Refrigerant Compliance Management 1 / 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC REFRIGERANT COMPLIANCE MANAGEMENT CUSTOMIZED

Refrigerant Compliance Management 1 / 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC

REFRIGERANT COMPLIANCE MANAGEMENT

CUSTOMIZED ENVIRONMENTAL TRAINING


INSTRUCTOR

Insert Instructor Name Here


Discuss Industrial Process Refrigeration.

Discuss the Requirements of the Refrigerant Recycling Rule.

Discuss How to Determine Full Charge of A System.

Discuss How to Calculate Leak Rate.

Discuss When to Make Leak Repairs.

Discuss the Requirements for Retrofit and Retirement.

Discuss the Requirements for Oil Changes.

Discuss Disposal Requirements.

Discuss Reports and Recordkeeping.

Discuss Use of Contractors.

OBJECTIVES


Understand Industrial Process Refrigeration.

Understand the Requirements of the Refrigerant Recycling

Rule.

Be Familiar With How to Determine Full Charge of A System.

Understand How to Calculate Leak Rate.

Understand When to Make Leak Repairs.

Understand the Requirements for Retrofit and Retirement.

Understand the Requirements for Oil Changes.

Understand Disposal Requirements.

Be Familiar With Required Reports and Recordkeeping.

GOALS


BACKGROUND

Ozone depleting substances (ODS) are found in certain refrigerants manufactured before 1995.

The United States and over 150 other countries signed the Montreal Protocol that pledges the phasing out of ODS by the end of 1995.

EPA is authorized to assess fines of up to $27,500 per day for any violation of ODS regulations.


Supervisors

Facility Engineers

Maintenance Personnel

Department Managers

Building Occupants

Process Specialists

Environmental and Safety Committees

LEARNERS


The goal of this course is to provide supervisors with the tools needed to stay in compliance with the Clean Air Act Amendments relevant to industrial process refrigeration systems. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good industrial process refrigeration management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities.

OVERVIEW


WHAT THIS COURSE DOES NOT DO

The course is not intended to provide information on the requirements for other types of refrigeration equipment or how to do everything required or permitted by the Clean Air Amendments, such as how to perform a leak test using an ultrasonic leak detector. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.


CLEAN AIR ACT AMENDMENTS (CAAA)

Title VI, entitled Stratospheric Ozone Protection, is generally directed toward eliminating the threat posed to the earth’s protective stratospheric (or high-level) ozone layer by certain ozone-depleting substances (ODSs)


FEDERAL REGULATIONS

Pertinent Regulations:

40 CFR Part 82, Subpart F


REQUIREMENTS

Require service practices that maximize recycling of ozone-depleting compounds (both chlorofluorocarbons [CFCs] and hydrochlorofluorocarbons [HCFCs] and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment Set certification requirements for recycling and recovery equipment, technicians, and reclaimers Restrict the sale of refrigerant to certified technicians Require persons servicing or disposing of air-conditioning and refrigeration equipment to certify to EPA that they have acquired recycling or recovery equipment and are complying with the requirements of the rule


REQUIREMENTS

Require the repair of substantial leaks in air-conditioning and refrigeration equipment with a charge of greater than 50 pounds Establish safe disposal requirements to ensure removal of refrigerants from goods that enter the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, and room air conditioners)


APPLICABILITY

Industrial process refrigeration used in the chemical, pharmaceutical, petrochemical, and manufacturing industries This sector also includes industrial ice machines, appliances used directly in the generation of electricity, and ice rinks The refrigerant recycling rule applies to systems that contain and use a class I or class II substance as a refrigerant:•Class I refrigerants are mostly chlorofluorocarbon (CFC) refrigerants or any mixture containing a CFC•Class II refrigerants are hydrochloro-fluorocarbon (HCFC) refrigerants or any mixture containing an HCFC


APPLICABILITY

Applicability Triggers The leak repair requirements of this regulation are triggered when an owner or operator of an industrial process refrigeration system discovers that refrigerant is leaking at a rate that would exceed 35 percent of the total charge in a 12-month period


APPLICABILITY

Trigger Rates

For all systems that have a refrigerant

charge of more than 50 pounds:

