Making Sense of EPA Refrigerant Use Restrictions

Impending EPA Deadlines Affect Your Use of R-22

The production of newly-manufactured R-22 refrigerant is slated to end in 2020 due to provisions in the Clean Air Act, which phase out production of all refrigerants with ozone-depleting potential.

R-22 is an excellent refrigerant with many uses and a huge installed base in refrigeration and HVAC applications. According to one estimate, as of 2017 there are 60 to 70 million systems in the U.S. operating with R-22 refrigerant.

NOTE: It's useful to understand the background, rules, and penalties for non-compliance, as described in this section. When you are ready to learn more about how to proceed, click the link on the three options below to help decide whether you should maintain, retrofit, or replace your current system.

System owners have 3 options:

01

Maintain

the system with R-22.

Link
02

Retrofit

the system to an alternative refrigerant.

Link
03

Replace

the system with one designed for an alternative refrigerant.

Link

Newly Manufactured R-22 Allocation

Existing Inventories and reclaimed R-22 needed to satisfy demand

Newly Manufactured Chart

EPA Rules You Need to Know SNAP (Significant New Alternative Policy) Program

In June 2013, as part of the President's Climate Action Plan, the EPA utilized the Significant New ALternatives Policy (SNAP) to allow the use of environmentally-safe refrigerants to replace ozone-depleting CFCs, HCFCs, and high GWP HFCs. As a result, the EPA reviewed refrigerant use applications to determine if viable lower GWP alternative refrigerants were available. When suitable alternatives are identified, they are approved for use in specific applications.

Applications that have not had SNAP rule changes restricting or prohibiting the use of refrigerants include:

  • Retail Food Refrigeration
  • Vending Machines
  • Household Refrigerators
  • Cold Storage Warehouses
  • Comfort Cooling Chillers

Applications that have had SNAP rule changes include:

  • Residential and Light Commercial A/C, Heat Pumps
  • Industrial Chillers
  • Commercial Ice Machines
  • Ice Skating Rinks
  • Industrial Process A/C
  • Residential Dehumidifiers
  • Refrigerated Transport
  • Water Coolers
  • Very Low Temperature Refrigeration

How Section 608 of the EPA's Clean Air Act Affects Refrigerant Decisions

A recent amendment to Section 608 extends the existing regulation to HFC refrigerants and, effective Jan. 2019, lowers the leak rate threshold in equipment containing 50 or more pounds of any refrigerant. It also requires owners/operators to repair leaks that exceed the threshold and perform verification and follow-up inspections to confirm that leaks are repaired.

Penalties For Non-Compliance Can Be Significant

The EPA can assess civil penalties up to $44,539 per day, per violation, for non-compliance.

Section 608 Leak Rate Thresholds

System Type Current Allowable Leak Rate Effective 1/1/19
Industrial process refrigeration 35% 30%
Commercial refrigeration 35% 20%
Comfort cooling 15% 10%

NOTE: Each independent refrigerant circuit in a system is considered a separate system for leak rate applicability.

Your Next Steps

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