Chapter 24 - Ozone-Depleting Chemical Elimination Plan.pdf

Ozone-Depleting Chemical Elimination Plan

FT. GREELY, ALASKA

OZONE-DEPLETING CHEMICAL (ODC)

ELIMINATION PLAN

AUGUST 2005

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TABLE OF CONTENTS

Page TABLE OF CONTENTS ............................................................................................................................ i LIST OF FIGURES .................................................................................................................................... ii LIST OF TABLES ...................................................................................................................................... ii ACRONYMS AND ABBREVIATIONS.................................................................................................. iii

Chapter 1.0 INSTALLATION BACKGROUND AND DESCRIPTION

Chapter 2.0 RESPONSIBILITIES

Chapter 3.0 INVENTORY

3.1 ODC INVENTORY

3.2 ODC INVENTORY CONTENT

3.2.1 CFC Equipment Inventory

3.2.2 Halon Equipment Inventory

3.2.3 ODC Equipment Not Included in Inventory

3.3 CURRENT ODC USES AT FT. GREELY

3.3.1 CFCs

3.3.2 Halons

Chapter 4.0 LAWS AND POLICY APPLICABLE TO ODC ELIMINATION

4.1 CLEAN AIR ACT (SECTION 602)

4.2 CLEAN AIR ACT (SECTION 608)

4.3 CLEAN AIR ACT (SECTION 612)

4.4 40 CFR 82 (LEAK LIMITS)

4.5 PUBLIC LAW 102-484 (SECTION 326)

4.6 ARMY ODC POLICY

Chapter 5.0 RECOVERY AND TURN-IN

5.1 CFC RECOVERY

5.2 HALON RECOVERY

5.3 EXCESS ODCS

5.4 FT. GREELY EXCESS ODC TURN-IN PROCEDURE

Chapter 6.0 MANAGEMENT

6.1 CLASS I ODC PRIORITIZATION

6.1.1 Refrigerants

6.1.2 Halons

6.2 REFRIGERANT ELIMINATION PLAN

6.2.1 Plan Overview

6.2.2 Refrigerant Uses At Ft. Greely

6.2.2.1 R-12 Uses

i

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TABLE OF CONTENTS (Concluded)

Page

6.2.2.2 R-113 Uses

6.2.2.3 R-502 Uses

6.3 REFRIGERANT ALTERNATIVES

6.4 ELIMINATION SCHEDULE

Chapter 7.0 RESOURCES

Appendix A. Ft. Greely, Alaska, Ozone-Depleting Chemical Inventory (Refrigerants) .................A-1

LIST OF FIGURES

Figure

1-1 Ft. Greely Installation ODC Sites

LIST OF TABLES

Table Page

4-1 CFC Annual Leak Limits 6-1 Summary of Refrigerant Usage ii

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ACRONYMS AND ABBREVIATIONS

AAE Army Acquisition Executive AAFES Army and Air Force Exchange

Service AC&R Air Conditioning and

Refrigeration ACSIM Assistant Chief of Staff for

Installation Management ALT Acquisition, Logistics, and

Technology ASA Assistant Secretary of the Army BRAC Base Realignment and Closure BTU British Thermal Unit CAA Clean Air Act CFC Chlorofluorocarbon DA Department of the Army DASA(ESOH) Deputy Assistant Secretary of the Army for Environment, Safety, and Occupational Health

DLA Defense Logistics Agency DoD Department of Defense DSCR Defense Supply Center Richmond

EPA Environmental Protection Agency FGA-ENV Ft. Greely Alaska, Directorate of

Public Works, Environmental Division

ESO Environmental Support Office FY Fiscal Year GSA General Services Agency HCF Hydroflurocarbon HCFC Hydrochloroflurocarbon HP Horsepower IL&E Installations, Logistics, and

Environment ODC Ozone-Depleting Chemical ODS Ozone-Depleting Substance OMA Operations and Maintenance, Army PL Public Law RPMA Real Property Maintenance

Account SNAP Significant New Alternatives

Policy USEPA United States Environmental

Protection Agency iii

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CHAPTER 1.0:

INSTALLATION BACKGROUND AND DESCRIPTION

The Installation Commander is responsible for ensuring that the installation’s dependency on the commercial availability of Class I Ozone-Depleting Chemicals (ODCs) is eliminated by the end of Fiscal Year (FY) 03 [Department of the Army (DA), Assistant Chief of Staff Installation Management (ACSIM) Memorandum dated January 7, 2003]. However, because Ft. Greely was placed on the Base Realignment and Closure (BRAC) list in 1995 and was not removed until 2000, it did not meet this deadline. During these 5 years, no ODC elimination projects were completed.