SYSTEM RATE

Commercial refrigeration 35%

Industrial process refrigeration 35%

Comfort cooling 15%

All other refrigeration 15%


APPLICABILITY

EXEMPTIONS OR EXCLUSIONS Leak repair provisions of this regulation do NOT affect systems normally containing 50 pounds or less of refrigerant


PROHIBITION ON VENTING

Section 608 of the Act prohibits individuals from knowingly venting ozone-depleting compounds used as refrigerants into the atmosphere Only four types of releases are permitted under the prohibition:

1. "De minimis" quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant

2. Refrigerants emitted in the course of normal operation of air-conditioning and refrigeration equipment such as from mechanical purging and leaks


PROHIBITION ON VENTING

3. Releases of CFCs or HCFCs that are not used as refrigerants

4. Small releases of refrigerant that result from purging hoses or from connecting or disconnecting hoses to charge or service appliances will not be considered violations of the prohibition on venting


RECLAMATION REQUIREMENT

EPA has also established that refrigerant recovered and/or recycled can be returned to the same system or other systems owned by the same person without restriction If refrigerant changes ownership, however, that refrigerant must be reclaimed Refrigerant used in MVACs and MVAC-like appliances is subject to the purity requirements of the MVAC regulations at 40 CFR Part 82 Subpart B EPA updates the list of reclaimers as new companies are added.


EQUIPMENT CERTIFICATION

EPA has established a certification program for recovery and recycling equipment EPA has approved both the Air-Conditioning and Refrigeration Institute (ARI) and Underwriters Laboratories (UL) to certify recycling and recovery equipment Certified equipment can be identified by a label reading: "This equipment has been certified by ARI/UL to meet EPA's minimum requirements for recycling and/ or recovery equipment intended for use with [appropriate category of appliance--e.g., small appliances, HCFC appliances containing less than 200 pounds of refrigerant, all high-pressure appliances, etc.]"


TECHNICIAN CERTIFICATION

EPA has established a technician certification program for persons ("technicians") who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphereThe definition of "technician" specifically includes certain activities as follows: attaching and detaching hoses and gauges to and from the appliance to measure pressure within the appliance; adding refrigerant to or removing refrigerant from the appliance any other activity that violates the integrity of the MVAC-like appliances, and small appliances.


TECHNICIAN CERTIFICATION

Apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician The Agency has developed four types of certification: 1. For servicing small appliances (Type I). 2. For servicing or disposing of high- or very high-pressure appliances, except small appliances and MVACs (Type II). 3. For servicing or disposing of low-pressure appliances (Type III) 4. For servicing all types of equipment (Universal). Technicians are required to pass an EPA-approved test given by an EPA-approved certifying organization


REFRIGERANT SALES RESTRICTIONS

Effective November 14, 1994, the sale of refrigerant in any size container is restricted to technicians certified either under the program described previously in Technician Certification or under EPA's motor vehicle air conditioning regulations The sales restriction covers refrigerant contained in bulk containers and pre-charged parts The restriction excludes refrigerant contained in refrigerators or air conditioners with fully assembled refrigerant circuits


CERTIFICATION

Certification by Owners of Recycling and Recovery Equipment EPA requires that persons servicing or disposing of air-conditioning and refrigeration equipment certify to the appropriate EPA Regional Office that they have acquired recovery or recycling equipment and that they are complying with the applicable requirements of this rule This certification must be signed by the owner of the equipment or another responsible officer and sent to the appropriate EPA Regional Office


RECLAIMER CERTIFICATION

Reclaimers are required to return refrigerant to the purity level specified in ARI Standard 700-1993 Reclaimers must release no more than 1.5 percent of the refrigerant during the reclamation process and must dispose of wastes properly Reclaimers must certify to the Section 608 Recycling Program Manager at EPA headquarters that they are complying with these requirements and that the information given is true and correct EPA encourages reclaimers to participate in a voluntary third-party reclaimer certification program operated by the Air-Conditioning and Refrigeration Institute (ARI) EPA maintains a list of approved reclaimers


FULL CHARGE

The full charge is the amount of refrigerant necessary for an industrial process refrigeration system to operate at normal operating characteristics and conditions There are two reasons why you need to know how much refrigerant is in the full charge for a system:

