What level of negligence is required to receive a 24 million dollar fine from the EPA? Is this the largest fine you have seen imposed from the EPA for a marine customer? are there more to come?
So they’re allowed to leak up to 35% per year per machine.
Really stretching that de minimis
You need to be big enough to matter and negligent enough to get caught, that’s about it.
Also, there appears to be a giant loophole in the law:
owners and operators of industrial 3 process refrigeration equipment normally containing more than fifty pounds of Refrigerant must 4 have leaks repaired if the leak rate of the appliance exceeds thirty-five percent on an annual basis 5 (i.e., if the appliance is leaking at a rate such that it would lose more than thirty-five percent of 6 its full charge in a twelve-month period)
Have a leak exceeding 35% per year? No problem, just increase nominal holding capacity of the system, and you’re in compliance!
Agreement to make $23 million dollars in Refrigeration upgrades to their vast fleet of vessels and shoreside processing plants. That’s a big number, but they are a huge company with a lot of facilities. It ain’t cheap to do anything in places like Akutan.
Akutan isn’t exactly the end of the earth, but you can see it from there!
I wonder who dropped the dime.
A contractor that is going to bid on the upgrades???
The CG entered into a MOU or MOA with the EPA (unfortunately) ~ 2013/14 to act as the EPA’s eyes and ears onboard vessels since the delicate Birkenstock clad lads and gals of the EPA were flumuxed how to board those scary steel ships. Probably stumbled on it during a CG safety exam or somesuch as they went down the checklist. Thought the fishing industry used to use ammonia systems, guess no longer the case.
In all my years going to sea I have yet to be asked about our refrigerant records though I always expected I would be some day. Very possible the EPA was tracking vendors ordering R22.
In alaska fisheries there has been some movement towards CO2 systems lately. Glacier Fish sold the Pacific Glacier partially due to the improved efficiency of their new CO2 refer system (so I hear)… I believe the AO plate freezer, freeze times cut in half, from 90-120 minutes down to under a hour… CO2 is much more friendly than R-22, Amonia, or any of the other R- # 's… I would be curious to see if Trident knew a penalty was near, they saw these drastic efficiency gains, and used this 23M as a form of penalty to drastically improve efficiency?