7. Country Presentations 7. Country Presentations 7.1 Sweden Ms. Maria Ujfalusi, Swedish Environmental Protection Agency SWEDISH ENVIRONMENTAL PROTECTION AGENCY Disposal of ozone-depleting substances Workshop 10 July 2000 Geneva Notes for section II: Sweden’s experience I am very glad to be here and be able to share with you our experience. In my presentation I will talk a little bit about the historical background, basic national legislation, recovery of refrigerants from non-domestic equipment and finally recovery of domestic equipment. Slide - Phase–out dates First I would like to start my presentation by showing you when the Swedish Government took different decision in this area. You will later see the importance of the time factor. As you can see the Government decided quite early to regulate the use of CFC as refrigerants. Historical background In 1988 the government decided to ban the use of CFC refrigerants in new equipment and installations from 1 January 1995. In 1994 it was decided that as from 1 January 1998 to ban to recharge existing equipment with CFC and last step in this work to prohibit CFC as a working medium in existing equipment from 1 January 2000. When regulating CFCs in 1988 the Government mandated the Swedish EPA to issue regulations on measures to reduce emissions of CFC refrigerants. This mandate was later extended to include HCFC and HFC refrigerants. In discussion between the Swedish EPA and the trade association, it was concluded that substantial CFC reductions could be achieved if leakage and other unintentional emissions were reduced through better design of the plant and better maintenance. It could also be achieved by recovery, lower charges through increased use of indirect systems, and use of refrigerants with a lower ODP. The Swedish Refrigeration Foundation, which was founded by following associations; the Swedish Association of Refrigerant Contractors, and the Association of Swedish Refrigeration Wholesalers, agreed to incorporate recommendations to this effect in the Swedish Refrigeration Code, which was under preparation. BLEKHOLMSTERRASSEN 36 SE -106 48 STOCKHOLM 00 PHONE +46-8-698 10 FAX +46-8-20 29 25 Antal Sidor 5 C:\environmentcd 2000\FINAL;S\7.1F -Ujfalusi geneva.doc NATURVÅRDSVERKET 2(5) SWEDISH ENVIRONMENTAL PROTECTION AGENCY It was, however, also concluded that the Refrigeration Code would not be effective if it was not backed up by government regulations. Therefore, the Refrigerants Order, issued by the Swedish EPA, refers to the Swedish Refrigeration Code, which was issued by the Swedish Refrigeration Foundation in co-operation with the SEPA. Slide - The Code of Practice and Refrigerants Order Basic national legislation In close co-operation with the industry, the Swedish EPA in 1989 issued the Refrigerants Order laying down detailed provisions for the handling of all CFC, HCFC and HFC refrigerants. It contains four main elements: 1 Only certified enterprises may install or conduct any service or maintenance requiring interference with a CFC, HCFC and HFC refrigerant circuit or affects its functioning. To achieve a certification, the enterprises must demonstrate that they have: 2 C At least one person in a supervising position with documented competence within the field, who has also passed a short course on the environmental effects of refrigerant emissions, the Refrigerants Order and the Refrigeration Code. C The necessary equipment for recovery, leak testing, etc, and C Adequate organisation and routines, including records of work done. When manufacturing, installing or altering refrigeration, air-conditioning or heat pump equipment, material and design shall be chosen in such a way that a) the risk of leakage is prevented as far as possible b) the maintenance is facilitated c) the refrigerant charge is kept as low as possible d) the refrigerants with the lowest ODP and GWP is chosen, taking into account other potential health and environment effects as well as commercial availability of refrigerants. 3 All equipment shall be well maintained, be subject to regular leak tests and controlled by certified enterprises, at least once a year. Leaks and other identified defects must be repaired before new refrigerant is added. 4 The refrigerants must be recovered or reclaimed for reuse or destruction during service and maintenance, as well as at dismantling and scrapping of any refrigeration plant. In order to facilitate recycling and reclamation, the refrigerant containers must be labelled and different types of refrigerants must be kept separate. 3(5) NATURVÅRDSVERKET SWEDISH ENVIRONMENTAL PROTECTION AGENCY Recovery of refrigerants from non-domestic equipment Slide - The system The Refrigerants Order states that the importers and distributors of stationary and mobile systems are required to receive recovered refrigerants for recycling, reclamation and destruction supplied by them. The importer or distributor of the refrigerants must also make gas bottles available for used refrigerants. No charges may be levied for reclaimed amounts. The costs of the system are covered by a fee included in the sales prices for every sold kg of refrigerant CFC, HCFC and HFC. The system started already in 1989 and is run completely independently from government agencies by the companies involved. Slide – Enforcement One chapter in the Environmental Code deals with environmental sanction charges. The government has by an Ordinance compiled a list of various violations with information on the charge for each violation. The charge may be 5,000 kronor at least and 1,000,000 kronor at most. Some of these charges concern ODS (see slide). The supervising authorities can levy these fees themselves without requiring proof of intent or negligence. Some of the local authorities have already made use of this possibility. Information To adapt to the requirements all parties must know what the programme means and understand why, when and how to be able to act correctly as the phase-out programme effects almost every sector in the society. Over the years we have issued information folders to refrigeration association, local and regional authorities, targeted organisations and other authorities. Issued newsletters, a handbook, arranged workshops and seminars, for the local authorities on yearly basis, articles to professional and technical journals. We issued information kits free of charge to the local authorities in order to support them in their work with information to owners/users of refrigeration systems. Further more one of the information folder was translated into English, Turkish, Arabic, SerboCroatian. Now I would like to say a few words about Recycling of refrigerators/freezers and recovery of CFC In our Ordinance (1998:902) on Waste Collection and Disposal requires that all scrapped refrigerators and freezers shall be disposed of, through the local authorities. This means that the local authority has the total responsibility of collecting, storing, transporting and recycling the discarded refrigerators and freezers. The ordinance also state that such waste must be transported separate from other waste to ensure that it can be taken care of separately. The refrigerators and freezers are transported to special NATURVÅRDSVERKET 4(5) SWEDISH ENVIRONMENTAL PROTECTION AGENCY destruction facilities where CFCs and HCFCs is recovered from the foam and refrigeration circuit. In 1997 we had 9 companies which dealt with recycling and recovery, but only 3 of them have the capacity to recover CFCs both from the cooling circuit and the polyurethane insulation. Two of these companies are stationary plants and one is a mobile facility. The Swedish EPA has issued guidelines for the required effectiveness of CFCs at the destruction facilities. Slide – Recycling requirements for domestic refrigerators All facilities have operating permits granted by the regional environmental authority. Reports and inspections, control compliance with requirements. How is this then organised? Sweden has 284 local authorities, one in each municipality, having a contract with one of the recycling companies. Depending on which company they hire, the collection, storing and the transport differs from one municipality to another one. The model with a stationary facility Slide – Stena Bilfragmentering – a stationary plant The municipality does the collection from households and servicing companies, or contracts a special company to do the work for them. Some of the equipment is delivered from building sites. The equipment must be handled with care and kept in an upright position. If two persons collect approx. 