Maintenance of heat meters. Once again on the issue of maintenance of nodes of the number of heat

Service jobs of general gates of accounting in apartment buildings, HOA, ECC, management companies, organizations and enterprises.

The warranty period of the instruments that make up the accounting node ranges from 1.5 to 4 years. As a rule, the manufacturer of instruments indicates that warranty obligations are carrying if the installation, commissioning work was carried out by a specialized organization.

If the installation of accounting nodes is performed within the framework of the municipal program, then on the basis of competitive selection: with several specialized organizations, the municipal contract is consist of a requirement to provide a five-year warranty for the work and equipment.

Specialized organizations, often they are service centers of manufacturers, are subscribed to such a contract, thereby extending the warranty period of up to five years to their risk. At the same time, it is calculated that they will be involved in the maintenance of the accounting nodes mounted by them.

Another side of the municipal contract represents the future way: nodes are new and good, and if something breaks, that is, a warranty for five years. Hence, further operation in the next five years is not more difficult than collecting testimony from meters at the end of the reporting period.

Apparently, the thought itself to pay money for servicing the metering nodes, which completed the installation and gave a five-year warranty for the work performed, it seems absurd.

Based on such a simplified idea of \u200b\u200bthe further operation of the accounting nodes, 16 kopecks from a square meter for maintenance are laid on the tariff. It approximately 500 rubles per month for servicing the metering nodes of one MKD.

To provide maintenance services, a new organization "The best servicing organization of the city of Vladimir" is created (conventionally), which under the contract with the management companies undertakes twice a month to control the state of the seals and shut-off valves, as well as collect meter readings at the end of each month.

Service centers, one of whom we are, offer the realistic set of services in the average cost of 1500 - 3500 rubles. per month for the metering knot, but most of the management companies prefer "five hundred rubles", without deepening in the contents of the contracts.

However, after two or three months, a massive refusal of services "The best servicing organization of the city of Vladimir" began and the transition to the services of service centers, that is, the services of specialized organizations trained in the manufacturer.

What is the reason? The reason was the fact that the energy supplying organization refused to make the testimony of many accounting sites, which were removed by the "best serving organization of the city of Vladimir," note, with a preliminary inspection of the state of the seal and shut-off reinforcement.

If the "best servicing organization of the city of Vladimir" fulfilled the contractual obligations in full, the guarantee for instruments and installation acts, and there is no commercial accounting, then the reason is apparently in the improper work of the service organization.

Given that in the country there is a massive introduction of accounting nodes, I believe that this story may be useful to those who have to be serviced by the metering nodes or service organization.

How to organize maintenance so that the readings of the accounting devices taken by the power supply organization?

Let's start with the Federal Law of the Russian Federation of July 27, 2010 №190-FZ "On Heat Repair". Article 19. Organization of commercial metering of thermal energy, coolant, establishes that the organization of commercial accounting may include:

1) installation of accounting devices;

2) operation of accounting devices, including the removal of the readings of the accounting devices and the transfer of these services to customers, calibration, repair and replacement of metering devices.

Another document. The rules for accounting for thermal energy and coolant from 1995. Clause 9.3. "The maintenance of the metering assembly associated with dismantling, calibration, installation and repair of equipment must be carried out by personnel of specialized organizations ...".

It follows that, besides removing the readings of the accounting devices, the obligation of the service organization must include the implementation of services for the repair and replacement of accounting devices, regardless of the availability of guarantees of the installation organization and the manufacturer. Warranty repairs will be made free of charge, but before the service organization must establish that the reason for the malfunction of the device. Next, competently place an advertising act, dismantle the device, and the device sent to repair the device is replaced with a serviceable device from your backup submental fund.

The calibration of measurement tools, according to Article 13 of the Federal Law "On Ensuring Measurement", is carried out by the established manner in the field of ensuring the unity of measurements of legal entities. Service organizations do not have such accreditation, but for instruments for calibration they need to be correctly dismantled, prepare for verification and after calibration again carry out installation in the accounting node. Therefore, it is advisable to include in the duty of the serving organization and this position.

But that's not all. Heat supply is a complex technological process. Hence complicated commercial accounting. Indications of serviceable devices can not always be taken to commercial calculations. Reason?

