AppendixH_RefrigMng_Guide_.pdf

U.S. General Services Administration PBS Office of Applied Science

Refrigerant Management What you need to know

Introduction

GSA uses and stores a large amount of refrigerants, which is a chemical used for a variety of building operation applications. When emitted, refrigerants deplete the ozone layer in the upper atmosphere. For this reason, EPA classifies refrigerants as ozone depleting substances (ODSs).

To minimize this impact on the surrounding physical and human environment, GSA must properly manage refrigerants from the time they enter the building until the time they leave the building.

The information provided herein serves as guidance to GSA property managers for complying with all associated regulatory requirements in properly managing refrigerants.

What is a refrigerant?

A refrigerant is a fluid that is used for heat transfer in a cooling system. Refrigerants absorb heat during evaporation at low temperature and pressure and release heat during condensation at a higher temperature and pressure. When refrigerants evaporate, the fluid absorbs the surrounding heat thus cooling the nearby area. The most common types of refrigerant are chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), both of which are ODSs and are commonly found in air conditioning units and chillers.

How are refrigerants regulated?

The Clean Air Act (CAA) requires Federal agencies to meet specific requirements when handling and disposing of refrigerants. This includes ensuring all technicians have an U.S. Environmental Protection Agency (EPA) certification, are using EPA-certified refrigerant recovery equipment, and are not venting refrigerants into the atmosphere. As a Federal agency subject to provisions in the CAA, GSA must ensure it manages all chillers, refrigerant recovery equipment, and stored refrigerants in accordance with federal, state and local regulations.

Refrigerants are classified as either Class I or Class II substances1.

Class I substances – include CFCs, halons, carbon tetrachloride, methyl bromide and methyl chloroform. When emitted into the atmosphere, these substances are broken down by strong ultraviolet light where they release chlorine atoms that then deplete the ozone layer.

Class II substances – include HCFCs. HCFCs, like CFCs, also contain chlorine and deplete the ozone layer, but to a much lesser extent than CFCs. HCFCs are currently being used to replace CFCs in accordance with the phase-out requirements in the Montreal Protocol and Title VI of the

CAA.

1 See 40 CFR 82.3 for a complete definition of Class I and Class II substances

What does this mean for GSA?

No venting of refrigerants: When servicing or disposing of equipment that contains refrigerant, it is illegal to “knowingly” vent, or release, these refrigerants into the atmosphere. Title 6 of the Clean Air Act defines four scenarios where releases are permitted:

1. small quantities released in the course of making good faith attempts to recycle or safely dispose the refrigerant

2. refrigerants emitted during the equipment’s normal course of operation

3. releases of CFCs or HCFCs not used as refrigerants

4. small releases of refrigerant resulting from purging hoses or connecting/disconnecting hoses to charge or service equipment

EPA-certification requirement: Property managers should ensure all contractors and agency employees are trained and EPA-certified if maintaining appliances containing refrigerants.

Property managers should also ensure all refrigerant recovery and recycling equipment are certified.

Refrigerant leaks: Equipment with refrigerant charges of 50 pounds or more must have all leaks repaired when those leaks together would result in the loss of more than 35 percent of the charge annually. Property managers must document all repair efforts and notify EPA within 30 days if leaks cannot be repaired.

Recordkeeping: Property managers should keep maintenance records readily available on all equipment that contains refrigerant. Records should identify the quantity of refrigerant added during each servicing, the date and type of service, an inventory of the type of refrigerants used and an inventory of all refrigerant containing equipment.

Disposing of refrigerants: EPA requires all refrigerant to be recovered prior to dismantling and disposing of equipment containing refrigerant. Equipment that typically enters the waste stream with its charge intact (room air conditioners) is also subject to special safe disposal requirements.

Federal agencies are required to follow requirements in Executive Order 13423 and its implementation instructions2 when disposing used-refrigerant. Prior to its disposition, federal agencies are required to first notify the Department of Defense (DOD) and give DOD an opportunity to acquire any excess refrigerant to fulfill its mission-critical needs.

Purchasing refrigerants: Federal regulations prohibit the buying and selling of products listed as nonessential class I products,3 goods which EPA considers unnecessary CFC-containing products. GSA must not purchase these products. Existing inventory of these products should be evaluated and offered to DOD or disposed of as a hazardous waste if deemed excess.

What if GSA does not comply?

