Compliance Guidance For
Industrial Process Refrigeration
Leak Repair Regulations
Under Section 608
Of The Clean Air Act
Prepared by:
The Chemical Manufacturers Association
and
The Environmental Protection Agency
October 1995
-------
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:
Scot Cidzik
Eastman Kodak Company
Sharon Gidumal
DuPont
Chris Jones
Eastman Chemcial Company
Jim Kinney
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
Dan Lucero
EPA, Region III
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
-------
TABLE OF CONTENTS
A. OVERVIEW A-l
Purpose A-l
Intended Audience A-l
What the Guidance Covers A-l
What the Guidance Does Not Cover A-l
Compliance A-2
How To Use the Guidance A-2
For More Information A-3
Background A-3
General Summary Flow Chart A-4
B. APPLICABILITY B-l
Affected Operations B-l
Applicability Triggers B-l
Questions and Answers B-2
C. FULL CHARGE C-l
Determining Full Charge C-l
Questions and Answers C-2
D. LEAK RATE D-l
Calculating a Leak Rate D-l
Timing D-2
Purged Refrigerant D-2
Recordkeeping and Reporting D-2
Questions and Answers D-3
E. LEAK REPAIR E-l
Leak Repair Requirement E-l
Situations Where More Than 30 Days Are Required E-l
Industrial Process Shutdown E-l
Unavailable Repair Parts or Other Regulations
That Require Additional Time E-l
Repair Verification 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
Unsuccessful Tests E-4
Questions and Answers E-4
Checklist to Determine if a Certified Technician Is Required E-6
-------
Timeline For Repair E-7
F. RETROFIT AND RETIREMENT OF LEAKING REFRIGERATION
SYSTEMS F-l
Time Extensions For Retrofit or Retirement of Industrial Process
Refrigeration Systems F-l
Relief From Obligation to Retrofit or Retire F-2
Questions and Answers F-3
Timeline & Checklist For Retrofit or Retirement F-5
G. RECORDKEEPING AND REPORTING REQUIREMENTS G-l
Leak Repair G-l
Retrofit or Retirement G-3
Full Charge G-7
Purged Refrigerant G-7
Questions and Answers G-8
H. SYSTEM MOTHBALLING H-l
Applicability H-l
Example of System Mothballing H-l
Questions and Answers H-2
I. OIL CHANGES 1-1
J. GLOSSARY J-l
K. REFERENCES K-l
Stratospheric Ozone Information Hotline K-l
Stratospheric Protection Division's INTERNET Home Page K-l
Stratospheric Ozone Protection Rulemaking Summary K-l
Stratospheric Ozone Protection Final Rule Summary K-l
EPA Applicability Determinations K-2
APPENDIX
Refrigerant Leak Repair Flow Chart Appendix
-------
A. OVERVIEW
-------
A. OVERVIEW
Purpose
The purpose of this guidance is to explain portions of the August 8,1995, amendments to
the leak repair provisions of the refrigerant recycling regulations (hereafter refered to as
"the amendments") and assist those affected by these amendments in complying with
them. The original refrigerant recycling regulations were published on May 14,1993
(58 FR 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.
If you are not sure how to do what the guidance recommends, consult with
knowledgeable personnel in your company or organization.
A-l
-------
Compliance with the portions of the refrigerant recycling regulations that are not covered
by this 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 this 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 that 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 the
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 find 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 this guidance document,
showing, in detail, all the decision points and possible paths to follow to comply with the
amendments.
A-2
-------
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(s) 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 a.m. - 4 p.m. 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.
A-3
-------
-------
General Summary Flowchart
EPA 300-B-95-010
Is there
enough leakage to
trigger the amendment's
requirement to take
action?
Module C, D)
Is my
refrigeration system
subject to EPA's leak
repair requirements?
(Module B)
No specific
action required
Deadlines & Extensions
Verification Testing
Recordkeeping & Reporting
What to do if you pass/fail
the tests
Switching to retrofit/retirement
of the system
Mothballing
(Module E-1)
(Module E-2)
(Module G-1)
(Module E-2)
(Module E-2)
(Module H-1)
\.
^^<
^*^ Decide
t Kepair ^^ whether to reoair.
-v. retrofit, or retire
^the system
( STOP J
Mandatory repair,
retrofit or retirement of
system
Retrofit or
Retirement
Deadlines & Extensions
Recordkeeping & Reporting
Switching to repair the leak(s)
Release from obligation to
retrofit/retire the system
Mothballing
(Module F-1)
(Module G-2)
(Module F-2)
(Module F-2)
(Module H-2)
October 1995
A-4
-------
B. APPLICABILITY
-------
In this 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," but
this guidance refers to "systems" — the term more
commonly used in the industry.
The refrigerant recycling rule applies to systems that
contain and use a class I or class II substance as a
refrigerant.
• Class I refrigerants are mostly
chlorofluorocarbon (CFC) refrigerants or any
refrigerant mixture containing a CFC.
• Class II refrigerants are hydrochloro-
fluorocarbon (HCFC) refrigerants or any
refrigerant mixture containing an HCFC.
NOTE: If you are not sure whether you have a class I or
class II 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 this regulation are
triggered when an owner or operator of an industrial
process refrigeration system discovers that refrigerant is
leaking at a rate that would exceed 35 percent of the
total charge in a 12-month period. (See Module D for
more information on leak rates.)
EXEMPTION
SOR
EXCLUSIONS
Leak repair provisions of this
regulation do NOT affect systems
normally containing 50 pounds or
less of refrigerant.
B-l
-------
QUESTIONS
ANSWERS
Why does the same refrigerant
number begin with different letters;
for example, is R-12 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
II ozone-depleting substances. This includes CFCs,
HCFCs, and blends that contain CFCs or HCFCs.
