Refrigerant emissions and leak management

Effective refrigerant management requires a comprehensive plan and careful documentation of procedure and repairs.

FACILITY MANAGEMENT AND HVAC REFRIGERANT EMISSIONS.

Managing the operation and maintenance of a facility's HVAC equipment has always been a major responsibility. Facility managers are responsible for ensuring the systems operate efficiently, effectively, and in compliance with environmental laws. Reducing refrigerant emissions is a key component of a facility refrigerant management program which helps ensure regulatory compliance and reduces operating costs.

TITLE VI SECTION 608 REFRIGERANT LEAK REPAIR REGULATIONS

Chiller leaks have long been recognized as a major source of refrigerant emissions into the atmosphere. The leak repair requirements, promulgated by the, Environmental Protection Agency under 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 pounds 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.

TRIGGER RATES

For all appliances that have a refrigerant charge of more than 50 pounds, the following leak rates for a 12-month period are applicable:

* Commercial refrigeration -- 35 percent

* Industrial process refrigeration -- 35 percent

* Comfort cooling -- 15 percent

* All other appliances -- 15 percent

In general, owners or operators must either repair leaks within 30 days from the date the leak was discovered, or develop a dated retrofit/retirement plan within 30 days and complete actions under that plan within one year from the plan's date. However, for industrial process refrigeration equipment and some federally owned chillers, additional time maybe available.

If at least 50 percent of an appliance's capacity is used in an industrial process refrigeration application, the appliance is considered industrial process refrigeration equipment and the trigger rate is 35 percent.

Those responsible for industrial process refrigeration equipment and federally owned chillers must conduct initial and follow-up verification tests at the conclusion of any repair efforts. These tests are essential to ensure that the repairs have been successful. In cases where an industrial process shutdown is required, a repair period of 120 days is substituted for the normal 30-day repair period. Any appliance that requires additional time may be subject to record keeping/reporting requirements.

MINIMIZING LEAKS REQUIRES LEAK MANAGEMENT PLAN

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 in order to effectively manage refrigerant leaks and comply with EPA requirements.

Implementing a defined leak management program that incorporates regulatory requirements and good maintenance practices is one of the key components of successful refrigerant compliance management.

DEVELOP A LEAK MANAGEMENT PLAN

A good plan is based on accurate equipment and refrigerant inventories and usage. The plan should address compliance with applicable laws and regulations, continued supplies and service, reduced emissions, and recovery and recycling. The plan should emphasize responsible refrigerant handling practices.

Your company's polices and procedures regarding each of the following issues should be included:

* Refrigerant purchase, sales and disposal

* Safe transport of refrigerants

* Refrigerant tracking and record keeping

* Contaminated refrigerant guidelines

* Leak testing, leak prevention and leak repairs

* Equipment and refrigerant inventory

* Refrigerant storage

* Certification for technicians

* Penalties for noncompliance

* Compliance audits and surveys

* Refrigerant recovery, recycling and red aiming

* Servicing practices

* Refrigerant cylinder handling

* Venting and losses

There are refrigerant management software programs on the market that can automate most of these requirements, including leak rate calculation, as well as help with leak management and regulations compliance.

Robert Johnson is president of Environmental Support Solutions, Tempe, Ariz. The company provides compliance software, training, and compliance tools to organizations affected by IAQ, Refrigerant, Waste and Health & Safety issues. For more information email the company at info@environ.com, call (800)-289-6116 ext. 1 or Visit their compliance information center at www.environ.com.

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