SEPA
CM
CHEMICAL
MANUFACTURERS
ASSOCtATIOJ
United States
Environmental Protection
Agency
Enforcement And
Compliance Assurance
(2224-A)
October 1?&f,
Compliance Guidance
For Industrial Process
Refrigeration Leak Repair
Regulations UaderFSeetion 608
Of The Clean /BOO* ^
Washington, DC 2046© ..
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Compliance Guidance For
Industrial Process Refrigeration
Leak Repair Regulations
Under Section 60S
Of The Clean Air Act
Prepared by:
The Chemlcml Manufacturers Association
and
The Environmental Protection Agency
October 1995
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ACKNOWLEDGEMENTS
This guide was prepared by a joint partnership between the Chemical Manufacturers
Association and the Environmental Protection Agency. At the time of publication of this
Guide, the development team had the following membership:
ScotCidzik
Sharon Gidumal
DuPonl
Chns Jones
Eastman Chemcial Company
JimKinney
Union Carbide Corporation
Kurt Martin
Monsanto Chemical Company
Shannon Moses
Union Carbide Corporation
TobyThreet
The Dow Chemical Company
PaulWinkler
Quantum Chemical Company
*Donn Hirschmann
Allied-Signal, Inc.
Tracy Back
EPA, Office of Compliance
Emily Chow
EPA, Office of Compliance
KenGiglieUo
EPA, Office of Compliance
DanLucero
EPA, Region in
Cindy Newberg
EPA, Stratosperic Protection Division
James Conrad
CMA, Office of General Counsel
Susan Cornelia
CMA, Office of General Counsel
Lucinda Schofer
CMA, Regulatory Af&irs Department
Rasma Zvaners
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-95-010
TABLE OF CONTENTS
A. OVERVIEW - ; - ; - i - - i - A-l
Punxise,, TTTTTT-. ___________________ [[[ ___ A-l
Intended Audience ------- ... ------- ... .. . --------------------- .. -------- '. . . ------------ A-l
What the Guidance Covers ....... .......... --------------------- .................................. A-l
What the Guidance Does Not Cover ... ........................ ..... ------- . .... A-l
rVMfinlifltif*^ .._._........*..........».»»*..».......*.**.*»».......»........».....,.. . A 2
^^^/ll ilf ii%lllV**l" »»»»*»«»**«»»»»»"""'""""*«**"""»»»»»"»**«***»*« * » ^"
How To Use the Guidance ---------- ...... ---------- :. ----------- ... ------------------- .... -------------- A-2
For More Information .. ...... ........... ----------- ............................................ A-3
Rflplfofviimfl .... [[[ A-3
i_f .^^-^^.^. tee[[[*......*..................... « & *r
General Summary Flow Chart ................ ---------- ................ ------------------ . ------------ A-4
B. APPLICABILITY. - . - , - ! - . B-l
Questions flno^nywCTS .*«.....«....**....«*»....**«
C. FULL CHARGE [[[ , ............... . .............................................. . - ~. C-l
irCtcnn mi IIR
D. LEAK RATE .................................................. _ .................... -, ................... ' - ............ IM
Questions and Answers «...*.«....«..***«»........*.«*....«....«**»«»..«.***»*.««..«..«.*«*. D-3
E. LEAK REPAIR - , - - - , - : - E-l
Situations Where More Than 30 Days Are Required ----- ................ -------- .E-l
Industrial Process Shutdown[[[^-!
Unavailable Repair Parts or Other Regulations
That Require Additional Time. ------------- ......... ------------------ ................. ---------- E-l
Repair Veriiication...............«[[['...E-2
Initial Verification Test. ____ [[[ _______ ........E-2
Follow-up Verification Test ------- . ----------- . -------- ... ----------- ... -------------------------------- E-3
Initial and Follow-up Verification Test Methods -------------------- ......... --------------- E-3
EPA Notification. ---------- . --------------------------------- ; -------------------------------------------- ....E-4
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EPA 30O-B-95-010
F. RETROFIT AND RETIREMENT OF LEAKING REFRIGERATION
SYSTEMS ' i F-l
Time Extensions For Retrofit or Retirement of Industrial Process
iCftlfi^£i&tioQ systems[[[«..............M...........x<-j
Relief From Obligation to Retrofit or Retire , .. .,.... F-2
\JUGSttQflS flfMi nflSn^CT** ***»*«»**»*«»***«**»****«**«********»«***»** J*~J
Timeline & Checklist For Retrofit or Retirement ., ....F-5
G. RECORDKEEPING AND REPORTING REQUIREMENTS __________ G-l
Leak Repair.......................
Retrofit or Retirement.......
Purged Keiiigerant ........
Questions ond Answers.. ......
H. SYSTEM MOTHBALLING
Applicability...
Example of System Mothballing.
Questions and Answers ..M....~...~
OIL CHANGES
X GLOSSARY
K.
Stratospheric Ozone Information Hotline
Stratospheric Protection Division's INTERNET Home Page
Stratospheric Ozone Protection Rulemakmg Summary.........
Stratospheric Ozone Protection Final Rule Summary
EPA Applicability Detennmanons ...........................
APPENDIX
Refrigerant Leak Repair Flow Chart ......
G-8
, ............. H-l
............. H-l
........... H-l
.....»»..... H-2
M
J-l
..............
............................
K-1
K-l
... K-l
. K-l
............... K-l
.. K-2
.. Appendix
October 1995
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A. OVERVIEW
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EPA300-B-95-010
A. OVERVIEW
Purpose '
Thepurpose of this guidance is to explain portions of die .August 8,1995, amendments to
the leak repair provisions of the refrigerant recycling regulations (hereafter refered to as
"die amendments") and assist those affected by these amendments in complying with
them, the original refrigerant recycling regulations were published on May 14,1993
(58 Eg 28660). The amendments were issued by EPA on August 8,1995, and became
effective on September 7,1995. The amendments make important changes to the
leak repair rules and readers familiar with the original rule should review the
amendments and this guidance carefully.
Intended Audience
This guidance is intended for those persons who are responsible for their company or
organization complying with the amendments. This may include plant engineers,
maintenance supervisors, or maintenance technicians.
What the Guidance Covers
This guidance is focused on aspects of the amendments relevant to industrial process
refrigeration systems. All refrigeration systems, including industrial process
refrigeration^ are subject to various requirements of the refrigerant recycling regulations.
Therefore, you should also read the amendments and other pertinent sections of those
regulations.
What the Guidance Does Not Cover
This guidance does not discuss:
requirements for other types of refrigeration equipment; or
provisions for federal facilities; or
other aspects of the refrigerant recycling regulations (for example,equipment
certification or rules for recovering or recycling refrigerant); or
disposal of appliances containing ozone-depleting substances.
This guidance does not explain HOW to do everything required or permitted by the
amendments, such as how to perform a leak test using an ultrasonic leak detector. The
guidance assumes that its readers are properly trained in the various actions it describes.
October 1995 A-l
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EPA 300-B-95-010.
If you are not sure bow to do what the .guidance recommends, consult with
knowledgeable personnel in your company or organization.
' '
Compliance with the portions of the refrigerant recycling regulations that are not covered
by mis guidance are very important Severe penalties can be imposed for violation of
these regulations. You should seek appropriate assistance if you have any questions
regarding provisions of the regulations not covered here. The guidance contains a list of
references, Module K, containing information on those provisions.
Compliance
*.
The policies set out in mis document are not final agency action, but are intended solely
as interpretive guidance. The guidance should not be used to replace the amendments;
rather, it is intended as a supplement to explain their practical requirements. Compliance
with this guidance generally should result in compliance with those aspects of the
amendments that it covers. ~ .
Varying from the guidance does not necessarily mean that you will be in violation of the
amendments. If you have any questions about whether or how you can depart from the
guidance refer to the amendments, consult with counsel, or call the EPA Stratospheric
Ozone Information Hotline (see next page).
How To Use the Guidance
This guidance is organized by modules. Each module is a discrete section mat covers an
important aspect of the amendments. Although the modules are intended to be free-
standing, we recommend that you review the entire document initially to understand me
interrelationships of the amendments* various parts. Once you understand the various
compliance options that the amendments present, the modules can be used as independent
references.
Throughout the guidance, you will fold words in italics. The italicized words are defined
in the glossary (Module J). In each module, a Question and Answer section is provided
to help clarify confusing issues or to answer commonly asked questions.
This guidance contains flow charts that illustrate the compliance options of the
amendments. A simplified version follows at the end of this module. A more detailed
version is contained in its entirety as an appendix at the end of mis guidance document,
showing, in detail, all the decision points and possible paths to follow to comply with the
amendments.
October 1995
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EPA300-B-95-010
You should understand two important issues UP FRONT:
1. The amendments contain several alternative pathways you can follow. Each one of
these pathways has deadlines that are triggered by various actions. Once you start
down one pathway, you may not be able to switch to another. UNDERSTAND the
associated time frames before you choose a course of action.
2. The amendments require you to notify EPA of various events. UNDERSTAND these
before you start, so you can make the appropriate notification^) at the required
time(s). -
For More Information '
*
Module K is a list of references containing more information about the amendments and
the refrigerant recycling regulations generally.
EPA operates a Stratospheric Ozone Information Hotline that provides information about
ozone protection regulations and requirements under Title VI of the Clean Air Act
Amendments of 1990. The Hotline also serves as a distribution center and point of
referral for an array of information pertaining to other general aspects of stratospheric
ozone protection and depletion.
