Overview of Ozone Depleting Substances Requirements EQcommitted to the Environmental Concerns of Ind

1
Overview of Ozone Depleting Substances
Requirements EQcommitted to the Environmental
Concerns of Industry

• Prepared by
• Environmental Quality Management, Inc.

July 2005
2
Statutory Requirements

• Section 612 of Clean Air Act Amendments of 1990
• 40 CFR 82 - Protection of Stratospheric Ozone
• Production and Consumption Controls
• Servicing of Motor Vehicle Air Conditioners
• Ban on Nonessential Products
• Federal Procurement
• Labeling of Products Using Ozone Depleting
  Substances (ODS)
• Recycling and Emissions Reductions (Subpart F)
• Significant New Alternative Policy (SNAP) Program
• Halon Emissions Reductions
• Acceptable Substitutes Subject to frequent
  change

3
Requirements and Applicability

• Major elements of 40 CFR Part 82, Subpart F
  (Recycling and Emissions Reduction final rule
  May 1993)
• Prohibitions (i.e., venting of refrigerant)
• Technician Certification
• Required Practices
• Recovery and recycling
• Leak rate limitations
• Repair of equipment
• Recordkeeping and Reporting
• Date of service, details and amount added
• Details of leak rate determinations and follow-up

4
Recordkeeping

• Recordkeeping - For each appliance containing
  over 50 pounds of refrigerant
• Identification of facility
• Leak rate determination, location, and
  documentation
• Full charge documentation
• Date of leak identified (greater than allowable)
• Type and details of services performed
• Amount of refrigerant added
• Refrigerant purchasing records (if applicable)
• Must retain at equipment site at least 3 years
• Retrofit/retire plan (if applicable)

5
Reporting

• Reporting - Must submit additional information to
  EPA if requesting an exemption or extension

6
Recordkeeping and Reporting Equipment Survey
7
Recordkeeping and Reporting Service Report

• ODS Equipment Service Report
• Refrigeration Unit Information
• Servicing Information
• Technician Information (if servicing is conducted
  by employee)
• Outside Vendor/Contractor Information (if
  servicing is conducted by contract vendor)
• Facility Review

8
Leak Rate Determination

• Leak rate calculation is used to determine
  timeframe for repairing, retrofitting, or
  retiring equipment
• Annual rate based on adding refrigerant as needed
  to return to full charge two regulatory
  threshold rates
• 35 for industrial/process refrigeration
• 15 for comfort cooling and other refrigeration
• Applies to equipment with Class I or Class II
  substances and a full charge of at least 50
  pounds
• Commercial
• Industrial
• Comfort cooling and all others

9
Leak Rate Determination (continued)

• Full Charge Determination
• Manufacturers data,
• Calculation,
• Measurement, and/or
• Midpoint of established range (if used, contains
  additional record keeping)

10
Leak Rate Determination (continued)

• Calculation of Leak Rate - Annualizing Method

11
Leak Rate Determination (continued)

• Calculation of Leak Rate Rolling Average Method
• NOTE If a leak was repaired within the last
  year, use the amount added since repair (and
  assume a one-time leak)

12
Leak Rate Follow-up

• Operators must repair leaks within 30 days of
  discovery of the leak, or within 30 days after
  when the leaks should have been discovered...
• (40 CFR Part 82.156(i))
• Repair leak(s) to bring rate to below 15 or 35
• Initial verification test (before startup) and
  follow-up verification test (within 30 days of
  repair) for industrial process equipment and some
  federally owned equipment
• Or,
• Develop a one-year retrofit or retirement plan

13
Leak Rate Follow-up (contd)

• A leak calculation should be performed as soon as
  possible after a leak is discovered as a good
  management practice
• Leak rate follow-up exceptions exist for
• industrial process equipment (requiring shutdown,
  can have up to 120 days may include additional
  notification to EPA) and
• federally owned equipment in radiological areas

14
Leak Rate Follow-up (contd)

• If a recovery vessel is used, purchased, and
  remains onsite during servicing of units, that
  recovery vessel must be registered with US EPA

15
Other Requirements

• Smaller units - with less than 50 lbs of charge,
  also have requirements, including
• units must be serviced by trained technicians,
  and
• must remove ODSs before disposal

16
Other Requirements (contd)

• SNAP Significant New Alternatives Policy
  provides the basis for the ever-changing list of
  acceptable and unacceptable substitutes
• www.epa.gov/ozone/title6/snap

17
ODS Compliance Planning

• Develop inventory of appliances that includes
  refrigerant type, use, and full charge amounts
• Ensure vendor and service documentation is
  sufficient to demonstrate compliance
• Complete leak rate calculations for appliances
  greater than 50 pounds
• Conduct follow-up verification testing for
  industrial process equipment
• Develop/maintain files for 3 years for services,
  leak rate calculations, and verification testing
• Remove ODSs from all equipment before disposal
  and document activities

18
ODS US EPA Reference Sources for Planning

• www.epa.gov/ozone/title6/overview
• www.epa.gov/ozone/ods
• www.epa.gov/ozone/record/index
• www.epa.gov/ozone/enforce
• www.epa.gov/ozone/title6/snap
• The U.S. Solvent Cleaning Industry and the
  Transition to Non Ozone Depleting Alternatives
  (go to www.epa.gov/ozone/snap/index)
• Federal Register notice of US EPA Bakery
  Partnership program February 6, 2002