Refrigeration Equipment: Using a Service Contractor Does Not Relieve the Owner from Environmental Obligations

摘要

Hydrochlorofluorocarbons (HCFCs) and, to a lesser extent chlorofluorocarbons (CFCs), are still widely used in refrigeration equipment at industrial facilities. EPA codified regulations covering service technician certification requirements, refrigerant recovery equipment certification requirements, and allowable leak rate limits in 40 CFR Part 82-Protection of Stratospheric Ozone. While facilities frequently use qualified service contractors for maintaining refrigeration equipment, the regulatory onus to track leak rates and keep records is on the owner. Assuming that the service contractor is adequately meeting Part 82 recordkeeping requirements is a dangerous and often incorrect assumption made at industrial facilities. Regulatory requirements were clarified in the January 11, 2005 amendment to 40 CFR Part 82. In the amendment, EPA clarified procedures to be used to calculate leak rates and provided guidance related to leak repair verification tests associated with repairing leaks in refrigeration equipment. The additional clarifications have made recordkeeping and close coordination refrigeration contractors even more critical.