Clean Air Act & Montreal Protocol: EPA 608 Practice Questions

In what year was the Montreal Protocol, the international treaty to phase out ozone-depleting substances, signed?

The Montreal Protocol was signed in 1987. The 1990 Clean Air Act Amendments added Title VI, which includes Section 608, to carry it out in the United States.

Production and import of CFC refrigerants such as R-12 ended in the United States on which date?

CFC production for use in the US ended on January 1, 1996. CFCs available today come from recovered, recycled or reclaimed stock.

Since January 1, 2020, R-22 can no longer be produced or imported. How can existing R-22 equipment still be serviced?

The 2020 ban stops new production and import, not the use of R-22. Technicians may keep servicing with recovered, recycled, reclaimed or previously produced R-22.

Under the US phaseout schedule, production of all HCFC refrigerants ends in what year?

R-22 production ended in 2020; the remaining HCFCs, such as R-123 for servicing chillers, end in 2030.

What is the current maximum civil penalty EPA may seek for a violation of the Clean Air Act refrigerant rules?

The Clean Air Act set $25,000 per day per violation; with inflation adjustments, 40 CFR 19.4 lists $124,426 per day for penalties assessed on or after January 8, 2025.

Under the Clean Air Act, EPA may pay an award to a person who provides information leading to a penalty for illegal venting. What is the maximum award?

Section 113(f) of the Act allows EPA to award up to $10,000 to a person who furnishes information leading to a criminal conviction or civil penalty.

The venting prohibition was extended from CFCs and HCFCs to non-exempt substitute refrigerants such as HFCs. On what date did the ban on knowingly venting HFCs during service begin?

Knowing release of CFCs and HCFCs was banned on July 1, 1992, and the ban reached substitutes such as HFCs on November 15, 1995. Later rule changes, such as the January 1, 2018 sales restriction, apply on their own dates.

Which of these may be released to the atmosphere during service without violating the venting prohibition?

Nitrogen, carbon dioxide and water are exempt substitutes in any application, so they may be released. R-454B, R-134a and R-123 must be recovered.

What is a de minimis release?

A de minimis release, such as the small amount lost when hoses are disconnected, is not a violation if it happens during good-faith recovery using certified equipment and the required practices.

Which section of the Clean Air Act covers refrigerant management for stationary equipment such as air conditioners and refrigerators?

Section 608 covers stationary refrigeration and air conditioning. Section 609 covers motor vehicle air conditioning (MVAC).

Under the Clean Air Act, CFCs are class I substances. HCFCs such as R-22 and R-123 are classified as what?

Class I covers CFCs, halons and similar high-ODP chemicals; class II covers HCFCs. HFCs and HFOs are substitutes, not ozone-depleting classes.

EPA may require a certified technician to do what at the technician's place of business?

EPA may require a demonstration of recovery or recycling procedures on site. Failing to demonstrate them, or misusing equipment, can lead to revocation or suspension of certification.

A technician recovers R-410A into a cylinder correctly, then later opens the cylinder valve in the shop to empty it. Is this a violation?

Knowingly releasing refrigerant that has already been recovered is a violation. R-410A is a non-exempt substitute, so its zero ODP does not matter.