Regulatory Developments, Special Topics in Environmental Management

Refrigerant Recordkeeping and Reporting

We recently encountered a list of the 10 most common Clean Air Act (CAA) violations, which included failure of facilities to track the loss of regulated refrigerants from equipment. (Seven of the other violations relate to permits.) In fact, tracking the loss of a refrigerant and recordkeeping in general are major responsibilities under EPA’s refrigerant management regulations (40 CFR Part 82, Subpart F). Sellers and purchasers must retain records of transactions, including the date of sale and the amount of refrigerant exchanged. Purchasers must have evidence that certified technicians are servicing their equipment. Equipment owners or operators (O/Os) must obtain and retain records of when their equipment is serviced. Reclaimers must have records of the materials they receive—both refrigerant and contaminant—and report this information annually to the EPA. While other requirements apply, the recordkeeping and reporting requirements at 40 CFR 82.166 are heavily weighted toward properly accounting for refrigerants lost to the atmosphere, more commonly called the leak rate.

EPA’s basic leak-rate requirement comprises minimum refrigerant charge—50 pounds (lb) in an appliance—and the rate of loss of the refrigerant over 12 months, or trigger rate. Once the trigger rate is reached, the O/O must repair the leak(s) within 30 days of discovery or develop within 30 days a plan to retrofit or retire the appliance, actions that must be completed within 1 year. The Agency recently amended the refrigerant rules. The main objective of the changes was to make substitute refrigerants such as hydrofluorocarbons (HFCs) subject to the safe handling requirements.

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