SEPA
CHEMCAL
MANUFACTURES
ASSOCIATION
Agwcy
Ertorc«m«ra Ana
Compianoe Awunrce
February 1996
Training Module
For Industrial Process
Refrigeration Leak Repair
Regulations Under Section 608
Of The Clean Air Act
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OVERVIEW
The purpose of this training module is to help members of the regulated community train
their employees on the requirements 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 training module 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 self-audit
checklist on the leak repair provisions to help members of the regulated community
determine their compliance status with the amendments. This training module is intended
to be used in conjunction with the compliance guidance and the self-audit checklist.
Copies of either document may be obtained by calling the Stratospheric Ozone
Information Hotline (800-296-1996) or CMA (703-741-5231).
The training module is intended solely as a compliance assistance tool. It is intended to
be used in conjunction with the compliance guidance, which explains the practical
requirements of the regulations. The training module 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
training module, as appropriate, to reflect facility-specific situations. However, in such
cases, it should be communicated to the intended user that the document should no longer
be considered an EPA/CMA workprdduct
CONTENTS OF THE TRAINING MODULE
The training module presentation includes 40 slides. The slides contain instructor's notes
to provide the user with background information on the slide topic and/or general .
directions for instruction. These instructor's notes are NOT formatted into script. The
user should read the instructor's notes and then generate his/her own script, incorporating
the information in the notes. Each slide may be tailored to the specific needs of the
facility/company.
The training module presentation has been structured in two basic sections: 1)
Introduction to the 1995 Amendments and 2) Compliance Guidance:
1) Introduction to the 1995 Amendments — this section includes slides 2-7 and is
intended to be an overview of the amendments. This section may be used in concert
with the Compliance Guidance section, or used separately for general awareness
training needs.
February. 1996
-------
2) Compliance Guidance - this section is more detailed and is intended to explain the
requirements of the August 8, 1995, amendments to facility personnel that need to
perform the compliance activities.
Copies Distributed through EPA
The training module presentation comes complete with all 40 slides and instructor's notes
in hard copy format. Users may transfer the information onto overheads and develop the
instructor's notes into script.
Copies Distributed through CMA
The training module presentation comes complete with two diskettes containing the
PowerPoint training presentation files. Please follow the instructions located on DISK 1
for installation and setup of these files. If the user does not have PowerPoint available on
his/her computer, an option to install the PowerPoint Viewer, which allows the user to
use the presentation without having to purchase PowerPoint (but not edit the
presentation), will be available during the installation routine (select Full Install option).
The training module presentation is set up to run automatically with a 45 second delay on
each slide. This delay may be adjusted by the user. If the user cannot run the
presentation on an overhead projector from his/her computer, the presentation may be
printed as overheads or slides.
EDITING THE TRAINING MODULE
Users who want to edit the training module presentation to incorporate their facility
specific or company specific information (see Overview section) may do so. Please note
that the training module presentation cannot be edited in the PowerPoint Viewer. The
user MUST open the document in PowerPoint (document name will show up as
"cgpresntppt") to edit Once the document is open the user may adjust the order of the
slides, add information to the slides, and/or edit the instructors notes into a script.
The user may print out the slides in "slide" format or in "notes" format. The "notes"
format will print as the pages in this book are formatted. The user may adjust this format'
to include more than one slide per notes page if necessary. '
REFERENCES
If the user has questions about the information provided in the training module, he/she
should refer to the amendments and the compliance guidance, consult with counsel, or
call the EPA Stratospheric Ozone Information Hotline.
Februarv. 1996
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ACKNOWLEDGEMENTS
This training module was prepared by a joint partnership between the Chemical
Manufacturers -Association and the Environmental Protection Agency. At the time of
publication of this Module, 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
Paul Winkler
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 ffl
*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
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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Training Module for the Amendments to the Leak Repair Rule Provisions of §608 Questionnaire
Please help us gauge the usefulness of this training 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 training'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.
3.
How many people does your facility employ (including contractors)? (check one of the following)
1-100 Employees 101-500 Employees 501-1000 Employees
1001-5000 Employees 5001-10,000 Employees >Wfl01 Emptoyee__
What are your job responsibilities? (check any of. the following mat apply)
Support Engineer _____ Complumce Staff Environmental Engineer,
Corporate Management _____
4.
_ Plant Management_____
Technician Maintenance
How did you hear about mis guidance? (circle one of the following)
Operator^
Other:.
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
Fhe training module provides a good overview of the amendments to the leak
repair provisions of $608.
Fhe training module helped my facility/company comply.
fhe training module format was user-friendly.
Die training module was timely.
used the training module in combination with the compliance guidance and/or
the self-audit checklist
I tailored the training to reflect the individual needs of my facility/company.
My company /facility would have developed a training program for this rule.
1
2
3
4
5
N/Ato
my job
rime/resources were saved by using this training module? (yes or no) If yes, how many hours were saved?.
-low many people were trained (or will be trained) using all or parts of mis training module?
iVere additional copies of this training module made? (yes or no) If yes, how many?
would like similar training modules to be developed for other rules. If so, which ones?
