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EnwDfWMnM Protection
Agency
Entorarmot Ana
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3OB9602
CM
CHEMCAL
ASSOCIATION
Self-Audit Checklist
For Industrial Process
Refrigeration Leak Repair
Regulations Under Section 608
Of The Clean Air Act
-------
Self-Audit Checklist for the Amendments to the Leak Repair Rule Provisions of §608
Questionnaire
Please help us gauge the usefulness of this checklist by completing this short form. Your response will be
kept confidential. Aggregated response data will be published, but only to illustrate whether this training
was beneficial to its users. Your judgment of the checklist's utility will help, CMA and EPA to decide how
to improve it, or whether they should even develop future compliance tools together. We appreciate you
taking time to complete the following questions.
DEMOGRAPHICS
1. What type of business do you work for? (check one of the following)
Chemical Refining Recycling Refrigeration Service
Other manufacturing (please identify):.
Other non-manufacturing (please identify):.
2. How many people does your facility employ (including contractors)? (check one of the following)
1-200 Employees.
101-500 Emp/oyees___
Smt-10,000 Employees.
501-1000 Employees.
>20,002 Employees^
3.
2002-5000 Enatloyees
What are your job responsibilities? (check any of the following mat apply)
Environmental Engineer,
Operator
Other
Support Engineer _
Corporate Management
Technician
Compliance Staff_
Plant Management.
JUig
Maintenance
4. How did you hear about this guidance? (circle one of the following)
CMA
Other:
EPA's Stratospheric Protection Hotline
Federal Register
ASSESSMENT
Please indicate your agreement with the following statements from l=Strongly Agree to 5»Strongly Disagree
Statement
The checklist is a good tool to assess my facility/company's compliance status
with the amendments to the leak repair provisions of §608.
Fhe checklist format was user-friendly.
The checklist was timely.
tt used the self-audit checklist in combination with the compliance guidance
land /or the training module.
a tailored the checklist to reflect the individual needs of my facility /company.
My company/facility would have developed a audit checklist for this rule.
1
2
3
4
5
N/Ato
my job
'ime/resources were saved by using this checklist? (yes or no) If yes, how many hours were saved?
'as the self-audit checklist incorporated into a corporate audit protocol rather than used as a stand alone checklist;
(yes or no) Did you have the checklist on disk? (yes or no) If yes, did it help in incorporating it? (yes or no)
fiow many people in your facility/company are using the checklist?
Were additional copies of this checklist made? (yes or no) If yes, how many?
would like similar checklists to be developed for other rules. If so, which ones?
Would you be interested in participating in another survey in the future to help CMA and EPA measure the succea
of this compliance assistance tool? (yes or no) If yes, please indicate your name and phone number where we can
contact you.
Additional Comments: (Please indicate any addition comments on the back page, or attach mem on a
separate page).
Return survey to the Chemical Manufacturers Association, c/o Compliance Assistance Manager at the
following address: 1300 Wilson Boulevard, Arlington. Virginia 22209 (or fax to 703/741-6231)
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ACKNOWLEDGEMENTS
This checklist was prepared by a joint partnership between the Chemical Manufacturers
Association and the Environmental Protection Agency. At the time of publication of this
Checklist, the development team had the following membership:
*Scot Cidzik
Eastman Kodak Company
Sharon Gidumal
DuPont
Chris Jones
Eastman Chemcial Company
JimKinney
Union Carbide Corporation
Kurt Martin
Monsanto Chemical Company
Shannon Moses
Union Carbide Corporation
Toby Threet
The Dow Chemical Company
PaulWinkier
Quantum Chemical Company
*Donn Hirschmann
Allied-Signal, Inc.
Tracy Back
EPA, Office of Compliance
Emily Chow
EPA, Office of Compliance
Ken Gigliello
EPA, Office of Compliance
DanLucero
EPA, Region in
*Cindy Newberg
EPA, Stratosperic Protection Division
James Conrad
CMA, Office of General Counsel
Susan Connella
CMA, Office of General Counsel
Lucinda Schofer
CMA, Regulatory Affairs Department
RasmaZvaners
CMA, Regulatory Affairs Department
Their technical insights, experiences, and suggestions were essential to the development
of this guide.
contributing participant of the development team
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EPA 300-B-96-001
OVERVIEW
The purpose of this self-audit checklist is to help members of the regulated community
determine their compliance status with portions of the August 8,1995, amendments to the
leak repair provisions of the refrigerant recycling regulations. The amendments were
issued by the Environmental Protection Agency (EPA) on August 8,1995, and became
effective on September 7,1995. The amendments make important changes to the
leak repair rules.
