The City of Albuquerque
Environmental Health Department and the U.S. EPA enforce environmental
regulations that apply to stratospheric ozone depleting substances (ODS), such
as chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs). The
Department of Safety, Health and Environmental Affairs (SHEA) coordinates all
environmental compliance efforts at UNM, including those related to ODS.
As with all environmental,
health & safety (EH&S)-related
issues at UNM, please contact SHEA first at 277-2753 for all ODS-related
questions and concerns. However, if the persons familiar with ODS at SHEA are
not available in a timely manner, and if there is an urgent ODS issue, please
contact the EPA’s Stratospheric Ozone Hotline at 1-800-296-1996. Regardless,
all EH&S-related reporting to regulatory agencies, such as the EPA, must be
reviewed by SHEA prior to being sent out.
Aside from reporting documents, all required record-keeping is the
responsibility of the ODS user, storer, or entity which operates &
maintains ODS-related equipment.
We
all live under the UV-radiation filtering stratospheric ozone layer that
protects both our health and the viability of the agricultural systems, which
grow our food. Therefore, it is in all of our own interests to do the right
thing in handling and using ODS to minimize its release to the atmosphere.
This program is applicable to
the UNM entities that use or store ODS for operations & maintenance
(O&M) of air conditioning and refrigeration systems and for other ODS use
in research, etc. Program requirements
are also applicable to outside contractors which work on such systems at UNM.
The goals of the program are listed in priority as follows:
1. To prevent and minimize releases of ODS to the environment;
2.
To comply with applicable laws and regulations governing ODS; and,
3.
To detect, report and correct releases of ODS should they occur.
Program Limitations: Only
the environmental compliance aspects of ODS are covered by this program. No, or only marginal, mention of related
issues, such as equipment operation & maintenance, are contained herein.
HCFC - Hydrochlorofluorocarbon
– any such chemical listed as a Class II ODS in Sections 608 or 609 of the
Clean Air Act.
Hotline - EPA’s
Stratospheric Ozone Hotline at 1-800-296-1996, or their website at
http://www.epa.gov/ozone
Major Maintenance, Service, or Repair - Maintenance, service, or repair that involves removal of the
appliance compressor, condenser, evaporator, or auxiliary heat exchanger coil.
MVAC - Motor Vehicle Air
Conditioner
MVAC-like Appliance - Mechanical
vapor compression, open-drive compressor appliances used to cool the driver's
or passenger's compartment of a non-road vehicle, including agricultural and
construction vehicles. This definition excludes those appliances using HCFC-22.
ODS - Ozone Depleting
Substance; Any of a group of halogenated hydrocarbon chemicals which
photochemically react in the stratosphere in a way which destroys the ozone
layer which protects the Earth from the excessive influx of harmful cosmic
& solar radiation.
O&M – Operations &
maintenance
Opening - Any
service, maintenance, or repair on an appliance that would release class I or
class II refrigerant from the appliance to the atmosphere unless the
refrigerant were recovered previously from the appliance. Connecting and
disconnecting hoses and gauges to and from the appliance to measure pressures
within the appliance and to add refrigerant to or recover refrigerant from the
appliance shall not be considered "opening."
Owner – The UNM entity which
responsible for O&M (e.g., PPD Manager or Lab PI) of the RREA, MVAC or
other ODS equipment at UNM.
PI – Principle Investigator
in a laboratory or person in charge of equipment not O&M’d by PPD.
PPD – Physical Plant
Department at UNM
Reclaim - To
reprocess refrigerant to at least the purity specified in the ARI Standard
700-1993, Specifications for Fluorocarbon Refrigerants, and to verify this
purity using the analytical methodology prescribed in the Standard. Reclamation
requires specialized machinery not available at a particular job site or auto
repair shop. The technician will recover the refrigerant and then send it
either to a general reclaimer or back to the refrigerant manufacturer.
Recover - To
remove refrigerant in any condition from an appliance and store it in an
external container without necessarily testing or processing it in any
way.
Recycle - To
extract refrigerant from an appliance and clean refrigerant for reuse without,
meeting all of the requirements for reclamation. In general, recycled
refrigerant is refrigerant that is cleaned using oil separation and single or
multiple passes through devices, such as replaceable core filter-driers, which
reduce moisture, acidity, and particulate matter. For MVACs, refrigerant can be removed from
one car's air conditioner, recycled on site, and then charged into a different
car.
