The United States Environmental Protection Agency (EPA) regulates which refrigerants may be used and how refrigerants must be handled. It is important to note that individual states may write their own refrigeration regulations above and beyond the EPA regulations.

Since 2015, EPA has proposed several rules, but some of those rules have been vacated in court. We understand that it may be confusing which rules still apply. Please read below to understand which regulations will come into effect in January 2019.

SNAP Program, Prohibited Refrigerants, and California

What is the SNAP Program?

EPA regulates which refrigerants may be used for new or retrofit refrigeration through the Significant New Alternatives Policy (SNAP) program.

Which refrigerants were affected by recent EPA rules?

EPA released Rule 20 and Rule 21 through its SNAP program, which delisted refrigerants with high global warming potential (GWP). This prohibited common refrigerants such as R-134A, R-404A, and R-507A. However, EPA was challenged in court and lost on Rule 20, which means it has been vacated and will not go into effect. It is possible that Rule 21 will also be vacated, but the courts are still evaluating it. Use the links below for more information:

• Zero Zone Guide to 2017 EPA Retail Refrigeration Regulations: Download
• Rule 20 Factsheet: https://www.epa.gov/sites/production/files/2015-08/documents/snap_regulatory_factsheet_july20_2015.pdf
• Rule 20 Vacated: https://www.gpo.gov/fdsys/pkg/FR-2018-04-27/pdf/2018-08310.pdf
• Rule 20 Allows R-404A: /refrigerant-regulations-update/
• Rule 21 Factsheet: https://www.epa.gov/sites/production/files/2016-12/documents/snap_action_scr2_factsheet.pdf

Can high GWP refrigerants be used?

Yes, depending on state. Rule 20 was vacated on a national level, but individual states may pass their own refrigeration regulations. In 2018, California passed a regulation that adopts Rule 20 (called Rule 1 in California). This rule prohibits high GWP refrigerants in California after January 1, 2019. More information is available on California legislature’s website: http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB1013

High GWP refrigerants can continue to be used in all other states, but that may change too. California is a member of the United States Climate Alliance (USCA), and the other states will likely adopt similar regulations. This includes Colorado, Connecticut, Delaware, Hawaii, Maryland, Massachusetts, Minnesota, New Jersey, North Carolina, Oregon, Rhode Island, Vermont, Virginia, and Washington.

In summary, R-134A, R-404A, and R-507A may be used in all states except California, which prohibits those refrigerants. However, other states in the USCA are likely to prohibit those refrigerants in the coming years.

Section 608, Record Keeping, and Leakage Rates

What is Section 608?

EPA regulates how refrigerants are handled through Section 608 of the Clean Air Act. Section 608 affects many sectors in the refrigeration industry:

• Technician Certification
• Refrigerant Recovery and/or Recycling Equipment
• Refrigerant Leaks
• Refrigerant Sales
• Record Keeping
• Safe Disposal
• Reclamation
• Service Practices

For more detail on how Section 608 applies, visit https://www.epa.gov/sites/production/files/2018-09/documents/section_608_of_the_clean_air_act.pdf

What are the new Section 608 regulations?

EPA issued new regulations that 1) require owner/operators to keep additional records for their refrigeration systems, and 2) change the allowable leakage rates for refrigeration systems. These rules affect ozone depleting refrigerants and will take effect on January 1, 2019.

The new rule included refrigerants with high GWP such as R-134A, R-404A, and R-507A. However, EPA proposed to omit refrigerants with high GWP from the rule. This has not been finalized, so more information will be provided as it becomes available. Use the links below for further reading.

• Summary of the Rule: https://www.epa.gov/sites/production/files/2016-09/documents/608_fact_sheet_supermarkets_property_managers_0.pdf
• Official Revision Announcement: https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations

What records does an owner/operator need to keep?

• Full System Charge
• Service Work Invoices
• Installation and Calibration of Automated Leak Detection System (if applicable)
• Leak History
• Reports for Leakage Rate Greater than 125% of Full-Charge in a Year
• Retrofit or Retirement Plans
• Requests to the EPA
• System Mothballing Reports
• Seasonal Variance Records

What are the allowable system leakage rates?

EPA reduced the allowable leakage rates. Annual leakage rates are calculated as a percentage of the full system charge. Details for calculating leakage rates can be found at https://www.epa.gov/sites/production/files/2016-09/documents/608_fact_sheet_supermarkets_property_managers_0.pdf.

What must be done when a leak is found?

If leakage rate exceeds allowable rates, the system must be repaired, retired, or replaced.

Repair: If a leak is repaired, the technician must ensure the system is leak-free before adding refrigerant. After refrigerant is added, the technician must check the repair again after the system returns to normal temperatures and pressures. Information for technicians can be found at https://www.epa.gov/sites/production/files/2016-09/documents/608_fact_sheet_technicians_0.pdf.

Retire or Replace: Owner/operators must develop a retrofit or retirement plan within 30 days if the leak cannot be repaired. The plan must be implemented within 1 year. If the leak is repaired within 180 days, the plan can be terminated and the system can be used.

