With the increasingly complicated changes in both International
and Federal laws, the need for strategic plans for the phaseout
of chloride bearing refrigerants (CFCs, HCFCs) has become critical
to most businesses.
Establishing a good strategic refrigeration management plan requires
that the execution of that plan remain dynamic. International
agreements on refrigerant phaseout under the Montreal Protocol
have been updated every two years. These updates also affect
the U.S. Clean Air Act (CAA). Your plan needs to have the built-in
flexibility to be able to change to incorporate new standards
and laws.
It is important to determine exactly where you are with your refrigerant
plan. To check how comprehensive your plan is, consider the following
"eightball questions". If your strategic refrigerant
plan does not address these issues it may be flawed.
1. Can you address all of the questions in an EPA Section 114
letter?
2. Are you in compliance with the latest ARI & ASHRAE standards
that affect operations and building codes?
3. Have you developed a risk assessment plan for responding to
a significant spill?
4. When buying reclaimed refrigerant, what standards apply? (There
are four)
5. On your CFC-11 or HCFC-123 chiller, is the purge piped outside?
(This is just one of many items in ASHRAE 15-1994)
6. To protect and warn of a refrigerant leak, should you have
a refrigerant sensor or an oxygen deprivation sensor?
7. As of July 1, 1992 the venting of CFCs and HCFCs has been prohibited
by law. How about HFCs?
8. What does the EPA consider a "deminimus release"
of refrigerants?
Having difficulty answering the questions based on your current
plan? The answers are readily available, and should be included
in a good strategic refrigerant transition plan.
Checking Your Plan Against the Eightball Answers:
EPA - Section 114 Letter
If you are a suspect in the violation of the U.S. Clean Air Act,
you may receive what is referred to as a section 114 letter from
the Environmental Protection Agency (EPA). The format is consistent
and will ask several questions about your use of refrigerants.
Questions such as the sale and purchase of refrigerants along
with the associated records that must be kept. The following
is a sample outline of the questions that are often asked and
information that needs to be provided to the EPA. (The letter
typically is three pages of questions).
(1) A copy of all service invoices for any service, maintenance,
repair or disposal performed on appliances at the FACILITY
on or after July 1, 1992.
(2) Records indicating the number of appliances serviced, maintained,
repaired or disposed of at the FACILITY on or after July
1, 1992.
(3) Records indicating the amount of refrigerant consumed during
the service, maintenance, repair or disposal of any appliances
at the FACILITY on or after July 1, 1992.
(4) Records indicating the amount of refrigerant recovered
or recycled during the service, maintenance, repair or disposal
of any appliances at the FACILITY on or after July 1,
1992.
If your plan is complete and kept up-to-date, addressing a Section
114 letter should be painless. It is much better to address these
questions now, rather than after receiving a Section 114 letter.
ARI and ASHRAE Standards
The Air Conditioning and Refrigeration Institute (ARI) along with
the American Society of Heating Refrigerating and Air-conditioning
Engineers (ASHRAE) produce recommendations and guidelines that
have become the refrigeration industry standards and are often
the basis for laws throughout the world.
In the execution of your refrigerant plan these standards should
be a source of reference:
ASHRAE Guideline 3-1990 Reducing Emission Of Fully Halogenated
Chlorofluorocarbon (CFC Refrigerants In Refrigeration And Air
Conditioning Equipment And Applications.
This guideline recommends practices and procedures that will reduce
inadvertent releases of refrigerants. The guide covers such areas
of manufacturer, installation, testing, operation, maintenance
and disposal of refrigeration and air conditioning equipment.
ASHRAE 34-1992 and Addendum 3a-1992; Number Designation and Safety
Classification of Refrigerants.
This standard establishes the refrigerant numbering system for
the industry, for example R-11, R-22, R-134a. It also establishes
a uniform system for assigning reference numbers and safety classifications
for both toxicity and flammability to refrigerants. This standard
and the addenda to this standard will continue to serve as a guide
to the various new refrigerants that are entering the market,
those refrigerants that are referred to as blends and azeotropes.
ASHRAE 15-1994, Safety Code For Mechanical Refrigeration.
This standard (ASHRAE 15) is the oldest standard produced by ASHRAE
and was first published in the 1930's when the first CFCs were
developed. The updates to ASHRAE 15 continue to be the industry
guide for the safe practices and applications of refrigeration
equipment. The latest version, 1994, has been written into building
code language so that the standard can be easily adapted into
the various building codes. This new version contains several
changes to the two previous standards produced in 1989 and 1992.
For a refrigerant strategic plan this document is a "must
read" and "must apply" guide. To quickly understand
the changes in ASHRAE 15-1994 an interpretive guide is available
from Carrier Corporation, number 819-116. (Contact your local
Carrier Building System and Service office).
If your refrigerant plan includes large chiller retrofits, include
documents from Air Conditioning and Refrigeration Institute (ARI)
in your reference file. These documents include; ARI Guideline
E, Fouling Factors, A Survey of Their Applications in Today's
Air Conditioning and Refrigeration Industry, ARI Standard 590,
Positive Displacements Compressor Water Chilling Packages and
ARI Standard 550, Centrifugal and Rotary Screw Water Chilling
Packages. Guideline E reviews the influence of waterside fouling
of heat transfer surfaces as it affects water cooled condensers
and water chilling evaporators used in the air conditioning and
refrigeration industry. This standard is an important reference
to determine the condition of old equipment, and understand the
purchase of new equipment in specifying fouling factors.
