REFRIGERANT COMPLIANCE
MANAGEMENT
CUSTOMIZED ENVIRONMENTAL
TRAINING
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INSTRUCTOR
Insert Instructor Name Here
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OBJECTIVES
 Discuss Industrial Process Refrigeration.
 Discuss the Requirements of the Refrigerant Recycling Rule.
 Discuss How to Determine Full Charge of A System.
 Discuss How to Calculate Leak Rate.
 Discuss When to Make Leak Repairs.
 Discuss the Requirements for Retrofit and Retirement.
 Discuss the Requirements for Oil Changes.
 Discuss Disposal Requirements.
 Discuss Reports and Recordkeeping.
 Discuss Use of Contractors.
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GOALS
 Understand Industrial Process Refrigeration.
 Understand the Requirements of the Refrigerant Recycling
Rule.
 Be Familiar With How to Determine Full Charge of A System.
 Understand How to Calculate Leak Rate.
 Understand When to Make Leak Repairs.
 Understand the Requirements for Retrofit and Retirement.
 Understand the Requirements for Oil Changes.
 Understand Disposal Requirements.
 Be Familiar With Required Reports and Recordkeeping.
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BACKGROUND
 Ozone depleting substances (ODS) are found in certain
refrigerants manufactured before 1995.
 The United States and over 150 other countries signed
the Montreal Protocol that pledges the phasing out of
ODS by the end of 1995.
 EPA is authorized to assess fines of up to $27,500 per
day for any violation of ODS regulations.
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LEARNERS
 Supervisors
 Facility Engineers
 Maintenance Personnel
 Department Managers
 Building Occupants
 Process Specialists
 Environmental and Safety Committees
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OVERVIEW
The goal of this course is to provide supervisors
with the tools needed to stay in compliance with the
Clean Air Act Amendments relevant to industrial
process refrigeration systems. It recommends
practical, actions that can be carried out by facility
management, maintenance personnel and building
occupants. The course will help you to integrate
good industrial process refrigeration management
activities into your existing organization and identify
which of your staff have the necessary skills to carry
out those activities.
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WHAT THIS COURSE DOES NOT DO
The course is not intended to provide information on
the requirements for other types of refrigeration
equipment or how to do everything required or
permitted by the Clean Air Amendments, such as
how to perform a leak test using an ultrasonic leak
detector. These specialties required training beyond
the intended scope of this course. Where this
expertise is needed, outside assistance should be
solicited.
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CLEAN AIR ACT AMENDMENTS
(CAAA)
 Title VI, entitled Stratospheric Ozone Protection, is
generally directed toward eliminating the threat posed
to the earth’s protective stratospheric (or high-level)
ozone layer by certain ozone-depleting substances
(ODSs)
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FEDERAL REGULATIONS
Pertinent Regulations:
 40 CFR Part 82, Subpart F
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REQUIREMENTS
 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 airconditioning and refrigeration equipment
 Set certification requirements for recycling and
recovery equipment, technicians, and reclaimers
 Restrict the sale of refrigerant to certified technicians
 Require persons servicing or disposing of airconditioning and refrigeration equipment to certify to
EPA that they have acquired recycling or recovery
equipment and are complying with the requirements of
the rule
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REQUIREMENTS
 Require the repair of substantial leaks in airconditioning and refrigeration equipment with a charge
of greater than 50 pounds
 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)
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APPLICABILITY
 Industrial process refrigeration used in the chemical,
pharmaceutical, petrochemical, and manufacturing
industries
 This sector also includes industrial ice machines,
appliances used directly in the generation of electricity,
and ice rinks
 The refrigerant recycling rule applies to systems that
contain and use a class I or class II substance as a
refrigerant:
•Class I refrigerants are mostly chlorofluorocarbon
(CFC) refrigerants or any mixture containing a CFC
•Class II refrigerants are hydrochloro-fluorocarbon
(HCFC) refrigerants or any mixture containing an HCFC
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APPLICABILITY
Applicability Triggers
 The leak repair requirements
of this regulation are triggered
when an owner or operator of an
industrial process refrigeration
system discovers that refrigerant
is leaking at a rate that would
exceed 35 percent of the total
charge in a 12-month period
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APPLICABILITY
Trigger Rates
For all systems that have a refrigerant
charge of more than 50 pounds:
SYSTEM
Commercial refrigeration
Industrial process refrigeration
Comfort cooling
All other refrigeration
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RATE
35%
35%
15%
15%
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APPLICABILITY
EXEMPTIONS OR
EXCLUSIONS
 Leak repair provisions of this
regulation do NOT affect systems
normally containing 50 pounds or
less of refrigerant
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PROHIBITION ON VENTING
 Section 608 of the Act prohibits individuals from
knowingly venting ozone-depleting compounds used as
refrigerants into the atmosphere
 Only four types of releases are permitted under the
prohibition:
1. "De minimis" quantities of refrigerant released in the
course of making good faith attempts to recapture and
recycle or safely dispose of refrigerant
2. Refrigerants emitted in the course of normal
operation of air-conditioning and refrigeration equipment
such as from mechanical purging and leaks
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PROHIBITION ON VENTING
3. Releases of CFCs or HCFCs that are not used as
refrigerants
4. 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
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RECLAMATION REQUIREMENT
 EPA has also established that refrigerant recovered
and/or recycled can be returned to the same system or
other systems owned by the same person without
restriction
If refrigerant changes ownership, however, that
refrigerant must be reclaimed
 Refrigerant used in MVACs and MVAC-like
appliances is subject to the purity requirements of the
MVAC regulations at 40 CFR Part 82 Subpart B
 EPA updates the list of reclaimers as new companies
are added.
