With fines related to EPA 608 totaling upwards of $37,500 per day, it’s important to note what regulation changes are expected to take place on January 1, 2019 and how these changes can affect your enterprise refrigerant management compliance.
In 2016, a well-known national grocery store chain violated the Clean Air Act by failing to promptly repair leaks from their refrigeration equipment. In addition to paying a hefty $500,000 fine, this violation resulted in over $2 million of mandatory repairs and upgrades, because of faulty enterprise refrigerant management.
However, this grocery store chain case is not the largest fine the EPA levied for faulty enterprise refrigeration management. One of the largest cases settled was over $4 million in fines with millions of dollars in mandatory upgrades. Previously, the EPA 608 section standards only applied to appliances containing ozone-depleting substances.
The new regulations apply to refrigerant appliances containing greater than or equal to 50 lbs. of refrigerant:
Leak rates now must be calculated every time refrigerant is added to the appliance. As a result, if the leak rates exceed the newer lowered thresholds, that appliance must be repaired to bring the leak rate back down.
For appliances that have exceeded the leak rate, periodic leak inspections (moved link) now will be required and conducted by a certified technician.
- Commercial refrigeration and industrial process refrigeration equipment (IPR) ≥ 500 pounds will need to be inspected once every three months until demonstrated that the leak rate has not exceeded the threshold for four quarters in a row.
- Commercial refrigeration and industrial process refrigeration equipment 50 to < 500 pounds will need to be inspected once a calendar year until demonstrated that the leak rate has not exceeded the threshold for one year.
- Comfort cooling equipment ≥ 50 pounds will need to be inspected once every three months until demonstrated that the leak rate has not exceeded 10% for one year.
If the appliance is continuously monitored by an automatic leak detection system, they are not required to adhere to the periodic leak inspections.
If the appliance has been inspected and needs repair, a verification test must be conducted ensuring that the repaired appliance has returned to normal operation conditions. Owner-operators have a 30-day repair period to inspect, repair and verify the appliance.
When components of a repair are not available within the 30-day repair period, a 30-day extension to repair will be available to all commercial refrigeration and comfort cooling appliances instead of just IPRs. For any appliances that need to be retired they have 18 months to retire or replace as opposed to the current standard of one year.
Some organizations are dealing with several variations of refrigerants and appliances, so the room for error and misunderstanding of standards is big, leaving them even more vulnerable to EPA fines. With refrigerant leaks as one of the highest maintenance expenses, adding on a repair and a hefty fine due to non-compliance could have a very significant impact on your organization.
Learn more about how Accruent helps identify problems, track repairs and minimize vulnerabilities in refrigeration management. Contact us today!