40 units/load then they can make 1.5 loads per day. Then the equipment is stored at the recovery station in covered containers, 6 x 2,5 x 2,5 m, which the company provides. Each container holds approx. 60 units. Finally the equipment is transported to the recycling company. A truck takes three containers. For a recycling station handling 500 units a month, three shipments a month is required. And this is how the system works with a mobile facility. Slide – SKAFAB/Stena Gotthard - a mobile system The costs of the recovery system are covered by a fee as part of the charges for the household waste collection system (some SEK 10 per household). Some municipalities levy this fee as an increment on the general waste fee, others only charge it when fetching old equipment. In Sweden the total available number discarded refrigerators are estimated to 300.000 units/year. NATURVÅRDSVERKET 5(5) SWEDISH ENVIRONMENTAL PROTECTION AGENCY (Average refrigerator/freezer contains about 100 g CFC 12 in the cooling circuit 350 g CFC 11 in the polyurethane insulation. 450 g CFC x 300.000 = 135 tonnes CFC) Conclusion and lessons learned In conclusion I would like to say that we have found that it is not enough to control the supply side, but it is equally important to control the demand side. In the phase-out work of ozone depleting substances we have focused on end-use control. Important elements in this work has been: C Collaboration within industry and between industry and government authorities. C Acceptance by all parties. C Early decisions – giving the stakeholders time to adapt and C Information, information and more information. I THANK YOU FOR YOUR ATTENTION ! Literature/References Ordinance (1995:636) on Substances which Deplete the Ozone Layer Refrigerants Order (SNFS 1992:16, Köldmediekungörelsen), issued by the SEPA, Ordinance (1998:902) on Waste Collection and Disposal The Environmental Code (Miljöbalken) Publications: Kökeritz, Ingrid 1997: Government Strategies to Phase Out Ozone-Depleting Refrigerants. Four Case studies from the Nordic Countries. UNEP IE and SEI Oberthür, Sebastian and Pfahl, Stefanie 1999: The Implementation of the Montreal Protocol on Substances that Deplete the Ozone Layer in the European Union. Case study: Sweden. PRESENTATION Maria Ujfalusi Section for Chemicals Control Tel +468 - 698 11 40 Fax +468 - 698 1222 [email protected] CFC ban in Sweden n n n 1 January 1995 use of CFC refrigerants in new equipment and installations 1 January 1998 for re-filling existing facilities for refrigeration, airconditioning and heat pumps 1 January 2000 as working medium in existing facilities. Disposal of ozonedepleting substances n n n n n Historical background Basic national legislation Recovery of refrigerants from non-domestic equipment Recovery of refrigerants from domestic equipment Conclusion Refrigerants Order n n n n n n Only certified enterprises may install or conduct any service or maintenance Material and design shall be chosen in such a way that: - leakage is prevented - maintenance is facilitated - refrigerant charge low - refrigerants with smallest effect, ODP and GWP The Refrigerants Order n n Regular leak tests, at least once a year Refrigerants must be recovered, reclaimed or destructed R 12 Plant owner R134 Free of charge Certified Service Company Swedish Waste Conversion Ltd. Importers/ wholesalers New Refr SEK 30:Producers abroad Exemption from the CFC end-use ban n Stationary, unitary equipment containing 900 gr or less CFC should be exempted from the end-use ban till 31 December 2004. Recycling level of CFC n n n n 80 % of the CFC 11 must be recovered 95 % of the CFC 12 must be recovered 95 % of the compressor oil must be recovered The concentration of CFC in PUR powder, may be maximum 0.5 % 7. Country Presentations 7.2 Japan Dr. Koichi Mizuno, National Institute for Resources and Environment, Japan Experiences of ODS Disposal in Japan Koichi Mizuno National Institute for Resources and Environment 1. Program of CFC Disposal The recovery of CFCs in Japan is planned on the premise that they are not recycled for reuse but are destroyed to further reduce the emissions, since the old equipment using CFCs is retired earlier, therefore recycling is economically less feasible. In April 1997, the Ministry of International Trade and Industry of Japan issued the “Promotional Program of CFCs Recovery,” to encourage the recovery systems created by private sector. In principle, the program suggested the manufacturers of the equipment to cover the expenses for establishing the recovery system, while users of the equipment to cover the running costs of the system. In response to the program, the industrial sector issued the action plans of CFC recovery in September 1997, which involve mobile air-conditioners, commercial air-conditioners, household refrigerators, and CFC manufacturing. The action plans indicated the industries related to mobile air-conditioners, commercial air-conditioners, and household refrigerators to establish the CFC recovery system, while the industries related to CFC manufacturing to destroy the recovered CFCs. In September 1997, the government issued the policy guidance for further promotion of the recovery and destruction of CFCs, after the liaison meeting of 18 related ministries and agencies. The Government of Japan reviews the reports from the private sector, and the local governments support the local associations for CFC recovery. 