Vould you be interested in participating in another survey on these materials in the future to help CMA and EPA
measure the success of this compliance assistance tool? (yes or no) If yes, please indicate your name and phone
ciumber where we can contact you.
Additional Comments: (Please indicate any additional comments here, on the back page, or attach them 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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EPA-300-B-96-001
Training Module
For Industrial Process
Refrigeration Leak Repair
Regulations Under Section 608
Of The Clean Air Act
CHEMICAL
MANUFACTURERS
ASSOCIATION
Developed by Environmental Support Solution*, Inc.
-------
jiV
il
&
Introduction to
Environmental Regulation
> Global Problem
+ International Response
+ United States' Action
-------
Clean Air Act
+ Section 608
+ Introduction to the 1995
Amendments
• Reasons
• Issues addressed
m
-------
Compliance
m.
+ Amendments require you to:
• Perform Activities in Timelines
• Perform Record-Keeping
'• Submit Reports
+ Compliance Aids
• Compliance Guidance
• Training Module
• Self-Audit Checklist
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Ill
Impact to Our Company
Applicability
+Units Affected
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General Summary Flowchart
> -i'V
Is my
refrigeration
system subject
to EPA's lesk
repair
requirements?
(Module B)
Is there
enough lesksge to
trigger the amendment's
requirement to take
action?
(Module C. 0)
Mandatory repair.
retrofit or retirement of
system
No specific action
required
Retrofit or
Retirement
(Module E-1)
(Moduli E-2)
(ModuleO-1)
Deadline* a Extension*
Veilflcatlon letting
Recordkeeplng a Repotting
What to do If you panffall
the te«t«
Switching to retrofit/retirement
of the •yttem
Mothbatllng
Decide
whether to
repair, retrofit, or
retire the system
Deadline* a Extension* (Module F-1)
Recordkeeplng ft Repotting (Module O-2)
Switching to repair the leak(i) (Module F 2)
Release from obligation to
retrofit/retire the *y*tem (Module F 2)
Mothballlng (Module H-2)
(Module E-2)
(Module H-1)
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Record-Keeping &
Reporting Requirements
•f Under Normal Service
(Repairs completed in < 30 or 120 days)
»
Time Extensions
Failed Follow-Up Verification Tests
Submission of Retrofit/Retire Plans
Full Charges
Purged Refrigerants
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1
Applicability
+ Industrial Process Refrigeration
Systems Utilizing:
• Greater than 50 Ibs. Glass I
• Greater than 50 Ibs. Class II
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'i*.
'fWRi
Jmff.
Applicability Trigger Rates
For all systems with a refrigerant charge of more than 50 Ibs;
• Commercial refrigeration 35 percent
• Industrial process refrigeration 35 percent
• Comfort cooling 15 percent
• All other refrigeration 15 percent
m\
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Further Applicability Issues
Exclusion for <50 Ibs. of Refrigerant
+ Exclusion for 50% or Less Utilization
Independent Circuits
4- Integrated Circuits
\m
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W-I-
•••:i'i!?"irŁ
•W'
Leak Rate Options
+Repair Leaks
+Retrofit the System
^Retire the System from Service
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1
;yf$.
Full Charge
Definition
Reasons for Determination
-------
I. »V'I '
15. n
Methods to Determine
Full Charge
Measurement
Calculation
Manufacturer Information
Range
Combination
-------
:?:.•$
res?
Further Full Charge Issues
Margin of Error
+ Manufacturer's Statement
«
Changes in Estimates
-------
MA
Record-Keeping and Reporting
Requirements
Establishing a Range
On-Site Documentation
Submitting Reports to EPA
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Calculating a Leak Rate
One method of calculation for percent
of full charge that would be lost per
12-month period:
Leak rate % =
pounds of refrigerant added x
pounds of full charge # days since refrig. was last added
365 days
xlOO
Timing
4- Purged Refrigerant
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'
Further Leak Rate Issues
+ Trigger Rates
•
+ Violations
+ Schedule of Leak Checks
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!
Leak Rate Record-Keeping and
Reporting Requirements
Purged Refrigerants
On-Site Documentation
Submitting Report to EPA
-------
ir
Leak Repair
Requirement
+Repair Within 30 Days
+Repair Below Trigger Rate
+Repairs are Not Required if:
• Retrofit the System
• Retire the System
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Technician Certification
Evacuating or Adding Refrigerant
Changing or Adding Oil
Replacing a Gauge
Changing or Calibrating a DP Cell
Changing a Pressure-Relief Valve
Drawing a Sample of Refrigerant or Oil
Dismantling a System for Disposal or Other
Action That May Reasonably Result in a
Release of Refrigerant
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I
Exceptions to 30 Day
Deadline
Additional time may be permitted in
the following situations:
4-Industrial Process Shutdown
+Unavailable Parts
4Other Regulations
+Mothballing
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Verification
Two Tests
• Initial verification
• Follow-up verification
+ Purposes
-------
lit
i SI
!•#
Initial Verification Test
Conducting a Test Following a
Leak Repair Attempt
System Brought Back On-Line
•Repairs Complete
• Decision to Retrofit or Retire
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Follow-Up Verification Test
#
Conducting a Test Following a
Leak Repair Attempt
• If normal operating conditions have
be maintained
• If system has been taken off line
•f Conducting Practicable Tests
Under Normal Characteristics or
Conditions
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iHI1
m
mm
Verification Test Methods
Soap Bubble Test
Electronic Leak Detector
Ultrasonic Leak Detector
Pressure Test
-f Vacuum Test
Fluorescent Dye and Black Light Test
Infrared Test
Halon Refrigerant Gas Detection Method
etc.
