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OZONE-DEPLETING
SUBSTANCES Introduction The National Oceanic
and Atmospheric Administration (NOAA) is committed to phasing out the
use of ozone-depleting
substances (ODSs) throughout
its operations. As one of the world's leading research agencies regarding
the ozone layer, NOAA has made significant contributions towards advancing
the scientific understanding of ODSs and their effects on the atmosphere.
The term "phaseout" is intended to incorporate both elimination
and minimization in the use of ODSs. There are practical difficulties
associated with the transition away from ODSs and, in some critical applications,
ODS alternatives are not currently available. Background Ozone can be found
throughout the earth's atmosphere. In the lower atmosphere (the troposphere),
ozone contributes to smog formation and is considered
an air pollutant. However, in a higher region of the atmosphere (the
stratosphere), the ozone layer absorbs ultraviolet radiation, which is
harmful to humans, animals, and plants. In humans, the effects of chronic
exposure to excessive ultraviolet radiation include skin cancer and cataracts.
Moreover, excessive ultraviolet radiation impairs photosynthesis and
disrupts plant metabolism, inhibiting worldwide food production. Scientists
have discovered thinning of the protective stratospheric ozone layer
at many latitudes and a seasonal ozone "hole" over the Antarctic
in spring. They have linked this ozone depletion with increased emissions
of a group of chemicals called ODSs. This group contains compounds such
as chlorofluorocarbons (CFCs); hydrochlorofluorocarbons (HCFCs); halons;
methyl bromide; 1,1,1-trichloroethane (TCA) (also referred to as methyl
chloroform); and carbon tetrachloride. In the troposphere, these compounds
are stable and inert. In the stratosphere, however, ODSs catalyze ozone-degrading
reactions in the presence of ultraviolet radiation, thus reducing the
concentration of beneficial ozone.
In response to the scientific evidence demonstrating "holes" in
the stratospheric ozone layer and the link between ozone depletion
and ODSs, 23
nations signed an agreement in 1987 to control the production and use of ODSs.
The agreement, called the Montreal Protocol, included provisions for regular
reviews of the adequacy of ODS control measures. The adequacy of control measures
was to be based on assessments of the ozone layer and other scientific, environmental,
and economic information. There have been 10 annual follow-up meetings to the
Montreal Protocol, where numerous additional agreements addressing the production
and use of ODSs have been reached. To date, more than 160 countries including
the United States, have signed the Montreal Protocol. Overview of Regulations and Directives As a result of the Montreal Protocol agreements, the United States has
developed regulations and directives to phaseout ODSs. The United States
has enacted Title VI of the Clean Air Act Amendments of 1990 (CAAA) to
implement elements of the Montreal Protocol. Directives related to the
Montreal Protocol such as ODS production phaseout schedules and other
applicable state and local laws have been developed. These driving forces
are summarized in the following sections.
Clean Air Act Title VI: Title VI of the CAAA establishes a comprehensive
regime for phasing out ODSs. Building on the Montreal Protocol, Title
VI calls for the phaseout of most ODSs by the year 2000 and the imposition
of other controls designed to minimize ODS emissions before they are
eliminated.
EPA designates ODSs as either Class I or Class II substances. In general, Class
I substances destroy more stratospheric ozone molecules than do Class II substances.
The ozone-depletion potential (ODP) is the ratio of the impact on ozone of
a chemical compared to the impact of a similar mass of CFC-11. Class I substances
have a greater ODP than Class II substances. Table 1 provides ODP values for
ODSs generally used at NOAA facilities. A list of EPA regional ODS contacts
is provided in Table 2. According to these contacts, states have not adopted
regulations significantly more stringent than their federal counterparts.
Executive Order 12843: Executive Order 12843, Procurement Requirements
and Policies for Federal Agencies for Ozone-Depleting Substances, states
that all federal agencies must "implement cost-effective programs to
minimize the procurement of materials and substances that contribute to the
depletion of stratospheric ozone." Specifically, this order requires
that all federal agencies shall, to the extent practical:
- Conform procurement regulations and practices to the policies and
requirements of Title VI of CAAA, which deal with stratospheric ozone
protection.
- Maximize the use of safe alternatives to ODSs.
- Evaluate the present and future uses of ODSs, by making assessments
of existing and future needs for ODSs, and evaluate ODS use and recycling
plans.
- Revise procurement practices and implement cost-effective programs
to modify specifications and contracts that require the use of ODSs
and to substitute non-ODSs to the extent economically practicable.
- Exercise leadership, develop exemplary practices, and disseminate
information on successful efforts in phasing out ODSs.
Major Components of ODS Phaseout Regulations Federal ODS regulations are derived from CAAA Title VI and Executive Order
12843. Major components of the regulations are outlined in the following
sections.