EPA periodically performs random inspections. Under the Clean Air Act, EPA is authorized to assess fines of up to $32,000 per day for any violation of these regulations. Examples of recent fines EPA has assessed for CAA violations can be found at EPA’s enforcement webpage -http://www.epa.gov/ozone/enforce/index.html

2 Executive Order 13423 Implementation Instructions were issued by CEQ on March 29, 2007. The instructions can be found at http://www.ofee.gov/eo/eo13423_instructions.pdf

3 Nonessential Class I Products are defined at 40 CFR 82.66. Also see 40 CFR 82.64 for information on the prohibition buying/selling nonessential Class I products

Are these substances being phased-out?

Yes. Section 604 of the Clean Air Act established a timetable for phasing out the production and consumption of class I and class II substances. Section 604(a) made it illegal to produce any class I substances after January 1, 2000. By 2030, all class II substances will also be banned from production. EPA has established a Significant New Alternatives Policy (SNAP) program to evaluate and regulate substitutes for ODSs being phased out. The purpose of the program is to allow a transition away from ODSs by identifying substitutes that offer lower risks to human health and the environment.

How can GSA dispose of excess refrigerants?

Executive Order 13423 Implementation Instructions require all Federal agencies to consult with DOD prior to disposing of unneeded ODSs. Where the recovered ODS is a critical requirement for DOD, Federal agencies are required to transfer the material to DOD; the transfer will be paid by DOD. The steps and flow chart below should be followed when disposing of excess refrigerants.

After determining the existence of unneeded refrigerants, GSA should take the following steps:

1. Email regional representatives in the PBS Environmental Management Leadership Network to notify GSA regions of the availability of excess refrigerant. They will advertise the refrigerant availability to the appropriate property management directors in the regions.

2. If there is no interest within GSA, contact DOD ODS Reserve Program Office, 8000 Jefferson Davis Highway, Richmond, VA 23297-5100, telephone (804) 279-5203 or email odsreserve@dscr.dla.mil If DOD has a need for the excess refrigerant, they will fund its transfer.4

3. If DOD does not need the refrigerant or if no response, GSA has the following options:

a. GSA can sell the refrigerant to an EPA certified refrigerant reclaimer

(www.epa.gov/ozone/title6/608/reclamation/reclist.html); or

b. GSA can sell the refrigerant to a certified technician. The technician will need a CAA Section 608 certification to buy refrigerant found in stationary appliances.

The technician will need a CAA Section 609 certification to buy refrigerant found in motor vehicle air conditions. GSA must keep a record of sale for 3 years following the sale. (www.epa.gov/ozone/title6/608/sales/sales.html); or

c. GSA can send the refrigerant to a Resource Conservation and Recovery Act (RCRA) permitted incinerator for destruction. GSA must keep all documentation for 3 years.

4 See section VIII (b) of Executive Order 13423 Implementation Instructions (http://www.ofee.gov/eo/eo13423_instructions.pdf)

Alternatives to using ozone depleting substances (ODSs)

A list of ODS alternatives can be found on the EPA SNAP website at: http://www.epa.gov/ozone/snap/

EPA has established a list of alternatives for those ODSs used in refrigeration and air conditioning operations: http://www.epa.gov/ozone/snap/refrigerants/index.html

EPA’s substitutes for CFC-114 and CFC-11 in chillers:

http://www.epa.gov/ozone/snap/refrigerants/lists/114cent.html

Excess ODS identified

Advertise the availability of excess refrigerants to members of the PBS

Environmental Management Leadership Network

Does GSA want the excess refrigerant?

YesThe region in need takes possession of excess refrigerant

DOD takes custody of excess refrigerant. DOD will fund the transfer.

No

Advertise availability to

DOD

Does DOD want the excess refrigerant?

Yes

GSA can sell refrigerant to an EPA certified reclaimer, a certified technician, or transport it to a RCRA permitted incinerator for destruction.

No

Steps to disposing excess refrigerant where can I find statutory references?

40 CFR Part 82 Protection of the Stratospheric Ozone

List of Class I Controlled Substances

List of Class II Controlled Substances

Executive Order 13423 and Implementation Instructions where can I find more information?1

GSA

Regional PBS Environmental Management Leadership Network contacts:

Environmental Management Leadership Network

Central Office:

Gina Noel @ gina.noel@gsa.gov, (202) 208-0117

EPA

EPA Stratospheric Protection Division http://www.epa.gov/ozone/strathome.html

EPA Ozone Layer Depletion – Regulatory Programs http://www.epa.gov/ozone/title6/index.html

Stationary Refrigeration and Air-conditioning http://www.epa.gov/ozone/title6/608/index.html

EPA Significant New Alternatives Policy (SNAP) Office http://www.epa.gov/ozone/snap

Montreal Protocol http://www.epa.gov/ozone/intpol/index.html

This fact sheet is provided as an overview of refrigerants and other ozone depleting substances and does not replace or supersede federal, state or local statutes or regulations.