Number 800-296-1996
Hours of Operation: 10:00 ajn. - 4 pjn. Eastern time, Mondays to Fridays,
excluding holidays. . ..
Background
The amendments pertain to the leak repair provisions of EPA* s refrigerant recycling
regulations. The refrigerant recycling regulations were called for by Congress as part of
Title VI of the Clean Air Act Amendments of 1990. Title VI, entitled Stratospheric
Ozone Protection, is generally directed toward eliminating the threat posed to the earth's
protective stratospheric (or high-level) ozone layer by certain ozone-depleting substances
(ODSs). Section 608 of the Act calls on EPA to publish rules regarding the use,
recycling, and disposal of ODS in various applications, including industrial process and
commercial refrigeration systems.
The original EPA rules on this subject (sometimes referred to within industry as the "no-
venting rule") were published on May 14,1993 (58 CFR. 28660). Several amendments
have been made to the rule; please see Module K, References, for a complete list of the
current amendments.
OctoberWS A-3
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B. APPLICABILITY
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EPA 300-B-95-010
In tills guidance document, the
term "systems" is used to refer
to refrigeration appliances and
equipment.
Trigger Rates
For all systems that have a refrigerant
charge of more than 50 pounds:
SYSTEM RATE
commercial refrigeration ' 35%
industrial process refrigeration 35%
Comfort cooling 15%
All other refrigeration 15%
B. APPLICABILITY
Affected Operations
Industrial process refrigeration is defined as complex,
customized systems used in the chemical,
pharmaceutical, petrochemical, and manufacturing
industries. These systems are directly linked to the
industrial process. This sector also includes industrial
ice machines, appliances used directly in the generation
of electricity, and ice rinks, (see Glossary) The
amendments refer to "appliances" and "equipment,*1 but
mis guidance refers to "systems*' me term more
commonly used in the industry.
The refrigerant recycling rule applies to systems that
contain and use a class I or class H substance as a
refrigerant.
Class I refrigerants arc mostly
chlorofluorocarbon (CFC) refrigerants or any
' refrigerant mixture containing a CFC.
__ *
Class n refrigerants are hydrochloro-
fluorocarbon (HCFC) refrigerants or any
, refrigerant mixture containing an HCFC.
NOTE: If you are not sure whether you have & class I or
class n refrigerant, refer to the lists in 40 CFR, Part 82,
Subpart A, Appendices A and B or call your refrigerant
supplier.
Applicability Triggers
»
The leak repair requirements of mis regulation are
triggered when an owner or operator of an industrial
process refrigeration system discovers mat refrigerant
is leaking at a rate that would exceed 35 percent of the
total charge hi a 12-month period. (See Module D for
more information on leak rates.)
EXEMPTIONS
OR
EXCLUSIONS
Ijfufr repair provisions of this regulation
do NOT affect systems normally
containing 50 pounds or less of
refrigerant
October 1995
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EPA 300-B-95-010
QUESTIONS
ANSWERS
Why does the same refrigerant
number begin with different letters;
for example, is R-I2 the same as
CFC-12?
There are many different ways to refer to the same
chemical Including some trade names. Since this
amendment applies to ozone-depleting substances (ODSs)
that are refrigerants, you should determine whether or not
your refrigerant is or contains an ODS.
Do the leak repair requirements
apply to HCFC refrigerants such as
R-22?
Yes, the requirements apply to all Class I and Class n
ozone-depleting substances. This includes CFCs,
HCFCs, and blends that contain CFCs or HCFCs.
The refrigerant recycling
amendments refers to "appliances.''
I thtnlc of appliances as household-
type refrigeration equipment, such as
refrigerators, freezers, and window
air conditioners. Is leak repair
required for these appliances'!
No, the refrigerant charges In household appliances are
normally less than 50 pounds. As it is used in these
regulations, the term "appliance" means any type of
refrigeration equipment, no matter how large or small.
Systems normally containing 50 pounds or less of
refrigerant are excluded from leak repair requirements,
even though they are appliances and are subject to other
aspects of the tgfii^efgnt recycling amendments.
I bavt an appliance that is used in an
industrial process refrigeration
application and is used in a cooling
application (or is used to cool a
control room). Which trigger rate
applies to my appliance1}
If at least 50 percent of an appliance** capacity Is being
used hi an industrial process refrigeration {application,
the appliance Is considered an industrial process
refrigeration system and a 35 percent leak rate is the
trigger. If less than 50 percent of die appliance's
capacity Is being used in an industrial process
refrigeration application, then this system would not be
considered industrial process refrigeration. In tin's
specific example, the system would be comfort cooling .
with a 15 percent nigger rate.
The leak repair requirements apply
only if the independent refrigerant
circuit has more than SO pounds of
refrigerant What is an independent
refrigerant circuit?
A refrigerant circuit consists of equipment that carries
refrigerant (typically In a closed loop) to and from the
point of cooling. For example, refrigerant may flow
from a compressor to other components, such as heat "
exchangers and evaporators, and back to the compressor.
Most refrigeration systems have only one refrigerant
circuit. A minority of systems have two or more
refrigerant circuits that are completely isolated from each
other (i.e., they are designed to avoid mingling refrigerant
from one circuit with refrigerant from another circuit).
These are independent refrigerant circuits.
October 1995
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EPA 300-B-95-010
QUESTIONS
ANSWERS
What if my industrial process
refrigeration system has two
independent refrigeration circuits,
one with a foil charge greater man 50
pounds, the other with ifittt charge
less than 50 pounds?
The circuit whoseyiitf charge is greater than 50 pounds
would be subject to leak repair requirements. The
circuit whose/«// charge is less than 50 pounds would
not be subject to leak repair requirements.
Many industrial process
refrigeration systems are physically
integrated into a manufacturing
process. How can I tell which
equipment is part of the refrigeration
system and which is not?
The industrial process refrigeration system consists of
only the interconnected equipment 'that contains,
conveys, or otherwise handles the refrigerant For
example, if a single major component has portions that
contain refrigerant and portions that contain other fluids
(such as process fluids in a heat exchanger or oil in a
'), the entire component is part of the
refrigeration system. Other piping or processing
equipment that contains solvents, taw materials, or other
nonrefrigerants is not pan of the refrigeration system.
October 1995
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C. FULLCHARGE
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EPA 300-B-95-010
Yon MUST know the fuU charge
of your refrigeration system.
Yon MUST use an acceptable
method.
If you use method a, b, ore, it
is recommended that you
document (and are able to show)
how you determined Hot full
charge, although it is not
specifically required.
If you' use method d, you are
required to document how you
determined the full charge.
If you use method e, you are
not required to keep records
unless you incorporate method d.
C. FULL CHARGE
The foil charge is the amount of refrigerant necessary for
an industrial process refrigeration system to operate at
normal operating characteristics and conditions. There
are two reasons why you need to know how much
refrigerant is in the foil charge for a system:
1. The leak repair requirements of this law do not
apply to any system v/bostfiiU charge is 50
pounds or.less of refrigerant in any independent
ntfrigerant circuit.
2. To calculate the leak rate for a system, you need to
know tot full charge (see Module D for more
information on leak rates).
To determine Ac fittt charge, yon must use one of the
following methods:
a. Measure the refrigerant For example, draw the
refrigerant from the system and weigh it Or, you
can measure how much refrigerant you put into an
empty system to fully charge it
b. Calculate the weight of the refiigeiant charge in
die system.
c. Use Hie manufacturer's information. Some
manufacturers specify the amount of refrigerant in
the foil charge for a system, either on a plate
attached to the system or in specifications (or
vendor literature).
d. Establish range. If you know the system
functions properly within a range of refrigerant
amounts, use the midpoint of that range. Special
recordkeeping requirements apply if this method
is used alone or in combination with other
methods. (See Module G for more information on
recordkeeping).
October 1995
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EPA 300-B-95-010
e. Combinations of a through d. For example,
suppose you have a system that consists of two
components connected by pipe or tubing. The
.length of the pipe or tubing varies from one
installation to another. As a result, the
manufacturer has specified bow much refrigerant
is in a full charge for the two components, but
NOT for the pipe or tubing. You may calculate
how much refrigerant is in the length of pipe or
tubing for your system, and then add that amount
to the manufacturer's estimates for the two
components. .
QUESTIONS
ANSWERS
Should I be concerned about the
tMBTtyip of error m determining the
fill charge?
Yes, but EPA recognizes that there Is some margin of
error In any determination of toe amount of refrigerant
In a system. If you have> made your detenamation based on
the best information available and sound professional
Judgment, the fall charge number is acceptable.
If the manufacturer's statement of
the full charge is wrong, what
should I do?
Do not use the manufacturer's statement of the full
charge V you know ft to incorrect
Sometimes a manufacturer's statement of the fall charge is
incorrect. For example, a system may have been customized
by adding more components. Or additional refrigerant may
be used because the system is operating under conditions
mat the manufacturer did not anticipate. In some cases, the
manufacturer may simply have goofed, and it is obvious that
the fall charge is much larger or smaller man the
manufacturer said. If the manufacturer r*ac obviously
goofed, choose one of the other acceptable methods to
e the fall charge.
The manufacturer's information may, however, still have
some use. For example, if you have customized a system by
adding components, you may be able to calculate the
amount of refrigerant in those components and add it to the
manufacturer's estimated charge for the original system.
Am I allowed to change the fall
charge number? If I change it,
should I recalculate all my leak rate
determinations?
Yes, yon may change the full charge number If yon
obtain new and better information. No, you do not have
to recalculate any previously determined leak rates. You
would, however, use the hew fall charge number in
calculating any future leak rates.