This ODC Elimination Plan focuses on identifying alternative materials for Air Conditioning and Refrigeration (AC&R) systems. Because halon systems were removed in 2002, they are not covered in this Plan. This Plan includes the most recent ODC inventory and the recommended refrigerant to eliminate the use of Class I ODCs on the installation.

Ft. Greely is located in the Interior of Alaska, approximately 90 miles east-southeast of Fairbanks. Ft. Greely came into being in 1942 as a staging area for planes ferried to the Soviet Union during World War II under the “Lend Lease” program. In 1955, Ft. Greely was designated as a cold weather training and testing ground for the U.S. Army. Then, in 1966, the Army began using the base and nearby Gerstle River Military Reservation as sites for testing biological, chemical, and other weapons. In 1995, the base was scheduled for closure under the BRAC.

More recently, the Department of Defense proposed that Ft. Greely become a storage area for interceptor missiles to be used in support of the space-oriented National Missile Defense program.

A Ft. Greely-wide layout of ODC usage areas (highlighted buildings) can be found in Figure 1-1.

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Figure 1-1. Ft. Greely Installation ODC Usage Areas

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CHAPTER 2.0:

RESPONSIBILITIES

The first step in preparing an installation ODC elimination plan is to identify who is responsible for using ODCs, and therefore, who is responsible for their removal. The final responsibility rests with the Installation commander.

The Ft. Greely Directorate of Public Works, Environmental Division (FGA-ENV) will be responsible for the day-to-day oversight of the ODC elimination program. The FGA-ENV will resolve key issues, if necessary, as outlined in this plan.

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CHAPTER 3.0:

INVENTORY

Because the core of the ODC elimination effort is the ODC inventory, it is important that the inventory be accurate, complete, and up to date. The development of the ODC Elimination Plan includes an inventory of all refrigeration and halon sources. The information contained in the inventory will be needed to evaluate options and provide recommendations for the retrofit or replacement of refrigerant and/or halon systems.

3.1 ODC INVENTORY

The following guidelines define an accurate Class I ODC inventory.

• Include only Air Conditioning and Refrigeration (AC&R) equipment that use CFC refrigerant. Do not include equipment that uses Hydrofluorocarbons (HFCs), such as R-134a or Hydrochlorofluorocarbon (HCFCs) such as R-22 (Class II ODCs).

• Include only fire suppression systems that use halon 1301. Do not include fire suppression systems that use HFCs, such as FM-200TM, or inert gases, such as InergenTM. Also, do not include halon 1211 fire extinguishers, because they are being replaced through attrition.

The following guidelines define a complete Class I ODC inventory.

• Include all serviced CFC equipment. Do not include hermetically sealed equipment such as home refrigerators, window air conditioners, or drinking fountains.

• Include all halon 1301 fixed flooding systems, regardless of the size or condition of the systems. Include all systems that will incur a cost to remove or replace.

• Include any bulk halon 1211 uses.

• Include basic information on each ODC system. Basic information should include location of the system, type and amount of ODC installed, and the use and condition of the system.

The following guideline defines an up-to-date Class I ODC inventory.

• Validate the most recent ODC inventory with a building-by-building inspection of equipment and systems. The inspection should be performed by someone who is familiar with where the Class I ODCs are used.

3.2 ODC INVENTORY CONTENT

3.2.1 CFC Equipment Inventory

To allow for proper planning to retrofit or replace the equipment, the following detailed information (along with the basic information stated above) will be collected for each piece of AC&R equipment:

• Leak rate, in pounds of refrigerant (could be annual, bi-annual, or monthly.

