Title VI- Stratospheric Ozone Compliance Training

Synopsis of EPA’s Title VI, section 608

• First, the Agency requires technicians servicing and disposing of air-conditioning and refrigeration equipment to observe certain service practices that reduce refrigerant emissions

• Second, EPA requires technicians servicing air-conditioning and refrigeration equipment to obtain certification through an EPA-approved testing organization and restricts sales of refrigerant to these certified technicians

• Third, EPA establishes recovery equipment certification programs. These would have the goals of verifying: That all recycling or recovery equipment sold was capable of minimizing emissions and that reclaimed refrigerant on the market was of known and acceptable quality to avoid equipment failures from contaminated refrigerant

•Fourth, EPA requires repair of substantial leaks, based on annual leak rates which vary according to the category of refrigeration equipment

•Fifth, to implement the safe disposal requirements of section 608, EPA requires that ozone-depleting refrigerants in appliances, machines, and other goods be removed from those items prior to their disposal, and that all air-conditioning and refrigeration equipment be provided with a servicing aperture that would facilitate recovery of the refrigerant.

Synopsis of EPA’s section 608 (continued)

Who do you think is the “responsible

person?”

A Responsible Official is One of the Following

• An individual who performs policy or decision making functions concerning Ozone Depleting Chemicals (ODC)– A principal executive officer or ranking official– A Supervisory or Lead Technician– A designated representative (technicians)

responsible for the overall operation of manufacturing, production, or operating facilities

• Remember: the responsibility cannot be delegated away!

Top Five EPA ODC Enforcement Actions

• Improper documentation by in-house technicians• Incomplete documentation by contractors• Improper disposal of refrigerant containing

equipment• Failure to repair leaking systems• Inadequate EPA technician certification

You Don’t Want to be Next!

• After all, who needs to begin their work day by opening a return receipt requested form letter that states “Pursuant to the authority of Section 114 (a)(1) of the Act, 42 U.S.C. & 7414(a)(1), you are required to provide the following information and documents within seven (7) days of receipt of this document”?

•Failure to comply with this requirement to provide information is a violation of Section 114 of the act and could result in an enforcement action for the recovery of civil penalties not to exceed $32,500 per day, per violation, or for injunctive relief or both. Section 113, 42 U.S.C. & 7413, of the Act gives EPA the authority to seek criminal penalties (jail time) from any person who knowingly makes any false statement, representation, or certification in any report required under the Act.

You REALLY Don’t Want to be Next!

Violations• Failure to maintain required

documents• Falsifying documents• Failure to respond to

demands for information (114A)

• Knowingly releasing refrigerant

Violation of the regulations can result in penalties of up to $32,500 per day per violation. “Bounty” of up to $10,000 could be paid to one of your technicians or managers for the report of a violation.

As the Responsible Person, Can You Answer these Five Basic Questions?

• Do you know the quantity of ODCs (Refrigerant Gas) that your organization has:– Purchased and Used = 0?– Recovered and Disposed = 0?– Itemized on a refrigerant

inventory?• Do all values balance to zero for the

past 3 years?

In Order to Answer these Questions:

• Develop, maintain, and keep records of an effective training program on the regulations imposed by the Clean Air Act (section 608 and 609)

• Your organization’s procedures should avoid common misconceptions, which will ensure that recordkeeping requirements are adequate to meet the compliance standards.

What Kind of Documents Should be Retained?

• Accidental or Unintentional Release Report

• Refrigerant Cylinder Input Form

• Service Order Form

• Work Order Form

• Facility Services Material Requisition Form

• Refrigerant Equipment Tracking Log

• Transportation "Move Order" Form

• Ready for Salvage Tag

• Cylinder ID Tag

• Refrigerant Gas Condition Tags (Virgin, Used, Contaminated, and Unknown)

Example: Service Order Form

• Equipment location, Technician performing work, cause or type of service problem

• Type of refrigerant used, Gas cylinder information, quantity and condition

• Parts and other materials used for repair, type of leak, follow up inspection

Sample of Salvage Tag

* ENVIRONMENTAL SAFETY NOTICE *

ENVIRONMENTALLY HARMFUL REFRIGERANTS AND OIL HAVE BEEN REMOVED FROM THIS UNIT IN COMPLIANCE WITH SECTION 608 OF THE

CLEAN AIR ACT

>>> THIS OBJECT IS SAFE TO SALVAGE AS SCRAP <<<

Removed by: (print) …………………………………………….

Work order # …………………………………………….

Equipment ID # …………………………………………….

Signature …………………………………………….

Date removed …………………..

* ENVIRONMENTAL SAFETY NOTICE *

ENVIRONMENTALLY HARMFUL REFRIGERANTS AND OIL HAVE BEEN REMOVED FROM THIS UNIT IN COMPLIANCE WITH SECTION 608 OF THE

CLEAN AIR ACT

>>> THIS OBJECT IS SAFE TO SALVAGE AS SCRAP <<<

Removed by: (print) …………………………………………….

Work order # …………………………………………….

Equipment ID # …………………………………………….

Signature …………………………………………….

Date removed …………………..

Training Requirements

• Who needs it?– Technicians– Administration– Procurement– Design and Construction– Sub-contractor

Retain the training documentation (who/what/when/where/etc.)- 3 years

Training RequirementsAt what frequency?

•12 to 18 months for employee refresher

•Within 30 days of a new hire

•Every 12 months for Sub-contractor

Retain the training documentation (who/what/when/where/etc.)- 3 years

ODC Reduction Definitions• Recovery

– To remove refrigerant in any condition from a system and store it in an external container without processing

– Recover and reuse with processing• Recycling

– To clean refrigerant for reuse by oil separation and pass through replaceable core filter dryers which reduce moisture, acidity, and particulates

– Performed on-site or in shop• Reclaim

– To reprocess (distill) refrigerant to new product specifications (ARI-700)

– Performed by a reprocessing facility• Recover and Destroy

What about Refrigerant Cylinders?

• Disposable cylinders are not to be refilled• Transportation of a refilled disposable cylinder is a felony

punishable by fines up to $32,500 and 5 years imprisonment

• Disposable cylinders are manufactured to DOT 39 standards

• Disposal of DOT 39 cylinders:– Recover refrigerant from empty cylinders,– Open valve– Puncture cylinder, and– Dispose in metal recycling bin

What about Recovery Cylinders?

• Recovery cylinders must comply with Department of Transportation, 49 CFR specifications

• Recovery cylinders should be painted yellow on the top and shoulders

• Recovery cylinders should be stamped with manufactured date

• Maximum gross weight should be stenciled on cylinder

• Refrigerant type should be identified on the cylinder

• “Y” combination valve that provides transfer of both liquid and vapor through a single port

Recovery Cylinders

•Maximum gross weight should be stenciled on cylinder

•Refrigerant type should be identified on the cylinder

•Should have a “Y” combination valve that provides transfer of both liquid and vapor through a single port

A Quality Program MUST Contain:

• A formal, written document stating the organization’s position on Refrigerant gas management

• The written intent to purchase as little new or “virgin” refrigerant as possible

• All refrigerant work is fully documented• Insist upon an annual refresher training and

review• Strict inventory control of Refrigerant• Consistent management of document and

data integrity