Inspection Directions: An EMS Approach to Inspecting for Section 608 and 609 Compliance.

Slides:



Advertisements
Similar presentations
CFC/HCFC Requirements & Enforcement Issues Don Gansert Managing Consultant November 20, 2008 trinityconsultants.com.
Advertisements

CFC/HCFC MANAGEMENT Training Conference 2013 – Chicago, IL
EMS Checklist (ISO model)
Universal Waste Management Training
Checking & Corrective Action
[Organisation’s Title] Environmental Management System
Jim Rudeen Waste Reduction, Compliance and Enforcement Section Chief KDHE, Bureau of Waste Management
CFCs/HCFCs Warrington Williams – Thanks to John Meyer Environmental Affairs Director John Morrell & Company.
Objectives Terminal Objective
DEQ Mission By the end of the decade, Virginians will enjoy cleaner water available for all uses, improved air quality that supports communities and ecosystems,
Department of Environmental Quality Environmental Management System Overview.
Environmental Management System (EMS)
EPA EMS General Awareness Training Presented by David Guest, Esq. U.S. EPA Washington, D.C.
ISO 9001 : 2000.
Conversation on the Chemical Facility Anti-Terrorism Standards (CFATS) and Critical Infrastructure Protection Chemical-Terrorism Vulnerability Information.
1 MASSACHUSETTS UNDERGROUND STORAGE TANK (UST) PROGRAM Baseline Compliance Assessment 1 MassDEP 8/2/2011.
R22 Phase Out Presentation To inform our customers of the single most important changes to the air conditioning industry in modern.
1 CXS490 Federal Regulations FAQ. Why do the Federal Halocarbon Regulations, 2003 exist? The Montreal Protocol on Substances that Deplete the Ozone.
Contractor Management and ISO 14001:2004
Environmental Management Systems An Overview With Practical Applications.
USDA-ARS West Lafayette, Indiana January  EMS is a system that incorporates and promotes all activities of the West Lafayette location: ◦ Environmental.
Environmental Management Systems Refresher
ENVIRONMENTAL MANAGEMENT SYSTEMS MARINE OPERATIONS CENTER – PACIFIC INTRODUCTION TO OUR SYSTEM JIM SCHELL, ENVIRONMENTAL COMPLIANCE OFFICER.
ISO 9000 Certification ISO 9001 and ISO
TIA Solid Waste Consultants, Inc.1 Presented by Miriam Zimms, Senior Consultant TIA Solid Waste Consultants, Inc. Tampa, Florida Pollution Prevention Conference.
ISO Standard is based on the management model of plan – do - check – act. Today we all be discussing the elements of the standard that deal with.
1 Exemption AdministrationTraining Related to Accepting Certificates Prepared by the Streamlined Sales Tax Governing Board Audit Committee Prepared January.
Top Tactics for Maximizing GMP Compliance in Blue Mountain RAM Jake Jacanin, Regional Sales Manager September 18, 2013.
Montreal Protocol Implementation in Sri Lanka- Current Situation and HCFC Phase out challenges Dr W L Sumathipala Senior Technical Advisor Ministry of.
European Commission: DG Environment Directorate ECCP-1 Review - Brussels 1 March 2006 DG Environment EU F-Gases Regulation and MAC Directive.
ISO EMS OVERVIEW May ISO EMS OVERVIEW TRAINING Contents What is an EMS? Why ISO & Certification? EMS Basic Elements Environmental.
Overview of EU Regulations affecting the use of Fluorinated Greenhouse Gases Tim G.A. Vink Director Regulatory Affairs, Compliance & QA Honeywell Fluorine.
Institutional Arrangements for HCFC Phase-out G.M.J.K Gunawardana G.M.J.K GunawardanaDirector Promotion, Environmental Education & National Ozone Unit.
Pollution Prevention Toyota Industrial Equipment Mfg., Inc. December 7, 2011.
The Tax Credit Process (Once credit has been awarded) Reservation and Carryover Gross Rent Floor Election Form Commitment 10% Certification Quarterly Progress.
Executive Order Greening the Government Through Leadership in Environmental Management.
Mahendra Senevirathne Project Coordinator National Ozone Unit Sri Lanka 17 September
Title VI- Stratospheric Ozone Compliance Training
Georgia Environmental Protection Division Stage II Gasoline Vapor Recovery Decommissioning Workshop June 11, 2014 EPD Tradeport Training Room.
1 DOE IMPLEMENTATION WORKSHOP ASSESSING MY EMS Steven R. Woodbury