Do I have to use the same method
to determine^// charge for all
systems at my facility?
No.
October 1995
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D. LEAK RATE
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EPA 300-B-95-010
The trigger rate for industrial
process refrigeration systems is
35 percent
REPAIR
RETROFIT
RETIRE
D. LEAK RATE
gach time you add refrigerant to a system normally
containing SO pounds or more of refrigerant (see Module C),
you should promptly calculate the leak rate. If die leak rate is
higher than the trigger rate, you are required to do one of the
following:
a. Repair leaks (see Module E); ,
b. Retrofit the system (see Module F); or
C. Retire me system from service (see Module F). .
Calculating a Leak Rate
Presented below is one way of calculating a leak rate.
Facilities can use other methods, e.g., rolling averages.
1. Take me number of pounds of refrigerant you added
to return the system to afittt charge and divide it by
the number of pounds of refrigerant in the normal >«//
charge far tits system.
#lbs refrigerant added
#Ibs refrigerant in normal >W/ charge
2. Take me number of days that have passed between
charges (mat is, how many days between the last time
refrigerant was added and this time refrigerant was
added) and divide by 365 (the number of days in a
year).
- #davs since refrigerant last: added
365 days
3. Take the number you determined in step 1 and divide
it by the number you determined in step 2.
4. Multiply the number you determined in step 3 by 100
(to calculate a percentage)..
Another way of expressing mis is with the following formula:
LEAK RATE %«
_ pounds of Futlchame _
X
365davs
_ «days since refrigerant last added.
X100
October 1995
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EPA 300-B-95-010
If you are the
OWNER OR OPERATOR:
The result is the.leak rate, expressed in the. percent of full.,
charge that would be lost per 12-month period.
In some complicated situations, other calculations may also
be appropriate. For example, if a known amount of
refrigerant was removed intentionally and put back into the
system, men that amount should not be counted as a "leak".
The four-step approach described above, however, will give
the correct leak rate in ordinary situations.
Timing
After refrigerant is added, you should calculate the leak rate
as soon as yon can. If the system is Jeakmg above the
trigger rate, the law imposes strict deadlines for repairing
the leaks or retrofitting or retiring the system (see Modules
EandF). For example, if you wait three days to determine
the leak rate, there will be three less days available to
solve the problem. .
Purged Refrigerant
In calculating the leak rate, you may exclude purged
refrigerant that is destroyed. A destruction efficiency of at
least 98 percent is required, and there are monitoring,
recordkeeping, and reporting requirements (see Module G
for more information on recordkeeping and reporting).
Recordkeeping/Reporting
Keep records that show:
1. The date and type of service;
2. How much refrigerant was added; and
3. The date when the refrigerant was added.
It may be required and is always advisable to keep
records of toe fall charge and leak rate. For
additional recordkeeping requirements, see Module
G, Recordkeeping and.r sporting Requirements.
Octoberl995
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EPA 300-B-95-010
QUESTIONS
ANSWERS
If the leak rate is less than the
trigger rate (for example, a leak
rate of 5 percent per 12-month
period), am I required to fix the
leaks?
No, action Is required only when the trigger rate Is
exceeded.
If a system has a 100-pound
charge and is allowed a 35
percent leak rate, I dont have to
fix leaks until 35 pounds of
refrigerant have leaked out,
right?
Wrong. What matters Is the annual teak rate. Toe annual
leak rate is the amount of refrigerant mat would leak out in a
12-month period if you did nothing about it For example,
suppose you know your system lost 4 pounds of refrigerant in
January, and you discovered the losses by adding refrigerant
on the first day of February. At a leak rate of 4 pounds per
month, the system would lose 48 pounds of refrigerant in a 12-
month period (48 percent of UK full charge), so you are
already under a deadline to promptly repair the teaks or
retrofit or retire the system. You dp NOT get to wait until 35
pounds of refrigerant have already leaked out before you start
figuring out how to solve me problem. .
If the leak rate is higher than
the trigger rate (for example, a
leak rate of 50 percent per 12-
month period), am 1 in violation
by either (a) operating the
system while it is leaking; or (b)
adding refrigerant to keep the
system operating?
No. Adding refrigerant or operating a system with a leak rate
higher than the nigger rate is allowed temporarily. A
violation would only occur if you do not adhere to the
timelines and methods required for repairing, retrofitting or
retiring the system as described in Modules E and F.
When should I calculate the leak
rate?
Yon should calculate an annual leak rate each time yon add
refrigerant or any time sound professional judgment
radicates the system may be leaking more than the trigger
rate.
Do I have to check the leak rate
on a routine basis, such as every
month?
No.
Should I establish a process to
routinely look for leaks?
You are not required to establish such a process, but It may
be beneficial as an early detection of leaks. You must repair,
retrofit, or retire the system when you are operating above the
trigger rate.
If my system starts leaking above
the trigger rate, is that a
violation?
No. The law does.not prohibit leaks, provided you repair,
retrofit, or retire the leaking system by applicable
deadlines. If a system develops a leak, It Is not Illegal; the
regulations recognize that systems leak.
October 1995
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E. LEAK REPAIR
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EPA 300-B-95-010
DECISION POINT!
f
Repair
Retrofit
or
Retire
NOTE:
In the recycling regulations, "evacuate"
means to remove refrigerant from a
system. It is comparable to me term
"recover," which is a word commonly
used in the refrigeration field
Evacuate is not used in these
amendments in its technical sense of
removing moisture or metis from a
system.
£. LEAK REPAIR
Leak Repair Requirement
If a system is leaking above the trigger rate, leak repairs
are required within 30 days of discovery. Repairs must
bring die annual leak rate below the trigger rate. See
Module B, Applicability, for more information on trigger
rates. A leak repair timeline is presented on page E-7.
Leak repairs are not required if you retrofit or retire the
system (see Module F).
Certain activities require a certified technician, see page
E-6 for more details.
Situations Where More Than 30 Days Are Allowed
There are situations where additional time may be
permitted as discussed below. Also, see Module H,
System Mothballing.
Industrial Process Shutdown
When an industrial process shutdown is needed to repair
leaks from industrial process refrigeration systems, &
120-day repair period (rather than a 30-day period) is
allowed.
Unavailable Repair Parts or Other Regulations That
Require Additional Time
Additional time (beyond the 30- or 120-day time periods)
is allowed to conduct leak repairs if the necessary repair
pans are unavailable or if other applicable federal, state,
or local regulations make a repair within 30 or 120 days
impossible. EPA must be notified per 40 CFR 82.166(n)
if repairs cannot be completed within 30 or 120 days of
discovery. Only the additional time needed to receive
delivery of the necessary parts or comply with the
pertinent regulations will be permitted.
October 1995
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30O-B-95-010
Repair Verification: .
A new feature of the amendments is a requirement to
verify the success of leak repairs (when leak repairs are
required) for industrial process refrigeration systems.
Two tests, called "initial"and "follow-up" verification
tests arei required for each repair site. A successful test
verifies that a leak has been repaired.
What are these tests for?
The primary purpose of the initial verification test is to
verify mat a leak or leaks have been repaired .before
refrigerant is added back to the system. Even when the
system is not evacuated to complete repairs, initial and
follow-up verification tests are required. The primary
purpose of tic follow-up verification test is to re-verify
mat repairs continue to hold after the system is returned.
to its normal operating characteristics or conditions.
Initial Verification Test
An initial verification test must be conducted following
any leak repairs. A refrigeration system may not be
brought back on line (if it has been taken offline), unless
a) an initial verification test indicates that repairs have
been successfully completed or b) a decision to retrofit or
retire is made. The initial verification test mastbe
conducted before the replacement of the full charge of
refrigerant in systems (or isolated portions of systems)
from which the refrigerant has been evacuated. In
systems that have not been evacuated, the initial
verification test must be conducted as soon as practicable
after the repair work is completed.
October 1995
E-2
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EPA 300-B-95-010
Follow-up Verification Test
& follow-up verification test must be conducted:
within 30 days after the initial verification test,
when normal operating characteristics or
conditions have been maintained; or
within 30 days of bringing the system back on
line, if taken off line, and where the system is
operating at normal operating characteristics or
conditions.
Exception: In certain cases the results of & follow-up
verification test may be less reliable if the test is
conducted at normal operating characteristics or .
conditions* For example, repairs made to leaks inside
heat exchangers would not normally be accessible after
die system is operating. In mis kind of situation, based
an sound professional judgment, tint follow-up
verification test may be conducted prior to returning to
normal operating characteristics or conditions.
However, tbe follow-up verification test must be
conducted at or near the normal operating pressure where
DiHCticablc, ^^" aC or near the normal. oiKS9ratinfE
temperature where practicable.
Initial and Follow-up Verification Test
Methods
Initial sad follow-up verification tests may use any
method that meets sound professional judgment. Test
examples include, but are not limited to:
A soap bubble test; or
Electronic leak detectors; or
Ultrasonic leak detectors; or
A pressure test; or
A vacuum test; or
A fluorescent dye and black light test; or
An infrared test; or
A near infrared (back scatter absorption gas
imaging) test; or
Halon refrigerant gas detection methods.
October 1995
E-3
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EPA 30O-B-95-010
EPA Notification
Notify EPA per 40 CFR 82.166(n) within 30 days after
completion of any verification test where a time
extension is utilized (see Module G).
