CFC Record Keeping & Reporting Requirements 5 — Questions and Answers
Question 1: A refrigerant distributor sells a 30-pound cylinder of R-410A to a technician. What must the distributor retain as documentation of the sale?
- A copy of the refrigerant's safety data sheet signed by the buyer
- Evidence that the buyer is a certified technician or employs certified technicians (Correct answer)
- An EPA purchase order number issued to the buyer
- The buyer's equipment ownership records
Correct answer: Evidence that the buyer is a certified technician or employs certified technicians
Distributors must verify and retain evidence that purchasers of refrigerant in containers over 20 pounds hold or employ certified technicians.
Question 2: Which scenario requires an owner to file a report with the EPA under Section 608 leak rate provisions?
- Any refrigerant addition to a system over 50 lbs
- When the annual leak rate exceeds the applicable threshold and repair is not feasible within 30 days (Correct answer)
- When a technician recovers more than 10 lbs in a single service visit
- Any time refrigerant is transferred between cylinders on-site
Correct answer: When the annual leak rate exceeds the applicable threshold and repair is not feasible within 30 days
Owners must notify EPA and provide documentation when a leak rate exceeds the threshold and repairs cannot be completed within the standard 30-day window.
Question 3: What is the primary purpose of maintaining a leak inspection log for a large refrigeration system under Section 608?
- To satisfy OSHA confined-space entry requirements
- To calculate the annual leak rate and trigger repair obligations (Correct answer)
- To qualify the system for refrigerant credits from the manufacturer
- To document refrigerant purity for warranty purposes
Correct answer: To calculate the annual leak rate and trigger repair obligations
The leak inspection log provides the data needed to calculate the annual leak rate, which determines whether mandatory repair obligations apply.
Question 4: Under Section 608, if a system owner cannot identify the source of a leak in a large appliance after a thorough leak check, what is the maximum additional time allowed before the EPA requires retirement or retrofit planning?
- 30 days
- 60 days
- 120 days (Correct answer)
- 180 days
Correct answer: 120 days
If a leak cannot be located after a thorough inspection, owners have up to 120 days before retrofit or retirement planning is required.
Question 5: A technician services a refrigeration system and transfers recovered refrigerant into a gray cylinder with a yellow top. What does this color coding indicate under DOT/industry standards?
- The cylinder contains reclaimed refrigerant meeting ARI 700 standards
- The cylinder contains recovered refrigerant that has not been reclaimed (Correct answer)
- The cylinder is approved for hydrostatic pressure testing
- The cylinder has been certified for cross-border transport
Correct answer: The cylinder contains recovered refrigerant that has not been reclaimed
Gray cylinders with yellow tops are the industry-standard color code for recovered (not reclaimed) refrigerant under DOT guidelines.
Question 6: Under EPA Section 608, which party is legally responsible if a refrigerant sale exceeding 20 pounds is made to an uncertified buyer and no certification verification was obtained?
- Only the buyer for misrepresenting their credentials
- Only the seller for failing to verify certification
- Both the seller and the buyer can be held liable (Correct answer)
- The EPA regional administrator assumes liability
Correct answer: Both the seller and the buyer can be held liable
Both the seller who fails to verify certification and the buyer who falsely claims certification can face EPA enforcement action.
Question 7: How does Section 608 define the 'annual leak rate' for a refrigeration appliance?
- Total refrigerant added divided by the full charge, expressed as a percentage per year (Correct answer)
- Total refrigerant vented divided by total refrigerant purchased annually
- The difference between refrigerant added and recovered over 12 months
- The average monthly refrigerant loss multiplied by 12
Correct answer: Total refrigerant added divided by the full charge, expressed as a percentage per year
The annual leak rate is calculated by dividing the total refrigerant added to make up for leaks by the appliance's full charge, expressed as a percentage.
CFC Record Keeping & Reporting Requirements 5
A refrigerant distributor sells a 30-pound cylinder of R-410A to a technician.
What must the distributor retain as documentation of the sale?