Developing an EPA refrigerants compliance program? Here's some basics

Title VI Stratospheric Ozone Protection of the Clean Air Act Amendments of 1990 (Public Law 101-549) was signed November 15, 1990. Among other things, it established a production phase-out schedule and yearly reduction percentages for ozone-depleting chemicals. One of the primary applications of these chemicals is refrigerant for air conditioning and refrigeration equipment in buildings and supermarkets. The amendment requires recycling; bans the intentional venting or releasing of refrigerants during maintenance, service, repair, or disposal; restricts emission of refrigerants; and establishes strict control over their use.

As the EPA is responsible for federal regulations concerning the protection of stratospheric ozone, it has issued numerous regulations to ensure compliance. These include equipment certification requirements, maintenance and service practices, refrigerant reclaiming requirements, training, and record keeping on the purchase, use, sale, and transfer, and disposal of these substances.

Presently, the EPA is amending the regulations on refrigerant recycling and required service practices under section 608 of the Clean Air Act for chlorofluorocarbon (CFC) and (HCFC) refrigerants. This will extend regulations to the new substitutes like HFC 134a. Effective November 15,1995, section 608(c)(2) of the Clean Air Act prohibits the knowing release of substitutes for CFC and HCFC refrigerants during the maintenance, service, repah or disposal of air-conditioning and refrigeration equipment.

With these regulations in place, virtually all commonly used commercial refrigerants in air conditioning and refrigeration, other than ammonia, are, or soon will be, regulated substances. Organizations that own or manage facilities with air conditioning and/or refrigeration equipment, including food distribution, must ensure they are in compliance with EPA Refrigerant Regulations.

Violations of these regulations and requirements can result in fines up to $27,500 per day per violation. Intentional violations can result in criminal penalties of up to five years imprisonment. Submission of false or misleading information, or failure to submit required records could result in criminal penalties, including two years imprisonment. Furthermore, unannounced inspections are conducted routinely by the EPA to evaluate compliance and to respond to violation reports.

Because of these developments, creating and implementing an EPA Refrigerant Regulations Compliance Program is vital to every affected organization to ensure successful compliance. Ideally, the plan will minimize capital expenditures and operating costs while achieving full compliance with applicable laws and requirements.

The following steps are critical toward the implementation of an EPA Refrigerant Regulations Compliance Program:

* A comprehensive refrigerant systems assessment should be performed. All equipment containing refrigerants and the quantity of refrigerant each piece contains should be identified, and an accurate and complete database should be established.

* An individual or team must be given the responsibility and authority to create the plan and to oversee its successful implementation. The person should have the authority and budget to effect change, be current on the organization's HVAC/R operations, industry standards, and related regulations; and be able to communicate successfully with other departments.

* The corporate refrigerant compliance manager will need to understand, evaluate, and institute necessary administrative controls, policies, and procedures to verify compliance. Required forms and any necessary permits must be completed and sent to the EPA.

* Organization's must define their existing work processes and modify them accordingly to ensure compliance to EPA requirements. This includes operating and maintenance practices, refrigerant recovery, recycling, and reclamation procedures.

* All current processes and procedures should be examined for gaps and potential compliance failure points.

* New policies and procedures may have to be established to ensure complete accountability from initial refrigerant acquisition through final disposal.

* An organization-specific refrigerant regulations compliance program is necessary. The program should describe how EPA regulations and requirements would be integrated into the organization's existing work processes. It should also define the organization's specific policies and procedures for refrigerant handling, from purchase through final disposal, including establishing uniform record keeping methods.

* Finally, a "Roll Out" implementation training process should be conducted to ensure everyone affected receives a copy of the compliance program and any other information they need to ensure success. This is also a good time to express commitment to organizational compliance.

After the training is completed, employees can be asked to sign a statement of understanding that compliance is a condition of their employment. In order to ensure ongoing compliance, regularly scheduled compliance update training should be conducted. This will reinforce the importance of compliance and further demonstrate the organization's "intent to comply".

Robert Johnson is president of Environmental Support Solutions. Mesa Ariz. The company provides compliance software, training and compliance tools to organizations affected by IAQ, Refrigerant, Waste and Health & Safety issues

Definition:

Leak Rate -- The rate at which an appliance is losing refrigerant measured between refrigerant charges or over 12 months, whichever is shorter. The leak rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 1 2-month period if the current rate of loss were to continue over that period. The rate is calculated using the following formula:

Pound of refrigerant add Pounds of refrigant in full charge x 365 days/year shorter of #days since refrigerant last added and 365 days x 100%

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