used. However, with the reversal of Section 608, equipment operators will no longer be under federal mandate to follow these widely adopted refrigerant management best practices:

  • Conducting leak rate calculations when refrigerant is added to an appliance
  • Repairing an appliance that leaks above a threshold leak rate
  • Conducting verification tests on repairs
  • Conducting periodic leak inspections on appliances that exceed the threshold leak rate
  • Reporting to the EPA about chronically leaking appliances
  • Retrofitting or retiring appliances that are not repaired
  • Maintaining related records
  • Overseeing technicians’ use of certified equipment and the reclamation process

These procedures are already considered to be the optimal standard practice, and end users who are focused on operational excellence are likely doing many (or most) of them today.

Maintaining other key program elements

The absence of a federal mandate for responsible HFC management creates a quandary for our industry. Currently, the EPA is seeking comments about the remaining provisions of Section 608, raising concerns about the potential for overturning other benefits of programs — specifically, guidelines for refrigerant reclaim procedures and technician certification and training programs.

Proper refrigerant reclamation reduces the likelihood of introducing impurities, which could lead to premature failures and increased maintenance costs for owners of HVACR equipment. What’s more, the certification program provides the vital information on how to deal with the ever-growing number of refrigerants. As I stated in the article: “One benefit of certification is that wholesalers are able to sell refrigerants to technicians who have a sufficient background and understanding of their liability under the Clean Air Act.”

Path forward

Already, several states are adopting standards for leak detection and control. Again, as I noted in the article, “We are already seeing some states such as California enact regulations that adopt many of the requirements in Section 608. Other states will likely step in, which may create more headaches for the industry. This could create problems for the industry and lead to a patchwork of inconsistent regulations that would be challenging for manufacturers and service providers to navigate.”

As always, Emerson will help you stay informed about further changes to Section 608. Regardless of the regulatory decisions, we’ll continue to provide guidance and expertise on how to design and implement refrigerant management programs.

Refrigerant Leak Detection Technology Saves $$ and the Environment

I recently wrote an article featured in Contracting Business discussing the importance of refrigerant leak detection as an essential service for retailers and HVACR contractors.

Refrigerant leaks have long been viewed as an inevitable part of operating a retail refrigeration system.  Retailers often wrote these leaks off as the cost of doing business, but the impact of refrigerant leaks goes beyond what most may expect. The true costs of refrigerant leaks are often underestimated, and contractors who understand this impact will be more valuable partners for their clients.

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According to the EPA’s GreenChill research, the average supermarket loses about 25 percent — or about 875 pounds — of its refrigerant supply because of leaks. When you multiply this across many stores in a grocery chain, the costs can be significant — not only in terms of the cost of the refrigerant, but with associated labor costs. There is also a potential loss of business because of food disruptions and food quality issues that may arise.

Refrigerant leaks also have an environmental impact. Most commonly used refrigerants are greenhouse gases and some are ozone-depleting substances. Assuming a leak rate of 20 percent across a chain of 100 typical supermarket stores, the amount of refrigerant leaked annually is equivalent to the emissions of 24,000 cars or 10,600 homes.

The EPA has had regulations in place for a number of years as part of the Clean Air Act. Now, the EPA has proposed an update to those regulations governing most refrigerants that could impact both contractors and retail operators. Contractors who keep up with how these regulations are changing can be better retailer partners by aligning their services to meet these changes. An effective leak detection program can help retailers manage and properly repair refrigerant leaks and avoid costly EPA settlements.

The goal should be not only to establish proper leak detection response protocols, but also to institute proactive measures that minimize or eliminate leaks altogether. A zero-tolerance policy for leaks is ideal. Accurate detection methods, reliable notifications and continuous monitoring are the key elements needed for effective leak detection programs.

To learn more about refrigerant leak detection for contractors, read the full Contracting Business article here.

 For more than 20 years, Emerson Retail Solutions has been helping businesses like yours safeguard food, reduce energy consumption, protect the environment and optimize business results. To learn more about our technology solutions and services for retailers, visit our website.

 John Wallace
Director of Innovation
Emerson Climate Technologies Retail Solutions

The Rubber Meets the Road

Final rulings signify start of next phase of transition

 For two years, the commercial refrigeration industry has been reeling from a one-two regulatory punch from the Department of Energy and the Environmental Protection Agency. This convergence of aggressive regulations was unprecedented for our industry.

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Dallas E360 Forum Served up Lively Refrigeration Dialogue

Emerson Climate Technologies recently held its fifth E360 Forum on September 3 in Dallas. The event was attended by more than 120 refrigeration industry constituents, ranging from supermarket, restaurant and convenience store end users to trade media representatives, refrigerant providers and original equipment manufacturers. Coming off the heels of the EPA’s final ruling on refrigerant delisting, it was no surprise that the far-reaching regulatory implications — including the DOE’s energy efficiency measures on walk-ins, reach-ins and ice machines — were main topics of conversations.

E360 Forum -Dallas

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E360 Webinar Discusses the EPA’s Final Refrigerant Ruling

What’s Next, and How Will It Affect Your Business?

Dr. Rajan Rajendran, V.P. of System Innovation Center and Sustainability at Emerson Climate Technologies, Inc. recently presented an E360 Webinar that addressed the details of the EPA’s final refrigerant delisting ruling. With more than 500 industry participants in attendance, the 14th Webinar in Emerson’s E360 Webinar series explored the final rule’s short- and long-term impacts on the commercial refrigeration industry. As a nationally recognized expert in refrigerants, Rajan began by demonstrating the global trend toward lower global warming potential (GWP) refrigerants — particularly noting the European Union’s target of phasing down to sub-150 GWP refrigerants in commercial refrigeration applications by 2022.E360 Webinar EPAs Final Refrigerant Ruling Read more

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