EPA Update

March 22, 2016

Stratospheric Protection Division

U.S. Environmental Protection Agency
• Background on HFCs 

• Climate Action Plan

• Domestic Regulatory Activity

– Significant New Alternatives Policy (SNAP) 

Program

– Section 608 Refrigerant Management Regulations

• GreenChill

• International Activity

Overview
UNEP 2011

Why Are HFCs a Concern?

• HFCs are synthetic fluorinated greenhouse gases (GHGs)

• Use and emissions of HFCs are growing rapidly, because they are 

replacement for ozone-depleting substances (ODS) being phased out 

under the Montreal Protocol

• Without action, U.S. HFC emissions 

were expected to double from current 

levels by 2020, and triple by 2030

• HFCs are used in:

– Air Conditioning (A/C)

– Refrigeration

– Foam Blowing

– Fire Suppression

– Aerosols

– Solvents
Climate Action Plan: HFCs

• Continue international diplomacy

– Lead negotiations under the Montreal Protocol to phase down HFCs

• Global phase-down could reduce more than 90 gigatons of CO2eq by 2050, equal t

roughly two years worth of current global GHG emissions 

– Work with partners in the Climate and Clean Air Coalition to reduce short-lived 

climate pollutants to: 

• promote climate-friendly alternatives to high-GWP HFCs 

• address technical standards

• reduce emissions from HFC use 

• Address HFCs through domestic actions

– Use existing Clean Air Act authority of SNAP Program to approve climatefriendly 

chemicals, prohibit some uses of most harmful

– Provide federal leadership by purchasing cleaner alternatives to HFCs 

whenever 

feasible and by transitioning to equipment using safer, more sustainable 

alternatives

– Apply refrigerant management requirements to HFCs
Private Sector Commitments

• The private sector is also moving forward

• The White House announced private commitments 

at events in October 2015 and September 2014

– Actions would reduce global GHG emissions by 1 million 

metric tons CO2 equivalent by 2025

– Equal to taking 210 million cars off the road for a year

• Companies are going above and beyond the regulations 

through GreenChill and RAD
• Acceptable — those that reduce overall risk to human health & 

environment

• Acceptable with use restrictions — if needed to ensure safe use

• Unacceptable

Evaluates alternatives and lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire Suppression; 

Adhesives, Coatings, Inks, etc.

Sectors include:

• Ozone-Depleting Potential

• Global Warming Potential

• Flammability

• Toxicity

Considers (among other factors): 
• SNAP rules consider individual end uses

• No across the board GWP cutoffs; no “bright lines”

• No prohibition on HFCs as a whole, or in any one sector

• New HFCs or HFC blends may be listed if risk not greater 

than other available substitutes 

• We recognize that timing is a critical dimension and that 

each end use has unique considerations 

• Status change actions will be issued through notice and 

comment rulemaking

Guiding Principles
• Issued two acceptability 

notices adding 

alternatives

• Issued new rule adding 

five low-GWP flammable 

refrigerants with use 

conditions 

• Published Status Change 

Rule prohibiting certain 

HFCs in certain end uses

• HFC Emissions 

Reductions: 54–64 MMT 

CO2eq in 2025

Near-term 

changes can 

provide both nearand long-term 

benefits.

Recent Actions
R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430

1233zd(E) heat transfer & flexible PU foams 

GWP <7 compared to alternatives:1070–4000

CO2 refrigerated transport

GWP: 1 compared to alternatives: ~1400–4000 

Methylal foam blowing end uses

GWP <3 compared to alternatives: 725–1430 

HFO-1336mzz(Z) foam blowing end uses

GWP: ~9 compared to alternatives: 725–1430

Powdered Aerosol D fire suppression

GWP <25 compared to alternatives: 0–3500

R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430 

R-448A (HFC/HFO blend) RefAC

GWP: 1387 compared to R-404A: 3922

R-513A (HFC/HFO blend) RefAC

GWP: 630 compared to HFC-134a: 1430

R-449A (HFC/HFO blend) RefAC

GWP:1397 compared to R-404A: 3922

HFO-1336mzz(Z) foam blowing end uses

GWP: ~9 compared to HFC-245fa: 1030

MPHE RefAC, solvent cleaning aerosols 

and adhesives/coatings

GWP <3 compared to alternatives: 0–3500

October 2014 July 2015

Acceptability Notices
• Use conditions required to address flammability

• New equipment only

* End uses are in addition to those previously listed by EPA, including those listed in 2011.

Refrigerant GWP

End Use and Application* 

Household 

Refrigerators

Retail

Refrigerator 

Stand-alone

Vending

Very Low-Temp 

Ref.