The self-audit checklist was developed jointly by EPA and the Chemical Manufacturers
Association (CMA) for use in conjunction with the "Compliance Guidance For Industrial
Process Refrigeration Leak Repair Regulations under Section. 608 of the Clean Air Act"
(EPA 300-B-95-010). In addition, the EPA/CMA workgroup has developed a training
package on the leak repair provisions to further support the regulated community. This
self-audit checklist is intended to be used in conjunction with the compliance guidance
and training package. Copies of the-compliance guidance and training package can be
obtained through either the Stratospheric Ozone Information Hotline (800-296-1996) or
CMA (202-741-5231).
The self-audit checklist is intended solely as a compliance assistance tool. The audit
checklist is intended to be used in conjunction with the compliance guidance, which
explains the practical requirements of the regulations. A compliance determination based
on the use of the self-audit checklist should generally result in compliance with those
aspects of the amendments that it covers. However, the self-audit checklist is not Agency
guidance and does not replace or modify the existing regulations or guidance; instead, it
is an informational tool to help in complying with the regulations. Facilities may
augment or modify the audit checklist to reflect facility-specific situations. However, in
such cases, it should be communicated to the intended users that the document should no
longer be considered an EPA/CMA workproduct
NOTE TO USERS
Responses in boxes within the "no" column outlined by thick lines indicate a potential
violation. The "N/A" column should be used to indicate those activities/requirements
that are not applicable to the subject refrigeration system. Activities not required by the
regulations are presented in italicized text. Where a "-" is provided in the Yes, No, or
N/A column, a response is only needed in the comment column. The comment field
should include, as appropriate, working paper references, location of documents, action
implemented to remedy potential areas of noncompliance, and other appropriate
comments.
COPIES RECEIVED FROM CMA
Copies of the self-audit checklist distributed by CMA include a disk with the checklist in
Microsoft Word 6.0. To install the file ("cklistdoc"), insert the disk in your a:\ drive and
copy the file to your Word 6.0 program or just open the document in Word.
February. 1996 1
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§608 INDUSTRIAL PROCESS REFRIGERATION LEAK REPAIR AUDIT CHECKLIST
# off Checklists for Facility
Name of Facility:
Date of Audit:
Name/title of person conducting the audit:.
Phone number:
Description of industrial process refrigeration system:
#
A.
A.I
A.2
Protocol/Question
Full Charge
Describe method used to determine the full
charge of the system (e.g., measure, calculate,
manufacturer's information, establish range,
combination).
If range method or combination of methods
incorporating the range method was used,
records are maintained including: [§82.166(q)]
y
..
'N
N/A
Comments
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#
A.3
A.4
Protocol/Question
a) identi fication of the owner/operator of the
system
b) location of system
c) original range for full charge, its midpoint,
and how the range was determined
d) all revisions of the full charge range
e) how determined date(s) of any revisions
Date full charge determined.
Auditor reviewed documentation to verify the
full charge determination:
a) the full charge determination appears to be
accurate
(If yes, go to statement after A.4(c))
b) the full charge determination appears to
overestimate the actual full charge
c) the full charge determination appears to
underestimate the actual full charge
Y
......
--
N
I
N/A
-
Comments
Date: '
If the full charge is 50 pounds or less, stop. If the full charge Is more than 50 pounds, continue.
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#
B.
B.I
B.2
B.3
B.4
Protocol/Question
Leak Rate
Date refrigerant last added to the system.
[82.166(k)]
A leak rate has been calculated for the system.
Describe method used to calculate leak rate.
Purged refrigerant was excluded from leak rate
calculation/determination.