EPA ODS Production Phaseout Schedules: CAAA Title VI, Sections 601
through 607, established ODS production phaseout schedules for the United
States that were more stringent than those contained in the original Montreal
Protocol, and gave EPA the authority to enforce ODS phaseout. In July 1992,
EPA issued a final rule implementing CAAA Section 604, which accelerated
ODS production phaseout. The final rule and the accelerated phaseout schedule
are summarized in EPA's Stratospheric Ozone Protection, Final Rule Summary, dated
December 1993. Subsequent to July 1992, several amendments to the accelerated
schedule, as implemented in CAAA Section 606, have been enacted.
Consistent with the Montreal Protocol, EPA's approach to eliminating ODS use
was to phase out ODS production over multiple years. Production of Class I ODSs
is phased out first because their ODPs are high compared to Class II ODSs. Because
of the Class I ODS production phaseout, NOAA will soon be unable to obtain Class
I ODSs. The U.S. production phaseout schedule for common Class I ODSs is presented
in Table 3.
The production phaseout schedule for Class II ODSs (HCFCs) extends until the
year 2030 because they have significantly lower ODPs than Class I. HCFCs with
relatively high ODPs (HCFC-141b, HCFC-142b, and HCFC-22) are scheduled for earlier
Class II phaseout than HCFCs with lower ODPs. The production phaseout schedule
for Class II ODSs, which includes the ODS HCFC-22 used at NOAA facilities, is
presented in Table 3. Although HCFCs will be phased out of production in the
long term, industry is using some EPA-approved Class II ODSs as alternatives
for Class I ODSs in the short term. The Class II ODS phaseout schedule is presented
in Table 4.
Emission Minimization: CAAA Title VI, Section 608 requires that federal
agencies: (1) reduce ODS use and emissions to the lowest achievable level, and
(2) maximize ODS recapture and recycling. Minimizing ODS refrigerant emissions
from air conditioners (ACs), motor vehicle air conditioners (MVACs), and refrigeration
units at NOAA facilities through good operating practices is essential. Refrigerant
emissions can be minimized through: (1) proper use, handling, and storage of
refrigerant gas cylinders; (2) detecting and repairing refrigerant leaks from
cooling systems; and (3) recovering and recycling refrigerants from cooling systems
during maintenance and repair or before disposal.
Training and Certification: CAAA Title VI, Sections 608 and
609 specify proper training and certification for unit technicians
and MVAC technicians. ODS technicians maintain, repair, or dispose
of ACs, refrigeration units, and MVACs, and their activities could
reasonably be expected to release ODSs to the atmosphere. A critical
function of these technicians is to reclaim refrigerants.
ODS technicians usually specialize in (1) ACs and refrigeration units (called
unit technicians), or (2) MVACs. Accordingly, different training and certification
requirements apply for unit technicians and MVAC technicians. For ODS technicians
who meet applicable training and certification requirements, no refresher training
or recertification is required.
Labeling: CAAA Title VI, Section 611 describes labeling requirements for
ODS storage devices and ODS-containing equipment. The manufacturers of these
products are responsible for correct labeling before they are introduced into
interstate commerce. These labeling requirements apply to products that contain
or are manufactured with an ODS. Since NOAA does not manufacture ODSs, these
requirements do not apply.
Significant New Alternatives Policy (SNAP): CAAA Title VI,
Section 612 requires EPA to establish a Significant New Alternatives
Policy (SNAP) to identify alternatives to both Class I and Class
II ODSs and to publish lists of acceptable and unacceptable substitutes.
It is illegal to replace a Class I or Class II ODS with any substitute
determined to present adverse effects to human health or the environment
where other substitutes have been identified that reduce overall
risk and are currently or potentially available.
On March 18, 1994, EPA published the SNAP final rulemaking (59 Federal Register
[FR] 13044), which described the process for administering the SNAP program and
contained EPA's first acceptability lists for substitutes in the major industrial
use sectors. These sectors include refrigeration and air conditioning; solvents;
foam blowing; fire suppression and explosion protection; sterilants; aerosols;
adhesives, coatings, and inks; and tobacco expansion.
EPA has published numerous updates to the SNAP since 1994, and will continue
to do so as new approved alternatives are developed. For future reference on
EPA updates, the most current and comprehensive SNAP list can be found on EPA's
Stratospheric Ozone Home Page at the following Internet address:
http://www.epa.gov/ozone/title6/snap
Procurement: Executive Order 12843, Procurement Requirements and
Policies for Federal Agencies for Ozone-Depleting Substances, states
that all federal agencies must "implement cost-effective programs to
minimize the procurement of materials and substances that contribute to the
depletion of stratospheric ozone." Ozone-depleting
substances continued >
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