Article 2 of the Federal Law of the Russian Federation of July 27, 2010 №190-FZ "On Heating" establishes the following concepts:

The quality of heat supply is a set of established regulatory legal acts of the Russian Federation and (or) the heat supply contract of heat supply, including thermodynamic parameters of the coolant.

The mode of consumption of thermal energy is the process of consumption of thermal energy, coolant in compliance with the thermal energy consumer of the mandatory characteristics of this process in accordance with legal acts, including the technical regulations and terms of heat supply contract.

Article 15 of the same law establishes that the heat supply contract must be determined as follows:

The magnitude of the heat load of heat-consuming installations of the consumer, the quality of heat supply parameters, the mode of thermal energy consumption;

Responsibility of the parties for non-compliance with the requirements for the quality of heat supply, violation of the mode of consumption of thermal energy, including responsibility for violation of conditions on the amount, quality and values \u200b\u200bof the thermodynamic parameters of the returned coolant.

The rules for accounting for thermal energy and coolant from 1995. Paragraph 1.3. It establishes that the calculations for the heat obtained are carried out on the basis of the readings of the metering devices and control of the parameters of the coolant. Paragraph 1.4. It establishes that mutual obligations for the calculations for thermal energy and the coolant, as well as to comply with the release modes and the consumption of thermal energy and the coolant are determined by the contract ....

Since it is obvious that non-compliance with consumption modes will adversely affect energy efficiency, we will also point to Article 9.16. Code of the Russian Federation on administrative offenses, which establishes the responsibility for non-compliance with the requirements of the energy efficiency of those imposed on the MCD.

From the above references it follows that the consumer can pay with an energy supply organization on the readings of the accounting devices only if there are no violations of the consumption mode, there are no violations of "conditions on the amount, quality and values \u200b\u200bof the thermodynamic parameters of the returned coolant." Otherwise, a fine, or the accrual of additional quantity, it all depends on the heat supply contract. There is another option - the output of metering devices from exploitation, with consequences. Consider this option in more detail, since it is related to the maintenance of accounting nodes.

So, the power supply organization determines the presence of regime deviations based on the readings of the accounting devices. Here is legitimate doubt. Does there really have violations in the domestic system that registered the device, or the device is lying, and in the system everything is in order?

Let us turn to everyday experience. Do we know the cases of leakage of the coolant in the downtown systems? Yes. What should the device fix? It will fix the difference between the mass between the coolant obtained from the system and returned back to the system. Is it a violation of the regime? Yes.

Are there any cases of expansion of hydraulics of the domestic system? Yes, many know that when in part of the apartments it is cold, you need to complain, then the restricting consumption of the nozzle coolant will be twisted. In the "cold" apartments will be warm, and in "warm" - hot, but the excess heat is easy to remove through the window. What will register the device? Violation of "Conditions of the number, quality and values \u200b\u200bof thermodynamic parameters of the returned coolant".

Another solution is known - to drain the heat carrier from the return pipeline into the sewer? What should the device fix? The difference between the masses between the resulting and returned heat carrier. Is this a violation? Sure.

If everyone knows that the state of the domestic engineering systems is far indifferer, then it is possible to say that warranty, targeted appliances with seals can be believed without a doubt?

Unfortunately no. If there are malfunctions from the domestic systems, then there is also a repair. When conducting welding, plumbing work in the system, the scale falls into the system, rust, slices of rubber, other foreign objects: they are stuck in the accounting unit and create the conditions unacceptable for the operation of the conditions, which leads to the loss of measurement accuracy. The device does not require repair, but it is required to restore the working conditions for its operation.

We conclude that the cause of unsatisfying the power supplying organization of instrument readings can be both a malfunction in the system and the loss of measurement accuracy.

How does these doubts allow the power supply organization? Simply. When monitoring the consumption mode for commercial accounting, the energy supplying organization is indifferent to the real cause of a malfunction, it only considers the actual instrument testimony, and not the reasons that led to such indications.

If the accuracy of the instrument testimony is in doubt, the energy supplying organization may remove the node from commercial metering, referring to § 9.10. Rules for taking Teit "Work outside the speed of accuracy."

For example, in a closed system by definition, there should be no difference between the masses between the feed and return pipe. If there is a difference, the device is faulty. Here is such logic. The logic is permissible, since both the instruments and the domestic system beyond the responsibility of the power supply organization.

