Vandenberg AFB Refrigerant Management Plan June 2020.pdf

THIRTIETH SPACE WING

Vandenberg Air Force Base, California

Refrigerant Management Plan

June 2020

OPR: 30 CES/CEIEC

1028 Iceland Avenue Vandenberg Air Force Base, CA 93437

Vandenberg Air Force Base

Refrigerant Management Plan Page ES-1

EXECUTIVE SUMMARY

This plan details the approach to be implemented at Vandenberg Air Force Base (VAFB) to ensure compliance with federal and state regulations and U.S. Air Force (USAF) directives regarding the management of systems and activities employing ozone depleting substances (ODSs) as refrigerants and regulated substitute refrigerants. Specifically, the objective of this plan is to minimize, to the extent possible, the release of such gases into the atmosphere from existing systems and procedures employed at VAFB while implementing a proactive, cost-effective approach to replace those systems, equipment, and procedures, which utilize such gases with environmentally safer alternatives. This plan addresses ODSs and their substitutes when used as refrigerants. The other main use of ODSs is halons, typically used for fire suppression, which are addressed separately in the VAFB Halon Management Plan.

The Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol) began on 1 January 1989 and established a timetable during which the production of ODSs are to be phased out. The United States incorporated the Montreal Protocol into Title VI of the Clean Air Act as amended in 1990, and implementing regulations were published by the U.S.

Environmental Protection Agency (EPA) in Title 40, Code of Federal Regulations, Part 82 (40 CFR 82), Protection of Stratospheric Ozone. In addition, Executive Order 13693 Planning for Federal Sustainability in the Next Decades, requires federal agencies to achieve greenhouse gas emission reductions and reporting with associated EPA and local regulations.

Key USAF directives relating to the management of ODS and regulated substitute refrigerants include USAF Manual (AFMAN) 32-7002, Chapter 3 Hazardous Materials Management, which establishes the following policies and requirements:

Specific procedures for procuring Class I ODSs, which are no longer being manufactured, including Senior Acquisition Officer approval as required, and Hazardous Materials Management Process Team authorization per USAF Form 3952 or equivalent electronic forms within the Enterprise Environmental, Safety, and Occupational Health Management Information System

Conserving existing inventories of Class I ODS and Class II ODS hydrochlorofluorocarbon-22, and restricting their transfer out of USAF control to sustain existing ODS-dependent weapon systems and fixed fire suppression systems until they are phased out

Minimizing to the extent possible inadvertent releases of ODS into the atmosphere through formal training and certification of technicians and the employment of EPA-approved refrigerant recovery and recycling equipment

Strictly prohibiting the intentional venting of ODS and regulated substitute refrigerants into the atmosphere

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Strictly complying with 40 CFR 82, especially as it relates to the monitoring and prompt repair of leaking heating, ventilation, and air conditioning and refrigeration systems

Implementing strategies to sustain, modify, or replace essential equipment, processes, and systems dependent on Class II ODS whose availability is steadily diminishing with the mandated complete phase-out of their manufacture by 2030.

The USAF goal is to eventually eliminate the use of Class I and Class II ODS while ensuring adequate ODS supplies for existing refrigeration appliances and ODS-containing equipment and systems during their expected serviceable lifespan. Activities governed by this plan include procuring, maintaining, repairing, installing, cleaning, and removing air conditioning or refrigeration appliances, and minimizing ODS use in other process equipment and activities throughout VAFB. All personnel assigned to organizations that have activities with a potential to discharge ODS into the atmosphere are required to adhere to this plan.

Under USAF direction, VAFB has undertaken a proactive approach to identify, evaluate, and reduce the use of ODS to the absolute minimum levels necessary to support mission activities.

This plan includes the steps necessary to manage ODS still needed to meet mission capabilities, and details procedures for Class I and II ODS procurement, use, and disposition.

The key USAF guidance document in the context of this plan is USAF Manual (AFMAN) 32- 7089, Refrigerant Management (USAF 2016a). Specifically, this manual addresses the

(1) management of refrigerant inventories; (2) monitoring equipment leakage rates and prompt repair/replacement when regulatory leakage rates are exceeded; (3) recovery, recycling, and disposal of refrigerants; (4) technician certification and equipment registration; (5) calculation of leakage rates; (6) refrigerant and equipment replacement planning; (7) maintenance of air conditioning/refrigeration equipment; (8) repairing EPA leaks; (9) managing records; and

(10) mandated use of the Air Program Information Management System (APIMS) Refrigerant Management Module. In addition, the manual includes five attachments providing detailed supporting text across the spectrum of these topics.

Accordingly, this Refrigerant Management Plan focuses on delineating those federal and state requirements relating to the management of ODS and regulated substitute ODS that are specifically applicable to operations and activities on VAFB. In particular, this plan details the approach by which VAFB complies with associated regulatory and USAF requirements and by which VAFB specifically assigns roles and responsibilities as they relate to the maintenance of ODS-containing equipment, mandated record keeping and notification, technician training and certification, and the management system that will oversee implementation of the VAFB ODS Management Program elements.

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1.0 RECORD OF CHANGES

Log completed change action as indicated.

Change Number

Change

Date of Entry

Signature and Organization of Individual Posting Entry

1 Deleted AFPAM 32-7089 References & Requirements

7/11/17 Mark Taberner, CH2M

2 Added AFMAN 32-7089 References & Requirements

7/11/17 Mark Taberner, CH2M

Added new 40 CFR Part 82 Requirements

7/11/17 Mark Taberner, CH2M

Editorial changes and added APIMS Refrigerant Management Module Reference Guide Appendix I

11/21/17

Mark Taberner, CH2M

5 Editorial changes 12/4/17 Laura Holeman, CH2M

6 Editorial changes 12/30/18 David Arokiasamy, CH2M

Editorial changes, clarified the 10 April 2020 Refrigerant Management Rule 40 CFR Part 82 Requirements, updated Appendix I

June 2020 Mark Kaschmitter, contractor

2.0 RECORD OF ANNUAL REVIEW

Log completed review action as indicated.

