Developing a Refrigerant Management Plan

Additional Info:

Robert Johnson, CEO, ESS

Chasing out ozone-depleting substances profoundly affects any facility using air-conditioning and refrigeration equipment. Replacing equipment and complying with emissions-release regulations require major capital outlays. Developing and implementing refrigerant management policies are vital to a successful phaseout.

A refrigerant management plan based on accurate equipment and refrigerant inventories is a roadmap for a smooth transition. The plan minimizes capital expenditures and operating costs while achieving compliance with applicable laws and ensuring continued supplies.

Designate a Refrigerant Manager

Coordinating the plan across all company functions and departments is essential. EPA urges facilities to designate a refrigerant manager as a focal point for program activities. He should have the authority and budget to effect change; be current on the plant's HVAC/R operations, industry standards, and related regulations; and be able to communicate successfully with other departments. (Responsibilities of a refrigerant manager are outlined in the accompanying section, "Duties of a Plant Refrigerant Manager.")

The refrigerant manager should institute certain administrative controls. Required forms must be completed and sent to the EPA and any permits obtained. Policies for leak repair, CFC purchase and storage, and waste-stream characterization must be established. Companies must define their contaminated CFC and HCFC disposal processes, procedures for flushing and cleaning, used refrigerant quality policy, and existing equipment service specifications. Halon (extinguishing agent used primarily for computer room protection) and refrigerant bank policies should also be established.

Administrative controls should include keeping records. EPA has established recordkeeping requirements for equipment containing CFCs and HCFCs. HFCs are likely to be added soon. Major refrigerant users (equipment containing more than 50 lb) must be identified and records kept of how much refrigerant each piece holds and if it exceeds the allowable leak rate. If equipment charged with certain refrigerants is leaking at more than the allowable rate, it must be repaired within 30 days, or a written plan to replace the equipment within 1 yr must be prepared.

EPA can require submission of detailed reports on refrigerant use, service, maintenance, and disposal. Fines for failing to comply with regulations can be as high as $25,000/day for each violation. Using a computer-based tracking and reporting program facilitates data handling and helps ensure compliance.

Develop a Basic Policy

Each company's mission should be to contain all refrigerants and prevent them from entering the environment. It has been a felony to vent refrigerants into the atmosphere intentionally since July 1992. They must be recovered, recycled, or reclaimed using proper techniques. A company's refrigerant policy should reflect an intent to comply with this law. (A suggested policy statement is provided in the accompanying section, "Basic Refrigerant Management Policy.")

Before a refrigerant management plan is formulated, a comprehensive systems assessment must be made. The assessment includes an equipment inventory; operating and maintenance practices; refrigerant recovery, recycling, and reclamation procedures; refrigerant containment; and chiller retrofit or replacement plans.

The inventory is needed so that the company can assess current refrigerant requirements and potential impact of regulations and legislation. It should also help determine management options and course of action and provide policy guidance and technical assistance. The plan also requires the development of budgets and replacement schedules, as well as a means to monitor the transition from CFCs to alternative refrigerants.

Every plan should provide for equipment containment, conversion, and replacement. For existing systems in good condition, continued use of CFCs may be a viable near-term solution. Expenditures must be made to ensure refrigerant containment and prudent procurement and inventory practices. Some containment options are shown in the table.

A written, monthly leak test schedule to ensure problems are discovered and repaired quickly helps minimize refrigerant loss. An accurate leak test log helps ensure compliance. Noting cost of technicians multiplied by the time spent helps provide accurate data.

A CFC stockpile policy helps ensure an adequate supply of refrigerant. The cost to stockpile R-11 in 1995 is estimated at $10 to $15/lb; cost for R-12 is $14 to $20/lb. Those costs are expected to rise in 1996.

If equipment is to be converted, its condition, service needs, and performance options must be considered. Machines with serious internal service problems are appropriate retrofit candidates. Those with major vessel or tube problems may not be. A report showing the machine's operating performance data using the alternative refrigerant should be developed. It should include options for optimizing efficiency through internal modifications. Retrofit costs range from $80 to $200/ton depending on the scope of the work. Work should be scheduled during regular overhauls to reduce costs.