We approached the key point. The energy supply organization displays the metering units only when it has the grounds to doubt the accuracy of the instrument readings, because These readings do not meet the expectations of the normal process.

Output. So, there should be no indications in which you can doubt. No falsifications! There is another one for the right decision. We need such a service technology that allows you to control the testimony and eliminate the causes of dubious readings immediately as they occur.

This conclusion is based on the organization of maintenance of accounting nodes by our enterprise.

The main task of service is to provide a normal, continuous operation of accounting nodes, in which all parties trust the results of accounting. I like or do not like the results of accounting, and the parties trust (forced to trust) the results are different concepts.

Go to the area of \u200b\u200bpractical implementation of this task.

To eliminate the causes of dubious testimony as they occur, it is necessary to detect them as it occurs. So, software and technical means need to keep continuous monitoring of parameters of all accounting nodes in an acceptable to solve the tempo task are required. Without the ability to monitor - the task of impossible!

We use an automated system for collecting information as a top-level system and data transfer equipment. With part of the accounting nodes, the connection is carried out through modems. Data collection is automatically daily at night after midnight. At the request of the operator, you can download readings anytime.

The key figure is a person performing dispatching functions. This analyst capable of the number columns and multi-colored graphs of parameters to see the process of heat-water supply and deviation of consumption modes. Some deviations of the parameters program determines automatically, but the human brain remains the strongest analytical apparatus.

Control does not boil down to primitive assessment - "There are indications" or "no indications". The lack of readings is an unpleasant, but the simplest case when you can easily install and quickly eliminate the cause. More difficult when the testimony is. How to determine that this testimony can be trusted?

Since the metrological characteristics of the devices cannot be determined at the site of operation, the "Quality" of the testimony is continuously estimated. Under the "Quality" of the testimony, we understand compliance with the expectations of the magnitude and dynamics of changes in the controlled parameters in time, as well as the relationship of changes between the dependent parameters.

When indications that do not meet the "Quality" criteria are detected, the dispatcher sends to an object of operational staff, which in place finally finds out that the reason was the reason for such testimony - incorrect measurements of the normal mode or correct changes in the abnormal regime.

Thanks to the monitoring, personnel directed to the object knows in advance - what actions he should take, and has accessories for replacement, if necessary.

It is important that the staff knows not only the devices, but is able to determine and is argued to prove a malfunction in the downtown system to receive a confirmation of a representative of the management company. It stimulates (but does not guarantee!) The efficiency of troubleshooting in the domestic network and protects the serving organization from claims to accounting devices.

So, the key point of service is that the serving, manageing and resource-supplying organization is equally trusted or do not trust the readings of the instruments of accounting, assessing their goodness.

If the serving and managing organization timely eliminate the causes, the consequence of disclaimed testimony, then commercial accounting becomes continuous and long-term.

We generalize the minimum requirements that the service organization must meet, capable of providing long-term and continuous commercial registration:

The organization must have a technical ability to continuously monitor serviced accounting nodes;

The organization must have trained personnel capable of evaluating the "Quality" of the testimony obtained during monitoring;

The organization must have trained personnel capable of disassembled the malfunction of the heat supply process from accounting devices malfunctions;

The organization must have training personnel trained by the manufacturer allowed by maintenance and small repair of these devices;

The organization must have a sufficient reserve fund for the operational replacement of faulty instruments;

The organization must be the service center of the manufacturer's plant, the instruments of which it serves;

The organization must have many years of experience in this direction.

If someone today has difficulty choosing a servicing organization for organizing the maintenance of accounting nodes, then I recommend to take into account the set out of the requirements or simply contact our organization Energo Troops LLC. It will save you from many unnecessary problems interfering with real energy saving.

Based on the above, we carry out the following works:

1. Periodic maintenance of the instruments of the heat metering unit (inspection, removal and analysis of readings, donoyake, adjustment, fine repairs, checking electrical connections, checking the oil level in thermal sensors).

2. Printout of the conductions of heat consumption, drawing up the report and protection of it in the heat supply organization.

3. Preventive work: dismantling, installation, cleaning of instruments.

4. Verification and interactive preparation of devices (tracking of the deadlines of the melief).

5. Replacement of instruments.

6. Repair of devices.

7. Putting-commissioning work on the tunner of thermal energy. Commissioning in the inspector of the heat supply organization. Drawing up an act of readiness.