[If no, go to statement after B.6(h)|
Y
~
N
N/A
--
Comments
Date:
(As necessary, refer to documentation
regarding previous additions of refrigerant)
«
i
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#
B.5
B.6
Protocol/Question
Records are maintained on-site to support the
amount of refrigerant claimed as sent for
destruction - records are based on a monitoring
strategy that provides reliable data to
demonstrate that the amount of refrigerant
claimed to have been destroyed was not greater
than the amount of refrigerant actually purged
and destroyed and that 98% or greater
destruction efficiency was met.
[§82.166(P)(2)]
The records pertaining to purged refrigerant
include:
[§82.166(p)(2)]
a) flow rate of purge flow
b) quantity or concentration of the refrigerant
in the vent stream
c) periods of purge flow
d) identification of the facility and a contact
person, including the address and telephone
number
Y
N
^^^
H
N/A
Comments
i
1
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#
Protocol/Question
e) general description of the refrigeration
system, focusing on aspects relevant to the
purging of refrigerant and subsequent
destruction
0 description of methods used to determine the
quantity of refrigerant sent for
destruction and type of records that are being
kept by the facility
g) frequency of monitoring and data-recording
h) description of the control device and its
destruction efficiency
Y
N
^i
N/A
Comments
f
<
The leak rate for the system you are examining Is % of the full charge;
continue if greater than 35%; stop If less than or equal to 35%.
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#
c.
C.l
Protocol/Question
REPAIR
The leak(s) was repaired within 30 days of
discovery. Sound professional judgment
indicates repair efforts will bring the leak rate
below the trigger rate. [§82. 1 360X3)]
(If yes, go to C.7|
(If no* complete (aH
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#
C.2
C.3
Protocol/Question
c) repair was delayed due to parts or other
applicable regulations
| If this is the only "yes" response in C.I,
go to C.4|
d) the system will be retired/retrofitted
[Ifyes, gotoF.ll
If an industrial process shutdown was needed to
repair the leak(s) from the industrial process
refrigeration equipment: the leak was repaired
within 1 20 days of discovery.
[§82.156(i)(2)(ii)]
[Ifyes, goto C.6)
{If no, but some repairs have been
done, go to D.I |
If the industrial process refrigeration equipment
has been mothballed: the leak was repaired
within 30 days of discovery (or 120 days if an
industrial process shutdown was necessary) in
addition to the time the system was mothballed.
[If yes, go to C.6 j
(If no, but some repairs have been
done, go to D.I |
Y
N
N/A
Comments
i
<
(if N/A is checked, include the number of
days left on the 1 20-day time clock in this
field)
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n
C.4
C.5
C.6
Protocol/Question
If parts necessary to repair the leak(s) are
unavailable or other applicable Federal, State,
or local regulations made repair within 30 or
120 days impossible: repairs were completed
within 30 or 120 days plus the additional time
needed to receive delivery of the necessary
parts or comply with the pertinent regulations.
[§82.156(iX2)(i)]
If more than one "yes" response is provided in
C. l(a)-(c), determine the leak repair deadline as
follows:
If C.I (a) = "yes", use 1 20 days rather than 30
If C.I (b) = "yes", add time the system was
mothballed
If C.I (c) = "yes", add time necessary due to
delay.
Was the deadline met?
EPA has been notified of the need for
additional time to repair leaks due to regulatory
delays or because delivery of necessary parts
will take too long. The notification and on-site
documents include: [§82.166(n)]
Y
N
N/A
Comments
<
i
<
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n
C.I
Protocol/Question
a) identification of the facility
b) leak rate
c) method used to determine the leak rate and
full charge
d) date of discovery that the leak rate was
above the trigger rate
e) location of the leaks to the extent
determined
f) any repair work that has already been
completed and the date the work was
completed
g) documentation of the reasons why more
than 30 days (or 1 20 days) are needed to
complete the work
h) estimate of when the repairs will be
completed
All repair efforts are documented.
[§82.156(i)(2)J
Y
N
*^»
N/A
Comments
i
(
10
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#
D.
D.I
D.2
D.3
D.4
Protocol/Question
Verification Testing
An initial verification test was conducted.
[§82.152]
t
If the system was taken offline, it was kept off-
line until the initial verification test indicated
that the repairs have been successfully
completed.