What must be done after a leak?

After a leak, systems must be checked for leaks based on the schedule below. All visible, accessible parts of the systems must be inspected.

• Refrigeration systems with over 500 lb. refrigerant charge must be inspected every 3 months until the leakage rate is below the annual requirement.
• Refrigeration systems with between 50 and 500 lb. refrigerant charge must be inspected every year until the leakage rate is below the annual requirement.
• Refrigeration systems with a leak detection system do not require regular leak inspections. However, the leak detection system must be calibrated annually.

When should a leak be reported to EPA?

If the annual leakage rate of a refrigeration system exceeds 125% of the full charge within a calendar year, owner/operators must notify EPA by March 1 of the subsequent year and describe their efforts to identify and repair leaks.

Vacated EPA SNAP Rule 20 Allows R-404A for Refrigeration Equipment

Background on SNAP Rule 20

Refrigerant regulations have significantly impacted the industry. In 2015, the United States Environmental Protection Agency (EPA) issued SNAP Rule 20 to prohibit the use of certain hydrofluorocarbons (HFCs) that were previously acceptable substitutes for ozone-depleting substances. Consequently, Rule 20 required refrigeration equipment manufacturers like Zero Zone to phase out specific refrigerants, including R-404A and R-507A.

Legal Challenge and Overturning of Rule 20

However, parties challenged Rule 20, contending that the EPA SNAP Program could not be used to phase out HFCs that did not deplete ozone. The D.C. Circuit Court of Appeals overturned Rule 20, and despite an appeal, the court’s decision stood. As a result, on February 5, 2018, Rule 20 was vacated, allowing R-404A and R-507A to be used in new and retrofit refrigeration equipment once again.

Immediate Changes in Refrigerant Availability

Starting immediately, Zero Zone offers a variety of refrigerants, including R-404A and R-507A, for rack systems and remote display cases. Additionally, Zero Zone Hybrid™ cases can be ordered with either R-404A or R-448A. Hybrid™ cases utilizing R-404A will be available for shipment by April 1, 2018. Similarly, display cases using remote condensing units can be ordered with either R-404A or R-448A, with remote condensing units utilizing R-404A available for shipment by April 1, 2018.

Future Considerations for Refrigerant Regulations

This change does not phase out R-448A or any of the lower GWP refrigerants approved by SNAP. Customers may want to order R-448A or other lower GWP refrigerants in preparation for any future regulations. For example, the California Air Resources Board (CARB) has proposed legislation to implement SNAP Rule 20 in September 2018 for the state of California. It is possible that other states will make similar rulings. Therefore, lower GWP refrigerants may still be the best option for many customers. Customers need to evaluate which refrigerant will be best for their situation.

Contact Information

For further information, contact Zero Zone at 800-247-4496 and ask for our Department of Regulatory Compliance and Refrigeration Technology. This message is informational only, and customers should review national and local laws and regulations to ensure compliance.

By focusing on refrigerant regulations, this text aims to provide clarity on the changes and future considerations for customers in the refrigeration industry.

Congratulations to Whole Foods Market Dublin on the 2017 EPA Award

Zero Zone congratulates Whole Foods Market in Dublin, California, for receiving the prestigious 2016 Platinum Certification through the EPA GreenChill Partnership. This EPA Award is given to GreenChill-certified stores that demonstrate exemplary advancement in reducing emissions of environmentally harmful refrigerants.

Achievements and Recognition

Whole Foods Market Dublin earned this recognition by using a state-of-the-art refrigeration system. Specifically, they employed the Zero Zone ColdLoop™ Cascade Ammonia/CO2 with an Adiabatic Air-Cooled High Side Condenser. This innovative system played a crucial role in their achievement, showcasing their commitment to environmental sustainability.

Whole Foods Dublin did not stop at the Platinum Certification. They also tied with the Piggly Wiggly store in Columbus, GA, for the title of “the best GreenChill certified store of all stores certified in the past year” in 2016. This additional accolade further underscores their dedication to excellence in refrigeration practices.

Zero Zone’s Contribution

Zero Zone is extremely proud to have supplied the refrigeration system that helped Whole Foods Dublin achieve this highly regarded EPA Award. Our cutting-edge technology and commitment to sustainability align perfectly with the goals of the GreenChill Partnership. We are thrilled to see our systems making a positive impact.

Future Implications

This achievement by Whole Foods Dublin sets a benchmark for other stores aiming to reduce their environmental footprint. As regulations and standards continue to evolve, businesses must adopt advanced refrigeration systems that minimize harmful emissions. Zero Zone remains committed to providing solutions that meet these stringent requirements and support our customers in achieving their sustainability goals.

Learn More

For further information about Whole Foods Market’s award and the innovative refrigeration systems that contributed to their success, please contact Zero Zone at 800-247-4496 and ask for our Department of Regulatory Compliance and Refrigeration Technology. This message is informational only, and customers should review national and local laws and regulations to ensure compliance.

Way to go, Whole Foods Dublin! Your achievements inspire us all to strive for excellence in environmental stewardship.

Learn more about Whole Foods Market’s award here!