How to Manage Refrigerant Gases Under the CARB Stationary Refrigeration Equipment Program
Daniel J. Stouffer
February 12, 2009
The proposed California Air Resource Board (CARB) draft legislation is identified as Subchapter 10, Article X, Sections 9 through 17 with sub-sections included of the California Code of Regulations which was created on September 4, 2008. As of this writing, the CARB early action members are working through a schedule of meetings to collect any feedback and refine the Stationary Equipment Refrigerant Management Program before it becomes law later in 2009.
Understanding refrigerant gas management regulations, including the 2009 CARB program and the expected EPA regulations, one can break down the overall topics into three main areas:
Purpose, * Applicability, and * Definitions
Purpose of Stationary Equipment Refrigerant Management Program
The purpose of the regulation relates to the management of high global warming potential (GWP) refrigerant. The new laws, taking effect in January of 2010, will reduce or eliminate emissions of refrigerant gases from AC/HVAC systems and related industrial refrigeration units. In addition to the elimination of refrigerant gas emissions and the requirements for AC/HVAC system owners to track their units, anyone involved in reclaiming, recycling or recovering refrigerant and/or related obsolete equipment are encouraged to upgrade to state-of-the-art (SOTA) equipment.
CARB and many of the leading manufacturers are in discussions to ensure that manufacturer specifications meet the emerging CARB and EPA standards. Unfortunately, there are challenges with cylinder management. It is often difficult to maintain accurate labels or tracking information for refrigerant containers passed throughout the industry. More work among manufacturers will lead to the creation of unique serial numbers to accurately track cylinders. For pervasive industry wide tracking of refrigerant gases, the establishment of a set of protocols for cylinder identification will continue to be important.
Applicability of AC/HVAC System Monitoring, Tracking, and Registration
These regulations provide a better understanding of who must comply. Essentially, the new CARB refrigerant management program applies to;
A) Any persons who own or operate stationary refrigeration or air conditioning systems containing refrigerant gas, and
B) Any persons who are engaged in installation, repair, maintenance, service, replacement recycling or disposal of stationary refrigeration or air conditioning systems as well as sellers of refrigerant.
Definitions and Key Refrigerant Gas Management Terms
Included in the CARB regulations is a useful guide that explains in detail many of the regulatory terms applicable and in hoping to facilitate enhanced compliance. Included as a summary are the key concepts related to refrigerant gases, refrigerant leaks, how to track refrigerant usage events, and more. The goal is to educate and provide information for facility managers to better manage refrigerants and their related reporting. Additional definitions and applicable citations include "Additional Refrigerant Charge", "Air Conditioning System", which defines AC/HVAC equipment as it applies to the regulation, "Air District" which means an Air Quality Management District or Air Pollution Control District for the purpose of refrigerant reporting and submittals, "Air Pollution Control Officer", and a citation for "Automatic Leak Detection" as well as for specification for qualifications on certifications for reclaimers and other certified technicians.
Why Refrigerant System Management is Such a Big Deal
Understanding the CARB Stationary Equipment Refrigerant Management Program regulation is simplified and outlined in their 27-page draft. Through the first part of 2009, the CARB early actions group will make revisions to the Stationary Refrigeration Equipment Program. It is known, due to mandatory deadlines for completion of this regulation that it will pass in 2009 and be effective in 2010.
As with all environmental compliance, determining whether an owner or operator must comply is the first step. Using the 2009 CARB draft as a guide, refrigerant management from an enforcement and user standpoint addresses the problem of refrigerant gases that increase global warming effects in a judicious and effective initiative.
The California Air Resources Board (CARB) early actions and improvements to refrigerant tracking enhances knowledge and improves the requirements necessary to track, maintain, and report high global warming potential refrigerants before they reach the atmosphere. With improved environmental monitoring and legislation, we gain improved environmental health and safety. This results in benefits to not only human prosperity but also long term benefits to the environment.
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To learn more effective refrigerant management tactics and the tools that support them, you can contact Daniel Stouffer, the Product Manager for Refrigerant Tracker. This web-based software makes it easy to monitor, manage, and report refrigerant gas usage. Stay in compliance with refrigerant management regulations. Visit Verisae's Refrigerant Tracker at -- http://www.Refrigerant-Tracker.com
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