1. The leak repair requirements of this law do not apply to any system whose full charge is 50 pounds or less of refrigerant in any independent refrigerant circuit

2. To calculate the leak rate for a system, you need to know the full charge


FULL CHARGE

To determine the full charge, you must use one of the following five methods:

1. Measure the refrigerant

2. Calculate the weight of the refrigerant charge in the system

3. Use the manufacturer's information

4. Establish range

5. Use a combination of 1-4


LEAK RATE

Each time you add refrigerant to a system normally containing 50 pounds or more of refrigerant, you should promptly calculate the leak rate. If the leak rate is higher than the trigger rate, you are required to do one of the following:

a. Repair leaks;

b. Retrofit the system; or

c. Retire the system from service.


LEAK RATE

Four Steps to Calculating a Leak Rate

1. #lbs refrigerant added

#lbs refrigerant in normal full charge

2. #days since refrigerant last added

365 days


LEAK RATE

Calculating a Leak Rate continued

3. Take the number you determined in step 1 and divide it by the number you determined in step 2.

4. Multiply the number you determined in step 3 by 100 (to calculate a percentage).


LEAK RATE

Timing After refrigerant is added, you should calculate the leak rate as soon as you can If the system is leaking above the trigger rate, the law imposes strict deadlines for repairing the leaks or retrofitting or retiring the system For example, if you wait three days to determine the leak rate, there will be three less days available to solve the problem


LEAK RATE

Purged Refrigerant In calculating the leak rate, you may exclude purged refrigerant that is destroyed A destruction efficiency of at least 98 percent is required There are monitoring, recordkeeping, and reporting requirements


LEAK RATE

Recordkeeping/Reporting

Keep records that show:

1. The date and type of service;

2. How much refrigerant was added; and

3. The date when the refrigerant was added

It may be required and is always advisable to keep records of the full charge and leak rate


LEAK REPAIR

If a system is leaking above the trigger rate, leak repairs are required within 30 days of discovery Repairs must bring the annual leak rate below the trigger rate Leak repairs are not required if you retrofit or retire the system


LEAK REPAIR

Industrial Process Shutdown

When an industrial process shutdown is needed to repair leaks from industrial process refrigeration systems, a 120-day repair period (rather than a 30-day period) is allowed.


LEAK REPAIR

Unavailable Repair Parts or Other Regulations That Require Additional Time Additional time beyond the 30- or 120-day time periods is allowed to conduct leak repairs if the necessary repair parts are unavailable or if other applicable federal, state, or local regulations make a repair within 30 or 120 days impossible EPA must be notified if repairs cannot be completed within 30 or 120 days of discovery Only the additional time needed to receive delivery of the necessary parts or comply with the pertinent regulations will be permitted


LEAK REPAIR

Repair Verification: There is a requirement to verify the success of leak repairs for industrial process refrigeration systems Two tests, called “initial” and “follow-up” verification tests are required for each repair site A successful test verifies that a leak has been repaired


LEAK REPAIR

What are these tests for? The primary purpose of the initial verification test is to verify that a leak or leaks have been repaired before refrigerant is added back to the system Even when the system is not evacuated to complete repairs, initial and follow-up verification tests are required The primary purpose of the follow-up verification test is to re-verify that repairs continue to hold after the system is returned to its normal operating Characteristics or conditions


LEAK REPAIR

Initial Verification Test An initial verification test must be conducted following any leak repairs A refrigeration system may not be brought back on line (if it has been taken off line), unless a) an initial verification test indicates that repairs have been successfully completed or b) a decision to retrofit or retire is made. The initial verification test must be conducted before the replacement of the full charge of refrigerant In systems that have not been evacuated, the initial verification test must be conducted as soon as practicable after the repair work is completed


LEAK REPAIR

Follow-up Verification TestA follow-up verification test must be conducted: Within 30 days after the initial verification test, where normal operating characteristics or conditions have been maintained; or Within 30 days of bringing the system back on line, if taken off line, and where the system is operating at normal operating characteristics or conditions. In certain cases the results of a follow-up verification test may be less reliable if the test is conducted at normal operating characteristics or conditions