Unsuccessful Tests
If you have an unsuccessful follow-up verification test,
you must notify EPA and develop a retrofit or retirement
plan within 30 days of the failed test If it is going to take
you more man one year you must also submit me plan
(see Module F). If ihc follow-up verification test
indicates mat me repairs to the system have not been
successfully completed, the owner or operator is required
retrofit or retire the system. However, there are some
options where the owner or operator is relieved of the
obligation to retrofit or retire the system (see Module F).
QUESTIONS
ANSWERS
When am I required to perform
initial and follow-up verification
tests on industrial process
refrigeration?
Initial maAfolunv-up verification tats are required
following iemk repairs when the refrigerant leak rate for
a system EXCEEDS (be trigger rate. Initial sod follow-up
verification tests are not required for leak repairs on systems
leaking less than the trigger rate.
Are initial and follow-up
verification tests required for
systems other than industrial
process refrigeration?
Yes, but only for federally owned chillers.
What constitutes a successful
verification test?
A verification test Is successful when It shows that die teak
has been successfully repaired.
Are mere any EPA-approved leak
detection methods I can use?
EPA does not specify any particular method(s). You may
use any method that meets sound professional Judgment.
Do initial and follow-up
verification tests have to verify mat
you reduced the annual leak rate to
zero?
No. The purpose of the verification requirement is to evaluate
the success of the particular repair you made.
October! 995
E-4
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EPA 300-B-95-010
QUESTIONS
ANSWERS
Must I repair all leaks on a system
to comply?
Repair efforts most bring leak rates below the trigger rate.
Under what circumstances do I
have a 120-day repair period?
A 120-day repair period Is allowed when an industrial
process shutdown Is required to repair a Ieak(s) from
industrial process refrigeration systems. An industrial
process shutdown occurs when an industrial process
temporarily stops operating or manufacturing what is being
produced at the facility.
Do I have an unlimited number of
attempts to repair leaks within the
allowed tune?
Yes, you are allowed to try to repair the leak(s) as
many times as yon need to within the allowed tune
period. The last repair attempt within the allowed
time and the verification tests on that attempt are what'
matters. If the repair efforts occur during a time
extension, send the results of the last initial and
follow'up verification tests performed during the
repair period to EPA.
Bo all leak repairs have to be
performed by a certified
technician!
If refrigerant could reasonably be expected to be released,
then the procedure must be performed by a certified
technician. (See the checklist on page £-5 for more
information.)
Do the time extensions for
repairing leaks apply to systems
other than industrial process
refrigeration systems?
Yes, there may be time extensions available for federally
owned chillers. Tune extensions are not available for outer
refrigeration systems except for system mothballing (see
Module H).
Octoberl595
E-5
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EPA 300-B-95-010
REFRIGERANT RECYCLING AMENDMENTS
Activity (on ODS refrigeration system)
,
«
v&cuAuikg in* rcingcrani
A If4i«j* .fi In^rnnt
Adding refrigerant
Changing the oil
Adding oil
Replacing a gauge
Changing or calibrating a DP cell
i lymging g nreSSUrc-reilCI VoJVC
Drawing a sample OT mngeiani or MI
Helping dismantle a system for i*TTrril. if that person's work
may reasonably result in a release of refrigerant
Any of the tasks listed above, jiiTformd under the direct
supervision of a certified technician
Maintenance mat would not reasonably release refrigerant
(such as painting; leak-checking; tone electrical work: and
some insulation work)
Fixing leaks by tightening nuts or boh*, if no specific reason to
think the activity may go wrong and increase the rate of release
evacuated to the extent required by $ 82.156
Is technician^
certification required?
YES2
v
s
s
s
v
s
s
V
s
NO
^
V
V
1 Technician Certification Amendment to me National Recycling Program FR 55912 (11/9/93) (see Module K)
2 A certified technician is required unless the system (or isolated portion) has been evacuated to the level listed
in the rule
October 1995
E-6
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Regulator
crm* t«r«
October 1QQS
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EPA 300-B-95-010
3 For Leak Repair
Bu«17 tat «raecpDam(M0 Modi* F)
Bo* §17 WK) Box f3S rataram 0* r
nd UmMM (in Moduto F)
E-7
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F. RETROFIT AND RETIREMENT
OF LEAKING REFRIGERATION SYSTEMS
-------
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EPA 300-B-95-010
DECISION POINT!
f
Repair
Retrofit
or
'Retire
EXCEPTION:
If yon switched from repair to retrofit
or retire, you must notify EPA within
30 days from the day you switch.
However, you are still under me
12-month period provision from the time
the leak was discovered.
More time may be available.
R RETROFIT AND RETIREMENT OF
LEAKING REFRIGERATION
SYSTEMS
Owners or operators of commercial refrigeration
equipment, industrial process refrigeration systems,
and/or all other systems normally containing more than
SO pounds of refrigerant are not required to repair leaks
If they develop, implement, and complete a 12-month
retrofit or retirement plan. Three conditions, however,
must be met:
1. The retrofit or retirement plan must be developed
within 30 days of detecting the leak and a copy
must be kept on site; and
2. The plan must be dated and the original made
available for EPA inspection upon request; and
3. Retrofit or retirement activities must be
completed within a 12-month period of the plan's
date.
Time Extensions for Retrofit or Retirement of
Industrial Process Refrigeration Systems
Additional time beyond the initial 12-month period to
complete retrofit or retirement activities is available to
owners or operators of industrial process refrigeration
systems if any of the following circumstances occur
a. A delay is caused by the requirements of other
applicable federal, state, or local regulations. In
mis case, additional time to the extent reasonably
necessary will be allowed; or
b. A suitable replacement refrigerant is not
available. In this case, additional time to the
extent reasonably necessary will be allowed; or
c. The unit is custom-built and the supplier of the
system or a critical component has quoted a
delivery time of more man 30 weeks from when
the order is placed. In this case, an additional
12-month period is allowed. To receive this
October 1995
F-l
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EPA300-B-95-010
An industrial process
shutdown does not extend the
deadline for notification to
EPA if more time is needed.
Even MORE TIME may be
available!
If you think the situation in
bullet #2 will apply, you will
need to tell EPA how you
will make the determination
in your submission to EPA
notifying them of the failed
follow-up verification test.
(The amendment refers to
this as providing parameters.^
The parameters you submit
'will be considered acceptable
unless EPA notifies you
within 30 days. Otherwise,
you must use parameters that
EPA provides.
extension, you must notify EPA within six
months of the expiration of the 30-day period
If the owner or operator of a custom-built
industrial process refrigeration system has
received an additional 12-month period for
retrofit or retirement activities, but still requires
more time to complete the retrofit or retirement
(beyond the additional time already allowed),
then a request for additional time may be
submitted to EPA.
If you mink you qualify for additional
time, you must notify EPA. See
Module G, Recordkeeping and
Reporting, for more information.
Relief From Obligation to Retrofit or Retire
As mentioned in the leak repair module, sometimes a
failed follow-up verification test can result in a
requirement to retrofit or retire a system. Yon may be
relieved of this requirement If either of the following
efforts is successful:
1. Make second efforts to repair the same leaks that
were me subject of the first repair attempt.
Repairs must be completed within 30 days of the
failed test (120 days where the repair requires an
industrial process shutdown). Second repairs are
subject to the same verification requirements as
the first efforts (i.e., initial and follow-up
verification tests). If the second follow-up '
verification test is successful, EPA must be
notified per 40 CFR 82.166(n) within 30 days of
its completion and the owner or operator is no
longer required to retire or retrofit the system.
2. Within 180 days of a fBfted follow-up verification
test associated with the initial repair efforts,
establish that the leak rate is below the trigger
rate. Within 30 days after that determination,
send a new notification telling EPA mat you are
now below the nigger rate (see Module G).
October 1995
F-2
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EPA 30O-B-95-010
QUESTIONS
ANSWERS
I have a custom-built industrial
process refrigeration system leaking
R-22 at over 35 percent per 12->
month period. I know that the leaks
cannot be repaired. In developing
the retrofit or retirement plan for this
refrigeration system, I will need
more than a 12-month period
because a critical component (the
compressor) requires more than 30
weeks deli very time. How do I
obtain more time to retrofit or retire
the system?
Within sfi months of 30 days after discovery of the teak,
notify EPA that yon need the second 12-month period and
why and Include the estimate for completion of the work.
(See Module G for rccordkeeping or reporting information.)
I followed the procedures for
obtaining the second 12-month
period to complete my retrofit or
retirement. Several months later, I
Notify EPA within 30 days of discovery of the new
completion date.
was notified by the manufacturer of
the critical component that my
original completion date will take 60
days longer than originally quoted.
What do I do?
What happens if I follow me
procedures for obtaining a second
12-month period to peribiiu a retrofit
or retirement, and then I am told by
the manufacturer of a critical
component mat the delivery will not
allow me to complete my retrofit
within two 12-month periods?
Yon have until the end of the ninth month of the second
12-month period to submit a request to EPA for additional
tune. .
October 1995
F-3
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EPA 300-B-95-010
QUESTIONS
ANSWERS
I have developed a retrofit plan and
notified EPA of a failed/o//ow-Mp
verification test. During the second
repair effort, however, I managed to
successfully repair the same leak(s).
Must I implement the retrofit plan?
No, yon are relieved of the obligation to retrofit bat yon
most notify EPA within 30 days.
According to the amendments,, I
am relieved of the obligation to
retrofit or retire an industrial
process refrigeration system if I
verity that the leak rate is below
the trigger rate within 180 days
after the failed follow-up
verification test. How is this done?
