California Refrigerant Management Program and EPA 608 Certification
Historically, most facilities that utilize halocarbon (Freon) refrigeration systems have avoided the burdensome Risk and Process Safety Management requirements that their ammonia refrigeration counterparts have been required to comply with since the early 1990s. But as of 2012, the tide has changed for halocarbon refrigeration systems in California. In the remainder of this blog, we will summarize the new regulatory requirements that are affecting the halocarbon refrigeration industry, specifically in California.
Regulation: Refrigerant Management Program (RMP) | Title 17 CCR §95380 – 95398
Enforcement Agency: California Air Resources Board (ARB)
Applicability: Stationary refrigeration systems that utilize high-global warming potential (GWP) greenhouse gas (GHG) refrigerants including chlorofluorocarbon (CFC), hydrochlorofluorocarbon (HCFC), and hydrofluorocarbon (HFC) refrigerants.
Purpose: Designed to reduce emissions from high-global warming potential greenhouse gas refrigerants from refrigeration systems.
Summary: The regulation divides refrigeration systems into three (3) groups, according to the refrigerant inventory. Each group has unique requirements which are summarized in the table below:
| Group | Threshold | Leak Check | Registration Date | Annual Reporting Required? |
| Group 1 | Systems with a full charge greater than or equal to 2,000 pounds of refrigerant. | Automatic Leak Detection (ALD) * Equipment located outdoors must be leak checked on a quarterly basis. |
Must have been registered with the Air Resources Board by March 1, 2012. | Yes $370.00 Annual Implementation Fee |
| Group 2 | Systems with a full charge greater than or equal to 200 pounds, but less than 2,000 pounds of refrigerant. | Quarterly Leak Inspection | Systems must have been registered with the Air Resources Board by March 1, 2014. | Yes $170.00 Annual Implementation Fee |
| Group 3 | Systems with a full charge greater than or equal to 50 pounds, but less than 200 pounds of refrigerant. | Annual Leak Inspection | Group 3 systems must have been registered with the Air Resources Board by March 1, 2016. | No |
The group designation will affect the requirements for reporting, record keeping, and leak detection, but regardless of the group, each system must be registered with the Air Resources Board through the R3 web portal. Additional rules that apply to all systems, regardless of their group, include:
- Repair leaks within 14 days of discovery.
- Certified EPA 608 technicians required to service/repair the refrigeration system.
- Retrofitting systems if leaks cannot be repaired.
Many California businesses have been caught off guard by these new requirements, but in actuality, Federal halocarbon refrigeration regulations have existed since the early 1990’s.
EPA regulations (40 CFR Part 82, Subpart F) under Section 608 of the Clean Air Act require technicians who service stationary refrigeration and air-conditioning equipment to follow specific practices regarding venting, servicing, leak repairs, and recordkeeping. These practices are meant to maximize recovery and recycling of ozone-depleting and global warming potential substances. As of November 9, 2015, the EPA published a proposed rule to amend the Clean Air Act section 608 refrigerant management program regulations. Below are a few changes that look familiar to the California Refrigerant Management Program:
- Annual leak inspections for system normally containing 50+ lb of refrigerant.
- Quarterly leak inspections for systems containing 500+ lb of refrigerant.
- Prohibiting operation of systems normally containing 50+ lb of refrigerant that have leaked 75% or more of their full charge for two consecutive years.
Should the proposed rule become law, California facilities would be required to comply with both the Federal and State regulations.
The issue of global warming and ozone depletion is gaining huge momentum in the regulatory world, and it is vital as a facility owner/operator with Freon refrigeration systems to comply with these regulations.
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