8. Challenge the inspector of the heat supply organization for surrendering the center of the thermal energy (the presence of the representative when checking the heat meter with a power supply organization).

9. The correct operation of the heat meter, leaks, pass, notop.

10. Monthly analysis of accounting devices.

11. Analytical work to identify non-standard (new) reasons for the exit of devices in order and restoring performance, etc.

To date, the service price is in the range of 500 to 5,500 rubles per month for one heat meter. The price is formed from the specific wishes of the customer and the number and types of work that he wants to see on his object. We are ready for each of our customer.

In order for the equipment to work for a long time and without problems, a high-quality and reliable installation of meters for heating performed by real professionals is necessary. Do not trust such a responsible lesson to dubious companies.

The company "TECK" is a specialist in the installation work and maintenance of thermal energy metering devices. We have accumulated a large number of regular customers. The company's team enjoys a good reputation and respect from partners and customers. For us there are no impracticable tasks! We are working at a high level and in the agreed period.

Unfortunately, with time, any equipment fails and stops performing their direct functions. To avoid unpleasant situations, it is necessary to carry out timely maintenance of heat meters. The condition of the device affects many factors that are able to reduce its functionality. It is necessary to keep the status of the counter under control, and from time to time to diagnose the condition of the equipment. You should not forget that from the correct data obtained from the meter will depend on your utility costs.

If you are interested in the cost of installing counters into water, more detailed information can be found on the company's website. We offer only accessible and democratic prices, which allows everyone to use our services. Our team receives exclusively positive feedback on the works carried out, but we do not stop at what has been achieved by trying to improve the skills and skills of qualified specialists of the company.

Order Maintenance of heat meters in Moscow

In the company "Tesco" you can buy a high-quality heat meter, which is distinguished by reliability, as well as a reasonable price.

In order to avoid erroneous data that equipment can give you, it is necessary to conduct competent maintenance that is able to extend the operational period of any technique. Installing a high-quality meter provides minimization of equipment repair costs.

If you are interested in the cost of the heat meter, go to our site and look at the price list for the products you are interested in. Be sure the prices will pleasantly surprise you! If you have any questions, please contact the specified contacts, and in the telephone mode, the operator will voiced all the necessary information!

• Do we need a servicing organization?
• Is there a law prescribing it to have?
• What awaits us if we give up the service service?
• What is included in the service service?

Let's deal with all questions in order.

Heat meter, from the owner, does not require special care. The lithium battery, from which the heat meter eats is not suitable for re-use, but requires disposal. No special care for the battery is not necessary, the service life declared by the manufacturer at least six years is usually not more than five years old and this is equal to the service life of the meter before it is inspected (the deadline for the melief is four five years for different heat meters). A specialist checking or serving heat meter, about four years, must change the battery. If you have consumption converters, also feed on batteries, then they must be changed every two years.

Thermal resistance - services do not require.

This theory - we will analyze in practice.

K. TN. S.N. Kanev, Associate Professor, CEO,
Khabarovsk Center for Energy Saving, Khabarovsk

The purpose of this publication is: to draw the attention of heat supply organizations that have a license for repairing measurement tools (C) and technical and maintenance of thermal energy accounting nodes, aspects that arise when checking licensed systems for the repair of SI, which are part of the accounting node.

Introduction

In January 2008, the territorial body of the State Metrological Supervision (Inspectorate of Rostechregulation in the Khabarovsk Territory) checked all enterprises of Khabarovsk, who have a license for repairing SI and are maintained by the maintenance of nodes of thermal energy.

According to the results of verification of licensing activities for the repair of measurement tools, protocols were compiled, which were then transferred to the Arbitration Court of the Khabarovsk Territory to initiate the case on the attraction of the licensee for administrative responsibility.

Note that during the inspection, the actual repair activities were not considered, only the formal (paper) side was checked:

■ availability of regulatory and regulatory and technological documentation;

■ availability of maintenance and transmission logs for calibration;

■ The presence of workers used in the repair of C;

■ The presence of reference systems used in the calibration of repaired C.

The main observations of the auditory authority, in particular for the group of enterprises of the Khabarovsk Center for Energy Saving, were reduced to the following.

1. The licensee violated the mechanization to repair technology, namely: in a timely manner (on time before the end of the calibration), did not provide the verification of measuring instruments used in the repair process.