• Contact information for persons responsible for the day-to-day operation of the equipment

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• Contact information for contractor (or unit) responsible for servicing the equipment

• Average power use (if available).

3.2.2 Halon Equipment Inventory

The following information (along with the basic information stated above) will be collected for halon systems to be included in the inventory:

• Location (building number and room)

• Amount of halon (in pounds)

• Area (square feet) and volume (cubic feet) of the protected room

• Type of equipment protected (e.g., communications, computers, etc.)

• Availability of water to the building.

3.2.3 ODC Equipment Not Included in Inventory

The following systems are not included in the most recent ODC inventory:

• Halon systems or CFC equipment installed in weapon systems

• ODC equipment in temporary facilities, tactical field-mobile structures, Defense Commissary Agency (DeCA) commissaries, or Army and Air Force Exchange Service (AAFES) exchanges

• General Services Administration (GSA) vehicles

• Halon 1211 fire extinguishers, either the small 5- to 10-lb handheld building extinguishers or the large, wheeled flight-line extinguishers. [Note: Inventory should include any halon 1211 installed in or maintained for flight-line emergency rescue vehicles. Any use should be reported to the Environmental Support Office

(ESO).]

• Any equipment or stores of the ODC solvents carbon tetrachloride or 1,1,1 trichlorethane.

3.3 CURRENT ODC USES AT FT. GREELY

3.3.1 CFCs

Ft. Greely is currently managing an inventory of approximately 2,089 lb of Class I ODC refrigerants in AC&R equipment such as refrigerators, freezers, etc. Refer to Appendix A.

3.3.2 Halons

Halons are used as fire suppressants. No Class I ODC halons are used at Ft. Greely. Halon systems were removed in 2002.

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CHAPTER 4.0:

LAWS AND POLICY APPLICABLE TO ODC ELIMINATION

Ft. Greely will comply with all laws, regulations, and policies on the use of ODCs. The following sections address applicable laws, regulations, and policies relative to the use of ODCs.

4.1 CLEAN AIR ACT (SECTION 602)

Section 602 of the Clean Air Act identifies the following chemicals as Class I ODCs:

Group I

Chlorofluorocarbon -11 (CFC-11) Chlorofluorocarbon -12 (CFC-12) Chlorofluorocarbon -113 (CFC-113) Chlorofluorocarbon -114 (CFC-114) Chlorofluorocarbon -115 (CFC-115)

Group II

Halon – 1211 Halon – 1301 Halon – 2402

Group III

Chlorofluorocarbon -13 (CFC-13) Chlorofluorocarbon -111 (CFC-111) Chlorofluorocarbon -112 (CFC-112) Chlorofluorocarbon -211 (CFC-211) Chlorofluorocarbon -212 (CFC-212) Chlorofluorocarbon -213 (CFC-213) Chlorofluorocarbon -214 (CFC-214) Chlorofluorocarbon -215 (CFC-215) Chlorofluorocarbon -216 (CFC-216) Chlorofluorocarbon -217 (CFC-217)

Group IV

Carbon tetrachloride

Group V

Methyl chloroform

Group VI

Methyl bromide

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Group VII

Hydrobromofluorocarbons

Group VIII

Chlorobromomethane.

4.2 CLEAN AIR ACT (SECTION 608)

In Section 608 of the Clean Air Act (CAA), the Environmental Protection Agency (EPA) has promulgated a number of rulings on the operation and maintenance of facility AC&R equipment.

• Venting of any refrigerant or halon during the service, maintenance, repair, or disposal of AC&R and fire suppression equipment is banned.

• All technicians who service AC&R equipment must be certified by the EPA.

• Only EPA-certified technicians can purchase CFCs.

• Only EPA-approved recovery/recycling equipment can be used, and any operation that uses such equipment must be certified to the local EPA region.

• Safely dispose of ODCs in AC&R equipment (e.g., old refrigerators and window air conditioners) that are entering a waste stream.

• Substantial leaks in AC&R equipment with a charge of 50 lb or more must be repaired.

