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CFC/HCFC Requirements & Enforcement Issues. Don Gansert Managing Consultant November 20, 2008. trinityconsultants.com. 40 CFR Part 82. Subpart A – Production & Consumption Controls Subpart B – Servicing of Motor Vehicle Air Conditioners

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cfc hcfc requirements enforcement issues

CFC/HCFC Requirements & Enforcement Issues

Don Gansert

Managing Consultant

November 20, 2008

trinityconsultants.com

40 cfr part 82
40 CFR Part 82
  • Subpart A – Production & Consumption Controls
  • Subpart B – Servicing of Motor Vehicle Air Conditioners
  • Subpart C – Ban on Nonessential Products Containing Class I Substances & Nonessential Products Containing or Manufactured with Class II Substances
  • Subpart D – Federal Procurement
  • Subpart E – Labeling of Products Using Ozone Depleting Substances (ODS)
  • Subpart F – Recycling and Emissions Reduction
  • Subpart G – Significant New Alternatives Policy Program
part 82 subpart f
Part 82 Subpart F

Most facilities have the necessary certifications or use contractors

  • Recovery/recycling equipment certifications
  • Technician training and certifications
  • Leak rate calculation for equipment containing greater than 50 lbs of refrigerant (per circuit)
  • Maintenance, recordkeeping, & reporting requirements

Common problem areas!

sample enforcement actions
Sample Enforcement Actions

Non-compliance with stratospheric ozone protection requirements is low-hanging fruit for USEPA and state agencies. $3.6 Billion in penalties for Part 82 in 1999 alone.

leak repair provision requirements
Leak Repair Provision Requirements
  • Each time your people or contractors add refrigerant to a system that holds > 50 lbs of a Class I or Class II compound
    • Promptly calculate the annualized leak rate
    • If leak rate > trigger rate, do one of the following
      • Repair leaks in a timely fashion (later slides)
      • Retrofit the system so no longer using a regulated CFC (within 1 year)
      • Retire the system from service (within 1 year)
applicable trigger rates
Applicable Trigger Rates
  • Commercial refrigeration units – 35%
  • Industrial process refrigeration units – 35%
  • Comfort cooling systems – 15%
  • All other refrigeration systems – 15%
leak rate calculation method 1 annualizing method
Leak Rate Calculation Method #1 –“Annualizing Method”
  • Step 1. Take the pounds of refrigerant added to return appliance to a full charge and divide it by the pounds of refrigerant the appliance normally contains at full charge;
  • Step 2. Divide 365 days by the shorter of the # of days that have passed since the last day refrigerant was added or 365 days;
  • Step 3. Take the # calculated in Step 1 and divide it by the # calculated in Step 2; and
  • Step 4. Multiply the # calculated in Step 3 by 100 to calculate a percentage
leak rate calculation
Leak Rate Calculation
  • Determines the amount of refrigerant that would leak out in a year if nothing done
  • Example (using “Annualizing Method”):Day 1 - Unit fully charged with 250 lbs of refrigerantDay 8 - Unit found to have lost 2 lbs of refrigerantLeak Rate = 41.7% =
leak rate calculation method 2 rolling average method
Leak Rate Calculation Method #2 –“Rolling Average Method”
  • Step 1. Take sum of the quantity of refrigerant added to the appliance over the previous 365-day period (or over the period that has passed since leaks in the appliance were last repaired, if that period is less than one year);
  • Step 2. Divide the result of Step 1 by the quantity of refrigerant the appliance normally contains at full charge; and
  • Step 3. Multiply the result of Step 2 by 100 to obtain a percentage
leak repair timeline
Leak Repair Timeline
  • If leak rate exceeds applicable trigger rate, then
    • Repair within 30 days (not to 0% leak rate but must be less than applicable trigger rate)*
      • If repair within 30 days, no notification needed
      • If need > 30 days to repair due to delays beyond your control, must notify the USEPA to request more time
        • Can request up to 1 year but only the amount of time truly needed to make the repair (e.g., to receive a new part)
  • If cannot repair in a timely fashion, develop retrofit or retirement plan within 30 days

*If industrial process shutdown needed to make repair, then have120-day repair window

verification testing requirements
Verification Testing Requirements
  • For Industrial Process Refrigeration units (and federally-owned commercial refrigeration & comfort cooling systems):
    • Perform an Initial Verification of the repairs upon completion (e.g., soap bubble test)
    • Perform a Follow-Up Verification test within 30 days after the Initial Verification test
  • Frequently performed as “best management practice” for other refrigerant-containing appliances to ensure success of repairs
if fail follow up verification test
If Fail Follow-up Verification Test
  • Must develop a retrofit or retirement plan within 30 days of the failed test
  • Can avoid implementing retrofit or repair plan, if
    • Attempt repairs again and retest within 30 days; if succeed 2nd time around, must notify USEPA that retrofit or retirement plan is not needed within 30 days, or
    • Demonstrate, within 180 days of the initial failed follow-up verification test, that the appliance's annual leak rate does not exceed the applicable trigger rate;must notify USEPA that retrofit or retirement plan is not needed within 30 days
leak repair recordkeeping reporting
Leak Repair – Recordkeeping & Reporting
  • Facilities must keep the following records for all systems with a charge > 50 lbs of a regulated CFC (required even when work is done by contractors)
    • The system type (e.g., Comfort Cooling)
    • Full charge for each system (e.g., 100 lbs of R-12)
    • Date & type of any maintenance and leak discoveries
    • Who performed the work (to verify certification)
    • Amount of refrigerant added
    • When the refrigerant added was purchased
    • Any leaks that were repaired and the dates of repairs
    • Calculated annualized leak rate
    • For Industrial Process Equipment leaking > trigger rate:
      • Date & result of Initial Verification test
      • Date(s) & result(s) of Follow-Up Verification test(s)
common mistakes
Common Mistakes
  • Assuming your contractor is handling the leak repair provisions (calculations, etc.) for you
    • You are responsible for violations no matter what the cause!
  • Not knowing which units are > 50 lbs full charge
  • Not performing leak rate calculations promptly, if at all
    • Only have 30 days to repair leaks if over trigger rate
  • Not performing follow-up verification tests
  • Not recording verification test dates & results
  • Incomplete service records (often just an invoice is not enough)
small appliances
Small Appliances
  • Small appliances
    • Water fountains, refrigerators, window mounted air conditioning units, etc.
  • Removal of the CFC/HCFC prior to disposal
  • Recordkeeping requirements
    • Name and date of company performing work
    • Certification/proof
    • 3 year retention period
summary
Summary
  • Develop CFC/HCFC inventory of all units
  • Identify the units with a capacity of 50 lbs or more
    • Keep all service records – 3 years
    • Maintain Leak Rate Calculations
  • Small (CFC/HCFC containing) Appliance Disposal
    • Keep records/certification – 3years
  • If you use a contractor, keep copy of the contractor’s certification on file