1. Determine the parameters yon "jH use to establish the
teak rate. Submit those parameters to EPA for
approval (as described in Module G, Recordkeeping and
Reporting). . '
2. Take any farther action!
try to reduce leaks.
Further action to reduce leaks might include repairing
smaller leaks Oat may not have been repaired previously:
replacing piping systems (or welding the joints) to
eliminate screwed or flanged connectors; or replacing
major components for which repair has pioveu
impractical, m some cases, me leak rate may be below the
Bigger rate without further action, even though one or
more of the original repairs did not pass &follow-tg>
verification test.
3. Determine the new leak rate, using the approved
parameters. For example, this-may include filling the
system, waning for a defined period of time, and seeing
how much refrigerant is needed to fill the system again.
NOTE: If yon are unable to verify that die leak rate Is
below the trigger rate by the deadline, yon win have used
op a substantial portion of the 12-month period to retrofit
or retire the system. Yon do fig get an extra 180 days
added to that period.
October 1995
F-4
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El
Regulatory Timeline & Checklist for Retrofit & Retirement Activities
Deadline to develop a retrofit
. or retirement plan
Deadline to notify EPA if
additional time will be needed
to complete the retrofit or
retirement due to delays
occasioned by specific events
Last day for EPA to notify
owners/operators of its final
determination regarding the
request for additional time
where an EPA r
required
se is
« Deadline to complete the
front or retirement (unless
the refrigeration system is an
tndustruu process ttfngciutum
system or a federally owned
chiller AND additional time
has been permited).
Last day to submit requests for
additional time beyond what
has been permited.
Last day for EPA to reject
request for additional time
beyond that which has already
been granted
End of additional one-year
period & beginning of further
additional time period to
complete the retrofit or
retirement
Leak Discovered
1
Beginning of initial 12-month
period
End of first 12-month period
End of second 12-month
extension (24 months from
leak detection)
Fill in your
dates below
(date)
30 Days after leak discovery or
after a failed/b/ioip-iip vcrf. test
(date)
6 Months after 30 day period
following leak discovery
(date)
60 days from submittal of request
for additional time
(date)
12 Months from the date of the
retrofit or retirement plan
(date)
9 Months into the first additional
(date)
30 Days from receipt of request for
further additional time
(date)
24 Months from the date of the
retrofit or retirement plan
(date)
Further additional time period (beyond 2 years) to complete the retrofit or retirement for industrial
process refrigeration systems.
fVtrtber 1995
F-5
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-------
G. RECORDKEEPING AND REPORTING
REQUIREMENTS
-------
-------
EPA 300-B-95-010
It is advisable in ALL cases to
maintain records of the leak rate
and full charge.
When servicing systems normally
containing 50 pounds or more of
refrigerant you are always required to
keep the following information:
date & type of service;
quantity of refrigerant added;
when refrigerant purchased;
when refrigerant added in cases
where the owner added their own
refrigerant.
G. RECORDKEEPING AND
REPORTING REQUIREMENTS
Records reportable to EPA must be maintained on site for
three years. Any reporting requirements must be submitted
to the following address:
608 Recycling Program Manager
Stratospheric Protection Division
6205J
US Environmental Protection Agency
401 M Street, SW
Washington,DC 20460
Leak Repair (Industrial Process Refrigeration)
If you complete all the required repairs successfully without
needing additional time, die amendments do not require any
new recordkeeping or reporting. This means mat no new
records or reports are required if the repairs are (1)
completed within 30 days (120 days if an industrial process
shutdown is necessary), and (2) pass initial BD& follow-up
verification tests. If more time is needed, or if the repairs
do not pass follow-up verification tests, additional
recordkeeping and reporting an required These
requirements are described below.
1. If any of the repairs have failed the follow-up
verification test.
a) You must keep on-site documentation of the
following' information and report it to EPA within
30 days after the faftcdfollow-up verification test:
the identification of the facility;
the leak rate;
the method used to determine the leak rate and
full charge;
the date of discovery that the leak rate was
above the trigger rate;
the location of leaks to the extent determined
to date;
Octobetl995
G-l
-------
EPA 300-B-95-O10
any repair work that has already been
completed; and the date when that work was
completed;
foe date($), type(s) and results of the failed
foUaw-up verification test(s); and
if you intend, or think you could eventually
attempt to verify within 180 days that the leak
rate is below 35 percent, you must provide
EPA die parameters on how die leak rate will
be determined EPA will inform you if they
object to your parameters (see Module F).
b) You must develop a retrofit or retirement plan
within 30 days after the faftedfollow-up
verification test. You must keep the plan en-site
and make the original available to EPA upon
request, but you do not have to submit the plan to
EPA unless you will need an extension of time to
finish the retrofit or retirement (beyond one year
from the date you develop your plan).
2. If you need additional time to repair leaks due to other
regulatory delays, or because delivery of necessary
repair parts will take too long, then:
a) Within 30 days after Tnayjnp the determination fbtt
you need extra time, you must keep on-site, and
report to EPA:
the identification of the iacility;
the leak rate;
me method used to determine the leak rate and
full charge',
the date of discovery mat the leak rate was
above the trigger rate;
the location of leaks to the extent determined
to date;
any repair work that has already been
completed; and the date when that work was
completed;
documentation of the reasons why more than
30 days (or 120 days, if an industrial process
shutdown is necessary for repairs) are needed
to complete the work; and
an estimate of when the repairs will be
completed.
G-2
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EPA 300-B-95-010
NOTE: You only get the amount of
extra tine that is reasonably
b) Notify EPA if you discover that the repairs will
take longer than you have previously told EPA.
Send fliis notification within 30 days after
discovering the need for more time. Include a
new estimate of when the work will be completed.
Retrofit or Retirement (Industrial Process
Refrigeration)
If you complete successful retrofit or retirement within the
normal one-year period, die amendments do not require any
new recordkeeping or reporting. However, you are still
required to develop and maintain, on-site, a retrofit or
tplan.
The amendments have some additional requirements for
thr'tiTW where you need an extension of time to complete
ihe retrofit or retirement, and for situations where you are
relieved of the duty to retrofit or retire a system. These are
I below.
1. If you are completing your retrofit or retirement within
the 12-month period, you must:
maintain the retrofit Of retirement plan on-site;
and
make the original plan available to EPA upon
request
2. If you will need an extension of time because of delays
caused by other regulations, or because mere is no
suitable replacement refrigerant, then:
. a) Notify EPA within six months after the end of the
30-day period following discovery of the excessive
leak rate. The notification must include the
following information, which must also be retained
on-site. EPA will respond within 60 days, telling
you whether they agree that you are entitled to the
extra'time you have requested.
the identification of the facility;
the leak rate;
the method used to determine the leak rate and
foil charge;
October 1995
G-3
-------
. . the date when the excessive leak rate was
discovered;
the location of leaks to the extent
determined so far;
any repair work that has already been
completed and die date of completion;
the reasons why you need an extension of
time, and an estimate of when the retrofit
or retirement will be completed. Include
" records sufficient for EPA to determine
that extra time is needed and bow much
. time; and
a copy of your retrofit or retirement plan,
b) If you have already notified EPA, and then you
discover that me work will take longer to complete
man you have previously told EPA, you must
, submit documentation with me reasons within 30
days after discovering that more time is needed
Include a new estimate of when the work will be
completed ft"d the date of your original notification
to EPA.
3. If you have been required to follow the retrofit or
retirement timeline because repairs failed & follow-up
verification test, men:
a) If you complete the retrofit or retirement within
12 months after the 30 day period from '
discovery of the leak, mere are no additional
reporting mjuu^iitcuts;
b) If you mtend to be released from me requirement to
retrofit or retire the system by demonstrating
(within 180 days after the failed/o//o>v-j/p
verification test) that you have brought the leak rate
below me trigger rate, then you must do three
things:
Within 30 days after the failed test(s), submit a
plan to fix other outstanding leaks for which
repairs, if any, are planned but not yet
completed to achieve an acceptable leak rate;
and
G-4
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EPA 300-B-95-010
Include, with the plan described above, a
description of how you will determine whether
the leak rate is below the trigger rate. Your
proposed method is acceptable unless EPA
objects within 30 days after receiving your plan.
If EPA objects and provides a different method,
. follow that method; and
After you have determined the new leak rate, if
it is less than the trigger rate notify EPA within
30 days after that determination. Tell them that
the leak rate is below the trigger rate, and tell
mem you are no longer required to retrofit or
retire the system. If part of your plan was to
complete and test further repairs, or to re-test .
existing repairs, include the date(s), type(s) and
results of foe follow-up verification tests.
c) If you are released from the requirement to retrofit
or retire the system because the second repair
efforts (within 30 or 120 days after the failed test)
have passed initial and follow up verification tests,
you must notify EPA within 30 days after
completion of the successful tests. Notify EPA that
your second repair efforts were successful, and mat
you are no longer required to retrofit or retire the
system.
Include in your notification to EPA:
the identification of the fecility;
a description of the refrigeration system;
me date of your original notification to EPA; and
the date work was completed on the system.
4. If your system is custom-built and you want the one-
year extension, men notify EPA (see Module F). The
notification is due within six months after the end of the
30 day period following discovery of the excessive leak
rate. The notification must include the following
information, which must also be retained on-site.
the identification of the facility and the owner or
operator;
a description of the refrigeration system;
the leak rate;
October 1995
G-5
-------
5.
the method used to determine the leak rate and
foil charge;
the date when the excessive leak rate was
discovered;
the location of leaks to the extent determined so
fir,
* any repair work that has already been completed
and the date of completion;
the reasons why you need an extension of time.