2. The licensee did not provide a list of measuring instruments and a chart of verification of measuring instruments for 2008

3. The licensee violated the conditions for the repair - did not conclude an agreement with the state metrological service for the verification of measuring instruments after repair: measuring pressure sensors (pressure gauges and manifestyle).

4. The licensee was repaired and sent to the verification of tape devices, not included in the licensed type of activity.

5. The licensee did not report on the licensed body - the Federal Agency for Technical Regulation and Metrology of its new, registered by the State Strestra, Legal address.

All comments will be discussed in detail below, in the meantime we note that the Arbitration Court of the Khabarovsk Territory in the first instance recognized all the arguments of the inspection authority asphic and decided: refuse to refuse the inspection requirements of the Inspectorate on State Metrological Supervision.

The purpose of this publication is: to draw the attention of organizations that have a license for repairing SI and technical and service maintenance nodes of thermal energy accounting, aspects that arise when checking licensed activities on the repair of SI, which are part of the accounting node.

Consider the following concepts:

■ service;

■ maintenance;

■ repair;

■ Verification.

Service maintenance

The concept of "service service" is absent in the regulatory and technical documentation,

but it can be qualified as follows. Service is a combination of services aimed at meeting the specific needs of each particular client.

The concept of service maintenance of the metering of thermal energy includes maintenance, repair and additional service functions, rendered to the consumer-insecurity of the accounting node:

■ Removing the testimony and analysis of data on the heat consumption of the subscriber;

■ Analysis of emergency situations arising during operation;

■ Preparation of the heat consumption report for the Subscriber and assistance in disposal issues arising between the Subscriber and the Energy Supporting Organization;

■ subscriber personnel training;

■ the provision of consulting services to the consumer on the heat supply of its object;

■ Conducting work on improving the work of the subscriber heat supply system (regulation, adjustment, etc.).

Maintenance

In accordance with maintenance, this is a complex of operations to maintain the performance of the product when used for intended, expectation, storage and transportation. In accordance with the service is operation, repair, commissioning and testing of equipment. Operation - systematic use, maintenance and repair of heat-consuming installations.

Thus, maintenance in accordance with includes repairs, and for repair in accordance with it is necessary to have a license for repairing SI.

With regard to thermal energy metering sites, maintenance is carried out in order to control the correctness of the operation of the accounting node and includes the following types of work:

■ systematic control over the operation of devices included in the accounting node and the diagnosis of their technical condition;

■ Current repair and adjustment SI;

■ If necessary, disassembly si, their repair and subsequent verification.

Repairs

In accordance with the repair - a set of operations to restore product performance and restoring product resources or their components. The following types of repair and repair methods differ.

Types of repair:

■ Capital - repair performed to restore the health of full or close to the full restoration of the product resource with replacing or restoring any of its parts, including the basic;

■ Middle repairs - repairs performed to restore the health and partial restoration of the product resource with replacing or restoring the components of the limited nomenclature and the control of the technical condition of the compound parts performed in the amount established in the regulatory and technical documentation;

■ Current (small) Repair - Repair performed to ensure or restore the performance of the product and consisting in replacing and / or restoring individual parts;

■ Repair by technical condition - Repair at which control of the technical condition is performed with periodicity and in the amount established in the regulatory and technical documentation, and the volume and moment of start of repair is determined by the technical condition of the product.

Repair methods:

■ Aggregate repair method - repair method in which defective aggregates are replaced with new or advanced repaired;

■ Repair method by a specialized organization - a method for performing repair by the organization specialized in repair operations;

■ Corporate repair - a method for performing repair by the manufacturer.

Verification

In accordance with the calibration of C - a set of operations performed by the state metrological service authorities in order to identify and confirm the compliance with the established technical requirements. Measurement facilities subject to state metrological control and supervision are subjected to verification when producing from production or repair.

So, if the concept of service, maintenance and repair can be combined, then the "verification" is in no way related to these concepts. Between repair and calibration there is only an indirect connection: Verification is performed after repair, i.e. Renovated C should be repaired. Although this is a controversial statement that will be shown below.