Refrigerant Circuit - The
parts of an appliance that are normally connected to each other (or are
separated only by internal valves) and are designed to contain refrigerant.
RREA - Refrigeration-Related
Equipment & Appliances
Small Appliance - Any
of the following products that are fully manufactured, charged, and
hermetically sealed in a factory with five pounds or less of
refrigerant: refrigerators and freezers designed for home use, room air
conditioners (including window air conditioners and packaged terminal air
conditioners), packaged terminal heat pumps, dehumidifiers, under-the-counter
ice makers, vending machines, and drinking water coolers.
Technician - Any
person who performs maintenance, service, or repair that could reasonably be
expected to release class I (CFC) or class II (HCFC) substances from
appliances, except for MVACs, into the atmosphere. Technician also means any
person performing disposal of appliances, except for small appliances, MVACs,
and MVAC-like appliances, that could be reasonably expected to release class I
or class II refrigerants from appliances into the atmosphere.
The environmental compliance
regulations pertaining to ODS, most applicable to UNM, are broken into two
general categories:
1. Refrigeration-Related Equipment &
Appliances (RREA), such as utility chillers, building air conditioning
(AC), refrigerators and freezers (stationary or truck-mounted), dehumidifiers,
MVAC-like equipment, etc. are regulated by Section 608 of the 1990 Amendments
to the CAA; and,
2. Motor Vehicle Air Conditioners (MVAC)
are regulated by Section 609 of the 1990 Amendments to the CAA.
a. Require
service practices that maximize recycling of ozone-depleting compounds (both
chlorofluorocarbons [CFCs] and hydrochlorofluorocarbons [HCFCs] and their
blends) during the servicing and disposal of air-conditioning and refrigeration
equipment.
b. Set certification requirements for
recycling and recovery equipment, technicians, and
reclaimers.
c. Restrict the sale of refrigerant to
certified technicians.
d. Require
persons servicing or disposing of air-conditioning and refrigeration equipment
to certify to EPA that they have acquired recycling or recovery equipment and
are complying with the requirements of the rule.
e. Require the
repair of substantial leaks in air-conditioning and refrigeration equipment
with a charge of greater than 50 pounds.
f. Establish
safe disposal requirements to ensure removal of refrigerants from goods that
enter the waste stream with the charge intact (e.g., motor vehicle air
conditioners, home refrigerators, and room air conditioners).
Since
July 1992, it has been unlawful to knowingly vent ODS refrigerants into the
atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning
or refrigeration equipment (appliances). Only four types of ODS releases are
now lawful:
a.
"De minimis"
quantities of refrigerant released in the course of making good faith attempts
to recapture and recycle or safely dispose of refrigerant.
b. Refrigerants emitted in the course of
normal operation of air-conditioning and
refrigeration
equipment (as opposed to during the maintenance, servicing, repair, or
disposal
of this equipment) such as from mechanical purging and leaks. However, the
repair of leaks is required for large equipment above a certain size (see
Refrigerant Leaks).
c. Releases
of CFCs or HCFCs that are not used as refrigerants. For instance, mixtures of
nitrogen and R-22 that are used as holding charges or as leak test gases may be
released, because in these cases, the ozone-depleting compound is not used as a
refrigerant. However, a technician may not avoid recovering refrigerant by
adding nitrogen to a charged system; before nitrogen is added, the system must
be evacuated to the appropriate level in Table 1 (see Attachment A). Otherwise,
the CFC or HCFC vented along with the nitrogen will be considered a
refrigerant. Similarly, pure CFCs or HCFCs released from appliances will be
presumed to be refrigerants, and their release will be considered a violation
of the prohibition on venting.
d. Small releases of refrigerant that
result from purging hoses or from connecting or
disconnecting
hoses to charge or service appliances will not be considered violations of the
prohibition on venting. However, recovery and recycling equipment manufactured
after November 15, 1993, must be equipped with low-loss fittings.
3. Service Practice
Requirements
a. Evacuation Requirements - Since July
13, 1993, technicians have been required to evacuate air-conditioning and
refrigeration equipment to established vacuum levels when opening the
equipment. If the technician's recovery or recycling equipment was manufactured
any time before November 15, 1993, the air-conditioning and refrigeration equipment
must be evacuated to the levels described in the first column of Table 1
(Attachment A). If the technician's recovery or recycling equipment was
manufactured on or after November 15, 1993, the air-conditioning and
refrigeration equipment must be evacuated to the levels described in the second
column of Table 1, and the recovery or recycling equipment must have been
certified by an EPA-approved equipment testing organization. Persons who simply
add refrigerant to (top-off) appliances are not required to evacuate the
systems.
