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Refrigerant Management Services
Yorke Refrigerant Compliance Services
- Regulatory Analysis – Evaluate your facility’s refrigerant inventory to determine applicability under EPA 40 CFR 84, CARB RMP and/or local air district rules such as South Coast Air Quality Management District (SCAQMD) Rule 1415, identify compliance gaps, and establish a tailored compliance roadmap.
- Compliance Tracking – Set up systems for ongoing tracking of refrigerant usage, leak repairs, service records, and reporting deadlines to ensure continuous compliance.
- CARB & Air Quality Management District (AQMD) Refrigerant Management Reporting – Prepare and submit annual refrigerant management reports required by CARB and local air districts. While reporting requirements remain unchanged, our team ensures accuracy and timely submittals, reducing the administrative burden on your staff.
EPA 40 CFR 84 (Subparts A-C)
The U.S. EPA regulates refrigerants under the Clean Air Act, primarily to reduce emissions of ozone-depleting substances (ODS) and high-global-warming-potential (GWP) Hydrofluorocarbons (HFCs). The emission reductions from HFCs are covered by three regulations under 40 CFR 84:
The HFC Allocation Regulations (40 CFR 84 Subpart A) establish an allocation program to reduce HFC importation and bulk production and allow critical applications to receive access to these allowances.
The HFC Technology Transition Regulations (40 CFR 84 Subpart B) facilitate trans to newer technologies by restricting certain HFCs in aerosol, foam, refrigeration, air conditioning, and heat pump sectors in new equipment.
The HFC Management Regulations (40 CFR 84 Subpart C) aim to maximize reclamation and minimize releases from HFCs and their substitutes during equipment installation, service, repair, and maintenance.
Key requirements include:
- Inspecting equipment leaks and making repair schedules;
- Recordkeeping of refrigerant use, servicing, and disposal;
- Understanding restrictions on venting, sales, and handling of regulated refrigerants; and
- Recovering and recycling practices during servicing and disposal.
Beginning in 2026, Subpart C lowers the federal applicability threshold to 15 pounds of refrigerant, compared to CARB’s 50-pound cutoff; it will include comfort cooling units not covered under RMP. This means EPA requirements will apply to systems not currently covered under CARB.
CARB Refrigerant Management Program (RMP)
While EPA regulations apply nationwide, California’s CARB program imposes additional requirements for larger systems. CARB’s RMP applies to facilities operating refrigeration systems containing 50 pounds or more of high-GWP refrigerant. Compliance obligations vary based on system charge size, and may include:
- Facility registration and reporting to CARB;
- Leak detection and monitoring requirements;
- Timely leak repair and follow-up verification; and
- Annual reporting of refrigerant use, leaks, and service activities.
AQMD Reporting
Local air districts may require additional recordkeeping, service, maintenance, and reporting not covered under CARB. For example, SCAQMD Rule 1415 requires biennial registration/reporting for comfort cooling equipment with at least 50 pounds of refrigerant. Unlike CARB’s RMP, AQMD rules often apply to comfort cooling equipment, which CARB exempts.
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Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC
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