Reviewed By Organization Date Reviewed Remarks

Mark Taberner CH2M 7/11/17

Mark Taberner CH2M 11/21/17

David Arokiasamy CH2M 12/30/18

Mark Kaschmitter Contractor June 2020 See noted changes above

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3.0 DOCUMENT CONTROL INFORMATION

Ensure correct document control information as indicated.

Document Control Information

Title:

Date of Issue:

Effective:

Number:

Supersedes

Author:

Hard Copy distribution of this document is not controlled.

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TABLE OF CONTENTS

Section Page

1.0 PURPOSE

1.1 ENVIRONMENTAL SIGNIFICANCE

1.2 REGULATIONS AND U.S. AIR FORCE GUIDANCE PERTINENT TO

VANDENBERG AIR FORCE BASE

1.2.1 U.S. Environmental Protection Agency Protection of Stratospheric

Ozone

1.2.2 California Air Resources Board Regulation for Managing High Global

Warming Potential Refrigerants for Stationary Sources

1.2.3 Air Force Manual 32-7002, Chapter 3 Hazardous Materials Management...

1.2.4 Air Force Manual 32-7002, Chapter 4Air Quality Compliance and

Resource Management

1.2.5 Air Force Manual 32-7089, Refrigerant Management

1.2.6 Rule Changes by U.S. Environmental Protection Agency Protection of

Stratospheric Ozone

1.2.7 Implementation of the New Title 40, Code of Federal Regulations, Part 82

2.0 RESPONSIBILITIES AND TASKING

2.1 STATIONARY REFRIGERANT MANAGEMENT TASKING

2.1.1 30 CES Commander

2.1.2 30 CES GHG/ODS Program Manager

2.1.3 30 CES Service Contracts

2.1.4 30 CES/Chief of Infrastructure Systems

2.1.5 30 CES/CEOIH Foreman

2.1.6 30 CES Refrigerant Manager

2.1.7 30 CES Work Leads

2.1.8 30 CES/CEOIH Technicians

2.1.9 30th Contracting Squadron

2.2 VEHICLE REFRIGERANT MANAGEMENT TASKING

2.2.1 30 LRS/LGRV Vehicle Management Flight Chief

2.2.2 30 LRS/LGRV Vehicle Maintenance Manager

2.2.3 30 LRS/LGRV Environmental Compliance Assistant

2.2.4 30 LRS/LGRV Non-Commissioned Officer in Charge

2.2.5 30 LRS/LGRV MVAC Technicians

2.3 LAUNCH OPERATIONS SUPPORT CONTRACT TASKING

2.3.1 Launch Operations Support Contract Environmental Health and

Safety Manager

2.3.2 Launch Operations Support Contract System Maintenance Engineer

2.3.3 Launch Operations Support Contract HVAC Technicians

2.4 TASKING FOR OTHER ORGANIZATIONS IN 30TH SPACE WING’S

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“FEDERAL FACILITY” TITLE V PERMIT

3.0 REFRIGERANT INVENTORY, MANAGEMENT, AND REPLACEMENT

3.1 LIST OF REFRIGERANT TYPES

3.2 RECORD KEEPING TOOLS

3.3 STATIONARY EQUIPMENT REGULATORY TIMELINES

3.4 STATIONARY REFRIGERANT APPLIANCE ASSESSMENT AND

RETIREMENT PRIORITY DECISION TREE

4.0 REFERENCES

5.0 ACRONYMS AND ABBREVIATIONS

APPENDICES

Appendix A Glossary Appendix B List of Tasked Organizations Appendix C Refrigerant Types Used at Vandenberg Air Force Base Appendix D Stationary Refrigerant Equipment Regulatory Requirements Appendix E Stationary Refrigerant Compliance and Monitoring Schedule Appendix F Mobile Refrigerant Equipment Regulatory Requirements Appendix G Stationary Refrigerant Unit Assessment/Retirement Priority Decision Tree Appendix H Excerpt AFMAN 32-7089 Attachment 4 Refrigerant Leak Detection and Room Sensors Appendix I APIMS Refrigerant Management Module Reference Guide

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1.0 PURPOSE

The purpose of this Refrigerant Management Plan (RMP) is to help manage refrigerant inventories in compliance with federal and state regulations, as well as U.S. Air Force (USAF) policy. This plan will assist Vandenberg Air Force Base (VAFB) refrigerant users and managers with managing refrigerant resources and systems while ensuring continued mission support. This plan also provides guidance for managing ozone depleting substances (ODSs) and greenhouse gases (GHGs) used as refrigerants on VAFB.

Refrigerant management falls under the purview of the 30th Civil Engineer Squadron (30 CES) Operations Flight Commander, with the support of other base organizations. The Vehicle Management Flight Chief within the 30th Logistics Readiness Squadron/Vehicle Management Flight (30 LRS/LGRV) is responsible for managing vehicle refrigerants. For refrigerant management to be effective, it is imperative that the Refrigerant Manager and other designated personnel have the support of commanders and senior staff.

Subsequent sections of this RMP identify the key base organizations and positions that implement the refrigerant management program at VAFB, noting the major activities for which each organization and position is responsible. The following appendices are also included in this RMP:

Appendix A Glossary Appendix B List of Tasked Organizations Appendix C Refrigerant Types Used at Vandenberg Air Force Base Appendix D Stationary Refrigerant Equipment Regulatory Requirements Appendix E Stationary Refrigerant Compliance and Monitoring Schedule Appendix F Mobile Refrigerant Equipment Regulatory Requirements Appendix G Stationary Refrigerant Unit Assessment/Retirement Priority Decision Tree Appendix H Excerpt from AFMAN 32-7089 Attachment 4 Refrigerant Leak Detection and

Room Sensors Appendix I APIMS Refrigerant Management Module Reference Guide

1.1 ENVIRONMENTAL SIGNIFICANCE

The term ODS is an identifying property of a substance for the purposes of categorization and regulation. Labeling a gas as a GHG identifies a different specific property of that gas for the same purposes. Therefore, a gas can be accurately categorized as both an ODS and a GHG, one of the two, or neither. Many refrigerants are both GHGs and ODSs, and therefore are subject to multiple regulatory requirements.