2. Activities of CFC Disposal Mobile Air-conditioners The Japan Automobile Manufacturers Association (JAMA) started a CFC recovery and destruction system in January 1998, which expanded to a nationwide scale in October 1998. Almost 3,000 automobile dealers were registered by July 1999. Beside this, local governments and the used car dismantling firms also established the recovery and destruction systems. As the result of such efforts, 140 tonnes of CFC-12 were recovered for destruction in the period from April 1998 to March 1999. Commercial Air-conditioners The CFC recovery, recycling, and destruction system was formed by the Japan Refrigeration and Air Conditioning Industry and the Japan Association of Refrigeration and Airconditioning Contractors. The Refrigerant Recycling Promotion and Technology Center has implemented the training for technicians and certifying for recovery firms. Currently 2,237 companies have been certified as the recovery firms and 9,115 technicians have also been certified. A total of 665 tonnes of CFCs was recovered from April 1998 to March 1999. Household Refrigerators Until now, the recovery and destruction have been carried out by the local governments and the household appliance sales outlets. Under the “Law for Recycling of Specified Kinds Consumer Electric Goods”, which is scheduled to come into effect in April 2001, the manufacturers need to formulate the recycling systems and to conduct the recovery of CFCs as a part of the recycling of their products. A total of 85 tonnes of CFC-12 was recovered from April 1998 to March 1999. Destruction of CFCs Based on the survey of the destruction facilities, a total of 556.5 tonnes of CFCs was destroyed in 1998. The amount destroyed is smaller than that recovered (see Table 1) because of the time lag of delivery of the recovered CFCs to the destruction sites. CFCs are being destroyed in approximately 30 facilities dispersed in Japan, in which various technologies including submerged combustion, gaseous/fume oxidation (high-temperature steam decomposition), rotary kiln, r.f. plasma, and so forth are used. Table 1. Recovery and Destruction of CFCs / tonnes. Mobile Air-conditioners Commercial Air-conditioners Household Refrigerators Destruction Recovery or Destruction 140 (recovered) 690 (recovered) 85 (recovered) 556.5 (destroyed) HCFCs contained in commercial air-conditioners are being recovered by using the existing CFC recovery system, and those recovered are recycled for reuse or destroyed. HCFCs contained in household air-conditioners will be recovered by the system to be formed under the “Law for Recycling of Specified Kinds Consumer Electric Goods.” 3. Implication of CFC Disposal on Global Climatic Changes Since the alternative substances of HFCs are the greenhouse gases, the recovery and destruction of HFCs is a probable way for the prevention of global warming. The disposal systems currently being established for CFCs and HCFCs are applicable to HFCs in the near future. Once the systems are established, therefore, they may reduce the investment costs for HFC disposal. The cost-effective systems for recovery and destruction of CFCs, HCFCs, and HFCs require the following items in the long run: • Formation of cost-effective recovery systems • Improvement of recovery machines applicable to CFCs, HCFCs, and HFCs. • Selection of low-cost destruction technologies 4. Halons In Japan, a total of 17,337 tonnes of halons were banked in fire extinguishing equipment on March 31, 2000. Most of the halons is halon-1301, amounting to 16,892 tonnes, and approximately 98% is banked in the fixed fire extinguishing systems (see Table 2). Halons are managed by the Halon Recycling and Banking Support Committee, Japan. By the year 1997, the delivery amount exceeded that from recovery, however, such trend was reversed in recent years. Nevertheless, the excess is a few tens tonnes per year. Presently, the government is setting the management strategy for the disposal. The destruction of halons seems technically more difficult because of their inflammability, however, the recovery is expected to be easier. The destruction facility of an r.f. plasma reactor was scheduled to be constructed by the end of the fiscal year of 2000. Table 2. Banked Halons in Japan Equipment Fixed Fire Extinguishing Systems Portable Fire Extinguishers Halon Halon-1211 Halon-1301 Halon-2402 Sub-total Halon-1211 Halon-1301 Halon-2402 Sub-total Total Number of Containers 700 323,900 3,000 327,600 8,200 75,000 2,100 85,300 412,900 March 31, 2000 Banked Halons / tonnes 32 16,721 372 17,125 37 171 4 212 17,337 Experiences of ODS Disposal in Japan Koichi Mizuno National Institute for Resources and Environment Agency of Industrial Science and Technology Ministry of International Trade and Industry April 1997: “the Promotional Program of CFCs Recovery” the Ministry of International Trade and Industry of Japan ! Private sector shall create the recovery systems on voluntary basis. ! The manufacturers of the equipment shall cover the expenses for establishing the recovery system. ! The government shall make the review system, in which they review the reports from the industries, publish the data, and suggest for the improvement. ! Users of the equipment shall cover the running costs for the system. September 1997: “the Action Plans of CFC Recovery” Industries of mobile air-conditioners, commercial air-conditioners, household refrigerators, and CFC manufacturing. ! The industries of mobile air-conditioners, commercial air-conditioners, and household refrigerators shall establish the CFC recovery system. ! The industries of CFC production shall destroy the recovered CFCs. September 1997: “the Policy Guidance” the liaison meeting of 18 related ministries and agencies. ! CFCs in mobile air-conditioners, commercial air-conditioners, and household refrigerators shall be recovered on voluntary basis. ! Related ministries and agencies shall request related organization for CFC recovery. ! The Environment Agency shall support the activities of the local associations of CFC recovery through the model projects. ! The guidelines of destruction of CFCs from refrigerators shall be issued. CFCs in Japan are not recycled for reuse, but are destroyed to further reduce the emissions. Estimate of CFC-12A/C and HFC-134a A/C Estimated Percentage of Refrigerants in Commercial Refrigerators in Japan (Centrifugal Refrigerators) 100% 100% 80% 80% HFC-134a A/C 60% 40% 40% CFC-12A/C HCFCs CFCs 60% 20% HFCs 20% Year 10 20 05 20 00 20 19 00 20 99 19 98 19 97 96 19 95 19 19 Year 95 0% 0% Mobile Air-conditioners " CFC Recovery and Destruction System ! the Japan Automobile Manufacturers Association (JAMA) January 1998: started October 1998: expanded to a nationwide scale July 1999: almost 3,000 automobile dealers registered ! local governments and the used car dismantling firms " Education ! poster 12,500, leaflet 960,000, Q&A handbook 278,000 " Amount Recovered: 140 tonnes of CFC-12 (April 1998 - March 1999) Commercial Air-conditioners " CFC Recovery, Recycling, and Destruction System ! The Japan Refrigeration and Air Conditioning Industry (JRAI) and the Japan Association of Refrigeration and Air-conditioning Contractors (JARAC) " Training and Certification ! The Refrigerant Recycling Promotion and Technology Center operated by JRAI, JARAC, and the Japan Fluorocarbon Manufacturers Association ! 2,237 companies certified as the recovery firms ! 