[§82.156
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#
D.5
D.6
Protocol/Question
The follow-up verification test was conducted
at normal operating characteristics and
conditions. [§82.1 56(i)(3)]
(If yes, go to D.6)
If no:
a) Did sound professional judgment indicate
that tests performed at normal operating
characteristics and conditions would produce
less reliable results?
b) The follow-up verification test was
conducted at or near the normal operating
pressure where practicable.
[§82.l56(i)(3)J
c) The follow-up verification test was
conducted at or near the normal operating
temperature if practicable.
[§82.156(iX3)J
The follow-up verification test indicated that
the repair efforts are successful.
(§82.l56(i)(3)(ii)]
(If yes, stop)
Y
N
N/A
Comments
i
i
12
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#
D.7
D.8
D.9
Protocol/Question
If repairs fail the follow-up verification test,
EPA was notified of the failed follow-up
verification test within 30 days of the failed
follow-up verification test and documentation
of the failed follow-up verification test is
available on site.
t§82.!5d(i)(3)(iii)]
A copy of the notification is maintained on site.
The notification/on-site documentation of the
failed follow-up verification test includes:
[§82.l66(n)J
a) identification of the facility
b) leak rate
c) method used to determine the leak rate and
full charge
d) date of discovery that the leak rate was
above the trigger rate
e) location of the leaks to the extent
determined
Y
N
I
1
1
1
N/A
Comments
The notification was sent to EPA on
i
i
13
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n
D.IO
D.ll
Protocol/Question
f) any repair work that has already been
completed and the date the work was
completed
g) the date(s), type(s), and results of the failed
follow-up verification test(s)
i) if applicable, the parameters that would be
used to attempt to verify that the leak rate is
below the trigger rate within 1 80 days
If the system failed the follow-up verification
test, a retrofit or retirement plan was developed
within 30 days after the failed follow-up
verification test. A copy of the plan is kept on
site and the original can be made available
upon request. (§82. 1 56(i)(6)(i)]
The owner/operator relies on being relieved of
the duty to retrofit or retire by:
a) successful second repair efforts within 30
days of the failed follow-up verification test (or
120 days, if a process shutdown is required)
(If yes, go to E.1]
Y
N
N/A
Comments
i
<
(the owner/operator is permitted to
implement both (a) and (b); complete all
applicable parts of the audit checklist)
14
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Protocol/Question
N
N/A
Comments
b) demonstrating within 180 days of the failed
follow-up verification test that the leak rate is
below the trigger rate
|If yes, go to E.I5|
[If no, to F.I]
E.
Retrofit/Retire Alternatives
If the owner/operator relies on successful second repair efforts to relieve the duty to retrofit/retire, complete section
E.1 through £.13.
i
If the owner/operator relies on demonstrating that the leak rate Is below the trigger rate to relieve the duty to retrofit
or retire, complete questions E.14 through E.17.
E.I
Second repair efforts were completed within 30
days (or 120 days where an industrial process
shutdown is required) after the initial failed
follow-up verification test.
[§82.156(i)(3)(iv)]
| If yes, go to E.21
If no:
Note: Unless N/A Is checked here, to
avoid noncomplfance, a "yes" response to
one of the options In E.I through E.l(b)
must be provided, or the owner/operator
must also successfully complete the 180
day option InD. 11 (b).
a) repair was delayed due to parts or other
applicable regulations
|If yes, go to E.3)
15
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#
E.2
E.3
E.4
Protocol/Question
b) the system was mothballed
| If yes, go to E.2 1
If the industrial process refrigeration equipment
has been mothballed: the leak was repaired
within 30 days of discovery (or 120 days if an
industrial process shutdown was necessary) in
addition to the time the system was mothballed.
[If yes, goto E.5)
[If no, go to F.I |
If parts necessary to repair the leak(s) are
unavailable or other applicable Federal, State,
or local regulations made repair within 20 or
120 days impossible: repairs were completed
within 30 or 1 20 days plus the additional time
needed to receive delivery of the necessary
parts or comply with pertinent regulations.
[§82. 1 56(i)(3)(iv), §82. 1 56(i)(2)(i)J
EPA has been notified of the need for
additional time to repair leaks due to regulatory
delays or because delivery of necessary parts
will take too long. The notification and
documents include:
Y
N
N/A
Comments
i
i
16
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#
Protocol/Question
a) identification of the facility
b) leak rate
c) method used to determine the leak rate and
full charge
d) date of discovery that the leak rate was
above the trigger rate
e) location of the leaks to the extent determined
f) any repair work that has already been
completed and the date the work was
completed
g) documentation of the reasons why more than
30 days (or 120 days) are needed to complete
the work
h) estimate of when the repairs will be
completed.