An ODS is a gas that contributes to the depletion of the stratospheric ozone layer when released into the atmosphere. Ozone is a naturally occurring atmospheric gas found between 20 and 30 miles above the earth. This ozone layer filters out a large percentage of ultraviolet radiation generated by the sun, protecting living organisms on earth. Many ODSs are refrigerants, generally chlorofluorocarbons, and are regulated as ODSs at the national and international levels. The other main class of ODSs is halon, which is addressed separately in the VAFB Halon Management Plan.

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A GHG is a heat trapping gas that absorbs and emits radiation from the earth when released into the atmosphere. An increase in the concentration of GHGs causes a radiative forcing that can only be compensated for by an increase of the surface-troposphere system temperature, known as the enhanced greenhouse effect. This effect contributes to the rise in global average temperatures, or climate change. Refrigerants are scientifically classified as GHGs, and those with global warming potentials (GWPs) of 150 or greater are regulated in California.

Properly managing and minimizing the release of refrigerants acts to mitigate impacts to the ozone layer and climate change.

1.2 REGULATIONS AND U.S. AIR FORCE GUIDANCE PERTINENT TO

VANDENBERG AIR FORCE BASE

1.2.1 U.S. Environmental Protection Agency Protection of Stratospheric Ozone

The U.S. Environmental Protection Agency (EPA) designed Title 40, Code of Federal Regulations, Part 82 (40 CFR 82) to bring the United States into compliance with the internationally ratified Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol) for ozone depletion mitigation. Accordingly, the regulation sets a mandatory phaseout by 2020 for the production of refrigerants classified by EPA as “Class I and Class II substances.” The majority of the stationary refrigerant appliances at VAFB use R-22, also known as hydrochlorofluorocarbon (HCFC)-22. R-22 is a Class II ODS, and it is the only ODS refrigerant used by VAFB.

The EPA phaseout of R-22 production limits the availability of R-22. There is no central stockpile within the USAF to prolong the availability of this refrigerant; therefore, bases need to manage current supplies effectively, while proactively evaluating future replacements. In most cases, the life cycle of refrigerant units allows for the phasing out of old technology, while reclaiming and reusing existing stocks of R-22 extends its availability.

Part 82 also regulates R-134a, also known as hydrofluorocarbon (HFC)-134a, although it is not a Class I or Class II ODS. R-134a is the only refrigerant used in VAFB vehicles. Specifically, Part 82, Subpart B regulates R-134a as follows:

Prohibitions and required practices for servicing, maintaining, repairing, and disposal of motor vehicle air conditioners (MVACs) and MVAC-like appliances

Technician training and certification standards

Record keeping

Standards for recovery only, recovery/recycle, and recovery/recycle/recharging equipment

To maintain compliance with this regulation, the 30 LRS/LGRV vehicle servicing facility performs MVAC service in-house, in a closed system. This system meets each of the applicable provisions of Subpart B, preventing the release of motor vehicle refrigerants during maintenance and servicing operations.

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1.2.2 California Air Resources Board Regulation for Managing High Global Warming Potential Refrigerants for Stationary Sources

The California Air Resources Board (CARB) established 17 California Code of Regulations (CCR) §95380 to §95398 to reduce GHG emissions. The CARB regulation more specifically targets owners and operators of refrigeration systems, with the goal of reducing atmospheric leaks and venting of high-GWP GHGs. Much like the EPA regulation, the CARB regulation requires record keeping and reporting of leak detection, repairs, and retrofits. CARB regulation records must be kept for a minimum of 5 years. If the CARB Refrigerant, Registration, and Reporting System (R3) is used for reporting, these records are inherently maintained for the required period.

CARB’s regulation covers stationary systems using refrigerants with GWP values of at least 150, including R-22, but the CARB regulation contains the following several categorical exclusions that the EPA regulation does not:

Mobile refrigeration systems – exempted by §95380

Residential comfort cooling units – exempted by §95380

Tactical support equipment – exempted by §95381

Systems containing a refrigerant charge of 50 pounds and less – exempted by CARB 2013 Refrigerant Management Program Question and Answer Guidance Document

Systems used solely for air conditioning – exempted by CARB 2013 Refrigerant Management Program Question and Answer Guidance Document

Because of the EPA R-22 production phaseout by 2020, VAFB’s use of this refrigerant will also decline. VAFB replaces or retires refrigerant units based on their condition and economic cycles.

The goal of the 30 CES Heating, Ventilation, and Air Conditioning (HVAC) Shop (30 CES/CEOIH) is to use R-410a and R-134a for refrigeration units and only R-404a for freezer units. 30 CES/CEOIH also intends to eliminate systems with a refrigerant circuit charge of greater than 200 pounds. While replacement refrigerants are appropriate to meet current ODS regulatory requirements, their high GWP values necessitate action under the CARB regulation. The phasing out of old refrigeration appliances presents opportunities to introduce new technology containing alternatives to R-22 that have no ozone depleting potential (ODP), and low or no GWP.

1.2.3 Air Force Manual 32-7002 Chapter 3 Hazardous Materials Management

AFMAN 32-7002 directs USAF bases to comply with the Air Force-wide Refrigerant Management Plan AFMAN 32-7089 Refrigerant Management. The USAF Hazardous Materials Management Process outlined in AFMAN 32-7002 provides guidance on a method to track, analyze, control, and reduce multiple hazardous materials.

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1.2.4 Air Force Manual 32-7002 Chapter 4 Air Quality Compliance and Resource Management

AFMAN 32-7002 establishes a framework for all USAF installations to use in complying with air quality requirements, and explains how to assess, attain, and sustain compliance with the Clean Air Act (CAA) as well as other federal, state, and local environmental regulations (USAF 2016b). This AFMAN requires that air quality compliance and resource management-related data, which include refrigerants, are verified and maintained in the USAF Air Program Information Management System (APIMS). Of further importance to this RMP, it references EPA 40 CFR Part 82 for USAF-wide ODS compliance.

