EPA compliance - Refrigerant Management

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Courtesy of IHS

Everyone's Responsibility

Today, the environment is everyone's responsibility. Are you taking an active part to keep it clean? We've all heard about the ozone layer. Ozone depletion in the atmosphere has become an increasing problem since the 1960's. The consequences of ozone depletion come in the form of increased health risks to people and the slow destruction of our worldwide ecosystems. Scientists have proven that the chlorine content in refrigerants play a major part in the des-truction of the ozone layer in the upper atmosphere. It is also a factor in the formation of greenhouse gases in the lower atmosphere. Greenhouse gases cause global warming. Your family's future depends on what is done today. In 1987, through the Montreal Protocol, the first worldwide step was taken to control ozone depletion. By 1989, 29 countries (representing 82% of the world's refrigerant consumption) ratified the protocol. In 1990, the Congress of the United States passed Title VI of the Clean Air Act (CAA), setting the stage for a strong regulatory program within the U.S. This legislation made it unlawful to vent refrigerant after July 1, 1992. The Clean Air Act gave the Environmental Protection Agency (EPA) the authority to establish and enforce ozone depleting refrigerant phase-out programs. To achieve the goals under these programs, escalating taxes were placed on these refrigerants. Chemical companies created alternate and transitional refrigerants. The EPA established rules and regulations under section 608 of the CAA that affected many aspects of the refrigerant industry. Some of these rules are:

  • Service practices must maximize recycling of ozone-depleting compounds.
  • Certified recovery and recycling equipment must be used.
  • Technicians must become certified.
  • The sale of refrigerants is allowed only to certified technicians.
  • Owners of equipment with charges over 50 pounds are required to repair leaks in equipment if the leaks exceed the specified allowable leak rate for that equipment.
  • Safe disposal procedures must be established for small appliances to ensure that proper refrigerant and oil removal is done before these appliances enter the waste stream.
  • Mandatory record keeping that applies to technicians, owners and operators of appliances.
In 1993, all of our trades staff who worked with refrigerants were trained and became certified. Since the Plant A/C Shop was the most prominent user of refrigerants on campus, it was most prudent for that shop to set up a protocol and begin tracking refrigerant use on campus. We purchased a software program from Environmental Support Solutions that helped us organize and streamline our record-keeping process. We were able to simplify and standardize the forms our trades staff use to capture the necessary information. Before 1990, refrigerants used on campus were purchased from various sources. U of M Purchasing and University Stores have established a prime vendor relationship for refrigerant purchases and refrigerant disposal. Plant Stores is now set up to stock and handle all refrigerant purchases and disposals for our trades staff. They also ensure that all refrigerant reclaim cylinders are inspected every five years as per Department of Transportation regulations. Plant Stores works with us to ensure that proper documentation accompanies all refrigerant and refrigerant cylinders entering or leaving our campus. In the industry, we call this, “tracking refrigerants from cradle-to-grave.” Record-keeping paperwork is paramount to a successful refrigerant management program. As far as the EPA is concerned, if there are no paper records, then there is no program. Getting people to document any movement or transfer of refrigerants on campus represents a special challenge, especially if they are not our regular employees. Anyone who is contracted by the U of M to work on and open equipment that contains refrigerants, regardless of who signs their paycheck, is considered our employee in the eyes of the EPA. Furthermore, as our employee, they are required to document their work, fill out the appropriate forms and turn them in to the owner (U of M), the same as our regular employees. Under Section 113 of the Clean Air Act, the EPA has the power to seek penalties of up to $27,500 per day for each violation they find. Enforcement actions are generally against owners and operators rather than the employee. However, the penalty policy does include technicians who service an appliance. Currently, the EPA has made available a bounty of up to $10,000 for reporting violations of the CAA. It is often the basis for many of their facilities inspections. The Plant A/C Shop continuously strives for a better-managed program. Refresher training of our employees is one of the best tools at our disposal. Recently, a representative from Environmental Support Solutions conducted an excellent training session for 33 trades staff and technicians. A separate training session was presented to 24 project managers, engineers, OSEH representatives and supervisors. Through these sessions, we were able to focus the training to empha-size the importance of the regulations, reinforce proper refrigerant handling prac-tices and ways to improve the program. As Foreman of the Plant A/C Shop, one of my goals for this program is to increase public awareness at the University by providing information about the Clean Air Act, EPA compliance and the respon-sibilities of the Plant Department. The media has already done a superb job informing the public about environmental pollution and the need for safe recycling and disposal practices. People are slowly beginning to realize and accept the fact that there is a cost involved for proper refrigerant handling. The regulations have forced our costs of doing service to rise. Many outside companies now include an environmental charge with their billings. Presently, we absorb such charges in our recharge rate. One of the project managers who attended the RCM training was quite taken with the program and was emphatic about complying with all of the EPA regulations. He stated, “Compliance is not just for us but for our children and their children's children.” This is the kind of attitude that people should have about compliance. The University of Michigan has committed to making serious efforts in environmental cleanup and recycling. It takes all of us to make it work. Do you have the right attitude? Are you doing your part?

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