LEAK REPAIR

Initial and Follow-up Verification Test Methods Initial and follow-up verification tests may use any method that meets sound professional judgment Examples include: A soap bubble test; orElectronic leak detectors; orUltrasonic leak detectors; orA pressure test; orA vacuum test; orA fluorescent dye and black light test; orAn infrared test or near infrared; orHalon refrigerant gas detection methods


LEAK REPAIR

Unsuccessful Tests If you have an unsuccessful follow-up verification test, you must notify EPA and develop a retrofit or retirement plan within 30 days of the failed test If it is going to take you more than one year you must also submit the plan If the follow-up verification test indicates that the repairs to the system have not been successfully completed, the owner or operator is required retrofit or retire the system There are some options where the owner or operator is relieved of the obligation to retrofit or retire the system


LEAK REPAIR

Activity Technician Required?

Evacuating the refrigerant Yes

Adding refrigerant Yes

Changing the oil Yes

Adding oil Yes

Replacing a gauge Yes

Changing or calibrating a DP cell Yes

Changing a pressure-relief valve Yes

Drawing a sample of refrigerant or oil Yes


LEAK REPAIR

Activity Helping dismantle a system for disposal

Any of the tasks listed so far, performed under the direct supervision of a certified technician

Maintenance that would not reasonably release refrigerant

Fixing leaks by tightening nuts or bolts, if no specific reason to think the activity may go wrong and increase the rate of release

Any work on the system after the refrigerant has been evacuated

Technician Required?

Yes

Yes

No

No

No


RETROFIT AND RETIREMENT

Owners or operators are not required to repair leaks if they develop, implement, and complete a 12-month retrofit or retirement plan Three conditions, however, must be met:1. The retrofit or retirement plan must be developed within 30 days of detecting the leak and a copy must be kept on site; and2. The plan must be dated and the original made available for EPA inspection upon request; and3. Retrofit or retirement activities must be completed within a 12-month period of the plan's date



Time Extensions for Retrofit or Retirement of Industrial Process Refrigeration Systems Additional time beyond the initial 12-month period is allowed for the following three circumstances occur:

1. A delay is caused by the requirements of other applicable federal, state, or local regulations

2. A suitable replacement refrigerant is not available

continued



Time Extensions for Retrofit or Retirement of Industrial Process Refrigeration Systems continued

3. The unit is custom-built and the supplier of the system or a critical component has quoted a delivery time of more than 30 weeks from when the order is placed If the owner or operator of a custom-built industrial process refrigeration system has received an additional 12-month period for retrofit or retirement activities, but still requires more time to complete the retrofit or retirement, then a request for additional time may be submitted to EPA



Relief From Obligation to Retrofit or Retire You may be relieved of this requirement if either of the following efforts is successful:

1. Make second efforts to repair the same leaks that were the subject of the first repair attempt

2. Within 180 days of a failed follow-up verification test associated with the initial repair efforts, establish that the leak rate is below the trigger rate


SYSTEM MOTHBALLING

System mothballing is the intentional shutdown of a refrigeration system for an extended period of time, where the refrigerant has been evacuated from the system to at least atmospheric pressure When a refrigeration system is in a mothballed condition, refrigerant leaks that existed when the system was operating have effectively been stopped because the system has been evacuated The time-related requirements resume on the day the system is brought back on line and is no longer considered mothballed Leak repairs following mothballing on industrial process refrigeration systems are still subject to initial and follow-up verification tests


SYSTEM MOTHBALLING

Applicability When a system is mothballed, the time suspensions are available for all types of systems, including commercial, industrial process, and any other systems containing more than 50 pounds of refrigerant Time suspensions under system mothballing apply to all time-related requirements for repairing leaks or replacing, retrofitting, or retiring a system, including time extensions that may be allowed in specific circumstances for industrial process refrigeration systems


SYSTEM MOTHBALLING

System mothballing requires the refrigerant to be removed from the system to at least atmospheric pressure If the owner or operator intends to make repairs to the system that require opening the system, the refrigerant must be removed to the required evacuation levels for that refrigerant before the system is opened