1.2.5 Air Force Manual 32-7089, Refrigerant Management

Air Force Manual (AFMAN) 32-7089 (USAF 2016a) supersedes Air Force Pamphlet (AFP) 32- 7089. AFP 32-7089 replaced the Air Force Civil Engineer Support Agency Refrigerant Management Handbook that outlined a process for refrigerant inventory, assessment, conservation efforts, and replacement implementation. The Refrigerant Management Handbook was developed in 1994 to provide guidance on the EPA ODS regulation and the Montreal Protocol. AFMAN 32-7089 outlines a more detailed and systematic process for refrigerant management, inventories, and record keeping.

1.2.6 Rule Changes by U.S. Environmental Protection Agency Protection of Stratospheric Ozone

On 11 March 2020, EPA released the final rule updating the Refrigerant Management Requirements under the CAA (40 CFR Part 82). The new rule updates the ODS refrigerant management requirements of the existing rule to apply to certain non-ODS replacement chemicals that are classified as potent GHG chemicals. The Part 82 regulations prohibit the knowing release of refrigerants during the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration equipment.

The rule more fully implements the prohibition under Section 608 of the CAA against knowingly venting, releasing, or disposing of ozone-depleting and substitute refrigerants. The rule accomplishes this by updating the existing requirements under Section 608 that currently apply to ozone-depleting refrigerants and then extending, as appropriate, the requirements to non-ozone-depleting substitute refrigerants, such as HFCs, as amended.

A summary of pertinent rule changes is as follows:

The rule regulates ODS refrigerants, such as chlorofluorocarbons (CFCs) and HCFCs. Non-ODS substitute refrigerants that will be subject to Part 82 requirements starting in 2017, 2018, or 2019 include HFCs, hydrofluoroolefins, and

Refrigerant Management Plan Page 5 perfluorinated chemicals. Exemptions are provided for ammonia, propane, and certain other refrigerants.

The modifications to the leak repair requirements apply to all refrigerants (excluding exempt refrigerants) beginning 1 January 2019. Each time a refrigerant is added to an appliance containing ODS refrigerant and 50 pounds and greater of refrigerant, the leak rate must be calculated. The technician is required to provide owners and operators with invoices including the amount of refrigerant added and the results of the leak inspection. The revised leak rate thresholds are as follows:

- 30 percent for Industrial Process Refrigeration (lowered from 35 percent)

- 20 percent for commercial refrigeration (lowered from 35 percent)

- 10 percent for comfort cooling (lowered from 15 percent)

Repairs must be made within 30 days to any equipment with leak rates that exceed these thresholds. The new rule requires verification tests and periodic leak inspections for repaired equipment. A new EPA annual reporting requirement is specified for “chronically leaking appliances,” which are those with an annual leak rate of more than 125 percent of the full charge amount.

The servicing of HFC appliances and the sale of HFC refrigerant will be restricted to certified technicians. Beginning 1 January 2018, certifying organizations will be required to post a list of new technicians certified after 1 January 2017. Technicians will be required to use certified recover and/or recycling equipment when opening an HFC appliance. Proper evacuation levels must be specified before opening an appliance. Prior to disposal, it will be required to remove any refrigerant present in the appliance. In order to reclaim and sell used refrigerant, reclaimers will be required to be certified and must analyze each batch of reclaimed refrigerant.

Following the implementation of the new rule, EPA anticipates the annual GHG emission reductions to be approximately 7.3 million metric tons carbon dioxide equivalents, equaling the annual GHG emissions of 1.5 million cars.

1.2.7 Implementation of the New Title 40, Code of Federal Regulations, Part 82

Steps to be taken to implement the new rule include the following:

Inventory all chillers and refrigeration equipment for types of refrigerant and equipment charge capacity.

Review refrigerants to determine whether they are acceptable or whether they are being phased out because of ODS potential.

Identify all large appliances with ODS refrigerant and greater than 50 pounds refrigerant charge.

Ensure that service is only conducted by a certified technician, and that certified recovery/recycling equipment is used.

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Implement a refrigerant tracking system to compute leak rates for each large appliance.

Implement an annual leak inspection program for large appliances. Further information regarding the Stationary Refrigeration and Air-Conditioning Program is available at http://www3.epa.gov/ozone/title6/608/.

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2.0 RESPONSIBILITIES AND TASKING

VAFB has approximately 120 active refrigerant containing comfort cooling appliances on base with individual refrigerant charges of 50 pounds or greater. 30 CES/CEOIH has approximately 40 certified HVAC technicians. The technicians have attended one-time EPA-required training and keep a copy of their certificates at their place of business as well as in APIMS. This practice maintains VAFB’s compliance with both CARB and EPA requirements.

The VAFB RMP is implemented through the efforts of several key organizations and positions.

The success of the RMP depends on the ability of these personnel and organizations to effectively communicate with one another and to coordinate their respective efforts in carrying out the management program outlined in this document. The VAFB Environment, Safety, and Occupational Health Council is responsible for overseeing these efforts.

2.1 STATIONARY REFRIGERANT MANAGEMENT TASKING

30 CES maintains VAFB real property. Many of these facilities have stationary equipment containing refrigerants used for the purposes of comfort cooling, commercial refrigeration, or industrial process cooling. For a successful refrigerant management program within 30 CES, the responsibilities of the following personnel are necessary.