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EQUIPMENT CERTIFICATION
 EPA has established a certification program for recovery
and recycling equipment
 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.]"
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TECHNICIAN CERTIFICATION
EPA has established a technician certification program
for persons ("technicians") who perform maintenance,
service, repair, or disposal that could be reasonably
expected to release refrigerants into the atmosphere
The definition of "technician" specifically includes
certain activities as follows:
 attaching and detaching hoses and gauges to and
from the appliance to measure pressure within the
appliance;
 adding refrigerant to or removing refrigerant from the
appliance
 any other activity that violates the integrity of the
MVAC-like appliances, and small appliances.
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TECHNICIAN CERTIFICATION
 Apprentices are exempt from certification
requirements provided the apprentice is closely and
continually supervised by a certified technician
 The Agency has developed four types of certification:
1. For servicing small appliances (Type I).
2. For servicing or disposing of high- or very highpressure appliances, except small appliances and
MVACs (Type II).
3. For servicing or disposing of low-pressure appliances
(Type III)
4. For servicing all types of equipment (Universal).
 Technicians are required to pass an EPA-approved
test given by an EPA-approved certifying organization
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REFRIGERANT SALES
RESTRICTIONS
 Effective November 14, 1994, the sale of refrigerant
in any size container is restricted to technicians certified
either under the program described previously in
Technician Certification or under EPA's motor vehicle air
conditioning regulations
 The sales restriction covers refrigerant contained in
bulk containers and pre-charged parts
 The restriction excludes refrigerant contained in
refrigerators or air conditioners with fully assembled
refrigerant circuits
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CERTIFICATION
Certification by Owners of Recycling and Recovery
Equipment
 EPA requires that persons servicing or disposing of
air-conditioning and refrigeration equipment certify to
the appropriate EPA Regional Office that they have
acquired recovery or recycling equipment and that they
are complying with the applicable requirements of this
rule
 This certification must be signed by the owner of the
equipment or another responsible officer and sent to the
appropriate EPA Regional Office
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RECLAIMER CERTIFICATION
 Reclaimers are required to return refrigerant to the
purity level specified in ARI Standard 700-1993
 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
 EPA encourages reclaimers to participate in a voluntary
third-party reclaimer certification program operated by the
Air-Conditioning and Refrigeration Institute (ARI)
 EPA maintains a list of approved reclaimers
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FULL CHARGE
 The full charge is the amount of refrigerant
necessary for an industrial process refrigeration system
to operate at normal operating characteristics and
conditions
 There are two reasons why you need to know how
much refrigerant is in the full charge for a system:
1. The leak repair requirements of this law do not apply
to any system whose full charge is 50 pounds or less of
refrigerant in any independent refrigerant circuit
2. To calculate the leak rate for a system, you need to
know the full charge
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FULL CHARGE
To determine the full charge, you must
use one of the following five methods:
1. Measure the refrigerant
2. Calculate the weight of the refrigerant
charge in the system
3. Use the manufacturer's information
4. Establish range
5. Use a combination of 1-4
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LEAK RATE
Each time you add refrigerant to a
system normally containing 50 pounds
or more of refrigerant, you should
promptly calculate the leak rate. If the
leak rate is higher than the trigger rate,
you are required to do one of the
following:
a.