Technicians
repairing small appliances, such as household refrigerators, window air
conditioners, and water coolers, must recover:
·
80 percent of the
refrigerant when:
-
the technician uses
recovery or recycling equipment manufactured before November 15, 1993, or;
-
the compressor in the
appliance is not operating;
OR
·
90 percent of the
refrigerant when:
- the technician uses recovery or recycling equipment
manufactured after November 15, and;
- the compressor in the appliance is
operating.
In
order to ensure that they are recovering the correct percentage of refrigerant,
technicians must use the recovery equipment according to the directions of its
manufacturer.
Technicians may also satisfy recovery requirements by evacuating the small
appliance to four inches of mercury vacuum.
b. Exceptions to Evacuation Requirements – There
are limited exceptions to the evacuation requirements for 1) repairs to leaky
equipment and 2) repairs that are not major and that are not followed by an
evacuation of the equipment to the environment.
If,
due to leaks, evacuation to the levels in Table 1 (Attachment A) is not
attainable, or would substantially contaminate the refrigerant being recovered,
persons opening the appliance must:
·
isolate leaking from
non-leaking components wherever possible;
·
evacuate non-leaking
components to the levels in Table 1; and evacuate leaking components to the
lowest level that can be attained without substantially contaminating the
refrigerant. This level cannot exceed 0 psig.
If
evacuation of the equipment to the environment is not to be performed when
repairs are complete, and if the repair is not major, then the appliance must:
·
be evacuated to at least
0 psig before it is opened if it is a high- or very high-pressure appliance; or
·
be pressurized to 0 psig
before it is opened if it is a low-pressure appliance. Methods that require
subsequent purging (e.g., nitrogen) cannot be used except with appliances
containing R-113.
c. Reclamation Requirement - Refrigerants
recovered and/or recycled can be returned to the same system or other systems
owned by the same entity without restriction. If refrigerant changes ownership,
however, that refrigerant must be reclaimed (i.e., cleaned to the ARI 700-1993
standard of purity and chemically analyzed to verify that it meets this
standard) unless the refrigerant was used only in a motor vehicle air
conditioner (MVAC) or MVAC-like appliance and will be used in the same type of
appliance. Visit the EPA Hotline for an updated the list of reclamation
companies.
4. Equipment
Certification
There
is an established EPA certification program for recovery and recycling
equipment.
Under
the program, all equipment manufactured on or after November 15, 1993 must be
tested by an EPA-approved testing organization to ensure that it meets EPA
requirements. Recycling and recovery
equipment intended for use with air-conditioning and refrigeration equipment,
besides small appliances, must be tested under the ARI 740-1993 test protocol.
Recovery
equipment intended for use with small appliances must be tested under either
the ARI 740-1993 protocol or the protocol in Appendix C of 40 CFR Part 82
Subpart F.
Recovery
efficiency standards vary depending on the size and type of air-conditioning or
refrigeration equipment being serviced. For recovery and recycling equipment intended for use with
air-conditioning and refrigeration equipment besides small appliances, these
standards are the same as those in the second column of Table 1 (Attachment A). Recovery equipment intended for use with
small appliances must be able to recover 90 percent of the refrigerant in the
small appliance when the small appliance compressor is operating and 80 percent
of the refrigerant in the small appliance when the compressor is not operating.
The
EPA has approved both the Air-Conditioning and Refrigeration Institute (ARI)
and
Underwriters
Laboratories (UL) to certify recycling and recovery equipment. Certified
equipment
can be identified by a label reading: "This equipment has been certified
by
ARI/UL
to meet EPA's minimum requirements for recycling and/ or recovery equipment
intended
for use with [appropriate category of appliance--e.g., small appliances, HCFC
appliances
containing less than 200 pounds of refrigerant, all high-pressure appliances,
etc.]."
Lists of certified equipment may be obtained by contacting ARI at 703-524-8800
and
UL at 708-272-8800 ext. 42371.