-------
Further Leak Repair Issues
+ When Verification Tests Are Required
Number of Leak Repair Attempts
Allowed
Definition of Success
Required Results
-------
HiMiii
ri
Unsuccessful Follow-Up
Verification Tests
+ Notify EPA
Develop Retrofit or Retirement Plan
Within 30 Days
Follow Alternate Option
fl
-------
Record-Keeping and Reporting Requirements
Repair
+ If Repairs Fail Follow-Up Verification Tests
+ If Additional Time is Needed
+ On-Site Documentation
+ Submitting Reports to EPA
-------
%$&
.
Regulatory Timeline
for Leak Repair
Sample Path 1: Leak cannot be reduced below
trigger rate in 30 days, verification test
successful .
Sample Path 2: Leak cannot be reduced below
trigger rate in 30 days, verification test failed
Sample Path 3: Leak can be reduced below
trigger rate in 30 days, verification test failed
Sample Path 4: Leak cannot be reduced below
trigger rate for 120 days
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Retrofit and Retirement
+ Plan Must Be Developed Within 30 Days:
• of Discovery of the Leak; or
• of the Failed Follow Up Verification Test; or
• of Determining to Retrofit or Retire the System
+ Plan Must Be Dated and the Original Made
__ * _ i
Available for EPA Inspection Upon Request
+ Activities Must Be Completed Within a 12-
Month Period of the Plan's Date Unless an
Extension Applies
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isti
m\
Time Extensions
Delay Caused By Requirements of
Other Regulations
Suitable Replacement Refrigerant Not
Available
Supplier of System or Critical
Component of Custom-Built System
Quotes Delivery Time of More Than
30 Weeks
-------
ii
m
Relief From Obligation
Complete Repair of Same Leak(s)
Within 30 Days of the Failed Follow-
Up Verification Test
Establish That Leak Rate is Below
Trigger Rate Within 1 80 Days of
Failed Follow-Up Verification Test
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Record-Keeping and Reporting
Requirements
Retrofit or Retirement
.4- Maintain the Retrofit or Retirement
PlanOn-Site
Make the Original Plan Available to
EPA Upon Request
-------
Record-Keeping and Reporting Requirements
Time Extensions to
Retrofit or Retire
+ Timeline to Submit Reports
+ Contents of Report
\m
IV.-
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Record-Keeping and Reporting Requirements
Updates to Plans and Time
Extensions
+ Updating Retrofit or Retirement Plan
+ Additional Time Needed
\m
-------
ill
System Mothballing
+ All Time-Related Requirements
Are Suspended
+ Amendment's Definition
+ Applicability
-------
Further System
Mothballing Issues
Leak Repairs on a Mothballed
System
+ Reporting Requirements
Deadline Suspension
•«* A ,,
*
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I8i
M5&&S&:
Oil Changes
Maximum Allowable Pressure: 5 psig
.+ Acceptable Procedures to Assure
Recovery of Refrigerant
• Evacuate the refrigeration system to a
pressure no higher than 5 psig, then remove
oil, or
• Drain oil into system receiver to be evacuated
to a pressure no higher than 5 psig
-------
sli.
General
Record-Keeping Issues
Length of Time to Keep Records
+ Other Corporate Record-keeping
Issues
-------
m
Responsible Care
A Public Commitment
CHEMICAL
MANUFACTURERS
ASSOCIATION
2501M Street, NW
Washington. DC 20037 202-687-1100
Developed by Environmental Support Solution*, Inc.
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Training Module
For Industrial Process
Refrigeration Leak Repair
Regulations Under Section 608
Of The Clean Air Act
cir
.*•"!>
Introduction to
Environmental Regulation
Tkb SIM* Begin SectloB 6mr. lurrodMtion to 1995 Aaradmento
d Problem
The theory linking chtorofluorocarbons (CFCs) to stratospheric ozone
depletion and environmental concerns was first proposed In the 1970s.
Scientific studies provided an understanding of the chemical processes and
physical mechanisms. Mathematical models predicted the effects of ozone-
depleting substances (ODS) released into the atmosphere and transported by
air currents to the stratosphere. The models predicted that continued use of
these substance* would lead to substantial ozone depletion In the next SO to
100 yean. The stratospheric ozone layer protects the earth's surface from
excessive quantities of harmful ultraviolet (UV-B) radiation. After evaluating
scientific evidence, an international consensus evolved that man-made,
chemical substances containing chlorine and bromine are causing the depletion
of the thin, fragile ozone layer. The conclusion was to reduce these releases
and restrict their use.