SYSTEM MOTHBALLING

Example of System Mothballing If the system operated for five days after discovery of the exceedance of the leak rate and then was shut down and mothballed for two months, when the system returned to operating, the owner would still have 25 days to either repair the leaks or develop a 12-month retrofit or retirement plan


OIL CHANGES

EPA’s refrigerant recycling amendments also address procedures to minimize emissions of refrigerant during oil changes The oil in a refrigeration system may contain large amounts of refrigerant EPA requires a reduction in pressure prior to an oil change so that the bulk of the refrigerant is recovered The maximum pressure allowed is 5 psig


OIL CHANGES

There are two acceptable procedures to assure recovery of refrigerant:1. Evacuate the refrigeration system, or isolated portion, to a pressure no higher than 5 psig and then remove the oil; or2. Drain the oil into a system receiver to be evacuated to a pressure no higher than 5 psig

These procedures minimize the loss of refrigerant from: a) the oil, and b) the interior of the refrigeration system as the oil comes out


SAFE DISPOSAL REQUIREMENTS

Equipment that is typically dismantled on-site before disposal has to have the refrigerant recovered in accordance with EPA's requirements for servicing However, equipment that typically enters the waste stream with the charge intact is subject to special safe disposal requirements Under these requirements, the final person in the disposal chain is responsible for ensuring that refrigerant is recovered from equipment before the final disposal of the equipment Technician certification is not required for individuals removing refrigerant from appliances in the waste stream


HAZARDOUS WASTE DISPOSAL

If refrigerants are recycled or reclaimed, they are not considered hazardous under federal law In addition, used oils contaminated with CFCs are not hazardous on the condition that: They are not mixed with other waste They are subjected to CFC recycling or reclamation They are not mixed with used oils from other sources Used oils that contain CFCs after the CFC reclamation procedure, however, are subject to specification limits for used oil fuels if these oils are destined for burning


RECORDKEEPING AND REPORTING

Leak Repair (Industrial Process Refrigeration)If the repairs have failed the follow-up verification test:a) Documentation of the following information and report it to EPA within 30 days after verification test:•the identification of the facility; •the leak rate; •the method used to determine the leak rate and full charge;•the date of discovery that the leak rate was above the trigger rate; •the location of leaks to the extent determined to date; b) Notify EPA if you discover that the repairs will take longer than you have previously told EPA



Full ChargeIf the full charge of an industrial process refrigeration system is determined by establishing a range or combining the use of an established range, records must be maintained.These records must include: Identification of the owner or operator of the system; Location of the system; Original range for the full charge of the system, its midpoint, and how the range was determined; Any and all revisions of the full charge range and how they were determined; and Dates such revisions occurred



Purged RefrigerantRecords must include ALL of the following: Flow rate; Quantity or concentration of the refrigerant in the vent; Periods of purge flow; Identification of the facility and a contact person; General description of the refrigeration system; Description of the methods used to determine the quantity of refrigerant sent for destruction; Frequency of monitoring and data-recording; and Description of the control device and destruction efficiency



Retrofit or Retirement (Industrial Process Refrigeration) If you complete successful retrofit or retirement within the normal one-year period, the amendments do not require any new recordkeeping or reporting Records reportable to EPA must be maintained on site for three years


Remember, You Control Your Facility or Area!

Review Procedures With Them Before Starting the

Job!

Ensure They Are Properly Trained!

Determine Their Environmental Compliance Record!

Determine Who Is in Charge of Their People!

Determine How They Will Affect Your Facility’s

Environmental Compliance!

TIPS FOR USING CONTRACTORS


ELEMENTS OF A SUCCESSFUL REFRIGERANT COMPLIANCE PROGRAM

1. DETAILED WRITTEN REFRIGERANT COMPLIANCE

INSPECTION GUIDELINES.

2. DETAILED WRITTEN REFRIGERANT COMPLIANCE BEST

MANAGEMENT PRACTICES.

3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS

4. PERIODIC REINFORCEMENT OF TRAINING

5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION

6. PERIODIC FOLLOW-UP


THE IMPORTANCE OF A CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner Former EPA Administrator

Documents

Refrigerant Compliance Management 1 / 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC REFRIGERANT COMPLIANCE MANAGEMENT CUSTOMIZED