Does anyone know if refrigerant oil sampling would fall under "de minimis" releases under the Clean Air Act? Thanks.

In my opinion it is 'de minimus'. The EPA would consider it a violation if you intentionally vented refrigerant while servicing the unit. In this case it is an unintentional emission caused by sampling the oil, covered under the same thinking as refrigerant emissions while hooking up hoses to the unit.

You could always call the EPA hotline 800 number to try to get an answer, but I doubt the hired contractors would be able to answer the question. The EPA person responsible for the section 608 program covering emissions is Julius Banks in D.C. if you want an answer from the person responsible for writing / administering the emission regulations.

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