Halocarbons/Schedule 5

Sch5-3329

0

2017

584308.4

Below is an overview the acceptance criteria for the program: • Containers are typically received from wholesalers however, in certain cases they will come directly from contractors and end-users. • Cylinders/drums will not be accepted into the program until they have been tested and ascertained to meet the acceptance criteria for refrigerant content. The test will identify and quantify the relative percentages (by volume) of the major refrigerants collected. If cylinders or drums do not contain CFC, HCFC or HFC refrigerants, the refrigerant will be designated for reclaim or may be disposed of through the RMC program on a user fee basis. • The level of precision for relative percent of specified refrigerants by volume required by the refrigerant content test will be plus-or-minus 2% and should be filled to a minimum of 40% and a maximum of 80% by volume. • If the cylinder contains HCFCs and/or HFCs, the Collection Service Provider will determine if the refrigerant is to be reclaimed or destroyed. It will be at the discretion of the Collection Service Provider to determine if the refrigerant is commercially viable for reclamation. The exception to this specification is if the RMC tag/proprietary tracking system or customer states that they want the refrigerant destroyed, the Collection Service Provider will place the refrigerant in the program, regardless of whether the refrigerant can be reclaimed. • If the refrigerant is deemed reclaimable, it is removed from the program and entered into the normal reclamation system. The Collection Service Provider will absorb all costs incurred and will not levy any processing fees or charge backs to the contractor/wholesaler or RMC on any CFC, HCFC or HFC refrigerant marked for RMC.

The RMC program accepts all halocarbon refrigerants (CFCs, HCFCs and HFCs) from commercial refrigeration systems or stationary air conditioning systems (HVACR) in Canada. RMC will accept halocarbon refrigerants from industries outside of the HVACR industry however a user fee is applied to cover the cost of handling, storing and disposing of the refrigerant. The program accepts halocarbon refrigerants from the HVCAR industry regardless of the amount of oil, water, acids and dyes. However, the program has established a threshold for PCBs which is 25PPM. To date, the program has not received a container that exceeded the PCB threshold. The program has established a threshold of 4% for hydrocarbons and any container that exceeds the established threshold will be returned to its owner. Due to the new lower GHG limits being established worldwide, many of the new refrigerants may be flammable, therefore, the program is reviewing its procedures to determine whether it can accept flammable refrigerants safely and to determine what changes will have to be made to the procedures to ensure the safety of all who handle these refrigerants within the HVACR industry.

The RMC Program is a national program that covers the entire country. RMC operates as an extension of the current refrigerant reclamation system in Canada thereby allowing the program to reach all provinces and territories. Below is an explanation of how the process works from collection through to disposal: 1. Contractors collect surplus refrigerant from the equipment owners in cylinders or drums that meet the specifications applicable to the industry. 2. The contractor transports the recovered refrigerant to the wholesaler outlet; there are over 268 outlets across Canada. 3. Wholesalers accept, store and consolidate cylinders and drums of refrigerant destined for the RMC program and/or the regular reclaim process, and ship them to a Collection Service Provider based on minimum program quantities. Container shipments to Collection Service Providers will typically be a mixture of cylinders and drums of refrigerant designated for reclamation and for destruction (RMC). 4. Collection Service Providers accept cylinders/drums collect freight from wholesalers and return emptied cylinders pre-paid freight, as is currently the practice in the refrigerant reclamation business. Currently, there are two facilities used by the RMC Program; one located in Mississauga and one located in Nova Scotia. At the moment, there are no other facilities in Canada capable of providing the services required by the program. 5. The Collection Service Provider will test each cylinder and drum submitted, but will accept them into the RMC program for disposal only if they meet the appropriate specifications for refrigerant content. At this point, the refrigerant in each cylinder/drum will be accepted to the program and tracking of quantities will begin. 6. The Collection Service Provider will transfer the accepted refrigerant to an approved bulk cylinder (1000-lb size). 7. Once a bulk container is full, the refrigerant will be tested for contaminants. At this point, the bulk containers will be transferred to an ISO tank in preparation for shipment to the disposal facility for destruction

The RMC communication plan focuses on wholesalers and contractors. RMC includes wholesalers in the plan because they are conduit between RMC and the contractor. Messaging centres on the need to capture and recycle or destroy ODS and GHG refrigerants and the environmental risks associated with venting and/or leakage. The material contains information about funding, explains the fee structure, and educates the contractor about their obligations under the regulations and P2 Plan. To date, the program has held several webinars with participating wholesalers and their customers and plans to hold additional webinars before the end of 2018. RMC and HRAI Staff have attended trade shows such CIPHEX in Calgary and Women in HVAC tradeshow in Halifax and have plans to attend a HVACR Chapter meeting in BC in early December 2018. Similar activities are planned for the 2019 year.

RMC conducts annual audits of its Collection Service Providers (CSPs). The most recent audit was conduct in June 2018 by Stantec Consulting Ltd. Below is their summary for 2018.Stantec Consulting Ltd. (Stantec) was commissioned by Refrigerant Management Canada Inc. (RMC) to conduct independent audits of the two RMC Collection Service Providers (CSPs), known as Fielding Environmental (Mississauga, ON), and Refrigerant Services Inc. (Dartmouth, NS). The CSPs receive waste chlorofluorocarbon (CFC), hydrochlorofluorocarbon (HCFC) and hydrofluorocarbon (HFC) refrigerant from contractors and wholesalers, test and bulk it into approved cylinders, and send the waste refrigerant under the RMC program for final destruction off-site.The scope of each audit included evaluation of the CSPs against federal and provincial environmental regulations pertaining to CFC/HCFC/HFC containing refrigerants, and against RMC's Operating and Performance Guidelines for Collection, Transportation & Storage Services, revised February 2017 and RMC’s Emergency Management Plan, revised June 2016. The site visits for the two audits were conducted in June 2018. The audit period was from the end of the previous RMC audits in 2017 to the last on-site day of the 2018 audit for each site. Stantec auditors also commented on environmental good management practices relevant to the handling of CFC, HCFC and HFC containing refrigerants at each facility.The audit objectives were to:Verify CSPs’ compliance with applicable regulations and regulatory approvals relevant to the RMC program. 1. Provide assurance to stakeholders of the integrity of the RMC program. 2. Provide assurance to RMC management that service provider operations are consistent with good practice and these operations comply with RMC policies and standards noted in the RMC Operating and Performance Guidelines for Collection, Transportation and Storage Services, revised February 2017, and the RMC Emergency Management Plan, revised June 2016. 3. Enhance RMC protection from potential liabilities by demonstrating due diligence.

RMC is funded by an environmental levy remitted by refrigerant manufacturers, importers and reclaimers on sales of HCFCs and, as of February 2017, HFC refrigerants. HCFCs and HFCs are controlled halocarbon substances primarily used in air conditioning equipment (residential, commercial and industrial) and commercial refrigeration equipment. The monies received from this levy funds all aspects of the program, including the collection, transportation, storage and the disposal of refrigerants that enter the program. Currently RMC levies are charged on sales: • Of new or reclaimed HCFC and HCFC blended refrigerants - $4.50 per kilogram • Of new or reclaimed HFC and HFC blended refrigerants - $1.00 per kilogram These levies are only charged on refrigerants being purchased for use in the stationary and air conditioning industry.