In September 1987. the United States and 22 other countries signed the initial
Montreal Protocol on Substances that Deplete the Ozone Layer. An agreement
was made to reduce the world's production of chlorofluorocarbons and halons.
A majority of the world's nations, more than 90 percent of producing and
consuming nations, have now signed the Protocol.
United States' Action
In response to the Montreal Protocol. Title VI, Stratospheric Ozone Protection
of the Clean Air Act Amendments of 1990. was signed November 15.1990.
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I Clean Air Acl
• Section Mi
• lnmxhicHonlolhel99J
Section 608
Title VI of the Clean Air Act Amendments of 1990 is directed toward
eliminating the threat posed to the earth's protective sualuspheilc ozone layer
by certain ozone-depleting substances (ODS). Under Section 60S EPA
published rules regarding the use, recycling, and disposal of ODSs in
applications including industrial process and commercial refrigeration systems.
The original refrigerant recycling regulations, including leak repair provisions,
were published oh May 14.1993.
Introduction to the 199< Amendment*
The I99S amendments pertain to the leak repair provisions of the Section 608
refrigerant recycling regulations. The amendments were issued by EPA August
>, 1995. and became effective September 7,1995.
The amendments make important changes to the leak repair rules and require
careful understanding to facilitate thorough compliance.
Issues Addressed
Various requirements of the refrigeration recycling regulations affect all
refrigeration systems. The amendments addressed here are relevant to
industrial process refrigeration systems.
Compliance
• AfMndkncnti pcquira you toi
The 1995 Amendments require certain activities to be performed, timelines to
be met, and records to be kept regarding leak repairs of industrial process
refrigeration systems. Your company is responsible for complying with the
amendments; persons affected may be plant engineers, maintenance
supervisors, and maintenance technicians.
Important Notes - The amendments contain several alternative pathways to
follow. Each has deadlines triggered by various action*. 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. Additionally, the
amendments require you to notify EPA of various events. Understand these
before you start
CMA and EPA jointly produced a Compliance Guide, this Training Module.
and • Self-Audit Checklist to help industry comply with the amendments.
Compliance Guidance - A guide developed by the Chemical Manufacturer's
Association and the Environmental Protection Agency, intended as an aid for
complying with the amendments. The guide is organized by modules
explaining the important aspects of the amendments.
Training Module - A slide presentation intended to aid in communicating the
information provided in the Compliance Guidance to those in your company
who need to Implement it
Self-Audit Checklist - A checklist designed to help you determine your
compliance status with the amendments.
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Impact to Our Company
•Applicability
•Unto Affected
The amendments make Important changes to the leak repair provisions of
EPA's refrigerant recycling regulations and ailed the use of ail industrial
process refrigeration systems.
Note: Trainer may wish to customize this slide with specific information on
facilities and operations impacted.
General Summary Flowchart
Note: CMA and EPA developed this flowchart to visually explain the impact
that this regulation will have on staff and operations. Trainers should walk
audience through the flowchart, giving them a perspective of how this
regulation will be triggered and how the decisions they make affect what
timelines they get and what activities they must perform.
-------
Record-Keeping ft
Reporting Requirements
• Under Nonnil Soviet
i*q>*t conpincd h < JO «r 110 4qn)
• ThwExttmion
« MW FoHow-Up Vctidcatoa Tntt
« Submbiloa of Rctrofltfltcdrc rfam
This regulation has very intricate record-keeping and reporting requirements
that arc triggered by meeting or failing to meet timelines, various decisions,
and certain conditions (custom built).
Note: When preparing leaks under normal service you may not be subject to
the amendments, but you are still required to follow the requirements of the
original refrigerant recycling rules published on May 14.1993.
It is vital that staff keep track of where they are in repair/retrofit process to
avoid violations of the amendment.
(Eld of fint section)
Applicability
« takakW Preens RcMfcnrioa
TMs Slide Begin Beetles) Tw«: CoaipllaBec ReqailreaieMts
The new regulations affect industrial process refrigeration systems: complex
customized systems used in the chemical, pharmaceutical, petrochemical, and
manufacturing industries.
The rule applies to systems that contain and use a class I or class II substance
as a refrigerant
Class I: cMoroftuorocarbon (CFC) refrigerants or any refrigerant mixture
containing a CFC.
Class II: hydrochloroflooTOcarbon (HCFC) refrigerants or any refrigerant
mixture containing a HCFC.
-------
Applicability Trigger Rates
ISfVtM
Mpoon
Mpaccal
UP
Action is required under this regulation when a system's leak rate exceeds the
trigger rate percentage per 12-month period.
For example, the leak repair requirements of this regulation an triggered when
an owner or operator of ah Industrial process refrigeration system discovers
that refrigerant is leaking at a rate in excess of 35 percent per 12-month period.
Please note that the 12 month period is not necessarily a calendar year.
| Further Applicability Issues
« EnMn ft* SOS or Lai Udliaiion
• bxfcpoidcnlChcafci
Exclusion for < SO Ibs.