Heat Transfer

Room AC

Self-contained

Ethane 6 √ √

Isobutane 8 √ √

Propane 3 √ √ √

R-441A (HC blend) <5 √ √ √

HFC-32 675 √

2015 Low-GWP Refrigerants 

Rule
July 2015 Change of 

Status Rule

 HFC-125 — January 2016

 HFC-227ea and Blends — July 20, 2016

 HFC-134a — July 20, 2016/January 1, 2018

 HFC-134a in New Light-Duty Systems — MY 2021

 HCFC and HFC-Containing Blends in New LightDuty Systems — MY 2017

 New Supermarket Systems — January 2017

 New Remote Condensing Units — January 2018

 New Vending Machines — January 2019

 New Stand-Alone Units (small medium-temp, large medium-temp, 

low-temp) — January 2019/January 2020

 Retrofitted Retail Food Refrig. Equipment and Vending Machines —

July 20, 2016

 All End Uses, Except Rigid PU Spray Foam — Various 

Dates Between January 2017–January 2021

Motor Vehicle 

Air Conditioning

Aerosols

Retail Food 

Refrigeration and 

Vending Machines

Foams
September 2015 Stakeholder 

Meeting

The EPA is considering a future proposed rule that could include:

• Listing of acceptable alternatives with use conditions

– Use conditions would mitigate risks, e.g., flammability, exposure limits

• Listing of unacceptable alternatives

– Where risks cannot be mitigated sufficiently, e.g., flammability, toxicity, 

air quality impacts, climate

• Change of listing status from acceptable to unacceptable

– EPA contemplating changes for equipment categories not addressed in 

July 20th final rule

– End uses based on stakeholder comments and EPA analysis could include:

• Refrigeration and A/C: e.g., chillers, refrigerated food processing and 

dispensing, household refrigerators and freezers, cold storage warehouses

• Rigid PU spray foam; fire suppression
Purpose of Section 608 of Clean Air Act: Reduce emissions of 

ozone-depleting substances (ODS) and substitute refrigerants 

during 

the maintenance, service, repair and disposal of appliances

Current requirements include:

• Prohibition against knowingly venting ODS and substitute 

refrigerants

• Service practices (ODS)

• Safe disposal requirements (ODS)

• Leak repair and prevention for larger appliances (ODS)

National Refrigerant 

Management Program
Service

Practice 

Requirements

Technician 

Certification

Refrigerant

Recovery and 

Recycling

Equipment

Refrigerant 

Leaks

Refrigerant

Sales 

Restrictions

Major Recordkeeping 

Requirements

Safe Disposal 

Requirements

Reclamation

Overview of Current

Requirements
Goals of 608 Updates

• Larger Context:

– Climate Action Plan

– Industry petition to create a level playing field for commonly used 

refrigerants

– Continue to reduce emissions of ozone-depleting refrigerants

• Immediate Goals:

– Extend Section 608 requirements to HFCs and other substitutes that 

are not exempt from the venting prohibition (“non-exempt 

substitutes”) 

– Decrease leaks from large appliances

– Enhance clarity and ease of compliance 

– Strengthen incentives that support careful management of 

refrigerants
If finalized, the proposal would*:

 Lower applicable leak rates 

–From 35% to 20% commercial and industrial process refrigeration 

–From 15% to 10% for comfort cooling appliances

 If leak rate exceeds applicable leak rate, owner/operator must:

–Conduct leak inspection 

–Repair all identified leaks within 30 days and verify repairs are successful

• Time extensions available

–If leaks cannot be repaired, develop retrofit/retirement plan within 30 days

–Complete appliance retrofit/retirement within one year

 Require periodic leak inspections 

 Establish a two-year leak limit of 75%

 Update recordkeeping requirements

Proposed Changes: Appliance 

Maintenance and Leak Repair

* The proposed requirements on this slide would only be applicable to appliances with 50 or more pounds of refrigerant charge.
• Currently: Technicians working on equipment containing ODS 

refrigerants must be certified and follow servicing practices, such 

as recovering refrigerant from an appliance before servicing

• Proposal extends requirements to apply to HFCs and other 

non-exempt substitutes

• Proposal would also require technicians to keep records of 

refrigerant recovered when disposing of appliances between 5–50 

pounds

– Current gap in recordkeeping requirements for equipment between 

5 and 50 pounds

– Recordkeeping includes the amount of refrigerant recovered at 

disposal 

and the final disposition of refrigerant removed from appliances

Servicing and Disposal 

Practices
Other Proposed Changes 

to 608

Extend to 

Substitutes

 All non-exempt refrigerants in small appliances, MVACs 

must be recovered before disposal

 Technicians must be certified to purchase all non-exempt 

substitutes, with exemption for small cans

 Tech certification companies must publish lists of who 

they certify (prospective, with opt-out for privacy)