Refrigerant Compliance Management 1 / 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC REFRIGERANT COMPLIANCE MANAGEMENT CUSTOMIZED.
RTI, MUMBAI/DAY 3/SESS 2/ SLIDE Basic concepts of EMS, EIA, ISO What is Environment Surroundings in which an organisation operates, including.
Automotive Air Conditioning and Repair 7-1 Goals of P2 in Automotive Air Conditioning Service Work n Pollution Prevention Goals –Minimize refrigerant vented.
MARCH 9, 2006 Boating Safety and Enforcement Grant Program Regulations Stakeholder Workshop Proposed Conceptual Regulations Department of Boating and Waterways.
Brette Kaplan, Esq. Erin Auerbach, Esq. Brustein & Manasevit, PLLC Spring Forum 2013
CFC Phaseout Implications for Commercial Cooling Presented by Marie Broadwell US Environmental Protection Agency, Region IX (415)
MassDEP Underground Storage Tank Program Program Requirements for Owners and Operators Winter 2015 Workshops 1.
ORDER ENVIRONMENTAL PROTECTION PROGRAM WORKSHOP OZONE-DEPLETING SUBSTANCE PHASEOUT ISSUES TED KOSS
ISO DOCUMENTATION. ISO Environmental Management Systems2 Lesson Learning Goals At the end of this lesson you should be able to:  Name.
BY: Winston G. Smith Environmental Engineer UST/PCB & OPA Enforcement & Compliance Section EPA Region 4.
1 City of Shelby Wastewater Treatment Division Becomes State’s Second Public Agency to Implement a Certified Environmental Management System CERTIFICATION.
Overview of 3 rd Party Inspection Program for USTs.
Checking and Corrective Action EPA Regions 9 & 10 and The Federal Network for Sustainability 2005.
1 City of Shelby Environmental Management System -QUALITY ALWAYS- IT’S ABOUT THE PEOPLE Presented by: Cynthia I.Walters Presented by: Cynthia I.Walters.
ORDER ENVIRONMENTAL PROTECTION PROGRAM WORKSHOP OVERVIEW OF ORDER Larry Stirling
WORKSHOP ON ACCREDITATION OF BODIES CERTIFYING MEDICAL DEVICES INT MARKET TOPIC 9 CH 8 ISO MEASUREMENT, ANALYSIS AND IMPROVEMENT INTERNAL AUDITS.
Executive Order Strengthening Federal Environmental, Energy and Transportation Management EMS Requirements and Expectations.
1 Federal Acquisition Regulation Environmental Coverage Richard Langston Energy Representative Civilian Agency Acquisition Council.
Overview of Environmental Management Systems Using ISO John Rupe Forest Service Rocky Mountain Region.
Office of Infrastructure and Management Results-Oriented Government: The Executive Branch Management Scorecard January 25, 2006 White House Summit on Federal.
Environmental Management Division 1 NASA Headquarters Environmental Management System (EMS) Michael J. Green, PE NASA EMS Lead NASA Headquarters Washington,
Updates to the Section 608 Refrigerant Management Program for HVAC Excellence Conference March 28, 2017.
F-Gases.
RETAP Retired Engineer Technical Assistance Program
GTEC 2017 Annual UST Management & Compliance Assistance Seminar
Management of Change Report Errors to Management.
Updates to the Section 608 Refrigerant Management Program for HVAC Excellence Conference March 28, 2017.
Operationalizing Export Certification and Regionalization Programmes
BMSe Work Orders with Refrigerant Service Order Form
EPA Dates.
Presentation transcript:

Inspection Directions: An EMS Approach to Inspecting for Section 608 and 609 Compliance

Executive Order “Greening the Government Through Leadership in Environmental Management” every Federal agency was mandated to implement Environmental Management Systems (EMSs) at appropriate facilities. April 26, 2000

4 Phases of an Environmental Management Systems Planning- The organization identifies how its operations might harm the environment, and develops methods to reduce this harm. Doing- The organization implements these methods to reduce harm and operates them for a designated time period. Checking- The organization assesses whether the methods that it is operating to reduce environmental harm and ensure regulatory compliance are proving to be effective. Acting - The organization determines what changes are necessary based on the performance assessment of the methods (see Phase 3) designed to reduce environmental harm.

