CFCs/HCFCs Warrington Williams – Thanks to John Meyer Environmental Affairs Director John Morrell & Company

Introduction to CFC/HCFC CFCs CFCs HCFCs HCFCs Regulatory Requirements Regulatory Requirements Leak Rate Calculation Leak Rate Calculation Leak Repair Leak Repair Leak Verification Tests Leak Verification Tests Recordkeeping/Reporting Recordkeeping/Reporting Your Responsibilities Your Responsibilities Where To Get More Information Where To Get More Information

What Are CFCs? A class of synthetic chemicals that are odorless, non-toxic, non-flammable, chemically inert, and stable thermodynamic properties – Class I Refrigerants A class of synthetic chemicals that are odorless, non-toxic, non-flammable, chemically inert, and stable thermodynamic properties – Class I Refrigerants First CFC synthesized in 1892, first used in 1930s. First CFC synthesized in 1892, first used in 1930s.

Where Are CFCs/HCFCs Used? Propellants in aerosol cans Propellants in aerosol cans Coolant in Refrigerators and Air Conditioners Coolant in Refrigerators and Air Conditioners Degreasing Agents Degreasing Agents In the Manufacturing of Foam Packaging In the Manufacturing of Foam Packaging

Problem With CFCs Cause destruction of the ozone layer by drifting to the stratosphere, in the presence of UV radiation, reacts with ozone to form free chlorine atoms and molecular oxygen. Cause destruction of the ozone layer by drifting to the stratosphere, in the presence of UV radiation, reacts with ozone to form free chlorine atoms and molecular oxygen. The chlorine liberated during ozone breakdown destroys even more ozone. The chlorine liberated during ozone breakdown destroys even more ozone. CFCs can remain in the atmosphere for more than 100 years. CFCs can remain in the atmosphere for more than 100 years. In 1984, conclusive evidence of stratospheric ozone destruction. In 1984, conclusive evidence of stratospheric ozone destruction. In 1987, the Montreal Protocol Established – global environmental treaty to ban the use of chemicals responsible for damage to the ozone layer. In 1987, the Montreal Protocol Established – global environmental treaty to ban the use of chemicals responsible for damage to the ozone layer. January 1, 1996, new CFC production ended. January 1, 1996, new CFC production ended.

What Are HCFCs? Hydrochlorofluorocarbons (HCFCs) are interim replacement compounds for CFCs- Class II Refrigerants Hydrochlorofluorocarbons (HCFCs) are interim replacement compounds for CFCs- Class II Refrigerants HCFCs still contain chlorine atoms, but the presence of hydrogen makes them reactive to chemicals in the troposphere, so chlorine does not reach the stratosphere. HCFCs still contain chlorine atoms, but the presence of hydrogen makes them reactive to chemicals in the troposphere, so chlorine does not reach the stratosphere. Production of HCFCs will most likely be phased-out by 2030 in the USA, by 2015 in Europe. Production of HCFCs will most likely be phased-out by 2030 in the USA, by 2015 in Europe. DuPont stopped producing HCFC-22 for new equipment in DuPont stopped producing HCFC-22 for new equipment in Hydrofluorocarbons (HFCs) - no chlorine, replacement for HCFCs, but big greenhouse gas emitter. Hydrofluorocarbons (HFCs) - no chlorine, replacement for HCFCs, but big greenhouse gas emitter.

CFC’s BAD, bad, BADDDD really Bad BAD, bad, BADDDD really Bad

CFC/HCFC Requirements 40 CFR 82, Subpart F - maximize recycling of ozone- depleting compounds (CFCs and HCFCs) during the service and disposal of air conditioning and refrigeration equipment 40 CFR 82, Subpart F - maximize recycling of ozone- depleting compounds (CFCs and HCFCs) during the service and disposal of air conditioning and refrigeration equipment Certification requirements for recycling and recovery equipment, technicians, and reclaimers. Certification requirements for recycling and recovery equipment, technicians, and reclaimers. Restricts sales to certified technicians. Restricts sales to certified technicians. Requires repair of substantial leaks in equipment with charge greater than 50 lbs. Requires repair of substantial leaks in equipment with charge greater than 50 lbs. Establishes safe disposal requirements. Establishes safe disposal requirements.

