Back in June 2013, President Obama announced his Climate Action Plan, a major component of which is to cut carbon pollution in the United States. The outline to accomplish this focuses on renewable energy, clean energy innovation, energy efficiency, and a cleaner transportation sector, but it also specifically addresses cutting carbon emissions from power plants, methane emissions, and emissions of hydrofluorocarbons (HFCs). Over the last 28 months, the U.S. Environmental Protection Agency (EPA) has been steadily moving forward to make these emissions cuts a reality.
The targets already hit
Cutting carbon emissions from power plants …Check! In August 2015, the EPA finalized the Clean Power Plan, which, when fully implemented, is expected to reduce carbon pollution from existing power plants to 32 percent below 2005 levels. The EPA also finalized new source performance standards (NSPSs) to limit carbon pollution from new power plants.
Cutting methane emissions … Check! The EPA and other federal agencies have addressed or are in the process of addressing the largest sources of methane emissions: landfills, coal mines, agriculture, and the oil and gas (O&G) industry. The EPA has proposed new and modified NSPSs addressing methane emissions from landfills and the O&G sector.
Aiming at refrigerants
Cutting emissions of HFCs … Check! Having already dealt with carbon pollution from power plants and methane emissions, the EPA recently proposed changes to the regulations against knowingly venting, releasing, or disposing of ozone-depleting refrigerants. The proposed changes extend the requirements to non-ozone-depleting substitutes, specifically HFCs. HFCs are widely used refrigerants, but they are also potent greenhouse gases with global warming potentials much greater than carbon dioxide.
In addition to extending the regulations to cover HFCs, the EPA is proposing numerous changes that impact all refrigerants covered by the regulations. These proposed changes include:
- Lowering the leak rate threshold that triggers repair of refrigeration and air-conditioning equipment containing 50 pounds (lbs) or more of refrigerant. For commercial and industrial refrigeration equipment the leak rate is being lowered from 35 percent to 20 percent; and for comfort cooling equipment, the leak rate is being lowered from 15 percent to 10 percent.
- Requiring regular leak inspections or continuous monitoring devices for refrigeration and air-conditioning equipment. Systems with a full charge of 50 lbs or more of refrigerant will have to be inspected for leaks annually. Inspections will be conducted quarterly for commercial and industrial systems with a full charge of 500 lbs or more of refrigerant.
- Prohibiting operation of any system with a full charge of 50 lbs or more of refrigerant if leaks equal or exceed 75 percent of the full charge for 2 consecutive years.
- Requiring technicians to keep records of refrigerant recovered from the disposal of systems with a full charge of 5 lbs to 50 lbs.
Impact and outlook
The proposed changes will increase the time and money facilities spend on maintenance of refrigeration and air-conditioning equipment and compliance with the applicable regulations. The lower leak rate threshold means conducting more repairs, retrofits, or equipment retirements. Inspections and documenting compliance with the other proposed changes will necessitate increased recordkeeping. All this is just more to add to the plate of facility and environment, health, and safety personnel.
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