 Remove reporting requirement for ownership of recovery 

equipment; require use of recovery equipment instead

 Restructure to better group requirements and improve 

language clarity

Simplify, 

Improve

 Update AHRI 700 reclamation standard used

 Update AHRI 740 recovery equipment standard used, 

add safety parameters for flammable refrigerants 

(UL 1963, supplement SB)

Update 

Standards
If finalized as proposed, the rule would result in:

Benefits

Annual GHG 

Reductions

(MMTCO2eq)

Annual ODS 

Reductions

(ODP-weighted MT)

Annual Incremental 

Compliance Cost 

(millions)

7.5 116 $63

 7.5 MMTCO2eq of GHG emissions reductions is the same as taking 

about 1.6 million cars off the road for a year

 We anticipate the regulated community would also experience 

$52 million in cost savings related to reduced purchases of refrigerant
Outreach/Stakeholder Engagement in Rule 

Development Phase

• November 2014 stakeholder meeting, 50+ participants

• More than 50 meetings with industry, environmental 

groups, trade associations, states

Timeline

• November 9 — Proposed rule published in Federal 

Register (80 FR 69457)

• January 25 — Deadline to submit written comments

• Currently reviewing comments and crafting a final rule

Outreach and Next Steps
GreenChill Partner Reporting

Due date for reporting -- March 31, 2016

• Data on installed refrigerants and emissions in 2015

• Refrigerant management plan for 2016 with 2016 

emission goal
A Changing World – A Changing 

Industry

19.5%

63.8%

0.1%

9.4%

0.0%6.5% 0.7%

2007

44.8%

30.5%

10.5%

5.3%

1.1%

5.8% 2.1%

2014



HFCs and the Federal Sector

• U.S. government is a large purchaser of 

goods and services 

– Fleet inventory (owned/leased): >635,000 

vehicles1

– Buildings (owned/leased): >353,000 buildings2

– Spending on supplies and equipment: nearly 

$191 billion each year

– $222 million on refrigeration and AC3

• In 2010, federal agencies reported HFC 

emissions of nearly 2.2 MMTCO2e4

1 U.S. General Services Administration (GSA) 2013. Index of Data, Federal Fleet Report 

for FY 2013. 2 U.S. GSA 2013. FY 2013 Federal Real Property Profile (FRPP) Summary Data Set. 3 Federal Procurement Data System 2007. Federal Procurement Report FY 2007. 4 Data.gov. 2011. FY2010 Federal Government Greenhouse Gas Inventory by Agency.
Federal Actions 

Addressing HFCs

• FAR proposed rule (May 11, 2015) addressed HFCs by directing 

the government to procure alternatives to high-GWP HFCs:

– Where feasible, substitute acceptable alternatives as identified 

by SNAP program

– Vendor reporting on use of HFCs (i.e., refrigerants)

– Final rule expected in 2016

• EO 13693 (March 19, 2015) — Planning for Federal 

Sustainability in the Next Decade 

– Direct GHG emissions reduced by at least 

40% by 2025

– Agencies to purchase sustainable products 

and services identified by EPA Programs, 

including alternatives to ODS and high-GWP 

HFCs, where feasible, as identified by SNAP
• Revamped EPA SNAP website

– http://www.epa.gov/snap

– Enhanced user friendliness for 

federal consumers to learn about 

acceptable alternatives

• Federal HFC emissions accounting tool

• Fact sheets

– General: HFCs used by federal agencies

– Sector-specific: HFC uses and alternatives

• Case studies

– Commercial refrigeration system at Lackland

Air Force Base Commissary (San Antonio, TX)

Support Materials Available
International Activities

• Since 2009, the United States, partnering with 

Canada and Mexico, have been pursuing an 

amendment to phase down HFCs under the Montreal 

Protocol

– Proposals would phase DOWN, not OUT, global HFC

production and consumption

• In Nov. 2015, parties reached an agreement on the 

Dubai Pathway to work to an amendment in 2016

– An amendment would achieve substantial greenhouse gas 

reductions and could avoid up to 0.5 degrees Celsius of 

warming by 2100

• Amending the Montreal Protocol would pave the way 

for all countries to transition away from using highGWP HFCs
BACKGROUND SLIDES
Proposed Changes: Leak Repair