9,115 technicians certified. " Amount Recovered: 665 tonnes of CFCs (April 1998 - March 1999. Household Refrigerators " Recovery System ! present: the local governments and the household appliance sales outlets ! from April 2001: the manufacturers formulate the recycling systems and conduct the recovery of CFCs as a part of the recycling of their products by the “Law for Recycling of Specified Kinds Consumer Electric Goods” " Amount Recovered: 85 tonnes of CFC-12 (April 1998 - March 1999) Summary of Recovery and Destruction of CFCs Table 1. Recovery and Destruction of CFCs / tonnes. Recovery or Destruction Mobile Air-conditioners 140 (recovered) Commercial Air-conditioners 665 (recovered) Household Refrigerators 85 (recovered) Destruction 556.5 (destroyed) April 1998 – March 1999 Implications of CFC Disposal on Global Climatic Changes " The Recovery and Destruction of HFCs is a probable way for the prevention of Global Warming. " The disposal systems currently being established for CFCs and HCFCs are applicable to HFCs in the near future. " Once the systems are established, they may reduce the investment costs for HFC disposal. " Cost-effective Systems for Recovery and Destruction of CFCs, HCFCs, and HFCs require: ! Formation of cost-effective recovery systems ! Improvement of recovery machines applicable to CFCs, HCFCs, and HFCs. ! Selection of low-cost destruction technologies Costs for CFC Recovery and Destruction Conducted by JAMA for Automotive AC Used cars Customers (End Users) Transfer to 20Recovery into 1-L containers 1-L containers kg containers Automotive AC Service Stations Recovery Sites Payment Used cars Customers (End Users) Payment (transfer + transportation + destruction) Payment (destruction) Large containers Recovery Sites Payment 20-kg containers CFC Destruction Plants Recovery into Payment large containers (transportation + destruction) CFC Recovery from Automotive AC Customers (End Users) Used cars Automotive Dealers Used Car Dealers Automotive Maintenance Service etc. Automotive Dismantling Firms Waste CFCs CFC Recovery & Destruction Systems by JAMA (Japan Automobile Manufacturers Association) Local Government Bodies Automobile Dismantling Firms CFC Recovery from Commercial Refrigeration and AC Equipment End Users (Firms) Used equipment Refrigeration and AC Equipment Manufacturers Refrigeration and AC Equipment Contractors Dismantling Construction Firms Private Disposal Firms Waste CFCs Refrigerant Recovery Firms Certified by Refrigerant Recycling Promotion and Technology Center CFC Recovery and Destruction by Local Government Bodies Destruction / Reclamation Plants Current CFC Recovery from Household Refrigerators Customers (End Users) Used appliances Appliance Retailers Municipal Offices Waste CFCs Private Disposal Firms Destruction Plants Future CFC Recovery from Household Refrigerators the Household Appliance Recycling Law, effective on April, 2001 Customers (End Users) Used appliances Municipal Offices Appliance Retailers Appliance Manufacturers’ ’ Recycling Plants Municipal Offices’ ’ Recycling Plants Independent Bodies Recycling Plants Waste CFCs Destruction Plants Table 2. Banked Halons in Japan March 31, 2000 Equipment Halon Number of Banked Halons / Container tonnes Fixed Fire Halon-1211 700 32 Extinguishing Halon-1301 323,900 16,721 Systems Halon-2402 3,000 372 327,600 17,125 Sub-total Portable Fire Halon-1211 8,200 37 Extinguishers Halon-1301 75,000 171 Halon-2402 2,100 4 85,300 212 412,900 17,337 Sub-total Total 7. Country Presentations 7.3 Australia Ms. Tamara Curll, Environment Australia International ODS Disposal Workshop Country Experience - Tamara Curll (Environment Australia) INTRO Slide 2 The objective of my presentation is to share Australia’s experience which suggests that access to state-of-the-art technology is only one of many important elements in effective, responsible ODS management and disposal. The outcome I seek is that one or many of policy and technological options I describe are subsequently incorporated into your own country’s ODS management strategies, providing effective solutions to your ODS disposal challenges. PRESENTATION OUTLINE Slide 3 Consequently, my presentation will cover: 1. Australia’s approach to managing its ODS stocks, focusing on the management of halons and CFCs; 2. The extent to which disposal of ODS has been part of this management strategy; 3. The measures employed in the management of ODS disposal, including the technologies used; 4. The lessons learnt from Australia’s experience in implementing its ODS disposal program, including key issues which countries may wish to bear in mind in developing and implementing their own. ODS MANAGEMENT IN AUSTRALIA Slide 4 Environment protection measures in Australia are coordinated by the Australian and New Zealand Environment and Conservation Council (ANZECC), comprising environment Ministers from the Australian national, State and Territory and NZ governments. Australia’s ODS management strategy was developed in 1989 and subsequently revised in 1994 by two ANZECC bodies: the Ozone Protection Working Group (OPWG), comprising relevant Cth, State and Territory government representatives; and the Ozone Protection Consultative Committee (OPCC), comprising government, industry, community and conservation groups. The recommendations of the strategies reflect a cooperative attempt by these key stakeholders to achieve a comprehensive and consistent national approach to ODS management in Australia which has been realised to a large extent by the complementary measures implemented by government and industry. The Commonwealth Government (Environment Australia) controls the import, export and manufacture of bulk ODS through transferable licence and quota systems and the import and manufacture of products containing specific ODS, including CFCs and halon. EA also owns Australia’s National Halon Bank which has safely stored, reclaimed and destroyed ODS. State and Territory Government control the sale, use, handling and distribution of ODS, through: licensing ODS transactions; mandatory training and accreditation of ODS equipment service personnel; mandatory recovery and return of ODS; and, mandatory decommissioning of portable and fixed halon systems, unless granted exemption on essential use grounds. As members of the National Halon Essential Uses Panel (NHEUP) industry and conservation organisation representatives advise the government as to whether proposed and ongoing halon applications justify exemption as an essential use. The Panel’s recommendations are based on criteria similar to that used in the Protocol’s essential use nomination procedure. Industry is also responsible for ODS management initiatives including: Refrigerant Reclaim Australia, a program for the responsible recovery, reclamation and destruction of ozone depleting refrigerants; and, codes of practice covering every ODS application sector. Australia has found this mix of government regulation and industry self-regulation extremely effective in managing its ODS stocks. Underpinning this mix of measures has been the ongoing education of the public and affected industries. Awareness raising has been the joint responsibility of governments, industry and public interest groups. ROLE OF ODS DISPOSAL IN AUSTRALIA'S ODS MANAGEMENT STRATEGIES Slide 5 ODS disposal has always been considered a necessary element of Australia’s ODS management. Australia has always defined ODS disposal to include storage. Measures for ODS storage were incorporated into Australia’s ODS management program in 1993 with the National Halon Bank’s (NHB) establishment. The NHB was the Commonwealth government’s response to a rapidly accumulating stockpile of halon within government, industry and the community. The accumulation was the result of compliance with State and Territory regulations, requiring the mandatory decommissioning of non-essential halon systems by 1995, and the mandatory recovery of all ODS from any decommissioned equipment. In the same year, Australian industry established Refrigerant Reclaim Australia (RRA), to manage the collection, recovery, reclamation and storage of ozone depleting refrigerants (ODR). Some sectors, including the fire protection, aviation, shipping and defence, chose to establish their own storage facilities. ODS disposal measures, in the stricter sense of destruction, were introduced in late 1996 with the installation of SRL Plasma's argon plasma arc technology at the NHB. Slide 6 Why Destroy? Australia’s decision to destroy ODS has been largely influenced by environmental and economic factors. Environmental 1. Stored halon represents an ongoing threat to the ozone layer through accidental emission and leakage, regardless of rigorous efforts to maintain a controlled storage environment. 