Overview of EPA Refrigerant Regulations

1
Overview of EPA Refrigerant Regulations

• Julius Banks
• U.S. Environmental Protection Agency
• 1st Annual National
• HVAC Educators Trainers Conference
• March 26-27, 2007
• Las Vegas, NV

2
Contact Information

• Julius Banks, Team Lead Refrigerant Recycling and
  Emissions Reduction
• Phone [phone]
• E-mail banks.julius_at_epa.gov
• www.epa.gov/ozone
• www.epa.gov/ozone/title6/608/608fact.html
• Ozone Hotline [phone]

3
Overview of Presentation

• Effects of UV radiation
• The Montreal Protocol and the Clean Air Act
  amendments of 1990
• What is an ODS?
• Refrigerant Recycling Requirements
• Venting Prohibition
• Certification Requirements Refrigerant Sales
  Restriction
• Service Requirements Leak Repair
• Enforcement
• Phaseout of R-22
• What this means to technicians
• What technicians should be telling their
  customers

4
Why All the Trouble?

• cataracts - cloudy vision, blindness
• in U.S., 25 linked to UV-b exposure
• non-melanoma and melanoma skin cancers
• 1 in 5 Americans ( 1.3 million people/yr)
• 1800 increase in malignant melanoma since 1930s
• impacts on children 80 of lifetime exposure to
  UV before age 18

5
The Montreal Protocol

• The Montreal Protocol on Substances That Deplete
  the Ozone Layer (Montreal Protocol) is a landmark
  international agreement designed to protect the
  stratospheric ozone layer. The treaty was
  originally signed in 1987 and substantially
  amended in 1990, 1992, and 1997.
• The Montreal Protocol stipulates phaseout
  schedules for the production and consumption of
  compounds that deplete ozone in the stratosphere.

6
The Clean Air Act

• Amended in 1990 to include Title VI Protection
  of the Stratospheric Ozone Layer
• Prohibits the intentional release of ODS during
  the maintenance, service, repair, or disposal of
  refrigeration and air conditioning equipment
• Directs EPA to establish requirements to reduce
  use and emissions of ozone-depleting substances
  and their substitutes during the servicing,
  repair, or disposal of appliances and industrial
  process refrigeration equipment.
• Product bans, servicing requirements, mandatory
  labeling, approval of alternatives
• Phaseout (down) the production and import of
  ozone-depleting substances

7
What are ozone-depleting substances?

• EPA regulates class I and class II
  ozone-depleting substances (ODS)
• Refrigerants CFCs and HCFCs (R-11, R-12, R-22,
  R-123)
• Solvents (R-113, methyl chloroform, carbon
  tetrachloride)
• Pesticide (MeBr)
• Fire suppression agents (halons)
• NOTE hydrofluorocarbons are not listed (for
  example, R-410A, R-134a)

8
Section 608of the Clean Air Act

• Under Section 608 of the CAA, EPA has written
  regulations (40 CFR Part 82, Subpart F) that
• Prohibit the intentional release of ODS
  refrigerants and their substitutes during
  service, maintenance, or disposal events
• Require service practices that maximize recycling
  of ozone-depleting substances during the service
  and disposal of air-conditioning and
  refrigeration equipment
• Set certification requirements for recycling and
  recovery equipment, technicians, and reclaimers
• Restrict the sale of refrigerant to certified
  technicians

9
Section 608of the Clean Air Act (contd)

• Require persons servicing or disposing of
  air-conditioning and refrigeration equipment to
  certify to EPA that they have acquired recycling
  or recovery equipment and are complying with the
  requirements of the rule
• Require the repair of substantial leaks in
  air-conditioning 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)

10
Refrigerant Venting Prohibition

• Illegal to intentionally release any refrigerant
  or substitute into the atmosphere during service,
  maintenance, repair, or disposal of a/c or
  refrigeration equipment
• Yes, it is illegal to vent R-134a and R-410A
  during a service call!