Action/Topic Current Proposed Change

Appliances affected All ODS appliances with full 

charge of 50 lbs or more 

All appliances with full charge of 

50 lbs or more of non-exempt 

refrigerants (e.g., ODS, HFCs)

Leak rate

Leak rate is 35% for 

refrigeration appliances and 

15% for comfort cooling

Lower to 20% and 10%, 

respectively; would exempt 

seasonal variances from counting 

toward leak rate

When leak rate 

exceeds trigger rate

Repair leaks within 30 days 

such that the leak rate is 

brought below the trigger rate

Conduct leak inspection and 

repair all identified leaks within 30 

days

How to verify repairs

Initial and follow-up verification 

tests required for IPR and 

federally owned appliances

Initial and follow-up verification 

test required for all affected 

appliances

If owner/operator 

fails to repair within 

30 days

Must develop a 

retrofit/retirement plan Unchanged

Timeline for 

retrofit/retirement 

plans

Appliance must be retrofitted 

or retired within one year Unchanged
32

Proposed Changes: 

Repair Extensions

Action/Topic Current Proposed Change

Extensions to 30-day 

repair timeline

If appliance or isolated appliance 

component is mothballed Unchanged

Up to 120 days for an industrial 

process shutdown Unchanged

If federal, state or local regulations 

prohibit timely repairs (IPR only)

Would be extended to all 

affected appliances

If necessary parts are not available 

(IPR only)

Would be extended to all 

affected appliances but capped 

at 180 days

If appliance is located in an area 

subject to radiological 

contamination or where the 

shutting down of the appliance will 

directly lead to radiological 

contamination (federally owned 

only)

Would be extended to all 

affected appliances

Extension request required for all 

but mothballing and IPR shutdown Unchanged
Proposed Changes: 

Retrofit/Retirement

Action/Topic Current Proposed change

Extensions to the oneyear retrofit/ retirement 

timeline

If appliance or isolated appliance 

component is mothballed Unchanged

If federal, state or local regulations 

prohibit timely retrofit (IPR only) Unchanged

If a suitable replacement refrigerant with 

a lower ozone depletion potential is 

unavailable (IPR only)

Removed

If a critical component of a custom-built 

IPR appliance is not available on time 

(IPR only)

Largely unchanged

If complications are presented by the 

federal agency appropriations and/or 

procurement process (federally owned 

only)

Unchanged

If appliance is located in an area subject 

to radiological contamination and 

creating a safe working environment will 

require more time (federally owned only)

Unchanged

Up to 18 months if replacement 

appliance 

uses an exempt refrigerant
• Establish a two-year leak limit

– Prohibit an appliance from leaking more than 75% of its full charge in two 

consecutive years

– If leak amount exceeded, appliance would need to be retired or mothballed

Example

– Appliance leaks 80% of its full charge between Jan. 1 and Dec. 31, 2018 

– From Jan. 1, 2019 to Dec. 31, 2019, the appliance could not leak more than 

75% of its full charge

– If above 75% in 2019, appliance would need to be retired or mothballed

• Taking comment on:

– Whether to allow for retrofit/retirement plan in lieu of mothballing

– Whether to provide an exception for unavoidable catastrophic leaks

– How the time frame should be set up: two consecutive years? Time periods 

based on calendar year or rolling?

Proposed Changes: Leak Limit
• Require regular leak inspections, unless regularly calibrated 

automatic leak detection equipment installed

– Quarterly for 500+ pound commercial refrigeration and IPR

• Annual inspections allowed if no refrigerant has been added in the past 365 days

– Annually for all other appliances with 50 or more pounds

– Proposing lower and higher charge thresholds for annual vs. quarterly

• Leak inspection would include examination of the refrigerant 

circuit of an appliance using:

– a calibrated leak detection device

– bubble tests

– visual inspection for oil residue

• Proposing to allow leak inspections be conducted by staff 

other than a certified technician

Proposed Changes: 

Leak Inspections
Proposed Changes: 

Recordkeeping

• Technicians would provide records for owners/operators that 

include: 

– (1) the identity and location of the appliance

– (2) the date and type of maintenance, service, repair or disposal 

performed, 

including the location of repairs and the results of any verification tests or 

leak inspections (if applicable)

– (3) the name and affiliation of the service technician 

– (4) the amount and type of refrigerant added to and/or removed from the 

appliance (if applicable)

– (5) the full charge of the appliance

– (6) the leak rate and the method used to determine the leak rate

• Owners/Operators would keep all service records, leak inspection 

results, full charge calculations, verification test results, 

retrofit/retirement plans, extension requests, etc. 

• EPA encourages electronic recordkeeping systems