TE1-001_ODS_and_Refrigerants.docx

TE 1-001

Instructions on handling of Ozone Depleting Substances (ODS) and Refrigerants

Environmental Requirements: Pursuant to 40 CFR 82 and the Clean Air Act, the contractor shall follow the following reporting and recordkeeping requirements.

1. The contractor shall maintain a comprehensive inventory of all types of military-owned refrigerant. The inventory will list the type of refrigerant, amount of refrigerant (lbs.), and cylinder identification numbers in which it is stored. A copy of the inventory will be submitted to the EMD Air Quality Program Manager by the 10th of the each month that documents additions/deletions (lbs.) to the weights from the previous month.

2. All refrigerant paid for by Fort Knox, dispensed into, and/or removed from a government-owned HVAC unit remains the property of the military. This refrigerant inventory will remain within the property boundaries of Fort Knox, unless prior written approval has been obtained by the COR for off-site reclamation or recycling.

3. The contractor will abide by the requirements of the most current version of the DoD Ozone Depleting Substances Turn-In Procedures. (Technical Exhibit 5.2-39) The procedure requires that the following types of excess refrigerant be turned into the ODS Reserve located in Richmond, Va.: CFCs 11, 12, 114, 500, 502 and HCFC-22. The Reserve accepts both used and new CFCs and HCFC-22 in a relatively pure state. The contractor is to notify the Environmental Management Division (EMD) Air Quality Program staff immediately when it determines that it has developed an excess quantity of the listed refrigerants that is no longer needed on post. EMD will initiate the process of obtaining government-owned compressed gas cylinders. The contractor shall transfer the refrigerant into the government-owned gas cylinders and transport them to Fort Knox’s base maintenance contractor who arrange for turn in to the ODS Reserve.

4. The contractor will maintain proof that all refrigerant recovery and recycling equipment is properly certified, properly labeled, and that certifications have been submitted to the US EPA. Retests or inspections of certified equipment shall be completed at least once every three years following initial certification. Documentation of certifications, completion of testing or inspections must be maintained onsite and available for inspection. Per regulation 82.158, any new recovery and recycling equipment manufactured or imported after January 1, 2017 must be certified by an EPA approved equipment testing organization to meet the requirements specified in the regulation. Equipment should be labeled as meeting the EPA certification requirements for Class I, Class II, and any non-exempt substitute refrigerant. Submittal of equipment certifications to EPA is no longer required as of January 1, 2017. (Refer to Technical Exhibit 5.2- 41 for specific regulatory text)

5. The contractor will maintain records of the name and address of any facility used to recycle or reclaim refrigerant and the date, type, and amount of refrigerant sent to such facilities. All recycle and/or reclamation facilities must have obtained and maintain proper certification by US EPA.

6. For all appliances, a Refrigerant Record maintenance form shall be thoroughly completed and, at a minimum, will include the following information: Building number where appliance located; serial number, full charge rate of appliance, refrigerant type; addition and/or deletion volumes of refrigerant; sufficient explanation as to why refrigerant was added, date of discovery of a leak, date of leak repair, and dates of initial leak tests, and, if completed, date of any follow-up leak test; and service technicians name. A copy of those records must be forwarded to the EMD Air Quality Program Manager by the 10th of each month.

7. Per 40 CFR 82.150 and 82.156, until January 1, 2018, the following requirements only apply to class I or class II refrigerants. Starting January 1, 2018, the requirements apply to those appliances containing any class I and class II refrigerants or any non-exempt substitute refrigerants. For appliances containing 50 lbs. or more of either a Class I or Class II refrigerant, or any non-exempt substitute refrigerants per 40 CFR 82.150 and 82.156, the following information shall be forwarded to the EMD Air Quality Program Manager on a monthly basis and sent by the 10th of the following month;

(a) In addition to the information on the Refrigerant Records maintenance form, leak rates must be calculated upon conclusion of the service to determine if the rate exceeds the following threshold values: 35% for commercial refrigeration units; 35% for industrial refrigeration; 15% for comfort cooling units [Calculation of a leak rate is mandatory for appliances with 50 lbs. or more of either a Class I or Class II refrigerant, or non-exempt substitute refrigerant.

(b) Calculations are to be completed by the annualized method listed under the definition of Leak Rate (Method 1) of 40 CFR82.152]

(c) The full charge of the unit.

(d) The date a leak rate above the applicable allowable rate was discovered.

(e) The date leak was repaired.

8. Comply with the reporting and recordkeeping requirements for leak repairs listed under 82.166 until January 1, 2019. Note that leak calculations and associated documentation are currently required as specified under Section 5.2.17.7. (Refer to Technical Exhibit 5.2- 41 for specific regulatory text)

9. Starting January 1, 2019 maintenance and leak repairs must be completed according to the requirements of regulation 40 CFR 82.157. The regulation applies to appliances with a full charge > 50 pounds of any class I, class II refrigerant, or any non-exempt substitute refrigerant. The following is a partial list of those requirements. Please refer to the attached regulation to review all requirements. (Refer to Technical Exhibit 5.2- 40 for specific regulatory text)

(a) Leak rate calculations must be conducted by the persons (certified technicians) adding or removing refrigerant upon conclusion of the service, unless the addition is made immediately following a retrofit, installation of a new appliance, or qualifies as seasonal variance.

