California Global Warming Solutions Act (ab 32): an Introduction to Refrigerant Gas Management

How to stay ahead and address the early action requirements for Stationary Equipment Refrigerant Management to be included in updates to AB 32.

The California Global Warming Solutions Act (AB 32), first passed in 2006 with additional early actions taking effect in 2010, is a broad and comprehensive directive with the goal of reducing greenhouse gasses (GHGs) by approximately 25% by the year 2020. This objective of the early action stems from increases in carbon equivalent emissions in California since 1990. The intent of the legislation to reduce greenhouse gasses to their 1990 levels, thereby reversing 16 years of pollution in less than 14 years.

As part of the California Global Warming Solutions Act (AB 32) the Air Resources Board (ARB) has approved an early action measure to reduce high-global warming potential (GWP) greenhouse gas (GHGs) emissions by establishing new legislation and defining requirements related to improved monitoring of AC/HVAC systems, enforcement of regulations, reporting of refrigerant usage, and recovery, recycling, or destruction of high-GWP refrigerant gases.

The greenhouse gasses (GHGs) as defined by the California's AB 32 are identical to those gasses identified in the Kyoto Protocol. These gases are already being regulated, monitored, and managed by many other countries around the World. In addition to carbon dioxide (CO2), which is the most widely known GHG, the following gasses are also defined as GHGs with high global warming potential (GWP) carbon equivalent emissions by the AB 32 legislation:

* Methane (CH4): a byproduct of waste decomposition, and natural geological phenomena; the majority of methane is derived from natural gas drilling.

* Nitrous Oxide (N2O): a pollutant created by industrial processes, motor vehicle exhaust, and industrial air pollutants reacting with the atmosphere; like methane, nitrous oxide can also be a product of waste decomposition in nature and agriculture.

* Sulfur Hexafluoride (SF6): a gas used for various electrical applications, including gas insulated switchgear. Sulfur Hexafluoride is also used for experimental applications.

* Perfluorocarbons (PFCs) and Hydrochlorofluorocarbons (HCFCs): a collection of commonly used refrigerant and aerosol gasses with a wide variety of other commercial applications. CFCs and HCFCs are considered Ozone Depleting Substances (ODSs), as defined in title VI of the US Clean Air Act (Section 608).

The California EPA's Air Resources Board (CARB) has developed a complex and highly detailed system of greenhouse gas management for refrigerant gasses, known as the Stationary Equipment Refrigerant Management Program, and stricter standards for new or existing refrigeration systems installation and ongoing maintenance. According to CARB this strategy includes careful monitoring of potential refrigerant gas leaks, improved record keeping and certification of personnel as well as specifications for PFC and HCFC recovery equipment.

The proposed Stationary Equipment Refrigerant Management Program, which integrates two AB 32 early action measures, addresses the detailed monitoring and management of the PFCs and HCFCs noted above and includes tracking requirements for new and existing commercial and industrial refrigeration systems. Likely to be implemented by January, 2010, is the monitoring and management of high global warming potential (GWP) refrigerants in large systems in the range of 2,000 pounds of refrigerant gas.

CARB is charged with the monitoring GHGs and high GWP gasses, as well and the eventual development and enforcement of specific and quantitative new regulations covering carbon related emissions which refrigerant management with the tracking, reporting, cylinder management, and gas recovery for stationary refrigerant and air conditioning (AC) systems all becoming key integral parts.

The CARB proposal could also involve fines for mismanagement of refrigerant record keeping, intentional venting of systems, and the inability to regularly submit the required refrigerant usage reports. The California Air Resources Board (CARB) is an extension of the EPA and works to monitor and enforce the US Clean Air Act. Section 608 of the Air Act regulates refrigerant gas usage, leaks, recovery, and annual reporting.

The overall intent of CARB's strategy is to monitor and reduce the introduction of man-made GHGs and high GWP gasses into the atmosphere, as called for in the California Global Warming Solutions ACT (AB 32) in effect since 2006 with tighter controls, monitoring, and overall regulations becoming enforceable by early 2010.

Refrigerant gas monitoring, tracking, and management are important business planning considerations. Just like organizations manage assets, like a delivery truck, the consequences the release of high GWP gases, such as refrigerant gases, must be consider. Refrigerants cost money, harm the ozone and environment, and are subject to mandatory carbon emissions reporting. As organizations with AC/HVAC systems containing refrigerant gas of 50 pounds or more will soon find out, the effective monitoring, management of data, and systematic reporting of refrigerant usage will be key to business success in our emerging carbon economy.