Attachment 018-Ozone Depleting Substances (ODS) Management Program-rev01-20-2021.pdf

Attachment 018 Operation and Maintenance Contract USDA-NCAUR, Peoria, IL

Ozone Depleting Substances (ODS) Management Program and Associated PWS Requirements

1.0 Introduction

Ozone Depleting Substances (ODS) has been demonstrated to be harmful to the stratosphere ozone layer and is regulated under Title VI of Clean Air Act. It is ARS policy that an ODS Program is implemented at the National Center for Agricultural Utilization Research (NCAUR) in accordance with 40 CFR 82 and EO 13693 to phase out the procurement of ODS and ODS-containing equipment as the equipment reaches the end of its expected service life or when leaks warrant replacement; and to seek out and use safe and alternative chemicals and technologies to replace ODS in existing applications and in new processes, programs, and procedures to the maximum extent feasible.

2.0 Objectives of Ozone Depleting Substances (ODS) Management Program

The objective of the ODS Management Program is to manage and phase out ozone depleting substances (ODS) at NCAUR. ODS are those chemicals that the Environmental Protection Agency has found to cause or contribute significantly to harmful effects on the stratosphere ozone layer. Examples of ODS include refrigeration equipment, fire extinguishing agents, solvents, and foam blowing agents

3.0 Required Elements of an Ozone-Depleting Substances Program

3.1 NCAUR Facility Engineer and Safety and Occupational Health Specialist

The NCAUR Facility Engineer and Safety and Occupational Health Specialist shall review facility work practices of contractors/vendors servicing ODS-containing equipment at NCAUR to ensure that all technicians who perform maintenance on ODS-containing equipment are certified by the EPA and that the following activities are appropriately managed and maintained:

ODS-containing equipment inventory (coolers, freezers, compressors, etc. that might use ODS);

Inventory of EPA certified recovery equipment; and Servicing records for equipment/systems that utilize fifty (50) or more pounds of

ODS. These records shall document date and type of services as well as the quantity of refrigerant added and the leak rate any time refrigerant was added to the system.

USDA-NCAUR, Peoria, IL

PWS Requirements:

The Contractor shall sustain NCAUR’s ODS Program. The Contractor shall manage, provide record keeping and execute their work to provide compliance with the requirements of this program. The Contractor’s efforts shall include, but not limited to, the following:

Ensure all technicians (direct employees and any subcontractors) who perform maintenance on ODS-containing equipment are certified by the EPA.

Maintain an inventory of EPA certified recovery equipment.

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

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

When executing the work of the Contractor, the Contractor and their refrigeration technicians (both direct employees and any sub-contractors) shall:

Ensure tools are in good working condition (all hoses and gauges are free of damage or possible leaks, recovery cylinders are in good condition, of the proper type and the retest date has not expired; and recovery equipment is approved and certified, properly oiled and filters are in good condition.

Use certified tanks to accomplish any refrigerant reclamation.

Use appropriate scales and measuring devices to determine the amounts of refrigerant transferred during servicing. Record amounts of refrigerant used.

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

Comply with specialized work practices and procedures requirements for shipments of refrigerants off-site for recycling or disposal.

Maintain all refrigeration records.

4.0 Refrigerants

4.1 Definitions

Appliances. Any device which contains and uses a Class I (CF) 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.”

USDA-NCAUR, Peoria, IL

Ozone Depleting Substances (ODS). ODS are chemicals that include chlorofluorocarbons (CFC), hydrochlorofluorocarbons (HCFC), and other halogenated chemicals such as halons that are found to contribute to stratospheric ozone layer depletions.

Reclaim. The act of processing used refrigerant gas which has previously been used in some type of refrigeration loop such that it meets specifications for new refrigerant gas.

In the United States, the Clean Air Act of 1990 requires that used refrigerant be processed by a certified reclaimer, which must be licensed by the United States Environmental Protection Agency (EPA), and the material must be recovered and delivered to the reclaimer by EPA-certified technicians.

Technician. Any person who performs maintenance, service, repair, or disposal that could reasonably be expected to release Class I (CFC) or Class II (HCFC) substances from appliances, except for motor vehicle air conditioner-like appliances (MVACs), into the atmosphere.

