REFRIGERANT 8-BALL QUESTIONS:

TESTING YOUR REFRIGERANT PLAN

by James R. Parsnow

Director, Environmental Systems Marketing

Carrier Corporation

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?