On the need to maintain thermal energy accounting nodes, especially on the basis of domestic heat meters, the author spoke another 13 years ago. At that time, most of the manufacturers of heat metering devices adopted an idea about the maintenance of the accounting nodes in the bayonets. They motivated this by the fact that their products do not need maintenance, because The performance of their products is maintained throughout the entire intermediate interval (MPI), which is usually from 3 to 5 years. After the end of the MPI, the planned repair of devices is carried out and their subsequent verification. However, this myth was debunked after the 1 -2 operation of this equipment.

The practice of exploitation has shown: neither one of the domestic heat meters actual MPI coincides with the passport, approved when conducting tests for the type of SI type.

For the overwhelming majority of domestic accounting devices, the actual MPI does not exceed 1 year (although sometimes there are samples, in which MPI is 2 years) with the declared MPI in 3-5 years.

Today, all domestic producers of heat metering devices seizely recognize this fact, introducing in NTD to the accounting instruments of the Count "Maintenance". In this column there are interesting records like:

■ "In the case of the use of heat meter under conditions of coolants with a physicochemical composition, differing from the requirements of regulatory documents, it is necessary to produce a periodic flushing of the flow part of the flow converters without abrasive materials; flushing regularly in service mode, not allowing metrological failure; The breakdown period of the flow part depends on the specific operating conditions ";

■ "If a precipitate is possible in the measured medium, the flow converter is necessary to periodically wash in order to eliminate deposits; In this case, do not allow mechanical damage to the inner surface of the converter and its electrodes ";

■ "When revealed during the operation of a yellow flush on the inner surface of the flow converter, it must be dismantled and wipe the inner surface of the measuring section with a soft cloth so as not to damage the electrodes."

Is it really funny. First, how to determine, matches the quality of the coolant with regulatory documents or not. If even the quality of the coolant corresponds to GOST at the exit from the source, it is not at all necessary that its quality will not change when the heat supply system is "rusty" pipes. Secondly, how to "wash" the flow part and what solution - nothing is said about this in NTD. And the most important thing: how to determine at what moment you need to rinse (read) the measuring site? How often do you need to do this in operating conditions? Does this not change the metrological characteristics of the device? Answer to these questions in NTD on these si you will not find.

Currently, the need for maintenance of heat metering devices during their operation is not discussed. In almost all regions of the Russian Federation, heat metering units are not allowed for commercial accounting if they are not on technical or service, although 13 years ago it was considered a crime.

Before returning to the check materials, we will once again stop at the concepts of repair and calibration si.

For the repair of flow transducers, heat meters and thermal conductors, no reference si is required. When repaired, it can be used: a set of keys and screwdrivers, tester (multimeter), oscilloscope, etc. And it is not necessary that these funds are believed.

After repair (in order to determine the quality of repair), these SI can be distributed (renovate, calibrate) using reference C on special stands. This can be done, but you can not do - if you are sure about the quality of repair and did not damage the dummy seals. Moreover, this operation can be done or the repair organization itself, or any other organization.

And finally, the third stage - verification of repaired C on special stands with the help of reference SI, which organs conduct

state metrology service. If, according to the results of calibration, the product is recognized as suitable, this means that the repair is made qualitatively.

It should be noted that although it is written that the calibration is subject to C during the release of them from the repair, it is all si after the repair must be believed. So, for example, if the current (small) repair of C (replacement of the battery, power supply, fuse, etc.) is carried out. And at the same time, the dummy seal is not damaged, then this product can not be refunded after repair.

In this regard, interesting questions arise.

1. Flushing, cleaning flow of flow transducer during operation - is it repair or maintenance? If the metrological characteristics of the device changed during operation, i.e. Metrological refusal (it is not clear, however, how to check it out), then this repair to which the license is required and after which it is necessary to conduct an extraordinary calibration. If metrological characteristics have not changed, then this maintenance and repair license is not needed.

2. Adjusting the device - is it repair or not repair? The question is not simple, as it seems at first glance. Suppose the device has adjusted and changed its class to lower, for example, from 0.25 to 0.5. In this case, the device remained operational. If you qualify how to repair,

this requires a repair license, and if it is not a repair, then the license is not required.

Here on such ambiguities and inaccuracies and are trying to play control and control bodies when verifying licensed repair activities.