(b) Leak rate thresholds are lowered to: 30% industrial refrigeration, 20% commercial refrigeration, 10% for comfort cooling appliances.

(c) Leaks must be repaired within 30 days to reduce leaks to the extent possible and below the thresholds listed in line (b).

(d) All leak inspections must be conducted by a certified technician

(e) Provide the owner with the following documentation and maintain such records for each appliance until three years after appliance is retired:

a. Identification of owner or operator of appliance;

b. Address where appliance is located;

c. The full charge of the appliance and the method used to determine the full charge;

d. If using method 4 (using an established range) for determining full charge, records must include the range for the full charge, its midpoint, and how the range was determined;

e. Any revisions of the full charge, how they were determined, and the dates such revisions occurred;

f. Date of maintenance, service, repair, or disposal performed;

g. Type of maintenance, service, repair, or disposal performed for each part;

h. Name of the person performing the maintenance, service, repair, or disposal;

i. Amount and type of refrigerant added to, or in the case of disposal removed from, the appliance;

j. The leak rate and the method used to determine the leak rate (not applicable when disposing of appliance, following a retrofit, installing a new appliance, or if the refrigerant addition qualifies as a seasonal variance)

k. Leak inspections that include the date of inspection, methods used to conduct the leak inspection, a list of the location of each leak that was identified, and a certification that all visible and accessible parts of appliance were inspected.

l. Maintain records, dates, and results of all initial and follow-up verification tests that include: location of appliance, date(s) of verification tests, location(s) of all repaired leaks that were tested, type(s) of verification tests used, and test results.

(f) Both initial and follow-up verification tests must be conducted on each leak that was repaired.

a. Initial verification tests must be performed within 30 days of an appliance exceeding he applicable leak rate specified in section (b) above. The initial verification test must demonstrate that leaks where a repair attempt was made are repaired.

i. For repairs that can be completed without the need to open or evacuate the appliance, the test must be performed after conclusion of the repair work and before any additional refrigerant is added to the appliance.

ii. For repairs that require the evacuation of the appliance or portion of the appliance, the test must be performed before adding any refrigerant to the appliance.

iii. If the initial verification test indicates that the repairs have not been successful, the owner or operator may conduct as many additional repairs and initial verification tests as needed within the applicable time period.

b. A follow-up verification test must be performed within 10 days of the successful initial verification test or 10 days of the appliance reaching normal operating characteristics and conditions (if the appliance or isolated component was evacuated for the repair(s)) Where it is unsafe to present or otherwise impossible to conduct a follow-up verification test when the system is operating at normal operating characteristics and conditions, the verification test must, where practicable, be conducted prior to the system returning to normal operation characteristics and conditions.

i. The verification test must demonstrate that leaks where a repair attempt was made are repaired. If the follow-up verification indicates that the repairs have not been successful, the owner or operator may conduct as many additional repairs and verification tests as needed to bring the appliance below the leak rate within the applicable time period and to verify the repairs.

c. Per 82.157(f), extensions to the 30 day repair deadline may be allowed under certain circumstances such as parts needed for repair cannot be obtained within 30 days. However, additional documentation and reporting to EPA is required. Refer to regulation 82.157 for specific details.

i. If the HVAC contractor or technician determine that it will take longer than 30 days to repair a leak, the contractor is to notify the EMD Air Quality Program Manager by COB the next business day following that determination.

ii. Completion of verification tests (initial and follow-up) or the requirement to request extensions to repair deadlines beyond 30 days is suspended if the appliance is mothballed. Mothballing is defined as evacuating refrigerant from an appliance or the affected isolated section, to at least atmospheric pressure, and temporarily shut down the appliance.

d. Per 82.157(g), leak inspections are to be conducted in accordance with the following schedule on any appliance exceeding the applicable leak rate listed in (b).

i. For commercial refrigeration and industrial process refrigeration appliances with a full charge of 50 or more pounds but less than 500 pounds, leak inspections must be conducted once per calendar year until the owner or operator can demonstrate through the leak rate calculations required under paragraph (b) of this section that the appliance has not leaked in excess of the applicable leak rate for one year.

ii. For comfort cooling appliances and other appliances not covered by paragraph i (above) leak inspections must be conducted once per calendar year until the owner or operator can demonstrate through the leak rate calculations required under paragraph (a) that the appliance has not leaked in excess of the applicable leak rate listed in section (b) for one year.

10. Safe disposal of appliances: Per 82.155, starting in January 1, 2018, this section applies to disposal appliances containing class I, class II, or any non-exempt substitute refrigerant. (Refer to Technical Exhibit 5.2- 41 for specific regulatory text)

(a) Persons recovering refrigerant from small appliances, MVAC, or MVAC-like appliances, for the purposes of disposal of these appliances must evacuate refrigerant to the levels specified in 82.156(b) through (d). See Technical Exhibit TE 5.2-041

(b) Follow the procedures and maintain the documentation listed in 82.155 (b) through (c).

11. Technicians must be properly certified according to the requirements of 40 CFR 82.161 and have a copy of their certificate(s) available at Fort Knox and available for inspection. Starting January 1, 2018, new technicians must also be certified to maintain, service, or repair appliances containing not only Class I or II refrigerants, but also any non-exempt substitute refrigerant. (Refer to Technical Exhibit 1-003 for specific regulatory text)