ATT_021_Ozone_Depleting_Substances_(ODS)_Management_Program.docx

AG-32SC-S-14-0010 ATT 0021

Ozone Depleting Substances (ODS) Management Program and Stationary Refrigeration Work Practices

1. Scope

The purpose of this program is to develop a guide for the National Center For Agricultural Utilization Research (NCAUR) to manage ozone-depleting substances (refrigerants and certain fire extinguishing agents) being used for operations and maintenance of air conditioning equipment, and fire suppression systems. This program also covers outside contractors that may maintain NCAUR equipment.

2. Responsibilities

Facility Manager & Safety Office shall review facility work practices of contractors/vendors servicing ODS-containing equipment to ensure that all technicians who perform maintenance on ODS-containing equipment are certified by EPA and that the following activities are appropriately managed and maintained:

1. ODS-containing equipment inventory;

2. inventory of EPA certified recovery equipment; and

3. servicing records for appliances normally containing 50 or more pounds of refrigerants. These records shall document date and type of service, the quantity of refrigerant added and the leak rate any time refrigerant was added to the system.

Contractors

Sustainment of NCAUR’s Refrigerant (and ODS) Program shall include the following work practices:

Contractor Project Management:

1. maintain a copy of the Certified Refrigeration Technician card with the area or department prior to any work being performed;

2. ensure that all technicians who perform maintenance on ODS-containing equipment are certified by EPA;

3. maintain an inventory of EPA certified recovery equipment;

4. maintain servicing records for appliances normally containing 50 or more pounds of refrigerants. These records shall document date and type of service, the quantity of refrigerant added and the leak rate any time refrigerant was added to the system; and

5. immediately notify the Government of any significant appliance leaks or unintentional venting of refrigerant.

Contractor Refrigeration Technician (certified):

1. ensure tools are in good working condition:

a. all hoses and gauges are free of damage or possible leaks;

b. recovery cylinders are in good condition, of the property type and the retest date has not expired; and

c. recovery equipment is approved & certified, properly oiled and filters are in good condition.

2. use certified tanks to accomplish refrigerant reclamation;

3. use appropriate scales and measuring devices to determine the amounts of refrigerant transferred during servicing. The amounts of refrigerant used shall be recorded;

4. if a cylinder is not clearly marked with the type of refrigerant it contains, properly label or tag the cylinder to identify refrigeration type;

5. shipment of refrigerants off-site for recycling or disposal must comply with sections 3.8, 3.9, and 3.11 of this document; and

6. unless otherwise specified in this procedure, maintain all refrigeration records.

3. Refrigerants

3.1. Definitions

Ozone Depleting Substances (ODS). For the purpose of this guide, ODS are group of chemicals that include chlorofluorocarbons-CFC, hydrochlorofluorocarbons-HCFC, and other halogenated chemicals such as halons that are found to contribute stratospheric ozone layer depletion.

Appliances Any device which contains and uses a Class I (CFC) or Class II (HCFC) substance as a refrigerant and which is used for household or commercial purposes, including any air conditioner, refrigerator, chiller, or freezer.

Opening Any service, maintenance, or repair on an appliance that would release Class I or Class II refrigerant from the appliance to the atmosphere unless the refrigerants were recovered previously from the appliance. Connecting and disconnecting hoses and gauges to and from the appliance to measure pressures within the appliance and to add refrigerant to or recover refrigerant from the appliance shall not be considered "opening."

Major maintenance, service, or repair Maintenance, service, or repair that involves removal of the appliance compressor, condenser, evaporator, or auxiliary heat exchanger coil.

Technician Any person who performs maintenance, service, or repair that could reasonably be expected to release Class I (CFC) or Class II (HCFC) substances from appliances, except for MVACs, into the atmosphere. Technician also means any person performing disposal of appliances, except for small appliances, MVACs, and MVAC-like appliances, that could be reasonably expected to release Class I or Class II refrigerants from appliances into the atmosphere.

Reclaim To reprocess refrigerant to at least the purity specified in the American Refrigeration Institute (ARI) Standard 700-1993, Specifications for Fluorocarbon Refrigerants, and to verify this purity using the analytical methodology prescribed in the Standard. Reclamation requires specialized machinery not available at a particular job site or auto repair shop. The technician will recover the refrigerant and then send it either to a general reclaimer or back to the refrigerant manufacturer.

3.2. Background

ODS has been demonstrated to be harmful to the stratospheric ozone layer and is regulated under Title VI of Clean Air Act. As a result of this oversight, the EPA has established a national recycling program for these substances when recovered during the servicing and disposal of refrigeration and air conditioning equipment. The NCAUR owns many appliances ranging in capacity from less than 50 pounds to 18650 pounds.

3.3. Prohibition on Venting

Under the Code of Federal Regulation 40 Part 82, individuals are prohibited from knowingly venting ODS into the atmosphere while maintaining, servicing, repairing, or disposing of appliances.

3.4. Service Practice Requirements

3.4.1. Evacuation Requirements

Air-conditioning and refrigeration equipment must be evacuated to EPA-required vacuum level prior to opening. If the technician's recovery or recycling equipment was manufactured on or after November 15, 1993, then an EPA-approved equipment testing organization must certify the equipment. Refrigerant recovery and recycling equipment manufactured before November 15, 1993, may be grandfathered if it meets the standard detailed in 40 CFR 82.158. Persons who simply add refrigerant to (top-off) appliances are not required to evacuate the systems.

3.4.2. Reclamation Requirement

EPA has 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.

