Consultation document on proposed revisions to Federal Halocarbon Regulations: chapter 3

Consultation Topics: Recovery and Halocarbon Inventory

This section is organized using the same headings as found in the Federal Halocarbon Regulations, 2003 (FHR 2003). For each heading, the purpose of the provisions is provided for context, followed by a summary of each issue, the proposed revision, and any targeted questions for which Environment Canada is seeking input.

Recovery

The purpose of the Recovery provisions is to reduce the risk of releasing halocarbon to the environment during system maintenance or at the end of a system’s life by mandating their recovery.

Issue 5 - Recovery from Out of Service Systems

Releases tend to occur when a refrigeration, air-conditioning or fire-extinguishing system is out of service for long periods of time. Section 8 of the FHR 2003 provides no time period in which a system can be out of service before the halocarbon must be recovered. Some systems may be taken out of service with the intention of going back into service (and therefore not decommissioned) for long periods of time, increasing the risk of halocarbon releases to the environment.

Proposed Revision

• Provide that a refrigeration, air-conditioning or fire-extinguishing system may be out of service up to a maximum time period of 12 months before the halocarbon must be recovered.

Questions

• Is 12 months a reasonable time period in which to require halocarbon to be recovered from a system that has been out of service?
• Are there systems for which this time period would not be practical or reasonable?
• Are there systems for which the risk of releasing halocarbon to the environment during recovery is greater than the risk of releasing halocarbon to the environment by leaving it in the system?

Issue 6 - Records of Dismantling, Decommissioning and Destruction Notices

Subsection 8(4) of the FHR 2003 requires that the owner keep a record of the information contained in a dismantling, decommissioning and destruction notice. With the exception of the final destination of the system, all the information required in the notice is also required in the system service log. This results in duplication of work and administrative burden.

Proposed Revisions

• Remove the requirement to keep a separate record of the information contained in the notice.
• Add the requirement to record the final destination of the system to the service log (to be completed at the end of the systems' life).
• Require only the retention of the service log.

Halocarbon Inventory

The purpose of adding Halocarbon Inventory provisions to the revised FHR 2003 is to simplify the onsite identification of halocarbon systems for both owners and Environment Canada officials.

Issue 7 - Halocarbon Inventory

Owners are not always able to quickly identify all systems that use halocarbons located onsite. Consequently, Environment Canada officials have difficulty in determining compliance with the FHR 2003.

Proposed Revisions

• Add a requirement for owners to maintain an inventory of all halocarbon systems onsite. The inventory would be site-specific and list the following information:

• type of system (refrigeration, air-conditioning, fire-extinguishing or solvent),

• make, model and serial number of the system, and

• location of the system (i.e., room number, roof, etc.).

• Exempt small refrigeration and air-conditioning systems from the halocarbon inventory (i.e., domestic refrigerators, freezers, air-conditioners, etc).