Refrigerant Rule Revisions: Is Your Facility Prepared? Outline

摘要

Recent amendments to the Montreal Protocol and U.S. EPA refrigerant management regulations in 40 CFR Part 82, Subpart F will significantly impact refrigerant compliance and maintenance programs at industrial, institutional, and commercial facilities. The Kigali amendment to the Montreal Protocol, which is likely to go into effect in 2019, expands the Protocol's focus from ozone depleting substances (ODS) to greenhouse gases (GHGs) through a phase out schedule for hydrofluorocarbons (HFCs) such as R-134a and R-410A. The Kigali amendment will impact numerous countries that are Parties to the Montreal Protocol if it is ratified. The HFCs affected by Kigali and U.S. EPA action are some of the most commonly used refrigerants today. There has already been progress on implementing this agenda in the U.S. with initial changes to EPA's regulations and by disapproving the use of certain HFCs in specific end-uses under recent SNAP (Significant New Alternatives Policy) Program determinations. The revised Subpart F provisions contain numerous substantial updates, including extending the requirements to cover substitute refrigerants that are GHG but do not contain ODS, lowering the leak rate thresholds that trigger repair requirements, and adding leak inspection requirements. The combination of revised Subpart F requirements, and tightening of HFC supply and allowable uses, result in significantly more HVAC systems being subject to regulation and the potential for substantial cost implications for any establishment using industrial-scale cooling equipment as the phase outs are realized. This presentation will provide an overview of the Subpart F compliance requirements (including those set to go into effect on January 1, 2019), and discuss the market and political aspects of this shift from ODS to GHG control under the Montreal Protocol and U.S. EPA regulations.