Columnist Robert Johnson explains EPA restrictions on refrigerant releases and regulations on mandatory leak repairs.

Leak repair requirements under Title VI, Section 608 of the Clean Air Act Amendments of 1990 require that when an owner or operator of an appliance that normally contains a refrigerant charge of more than 50 lb discovers that refrigerant is leaking at a rate that would exceed the applicable trigger rate during a 12-month period, the owner or operator must take corrective action. The Clean Air Act also requires that refrigerant vented into the atmosphere during installation, service or retirement of equipment be minimized.

For appliances with a refrigerant charge of more than 50 lb, the following leak rates for a 12-month period are applicable:

  • Industrial process refrigeration: 35%.
  • Commercial refrigeration: 35%.
  • Comfort cooling: 15%.
  • All other appliances: 15%.

Restrictions on refrigerant releases and regulations on mandatory leak repairs have made chiller leak management and refrigerant conservation more important than ever. Maintenance engineers must be properly trained and must know what the specific regulations and requirements are to effectively manage refrigerant leaks and comply with Environmental Protection Agency requirements. While any maintenance engineer who services or oversees chillers should be knowledgeable about traditional preventive maintenance procedures and the steps to minimize refrigerant discharge, some maintenance steps that involve refrigerant handling and transfer must be performed by EPA-certified technicians.

Penalties for letting uncertified personnel service refrigeration equipment are substantial. Implementing a defined leak management program that incorporates regulatory requirements and good maintenance practices is a key component of successful refrigerant compliance.

Leak-Management Program

New regulations, rising refrigerant prices and the reduced energy efficiency of improperly charged refrigerant chillers demand a comprehensive and sophisticated approach to refrigerant conservation and leak management. A sound program will improve efficiency and reduce operating costs. It also will protect against possible lawsuits or fines by the EPA.

A leak-management program should include several actions:

  • Conduct an inventory of equipment and refrigerants.
  • Develop a leak-management plan.
  • Implement a refrigerant record-keeping system.
  • Maintain existing equipment and refrigerant supplies.
  • Replace old or inefficient equipment.

Detailed records of equipment stocks and refrigerant are essential for making informed decisions about refrigerant usage and leak management. Priority should be given to equipment with the largest charge. Inventory sheets should individually itemize chillers and pieces of commercial refrigeration equipment.

Information is needed on the manufacturer, model, serial number, year installed, capacity in tons, charge size, leak rates (based on records of recharging, or topping off), refrigerant and location.

The quantity of refrigerant purchased, consumed, disposed of or reclaimed should be monitored and analyzed. Refrigerant inventories should be kept by type and include the volume contained in each piece of existing equipment, as well as amounts currently stored. These inventories should be updated regularly. Local codes for storage limits should be consulted.

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