2.1.1 30 CES Commander

The 30th Civil Engineer Squadron Commander (30 CES/CC) is responsible for the following:

Ensuring implementation of assigned squadron tasks

Maintaining responsibility for VAFB real property refrigerant appliances

Assigning the 30 CES/CEOIH Foreman and one alternate as Refrigerant Manager

2.1.2 30 CES GHG/ODS Program Manager

The 30 CES GHG/ODS Program Manager is responsible for the following:

Developing, maintaining, and providing instruction and guidance related to the

RMP

Ensuring that registration and reporting requirements are submitted to CARB in R3 according to details outlined in Appendix D (Stationary Refrigerant Equipment Regulatory Requirements) and Appendix E (Stationary Refrigerant Compliance and Monitoring Schedule)

Reporting leak exceedance notifications to EPA according to Appendix D (Stationary Refrigerant Equipment Regulatory Requirements) and Appendix E (Stationary Refrigerant Compliance and Monitoring Schedule) and chain of command

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Coordinating the designation of the Refrigerant Manager and acting as alternate when one is not present or designated

2.1.3 30 CES Service Contracts

30 CES Service Contracts is responsible for ensuring that refrigerant management and compliance actions for the Launch Operations Support Contract (LOSC) are accomplished in accordance with contract requirements.

2.1.4 30 CES/Chief of Infrastructure Systems

30 CES/Chief of Infrastructure Systems is responsible for the following:

Ensuring implementation of the RMP within 30 CES

Ensuring that designated personnel within the 30 CES/CEOIH accomplish delegated assignments in a timely manner

Verifying that the 30 CES/CEOIH Foreman is certified according to EPA 40 CFR Part 82

Communicating with the 30 CES GHG/ODS Program Manager regarding the RMP, applicable regulations, and USAF policies

2.1.5 30 CES/CEOIH Foreman

The 30 CES/CEOIH Foreman is responsible for the following:

Obtaining and maintaining certification according to EPA 40 CFR Part 82

Ensuring that all 30 CES/CEOIH technicians and work leads follow procedures listed in the RMP

Ensuring proper training for the 30 CES/CEOIH technicians

Supervising and ensuring that refrigeration work is properly accomplished

Reporting refrigerant status to 30 CES/Chief of Infrastructure Systems

Coordinating appointment of a primary and alternate Refrigerant Manager as directed by 30 CES/CC

2.1.6 30 CES Refrigerant Manager

The 30 CES Refrigerant Manager designated by Environmental Compliance is responsible for the following:

Disseminating RMP updates to the 30 CES/CEOIH technicians

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Maintaining a complete refrigerant equipment inventory in APIMS

Biannually maintaining and checking document recovery unit, pursuant to manufacturer’s recommendations for replacement of faulty equipment

Maintaining records of refrigerant recovery, recycling, and reclaiming equipment that includes manufacturer names, evacuation certification types, date of certification, and refrigerant type on base and in APIMS

Ensuring that recovery units operated by technicians meet evacuation requirements as detailed in 40 CFR Part 82

Monitoring technician certification and ensuring that all technicians are properly certified

Maintaining a record of technician certification in APIMS

Ensuring that leak audits are performed on all equipment according to requirements in Appendix E (Stationary Refrigerant Compliance and Monitoring Schedule).

Refer to Appendix H (AFMAN 32-7089: A5 Refrigerant Leak Detection Methods and Room Sensors) for further guidance.

Maintaining a record of leak audits in APIMS

Using APIMS to maintain a record that indicates the amount of refrigerant added to refrigerant appliances on base on a given date

Following applicable reporting and record keeping requirements for stationary refrigerant appliances (Appendix C)

Overseeing proper storage and security of refrigerants (mechanical rooms do not qualify as storage units)

Maintaining and retiring the current inventory of refrigerants/ODSs on an as-needed cycle (retired ODS will be turned in to the Hazardous Materials Pharmacy).

Ensuring the proper transportation and disposal of used refrigerant, oil, and parts

Using this RMP to ensure compliance with all regulations and guidance referred to in Section 4

Reporting to the 30 CES/CEOIH Foreman and informing the 30 CES GHG/ODS Program Manager of any noncompliant refrigerant activities

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2.1.7 30 CES Work Leads

The 30 CES work leads are responsible for the following:

Performing leak audits on equipment according to requirements in Appendix E (Stationary Refrigerant Compliance and Monitoring Schedule) (refer to Appendix H for further guidance)

Maintaining a record of leak audits in APIMS

Ensuring that all 30 CES/CEOIH technicians follow the procedures listed in the

RMP

Reporting any violations of the RMP by technicians or contractors to the Refrigerant Manager

Identifying needed equipment and services required to comply with applicable CARB and EPA regulations

Reporting the refrigerant status to the Refrigerant Manager

Entering data from work performed on any refrigerant containing equipment used for the VAFB mission into APIMS in a timely manner

2.1.8 30 CES/CEOIH Technicians

The 30 CES/CEOIH technicians are responsible for the following:

Performing leak audits on equipment according to requirements in Appendix E (Stationary Refrigerant Compliance and Monitoring Schedule)

Performing initial leak tests, using an acceptable method, before charging refrigerant into a system (refer to Appendix H for further guidance)

Performing repairs within 14 days of detection except in specific situations when a longer time period is allowed

Performing initial verification test after each repair, and following up with verification test within 30 days of the date the system is operating

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Performing proper refrigerant recovery procedures as required by regulations and guidance referred to in Section 4

Following procedures to eliminate refrigerant contamination and mixing

Ensuring that refrigerants are not vented to the atmosphere for the VAFB mission into APIMS in a timely manner

Notifying the 30 CES/CEOIH work leads if another contractor or technician is observed violating regulatory requirements

2.1.9 30th Contracting Squadron

The 30th Contracting Squadron is responsible for the following:

In coordination with the 30 CES GHG/ODS Program Manager, ensuring that all statutory mandated GHG/ODS-related clauses are incorporated into contracts

Ensuring that contract administration functions are provided pursuant to Federal Acquisition Regulation 42.302; the Contracting Officer may retain any of these functions or assign them to the appropriate designated Contract Administration Service Component for administration

2.2 VEHICLE REFRIGERANT MANAGEMENT TASKING

30 LRS maintains VAFB’s vehicle fleet. Some of these vehicles currently have air-conditioning systems that require R-134a, a high-GWP refrigerant, as the cooling medium. For a successful refrigerant emissions reduction program within 30 LRS/LGRV, the responsibilities of the following personnel are necessary.