5. Equipment
Grandfathering
Equipment
manufactured before November 15, 1993, including homemade equipment,
may be grandfathered if it meets the standards in the first column of
Table 1 (Attachment A). Third-party testing is not required for equipment
manufactured before November 15, 1993, but equipment manufactured on or after
that date, including home-made equipment, must be
tested
by a third-party (see Equipment Certification).
6. Refrigerant Leaks
Owners
of equipment with charges of greater than 50 pounds are required to repair
leaks in
the
equipment when those leaks together would result in the loss of more than a
certain
percentage
of the equipment's charge over a year. For the commercial and industrial
process
refrigeration sectors, leaks must be repaired when the appliance leaks at a
rate that
would
release 35 percent or more of the charge over a year. For all other sectors,
including
comfort
cooling, leaks must be repaired when the appliance leaks at a rate that would
release
15 percent or more of the charge over a year.
The
trigger for repair requirements is the current leak rate rather than the total
quantity of
refrigerant
lost. For instance, owners of a commercial refrigeration system containing 100
pounds of charge must repair leaks if they
find that the system has lost 10 pounds of charge
over
the past month; although 10 pounds represents only 10 percent of the system
charge in
this
case, a leak rate of 10 pounds per month would result in the release of over
100
percent
of the charge over the year. To track leak rates, owners of air-conditioning
and
refrigeration
equipment with more than 50 pounds of charge must keep records of the
quantity
of refrigerant added to their equipment during servicing and maintenance
procedures.
Owners
are required to repair leaks within 30 days of discovery. This requirement is
waived
if, within 30 days of discovery, owners develop a one-year retrofit or retirement
plan
for the leaking equipment. Owners of industrial process refrigeration equipment
may
qualify
for additional time under certain circumstances. For example, if an industrial
process
shutdown is required to repair a leak, owners have 120 days to repair
the leak. Owners or operators of leaky industrial process refrigeration
equipment should both see the “Section 608: Leak Repair fact sheet (Attachment
B) and promptly notify SHEA. SHEA will assist
with information concerning time extensions and pertinent record-keeping and
reporting requirements.
7. Technician Certification
Any maintenance, service, repair, or disposal of RREA at UNM (that could be reasonably expected to release refrigerants into the atmosphere) must be done only by EPA-certified technicians. The EPA regulated activities specifically includes and excludes the following:
Included:
a.
attaching and detaching
hoses and gauges to and from the appliance to measure pressure within the
appliance;
b.
adding refrigerant to or
removing refrigerant from the appliance;
c.
any other activity that
violates the integrity of the MVAC-like appliances, and small
appliances.
In
addition, apprentices are exempt from certification requirements provided the
apprentice
is closely and continually supervised by
a certified technician.
The
four types of EPA-certification are as follows:
a. For servicing small appliances (Type
I).
b. For servicing or disposing of high- or
very high-pressure appliances, except small
appliances
and MVACs (Type II).
c. For servicing or disposing of
low-pressure appliances (Type III)
d. For servicing all types of equipment
(Universal).
Technicians
are required to pass an EPA-approved test given by an EPA-approved
certifying
organization to become certified under the mandatory program. The Hotline
distributes current lists of approved testing organizations.
8. Refrigerant Sales
Restrictions
The sale of CFC-12 in containers smaller than 20 pounds is restricted solely to technicians certified under EPA's motor vehicle air conditioning regulations. EPA-certified technicians servicing appliances other than motor vehicle air conditioners may still buy containers of CFC-12 larger than 20 pounds.
Effective November 14, 1994, the sale of
refrigerants in any size container is restricted to
technicians
certified either under the program described in Technician Certification above
or
under
EPA's motor vehicle air conditioning regulations. The sales restriction covers
refrigerant
contained in bulk containers (cylinders or drums) and pre-charged parts. The
restriction
excludes refrigerant contained in refrigerators or air conditioners with fully
assembled
refrigerant circuits (such as household refrigerators, window air conditioners,
and
packaged air conditioners), pure HFC refrigerants, and CFCs or HCFCs that are
not
intended
for use as refrigerants. In addition, a restriction on sale of pre-charged split
systems
has been stayed (suspended) while EPA reconsiders this provision.
9. Certification by
Owners of Recycling and Recovery Equipment
Technicians
servicing or disposing of air-conditioning and refrigeration equipment at UNM
must certify to EPA Region VI (in Dallas, TX) that they have acquired (built,
bought, or leased) recovery or recycling equipment and that they are complying
with the applicable requirements of this rule. A copy of the EPA Refrigerant
Recovery or Recycling Device Acquisition Certification Form is included in
Attachment C. This certification form
must be filled out by the UNM entity which O&Ms the equipment, e.g., a PPD
Manager, who will then forward it to SHEA for review. SHEA will review the completed from and forward
it for signature by a responsible UNM officer.