11
Technician Certification

• Federal mandate for any type of repair or service
  on a refrigerated appliance
• Type I small appliances (refrigerators, window
  a/c)
• Type II med-high pressure (residential R-22
  systems)
• Type III low pressure (R-11 chiller)
• EPA approved certifications never expire
• Grandfathering for technicians certified under
  voluntary programs ended in 1995
• Testing must be performed by an EPA-certified
  testing organization

12
Technician Certification (contd)

• Not required for disposal of small appliances
• The disposer must make certain that all
  refrigerant has been recovered prior to
  shredding, dismantling, etc.
• Does not apply to systems using non-ODS
  alternatives in the stationary sector (for
  example, R-410A, R-134a, R-404A)

13
Upcoming Rule Changes for Certifying Programs

• 2008 - Notice of Proposed Rulemaking
• Proctor certification
• Exam stocking
• Annual reporting
• Reporting Recordkeeping requirements
• On-line testing
• Type I certification updates

14
Refrigerant Sales Restriction

• Statutory under Sect. 609 of the Clean Air
  Act-restricts sales of CFC refrigerants in small
  quantities to Sect. 609 (i.e., motor vehicle air
  conditioning) technicians
• Under Sect. 608 EPA has extended the sales
  restriction to ODS in all size containers
• Sales of refrigerant blends containing HCFCs are
  restricted (e.g., FRIGC FR-12, Free Zone, Hot
  Shot or R-414B, GHG-X4 or R-414A, Freeze 12)
• Pre-charged parts are LEGAL to sell without
  certification
• USED ODS refrigerant cannot be resold to a new
  owner without being reclaimed by an EPA-certified
  refrigerant reclaimer

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Other Certification Requirements

• Service companies and in-house techs/contractors
  must certify to EPA that they have EPA-certified
  recovery/recycling equipment
• Manufacturers of recovery/recycling equipment
  must certify their equipment meets ARI 740
  specifications NOT technicians
• Reclaimers are required to return refrigerant to
  the purity level specified in ARI Standard 700
  (an industry-set purity standard) and to verify
  this purity using the laboratory protocol set
  forth in the same standard NOT technicians.

16
Leak Repair Requirements

• Refrigeration and a/c systems with charge sizes
  greater than 50 lbs
• Industrial process refrigeration
• Commercial refrigeration
• Comfort cooling a/c
• Must repair within 30 days
• Or convert to non-ODS
• Or retire within 1 year
• Leak repair is the responsibility of the
  equipment owner/operator NOT the technician

17
Recordkeeping Reporting Requirements

• Technicians must keep copy of certification card
  at their place of business
• Technicians must provide service record to their
  customers
• Date and type of service
• Amount of refrigerant added to the system
• Service companies our companies with in-house
  service personnel must certify to their EPA
  regional office
• You have EPA certified refrigerant
  recovery/recycling equipment
• You will properly use such equipment

18
Urban Legends, Myths, and Misunderstandings

• I can get a 10,000 reward for turning in my
  employer, former best friend or spouse
• EPA has a database of technicians so they can
  replace my lost tech cert card
• It is okay to vent HFC refrigerants such as
  R-134a and R-410A
• All junior level techs are considered apprentices

19
Urban Legends, Myths, and Misunderstandings
(contd)

• EPA is responsible for the SEER-13 standard
• EPA is responsible for the CFC excise tax
• EPA is issuing a tax on HCFC and HFC refrigerants
• There is no enforcement of the refrigerant
  regulations
• EPA will ban the use of R-22 after 2010
• Environmentally safe refrigerants are on the
  market for use in residential and commercial uses

20
U.S. HCFC Phaseout Regulations

• 1993 rule established framework, schedule
• Implements step-downs for HCFCs
• Included worst-first approach 141b, 22, 142b
• 2003 rule allocated allowances
• Phased out HCFC-141b production, import
• Cut U.S. consumption 35 below cap by 1/1/04
• Issued baseline allowances to individual
  companies based on historical information for
  production, import of HCFC-22, HCFC-142b
• Allocated allowances HCFC-22 HCFC-142b
• Allocated100 of consumption production caps
• Allocated allowances to individual companies

21
Milestones in the HCFC-22 Phaseout

• Jan. 1, 2010 - Ban on production import of R-22
  except for on-going servicing needs in equipment
  manufactured before 1/1/2010
• Jan. 1, 2015 - Ban on production, import, use of
  HCFCs except where the HCFCs are used as a
  refrigerant in appliances manufactured prior to
  1/1/2020
• Ban on remaining production import of R-22
• Ban on remaining production import of all other
  HCFCs
• Certain exemptions apply for HCFCs that are
  recovered either recycled or reclaimed or used
  in processes resulting in their transformation or
  destruction.