Leak Rate Calculation The leak rate must be calculated each time a leak is discovered. The leak rate must be calculated each time a leak is discovered. LEAK RATE % = ((lbs refrigerant added / lbs refrigerant in normal full charge) x LEAK RATE % = ((lbs refrigerant added / lbs refrigerant in normal full charge) x (365/# days since refrigerant last added)) x 100

Leak Repair For equipment >50 lb charge, if the leak rate exceeds 35% of total charge in a 12 month period, then the leak must be repaired within 30 days following discovery, unless: For equipment >50 lb charge, if the leak rate exceeds 35% of total charge in a 12 month period, then the leak must be repaired within 30 days following discovery, unless: –an industrial process shutdown is required in order for the repair to be completed. In this circumstance, the regulations allow the repair to be completed within 120 days.

Leak Repair Verification Tests Initial and follow-up verification tests must be conducted and documented for each repair. The initial test must be conducted immediately following the repair, before refrigerant is added to the equipment. Initial and follow-up verification tests must be conducted and documented for each repair. The initial test must be conducted immediately following the repair, before refrigerant is added to the equipment. The follow-up verification test must be completed within 30 days following the repair, or, if the equipment was taken out of service, within 30 days of bringing the equipment back on-line. The follow-up verification test must be completed within 30 days following the repair, or, if the equipment was taken out of service, within 30 days of bringing the equipment back on-line.

Leak Repair Verification Tests Soap Bubble Test; Soap Bubble Test; Electronic Leak Detectors; Electronic Leak Detectors; Ultrasonic Leak Detectors; Ultrasonic Leak Detectors; Pressure Test; Pressure Test; Vacuum Test; Vacuum Test; Fluorescent Dye and Black Light Test; Fluorescent Dye and Black Light Test; Infrared Test; or Infrared Test; or Halon Refrigerant Gas Detection. Halon Refrigerant Gas Detection.

Recordkeeping Persons servicing, owning or operating industrial process refrigeration equipment containing over 50 pounds of regulated CFC/HCFC refrigerant must maintain records for: Persons servicing, owning or operating industrial process refrigeration equipment containing over 50 pounds of regulated CFC/HCFC refrigerant must maintain records for: (a) the date a leak is discovered; (a) the date a leak is discovered; (b) the date a leak is repaired and/or the equipment is serviced (including a description of the repair or service work); (b) the date a leak is repaired and/or the equipment is serviced (including a description of the repair or service work); (c) the date and quantity of refrigerant added or removed; (c) the date and quantity of refrigerant added or removed; (d) the date, type and results of the initial verification test; and (d) the date, type and results of the initial verification test; and (e) the date, type and results of the follow-up verification test. (e) the date, type and results of the follow-up verification test.

Reporting If you fail a follow-up verification test, you must notify EPA within 30 days of this failed test. If you fail a follow-up verification test, you must notify EPA within 30 days of this failed test. The notification must include the dates and types of all initial and follow-up verification tests performed and all associated test results. The notification must include the dates and types of all initial and follow-up verification tests performed and all associated test results. –Reference: 40 CFR (i)(3)(iii) Also, if you must report to EPA if you fail to complete repairs within 30 days of the leak Also, if you must report to EPA if you fail to complete repairs within 30 days of the leak

Key Points Any equipment containing more than 50 pounds of CFC/HCFC refrigerant are covered by this regulation. Any equipment containing more than 50 pounds of CFC/HCFC refrigerant are covered by this regulation. Cannot exceed release amounts equivalent to 35% of system volume in the last 365 days. Cannot exceed release amounts equivalent to 35% of system volume in the last 365 days. If you do, you have 30 days to fix the cause of the release (process shutdown days), and must conduct initial and follow-up leak verification tests. If you do, you have 30 days to fix the cause of the release (process shutdown days), and must conduct initial and follow-up leak verification tests.

Your Responsibilities Implement a tracking mechanism such as an Excel spreadsheet that calculates the rolling release totals. Implement a tracking mechanism such as an Excel spreadsheet that calculates the rolling release totals. Maintain copies of certifications on-site for technicians servicing your CFC/HCFC containing equipment. Maintain copies of certifications on-site for technicians servicing your CFC/HCFC containing equipment. Must retain records of leaks/releases. Must retain records of leaks/releases.

More Information 40 CFR 82, Subpart F 40 CFR 82, Subpart F Follow link to BMPs for leak calculator Follow link to BMPs for leak calculator