SHEA will return a signed copy of the form back to the equipment O&M
entity when sending it on to the EPA Region VI Office.
Note
that this certification is a one-time requirement. Therefore, if a shop purchased a piece of
CFC-12 recycling equipment in the past, and sent the certification to EPA, the
shop does not need to send a second certification to EPA when it purchases a
second piece of equipment, no matter what refrigerant that equipment is designed
to handle. Although owners of recycling and recovery equipment are required to
list the number of trucks (or “service vehicles”) based at their shops, they do
not need to have a piece of recycling or recovery equipment for every truck.
Outside
contractors should certify their own equipment.
Reclaimers
are required to return refrigerant to the purity level specified in ARI
Standard
700-1993
(an industry-set purity standard) and to verify this purity using the
laboratory
protocol
set forth in the same standard. In addition, reclaimers must release no more
than
1.5
percent of the refrigerant during the reclamation process and must dispose of
wastes
properly.
Reclaimers must certify to the Section 608 Recycling Program Manager at EPA
Headquarters
that they are complying with these requirements and that the information given
is
true and correct. Certification must also include the name and address of the
reclaimer
and
a list of equipment used to reprocess and to analyze the refrigerant.
EPA
encourages reclaimers to participate in a voluntary third-party reclaimer
certification
program
operated by the Air-Conditioning and Refrigeration Institute (ARI). The voluntary
program
offered by ARI involves quarterly testing of random samples of reclaimed
refrigerant.
Third-party certification can enhance the attractiveness of a reclaimer's
product
by
providing an objective assessment of its purity. EPA maintains a list of
approved
reclaimers
that is available from the Hotline. In addition, a checklist helps prospective
reclaimers
provide appropriate information for EPA to review.
11. MVAC-like Appliances
Some
of the air conditioners that are covered by this rule are identical to motor
vehicle air
conditioners
(MVACs), but they are not covered by the MVAC refrigerant recycling rule
(40
CFR Part 82, Subpart B) because they are used in vehicles that are not defined as
"motor
vehicles." These air conditioners include many systems used in
construction
equipment,
farm vehicles, boats, and airplanes. Like MVACs in cars and trucks, these air
conditioners
typically contain two or three pounds of CFC-12 and use open-drive
compressors
to cool the passenger compartments of vehicles.
The EPA is defining these air
conditioners
as "MVAC-like appliances" and is applying the MVAC rule's
requirements for
the
certification and use of recycling and recovery equipment to them. That is,
technicians
servicing
MVAC-like appliances must "properly use" recycling or recovery
equipment that
has been certified to meet the MVAC
standards. In addition, EPA is allowing technicians who service MVAC-like
appliances to be certified by a certification program approved under the MVAC
rule, if they wish.
12. Safe Disposal
Requirements
Equipment
that is typically dismantled on-site before disposal (e.g., retail food
refrigeration, central residential air conditioning, chillers, and industrial
process refrigeration) has to have the refrigerant recovered in accordance with
EPA's requirements for servicing. However, equipment that typically enters the
waste stream with the charge intact (e.g., motor vehicle air conditioners,
household refrigerators and freezers, and room air conditioners) is subject to
special safe disposal requirements.
Under
these requirements, the final person in the disposal chain at UNM (e.g., the
PPD Manager overseeing an appliance replacement) is responsible for ensuring
that refrigerant is recovered from equipment before the final disposal of the
equipment. However, persons (e.g. outside contractors) "upstream" can
remove the refrigerant and provide documentation of its removal to the final
person if this is more cost-effective.
The
equipment used to recover refrigerant from appliances prior to their final
disposal must
meet
the same performance standards as equipment used prior to servicing, but it
does not
need to be tested by a laboratory. This
means that self-built equipment is allowed as long as
it
meets the performance requirements. For MVACs and MVAC-like appliances, the
performance
requirement is 102 mm of mercury vacuum and for small appliances, the
recovery
equipment performance requirements are 90 percent efficiency when the
appliance
compressor is operational, and 80 percent efficiency when the appliance
compressor
is not operational.