Repair leaks;
b.
Retrofit the system; or
c.
Retire the system from service.
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LEAK RATE
Four Steps to Calculating a Leak Rate
1.
#lbs refrigerant added
#lbs refrigerant in normal full charge
2. #days since refrigerant last added
365 days
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LEAK RATE
Calculating a Leak Rate continued
3. Take the number you determined in
step 1 and divide it by the number you
determined in step 2.
4. Multiply the number you determined
in step 3 by 100 (to calculate a
percentage).
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LEAK RATE
Timing
 After refrigerant is added, you should
calculate the leak rate as soon as you can
 If the system is leaking above the
trigger rate, the law imposes strict
deadlines for repairing the leaks or
retrofitting or retiring the system
 For example, if you wait three days to
determine the leak rate, there will be three
less days available to solve the problem
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LEAK RATE
Purged Refrigerant
 In calculating the leak rate, you may exclude purged
refrigerant that is destroyed
 A destruction efficiency of at least 98 percent is
required
 There are monitoring, recordkeeping, and reporting
requirements
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LEAK RATE
Recordkeeping/Reporting
Keep records that show:
1. The date and type of service;
2. How much refrigerant was added; and
3. The date when the refrigerant was added
 It may be required and is always advisable to keep
records of the full charge and leak rate
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LEAK REPAIR
 If a system is leaking above the trigger rate, leak
repairs are required within 30 days of discovery
 Repairs must bring the annual leak rate below the
trigger rate
 Leak repairs are not required if you retrofit or retire
the system
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LEAK REPAIR
Industrial Process Shutdown
When an industrial process
shutdown is needed to repair
leaks from industrial process
refrigeration systems, a 120-day
repair period (rather than a 30-day
period) is allowed.
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LEAK REPAIR
Unavailable Repair Parts or Other Regulations That
Require Additional Time
 Additional time beyond the 30- or 120-day time
periods is allowed to conduct leak repairs if the
necessary repair parts are unavailable or if other
applicable federal, state, or local regulations make a
repair within 30 or 120 days impossible
 EPA must be notified if repairs cannot be completed
within 30 or 120 days of discovery
 Only the additional time needed to receive delivery of
the necessary parts or comply with the pertinent
regulations will be permitted
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LEAK REPAIR
Repair Verification:
 There is a requirement to verify the
success of leak repairs for industrial
process refrigeration systems
 Two tests, called “initial” and “followup” verification tests are required for
each repair site
 A successful test verifies that a leak
has been repaired
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LEAK REPAIR
What are these tests for?
 The primary purpose of the initial verification test is to
verify that a leak or leaks have been repaired before
refrigerant is added back to the system
 Even when the system is not evacuated to complete
repairs, initial and follow-up verification tests are required
 The primary purpose of the follow-up verification test is
to re-verify that repairs continue to hold after the system is
returned to its normal operating Characteristics or
conditions
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LEAK REPAIR
Initial Verification Test
 An initial verification test must be conducted following
any leak repairs
 A refrigeration system may not be brought back on line
(if it has been taken off line), unless
a) an initial verification test indicates that repairs have
been successfully completed or
b) a decision to retrofit or retire is made.
 The initial verification test must be conducted before the
replacement of the full charge of refrigerant
 In systems that have not been evacuated, the initial
verification test must be conducted as soon as practicable
after the repair work is completed
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LEAK REPAIR
Follow-up Verification Test
A follow-up verification test must be conducted:
 Within 30 days after the initial verification test, where
normal operating characteristics or conditions have
been maintained; or
 Within 30 days of bringing the system back on line, if
taken off line, and where the system is operating at
normal operating characteristics or conditions.
 In certain cases the results of a follow-up verification
test may be less reliable if the test is conducted at
normal operating characteristics or conditions
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LEAK REPAIR
Initial and Follow-up Verification Test Methods
Initial and follow-up verification tests may use any
method that meets sound professional judgment
Examples include:
A soap bubble test; or
Electronic leak detectors; or
Ultrasonic leak detectors; or
A pressure test; or
A vacuum test; or
A fluorescent dye and black light test; or
An infrared test or near infrared; or
Halon refrigerant gas detection methods
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LEAK REPAIR
Unsuccessful Tests
 If you have an unsuccessful follow-up verification
test, you must notify EPA and develop a retrofit or
retirement plan within 30 days of the failed test
 If it is going to take you more than one year you must
also submit the plan
 If the follow-up verification test indicates that the
repairs to the system have not been successfully
completed, the owner or operator is required retrofit or
retire the system
 There are some options where the owner or operator
is relieved of the obligation to retrofit or retire the
system
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LEAK REPAIR
Activity
Technician Required?