Any type of refrigeration system normally containing 50 pounds of refrigerant
or less is excluded from the leak repair requirements.
If less than 50 percent of a system's capacity Is being used in an industrial
process refrigeration application, the system Is excluded from the requirements
of the amendments.
A refrigerant circuit consists of equipment that
carries refrigerant, typically in a closed loop, to
and from the point of cooling. Some systems have
two or more refrigerant circuits that are completely
isolated from each other to avoid mingling of
refrigerant; these are independent circuits.
Only the circuits with full charges greater than
50 pounds are subject to leak repair requirements.
Integrated Clreirita
In an industrial process refrigeration system
that is physically integrated into a manufacturing
process, only the Interconnected equipment that
contains, conveys, or otherwise handles
refrigerant is considered part of the system
subject to leak repair requirements.
to
-------
Leak Rate Options
•Retrofit die Synen
•Retire the Syaon Bom Senln
Each time refrigerant is added to a system normally containing more than 50
pounds of refrigerant, the leak rate should be promptly calculated. If the leak
rate is higher than the trigger rate, you are required to do one of the following:
• Repair Leaks
• Retrofit the System
• Retire the System from Service
I Full Charge
• De (Mian
Definition
The amount of i
system to operate at normal operating characteristics and conditions.
eftige
try for an industrial process refrigeration
• The leak repair requirements apply only to systems whose full charge Is
greater than 50 pounds of refrigerant in any Independent refrigerant circuit
• The full charge must be known hi order to calculate the leak rate for a
system.
-------
Methods to Determine
Full Charge
« edentate)
• MmrfKtuKf InftxnuifcNi
«CamMralkM
Note that difTeitnt methods nuy be used to determine full charge for different
systems at a facility.
Draw the refrigerant from the system and weigh it or'measure die amount of
refrigerant required to fully charge an empty system.
Calculation
Calculate the weight of the refrigerant charge In the system.
Manufacturer Infimnalloii
Some manufacturers specify, on a plate attached to the system or hi
specifications, the amount of refrigerant in the full charge for a system.
Binge.
If a range of refrigerant amounts for proper function of a system is known, the
midpoint of that range may be used to'determine the system's full charge. Note
that special record-keeping requirements apply if this method is used alone or
in combination with other methods.
Combination
Use a combination of the above methods.
Further Full Charge Issues
• MujtaofEnor
Margin of Enor
EPA recognizes there is some margin of error In any determination of the
amount of refrigerant In a system. A determination based on the best
information available and sound professional judgment is acceptable.
If suspect lo be wrong, use another method to determine the full charge.
If new and better Information is obtained, the full charge number may be
changed. Recalculation of any previously determined leak rates is not required.
but the new full charge number must be used fa calculating any future leak
rates. !
i<
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Establishing a Range
UOn-ShcDocwncMliMi
If the full charge or an industrial process refrigeration system is determined by
establishing a range or combining the use of an established range with any
other acceptable method, the records containing the following information
must be maintained. '. .
• Identification of Owner or Operator
• Location of System
• Original Range for Full Charge. Its Midpoint, and How Range Was
Determined
• Revisions of the Full Charge Range and How They Were Determined
• Dates Such Revision Occurred
Submitting Report* to EPA ' ' •
No reports are required to be submitted to EPA.
Calculating • Leak Rate
» Om mttai oToricaWm fct pace*
•( M dm* ta «add be tat f*
n-moatt period:
• _ m^n ••
li,nl ...If J.MJU
Calculating • I .gale Bate
I. Divide the number of pounds of refrigerant you added to return the
system to a full charge by the number of pounds of refrigerant in the
normal full charge for the system. .
2. Divide 365 by the number of days that have passed between charges
(number of days between the last time refrigerant was added and this
time refrigerant was added).
3. Multiply answers determined in (I) and (2).
4. Multiply answer determined in (3) by 100.
(Optional Calculation Problem)
Calculate the percent of full charge that would be lost per 12-month period
with the following information: 118 days have passed since you last added
refrigerant, you add 128 pounds of refrigerant today to a system whose fall
charge is 1000 pounds. (Answer 40*)
Note that other calculations may also be appropriate In complicated situations.
Note that record-keeping requirements apply to calculating leak rates.
Timing
Calculate the leak rate as soon after the refrigerant is added as possible. If the
system is leaking above the trigger rate, the law imposes strict deadlines for
repairing, retrofitting or retiring the system.
Purged Refrigerant
In calculating the leak rate, you may exclude purged refrigerant that is
destroyed at a destruction efficiency of at least 98 percent. Note that record-
keeping and reporting requirements apply when excluding purged refrigerant
from the leak rate.
IS
16
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Further Leak Rate Issues
• Vlotiriom
« Schedule of Lak Checki
Trigger Rates
If the leak rate is less than the trigger rate, no action Is required.
If the leak rate Is greater than the trigger rate, upon discovery you are
immediately under a deadline to repair the leaks or retrofit or retire the system.
Violations
If the leak rate is greater than the trigger rate, operation of the system and
adding refrigerant to the system to keep it operating are temporarily allowed. A
violation occurs If you do not adhere to, the timelines and requirements
associated with repairing, retrofitting, or retiring the system.