2.2.1 30 LRS/LGRV Vehicle Management Flight Chief

The 30 LRS/LGRV Vehicle Management Flight Chief is responsible for the following:

Implementing the RMP for 30 LRS/LGRV

Disseminating RMP updates to the Vehicle Maintenance Manager

2.2.2 30 LRS/LGRV Vehicle Maintenance Manager

The 30 LRS/LGRV Vehicle Maintenance Manager is responsible for the following:

Ensuring that the RMP and all other applicable vehicle refrigerant regulatory requirements are implemented

Ensuring that delegated assignments in vehicle maintenance are being accomplished in a timely manner

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Reporting high-GWP vehicle refrigerant status to the Vehicle Management Flight Chief as needed

2.2.3 30 LRS/LGRV Environmental Compliance Assistant

The 30 LRS/LGRV Environmental Compliance Assistant is responsible for the following:

In coordination with the Vehicle Maintenance Manager, ensuring that the RMP and all other vehicle refrigerant regulatory requirements are implemented

Ensuring that delegated assignments in 30 LRS/LGRV are being accomplished in a timely manner

Retaining required records of MVAC technician certifications, as well as records of the name and address of any facility to which disposed refrigerant is sent according to EPA Part 82, Subpart B

Ensuring that recovery, recycle, and recharging equipment is properly labeled according to EPA Part 82, Subpart B, Appendix C

Communicating with the 30 CES GHG/ODS Program Manager regarding the RMP and vehicle refrigerant regulations

Reporting vehicle refrigerant status to the Vehicle Maintenance Manager

2.2.4 30 LRS/LGRV Non-Commissioned Officer in Charge

The 30 LRS/LGRV Non-Commissioned Officer in Charge is responsible for the following:

Ensuring that only certified technicians work on vehicle refrigerant equipment

Completing required records for all vehicle refrigerant-related activities

Reporting vehicle refrigerant status to the Environmental Compliance Assistant

2.2.5 30 LRS/LGRV MVAC Technicians

30 LRS/LGRV MVAC technicians are responsible for the following:

Following the RMP

Completing required records for all vehicle refrigerant-related activities

Following procedures to eliminate refrigerant contamination and mixing

Performing proper vehicle refrigerant recovery procedures as required by 40 CFR Part 82, Subpart B

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Recovering and recycling refrigerant from vehicles before vehicles are turned in to the Defense Reutilization and Marketing Office

Ordering vehicle refrigerant, as needed, from the Hazardous Materials Pharmacy

Preventing vehicle refrigerant releases to the atmosphere

Notifying their Floor Supervisor or the Non-Commissioned Officer in Charge if another contractor or technician is observed violating vehicle refrigerant regulatory requirements

2.3 LAUNCH OPERATIONS SUPPORT CONTRACT TASKING

2.3.1 Launch Operations Support Contract Environmental Health and Safety Manager

The LOSC Environmental Health and Safety Manager (EHSM) is responsible for the following:

Ensuring that the LOSC System Maintenance Engineer (SME) and technicians follow the RMP.

Informing the SME and technicians of any updates to the RMP for the VAFB mission into APIMS in a timely manner

Overseeing proper storage and security of refrigerants (mechanical rooms do not qualify as storage units)

Following all applicable reporting and record keeping requirements for stationary refrigerant appliances; refer to Appendix D (Stationary Refrigerant Equipment Regulatory Requirements) for details

Ensuring that the SME and technicians perform leak detection and monitoring, perform leak repairs, prepare retrofit or retirement plans for any leaking stationary refrigerant appliances, and follow required service practices for stationary high- GWP appliances; refer to Appendix D and Appendix H for details

Maintaining an inventory of refrigeration units serviced by LOSC

Monitoring LOSC HVAC technician certification, and ensuring that all technicians are properly certified

Informing the 30 CES GHG/ODS Program Manager of any noncompliant refrigerant activities

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2.3.2 Launch Operations Support Contract System Maintenance Engineer

The LOSC System Maintenance Engineer is responsible for the following:

Identifying equipment and services needed to be in compliance with EPA 40 CFR Part 82 and CARB 17 CCR § 95380 - § 95398

Ensuring that all LOSC HVAC technicians follow the RMP

Reporting any violations of the RMP by LOSC HVAC technicians to the EHSM

2.3.3 Launch Operations Support Contract HVAC Technicians

The LOSC HVAC technicians are responsible for the following:

Performing leak detection, monitoring, and repairs; preparing retrofit or retirement plans for any leaking stationary refrigerant appliances; and following required service practices for stationary high-GWP appliances in accordance with 17 CCR § 95380 - § 95398

Notifying the EHSM and SME if another contractor or technician is observed violating regulatory requirements

2.4 TASKING FOR OTHER ORGANIZATIONS IN 30TH SPACE WING’S

“FEDERAL FACILITY” TITLE V PERMIT

Other organizations in 30th Space Wing’s “Federal Facility” Title V Permit are responsible for the following:

Performing refrigerant management actions in compliance with EPA 40 CFR Part 82 and CARB 17 CCR §95380 – §95398, as described in Section 2.3

Ensuring that assigned or contracted HVAC technicians perform leak detection and monitoring, perform leak repairs, prepare retrofit or retirement plans for any leaking stationary refrigerant appliances, and follow required regulatory service practices for stationary high-GWP appliances; refer to Appendix D and Appendix H for details

Maintaining refrigerant records as required by EPA and CARB regulations, and promptly responding to the 30 CES GHG/ODS Program Manager’s request for information needed to complete regulatory reports, or to respond to regulators’ request for information

Coordinating the organization’s refrigerant management compliance actions with the 30 CES GHG/ODS Program Manager

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3.0 REFRIGERANT INVENTORY, MANAGEMENT, AND

REPLACEMENT

The survey and assessment of the condition of all refrigerant appliances maintained and operated by VAFB is an ongoing process. To meet the USAF refrigerant assessment and replacement prioritization goals, VAFB uses the analysis tools listed in this section.