Technician
certification is not required, but is recommended, for individuals removing
refrigerant from small appliances in the waste stream.
The
safe disposal requirements went into effect on July 13, 1993. Equipment must be
registered
or certified with the EPA and sample form is included in Attachment C.
13. Major Recordkeeping
Requirements
Technicians
servicing appliances that contain 50 or more pounds of refrigerant must
provide
the equipment owner (e.g., the PPD Manager or Lab PI) with a written invoice or
record that indicates the amount of refrigerant added to the appliance.
Technicians must also keep a copy of their proof of certification at their
place of business.
Owners
of appliances that contain 50 or more pounds of refrigerant must keep servicing
records
documenting the date and type of service, as well as the quantity of
refrigerant
added.
Wholesalers
who sell CFC and HCFC refrigerants must retain invoices that indicate the
name
of the purchaser, the date of sale, and the quantity of refrigerant purchased.
Reclaimers
must maintain records of the names and addresses of persons sending them
material
for reclamation and the quantity of material sent to them for reclamation. This
information
must be maintained on a transactional basis. Within 30 days of the end of the
calendar
year, reclaimers must report to EPA the total quantity of material sent to them
that
year
for reclamation, the mass of refrigerant reclaimed that year, and the mass of
waste
products
generated that year.
14. Hazardous Waste
Disposal
If
refrigerants are recycled or reclaimed, they are not considered hazardous under
federal
law.
In addition, used oils contaminated with CFCs are not hazardous on the
condition that:
a. They are not mixed with other waste;
b. They are subjected to CFC recycling or
reclamation; or,
c. They are not mixed with used oils from
other sources.
Used
oils that contain CFCs after the CFC reclamation procedure, however, are
subject to
specification
limits for used oil fuels if these oils are destined for burning. Individuals
with
questions
regarding the proper handling of these materials should contact UNM SHEA
at 277-2753. For compressor, chiller, etc., oil change
procedures in compliance with CAA-requirements, see Attachment D.
One of the largest uses of
CFC-12 in the U.S. is as a refrigerant in motor vehicle air conditioners
(MVACs). The EPA has delegated to the
Albuquerque Environmental Health Department the authority to establish
requirements to prevent the release of refrigerants during the servicing of
MVACs and to require recycling of refrigerants. Widespread refrigerant
recycling reduces the
demand for virgin ODS
refrigerants and thus extends the time that they will be available. The
following sections describe the requirements of the law and its potential
impact on UNM.
In
the discussion below, recycling means the use of a machine to remove impurities
and oil
and
then recharge the refrigerant into either the same car or a different car.
Recycled
refrigerant
is not as pure as reclaimed refrigerant. Recycling occurs in the service shop.
Reclamation
means the removal of all oil and impurities beyond that provided by on-site
recycling
equipment, and reclaimed refrigerant is essentially identical to new, unused
refrigerant.
Reclamation cannot be performed in the service shop. Rather, the shop generally
sends
refrigerant either back to the manufacturer or directly to a reclamation
facility.
2.
Requirements For All MVAC Refrigerants
a.
Venting refrigerants containing
any ODS is prohibited.
b.
Approved Equipment -
Technicians who repair or service MVACs must recover the refrigerant and either
recycle it on-site, or send it off-site to a reclamation facility. Technicians must use EPA-approved equipment
to perform the refrigerant recovery and recycling. A list of approved recover/recycle and
recover-only equipment is available from the Hotline. Certain EPA-approved models can recycle both
CFC-12 and HFC-134a refrigerants.
Some
CFC-12 recovery/recycling equipment can be converted for use with HFC-134a.
However, technicians are prohibited from changing fittings on the same unit
back and forth so that the unit is used for CFC-12 in the morning, HFC-134a in
the afternoon, then back to CFC-12 again, etc.
For refrigerant blends see the Requirements Specific to
Refrigerant Blends below.
c.
Technician Training and Certification - Technicians who repair or service MVACs must be trained and
certified by an EPA-approved organization.
If a technician is already trained and certified to handle CFC-12, he
does not need to be recertified to handle HFC-134a or refrigerant blends. A
list of approved MVAC training and certification programs is available from the
Hotline.
d.
Recordkeeping Requirements - Service shops must certify to EPA that they own EPA-approved
refrigerant recovery or recycling equipment. A copy of the EPA Refrigerant
Recovery or Recycling Device Acquisition Certification Form is included in
Attachment C. Note that this
certification is a one-time requirement.