2. An inventory of Australia’s halon stock in 1998 confirmed expectations it exceeded Australia's projected essential use needs to 2030. Added to this, Australia was cognisant of the fact that global stocks of 1211 provided a more than adequate supply for essential use applications. 3. Australia had at its disposal, the expertise and technology to remove the environmental threat posed by an excess of domestic and overseas ODS stocks. Economic 1. The more than adequate global stock of halon 1211 meant Australia's long term storage of halon 1211 in excess of its projected essential use needs only added to the ultimate disposal cost. 2. Economic analysis that indicated if the NHB was required to relocate, the expense of destroying existing and estimated future collections was more economical than the provision of new storage capacity and the relocation of the stock to the new site. 3. Sample analysis which indicated some halon and CFC stock will be contaminated to a degree which prevents its effective recycling or reclamation, rendering its continued storage not cost-effective. ODS DISPOSAL Slide 7 The National Halon Bank is Australia’s major ODS disposal management facility. Its organisational structure is represented in this diagram. Environment Australia (EA) owns the NHB and contracts DASCEM Holdings Pty Ltd to manage the NHB’s activities. This involves managing: 1. arrangements for the collection, transportation, decanting, purification, safe storage and destruction of halon and ODR; 2. The design and implementation of public awareness campaigns and operation of community, small business and dumped halon collection activities (Community Service Obligation (CSO)); and 3. The sale of halon to approved users in Australia and overseas. Australia’s ODS disposal program can be broken down into the following elements: 1. Collection and transportation: DAS Distribution is responsible for the collection and transportation to the NHB of ODS deposited at collection points. Established in 1993, the network of collection points uses metropolitan, rural and remote fire stations, fire equipment suppliers and DAS Distribution depots throughout Australia. Halon deposited by the general public and small business (< 20 employees) is free of charge. All other business and Commonwealth, State and local governments currently pay US$11.40/kg of halon 1211 and US$14.40/kg of halon 1301 deposited at the collection points. 2. Public awareness/education: DASCEM launched the CSO’s public awareness/education campaigns in 1995. The campaigns’ aim was to inform halon system owners of their legal obligations to decommission their equipment, and to provide them with information on the procedure for depositing their halon with the NHB. The campaigns initially focussed on the environmental damage halon causes to the ozone layer. Recently, the campaign’s message has begun to emphasise the safety concerns associated with relying upon old, poorly maintained halon fire protection systems. 3. Recovery and reclamation: REMTEC employs a combination of specially developed cylinder piercing technology (CPT) and purpose-built Defender Units to recover halon from the collected cylinders. REMTEC is currently undertaking the world’s largest decanting and processing project, anticipated to involve in excess of 1600MT of halon, including 550MT of 1301). Commenced in late 1998, the project’s expected completion date is December 2002 . 4. Destruction: ODS destruction has been carried out at the NHB by SRL Plasma using their ‘PLASCON’ argon plasma arc destruction technology, which was developed in cooperation with the Australian Government’s Commonwealth Scientific and Industrial Research Organisation (CSIRO). As Garry noted earlier in his presentation, to date, the technology has destroyed 1000MT of halon 1211 and 70MT of CFCs at the NHB. As stated earlier, the industry-run initiative Refrigerant Reclaim Australia (RRA) plays a major role in the disposal of ODR. The program is funded by a voluntary levy of US$0.6/kg on importers. Under the Program, contractors recover contaminated and unwanted refrigerant from equipment into refillable cylinders supplied by their wholesaler. Full cylinders are returned to the wholesaler by the contractor, who receives in return a credit of US$1.50/kg, regardless of the ODR’s purity. To date, the program has recovered and collected 440MT of ODR, 110MT of which has been reclaimed to new specification while a further 120MT has been destroyed. DAS Distribution provides collection and transportation services to RRA, collecting the recovered ODR from wholesalers and transporting it to the NHB where it is analysed to determine whether it will be reclaimed or destroyed. LESSONS LEARNT/KEY CONSIDERATIONS Slide 8 There has been a lot of information in this presentation. If, however, Australia was to identify what it believed were the key contributors to the effectiveness of its ODS disposal program, they would be the following: 1. Threshold questions Australia believes it is important that ODS disposal programs are developed to reinforce the overall integrity of a country’s ODS management strategies. Decisions as to the nature and extent of the program, and how it operates within the established ODS management measures, should therefore be informed by the following threshold questions: How much (if any) ODS should be reserved? For how long should it be reserved? Who should pay for the storage costs? What should be done with ‘surpluses’? Destruction, long term storage, export for essential uses? In Australia’s case, its ODS disposal program complements measures under the ODS management strategy to remove non-essential halon systems and simultaneously ensure the ready availability of adequate reserves to meet the essential use requirements of identified users. For this reason, it is critical that countries look closely at developing halon and CFC management strategies as proposed in decisions X/7 and XI/16. 2. Ownership of solutions Providing key affected stakeholders with a sense of ownership of the chosen approach to ODS disposal contributes greatly to its effective implementation. Australia has found that, if key stakeholders are given the opportunity to participate in the development and implementation of the ODS disposal program, it is more likely to be sustainable as it will: recognise the technical, commercial and regulatory constraints underwhich the stakeholders operate and also gives the stakeholders a vested interest in ensuring a project with which they are associated is a success. 3. National information, education and training The value of early and consistent communication in facilitating the required changes in commercial operations and consumer behaviour can not be overestimated. This is obviously particularly important where mandatory halon decommissioning measures are to be used, given the planning and investment lead time that maybe necessary to ensure safety is not compromised. All actors in the product chain, from the ODS importer to the accredited service technician who decommissions the ODS equipment, must be co-opted to ensure information on the program’s objectives and measures flows through the whole of the industry and the community. 