3.1 LIST OF REFRIGERANT TYPES

Appendix C contains a list of the refrigerant types used in appliances and storage containers at

VAFB.

3.2 RECORD KEEPING TOOLS

The 30 CES/CEOIH and LOSC contractor maintains a current list of shop-managed equipment, organized by refrigerant, in APIMS. The APIMS Refrigerant Management Module Reference Guide is in Appendix I and provides step-by-step instructions on how to create and edit service records, update refrigerant and equipment inventories, and record leak repair verifications. The use of APIMS is mandated by AFMAN 32-7002. Records including complete inventory, leak detection, and repair of refrigerant equipment are updated regularly to keep current with the applicable regulatory requirements. The 30 CES GHG/ODS Program will ensure that all necessary records are kept current in R3.

Records for each stationary refrigeration appliance must include the details found in this RMP’s Appendix D. Records for mobile refrigeration equipment are in Appendix F (Mobile Refrigerant Equipment Regulatory Requirements).

3.3 STATIONARY EQUIPMENT REGULATORY TIMELINES

Appendix G provides a scheduling timeline for when registration, reporting, leak detection, and repair are to occur.

3.4 STATIONARY REFRIGERANT APPLIANCE ASSESSMENT AND

RETIREMENT PRIORITY DECISION TREE

Priorities for repair, retrofit, and retirement of refrigerant appliances are determined through appropriate analysis in Appendix G. The decision tree shows the technical analysis and action for determining the repair, retrofit, and retirement of current equipment. The system depicted allows for a simplified, structured evaluation of which units to replace, while allowing the 30 CES/CEOIH, LOSC, and other organizations or contracts to include their expert subjective opinions. A leaking system is more likely to be replaced than an older system strictly because of the inherent problems associated with a leaky system (for example, being out of regulatory compliance).

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4.0 REFERENCES

California Air Resources Board (CARB). Regulation for the Management of High Global Warming Potential Refrigerants. Title 17, Code of California Regulations, §95380 - §95398.

U.S. Air Force (USAF). 2016a. AFMAN 32-7089, Refrigerant Management Program.

U.S. Air Force (USAF). 2020. AFMAN 32-7002, Environmental Compliance and Pollution Prevention

U.S. Environmental Protection Agency (EPA). Title 40, Code of Federal Regulations, Part 82.

Protection of Stratospheric Ozone.

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5.0 ACRONYMS AND ABBREVIATIONS

30 CES 30th Civil Engineer Squadron

30 CES/CC 30th Civil Engineer Squadron Commander

30 CES/CEOIH 30th Civil Engineer Squadron Heating, Ventilation, and Air Conditioning Shop

30 LRS/LGRV 30th Logistics Readiness Squadron/Vehicle Management Flight

AF Air Force

AFMAN Air Force Manual

AFP Air Force Pamphlet

APIMS Air Program Information Management System

CAA Clean Air Act

CARB California Air Resources Board

CCR California Code of Regulations

CES Civil Engineer Squadron

CFC chlorofluorocarbons

CFR Code of Federal Regulations

EHSM Environmental Health and Safety Manager

EPA U.S. Environmental Protection Agency

GHG greenhouse gas

GWP global warming potential

HCFC hydrochlorofluorocarbon

HFC hydrofluorocarbon

HVAC heating, ventilation, and air conditioning

LOSC Launch Operations Support Contract

Refrigerant Management Plan Page 19

Montreal Protocol Montreal Protocol on Substances that Deplete the Ozone Layer

MVAC motor vehicle air conditioner

ODP ozone depleting potential

ODS ozone depleting substance

R3 Refrigerant, Registration, and Reporting System

RMP Refrigerant Management Plan

SME System Maintenance Engineer

VAFB Vandenberg Air Force Base

APPENDIX A GLOSSARY

GLOSSARY

Appliance means any device that contains and uses a high-GWP refrigerant, including any air conditioner, refrigerator, chiller, freezer, or refrigeration system.

Chlorofluorocarbon (CFC) means a class of compounds primarily used as refrigerants consisting of only chlorine, fluorine, and carbon.

Global Warming Potential (GWP) is a concept developed to compare the ability of each GHG to trap heat in the atmosphere, relative to the reference gas of carbon dioxide. The definition of a GWP for a particular greenhouse gas is the ratio of heat trapped by one unit mass of the greenhouse gas to that of one unit mass of carbon dioxide over a specified period. Thus, the GWP of carbon dioxide is defined to be 1.0, and all other GHGs have greater GWPs.

Greenhouse gas (GHG) refers to any gas that absorbs infrared radiation in the atmosphere. GHGs include carbon dioxide, methane, nitrous oxide, ozone, chlorofluorocarbons, hydrochlorofluorocarbons, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.

High-GWP refrigerant is a compound used as a heat transfer fluid or gas that is (1) a chlorofluorocarbon, a hydrochlorofluorocarbon, a hydrofluorocarbon, a perfluorocarbon, or any compound or blend of compounds, with a GWP value equal to or greater than 150, or (2) any ODS as defined in Title 40, Code of Federal Regulations, Part 82, §82.3 (as amended March 10, 2009).

Hydrochlorofluorocarbon (HCFC) is a class of compounds primarily used as refrigerants, consisting of only hydrogen, chlorine, fluorine, and carbon.

Hydrofluorocarbon (HFC) is a class of compounds primarily used as refrigerants, consisting of only hydrogen, fluorine, and carbon.

Ozone depleting substance (ODS) is a family of synthetic compounds that includes, but is not limited to, CFCs, bromofluorocarbons (halons), methyl chloroform, carbon tetrachloride, methyl bromide, and HCFCs. These compounds have been shown to deplete stratospheric ozone;

therefore, they are typically referred to as ODSs.