On the comments of controlling bodies

Let's return to the comments of the controlling bodies, which are presented at the beginning of this publication. The first gross violation that falls from the point of view of the verifier body, under the item "b" is a violation of the repair technology, which is that the licensee during the repair process used not timely attorney reference systems with the help of which, allegedly, was carried out . It should be noted that in fact it was about the reference C (pulse generator, frequency meter, resistance store, etc.), which are used when calibrated repaired SI, and not when they are repaired. At the time of the inspection, some of these standards was commissioned in verification, which was confirmed by the letter of the metrological service, adopted these devices in calibration.

The essence of this comment that the auditory body has incriminated to the licensee, comes down to the following.

1. In accordance with the SI calibration schedule for 2007, the reference SI should have been reversed in December 2007, and verification in January 2008, but before the end of the MPI. Since the licensee broke the schedule, it is, according to inspection, is a violation. It should be noted that in the contract for the provision of metrological services there is an item: "The Contractor undertakes in agreement with the Customer to carry out the SI verification, not included in the schedule presented outside the graph or with the disturbed periods specified in the chart." However, the reference to this item of the contract did not take into account the inspection.

2. The inspection issued the licensee also that part of the reference SI, which, in its opinion, are used for repair, at the time of the inspection was absent (was at the verification of VKCSM). Consequently, during the segment of time when the reference Si was on calibration, the licensee did not have the possibility of implementing licensed activities. He had to warn the licensing authority about this - the Federal Agency for Technical Regulation and Metrology, but he did not. The licensee drew the attention of the inspection that during this period he did not conduct a repair or verification, but

it was not taken into account. And although the inspection did not prove the fact of repair and, consequently, the violation of the repair technology, it still considered it a violation and demanded to punish the licensee. From the point of view of a normal person, this is absolute nonsense: to punish not for the commission of a crime, but for the potential opportunity to implement a crime. According to the logic of the inspection, it turns out like a classic: "If a rifle hangs on the wall, then it will once be shot", which means that someone can kill.

The court figured out this question as follows. We will quote the court's decision: "Based on the definition of the" technological process "given in GOST 3.1109-82" Terms and definitions of basic concepts ", violation of technology and manufacturing and repairing SI means the presence of a disturbance of the production process in the manufacture and repair of C. The inspection does not provide evidence that the untimely delivery of devices for verification led to a violation of the system of repair SI. At the time of finding devices at calibration in HCSM, the latter could not be applied by the licensee during the repair of SI and, as a result, the impaired technology of repair could not be. "

Let us then consider the second remark made to the licensee by the controller: the licensee did not submit a list and timing of measuring instruments for 2008 with the calibration schedule figured out: the calibration schedule for 2008 was at the time of the inspection on coordination in HCSM and was presented later on the judicial trial. But about the list, the control body insisted on its position, which was as follows. In accordance with, "periodic calibration are subject to measuring instruments in operation or storage; Lists of measuring instruments to be calibrated are the owners of measuring instruments and send them to the state metrological service authority. "

Those. According to the logic of the regulatory authorities, the licensee was supposed to show inspects with a list of all measuring instruments on its balance sheet and in operation or on storage: electric meters, heat and water meters, for which communal payments with resource-supplying organizations are carried out, etc. Moreover, in what form it should be drawn up this list and for what period it should be drawn up, is not specified.

This list of the licensee was absent, but the court considered that this does not apply to licensing activities. Nevertheless, the inspection insisted that the licensee broke the regulatory act, namely, and

so, thereby violated the conditions for conducting licensing activities. However, the court did not accept the argument of the controlling body on this issue.

I want to draw the attention of anyone who has on its balance sheet and exploits the measurement tools for the fact that the STI list to be calibrated must have. This is the first thing that checks the inspection on metrological oversight and control. Moreover, this applies not necessarily to test the repair activities.

According to the author, this list does not need an enterprise-balancer, nor the more organ of the State Metrological Service (HMS), which carries the C. Both sides believe these C in accordance with the deadlines established in the NTD on these SI and on the basis of an agreement for the provision of metrological services, annually concluded between these parties. Therefore, the presence of a list is an extra hook for the territorial governments of Rostechregulation, which they are trying to catch the verified organization - the owner of S.

Consider the third note: "The licensee violated the condition of repair - did not include in the contract with the HMS for verification after the repair of pressure gauges and vacuummeters."

First, as mentioned above, repair and verification are different things and you can not mix them. If these si was not included in the calibration schedule for 2007, this did not violate the repair condition.