4.3 CLEAN AIR ACT (SECTION 612)

The United States Environmental Protection Agency (USEPA), under Section 612 of the CAA, established the Significant New Alternatives Policy (SNAP) Program. The SNAP Program identifies alternatives to ozone-depleting substances and provides lists of acceptable and unacceptable substitutes. As a result of the SNAP list, the CAA makes it illegal to replace any Class I or Class II substance with an alternative that has been identified as hazardous to human or environmental health if acceptable alternatives are available.

4.4 40 CFR 82 LEAK LIMITS

This ruling specifically addresses leaks in AC&R equipment. It limits the amount of ODC refrigerant a piece of equipment may annually leak. Table 4-1 lists Ft. Greely’s leak limits.

These values are the maximum allowable leak rates for CFC AC&R with a capacity refrigerant charge of more than 50 lb. Units leaking at a rate greater than the limit will be repaired or replaced.

4.5 PUBLIC LAW 102-484 (SECTION 326)

Public Law 102-484 is the Defense Authorization Act for Fiscal Year 1993. Section 326 specifically prohibits the Department of Defense from awarding any contract after June 1, 1993, that requires the use of a Class I ODC. This prohibition applies to the purchase of AC&R equipment, fire suppression systems, CFC refrigerant, and halon. It also applies to installation service contracts that require a contractor’s technicians to top off AC&R equipment or to charge halon systems.

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Table 4-1. CFC Annual Leak Limits

System Proposed Rate (%)

Industrial Process Refrigeration 20 Commercial Refrigeration (Old) 15 Commercial Refrigeration (New) 10 Comfort Cooling (Old) 10 Comfort Cooling (New) 5 Other Appliances (Old) 10 Other Appliances (New) 5

New Army contracts should be free of Class I ODCs. Only the office of the Army Acquisition Executive (AAE) can approve the use of Class I ODCs in new Army procurements. All requests for approval will be prepared by Ft. Greely and submitted through the ESO for coordination to the office of the AAE for approval [Assistant Secretary of the Army (ASA) Acquisition, Logistics, and Technology (ALT) Memorandum dated June 16, 2004].

4.6 ARMY ODC POLICY

Current Army policy on ODC elimination in facilities is summed up in the ACSIM policy memorandum of 3 July 1997, “Elimination of the Dependency on Ozone-Depleting Chemicals (ODCs) in Army Facilities.”

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CHAPTER 5.0:

RECOVERY AND TURN-IN

5.1 CFC RECOVERY

Army policy requires the recovery of all installed CFCs. CFC recovery means the capture of refrigerant in the system. EPA rulings have identified specific recovery and recycling equipment, and established specific recovery procedures, to optimize the recovery process.

5.2 HALON RECOVERY

Because Ft. Greely does not have any halon chemicals, a discussion of halon recovery is not covered in this Plan.

5.3 EXCESS ODCS

Army policy has required that all halon and excess CFCs be shipped directly to the Army ODC Reserve. The Army ODC Reserve is the Army’s account in the Department of Defense (DoD) Ozone-Depleting Substance (ODS) Reserve. The DoD ODS Reserve is managed by the Defense Logistics Agency (DLA) through the Defense Supply Center, Richmond (DSCR) and is located at the Defense Depot, Richmond, Virginia (DDRV).

Excess CFCs are defined by Army policy [DASA(ESOH)] memorandum of 18 October 1994, as CFC refrigerant that “is no longer required by the installation to support operational equipment (i.e. chillers, air conditioner, freezers, etc).” It is highly encouraged that as much recovered CFC refrigerant as possible be reused on the owning installation. However, “reuse” does not include trading or selling CFCs for any reason. If the installation cannot use the refrigerant, it must be turned in to the Army ODC Reserve.

5.4 FT. GREELY EXCESS ODC TURN-IN PROCEDURE

All excess ODCs will be turned in according to all applicable regulations and guidelines.

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CHAPTER 6.0:

MANAGEMENT

The dependency on the commercial availability of Class I ODCs must be eliminated from Army facilities. Planning is important to meet this goal of elimination. Properly managing the elimination of Class I ODCs from the installation involves three steps: prioritizing projects, choosing alternatives, and developing a schedule of elimination.