Schedule-
Calculate the annual leak rate each tune refrigerant is added or any time sound
professional judgment Indicates the system may be leaking more than the
trigger rate.
Sound professional judgment assumes • combination of logic, operational
experience, and practical methods of calculation that are based on training,
experience, and education.
No monthly or other periodic schedule of leak checks is required.
A process to routinely look for leaks may be beneficial for an early detection
of leaks but is not required by the regulations.
On-She Documentation
When excluding purged refrigerants that are destioycd from annual leak rate
calculation*, you must maintain records to support the amount of refrigerant
claimed as sent for destruction. Records must Include all of the following
Information.
• Flow Rate of Purge Flow
• Quantity or Concentration of Refrigerant in Vent Stream
• Periods of Purge Flow
• Identification of Facility and Contact Person
• Description of Refrigeration System
• Description of Methods Used to Determine Quantity of Refrigerant Sent
for Destruction
• Frequency of Monitoring and Data-Recording
• Description of Control Device and Its Efficiency
Submitting Repnrta to EPA
No reports are required to be submitted to EPA.
IT
II
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Leak Repair
Requirement
»Rtj»irWlthbiJOD»yi
•Rcfufc Bdow Tri||
-------
Exceptions to 30 Day
Deadline
Additional Ibnenuy be pemtncd IB
»OdKillcsultflom
•MotM»llkit
Verification
» Two Ton
Industrial Process Shutdown
When an industrial process shutdown is required to repair leaks from Industrial
process refrigeration systems, a 120-day repair period is allowed.
Unavailable Parts
Additional time, beyond the 30- or 120-day time periods, is allowed to conduct
leak repairs if necessary repair parts are unavailable. Only the additional time
needed to receive delivery of the necessary parts will be permitted. Note that
EPA must be notified if repairs cannot be completed within 30 or 120 days of
discovery.
i
Other Regulation*
Additional time, beyond the 30- or 120-day time periods, la allowed if other
applicable Federal, State, or local regulations make repair within 30 or 120
days impossible. Only the additional time needed to comply with the pertinent
regulations will be permitted. Note that EPA must be notified If repairs
be completed within 30 or 120 days of discovery.
Two Teats
The amendments require verification of the success of leak repairs for
industrial process refrigeration systems. Two tests, "initial" and "follow-up,"
are required for each repair site (e.g.. tightening a flange or a valve).
The primary purpose of the initial verification test is to verify that a leak or
leaks have been repaired before refrigerant is added back to the system.
The primary purpose of the follow-up verification test is to re-verify that
repairs continue to hold after the system is returned to its normal operating
characteristics or conditions.
Modelling
If the owner or operator intends to make repairs to a mothballed system that
requires opening the system, the refrigerant must be removed to the required
evacuation levels for that refrigerant before opening that system.
21
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Initial Verification Test
• Conducting t Tea FoDowhif •
Lot Rep* Anempl
• Sjmem Bnw|hl Back On-LJm
Conducting • Teat Following • Leak Repair Attempt
An initial verification test must be conducted following any leak repairs that
were conducted to fix leaks exceeding the trigger rate. This test must be
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, this test must be conducted as soon as
practicable after the repair work is completed.
System Bmugtit Back On-Une
A refrigeration system may not be brought back on line unless this test
indicates that repairs have been successfully completed or a decision to retrofit
or retire is nude.
Note where a time extension is utilized. EPA must be notified within 30 days
after the completion of a verification test
Follow-Up Verification Test
» Ceadwdni t Tol FoOowkii •
« Conductini h«>lc«Mc Ton
Uadct Nora^ CbmcKriHk* or
• T*** Following I jf»\ Pfpair Attempt
If normal operating conditions have been maintained - perform the test within
30 days after the initial verification lest
If system has been taken off line — perform the test within 30 days of bringing
the system back on line and when the system is operating at normal operating
characteristics or conditions.
Under ^nttnal ffo«f«f1erigtloi or
The follow-up verification test must be conducted at or near the normal
operating pressure and temperature where practicable.
Note where a time extension is utilized. EPA must be notified within 30 days
after the completion of a verification test
In certain cases the results of a 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 the system b operating. If this Is the case, based on sound
professional judgment, this test may be conducted prior to returning to normal
operating characteristics or conditions.
24
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Verification Test Methods
. UnoofcUADauor
• Mm* Tot
• VranTc*
• rtomcci*Dy«Ml Stack LI|)iiTai
> IMaiilUftt|RinlO>lDMKthmMc*od
Further Leak Repair Issues
• What VcrUlcttfai Tern Am Required
» NMtooTU* Rep* Antmpo
ADmtd
«DdtaMoaefS«ccn
• ReqBMRenfa
Verification Teat Methods
Initial and follow-up verification testa may use any method that meets sound
professional judgment. Test examples listed are some, but not all. of the
possible methods.
EPA does not specify any particular method.
Wten Vgrlfy-«ilfM Tents A** Required
Initial and follow-up verification tests a
s required following teak repairs.
