Magazine article Journal of Property Management

CFC Update: The Final Rule

Magazine article Journal of Property Management

CFC Update: The Final Rule

Article excerpt

On April 23, 1993, the Environmental Protection Agency completed the long-awaited final rule for the handling and recycling of CFC and HCFC refrigerants. The rule and the regulations that will follow have a dramatic impact on property managers and owners and will require a thorough review of procedures and personnel involved in managing building cooling systems and appliances.

"Anyone who operates or owns a refrigerant system needs to have a refrigerant plan," says Jim Parsnow, Carrier's marketing communications manager.

Managing and minimizing potential problems requires developing a plan for maintenance, repair, and eventually conversion or replacement of equipment using CFCs or HCFCs. Property managers will need to ensure that appliances and cooling equipment are maintained and serviced in line with EPA requirements. (There are hefty penalties for venting refrigerants and bounties for reporting such incidents.)

Perhaps most important, the final rule reverses the EPA's earlier position and requires refrigerant technicians to be certified. Thus, managers will have to consider certifying staff or shifting work to certified outside contractors.

Although much of the final rule follows requirements outlined in the proposed rule, there are a few points worth noting for the property manager and owner.

Assessing equipment

The EPA requires that before air conditioning or refrigeration equipment is serviced, all of the refrigerant must be evacuated, or transferred, to the system receiver or to recovery and recycling equipment. The one exception is the repair of an isolated component of equipment, if the component contains only a limited amount of refrigerant.

The agency is requiring owners/operators to maintain records of the servicing and repair of all air conditioning and refrigeration equipment. Records must also include the refrigerant purchased and how much refrigerant is added to each piece of equipment on a monthly basis.

The final rule adds a provision requiring that leaks in commercial and industrial equipment in which 35 percent of the charge has been replaced within a year must be repaired within 30 days. For equipment with more than 50 pounds of charge, a loss of more than 15 percent of the charge in a year requires repair within 30 days. Smaller equipment, where repairing leaks of this size might not be cost effective, are exempt from the requirement.

Recovery (the safe extraction and containment of refrigerant) and recycling (cleaning and reusing it in the same equipment or in another machine owned by the same owner) are generally onsite procedures which could be done by certified staff or certified contractors with machinery that meets EPA standards. However, recycled refrigerant cannot be used at other sites or by other owners.

Owners of recycling or recovery equipment, including building owners with in-house service personnel, must submit a signed statement to an EPA Regional Office within 90 days of the rule's publication date (which was May 14, 1993) stating that they have enough certified or grandfathered equipment to perform on-site recovery or recycling.

The EPA is grandfathering all recycling and recovery equipment now in service and is not requiring that it be phased out by a specified time. Nor is the agency requiring that existing equipment be certified. The EPA reached this decision because it felt that most equipment manufactured in the last two years would meet certification requirements.

All recovery or recycling equipment manufactured or imported after November 15, 1993, must be tested and certified by an EPA-approved organization. Manufacturers must retest models every three years and label all equipment as certified.

For the most part, reclamation of refrigerant will be the province of outside contractors, who must also now be certified by the EPA. Reclamation, the cleaning of refrigerants to a purity level of at least ARI Standard 700, is an essential step before refrigerant can be resold or used in different equipment. …

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