Secondly, the licensee drew the attention of the inspectors that these SI was not repaired by them, but were commissioned, because Expired MPI.

Thirdly, in the contract of the Licensee with the HMS for the provision of metrological services, there is an item in accordance with which the Contractor (HMS) undertakes in agreement with the Customer (Licensee) to carry out the SI verification not included in the chart. Therefore, the court did not take into account this remark and took the argument of the inspection.

The fourth issue of the inspection consisted that "the licensee was repaired and sent to the verification of narrowing devices (SU), not included in the licensed activity." According to the inspection - this is a very gross violation, because The licensee carried out the repair of Su, without having this right. During the inspection, the licensee drew the attention of those inspecting that he did not repair Su, but only handed over them for verification in the HMS.

It should be noted that only standard diaphragms are used in Khabarovsk, which, in principle, are not subject to repair. Licensee at the request of consumers who serve heat metering nodes, really handed over standard diaphragms for verification, taking them from dirt and flushing in kerosene, but this is not a repair! Since the inspection could not prove the fact of repair, the court considered it unreasonable.

And finally, the last - the fifth note: "The licensee did not report the licensed body about the change of its legal address."

In accordance with: "In the case of the reorganization of a legal entity, changes in its name or location, as well as in the event of a change in the address of the location of the licensed type of activity, the licensee is obliged to submit an application for re-issuing a document confirming the license."

Since neither the actual nor postal address of the licensee has changed, the address of the license activity is also not changed, and the legal entity was not reorganized - the licensee, the licensee found that he acted in strict accordance with and therefore did not notify the licensed body to change the legal Addresses. The court rose to the side of the licensee and recognized the arguments of the inspection not substantiated.

In conclusion, you can quote the decision of the Arbitration Court of the Khabarovsk Territory:

"In accordance with paragraph 1.4 and 1.5 of the Code of the Russian Federation on administrative violations, the person is subject to administrative responsibility only for those administrative offenses in respect of which its fault is established, unreasonable doubts about the guilt of the person involved in administrative responsibility are interpreted in favor of this person. Provisions of Art. 65 and 210 The Arbitration Procedure Code of the Russian Federation establishes the rules according to which the obligation to proof obligations served as the basis for bringing to administrative responsibility is imposed on the administrative body that has accepted the disputed decision (in our case, this is the inspection of the state-speaking and control distance). "

This decision follows from, namely: paragraph 3 of Art. 12 "To relations associated with

by the licensing authority to verify compliance with the licensee of licensing requirements and conditions in the implementation of the licensed type of activity, the provisions apply. "

In accordance with Art. 3 of the law basic principles for the protection of the rights of legal entities and individual entrepreneurs during state control (supervision) are: the presumption of good faith, i.e. The innocence of a legal entity, and, consequently, the controlling body must prove the fault of the injured person, and not vice versa.

Based on the foregoing, you can do the following conclusions.

1. The organization engaged in the maintenance of thermal energy accounting nodes must have a license for Rostechregulation for the repair of SI, which are part of the accounting node.

2. If the territorial rostechregulation authorities will check your licensed system repair activities and during this check, they will draw conclusions that you have violated the conditions for conducting this activity, they will have to prove your guilt by presenting the relevant facts, and you do not have to Assist, testifying to themselves, providing them with the information they request, sometimes even illegal.

Literature

1. GOST 18322-78. Technical maintenance and repair system. Terms and Definitions.

2. Rules of operation of heat-consuming installations and thermal networks of consumers, GOS-ENERGONADZOR, 1998

3. Federal Law No. 128-FZ "On licensing certain types of activities."

4. The law on ensuring the unity of measurements (as amended by the Federal Law of January 10, 2001 No. 15-FZ).

5. Glukhov A.P., Kanev S.N., Putyatin V.I. Experience of the Khabarovsk Center for Energy Saving Saving Heat Accounting Devices in Enterprises // Industrial Energy. №2, 1995.

6. Regulations on the licensing of activities of the on-screening and repair of measuring instruments, utensils. Decree of the Government of the Russian Federation of August 13, 2006 No. 493.

7. PR. 50.2.006 "The procedure for the verification of measuring instruments."

8. Federal Law on the Protection of Rights of Legal Entities and Individual Entrepreneurs in the conduct of state control (supervision) No. 134-ФЗ from 2001