Number nf | .till RtBHt* Attetnpta Allowed
You are allowed to try to repair the leak as many times as you need to within
the allowed time period. The last repair attempt within the allowed time and
the verification tests on that attempt are what matter.
Note that If the repair efforts occur during a time extension, the results of the
last initial and follow-up verification test performed during the repair period
must be sent to EPA.
A verification test Is successful when h shows that the leaK has been
successfully repaired.
Rfnuiffed Results
Initial and follow-up verification tests evaluate the success of the particular
repair you made; they do not have to verify that you reduced the annual leak
rate to zero. Repair efforts must bring leak rates below the trigger rate.
25
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Unsuccessful Follow-Up
Verification Tests
• NodiyETA
« Develop RcOolh ot RcHnmcM Pbn
WKhln30D»yt
• Follow AhcmM Option
Notify EPA
If you have an unsuccessful follow-up verification test, you must notify EPA
on the last repair attempt within the allowed time.
You are allowed to try to repair the leak as many times as you need to in the
allowed time period. The last repair attempt within the allowed time, and the
verification test on that attempt, are what matters.
Develop Retrofit or Retirement Plan Within 30' Days
You must develop a retrofit or retirement plan within 30 days of the failed test.
If it is going to take you more than one year, you must submit the plan as well.
Follow Alternate pptiotM
If the follow-up verification test indicates that the repairs to the system have
not been successfully completed, the owner or operator is required to retrofit or
retire the system. There are. however, some options by which the owner or
operator is relieved of the obligation to retrofit or retire the system. These will
be discusses shortly.
Failed Tert/Mme Time
If more time is needed or if repairs do not pass follow-up verification tests,
addition record keeping and repotting are required. The following information
Is required whenever additional requirements apply.
• Identification of Facility
• Leak Rate
• Method Used to Determine Leak Rate and Full Charge
• Date When Excessive Leak Rate was Discovered
• Location of Leaks to Extent Determined to Date
• Any Repair Work Already Completed with Dates of Completion
• Date(s). Type(i), and Results) of Failed Test
• If applicable, parameters use to attempt to verify if the leak rate is below
the trigger rate within 180 days
• Retrofit or Retirement Plan
Keep on-site documentation of the above listed information and report it to
EPA within 30 days after failed test You do not have to submit the retrofit or
retirement plan to EPA unless you will need an extension of time to finish the
retrofit or retirement.
J7
21
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Regulatory Timeline
for Leak Repair
riff Mi h M dm. ttftflcttloa Ml
SM
* Mk I: Urit CBIMI bi rvhcnl
* ran to M 4»?t. rolflc«k«i Ml MM
l be reduce) briow
(Walk students through possible paths of the Regulatory Timeline For Leak
Repair on page E-7)
Sample Path I
Boxes 1,2.6.1,9.12.13.14.15.16.37
Sample Path 2
Boxes 1.2.6.1.10.11.13,14.15.17.20.35
Sample Path 3
Boxes 1.3.7.17.23.26.28.30.31.32.34.36,37
Sraiplc Pfttn 4
Boxes 1.4.7.19.37
Retrofit and Retirement
Moa* taM «*• fk«» DM IMai m
Owners or operators of commercial refrigeration equipment, industrial process
refrigeration systems, and/or all other systems normally containing more than
50 pounds of refrigerant are not required to repair leaks if they develop.
Implement, and complete a 12-month retrofit or retirement plan.
Note that there are different deadlines if you have switched from repair to
retrofit or retire. Please refer to the amendments and Guidance document for
more details on deadlines.
M
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Time Extensions
« Dcby Cued By RcqulmMnlf of
Odm Refutation!
# SuluMc BfpfmjufP* RcfHfcmil Not
AvtJtrffc
• Supplier of Syaem or Cikkd
Component orCiamn-BulhSyaaii
HI Quote* DcHveryTfaMofMore Tim
30 Week*
Additional time beyond initial 12-month period to complete retrofit or
retirement activities is available in the listed circumstances.
Othgf Regulations i
Additional time to the extent reasonably necessary will be allowed.
Replacement Refrigerant Not Available
Additional time to the extent reasonably necessary will be allowed.
Delivery Time
An additional 12-month period is allowed. Note that EPA must be notified
within six months of the expiration of the 30 day period. Beyond this
extension, the owner or operator may submit a request for additional time to
EPA.
Relief From Obligation
« CbBpktt Ktpdr of Sm» !.•>(»)
WkMaJODiyiofteFiiMFollow-
UpVcr«»c«lonTe*
« EttMUi ThM Leak RJ** b Betow
Tri||ct fete Wkhfe IM D«y« of
Filled Folkm-Up Verification Tat
Ifa failed follow-up verification test results in a requirement to retrofit or retire
a system, you may be relieved of this requirement by accomplishing, either of
the listed activities.
CmnrAftt Rgnair Effort*
Second repair efforts are subject to the same verification requirements as the
first repair efforts. Note that if the follow-up verification test for the second
repair effort is successful. EPA must be notified within 30 days.