Include records sufficient for EPA to determine
mat you qualify'for the extra year. This means
you must demonstrate that me new or retrofitted
system is custom-built, and mat a vendor has
quoted a delivery time of more man 30 weeks
from when an order is placed, for the system or a
critical component,
an estimate that the retrofit or retirement will be
completed by the end of the one-year extension;
a copy of your retrofit or retirement plan; and
the date of your original notification to EPA if
any.
If your system is custom-built, you have already received
one extra year, and you discover mat you will need more
time (beyond a total of two years), men you must request
additional time. The request must be sent to EPA before
the end of the ninth month of the second year. It must
contain relevant revisions of the information you
submitted when you sent the notice to get the first extra
year. Notify EPA how much more time you will need,
and the reasons why. If EPA does not object within 30
days after receiving your request, you are granted the
additional time.
October 1995
G-6
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EPA 300-B-95-010
Full Charge
If the./!*// charge of an industrial process refrigeration
system is determined by establishing a range or combining
me use of an established range with any other acceptable
method (discussed in Module C), records must be
These records must include:
»
Identification of the owner or operator of the system;
Location of the system;
Original range for the foil charge of the system, its
midpoint, and how the range was determined;
Any and all revisions of ihtjull charge range and
bow they were determined; and
Dates such revisions occurred.
Purged Refrigerant
Owners or operators who wish to exclude purged
refrigerants that are destroyed from annual leak rate
calculations must maintain records to support the amount of
refrigerant claimed as sent for destruction. Records must be
based on a monitoring strategy that provides reliable data to
demonstrate that the amount of refrigerant sent for
destruction corresponds with the amount of refrigerant
purged. Records must include ALL of the following:
Bow rate;
Quantity oc concentration of tile refrigerant in the
vent stream;
Periods of purge flow;
Identification of the facility and a contact person,
including the address and telephone number;
General description of the refrigeration system,
focusing on aspects of the system relevant to the
purging of refrigerant and subsequent destruction;
Description of the methods used to determine the
quantity of refrigerant sent for destruction and type
of records that are being kept by the facility;
Frequency of monitoring and data-recording; and
Description of the control device and its destruction
efficiency.
October 1995
G-7
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QUESTIONS
ANSWERS
Do I need to maintain records and
submit information every time a leak
is found and repaired?
No, the law does not require recordkeeping for
the foDowIng scenarios:
If you are below the trigger rate, you do not
need to maintain or submit records (except the
normal servicing records required by the
original refrigerant recycling regulations).
If you repair a leak within 30 or 120 days (if
applicable) of discovery, you are required to
perform verification tests but are not required
to submit records.
If you are above me trigger rate and require an
you must maintain and submit records.
Do I always need to maintain records
and submit information to retrofit or
retire industrial process refrigeration
systems? .
Yes and no. If you can retrofit or retire the affected
system within a 12-month period, records must be
maintained, but information does not need to be
submitted to EPA. In this case, the owners or operators
must develop a 12-month retrofit or retirement plan
within 30 days of discovering a leak rate higher than 35
percent. .The plan, or a legible copy of the plan, must be
kept at the site of theleaky system. The original must be
available for EPA inspection on request The plan must
be dated and all work under the plan must be completed
within a 12-month period of the plan's date. If more man
a 12-month period is necessary mere will be additional
recordkeeping and reporting requh
How long must I keep the records?
Three years.
Am I allowed to update a pre-existing
retrofit or retirement plan if it was
developed in advance of my
discovering a leak rate above the
trigger rate?
Yes.
If I have submitted information
indicating that my company would
retrofit a leaky industrial process
refrigeration system, but the leak was
successfully repaired .during a second
repair effort, what should I do?
Yon are not required to retrofit or replace the
affected system If second efforts to repair the same
leaks that were subject to the first repair efforts are
successfully completed within the 30- or 120- day
period. You must notify EPA within 30 days of the
successful/0//0HH verification test.
October 1995
G-8
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EPA 30O-B-9S-O10
QUESTIONS
ANSWERS
Will EPA notify me of the acceptance
or denial of a request for additional
time to retrofit or retire our industrial
process refrigeration system?
The answer depends on why additional time was
requested. EPA will notify the owner or operator
within 60 days:
If additional time was requested because of
delays caused by other federal, state, or local
regulations; or
If an acceptable alternative refrigerant with a
lower ozone-depleting potential is not available.
The extension will be considered granted without
notification from EPA when ALL the following criteria
ate met:
1.
3.
Additional time is requested because the new or
the retrofitted industrial process refrigeration
system is custom-built; and
The supplier of the industrial process
refrigeration system/ or one or more of its
crucial components, has quoted a delivery
time of more than 30 weeks from when the
order was placed; and
The owner or operator notifies EPA within six
months of the 30-day period following the
original discovery of a leak rate higher man 35
4. The owner or operator maintains adequate
records to allow a determination that the criteria
are met
In those cases where more than two years are needed and
a timely request is made, the request is considered
granted unless EPA objects to the request within 30
days.
October 1995
G-9
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SYSTEM MOTHBALLING
-------
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EPA300-B-95-010
Important Note:
System mothballing requires the
refrigerant to be removed from the
If the owner or operator intends to make
repairs to the system that require
opening die system, die refrigerant
must be removed tome required
evacuation levels for that refrigerant
before the system is opened.
H. SYSTEM MOTHBALLING
System mothballing, for the purposes of these
amendments, is the intentional shutdown of a
refrigeration system for an extended period of time,
where the refrigerant has been evacuated from the system
to at least atmospheric pressure.
These amendments recognize that when a refrigeration
system is in a mothballed condition, refrigerant leaks that
existed when the system was operating have effectively
been stopped because the system has been evacuated.
Therefore, the amendments allow the time-related
requirements for repairing, retrofitting, or retiring a
leaking system to be temporarily suspended while the
system is mothballed. The time-related requirements
resume on the day the system is brought back on line and.
is no longer considered mothballed Leak repairs
.following mothballing on industrial process refrigeration
systems are still subject to initial aa& follow-up
verification tests.
Applicability
When a system is mothballed, the time suspensions are
available for ajl types of systems, including commercial,
industrial process, and any other systems containing more
man 50 pounds of refrigerant Time suspensions under
system mothballing apply to all time-related requirements
for repairing leaks or replacing, retrofitting, or retiring a
system, including time extensions mat may be allowed in
specific circumstances for industrial process
refrigeration systems.
Example of System Mothballing
If a comfort-cooling system with over SO pounds of
refrigerant has a leak rate of more than 15 percent per 12-
month period, the leak or leaks must be repaired within
30 days of discovery or the system mtist be retrofitted or
retired within a 12-month period. However, if after
October 1995
H-l
-------
EPA 30O-B-95-010
discovery of the exceedance of the leak rate, the owner of
the system voluntarily mothballs the system for a period
of time, the requirement to repair leaks or retrofit or retire
me system is suspended for that same time period For
example, if the system operated for five days after
discovery of the exceedance of the leak rate and then was
shut down and mothballed for two months, when the
system returned to operating, the owner would still have
25 days to either repair the leaks or develop a 12-month
retrofit or retirement plan.
QUESTIONS
ANSWERS
Does mothballing mean I just shut
down my system and don't use it
for a while?
No. There is an additional requirement that the
refrigerant must be evacuated to at least
atmospheric pressure. This ensures that there is
practically no potential for refrigerant to escape fr
the system while it is down.
Am I allowed to conduct leak
repairs on a system that is
mothballed? How long do I have
to conduct these repairs?
Yes, repairs may be conducted white a system b
mothballed, and there is no time limit to mate the
repairs. If the system must be opened to conduct
the repairs, the refrigerant must be removed to the
required evacuation levels first Also, for industrial
vfiigeration systems, applicable verification
tests on the leak repairs must be conducted.
Do I have to report to EPA if I'm
temporarily mothballing a system
that's leaking above the trigger
rate?
tiQ, system mothbaBing toes not require a report to
EPA. However, die owner or operator will need to
report to EPA if the decision to temporarily mothball
a system results in delaying an estimated completion
date that has previously been submitted to EPA for
repairing, retrofitting or retiring the system.
Suppose I write up a 12-month
retrofit plan within 30 days of
discovering an excessive leak rate
on a system, and, during mat 12-
month period, I mothball the
system for a period of three
months. When must the retrofit be
completed?
If the system was mothballed for three months and
no bther time extensions apply, the retrofit must be
completed within 15 months of the plan's date. If
a plan has been submitted to EPA, then yon must
notify EPA of the extension of the completion date.
October 1995
H-2
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EPA 300-B-95-010
QUESTIONS
ANSWERS
Is the deadline for verification
testing suspended while a system is
mothballed? For example, if I
have an industrial process
refrigeration system with a leak
rate above the trigger rate, and I fix
the leaks while the system is
mothballed, may I continue to keep
the system mothballed for four
more months without performing
verification tests?
Yes. All deadlines arc impended during
ntomballing. In the example you have given, initial
verification tests could be performed at any time
before bringing die system on-line.' Follow-up
verification tests are not required, and usually are not
allowed, while the system is mothballed. If the repairs
fail initial verification tests, you are allowed to
continue your repair efforts while the system is still
mothballed. However, the repairs must pass initial
verification tests before the system is brought on-line,
unless you plan to retrofit or retire the system. When
you bring the system out of a mothballed state, the
deadline for performing follow-up verification tests .
would begin. In the example you have given, you
would have up to 30 days to perform those tests.
