|
Refrigeration Leak Repair:
How It Affects Your Facility
by Capaccio Environmental Engineering, Inc.
The Stratospheric Ozone
Protection regulations of the Clean Air Act (CAA) are
presented in Section 608 of the CAA, which sets forth
requirements for the recycling and disposal of
refrigerants during the service, repair, and disposal of
appliances and industrial process refrigeration units, and
in Title 40 CFR Part 82, Subpart F, which sets forth the
leak repair regulations. In recent months the EPA has
cited firms for failing to conduct maintenance, repairs,
follow-up testing, and the required recordkeeping for
refrigeration equipment in accordance with these
regulations.
The following sections discuss
the basic prohibitions, leak repair requirements and
recordkeeping requirements of the regulation. Please note
that the following sections are intended to summarize the
main regulatory requirements and should not be used to
determine compliance. Please carefully review the
regulations and consult a qualified professional prior to
making a compliance determination for your facility.
Prohibition (40 CFR §82.154)
Effective
June 13, 2005, no person maintaining, servicing,
repairing, or disposing of appliances may knowingly vent
or otherwise release into the environment any Class I or
Class II refrigerant or substitute from such
appliances with the following exceptions:
-
Ammonia in commercial or
industrial process refrigeration or in absorption units;
-
Hydrocarbons in industrial
process refrigeration (processing of hydrocarbons);
-
Chlorine in industrial
process refrigeration (processing of chlorine and
chlorine compounds);
-
Carbon dioxide in any
application;
-
Nitrogen in any application;
or
-
Water in any application.
Leak
Repair (40 CFR §82.156(i)(1))
Owners/operators of equipment
with charges of greater than 50 pounds are required to
repair leaks in the equipment when those leaks together
would result in the loss of more than a certain percentage
of the equipment's charge over a year. For the commercial
and industrial process refrigeration sectors, leaks must
be repaired when the appliance leaks at a rate that would
release 35 percent or more of the charge over a year. For
all other sectors, including comfort cooling, leaks must
be repaired when the appliance leaks at a rate that would
release 15 percent or more of the charge over a year.
The trigger for repair requirements is the current leak
rate rather than the total quantity of refrigerant lost.
For instance, owners of a commercial refrigeration system
containing 100 pounds of charge must repair leaks if they
find that the system has lost 10 pounds of charge over the
past month; although 10 pounds represents only 10 percent
of the system charge in this case, a leak rate of 10
pounds per month would result in the release of over 100
percent of the charge over the year. To track leak rates,
owners of air-conditioning and refrigeration equipment
with more than 50 pounds of charge must keep records of
the quantity of refrigerant added to their equipment
during servicing and maintenance procedures.
Recordkeeping Requirements (40 CFR §82.166)
When
servicing systems normally containing 50 pounds or more of
refrigerant, owners/operators are required to keep the
following records (Note: Although not required, it is
recommended that these records be maintained for all
refrigerant containing equipment):
-
The date and type of
service;
-
How much refrigerant was
added to appliance;
-
The date the refrigerant was
added to appliance; and
-
When refrigerant was
purchased
Technicians
servicing appliances that contain 50 or more
pounds of refrigerant must provide the owner of the
appliances with an invoice that indicates the amount of
refrigerant added to the appliance. Technicians must also
keep a copy of their proof of certification at their place
of business. Note: Though not required, it is
recommended that copies of technician certifications for
contract personnel be reviewed to verify contractor
personnel are properly certified.
All records must be maintained
onsite and kept for a minimum of three years.
For
more information or assistance with this regulation, please contact David Cotter at Tel. 508-970-0033
ext. 133 or via Email to
dcotter@capaccio.com
|
