Industrial process refrigeration systems (chemical, pharmaceutical, petrochemical, and manufacturing industries, ice machines, appliances used directly in the generation of electricity, and ice rinks)
Comfort cooling (residential, office, and commercial building chillers, commercial split systems, and packaged roof-top units).
EPA has identified the following industries/facilities as potentially subject to this regulation: food handling and retail operations, pharmaceutical, aerospace, hotels, casinos, superstores, warehouse clubs, industrial plants, manufacturing, government buildings, hospitals, schools, universities and research facilities.
Practical Implications
Owners or operators of appliances that contain 50 or more pounds of ozone depleting refrigerant must keep service records documenting the date and type of service and the quantity of refrigerant added. Starting January 1, 2019, this requirement will apply to a broad range chlorofluorocarbon and other refrigerants.
Owners/operators will also be required to maintain records of leak inspections and tests performed to verify repairs of leaking appliances. Depending on the appliance type, refrigerant leak rates as low as 10 percent per year trigger mandatory corrective action (repair within 30 days or develop a plan to retrofit or retire the appliance within one year). Initial and follow-up verification tests at the conclusion of repair efforts will be required.
On-site records of maintenance, service, repair and disposal must be maintained and available for inspection. Certain events will require facilities to report directly to the EPA.
TRC can assess how this rule may apply to your business operations. We can conduct an audit of your current compliance program and recommend actions to ensure compliance going forward. Our experts can design a compliance schedule, recordkeeping system and leak rate calculator tailored to your operations in order to meet EPA’s requirements. TRC can also conduct follow-up audits to confirm compliance or identify areas for improvement in your compliance program.
Ruthanne Calabrese is a Senior Project Manager with the Environmental Services unit at TRC’s Windsor, Conn. office. She has more than 20 years of experience managing environmental compliance and strategy within the utility industry. She has extensive experience developing risk mitigation plans for priority environmental compliance risks, providing policy impact analysis, advocating for utility companies during rule development, fostering and maintaining key stakeholder relationships, and developing communications regarding company’s environmental performance and positioning. You can reach Ruthanne at (869) 298-6359 or RCalabrese@trcsolutons.com
Appliance Disposal Facilties 