Please remember mat, if you have evacuated the
system only to Atmospheric pressure dunng
mothballing, a deeper vacuum will generally be
required before you open the mothballed system to
vpairs.
October 1995
H-3
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-------
L OIL CHANGES
-------
-------
EPA 300-B-95-010
Why are we talking about oil
changes? That has nothing to do
with leak repair!
Maximum allowable pressure:
Spsig
NOTE: Changing oil at higher
than S psig is considered a violation
of die prohibition against
knowingly venting a refrigerant
NOTE: The refrigerant recycling
amendments generally do not
permit the use of nitrogen to
pressurize low pressure systems or
receivers.
I. OIL CHANGES
EPA's recent refrigerant recycling amendments deal
with leak repair. However, they also address
procedures to minimize emissions of refrigerant
during oil changes. Many companies and technicians
have been interested in this topic, so. it is discussed
here.
The oil in a refrigeration system may contain large
amounts of refrigerant EPA requires a reduction in
pressure prior to an oil change so that the bulk of me
refrigerant is recovered. The maximum pressure allowed
is 5 psig. This greatly reduces refrigerant emissions
while still allowing a slight positive pr
oil from the compressor.
to force the
There are two acceptable procedures to assure recovery of
refrigerant:
*
1. Evacuate (or pressurize) the refrigeration system,
. or isolated portion, to a pressure no higher than 5
psig and then remove the oil; or
2. Drain the oil into a system receiver to be
evacuated (or pressurized) to a pressure no higher
than 5 psig.
These procedures np^irpiT^ the loss of refrigerant from:
a) the oil, and b) the ulterior of the refrigeration system as
the oil comes out EPA allows a slight positive pressure
to help expel the oil.
October 1995
1-1
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J. GLOSSARY
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-------
EPA300-B-95-010
Appliance
Class I refrigerant
Class JI refrigerant
Commercial refrigeration
Critical component
Custom-built
J. GLOSSARY
The glossary provides important terms used in this
guidance.
Any device that contains and uses a class I or class n
substance as a refrigerant and is used for household,
commercial, or industrial purposes, including any air
conditioner, refrigerator, chiller, or freezer. Essentially
any sort of cooling equipment that uses a class I or class
n substance as a refrigerant is an "appliance.*1
Most Class I substances are usually chlorofluorocarbons
(CFCs). A complete listing of class I substances can be
found at 40 CFR Part 82, Subpart A, Appendix A.
Class n substances are hydrochlorofluorocarbons
(HCFCs). A complete listing of class 0 substances can
be found at 40 CFR Part 82, Subpart A, Appendix B.
Refrigeration appliances utilized in the retail food and
cold storage warehouse sectors. Retail food includes the
refrigeration equipment found in supermarkets,
convenience stores, restaurants, and other food service
establishments. Cold storage includes the equipment
used to store meat, produce, dairy products, and other
perishable goods.
A component without which an industrial process
refrigeration system will not function, will be unsafe in
its intended environment, and/or will be subject to.
failures mat would cause the industrial process served by
the system to be unsafe.
The system or any of its critical .components cannot be
purchased and/or installed without being uniquely
designed, fabricated, and/or assembled to satisfy a
specific set of industrial process conditions.
October 199S
1-1
-------
EPA 30O-B-95-010
Follow-up verification test
Full charge
Those tests that involve checking the repairs within 30
days of returning the system to normal operating
characteristics or conditions. Follow-up verification tests
for equipment from which the refrigerant charge has been
evacuated means a test conducted after the system or
portion of the system has resumed operation at normal
operating characteristics or conditions of temperature and
pressure, except hi cases where sound professional'
judgment dictates that these tests will be more
meaningful if performed prior to the return to normal
operating characteristics or conditions. A follow-up
verification test for a system that has' not been evacuated
means a reverification test conducted after die initial
verification test and usually within 30 days of normal
operating conditions. Where a system is not evacuated, it
is only necessary to conclude any required changes in
pressure, temperature* or other conditions to return the
system to normal operating characteristics or conditions.
The amount of refrigerant required for normal operating
characteristics or conditions of industrial process '
refrigeration systems and certain federally-owned
appliances as determined using one or a combination of
the following four methods:
1 . Using the system manufacturer's determination of
the correct full charge for the system;
2. I>temmiing me full charge by appropriate
calculations based on component sizes, density of
refrigerant, volume of piping, and all relevant
3.
4.
Using actual measurements of die amount of
refrigerant added or evacuated from an industrial
process refrigeration system; and/or
Using an established range based on the best
available data, regarding the normal operating
characteristics and conditions for the system,
when the midpoint of the range will serve as the
full. charge and where records are nmjntain^ in
accordance with 40 CFR 82.166 (q).
October 1995
J-2
-------
EPA 300-B-95-010
Industrial process refrigeration
Industrial process shutdown
Initial verification test
Normal operating characteristics
or conditions
Opening
Complex, customized systems used in the chemical,
pharmaceutical, petrochemical, and manufacturing
industries. These systems are directly linked to the
industrial process. This sector also includes industrial ice
machines, appliances used directly in the generation of
electricity, and ice rinks. Where one appliance is used for
both industrial process refrigeration and other
applications, it will be considered an industrial process
refrigeration system if SO percent or more of its operating
capacity is used for industrial process refrigeration.
An industrial process or facility temporarily ceases to
operate or manufacture whatever is being produced at the
facility.
Those leak tests that are conducted as soon as practicable
after the repair is completed. If the system or isolated
portion is evacuated, it means a test conducted prior to
replacing of the full refrigerant charge and before the
system or portion of the system has reached operation at
normal operating characteristics or conditions of
temperature and pressure. An initial verification test
conducted without the evacuation of the refrigerant
charge means a test conducted as soon as practicable after
the completion of the repair work.
Temperatures, pressures, fluid flows, speeds, and other
characteristics that would nonnally be expected for a
given process load and ambient condition during
operation. Normal operating characteristics or conditions
are marked by the absence of atypical conditions
affecting the operation of the refrigeration system.
Any service, maintenance, or repair on an appliance mat
would release class I or class n refrigerant from the
appliance to the atmosphere unless the refrigerant were
recovered previously from the appliance. Connecting and
disconnecting hoses and gauges to and from the appliance
to measure pressures within the appliance and to add
refrigerant to or recover refrigerant from the appliance
shall not be considered "opening."
October 1995
J-3
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EPA 30O-B-95-010
Reclaim refrigerant
Recover refrigerant
Refrigerant circuit
Soundprofessionaljudgment
Suitable replacement refrigerant
System mothballing
Reprocess refrigerant to at least the purity specified in
appendix A to 40 CFR part 82, subpart F (based on ARI
Standard 700-1993, Specifications for Fluorocarbon and
Other Refrigerants) and verify this purity using die
analytical methodology prescribed in appendix A. In
general, reclamation involves the use of processes of
procedures available only at a reprocessing or
manufacturing facility.
To remove refrigerant in any condition from an appliance
without necessarily testing or processing it in any way.
The parts of an appliance that are normally connected to
each other (or are separated only by internal valves) and
are designed to contain refrigerant
A decision-making process mat uses a combination of
logic and operational experience, with methods of
calculation that are practical, based on training,
experience, and education.
A refrigerant acceptable under section 612(c) of the
Clean Air Act Amendments of 1990 and all regulations
promulgated under that section, and compatible with
other materials which it may come into contact. The
SNAP-approved refrigerant must also be able to achieve
the temperatures required for the affected industrial
process in a technically feasible manner.
NOTE: The Significant New Alternatives Policy (SNAP)
program implements section 612 of the amended Clean
Air Act of 1990. SNAP requires EPA to evaluate
substitutes for ozone-depleting substances and disapprove
the use of unacceptable substitutes. SNAP generates lists
of acceptable and unacceptable substitutes for each of the
major industrial use sectors.
Intentional shutdown of a refrigeration System
for an extended period of time by the owners or operators
of that facility, where the refrigerant has been evacuated
from the appliance, or the affected isolated section of the
appliance, at least to atmospheric pressure.
October 1995
J-4
-------
EPA 300-B-95-010
Technician
Any person who performs maintenance, service, or repair
that could be reasonably expected to release class I or
class H refrigerants from appliances, except for MVACs,
into the atmosphere. Technician also means any person
who performs disposal of appliances, except for small
appliances, MVACs, and MVAC-like appliances, that
could be reasonably expected to release class I or class H
refrigerants from the appliances into the atmosphere.
Performing maintenance, service, or repair, or disposal
could be reasonably expected to release refrigerants only
if the activity is reasonably expected to violate the
integrity of the refrigerant circuit Such activity includes
attaching and detaching hoses and gauges to and from the
appliance to add or remove refrigerant or to measure
pressure and adding refrigerant to and removing
refrigerant from the appliance. Activities such as
painting the appliance, rewiring an external electrical
circuit, replacing insulation on a length of pipe, or
tightening nuts and bolts on the appliance are not
reasonably expected to violate the integrity of the
refrigerant circuit. Performing maintenance, service,
repair, or disposal of appliances that have been evacuated
pursuant to 40 CFR 82.156 could not be reasonably
expected to release refrigerants from the appliance unless
the maintenance, service, or repair consists of adding
refrigerant to the appliance. Technician includes but is
not limited to installers, contractor employees, in-house
service personnel, and in some cases, owners or
operators.
