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Hazardous Air Pollutants (HAPs) and
Ozone Depleting
Chemicals (ODCs)
The 1990 Clean Air Act Amendments (CAAA) directed the U.
S. Environmental Protection Agency (USEPA) to regulate
emissions into the air of 188 toxic chemicals. These
chemicals, called Hazardous Air Pollutants (HAPs), are
known as suspected carcinogens, and have high usage and
emissions in a wide variety of processes. EPA has
determined that emissions of these chemicals present a
threat to human health and the environment. As an owner
or operator of equipment that uses products that contain
chemicals, it is our responsibility to track and control
any of the 188 regulated chemicals listed by the USEPA.
The state of Texas also requires owners and operators of
equipment to track and control Texas contaminants in
addition to those listed by USEPA. Refrigerants
containing fluorocarbon compounds that contain chlorine
are harmful to the stratospheric ozone layer and thus
they are also known as ODCs. Based on their potential to
deplete ozone ODCs have been classified as either a
Class I or Class II ODC and are regulated by Title VI of
the Clean Air Act.
 Do
you do aviation maintenance?
Click here for the Aerospace NESHAP
Click here for Asbestos Information
Upcoming Defense Land System and Miscellaneous
Equipment (DLSME) NESHAP
Information on use and
recovery/recycling of ODCs
Accidental Release Reporting
How to
obtain refrigerant technician certification
What to do
with equipment with refrigerant in it
 Fort
Hood must comply with rules and regulation affecting
aerospace maintenance and rework facilities under
40 Code of Federal Regulation (CFR) 63, Subchapter GG.
This NESHAP covers cleaning, engine flushing, aircraft
washing, and painting operations. Use of hazardous
materials during aviation maintenance procedures must be
controlled and documented. Semi-annual and annual
compliance certification is also another requirement of
this regulation. Training on Aerospace NESHAP is
required and available by contacting the
DPW Environmental Division’s NESHAP Project Manager,
(254)288-5284
or viewing the presentation at this link
Aerospace NESHAP Requirements.
In 1997, Fort Hood conducted its base-wide asbestos
survey of 2,606 buildings. This survey has been
instrumental in conducting renovation, abatement and
demolition of facilities located at Fort Hood. Asbestos
on Fort Hood is regulated under
40 Code of Federal Regulation (CFR) 61, Subchapter M
and rules of the Texas Department of Health. Maximum
elimination of asbestos shall be implemented whenever
conditions present the opportunity.
These activities will be achieved through:
- normal attrition, replacing the component, and/or end-item with
other materials as part of facilities renovations
- using applicable open-ended contracts and other opportunities as
funding and technology allows.
 Fort
Hood is awaiting promulgation of the new Defense Land
System and Miscellaneous Equipment (DLSME) NESHAP which
will cover all military surface coating operations and
may include facility maintenance and area sources.
The use and recovery of ODCs (Ozone Depleting Chemicals)
on Fort Hood is regulated by the USEPA under
40 Code of Federal Regulation (CFR) 82. All Fort
Hood military, government and contract air conditioning
and refrigeration service personnel including
technicians/mechanics that procure, use, recover,
remove, or recycle refrigerants or halons are required
to follow the procedures outlined in the
Fort Hood ODC Standard Operating Procedure.
Refrigerant recovery/recycle equipment must be
registered with the Environmental Protection Agency. In
order to comply with requirements of Fort Hood's Title V
operating permit please complete the
certification form
and return it to the DPW Environmental Division's air
program by email or (254) 287-2718(fax).
In the event of accidental or unintentional release of
Ozone Depleting Chemicals (ODCs) on Fort Hood, please
immediately contact the Directorate of Public Works,
Environmental Office (DPW-ENV),
Air Program Manager, 287-8714 or 287-6499. The
information requested is provided on the
(right-click the link and select "Save
Target As..")
Accidental or Unintentional Venting Report.
 The
EPA has established a technician certification program
for persons ("technicians") who perform maintenance,
service, repair, or disposal that could be reasonably
expected to release refrigerants into the atmosphere.
The definition of "technician" specifically includes
certain activities as follows:
- Attaching and detaching hoses and gauges to and from the
appliance to measure pressure within the appliance.
- Adding refrigerant to or removing refrigerant from the
appliance.
- Any other activity that violates the integrity of the
refrigerant circuit while there is refrigerant in the appliance.
 If
you meet the definition of a “technician” and need to
obtain certification; there are 5 separate levels
depending on what you do. There are many vendors that
offer certifications. For Motor Vehicle Air
Conditioning, Section 609, one vendor that offers
on-line certification is the
Mobile Air Conditioning Society. For Section 608
Certifications (Types I, II, II and IV (Universal), you
may obtain the
Study Guide then request the certification test by
contacting this office,
DPW-ENV, 287-8755. There are monetary fees
involved in all levels of certification, depending on
the vendor.
Under 40 CFR Part 82, the EPA has established rules for
air conditioning and refrigeration equipment that will
be permanently retired, dismantled or otherwise disposed
of. A certified refrigerant technician must remove all
refrigerant from unserviceable equipment and prepare a
refrigerant removal statement for the equipment. If the
equipment is still serviceable and usable, it can be
turned into DRMO without draining the refrigerant. For
property book items such as window air conditioners and
refrigerators, a work order (DA Form 2407) can be
submitted through DOL
Maintenance Customer Service Office, 287-5640/5338.
Please contact DPW-ENV, 553-1581 if you have any
questions.
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PRIVACY & SECURITY