Evacuating the refrigerant
Yes
Adding refrigerant
Yes
Changing the oil
Yes
Adding oil
Yes
Replacing a gauge
Yes
Changing or calibrating a DP cell
Yes
Changing a pressure-relief valve
Yes
Drawing a sample of refrigerant or oil
Yes
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LEAK REPAIR
Technician
Required?
Activity
Helping dismantle a system for disposal
Yes
Any of the tasks listed so far, performed under the
direct supervision of a certified technician
Yes
Maintenance that would not reasonably release
refrigerant
No
Fixing leaks by tightening nuts or bolts, if no specific
reason to think the activity may go wrong and increase
the rate of release
No
Any work on the system after
the refrigerant has been evacuated
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RETROFIT AND RETIREMENT
 Owners or operators are not required to repair leaks if
they develop, implement, and complete a 12-month
retrofit or retirement plan
 Three conditions, however, must be met:
1. The retrofit or retirement plan must be developed
within 30 days of detecting the leak and a copy must be
kept on site; and
2. The plan must be dated and the original made
available for EPA inspection upon request; and
3. Retrofit or retirement activities must be completed
within a 12-month period of the plan's date
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RETROFIT AND RETIREMENT
Time Extensions for Retrofit or Retirement of
Industrial Process Refrigeration Systems
 Additional time beyond the initial 12-month period is
allowed for the following three circumstances occur:
1. A delay is caused by the requirements of other
applicable federal, state, or local regulations
2. A suitable replacement refrigerant is not available
continued
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RETROFIT AND RETIREMENT
Time Extensions for Retrofit or Retirement of
Industrial Process Refrigeration Systems continued
3. The unit is custom-built and the supplier of the
system or a critical component has quoted a delivery
time of more than 30 weeks from when the order is
placed
 If the owner or operator of a custom-built industrial
process refrigeration system has received an additional
12-month period for retrofit or retirement activities, but
still requires more time to complete the retrofit or
retirement, then a request for additional time may be
submitted to EPA
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RETROFIT AND RETIREMENT
Relief From Obligation to Retrofit or Retire
 You may be relieved of this requirement if either of
the following efforts is successful:
1. Make second efforts to repair the same leaks that
were the subject of the first repair attempt
2. Within 180 days of a failed follow-up verification test
associated with the initial repair efforts, establish that
the leak rate is below the trigger rate
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SYSTEM MOTHBALLING
 System mothballing is the intentional shutdown of a
refrigeration system for an extended period of time,
where the refrigerant has been evacuated from the
system to at least atmospheric pressure
 When a refrigeration system is in a mothballed
condition, refrigerant leaks that existed when the
system was operating have effectively been stopped
because the system has been evacuated
 The time-related requirements resume on the day the
system is brought back on line and is no longer
considered mothballed
 Leak repairs following mothballing on industrial
process refrigeration systems are still subject to initial
and follow-up verification tests
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SYSTEM MOTHBALLING
Applicability
 When a system is mothballed, the time suspensions
are available for all types of systems, including
commercial, industrial process, and any other systems
containing more than 50 pounds of refrigerant
 Time suspensions under system mothballing apply to
all time-related requirements for repairing leaks or
replacing, retrofitting, or retiring a system, including time
extensions that may be allowed in specific
circumstances for industrial process refrigeration
systems
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SYSTEM MOTHBALLING
 System mothballing requires the refrigerant to be
removed from the system to at least atmospheric
pressure
 If the owner or operator intends to make repairs to the
system that require opening the system, the refrigerant
must be removed to the required evacuation levels for
that refrigerant before the system is opened
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SYSTEM MOTHBALLING
Example of System Mothballing
 If the system operated for five days after discovery of
the exceedance of the leak rate and then was shut
down and mothballed for two months, when the system
returned to operating, the owner would still have 25
days to either repair the leaks or develop a 12-month
retrofit or retirement plan
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OIL CHANGES
 EPA’s refrigerant recycling amendments also address
procedures to minimize emissions of refrigerant during
oil changes
 The oil in a refrigeration system may contain large
amounts of refrigerant
 EPA requires a reduction in pressure prior to an oil
change so that the bulk of the refrigerant is recovered
