EPA audit

[hvacmam]

I remember seeing a few months ago that someone's company had been audited by the EPA regarding refrigerant. I was wondering if anyone knows just what that involves? I've been keeping track using Compliance Suite (or one of its older incarnations) since 1997. We have a lot of refrigerant that's unaccounted for.

Thanks in advance.


Vicki in Phoenix

[craig1]

It's my understanding that its the responsibility of the equipment owners to keep track of the refrigerant their equipment uses if they have equipment that falls into the large scale systems that have maximum allowable leakage rates.

I've never kept track of anything other than for accounting purposes.

[craig1]

Deleted

[craig1]

Well, here it is right from the horses mouth
http://www.epa.gov/ozone/title6/608/...t.html#records


"
Major Recordkeeping Requirements
Technicians
servicing appliances that contain 50 or more pounds of refrigerant must provide the owner with an invoice that indicates the amount of refrigerant added to the appliance. Technicians must also keep a copy of their proof of certification at their place of business.


Owners or Operators
of appliances that contain 50 or more pounds of refrigerant must keep servicing records documenting the date and type of service, as well as the quantity of refrigerant added.


Wholesalers
who sell CFC and HCFC refrigerants must retain invoices that indicate the name of the purchaser, the date of sale, and the quantity of refrigerant purchased.


Reclaimers
must maintain records of the names and addresses of persons sending them material for reclamation and the quantity of material sent to them for reclamation. This information must be maintained on a transactional basis. Within 30 days of the end of the calendar year, reclaimers must report to EPA the total quantity of material sent to them that year for reclamation, the mass of refrigerant reclaimed that year, and the mass of waste products generated that year."

[hvacmam]

So, basically, we're keeping track of refrigerant and it serves no useful purpose except for repairs on units with 50lbs or more charge. <sigh> As a municipality, we do own all of the equipment that we service.

I had been under the impression (given me by the trainers at Compliance Suite fifteen years ago) that any refrigerant not accounted for was considered by the EPA to be vented.

Thanks.

Vicki in Phoenix

[craig1]

I had been under the impression (given me by the trainers at Compliance Suite fifteen years ago) that any refrigerant not accounted for was considered by the EPA to be vented.

Of course they want to make it sound complicated to justify their software. If people knew they could keep sufficient records with Excell or *gasp* a paper book, would anyone buy their software?

[ryan1088]

At my old job there was an audit about 2 years ago. With 15 guys holding EPA cards, they just shuffled through all the documented papers, having no idea how much we had purchased. It was pretty much a joke. If you didn't write something stupid on their paperwork, they didn't think anything of it.


---------------------------------
There are people who live and learn, while others are just livin'. Don't be the latter.

[hurtinhvac]

At my old job there was an audit about 2 years ago. With 15 guys holding EPA cards, they just shuffled through all the documented papers, having no idea how much we had purchased. It was pretty much a joke. If you didn't write something stupid on their paperwork, they didn't think anything of it.

At the base? With large equipment containing over 50#?

Curious as to how many company owners are interpreting the rules and are tracking...cause I don't recall anything from my 608 certification about recording every pound used in smaller systems. Just that they do track how much is purchased...

[hvacmam]

Of course they want to make it sound complicated to justify their software. If people knew they could keep sufficient records with Excell or *gasp* a paper book, would anyone buy their software?

Well, except that we use the heck out of the software for other stuff. For example, every man in our shop has an 88 page printout in his truck of the units at over 200 facilities that lists model & serial numbers, amount and type of refrigerant, as well as voltage and phase. I put it together using a file I generated with the program.

I can also do reports such as what kind of sealed system work has been done on what unit on what dates, or what date was a unit installed and by whom. I'm frequently asked for reports of what units are where at a given facility, and those reports take just a few seconds to generate and print.

I think as a government agency we should be able to document for taxpayers where all of the refrigerant that we buy is used. An unaccounted for cylinder (and we have a lot of those, unfortunately) could have been taken home by a technician and used in side jobs or sold.


We also have over a dozen D.O.T. cylinders that haven't been seen since they were purchased. But that's a different issue. I'm just an HVAC tech using the program for my employer because I was the only person in the shop in who knew that DOS wasn't the Spanish word for 2.

But I've changed the subject. Sorry. (The Ritalin hasn't kicked in yet.)

[btuhack]

gov't/muni workers/shops are probably immune from the epa. Dinging you is just dinging the tax payers(again), they want private party deep pockets.

" We have a lot of refrigerant that's unaccounted for."... careful what you blurt out in open forums, tree huggers have computers too.

http://www.usatoday.com/story/money/...n-air/2766627/

[hvacmam]

PERFECT. Thank you. I have a superintendent who doesn't think the EPA enforces this.

I doubt that municipalities are exempt because we've had to pay other fines in the past, like this one.

http://www.justice.gov/opa/pr/Pre_96...5/443.txt.html

gov't/muni workers/shops are probably immune from the epa. Dinging you is just dinging the tax payers(again), they want private party deep pockets.

" We have a lot of refrigerant that's unaccounted for."... careful what you blurt out in open forums, tree huggers have computers too.

http://www.usatoday.com/story/money/...n-air/2766627/

[btuhack]

Oh, you're trying to undermine your supervisor and use the epa as a weapon. In that case, I retract my comment. I really need to pay better attention to the traps internet folks set.

If you want to start a thread about how employees should let the bosses be bosses, I'd be delighted to chime in on that.

[hvacmam]

Not me. I got the best supervisor ever.


Vicki in Phoenix

Oh, you're trying to undermine your supervisor and use the epa as a weapon. In that case, I retract my comment. I really need to pay better attention to the traps internet folks set.

If you want to start a thread about how employees should let the bosses be bosses, I'd be delighted to chime in on that.