Standards 550 and 590 are the industries' performance standards
for reciprocating chillers (590) and centrifugal and rotary chillers
(550). Currently these two standards, currently in the process
of being combined into one standard, ensure that the efficiency
and performance of chillers throughout the industry is understood
and maintained at a mandated level.
Risk Assessment
Your Refrigerant Plan should address the actions required if a
significant spill occurs. Accidents happen whether as a result
of carelessness, or untrained personnel, the release of refrigerants
into the environment could have a significant impact on your company.
The risks include EPA investigation, injury, and possible fines.
In addition to effects on the local environment, CFCs and HCFCs
are listed in the Emergency Planning and Community Right To Know
Act. Personnel inquiry, accompanied by law suits, and numerous
other "what if" concerns should be addressed.
A documented, strategic spill assessment, should be part of your
refrigerant plan. Your legal staff should help you address these
issues, assisted by industry experts. A good plan requires excellent
safety stewardship (to act as a responsible manager or administrator).
An article written for the Harvard Business Review, March-April
1994 "What Asbestos Taught Me About Managing Risks, by Bill
Sells, is an excellent reference in addressing risk issues.
Four Standards That Apply When Buying Reclaimed Refrigerant
ARI documents are the industry standard. The four standards that
should be understood and applied when recovering, recycling and
reclaiming refrigerants are the following:
ARI 700-1993, Specifications For Fluorocarbon and Other Refrigerants.
This standard has been incorporated into the U.S. Clean Air Act
as the purify standard for the acceptability of refrigerant quality
for new, reclaimed and/or repackaged refrigerants. As equipment
is replaced, converted or decommissioned this standard has been
the guide to ensure refrigerant purity levels. If your plan does
not address this standard as the rule for determining refrigerant
quality then you may be dealing in refrigerants that could void
equipment warranties, and may be in violation of local and federal
laws. Keep in mind that these laws are dynamic and ARI 700 has
been affected by these changes. As of March 1, 1995 the U.S.
Clean Air Act "sunsetted" (ended by elapsed time frame)
the requirement for compliance to ARI 700 standard requirements.
This "sunset" change in the law was extended. However
as no formal standard is yet in place, due to differences in the
industry recommendations as to what practices and guidelines should
be followed through the refrigeration industry in a "practical
application". ARI, as the industry institute, however provided
the guidance in creating a new "Industry Recycling Guide,
(IRG-2). This guide, available from ARI will now become the base
for replacing ARI 700 as the Clean Air Act reference. However,
the guide still references the practices set forth in ARI 700.
Fig. #1 is an example flow chart from IRG-2.
The remaining two standards that should be considered as part
of your refrigerant recover, recycle, reclaim plan are ARI Guideline
K, Containers For Recovered Fluorocarbon Refrigerants and ARI
Guideline N, Assignment of Refrigerant Container Colors. Guideline
K provides requirements for the design, construction, and assembly
of refrigerant containers. Guideline N sets the color standards
for containers for existing, new and reclaimed refrigerants.
This standard will continue to be updated as refrigerant colors
are assigned to identify the containers of the new blended and
azeotrope refrigerants being introduced.
CFC-11 and HCFC-123 Chiller Purge Exhaust
Your CFC-11 and HCFC-123 chiller purge exhaust should be piped to the outside of the building
according to standard ASHRAE 15-1994. When you considered that
the old purge systems on CFC-11 chillers and some of the HCFC-123
chillers blow off between three to twenty pounds of refrigerant
for every pound of non-condensables (air that the purge is designed
to extract), not venting these devices, can have a serious environmental
and safety impact. Even the newly installed "high efficiency"
purges should be vented to the outside of the building. Read,
understand, and apply ASHRAE 15-1994.
Refrigerant Sensor or Oxygen Deprivation Sensor?
The ASHRAE 15-1994 Safety Code for Mechanical Refrigeration provides
the guidance. Under the 1992 version of this standard refrigerant
application in the A1 Flammability and Toxicity group (ref. ASHRAE
34) could use an oxygen deprivation sensor that would alarm at
19.5% oxygen levels in a mechanical room (consider that the normal
room has approximately 20% oxygen level). Unfortunately at a
5% drop in oxygen levels, it was possible to have 67,000 ppm of
refrigerant present. A level that exceeds by a factor of 6.7
the levels of even the safest refrigerants (i.e. HFC-134a, 1000
ppm). The latest ASHRAE 15-1994 recommends that sensors specifically
alarm at the refrigerant concentration not less than or equal
to the corresponding TLV-TWA (Threshold Limit Value-Time Weighted
Average) of the refrigerant. Again, reference ASHRAE 15 as the
safety guide.
Can You Vent HFCs
Stated simply - No! Where the U.S. Clean Air Act prohibited venting
of CFCs and HCFCs back in July of 1992, the Clean Air Act (CAA)
has also implemented a clause of the 1990 CAA, that as of November
15, 1995, no alternative refrigerant is allowed to be vented to
the environment. Further those refrigerants must also fully comply
with the regulations on recover, reclaim and recycling.
A "deminimus release" of Refrigerants
The definition of a "deminimus release" according to
the Environmental Protection Agency (EPA) is: "quantities
of refrigerant released in the course of making good faith attempts
to recapture and recycle or safely dispose of refrigerant"
(taken from EPA, Summary of Final Rule).
It is best summarized by the following quote: "Do not vent
any refrigerants. Use them with extreme responsibility and stewardship
in the future" (J. Parsnow - CFC and Halon Conference 1994).
Eight questions with considerable impacts on your current strategic refrigerant plans. Could you address all the questions? Is your plan as comprehensive as you thought? Or are you behind the eight ball?