Therefore, if a shop purchased a piece of CFC-12 recycling equipment in
the past, and sent the certification to EPA, the shop does not need to send a
second certification to EPA when it purchases a second piece of equipment, no
matter what refrigerant that equipment is designed to handle. If
refrigerant
is recovered and sent to a reclamation facility, the shop must retain the name
and address of that reclaimer.
e.
Sales Restrictions - The
sale of ODS refrigerants is restricted to only EPA-certified technicians.
a.
Using Older Equipment to Recover Blends - Technicians have a number of choices in recovering blend
refrigerants. One option is that a technician may permanently dedicate an older
piece of equipment he owns to recovering one or more blend refrigerants. The
technician may also use this equipment to recover contaminated CFC-12 and
HFC-134a and other "mystery mixtures." This equipment, however, may
no longer be used to recover uncontaminated CFC-12 or HFC-134a. Refrigerant recovered
using this kind of "junk" tank must then be shipped off-site for
reclamation or destruction.
b.
Using New Equipment to Recover Blends - Another option for recovering a blend refrigerant is to use a
new piece of EPA-approved equipment designed to recover, but not recycle, any
single, specific blend refrigerant.
c.
Recycling Blends -
Recycling of refrigerant blends used in motor vehicle air conditioning systems
(MVACs) is allowed, provided that: a) recycling equipment meets a new
Underwriters Laboratories (UL) standard (Standard 2964) and, b) refrigerant is
returned to the vehicle from which it was removed. The only exception to item
b) is for fleets of vehicles with a common owner; recycled blend refrigerant
may be moved among vehicles within such a fleet. The EPA adopted a new UL standard into
regulation and grandfathered any equipment that (1) meets the UL standard and
(2) is purchased before the date on which EPA published the UL standard rule.
d. Converting CFC-12 or HFC-134a Recycle
Equipment for Use with Blend Substitutes - Conversion of existing CFC-12 or
HFC-134a recycling equipment for either temporary or permanent use with a blend
refrigerant is prohibited, unless the equipment is used only to recover, but
not to recycle, the refrigerant. In the future, the EPA may issue regulations
allowing these conversions but placing certain restrictions on who performs the
conversions, what models may be converted, etc.
When
retrofitting a MVAC for use with another refrigerant (e.g., replacing CFC-12 w/
a blend), the technician must first extract the CFC-12, must cover the CFC-12
label with a label that indicates the new refrigerant in the system and other
information, and must affix new fittings unique to that refrigerant. In
addition, if a technician is retrofitting a vehicle to a
refrigerant
that contains R-22, the technician must ensure that only barrier hoses are used
in the A/C system. Finally, if the system includes a pressure relief device,
the technician must install a high-pressure compressor shutoff switch to
prevent the compressor from increasing pressure until the refrigerant is
vented.
Much
more information about the SNAP program and about retrofitting procedures is
available
in a fact sheet called "Choosing and Using Alternative Refrigerants"
through the
EPA’s
Ozone Hotline (800-296-1996).
ODS are a broad group of
chemicals which have a variety of applications outside of their use as refrigerants. ODS (esp. Freons) are commonly used as
solvents for a variety of parts cleaning applications and as solvents in
analytical chemistry procedures. ODS are
also used in sterilant mixtures and as extinguishing agents in specialized fire
suppression systems. All these
non-refrigerant uses of ODS are not regulated as of the time this program is
written (February 2001). Therefore, ODS
use and uncontrolled evaporation into the atmosphere from those uses is
currently legal and unregulated.
Regardless, SHEA encourages all
UNM entities which use and have need for ODS to consider the use of alternative
chemicals to ODS. Please checkout the
constantly updated lists of alternative chemicals that EPA has evaluated and
recommends as more stratospheric ozone-friendly substitutes for ODS at the EPA
website ( http://www.epa.gov/ozone/title6/snap/lists
).
The ban on manufacturing and
importation of ODS in the U.S. and other 1st World Nations has severely
restricted their supply. Therefore, the
cost for ODS has multiplied and will continue to go up. The high cost of ODS has created a black market
for the illegal importation of ODS. To
keep your ODS from being potential confiscated by law enforcement agencies,
please purchase ODS from only known reputable dealers.
If a UNM entity has stocks of
surplus ODS that they wish to sell, please contact SHEA for advice on if and
how the ODS may be legally sold.