Establish That Leak Rate Ix Relnw Trig
r Rate
I. Determine the parameters you will use to establish the leak rate and
submit to EPA for approval.
2. Take any further action necessary to reduce leaks.
3. Determine new leak rate using the approved parameters.
If you are unable to verify that the leak rate is below the trigger rate by the
deadline, you will have used up a substantial portion of the 12-month period to
retrofit or retire the system.
Note that the paiametcis you submit will be considered acceptable unless EPA
notifies you within 30 days. Otherwise, you must use parameters EPA
provides.
Also note that within 30 days after that determination. EPA must be notified.
-------
Retrofit or Retirement
. Mtinttin die Rttrofll a KetkaMnl
PtaOn-Ste
• Mike *e Oriftail Ptn Avribbk *>
EPA Upon Requta
Time Extensions to
Retrofit or Retire
» TtawHnt to S*tak Report*
I of Report
If you complete successful retrofit or retirement within the normal one-year
.period, no extra record keeping or reporting is required.
Timeline to Siihtnh
Notify EPA within six months after the end of the 30-day period following
discovery of the excessive leak rate, including the Information found on Slide
28 plus the following information. (EPA will respond to your request within 60
days.)
• Reasons Why You Need an Extension of Time
• Estimate of When Retrofit or Retirement Will Be Completed
• Copy of Retrofit or Retirement Plan
Notify EPA within 30 days after discovering need for even more time and
Include the date of your original notification to EPA and a new estimate of
when work will be completed.
33
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lni fa
Updates to Plans and Time
Extensions
• Updating Retrofit or Rcncmcni rtn
« AddhtondTkneNetdrd
Retrofit Of Retirement Plan
If plan was developed hi advance of discovering a leak rate above the trigger rate, h may be updated.
Additional Time Needed
I . The owner or operator must submit a request for additional time to retrofit or retire the
system within 6 months after the 30-day period following the exceedence of the trigger rate
if:
• Additional time is needed because of delays caused by other regulations; or
• An acceptable altenutlverefHgcfart with a lower ozone-depleting substance is not
available.
EPA will notify the owner or operator of its determination within 60 days of receipt of
submittal.
2. The owner or operator must notify EPA within 6 months of the expiration of the 30-day
period following the original discovery of an exceedence of the trigger rate when requesting
an additional year beyond the initial one-year retrofit period. The following criteria must
also be met:
• Additional time is requested because the new or retrofitted system is custom-built; and
• Supplier of the system or a crucial component has quoted a delivery time of more than
30 weeks from the tune when the order was placed; and
• Owner or operator maintains adequate records to allow a determination that the criteria
are met.
3. Owner or operator may request additional time beyond the additional one-year period If .
needed and where the initial additional one-year was granted as discussed in (2) above.
Requests must be made before the end of the 9th month of the first additional one-year
period.
Unless EPA objects to the request within 30 days of receipt of the submittal, h is considered
approved.
System Mothballing
AictapcaM
The aineiHliiieiits allow the time-related requirements for repairing, retrofitting,
or retiring a leaking system to be temporarily suspended while the system is
rnothballed.
The time-related requirements resume on the day the system is brought back
on line.
Amendment'i Definition
Intentional shutdown of refrigeration system for an extended period of time
where refrigerant has been evacuated from the system to at feast atmospheric
pressure.
Note that if the owner or operator intends to'make repairs that require opening
the system, the refrigerant must be removed to the required evacuation levels
for that refrigerant before the system is opened.
Applicability
Time suspensions under system mothballing apply to all time-related
requirements for repairing leaks or replacing, retrofitting, or retiring a system.
33
36
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Further System
Mothballing Issues
» Lc* kcpto on t ModiMM
Repotting Kequlftinenls
DadUneSiapcmloa .
Oil Changes
Afeirttib Plane: )|»%
i FMadm* 10 Anon
Rcuivtiy of RcfHacnnl
• E
I .eak Rtpalra on • Mothballed System
Repain may be conducted while a system is mothballed, and there Is no time
limit to make the repairs.
Allowable Pn
The amendments address procedures to minimize emissions of refrigerant
during oil changes. EPA requires a reduction m pressure prior to an oil change
to the bulk of the refrigerant is recovered.
System mothballing does not require a report to EPA. However, the owner or
operator must report to EPA if the decision to mothball a system results to
delaying an estimated completion date previously submitted to EPA for
repairing, retrofitting, or retiring the system.
•MePn
These procedures minimize the loss of refrigerant from the oil and the interior
of the refrigeration system.
DeadlineSusei
Note: Once oil Is drained, the refrige
ids to be recovered from the oil
according to EPA'* specifications, which differ according to the refrigerant
Remember, all deadlines ere suspended during mothballing.
Time related requirements resume on the day the system is brought back on-
line and is no longer considered mothballed.
37
)l
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General
Record-Keeping Issues
» Lent* of Time la Keep Rctanb
« Otto Cefpontt ReconMutpkif
Lenath of Time to Keen Records
Three yens.
trainer nuy want to modify slide and discuss other corporate record-keeping
issues.
40
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