Executive Order Section 202- Environmental Compliance. Section 206- Reductions in Ozone- Depleting Substances.

Sec Environmental Compliance. Each agency shall comply with environmental regulations by establishing and implementing environmental compliance audit programs and policies that emphasize pollution prevention as a means to both achieve and maintain environmental compliance

Section 206- Reductions in Ozone- Depleting Substances each agency shall develop a plan to phase out the procurement of Class I ozone-depleting substances for all non-excepted uses by December 31, Through evaluating present and future uses of ozone-depleting substances and maximizing the purchase and the use of safe, cost effective, and environmentally preferable alternatives,

Phase Out of R-22 and R-142b January 1, Ban on production and import of R-22 & R-142b except for servicing needs January 1, Ban on sale and use of all HCFCs (except continuing servicing needs of refrigeration equipment) January 1, Ban on remaining production & import of R-22 & R-142b

Phase Out of R-22 and R-142b Very similar to phase out of R-12 in Motor Vehicle Air Conditioning systems The ban on production means only stockpiles of new or recycled R-22/142b will be available Replacement of existing equipment is not required

Protection of Stratospheric Ozone Prohibitions - Uncertified Technicians - Uncertified Recycle/Recovery/Reclamation Equipment - Intentional Venting Practices - Leak Repair - Proper Disposal of Refrigerant Record Keeping - Verification and Follow-up Verification tests (it’s not enough to perform the test, document it) - Technician and Equipment Certifications

Technician Certification Staff - must be properly certified - site maintains copies for 3 years Contract Vendor - must be properly certified - site maintains copies for 3 years Third party vendors not under contract - no requirements to maintain records on-site

Equipment Recovery/Recycle/Reclamation Equipment certification form Manufacturer’s label affixed to the equipment Substantially Identical Equipment

Practices Leak Repair - Preventive Maintenance - Refrigerant Tracking - Audits Disposal of refrigerant - Staff - Contract Vendor -Third Party Vendor

Records Technician Certifications Quantity and type of refrigerant added by owner/operator to appliances > 50lbs Date of repair Type of Service Disposal ticket/invoice from reclamation vendor

Records Initial report for leaks that have not been repaired within 30 days Initial Verification Reports Follow-up Verification Reports Documents of work performed Retrofit or Retirement plans Requests for time extensions!!!

Documentation for Leak Repair Identification of the facility Leak rate Methods used to determine the leak rate and full charge Date of discovery leak rate was above 35% (15%) Location of leaks to the extent determined to date Repair work already completed; estimated dates of completion; date of actual completion Date(s), type(s) and results of the failed follow-up verification test(s) Parameters for determining leak rate for verification <180 days

Records Dates of completion for repairs, extensions, etc. Extension notices granted by EPA A copy of the notification sent to EPA documenting second repair efforts were successful, and the facility is no longer required to retrofit or retire the system*

Retrofits or Retired Systems The plan submitted to EPA wherein it was explained your plan to achieve an acceptable leak rate Description of the leak rate method Notifications to and responses from EPA Notification (copy) of the successful second repair efforts that remove the requirement to retrofit or retire the system Extension requests

Self-Determined Full Charge 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

Excluding Purged Refrigerants Maintain records to support the amount of refrigerant claimed as sent for destruction Flow rate Quantity or concentration of the refrigerant in the vent stream Periods of purge flow Facility Identification and contact person

Excluding Purged Refrigerants General description of the refrigeration system, focusing on aspects of the system relevant to the purging of refrigerant and subsequent destruction Description of the methods used to determine the quantity of refrigerant sent for destruction and type of records that are being kept by the facility Frequency of monitoring and data-recording Description of the control device and its destruction efficiency