3.5. Equipment Certification

EPA has established a certification program for refrigerant recovery and recycling equipment. EPA requires that persons servicing or disposing of air-conditioning and refrigeration equipment certify they have acquired (built, bought, or leased) recovery or recycling equipment and that they are complying with the applicable requirements of this rule. Owners do not have to send in a new form each time they add recycling or recovery equipment to their inventory. Certification of refrigerant recovery and recycling performed by technicians certified by the EPA is required on equipment manufactured on or after November 15, 1993 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.”

Further, equipment certification is required when equipment is to be scrapped or shipped off-site. In such cases, the refrigerant will be evacuated, a signed an dated evacuation label affixed to the equipment. Additionally, when equipment is scrapped the refrigeration lines shall be cut after the refrigerant is removed.

3.6. Refrigerant Leak

Appliances having refrigerant capacity greater than 50 pounds include all maintenance records indicating quantity of refrigerant added during servicing and maintenance. Based on the quantity of refrigerant added to the equipment, if leak rate of 15 percent or more is discovered, the leak rate must be repaired within 30 days of discovery.

3.7. Technician Certification

EPA has established a technician certification program for technicians who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphere. All Contractor technicians providing services to the NCAUR must be certified through EPA-approved training program. Outside contractors must provide proof of certification for their personnel to the Contracting Officer prior to service or repair work.

3.8. Safe Disposal Requirements

All major ODS containing equipment-chillers must have their ODS recovered prior to dismantling. Also small units that can enter waste stream intact, such as freezers, window air conditioners shall have their refrigerant recovered prior to waste pick up.

3.9. 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.

Prior to disposing of ODS removed or reclaimed from facilities or equipment, NCAUR will contact DOD, ODS Reserve Program Office, 8000 Jefferson Davis Highway, Richmond, Virginia 23297, telephone 804-279-4525, e-mail odsreserve@dscr.dla.mil. DOD has a need for these materials and may be willing to pay for shipping.

For further information regarding the procurement of ODS and equipment requiring ODS, refer to Procurement and Property Policy Memorandum 23-02, “Energy Initiatives.”

3.10. Recordkeeping Requirements

1. the Contractor must keep a copy of their proof of certification for all refrigeration technicians at their place of business;

2. for appliances that contain 50 or more pounds of refrigerant, the Facility Manager must keep servicing records documenting the date and type of service, as well as the quantity of refrigerant added;

3. ODS purchase as well as disposal logs;

4. copy of EPA registration record for ODS recovery/recycling equipment;

5. all records related to ODS must be maintained onsite for five years and submitted to the Facility Manager at Contract transition to be maintained with the NCAUR.

3.11 NCAUR Recordkeeping In Compliance With REE

NCAUR has adopted the REE policy:

• phase out the procurement of all ODS and ODS-containing equipment as the equipment reaches its expected life service or by December 31, 2010;

• seek out and use safe alternative chemicals and technologies to replace ODS in all existing applications and in new processes, programs, and procedures to the maximum extent possible; and

• contact the Department of Defense (DOD), ODS Reserve Program Office, prior to disposal of ODS removed or reclaimed from facilities or equipment.

3.12 NCAUR Recordkeeping In Compliance With The ARS/MWA

NCAUR’s ODS inventory will be maintained to include:

• the type and quantity of ODS contained in equipment/systems,

• the type and quantity of solvents and/or fumigants containing ODS used and stored on-site, and

• the type and quantity of ODS procured annually.

The plan will be reviewed and updated by November 30 of each year. All records including plans and inventories should be maintained so that a clear trail of progress is well documented.

3.13 Substitution of ODS

When selecting chemical substitutes to ODS, preference will be given to non-ozone depleting chemicals, if feasible and economically practicable. If no substitute is available, priority will be given to selecting substitutes with low ozone-depletion potential and/or low global-warming potential. The manufacturer can provide this information either from an MSDS or other supplemental material.

4. Halon

4.1. Prohibition on Venting

Code of Federal Regulation 40 Part 82 prohibits individuals from intentionally venting of halon during testing, maintaining, servicing, repairing, or disposing of halon-containing equipment, or during the use of such equipment for technician training. Following limited exemptions exist for this rule as it applies to NCAUR facilities that use halon containing systems as fire extinguishing means:

• De minimis releases associated with good faith efforts to recycle or recover halon, e.g. release of residual halon contained in fully discharged total flooding fire extinguishing systems;

• Release of halons during testing of fire extinguishing systems or equipment is exempted only if the following four criteria are met: (a) systems or equipment employing suitable alternative agents are not available, (b) system or equipment testing requiring release of agent is essential to demonstrate system or equipment functionality, (c) failure of the system would pose great risk to human safety or the environment, (d) a simulant agent cannot be used for the testing purposes.

4.2. Technician Training

EPA requires a technician certification program for technicians who perform maintenance, service, repair, or disposal that could be reasonably expected to release halon into the atmosphere. All Contractor technicians providing services to the NCAUR must be certified through EPA-recommended training program. Outside contractors must provide proof of certification for their personnel to facility managers prior to service or repair work.

4.3. Proper Disposal

Halon-containing equipment must be properly disposed of at the end of its useful life. Proper disposal means only sending such equipment for halon recovery or recycling by a facility (e.g., a manufacturer, a fire equipment dealer, a recycler, or an in-house recovery or recycling operation) operating in accordance with NFPA 10 and NFPA 12A standards. Halon itself must be properly disposed of. Proper disposal means only Halon recycling by a facility operating in accordance with NFPA 10 and NFPA 12A.

4.4. Recordkeeping Requirements

Following records should be maintained onsite for a minimum of three years:

• Inventory of halon containing equipment including type and quantity of halon in the system;

• Service maintenance and repair records including date and type of service, quantity of halon purchased and added;

• Halon containing equipment recycling/disposal records (halon type and quantity and the date sent off-site and the name and address of disposal/recycling facility)

• Technician training records.