Section 608 of the Clean Air Act turns into daily rules for technicians: do not vent refrigerant, recover it to set levels, and make sure leaking equipment is found and fixed. This article walks through what 40 CFR 82 Subpart F requires and where the exceptions sit.
The venting prohibition and its exceptions
No person maintaining, servicing, repairing or disposing of an appliance may knowingly vent or otherwise release refrigerant into the environment (40 CFR 82.154(a)(1)). Releasing refrigerant after it has been recovered is also a violation (40 CFR 82.154(a)(3)).
The rule exempts certain substitutes in listed uses. Carbon dioxide, nitrogen and water are exempt in any application. Ammonia is exempt in commercial or industrial process refrigeration and in absorption units. Hydrocarbons are exempt in industrial process refrigeration. Propane, isobutane and R-441A are exempt only in the equipment types the rule names, such as household refrigerators and freezers (40 CFR 82.154(a)(1)(i)-(x)). Read the end-use list before assuming a refrigerant is exempt.
There is one more allowance. De minimis releases during a good-faith attempt to recover or recycle refrigerant are not violations, but only if you follow the evacuation and equipment rules, use certified recovery or recycling equipment whenever refrigerant leaves an appliance, observe the technician certification rules, and meet the reclamation requirements (40 CFR 82.154(a)(2)). A sloppy job does not qualify.
Certified equipment and the technician
You may not service or dispose of an appliance containing a covered refrigerant without following the required practices and using recovery or recycling equipment certified for that refrigerant and appliance type (40 CFR 82.154(b)). Equipment must be used as the manufacturer directs unless those directions conflict with the rule (40 CFR 82.156(g)).
Anyone who could reasonably be expected to break into the refrigerant circuit needs a certification. Type I covers small appliances, Type II covers medium-, high- and very high-pressure appliances, Type III covers low-pressure appliances, and Universal covers all three (40 CFR 82.161(a)(1)). Apprentices are exempt only while closely and continually supervised by a certified technician (40 CFR 82.161(a)(2)).
Recovery and evacuation levels
Before opening an appliance or disposing of it, evacuate the refrigerant, including all liquid, to the required level and verify that level before you open it (40 CFR 82.156(a)). You may evacuate the whole appliance or just the part being serviced if it can be isolated. The required level depends on the pressure class and, for some, the charge size (Table 1, 40 CFR 82.156(a)). For equipment made on or after November 15, 1993:
- Very high-pressure: 0 inches of mercury vacuum.
- High-pressure: 0 inches of mercury under 200 pounds of charge; 10 inches at 200 pounds or more.
- Medium-pressure: 10 inches of mercury under 200 pounds; 15 inches at 200 pounds or more.
- Low-pressure: 25 mm of mercury absolute.
Small appliances use a percentage test. With newer recovery equipment, recover 90 percent of the refrigerant if the compressor works or 80 percent if it does not. Alternatively, evacuate to four inches of mercury vacuum (40 CFR 82.156(b)). For MVAC-like appliances and MVACs being disposed of, the pressure must be brought to or below 102 mm of mercury vacuum (40 CFR 82.156(c)-(d)).
Two exceptions matter. If the work is not major and you will not evacuate to the atmosphere afterward, you may take a medium-, high- or very high-pressure appliance to 0 psig instead; a low-pressure appliance must be pressurized to no higher than 0 psig (40 CFR 82.156(a)(1)). If leaks make the table levels unattainable, isolate the leaking parts and evacuate the rest to the table level; the leaking parts go as low as possible without contaminating the refrigerant, never above 0 psig (40 CFR 82.156(a)(2)). Refrigerant may be returned to the same appliance, or another one the same person owns, without recycling or reclaiming it, unless it is an MVAC or MVAC-like appliance (40 CFR 82.156(h)).
Leak repair for large appliances
The leak repair section applies to appliances with a full charge of 50 pounds or more of class I or class II refrigerant, and it does not cover appliances holding only substitute refrigerants (40 CFR 82.157(a)). The duty falls on the owner or operator. The leak rate must be calculated each time refrigerant is added (40 CFR 82.157(b)). Trigger rates are:
- 20 percent for commercial refrigeration;
- 30 percent for industrial process refrigeration;
- 10 percent for comfort cooling and other appliances of 50 pounds or more (40 CFR 82.157(c)(2)).
Once an appliance exceeds its rate, leaks must be found and repaired within 30 days of the refrigerant addition, or 120 days if an industrial process shutdown is needed, unless the owner retrofits or retires the appliance. A certified technician must perform the leak inspection (40 CFR 82.157(d)). Each repair needs an initial verification test within that period and a follow-up test within 10 days of the successful initial test, or of the system reaching normal operating conditions if it was evacuated (40 CFR 82.157(e)). Extra time is allowed in limited cases, such as parts that are not available, but not beyond 180 days (270 with a shutdown) from the date the rate was exceeded, and the owner must ask EPA within the original period (40 CFR 82.157(f)).
If repairs fail, or the owner chooses not to repair, a retrofit or retirement plan is due within 30 days, with a completion schedule of no more than one year (40 CFR 82.157(h)). An appliance of 50 pounds or more that leaks 125 percent or more of its charge in a calendar year must be reported to EPA by March 1 of the next year (40 CFR 82.157(j)).
Records
Most records under this section are kept at least three years (40 CFR 82.157(l)). They include the appliance's full charge and how it was determined, a service record each time an appliance of 50 pounds or more is serviced or disposed of, leak inspection results, and verification test results. The person doing the work must give the owner documentation of the refrigerant added or removed and the leak rate details (40 CFR 82.157(b), (l)(2)).
Technicians who evacuate appliances holding more than 5 and less than 50 pounds for disposal keep their own three-year records: company, appliance location, recovery date, refrigerant type, monthly totals and transfers for reclamation or destruction (40 CFR 82.156(a)(3)). Final processors of small appliances keep signed statements or contracts for three years (40 CFR 82.155(c)). Technicians also keep a copy of their certificate at their place of business (40 CFR 82.161(a)(4)).
Practice EPA Section 608 questions with explanations and timed mock exams.