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The U.S. EPA published the final rule revisions, "Protection of Stratospheric Ozone: Update to the Refrigerant Management Requirements under the Clean Air Act" in the Federal Register (81 FR 82272) on November 18, 2016. These revisions represent a major overhaul of the provisions under Title 40 of the Code of Federal Regulations (40 CFR) Part 82, Subpart F [also referred to as the ozone depleting substance (ODS) refrigerant management rule]. A few of the significant changes in the final rule include, but are not limited to, the following:

  • Significant expansion of the applicability of the rule to non-ODS containing refrigerants,
  • New disposal recordkeeping requirements for appliances with full charge > 5 pounds and
  • < 50 pounds,
  • Strengthens the leak repair requirements by lowering the leak rate thresholds and enhancing the requirements to demonstrate and document that a leak has been repaired,
  • Establishes annual "significant leaker" reporting provisions for units that leak ≥ 125% of full charge in a calendar year, and
  • Significantly expands explicit recordkeeping requirements under the leak repair provisions.

The effective date for this rule was January 1, 2017, with varying compliance dates of January 1, 2017, January 1, 2018 (1 year), and January 1, 2019 (2 years), depending on equipment size, refrigerant type, and/or rule provision. Note that the revised leak repair provisions, including their applicability to non-exempt substitutes, have a compliance date of January 1, 2019.

The rule will require most facilities to update their refrigerant compliance program. Typical updates needed include: service/repair forms, refrigerant evacuation certifications, equipment disposal forms, and procedures. One of the most significant updates needed will be to the leak repair and tracking program, including expansion to non-ODS refrigerants, retrofit/retirement tracking, shorter timeframes for required follow-up verification tests, and chronic leaker tracking.

Need help? Trinity can assist by performing a gap analysis to identify areas that will need to be updated. In addition, Trinity has developed refrigerant management tools designed to meet the new requirements.

For assistance with your air permitting needs, contact the Trinity office nearest you by calling 800-229-6655 for more information.