4. Leadership & funding Although Australia strongly advocates a cooperative approach to the process of developing and implementing ODS disposal programs, leadership is obviously necessary to initiate the process, monitor its progress and ensure its objectives are achieved. Australia believes this role falls naturally to the country’s government for the following reasons: a) As the signatory to the Montreal Protocol, the government has a vested interest in ensuring compliance with Protocol obligations. Its participation in Protocol fora also gives it ready access to the environmental, economic, technical and scientific information required to: educate stakeholders; and, inform the program’s developmental, implementation and review phases; b) its leadership lends credibility to the efforts of those charged with the disposal program’s development, implementation, monitoring and enforcement; c) it may have the opportunity to lead by example. The Australian government was the major owner of halon installations prior to the introduction of the mandatory decommissioning legislation, therefore by complying with the ODS disposal measures, the government not only demonstrated its commitment to the objective of eliminating ODS, but also the economic and technical feasibility of compliance. Adequate funding of any ODS disposal program is essential to its effectiveness and sustainability. As noted earlier, two approaches have been adopted in Australia. Firstly, up until now, all costs associated with the ongoing decanting, purification, destruction and storage of halon have been borne by the Commonwealth and offset by halon deposit fees. An arrangement whereby essential users bear the costs associated with the decanting, purification and storage of their halon requirements held at the NHB is now being considered. 5. Regulatory/financial incentives and disincentives Australia’s experience suggests that at least some form of regulatory catalyst is required to achieve significant ODS disposal. In regard to Australia’s halon disposal program: despite the fact that all key stakeholders agreed to the original recommendation in Australia’s 1989 Strategy that all non-essential 1211 extinguishers should be replaced by December 1995, decommissioning was minimal until, in response to a subsequent recommendation of the 1994 Revised Strategy, the State and Territory governments legislated mandatory decommissioning of all non-essential halon systems. The financial incentive provided in the form of a rebate to ODR service personnel through the RRA program has proven particularly effective in ensuring the return, rather than release to atmosphere of ODR which no longer holds a commercial value - namely, ODR which is beyond reclamation or for which supply exceeds demand. While RRA is an excellent example of industry environmental stewardship and the effectiveness of financial incentives. The industry concedes that this innovative approach would not have developed without the incentive provided by the regulations requiring ODR be recovered and returned to wholesalers. Consequently, Australia’s experience has been that the early establishment of cooperative partnerships with affected stakeholders, particularly industry, not only encourages the development of innovative, cost-effective measures for responsibly managing ODS and its disposal, but also, facilitates the implementation and ongoing effectiveness of the approach adopted. CONCLUSION - HOW CAN WE HELP? Slide 9 I have greatly appreciated the opportunity to share Australia’s experience in the development and implementation of policy and technological options for ODS disposal. Australia, does not however, want to limit itself to purely providing information. In closing, I want to remind you of Australia’s achievements in ODS disposal to date: 1. We have developed and implemented ODS management and disposal initiatives without significant technical and economic disruption; 2. We are owners and managers of the second largest halon depositary in the world, which is progressing the largest decanting, purification and storage program, utilising state-of-the-art technologies; 3. We have developed and commercially operated an ODS destruction technology, namely SRL Plasma's argon plasma arc, which has been independently assessed as the best environmental and technical option for ODS disposal. Our hope is that you will accept our invitation to explore options for sharing this policy and technological experience with your country in the future. Tamara Curll Assistant Director Ozone Protection Environment Australia Tel: +612 6274 1701 Fax: +612 6274 1172 Email: [email protected] ODS Disposal Workshop Country Experiences: AUSTRALIA Tamara Curll ENVIRONMENT AUSTRALIA OBJECTIVE OUTCOME PRESENTATION OUTLINE FAustralia’s ODS management strategy FThe role of ODS disposal FODS disposal management/measures FLessons learnt and key considerations ODS Management in Australia FORMAL CONSULTATIVE FORA ANZECC OPCC/OPWG ENVIRONMENT AUSTRALIA Import,export,manufacture National Halon Bank Awareness raising STATE GOVERNMENT Sale, use, handling Mandatory decommissioning Awareness raising National Halon Essential Uses Panel NON-GOVERNMENT RRA Codes of Practice Awareness raising The Role of ODS Disposal 1993: storage measures introduced • National Halon Bank • RRA • Industry-specific storage 1996: destruction measures introduced • SRL Plasma argon plasma arc plant The Role of ODS Disposal cont. WHY DESTROY? Environmental factors Economic factors ODS Disposal: Measures Environment Australia Refrigerant Reclaim Australia DASCEM (NHB Operator) REMTEC (Decanting/Purifying) DAS Distribution (Collecting/Transporting) SRL Plasma (Destruction) Lessons Learnt & Key Considerations Hthreshold Hleadership/ questions funding Hownership of Hregulatory/ solutions financial Hnational education, incentives & disincentives information and training What can we offer? HAssistance in the development of ODS management strategies; HReclamation, recycling and reuse of ODS; HDestruction of excess and contaminated ODS; HProvision of halon to meet national critical use needs. THANK YOU 7. Country Presentations 7.4 Canada Mr. Alex Cavadias, Environment Canada Canada’s Proposed Strategy to Accelerate the PhaseOut of Uses of CFCs and Halons and Dispose of the Surplus Stocks Since 1990, Canada has been managing halons through a number of initiatives and control measures. These initiatives have included control measures on the import, export, use and recovery of halons. In 1998 the Federal Provincial Working Group (FPWG) started developing Canada’s Strategy to Accelerate the Phase-Out of CFCs and Halons Uses and to Dispose of the Surplus Stocks. The Strategy, in part, is being developed to achieve an orderly and affordable phase-out of remaining halon uses in Canada. This strategy reflects the current measures that are in place and also has proposed initiatives that are being considered. The objective of the Strategy is to minimize and avoid the ultimate release to the environment of CFCs and halons. The strategy will accomplish this by accelerating the use of alternatives and rendering the remaining surplus stocks harmless. Introduction Canada’s Strategy to Accelerate the Phase-Out of CFCs and Halons Uses and to Dispose of the Surplus Stocks is part of the ongoing process of fulfilling Canada’s commitment to protect the earth’s ozone layer. Development of the Strategy came about as a result of a comprehensive review, started in 1994, of the Canadian ozone layer