22
Meeting the 2010 Milestone

• EPA will reduce allowances for HCFC-22
  HCFC-142b as of January 1, 2010
• Production and import of virgin HCFC-22 142b
  will be for servicing existing equipment only
• Newly manufactured appliances (e.g.,
  refrigeration and a/c equipment) in the US will
  not be able to be charged with virgin HCFC-22,
  HCFC-142b or blends containing these substances
• Production and Consumption Allowances EPA must
  determine the allowance amounts while
• Staying below the Montreal Protocol caps
• Ensuring production/imports are for servicing
  only
• Recognizing the role of recovered refrigerants

23
Servicing Existing Equipment after 2010

• Consumers wont be required to stop using HCFC-22
• Consumers wont be required to replace existing
  equipment
• Existing (pre-2010) equipment using HCFC-22 or
  HCFC-142b may be serviced as usual
• After 2010, supplies of HCFC-22 will be more
  limited
• After 2020, only stockpiled or reclaimed HCFC-22
  will be available

24
Analysis of Servicing NeedsStudy Objective and
Focus

• Help EPA set allocation for future consumption
  caps by projecting
• Units of equipment using HCFCs beyond 2010
• HCFCs needed to service equipment after 2010
• Analysis focused on HCFC-22 for refrigeration and
  AC equipment servicing needs
• Projected R-22 servicing demand exceeds the
  consumption cap starting in 2015
• Use of recovered/reclaimed refrigerant will be
  necessary to avoid R-22 supply shortages.

25
Results Scenario 1 (50 Recovery)
100,000
90,000
Recovered R-22
Virgin R-22
80,000
Total R-22 Service Demand

70,000
HCFC-22 (MT)
HCFC Consumption Cap
60,000
50,000
40,000
30,000
20,000
10,000
0
2015
2020
2010
Source EPA's Vintaging Model (VM IO
file_6-30-06_ALL)
26
Results Scenario 2 -- (10 Recovery)
100,000
Recovered R-22
90,000
Virgin R-22
80,000
Total R-22 Service Demand

70,000
HCFC Consumption Cap
60,000
HCFC-22 (MT)
50,000
40,000
30,000
20,000
10,000
0
2015
2020
2010
Source EPA's Vintaging Model (VM IO
file_6-30-06_ALL)
27
STOP VENTING!!!!

• R-22 is being phased out
• Its value will increase in the future
• Help avoid shortages and protect the environment
  by recovering and reusing
• Save your customers money by avoiding top-offs
• Need more info on the Phaseout?
• www.epa.gov/ozone/title6/phaseout

28
Ban on HCFC Equipment

• The intent of Clean Air Act was to end the use of
  ODS not to end solely the domestic manufacture of
  products containing ODS
• CAA establishes requirements to
• Ban emissive uses,
• Establish safe servicing procedures to limit
  emissions,
• Phaseout ODS production, import, and export,
• Identify alternatives, etc.
• All in an effort to assist with a smooth
  transition to alternatives

29
Potential Proposed Ban

• CAA already restricts import of HCFCs in bulk --
  but not after the substances are charged into
  air-conditioning and refrigeration equipment
• EPA may propose to ban
• The sale and distribution in interstate commerce
  of all air-conditioning and refrigeration
  equipment (including import and export)
  containing HCFC-22, HCFC-142b, and/or blends
• Similar to the current ban on the sale and
  distribution of air-conditioning and
  refrigeration appliances containing CFCs

30
Why Propose a Ban?

• Without taking steps to ban pre-charged products
  there could be continued impacts on stratospheric
  ozone
• Increased potential for improperly servicing or
  venting
• Because these products could not be legally
  charged with virgin HCFCs
• could lead to servicing by non-certified
  technicians, unaware of the servicing
  requirements
• Important with or without the ban improperly
  servicing and venting would still be illegal!

31
Why Propose a Ban? (contd)

• US market for imported HCFC-charged appliances
  could delay the phaseout of HCFC production
  abroad
• Our continued desire for products containing
  HCFCs could lead to greater manufacture of HCFCs
  and products containing HCFCs abroad
• Efforts to assist countries to move to non-ozone
  depleting alternatives could be hampered
• Suitable alternatives are already manufactured
  both domestically and abroad

32
Things to tell newly trained technicians

• Dont intentionally vent any refrigerant
• Use recovery equipment
• Properly dispose of small appliances
• Dont carry your cards in your wallet
• Avoid topping off leaking systems
• EPA has not banned the use of R-22 equipment
• Verify what you read or hear
• www.epa.gov/ozone
• [phone]

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Closing

• Questions
• Town hall Style meetings