4.2 Prohibition on Venting

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

4.3 Substitution of ODS

The NCAUR replaces equipment in poor condition with new equipment that does not utilize ODS. When selecting chemical substitutes to ODS, preference is given to non-ozone depleting chemicals, if feasible and economically practicable. If no substitute is available, priority is given to selecting substitutes with low ozone-depletion potential and/or low global-warming potential. The manufacturer can provide this information either from an SDS or other supplemental material.

Eliminate the use of ozone depleting compounds during and after construction where alternative environmentally preferably products are available, while accounting for life cycle impacts. HVAC systems and fire suppression systems must not employ ozone depleting substances. This includes new construction as well as renovation of existing systems. The use of Freon or other ozone depleting gas is not acceptable for testing and certification of gas tight ductwork and isolation valves; and shall be completed using soap bubble leak detection and/or helium gas for repair prior to final testing and certification.

For further information regarding the procurement of ODS and equipment requiring ODS, refer to Acquisition and Property Division. For information regarding systems prohibiting ODS, refer to REE Manual 242.1.

USDA-NCAUR, Peoria, IL

4.4 Specialized Work Practices and Procedures

4.4.1 Evacuation Requirements

Air-conditioning and refrigeration equipment must be evacuated to EPA-required vacuum level prior to opening. Manufacturers and importers of recovery and/or recycling equipment must have such equipment certified by an approved equipment testing organization in accordance with 40 CFR 82.158 Table 2 and Appendix B1, B2, B3, and/or B4.

4.4.2 Reclamation Requirement

The 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, that refrigerant must be reclaimed.

During minor repairs of ODS equipment, the O&M Contractor will discharge refrigerant into a recovery cylinder. When the recovery cylinder is full, it is exchanged with the vendor. The vendor transfers the recovered refrigerant to Hudson Technologies who recycles or destroys in accordance with federal regulations.

4.5 Equipment certification

EPA regulations in 40 CFR Part 82, Subpart F under Section 608 of the Clean Air Act require that refrigerant recovery and recycling equipment be tested to ensure it meets EPA requirements. EPA no longer requires that persons servicing stationary air-conditioning and refrigeration equipment certify that they have acquired refrigerant recovery or recycling equipment and that they are complying with the applicable requirements.

4.6 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.

4.7 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 to their personnel to the Contracting Officer prior to service or repair work.

USDA-NCAUR, Peoria, IL

4.8 Safe Disposal Requirements

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

4.9 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 1) they are not mixed with other waste; 2) they are subjected to CFC recycling and reclamation; and 3) they are not mixed with used oils from other sources. Used oils that contain CFCs after the CFC reclamation procedure are subject to specification limits for used oil fuels if these oils are destined for burning.

In accordance with REE policy, the NCAUR shall contact the Department of Defense (DOD), ODS Reserve Program Office, 8000 Jefferson Davis Highway, Richmond, Virginia 23297, telephone (804) 279-4525, email odsreserve@dscr.dla.mil prior to disposal of ODS removed or reclaimed from facilities or equipment. DOD has a need for these materials and will pay for shipping.

4.10 Recordkeeping Requirements

NCAUR has adopted the REE policy (ARS Manual 160.0M, Section 52):

Phase-out the procurement of all ODS and ODS-containing equipment as the equipment reaches its expected life service;

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 Office, prior to disposal of ODS removed or reclaimed from facilities and equipment.

NCAUR’s ODS inventory will be maintained to include:

Type and quantity of ODS contained in equipment/systems;

Type and quantity of solvents and/or fumigants containing ODS used and stored on-site; and Type and quantity of ODS procured annually.

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

USDA-NCAUR, Peoria, IL

5.0 Halon

5.1 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. The 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.

5.2 Technician Training

The 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.

5.3 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.

5.4 Recordkeeping Requirements

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

Inventory of halon containing equipment including the 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, the date sent off-site, and the name and address of the disposal/recycling facility);

Technician training records.

USDA-NCAUR, Peoria, IL

• 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.