Y
N
u
n
i
N/A
Comments
.. i.
i
<
17
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#
E.5
E.6
E.7
E.8
E.9
Protocol/Question
An initial verification test was conducted.
[§82. 156(i)(3)(iv), §82.l56(i)(3)]
The initial verification test was successful.
If the system was taken offline, it was kept off-
line until the initial verification test indicated
that the repairs have been successfully
completed.
[§82. 1 56(i)(3)(iv), §82. 1 56(i)(3)(i)J
(If yes, go to £.9]
If a response "no" was provided in E.4, the
system will be retrofitted/retired.
[If yes, go to F.I )
A follow-up verification test was conducted
within 30 days after the initial verification test,
or if the system was taken offline, within 30
days of bringing the system back on line.
[§82. 1560)(3)0v), §82. 1560X3)]
Y
N
N/A
Comments
(compart date of test to timing requirements
provided in §82.152 - definition of "initial
verification test")
«
18
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#
E.10
E.ll
Protocol/Question
The follow-up verification test was conducted
at normal operating characteristics and
conditions. [§82. 1 56( 1 )(3)]
(If yes, to E. 11]
If no:
a) Did sound professional judgment indicate
that tests performed at normal operating
characteristics and conditions would produce
less reliable results?
b) The follow-up verification test was
conducted at or near the normal operating
pressure where practicable.
[§82.156(i)(3Xiv),§82.l56(i)(3)J
c) The follow-up verification test was
conducted at or near the normal operating
temperature if practicable.
(§82. l56(i)(3Xiv), §82.l56(iX3)J
The follow-up verification test indicated that
the second repair efforts are successful.
[§82. 1 56(i)(3)(iv), §82. 1 56(i)(3)(ii)J
Y
N
m^^^m
N/A
Comments
i
19
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#
E.I2
E.13
Protocol/Question
EPA was notified within 30 days of the
successful follow-up verification test.
t§82.156(i)(3)(iv)]
The notification of the successful follow-up test
includes: f82.166(n)]
a) identification of the facility
b) leak rate
c) method used to determine the leak rate and
full charge
d) date of discovery that the leak rate was
above the trigger rate
e) location of the leaks to the extent
determined
0 any repair work that has already been
completed and the date the work was
completed
g) the date(s), type(s), and results of the
successful follow-up verification test
IStopl
Y
N
N/A
Comments
.
i
*
20
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#
E.14
E.15
E.16
E.I7
. Protocol/Question
If "yes" is indicated in D.9(i), did EPA
disapprove the submitted parameters within 30
days of receipt of the notice?
Within 180 days of the initial failed follow-up
verification test, it is established by approved
parameters that the annual leak rate does not
exceed the trigger rate.
l§82.156(i)(3)(v)J
|lf no, gotoF.I]
EPA was notified of the determination that the
system's annual leak rate does not exceed the
trigger rate within 30 days of the determination.
The notification to EPA (E.I 6) includes:
a) identification of the facility
b) date of the first notification regarding the
failed initial follow-up verification test
Y
--
1
1
N
LJ
H
N/A
Comments
Note: Identify the approved parameters.
i
i
21
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#
F.
F.I
F.2
Protocol/Question
c) determination that the system's annual leak
rate does not exceed the trigger rate
(Stop)
Retrofit/Retire Implementation
A retrofit or retirement plan for the leaking
system was developed within:
a) 30 days of discovery of leak; or
[§82.156(i)(6)]
b) 30 days of the failed follow-up verification
test; or
[§82.l56(i)(6)J
c) 30 days of determining to retrofit/retire the
system.
[§82.156(i)(6)(ii)]
The retrofit or retirement plan is dated, a copy
of the plan is kept on site, and the original can
be made available upon request.
[§82.)56(i)(6)J
Y
..