Proper operation and maintenance practices improve overall chiller performance, simplify preventive maintenance, and facilitate training. They provide efficient, reliable air conditioning and reduce refrigerant loss. Guidance is available in manufacturers' manuals, EPA regulations, and American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) guidelines.

Any program should make safety a priority. Common-sense handling of refrigerant equipment and use of proper procedures prevent injuries and mistakes. The refrigerant management plan should include a safety policy to minimize hazards. Potential hazards relate to the physical and chemical characteristics of the refrigerant (toxicity, flammability, pressure, and temperature parameters). OSHA and ASHRAE standards are helpful in formulating an emergency response plan.

Establish a Timetable

A general timetable should be developed to implement the plan. The most critical phase is the period prior to January 1, 1996, when CFC production ceases. Completing low-cost chiller modifications and containment measures and initiating appropriate operations and maintenance practices are key. For planning purposes, chiller budget requirements should be made known so they may be integrated with other capital requirements. Developing a schedule of dates and budget impacts formulates an assertive instead of a reactive approach.

A typical schedule should include:

Designate a facility refrigerant manager
Train manager and technicians
Perform systems assessment and evaluate alternatives
Formulate refrigerant management plan
Implement administrative controls and refrigerant policy
Initiate recordkeeping system
Analyze the results and refine the program.

An aggressive policy is necessary to meet the environmental challenges of the CFC phase-out. Making prudent long-term capital investment decisions and meeting short-term demands, while maintaining equipment and refrigerant assets, should be of vital concern to any plant.

Duties of a Plant Refrigerant Manager

The primary role of the facility refrigerant manager should be to ensure compliance with CFC phaseout regulations. His principal duties should include:

Coordinate refrigerant purchases and maintain inventory of use records
Gather and disseminate information on refrigerant technology, codes, and regulations
Develop and apply administrative controls
Develop and implement a refrigerant policy
Perform a systems assessment and evaluate alternatives
Plan for future refrigerant and equipment needs
Develop a refrigerant management plan schedule
Ensure regulatory compliance
Participate in budgeting processes
Ensure safe handling of refrigerants by all personnel
Minimize risks associated with refrigerant handling.

The manager's authority should encompass procurement of equipment and services to comply with regulations; technician training; refrigerant transportation and disposal; safety equipment; and management of refrigeration equipment retrofit or replacement.

Refrigerant Containment Options
Option	Approximate Cost, $	Type of System
High-efficiency purges	6000	Low pressure
Relief valves/rupture discs	4500	Low/high pressure
Isolation service valves	2800	Low/high pressure
Containment storage vessel	8000	Low/high pressure
Off-cycle pressurization	5500	Low pressure

Basic Refrigerant Management Policy

A basic refrigerant management policy should clearly show the company's intention to comply with all regulations. Several features should be included in the policy.

Recovery and recycling equipment will be made available to service technicians in sufficient quantity to perform within EPA regulations.
Responsibility for the care and maintenance of recovery and recycling equipment, including recordkeeping, rests with the service technician.
Records will be kept to guarantee performance and ensure regulation compliance. Included are inventory cards attached to new drums of refrigerant, use records for recycling and recovery equipment, and records on disposition of recovered or recycled refrigerant.
Refrigerant cylinders stored on-site will not be filled to more than 80% of fluid capacity.
Refrigerants shall not be mixed. A separate, clean, evacuated, labeled vessel will be provided for each refrigerant.
Leak testing shall be performed periodically to ensure the integrity of all systems.
Leaks will be repaired upon discovery. Management will be notified of any substantial venting or inability to repair leaks immediately.
Refrigerants shall be recovered, reclaimed, or properly destroyed whenever removed from equipment.
Before refrigerant is recovered, recycling or reclamation requirements shall be determined. Equipment will meet or exceed Air-Conditioning and Refrigeration Institute standards before being reused.
Only approved containment vessels and equipment will be used. Dry nitrogen shall be used to break all vacuums created by the recovery process.

ESS is the leading provider of Operational Risk Management software and services for Environmental, Health & Safety (EH&S) and Crisis Management. The company has provided Essential Suite™ and Compliance Suite™ solutions to more than 17,000 businesses, government agencies and other organizations worldwide.