6.1 CLASS I ODC PRIORITIZATION

Ft. Greely has prepared an inventory of all Class I ODCs on the installation. Because halon systems were removed in 2002, the inventory includes only CFC refrigerants. From this inventory, priorities will be set for the retrofit or replacement of each piece of equipment that contains significant quantities of a Class I ODC.

6.1.1 Refrigerants

In choosing a CFC alternative, two requirements must be met: First, any alternative must have an EPA SNAP approval, and second, it must have a toxicity clearance from the Army Surgeon General before being used. All systems that use Class I ODC refrigerants will be evaluated and a recommendation for replacement or retrofit will be made.

6.1.2 Halons

No halon-containing equipment is in use at Ft. Greely. All such equipment was removed in 2002.

6.2 REFRIGERANT ELIMINATION PLAN

6.2.1 Plan Overview

The Refrigerant Elimination Plan will be developed pursuant to Federal EPA regulation on protecting the earth’s stratospheric ozone layer and implementation of Army guidance. The ultimate goal of the Refrigerant Elimination Plan will be to replace existing ozone-depleting materials with alternative materials that do not have negative impacts on the environment or human health.

6.2.2 Refrigerant Uses at Ft. Greely

Table 6-1. Summary of Refrigerant Usage

ODC Category

Approximate No. of Systems

System Charge (Total lb)

Amount of Material in Storage (lb)

R-12 8 1985 - R-113 1 2 - R-502 2 102 -

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6.2.2.1 R-12 Uses

Approximately eight non-sealed AC&R systems at Ft. Greely use R-12. Seven systems use R-12 in excess of 10 lb. These systems include two walk-in freezers (600 lb each), two walk-in chillers (145 lb each), one produce container (33 lb), one reach-in freezer container (33 1b), and one frozen food (425 lb) container.

6.2.2.2 R-113 Uses

One system at Ft. Greely, a cascade unit, uses R-113, in the amount of 2 lb.

6.2.2.3 R-502 Uses

Two non-sealed systems at Ft. Greely use R-502, with only one system using R-502 in excess of 10 lb. This system, a fresh meat case, uses 100 lb of R-502.

6.3 REFRIGERANT ALTERNATIVES

All of the systems currently utilizing R-12 will be replaced with R-404A. R-402A is an HCFC-based refrigerant used for replacing R-502 in existing and new low- and medium-temperature systems. The cascade units utilizing R-113 and R-502 are out of service and there is no plan to replace the refrigerants.

6.4 ELIMINATION SCHEDULE

All systems utilizing R-12 will be replaced with R-404A during Fiscal Year 2006.

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CHAPTER 7.0:

RESOURCES

In order to successfully eliminate Class I ODCs from the installation, it is important to be able to combine funds from a variety of sources. Possible funding sources might include Unit Specific Funds, Installation Environmental Operations and Maintenance, Army (OMA) Funds, Installation Real Property Maintenance Account (RPMA) OMA Funds, and Special Program Funds. Ft.

Greely will use the most appropriate funding sources to ensure funds are available to implement this Plan.

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A-1

APPENDIX A.

FT. GREELY, ALASKA

OZONE-DEPLETING CHEMICAL INVENTORY

(REFRIGERANTS)

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Ft. Greely, Alaska, Ozone-Depleting Chemical Inventory (Refrigerants)

Bldg No.

Room

Type of

Equipment

Refrigerant

Make

Model/ Serial

Year

Installed

Capacity

HP-BTU-

Ton

Servicing

Organization

Servicing Point of Contact

Charge

Leak

Leak Rate

601 Produce Cs

R-12 33.0

601 Frozen Food Cs

R-12 425.0

601 Reach-in Fzr Cs

R-12 33.0

601 Reach-in Clr Cs

R-12 3.6

601 Walk-in Clr R-12 145.0 601 Walk-in Clr R-12 145.0 601 Walk-in Fzr R-12 600.0 601 Walk-in Fzr R-12 600.0

R-12 TOTAL 1984.6

608 Cascade Sys

R-113 2.0

R-113 TOTAL 2.0

601 Fresh Meat Case

R-502 100.0

608 Cascade Sys

R-502 2.0

R-502 TOTAL 102.0

A-2

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Chapter 24 - ODC Elimination Plan