October 1995
J-5
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K. REFERENCES
-------
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EPA 30O-B-95-010
K. REFERENCES
STRATOSPHERIC OZONE INFORMATION HOTLINE: 800-296-1996
The hotline is open between 10:00 ajn. and 4:00 p jn. Eastern tune.
STRATOSPHERIC PROTECTION DIVISION'S INTERNET HOME PAGE:
HTTP:\\WWW£PA.GOV\DOCS\OZONE\iNDEXJJTML
STRATOSPHERIC OZONE PROTECTION RULEMAKING SUMMARY
Section 608-National Recycling Program
58 FR 28660 (5/14/93)
1) Technical Amendments to the National Recycling Program:
FR 42950 (8/19/94)
' Amends the final rule by making clarifications and:
2) Technician Certiftcatte* Amendment to the National Recycling
Program: FR 55912 (11/09/94)
Establishes the process by whichEPA can review and approve
voluntary teduticum certification programs that apply by
December 9,1994 to be "grandfethered"
Clarifies the scope of the technician certification requirement and
provides a limited exemption from certification for apprentices.
Section 612 - Significant New Alternatives Policy
59 FR 13044 (3/18/94)
Establishes a process for continuing review of substitutes to determine their
acceptability and provides a petition process to add and delete substances from
published lists. Includes initial lists of acceptable and unacceptable
. substitutes.
STRATOSPHERIC OZONE PROTECTION FINAL RULE SUMMARY
EPA-430-f-93-010
A feet sheet that provides an overview of the refrigerant recycling
requirements of section 608 of the Clean Air Act, 1990, as amended, including
final regulations published on May 14,1993 (58 FR 28660) and the
prohibition on venting that became effective on July 1,1992.
NOTE: Additional fact sheets on individual rules are also available through
the Hotline.
October 1995 . K-l
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EPA 300-B-95-010
EPA APPLICABILITY DETERMINATIONS
*
Guidance prepared by the regulatory agency at the request of an outside party
regarding;the applicability of a regulation to a specific feciHty/umtforocess.
Applicability determinations are made available through cither the Technology
Transfer Network (TTN) or the Stratospheric Ozone Information Hotline. The
TIN can be accessed via computer modem at (919) 541-5742; for more
information regarding the TTN, call (919) 541-5384 between 1:00 pjn. and
5:00 pjn. Eastern time.
October 1995
K-2
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APPENDIX:
REFRIGERANT LEAK REPAIR
FLOW CHART
-------
-------
Refrigerant Leak Repair Flow Chart
The following flow chart is divided into six pages, and is constructed so that it may be viewed as
a whole by placing the pages in the arrangement shown below.
Pagel
Page 4
Page 2
PageS
Page 3
Page 6
Where appropriate, the flow chart includes references to 40 CFR from which the statements in
the boxes are derived.
-------
-------
Refrigerant Leak Repair Flow Chart
Page 1 of 6
bmeiiomaleftjigeof
the refrigeration
system > 5011s?
Ootopg.2
System is amide the scope of
this rale. No cttai tnfliirfd
C.1960K5N
End
TriBcrfctknteis
)SK molly.
IBJSKIXD*
Repair leaks mfficnat to tower
leak me below 15% unually
(35% fot miiiitmciil) widiin
30 day» of dJMovny.^
112.156(00). 82.1S6(IK5)*
82-156(1X9)]
C
Develop, wfthto 30 Oay» of kak
discovery*, a one-yev itmfli or
system. Keeppln(or»le|ti)le
oopy) at the file of the
Follow leak repeir
Complete ptan within
one year of pin dete.*
|«2.156(IM6)1
Dovclopt wlfiuD 30 uys of
fcoofli or ictDOHcnt pip lor
the leaking system. Keep p
(or a legible oopy) at the site
f82.156(iM6)|
End
*Note:Alll
s for repainng, retrofitting, or Httiring Icifcing system ire temponrily suspended
if the system is mothballed. |tUS6QX10), C.1S2]
T
Ootop0.4
-------
tfotnpy. 0vtep0.4
Oo tDffp« 3 fer OtfM
C Morv ftan 2 XMfv
IfWtnayt
quoted ddlmy fiy wy
>30 weeks flwn
when order b placed?
I8U56(QC)(ilXB)]
If you bm ux already dooc M, follow fee
otter applicable ptifawayi to
^1 MBMaaaaM jfctf *« !! MMM J aTn»
imi nouH oi me UOWCQ ior
12.166(0)
Odvio
for DIG conge. Submit ttc
|KL156(IK7)(HXC))
Mifiitiio PBConb irtf fpmc ID dttennme gott
iscusiooi bolt cod quoted dclivoy nc
WUDID IM totw tow WOWBO.
|tUS6(IM«)
: All time-related requBementt for fcpaning.
if te lynein n raotkballed. |8L156(iK10), C.IS21
-------
Page 3 of 6
4
H
JOotopg.2.
Notify EPA of the need far additional
llow EPA to demote fhtt ddqn
ocduoncd by other ic^DUDOBf uwv
due to- IDC unAvuubilny w * luifinlff
apply per C.l«(o).
lw Mriod
tine
allowed from
* tt WMWCa UDMIS
EPA objects. EPA wDloottty of to
iffftTHHIlUliflll wltllitt ftft IHQ^ ftT
of OB yon
teptaft
tobmita request to EPA per ,
«L166(o) to farther extend the
i EPA o^e« within 30 days of
ftoripi.
L
-------
Page 4 of6
to rep*
tab?
rtU56
-------
.Page 6 of 6
Uafcf«jJ»ofaifcc*»aftjf(r
(tmmpg.4)
M"*
Wtthta 30 t(I20d9> tf totantai pneca
IS tOQUIIw)i AA BHiiHtlfCO HUlfiHCf fli
tee.
Coodaeti
tttte
the Kptir effort (Mid prior to icpltcenait of the
lefi^cnat. IfcmooMBd.) If offline, lyttai my oot
hremjtt bock OB toe mil leB(t) x moiiftil
XX
No
30 itayt of ouaiptcUuf icptits or
If off line, tyttem my
be brought tack on Une.
Retnrfitorietireinetitb
rtil) ff ipiirrd
|SU9«IX3MI)]
Notify EPA wtthto 30 fttfi of
uicemftil wriHiiilkm per
l56(i)(3)OT)l
Ootopg. 0
See pg. B-3 of the pddnoe aocament for details.
wnplatitig a ntroSt orntninent ml the deadline formjtxsting an Mtwiston Kmon than one yoarJS
1 noodvd ID wftoft or mfiw am ootfi basadon lf» date of 0w MM Mtffication tost trnmthoiraMnpalrvtlorts. You ahouM be aware t^ttttae
iMaflines and make tppropriatopnvisionsff you intend to ator^
f am ultimately unat
-------
Page 6 of6
Front pg. 8
JMtafftwnJ
WHBuy
m^ ^j^ - ' ^ ^- ^^^JA^^ABrf^H 4^«^ ^^^^ ^BlAl^t
ID WNtucnoD or BDMO mmm RH mn BDDH
i^rir dfira. ood(y EPA of ptfoeten to be OMd
ftr otibBditav Me Me fa ta Otn 35%.
EPA otijtcu
lOpttan
OfteflowcbMlo
»-
iwttrinlioays
d^^rf
WV1
-------
Compliance Guidance for the Amendments to the Leak Repair Rule Provisions of $608
Questionnaire
Please help us gauge the usefulness of mis guidance by completing mis short form. Your response will be
kept confidential. Aggregated response data will be published, but .only to illustrate whemer mis
guidance was beneficial to its users. Your judgment of the document'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 busmess do you work for? (check one of the foUowing)
fJifaafal aii Hffjninv Recycling Refrlgertttum Service,.
Other manufacturing (please M«ifjfy)-
Other non-manufacturing (please identify):.
2. How many people does your facility employ (including contractors)? (check one of the following)
<50 Employees 52-100 Employees 203-500 Employees^..,_
502-2000 Emp%«s__ 1002-5000 Emptojws^^ 5001-10flQO Employees.
>WJOOO Employees ^__
3. What are your job responsibilities? (check any of the following that apply)
Support Engineer * Compliance Sfa^y Environmental Engineer,
Corporate M/Btugtmtnt,
Technician
Punt Mttnagemtnt.
Operator^
Other
4. How did you hear about mis guidance? (circle one of the following)
CMA EPA's Stratospheric Protection HoAine Trade Press
Other:
ASSESSMENT
Please indicate your agreement with the foUowing statements from
IgStrongly Agree to 5=Strongly Disagree
Statement
The guidance provides a good overview of the amendments to the leak repair
provisions of $608.
me guidance Helped my faculty/company comply.
The guidance was timely.
me guidance neipea my faculty/ company get into compliance quicker man it
would have if I had to develop our own guidance.
nte guidance saved my facility /company resources/ time mat would nave oeen
spent developing our own guidance.
In addition to this guidance, a training package would be useful.
n addition to this guidance, a self-auditing package would be useful.
would like similar guidance to be developed for other rules. If so, which ones?
Additional Comments: (Pleas^ indicate w»y addition comments on the back p*ge, <
separate page).
1
2
3
4
5
N/Ato
my Job
or attach them on a
Return survey to the Chemical Manufacturers Association, c/o Compliance Assistance Manager at the
following address:
Prior to January 7,1996, to: 2501M St., NW, Washington, DC 20037 (or fax to 202/887-5426)
After January 7,19%, to: 1300 Wilson Boulevard, Arlington, Virginia 22209 (or fax to 703/741-6531)
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