protection program. That review helped to point out that unless new initiatives are put in place to take CFCs and halons out of service and dispose of them, most of the Canadian inventory of these substances will ultimately be released to the environment. Extensive consultations with stakeholders have been a key part of the development of this strategy. Consultation sessions focusing on the proposed strategy were held during February 2000 in Vancouver, Winnipeg, Halifax, Montreal and Toronto. In all, over 200 people participated in these sessions. Reports summarizing the consultations and the responses of the FPWG to the recommendations from the consultations are available under separate cover. Action to accelerate the phase-out of uses of CFCs and halons is also being taken under the Montreal Protocol. At the 10th Meeting of the Parties to the Montreal Protocol, the Parties adopted Decision X/7, which requested all parties to develop national and regional strategies for the management of halons, including emissions reduction and ultimate elimination of their use. A similar Decision was made at the 11th Meeting of the Parties regarding the use of CFCs. Industrialized countries are to submit their strategies by July 2000 and July 2001 respectively. Jurisdictional Background in Canada In Canada, regulatory responsibility for ozone layer protection is shared by the federal and provincial governments. The federal government is responsible for implementing controls needed to meet Canada’s obligations under the Montreal Protocol, and for regulating federal facilities, which are not covered by provincial regulations. The provincial governments control the use, recovery, recycling and release of ozone-depleting substances. The Federal-Provincial Working Group was established in 1989 by the Canadian Council of Ministers of the Environment (CCME). The goal of the Working Group was to establish a coordinated national strategy for the management of ODS, including harmonization of controls for CFCs and halons in Canada. Over the years, the Group’s mandate has remained essentially unchanged, although its scope has broadened to keep in concert with changes to the Montreal Protocol and other environmental issues. The Working Group reports to the National Air Issues Coordinating Committee of the CCME. Conclusion The Proposed Strategy will meet our national objective and our international commitments. It will achieve an orderly and affordable phase-out of remaining CFC and halon uses in Canada and will minimize and avoid their ultimate release to the environment. The Strategy will accomplish this by accelerating the use of alternatives and rendering surplus stocks of CFCs and halons harmless. Halons will be restricted to essential uses, i.e., aircraft and certain military applications. Canada will also encourage safe recovery, storage and destruction of surplus CFCs and halons and also the use of alternatives. The Strategy plays a vital role in Canada’s National Ozone Layer Protection Program and in meeting Canada’s international obligations. In addition, the Strategy will be reviewed regularly to reflect international, technological and environmental developments. Canada’s Proposed Strategy to Accelerate the Phase Out of Uses of CFCs and Halons and Dispose of the Surplus Stocks July 10 - 2000 Geneva Environment Canada Environnement Canada Presentation Summary l l l l l Introduction/Background Objective Inventory Content of the Proposed Strategy Next Steps Environment Canada Environnement Canada Introduction/Background l Montreal Protocol Ø Reduction and Phase-Out of Consumption Ø Requirement for CFC and Halon Mgt. Strategy l l Shared Responsibility, Federal and Provincial Canada’s National Action Plan Ø Federal Provincial Working Group Ø Reduce demand/minimize emissions Ø Anticipate Surplus Ø Develop national strategy for managing surplus Environment Canada Environnement Canada Current Situation l l l l l l Mandatory R/R/R No venting Mandatory Training of A/C Technicians Banned refill and uses for certain applications Mandatory recovery from equipment before disposal Anticipate a surplus of CFCs and Halons Environment Canada Environnement Canada Objective The Federal Provincial Working Group (FPWG) has arrived at the following objective: l To minimize and avoid the ultimate release to the environment of Canada’s stock of CFCs and Halons by accelerating the use of alternatives and rendering the remaining stocks harmless Environment Canada Environnement Canada Options/Management Tools A study was carried out that identified and reviewed four strategic options for managing surplus ODS: Ø status quo Ø restrict import / exports of reclaimed material Ø limit recharging of equipment categories Ø limit use in equipment categories All have various pros and cons and cost implications Environment Canada Environnement Canada CFC Material Inventory 1998 Commercial 26% Mobile AC 34% Mobile Refrig 7% Chillers 9% Appliances / Residential 24% Total Available = 22 863 Tonnes Environment Canada Environnement Canada Figure based on Predictive Model Report - February 24, 1999 Halon Inventory 1998 1211 45% 1301 55% Total Available: 3 130 Tonnes Environment Canada Environnement Canada CFC Inventory Forecast Total Available CFC 25000 15000 10000 5000 Environment Canada Environnement Canada Figure based on Predictive Model Report 2020 2019 2018 2017 2016 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 2005 2004 2003 2002 2001 2000 1999 0 1998 Tonnes 20000 Highlights of the Proposed Strategy l Addressed CFCs and Halons by Sector l Identified Dates that Bans Refilling, Sector by Sector l Proposed Management Tools Ø Industry initiatives, i.e.: EPR Ø Regulations l Took Into Account Disposal Aspects Environment Canada Environnement Canada Initial and Current Proposals Sector January Proposal Current Thinking Mobile Air Prohibit refill with CFCs Conditioning by 2000 Implement refill prohibition as soon as possible Mobile Prohibit refill with CFCs Refrigeration effective 2003 Subject to further consultations with impacted stakeholders and cost benefit-analysis Domestic Maintain current emission Approach unchanged Refrigeration minimization activities Environment Canada Environnement Canada Initial and Current Proposals Sector January Proposal Commercial Ban refill with CFCs Refrigeration effective 2003 Current Thinking Staged approach (e.g. implement for different categories between 2004 to 2006). Subject to further consultations with impacted stakeholders and CBA Building Air Limit releases from low As proposed + consider further Conditioning pressure purges to less than release reductions (chillers) 0.1 kg/kg air effective 2003 Prohibit recharge after major Ban refill with CFCs overhaul of equipment starting in effective 2008 2005 or 2008 (age of equipment may be considered in final prop.) Environment Canada Environnement Canada Initial and Current Proposals Sector January Proposal Current Thinking Halons Ban refill of portable equipment by 2003 Approach unchanged Ban refill of fixed equipment by 2005 Starting in 2005, only allow 1 refill of equipment; owner will have 12 months to convert system following refill. Ban refill by 2010 Allow refill permits for critical uses Environment Canada Environnement Canada Exempt critical uses Disposal of Surplus Stocks l Very limited disposal capability in Canada l Only one facility has permit l Current capacity very small; modifications to facility needed to increase capacity l Disposal facilities