N
^
N/A
Comments
Note: To avoid noncompliance, all of the
options In F.I cannot be "no."
i
i
22
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#
F.3
F.4
Protocol/Question
All work specified in (he retrofit or retirement
plan is completed within one year of the plan's
date unless you switched from repair under
§82.156(i)(6)(ii), in which case, the deadline is
one year from discovery of the leak rate.
| If yes, stop)
If no:
a) the system has been mothballed
| If yes, go to F.4 )
b) retrofit/retirement activities were delayed
due to other applicable regulations or lack of a
suitable replacement refrigerant with a lower
ozone depletion potential
|If yes, goto F.5|
If the system has been mothballed;
retrofit/retirement activities were completed in
a timeframe equal to, or less than, one year plus
the same period of time that the system was
mothballed.
| If yes, stop)
V
N
N/A
Comments
Note: To avoid noncompliance, a "yes"
response to one of the options in F.3 must
be provided or an extension under F.9 or
F.ll must apply.
«
i
23
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#
F.5
F.6
Protocol/Question
If there was an extension of time due to delays
caused by the requirements of other applicable
Federal, State, or local laws or regulations, or
due to the unavailability of a suitable
replacement refrigerant with a lower ozone
depletion potential, work under the plan was
completed within one year plus the extension.
EPA was notified of the need for a time
extension to complete retrofit/retirement
activities within 6 months of the 30-day period
following discovery. The notification is
maintained on-site and explains why a time
extension is needed, and includes:
[§82.156(i)(7Xii), §82.166(o)J
a) identification of the facility
b) leak rate
c) method used to determine the leak rate and
full charge
Y
N
N/A
j
Comments
The notification was sent to EPA on
5
<
24
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n
F.7
F.8
Protocol/Question
d) date of discovery that the leak rate was
above the trigger rate
e) location of the leaks to the extent
determined
f) any repair work that has already been
completed and the date the work was
completed
g) reasons why you need an extension of time,
and an estimate of when the retrofit or
retirement will be completed
h) a copy of the retrofit or retirement plan
EPA notified the facility of its determination
regarding the time extension within 60 days of
the above submittal.
[§82.156(i)(7)(ii)]
The retrofit/retirement of the system is
completed within the time extension.
| If yes, stop)
Y
*
N
H
q
1
N/A
!
Comments
<
25
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tt
F.9
F.10
Protocol/Question
If delays are caused by: ( 1 ) the installation or
retrofitting of a custom built system; and (2)
the supplier of the system or a critical
component has quoted a delivery time of more
than 30 weeks from when the order is placed,
work is completed within one year plus the
initial 12 month period to complete
retrofit/retirement activities.
[§82.156(i)(7)(ii)J
EPA was notified within 6 months of the
expiration of the 30-day period following the
discovery of an exceedance of the trigger rate.
The notification includes:
[§82.156(i)(7)(ii), §82.166(o)J
a) the identification of the facility and the
owner or operator
b) a description of the refrigeration system
c) the leak rate
d) the method used to determine the leak rate
and full charge
Y
1
N
j
ij
H
1
N/A
Comments
*
26
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#
Protocol/Question
e) (he date when the excessive teak rate was
discovered
0 the location of leaks to the extent determined
so far
g) any repair work that has already been
completed and the date of completion
h) the reasons why you need an extension of
time (demonstrating that the new or retrofitted
system is custom built, and that a vendor has
quoted a delivery time of more than 30 weeks
from when an order is placed, for the system or
a critical component
i) an estimate that the retrofit or retirement will
be completed by the end of the one-year
extension
j) a copy of the retrofit or retirement plan
k) the date of the original notification to EPA
(if any)
Y
1
N
H
i
j
1
N/A
Comments
!
*
>
27
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#
F.U
F.I2
F.B
F.14
Protocol/Question
The retrofit/retirement of the custom built
system is completed within the one-year time
extension.
(If yes, stopj
If additional time beyond the first additional
one-year time period is needed, a request for
such time was submitted to EPA before the end
of the ninth month of the first additional year
and includes revisions of information submitted
to EPA (see F.6). (§82.156(i)(7Xiii)]
EPA objected to the request for a second block
of additional time to complete
retrofit/retirement activities within 30 days of
receipt of the request.
Retrofit/retirement activities were completed
within the second time extension.
Y
N
N/A
Comments
'
i
i
28
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