 The maximum pressure allowed is 5 psig
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OIL CHANGES
There are two acceptable procedures to assure
recovery of refrigerant:
1. Evacuate the refrigeration system, or isolated
portion, to a pressure no higher than 5 psig and then
remove the oil; or
2. Drain the oil into a system receiver to be evacuated
to a pressure no higher than 5 psig
These procedures minimize the loss of refrigerant from:
a) the oil, and
b) the interior of the refrigeration system as the oil
comes out
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SAFE DISPOSAL REQUIREMENTS
 Equipment that is typically dismantled on-site before
disposal 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 is subject to special safe
disposal requirements
 Under these requirements, the final person in the
disposal chain is responsible for ensuring that
refrigerant is recovered from equipment before the final
disposal of the equipment
 Technician certification is not required for individuals
removing refrigerant from appliances in the waste
stream
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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:
They are not mixed with other waste
They are subjected to CFC recycling or reclamation
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
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RECORDKEEPING AND
REPORTING
Leak Repair (Industrial Process Refrigeration)
If the repairs have failed the follow-up verification test:
a) Documentation of the following information and report it to
EPA within 30 days after verification test:
•the identification of the facility;
•the leak rate;
•the method used to determine the leak rate and full charge;
•the date of discovery that the leak rate was above the trigger
rate;
•the location of leaks to the extent determined to date;
b) Notify EPA if you discover that the repairs will take longer
than you have previously told EPA
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RECORDKEEPING AND
REPORTING
Full Charge
If the full charge of an industrial process refrigeration
system is determined by establishing a range or
combining the use of an established range, records
must be maintained.
These records must include:
 Identification of the owner or operator of the system;
 Location of the system;
 Original range for the full charge of the system, its
midpoint, and how the range was determined;
 Any and all revisions of the full charge range and how
they were determined; and
 Dates such revisions occurred
Refrigerant Compliance Management 58 / 63
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Training 4 Today 2001
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RECORDKEEPING AND
REPORTING
Purged Refrigerant
Records must include ALL of the following:
 Flow rate;
 Quantity or concentration of the refrigerant in the vent;
 Periods of purge flow;
 Identification of the facility and a contact person;
 General description of the refrigeration system;
 Description of the methods used to determine the
quantity of refrigerant sent for destruction;
 Frequency of monitoring and data-recording; and
 Description of the control device and destruction
efficiency
Refrigerant Compliance Management 59 / 63
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Training 4 Today 2001
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RECORDKEEPING AND
REPORTING
Retrofit or Retirement (Industrial
Process Refrigeration)
 If you complete successful retrofit
or retirement within the normal oneyear period, the amendments do not
require any new recordkeeping or
reporting
 Records reportable to EPA must
be maintained on site for three years
Refrigerant Compliance Management 60 / 63
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Training 4 Today 2001
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TIPS FOR USING CONTRACTORS
 Remember, You Control Your Facility or Area!
 Review Procedures With Them Before Starting the Job!
 Ensure They Are Properly Trained!
 Determine Their Environmental Compliance Record!
 Determine Who Is in Charge of Their People!
 Determine How They Will Affect Your Facility’s
Environmental Compliance!
Refrigerant Compliance Management 61 / 63
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Training 4 Today 2001
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ELEMENTS OF A SUCCESSFUL
REFRIGERANT COMPLIANCE PROGRAM
1. DETAILED WRITTEN REFRIGERANT COMPLIANCE
INSPECTION GUIDELINES.
2. DETAILED WRITTEN REFRIGERANT COMPLIANCE BEST
MANAGEMENT PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP
Refrigerant Compliance Management 62 / 63
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Training 4 Today 2001
Published by EnviroWin Software LLC
THE IMPORTANCE OF A
CLEAN ENVIRONMENT
“I would ask all of us to remember
that protecting our environment is
about protecting where we live and
how we live. Let us join together to
protect our health, our economy,
and our communities -- so all of us
and our children and our
grandchildren can enjoy a healthy
and a prosperous life.”
Refrigerant Compliance Management 63 / 63
© Copyright
Training 4 Today 2001
Carol Browner
Former EPA
Administrator
Published by EnviroWin Software LLC