Ozone Depletion Potential (ODP) is a number that refers to the amount of ozone depletion caused by a substance. The ODP is the ratio of the impact of a chemical on the ozone layer compared to the impact of a similar mass of CFC-11. Thus, the ODP of CFC-11 is defined to be 1.0, and all other ODSs have greater or lesser ODPs.

System mothballing means the intentional shutting down of a refrigeration system for a period of time greater than 60 days by the owners or operators of that facility, where the refrigerant has been evacuated from the refrigeration system or the affected component of the refrigeration system, at least to atmospheric pressure.

Refrigerant leak means any discharge of refrigerant into the atmosphere from an appliance, certified refrigerant recovery or recycling equipment, refrigerant cylinder, or other container.

APPENDIX B LIST OF TASKED ORGANIZATIONS

LIST OF TASKED ORGANIZATIONS

ORGANIZATION: OFFICE SYMBOL/ACRONYM

30th Civil Engineer Squadron Commander 30 CES/CC

30th Civil Engineer Squadron Environmental Compliance 30 CES/CEIEC

30th Civil Engineer Squadron HVAC Shop 30 CES/CEOIH

30th Civil Engineer Squadron Infrastructure Systems 30 CES/CEOI

30th Civil Engineer Squadron Service Contracts 30 CES/CEOES

30th Contracting Squadron 30 CONS

30th Logistics Readiness Squadron/Vehicle Management Flight 30 LRS/LGRV

Launch Operations Support Contract LOSC

OTHER ORGANIZATIONS:

30th Medical Support Squadron 30 MDSS/SGSLF

Defense Commissary Agency DeCA/WP-VRG

APPENDIX C REFRIGERANT TYPES USED AT

VANDENBERG AIR FORCE BASE

REFRIGERANT TYPES USED AT VANDENBERG AFB

Refrigerants and Halon Blend ODP (CCl3F = 1) GWP (CO2 = 1) Source

Monochlorodifluoromethane (R-22) (HCFC-22) (CHF2Cl)

No

0.055

1,700

EPA

Refrigerant (R-410a) Blend of R-32 and R-125 None 1,725 EPA

Refrigerant (R-404a) Blend of R-143a, R-125, and R-134a None 3,260 EPA

1,1,1,2-Tetrafluoroethane (R-134a) (HFC-134a) (CH2FCF3)

None

1,300

EPA

Refrigerant (R-407c) Blend of R-32, R-125, and R-134a None 1,526 EPA

Used in Blends

Difluoromethane

(R-32) (HFC-32) (CH2F2)

Not applicable None 550 EPA

Pentafluoroethane

(R-125) (HFC-125) (CF3CHF2)

Not applicable None 3,400 EPA

1,1,1-Trifluoroethane (R-143a) (HFC-143a) (C2H3F3)

Not applicable None 4,300 EPA

1,1,1,2-Tetrafluoroethane (R-134a) (HFC-134a) (CH2FCF3)

Not applicable None 1,300 EPA

APPENDIX D STATIONARY REFRIGERANT

EQUIPMENT REGULATORY

REQUIREMENTS

STATIONARY REFRIGERANT EQUIPMENT REGULATORY

Regulatory Record Keeping Checklist as Required by 17 CCR §95380-§95398

§95383 (e) All Facilities and Systems Information: a

(1) Facility Information:

(A) Name of operator

(B) Federal tax ID number

(C) NAICS business type code (2007 NAICS U.S. structure)

(D) Facility Standard Industry Classification code (SIC)

(E) Name of the facility

(F) Mailing address

(G) Physical address

(H) Facility contact person

(I) Facility contact person phone number

(J) Facility contact person email address

(2) Refrigeration System Information:

(A) System ID number (assigned by facility owner or operator)

(B) Equipment type (per definition in regulations)

(C) Equipment manufacturer

(D) Equipment model or description

(E) Equipment model year

(F) Equipment serial number

(G) Physical location (description through schematic or floor plan with locations clearly noted)

(H) Temperature classification (i.e. low, medium, high, or other)

(I) Full charge of the refrigeration system

All refrigerant systems component data, measurements, calculations and assumptions used to determine the full charge

(J) Type (name) of high-GWP refrigerant used

§95388 (b) Automatic Leak Detection System Audit, Leak Inspection, and Refrigeration System Service or Refrigerant Leak Repair Information:b

(1) Refrigerant System Information:

(A) System ID number (assigned by facility owner or operator)

(B) Equipment type

(C) Equipment manufacturer

(D) Equipment model

(E) Equipment model year

(F) Equipment serial number

(G) Physical location

(H) Temperature classification (i.e. low, medium, or other)

(I) Full charge of the refrigeration system

(J) Type of GWP-refrigerant(s) used

(K) Date of initial installation

(2) Refrigerant System Service and Leak Repair Information:

(A) Date leak detected/date of inspection, if applicable

(B) Date of service provided or leak repair completed

(C) Cause of leak, if applicable

(D) Description of service provided or leak repair completed

(E) Date of initial verification, if applicable

(F) Date of follow-up verification, if applicable

(G) Total additional refrigerant charge of each type of refrigerant, if applicable

(H) Purpose for additional charge, if applicable

(I) Name of certified technician, if applicable

(J) Technician's certification ID number (certification program pursuant to Title 40 CFR, Part 82, §82.161), if applicable

(K) Technician's certification type (certification program pursuant to Title 40 CFR, Part 82, §82.161), if applicable

§95388 (3) Purchases and Use Annual Information (in lbs of each type of high-GWP in calendar year):

(A) Total weight purchased

(B) Total weight charged into a refrigeration system

(C) Total weight recovered from a refrigeration system

(D) Total weight stored in inventory at the facility or stored at a different location for use by the facility

(E) Total weight shipped by owner/operator for reclamation/destruction

§95389 (a) Documentation (Plans, Reports, etc.):

(2) All leak detection systems, leak inspections, and automatic leak detection system annual audit and calibrations documentation

(4) Retirement plans including disposal plan and timetable

(4) Retrofit plans including a timetable

(6) Any application for…