available in other countries: l United States l Europe l Australia Environment Canada Environnement Canada Disposal of Surplus Stocks l l Guideline Document on disposal technologies is a key component of the Disposal Strategy Guideline Document: l Provide information to regulatory authorities l Assist in determining how the surplus will be disposed of in Canada Environment Canada Environnement Canada Next Steps l Complete Consultations June-July l Status Report to NAICC-A and SAC June 12 l Propose Strategy to NAICC-A August l Propose Strategy to CCME Fall 2000 l Distribute Strategy Winter 2000 Environment Canada Environnement Canada Steps Taken so far in Developing the Strategy l l l l l Forecasting Surplus Consultations Developing Options, Management tools Identifying the Issues Establishing the Objective Environment Canada Environnement Canada Consultations l Consultation meetings in 5 cities in February: 200 participants l Strategy posted on the web l Comments received in writing Environment Canada Environnement Canada Comments Received - General l Consistency among jurisdictions is important l Sufficient time to comply necessary l Develop cost-benefit analysis l Halon sector much less organized than R/AC l In some cases a refill ban is equivalent to a use ban Environment Canada Environnement Canada Comments Received - General l Stakeholders supportive of overall initiative l Many practical suggestions as to how to improve strategy l Extended producer responsibility initiatives desirable l Governments will need to initiate awareness program l Incentives desirable l Access to disposal facilities perceived as an issue Environment Canada Environnement Canada 8. Panel Discussion PANEL DISCUSSION The following questions were prepared to help generate and focus discussion on the general issues relevant to the management of existing stocks of CFCs and halons at the workshop Panel Discussion. 1. Should non-Article 5 parties to the Montreal Protocol destroy their existing stocks of CFCs and halons? 2. What are the challenges/obstacles/barriers to developing ODS disposal programs in non-Article 5 countries? In Article 5 countries? 3. What challenges/obstacles/barriers have been encountered in non-Article 5 countries in the destruction of CFCs and halons? In Article 5 countries? 4. What challenges/obstacles/barriers have been encountered in non-Article 5 countries in the commercialization of destruction technologies? In Article 5 countries? 5. Should there be an international mechanism to help countries dispose of ODS? 6. What are the options available for dealing with the problem of contaminated CFCs in Article 5 countries? 7. What type of international mechanism is required to disseminate information on disposal technologies (in addition to the Meetings of the Parties)? What are the information needs and who could best address them? 8. Given the importance of climate change concerns for the emission of greenhouse gases from incineration, should preference be given to disposal programs that use non-incineration technologies? Panel chairpersons Geoff Tierney, United Nations Environment Programme John Hilborn, Environment Canada Panelists Francesco Castronovo, Secretaria de Medio Ambiente, Mexico Alex Cavadias, Environment Canada Dr. Nelson Espinosa Pena, Ministerio de Ciencia Technologia y Medio Ambiente, Cuba Blaise Horisberger, Département Fédéral de l'Environnement, des Transports, de l'Energie et de la Communication, Switzerland Dr. David B. Omotosho, Federal Ministry of Environment, Nigeria Due to time constraints, it was not possible for the panelists to address each of the prepared questions. Instead, the questions set the context for a general discussion during which various views were expressed about the need and timing of ODS disposal or destruction in both Article 5 and non-Article 5 countries. Below are some of the main opinions expressed by various panelists and participants. The reporting of these opinions does not imply that there was a consensus on any of the issues discussed or views expressed. Non-Article 5 countries issues • Some non-Article 5 countries have or are making a policy decision to ban the use of CFCs and/or halons before the end of the useful life of equipment. If a decision is made to convert or ban ODS-based equipment, then the only option left for the ODS previously contained in such equipment is destruction. • The costs involved in retiring equipment prematurely and subsequently destroying surplus stocks of ODS are too high to impose on society. Moreover, compliance with the Montreal Protocol does not require destruction of ODS. • Early retirement of equipment could provide an opportunity for industry to upgrade and adopt more energy-efficient, thus more cost-effective, technologies. Article 5 countries issues • Given the high costs of destruction, the best use of CFCs is to recycle and reuse them until the end of the useful life of equipment. • Destruction is possibly not required in all ODS-using sectors, but certainly in some. As an example, as old fire extinguishers are being replaced, people are starting to stockpile halon 1211, which has little market value. It is not clear what could be done with such stockpiles except destroy them. • Following the implementation of recovery and recycling programs in Article 5 countries, small amounts of CFCs are being stored. Capacity is required to destroy these ODS in Article 5 countries, or else the ODS should be exported for destruction. • Guidance from the Montreal Protocol is required with respect to contaminated ODS. • Recyclers and reclaimers of ODS in some non-Article 5 countries would be happy to pay Article 5 countries for their contaminated ODS. • In many countries the amounts of ODS that may require destruction or recycling will likely be small; hence perhaps the solution is to build regional facilities for destruction or recycling. • Destruction of ODS on-site in many countries is not economical; therefore, the possibility of sending waste ODS abroad for destruction should be considered. • Information exchange on disposal issues is a good start, but eventually an international mechanism should be established to help countries dispose of their ODS. General issues • While in the early years of the Protocol, it was assumed that whatever ODS were in equipment would be released into the atmosphere, the advance of new technologies and the possibility of retrofitting old equipment are providing options for governments to go further than what is strictly required under the Protocol. Furthermore, in light of ozone depletion predicted to be at a peak over the next ten years, all governments need to consider the issue of disposal, although the actual decision to destroy or not destroy will depend on national circumstances. • In order to lower costs of ODS destruction, perhaps linkages could be established with other international environmental agreements, such as the POPs Protocol, wherein destruction of chemicals could be required. • Banning the use of CFCs and/or halons in non-Article 5 countries could lead to the export of used equipment functioning on ODS to Article 5 countries, in effect resulting in simply displacing emissions of ODS from non-Article 5 to Article 5 countries. While some participants felt that the way to prevent this problem from occurring was to ban the export of used ODS-based equipment, others pointed out that this may not be possible because of the need to stay consistent with the GATT.
© Copyright 2025 Paperzz