The refrigerant recycling
amendments refers to " appliances."
I think of appliance?, 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 refrigerant recycling amendments.
I have 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 appliance!
If at least 50 percent of an appliance's capacity is
being used in 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 the
appliance's capacity is being used in an industrial
process refrigeration application, then this system
would not be considered industrial process
refrigeration. In this specific example, the system
would be comfort cooling with a 15 percent trigger rate.
The leak repair requirements apply
only if the independent refrigerant
circuit has more than 50 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.
B-2
-------
QUESTIONS
ANSWERS
What if my industrial process
refrigeration system has two
independent refrigeration circuits,
one with a full charge greater than
50 pounds, the other with a full
charge less than 50 pounds?
The circuit whose full charge is greater than 50
pounds would be subject to leak repair
requirements. The circuit whose full 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
compressor), the entire component is part of the
refrigeration system. Other piping or processing
equipment that contains solvents, raw materials, or
other nonrefrigerants is not part of the refrigeration
system.
B-3
-------
C. FULL CHARGE
-------
You MUST know the full charge
of your refrigeration system.
You MUST use an acceptable
method.
If you use method a, b, or c, it
is recommended that you
document (and are able to show)
how you determined the 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 full 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 full charge for a system:
1. The leak repair requirements of this law do not
apply to any system whose full charge is 50
pounds or less of refrigerant in any independent
refrigerant circuit.
2. To calculate the leak rate for a system, you need to
know the full charge (see Module D for more
information on leak rates).
To determine the full charge, you 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 refrigerant charge in
the system.
c. Use the manufacturer's information. Some
manufacturers specify the amount of refrigerant in
the full 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).
e. Combinations of a through d. For example,
suppose you have a system that consists of two
C-l
-------
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 how 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
margin of error in determining the
full char gel
Yes, but EPA recognizes that there is some margin of
error in any determination of the amount of refrigerant in
a system. If you have made your determination based
on the best information available and sound
professional judgment, the full 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
if you know it is incorrect.
Sometimes a manufacturer's statement of the full
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 that the manufacturer
did not anticipate. In some cases, the manufacturer
may simply have goofed, and it is obvious that the full
charge is much larger or smaller than the
manufacturer said. If the manufacturer has obviously
goofed, choose one of the other acceptable methods to
determine the full 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 full
charge number? If I change it,
should I recalculate all my leak
rate determinations?
Yes, you may change the full charge number if you
obtain new and better information. No, you do not have
to recalculate any previously determined leak rates. You
would, however, use the new full charge number in
calculating any future leak rates.
Do I have to use the same method
to determine full charge for all
No.
-------
systems at my facility?
D. LEAK RATE
C-2
-------
The trigger rate for industrial
process refrigeration systems
is 35 percent.
REPAIR
RETROFIT
RETIRE
D. LEAK RATE
Each time you add refrigerant to a system normally
containing 50 pounds or more of refrigerant (see Module C),
you should promptly calculate the leak rate. If the 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 the 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 the number of pounds of refrigerant you added
to return the system to a full charge and divide it by
the number of pounds of refrigerant in the normal full
charge for the system.
#lbs refrigerant added
#lbs refrigerant in normal full charge
2. Take the number of days that have passed between
charges (that 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).
#days 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 this is with the following formula:
LEAK RATE % =
365 days
pounds of refrigerant addt
- -
sd x
X
pounds of Full charge
10(
#days since refrigerant last add
D
ed
D-l
-------
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, then 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 you can. If the system is leaking above the
trigger rate, the law imposes strict deadlines for repairing
the leaks or retrofitting or retiring the system (see Modules
E and F). 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).
Reco rdkeeping/Repo rting
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 the full charge and leak rate.
For additional recordkeeping requirements, see
Module G, Recordkeeping and Reporting
Requirements.
D-2
-------
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 don't have
to fix leaks until 35 pounds of
refrigerant have leaked out,
right?
Wrong. What matters is the annual leak rate. The annual
leak rate is the amount of refrigerant that 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 the full charge), so you are already under a
deadline to promptly repair the leaks or retrofit or retire
the system. You do NOT get to wait until 35 pounds of
refrigerant have already leaked out before you start
figuring out how to solve the problem.
If the leak rate is higher than
the trigger rate (for example, a
leak rate of 50 percent per 12-
month period), am I 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 trigger 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?
You should calculate an annual leak rate each time you add
refrigerant or any time sound professional judgment
indicates 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.
-------
D-3
-------
E. LEAK REPAIR
-------
DECISION POINT!
Repair
Retrofit
or
Retire
NOTE:
In the recycling regulations, Evacuate"
means to remove refrigerant from a
system. It is comparable to the 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 inerts from a
system.
E. 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 the 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, a 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
parts 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.
E-l
-------
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 are 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 that 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 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.
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 off line), 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 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, the initial
verification test must be conducted as soon as practicable
after the repair work is completed.
-------
Follow-up Verification Test
A follow-up verification test must be conducted:
• within 30 days after the initial verification test,
where 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 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 is
operating. In this kind of situation, based on sound
professional judgment, the follow-up verification test may
be conducted prior to returning to normal operating
characteristics or conditions. However, the follow-up
verification test must be conducted at or near the normal
operating pressure where practicable, and at or near the
normal operating temperature where practicable.
Initial and Follow-up Verification Test
Methods
Initial and 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.
E-a
-------
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 than one year you must also submit the plan (see
Module F). If the follow-up verification test indicates that
the 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 and follow-up verification tests are required
following leak repairs when the refrigerant leak rate for a
system EXCEEDS the trigger rate . Initial and 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 the leak
has been successfully repaired.
Are there 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
that 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.
E-4
-------
QUESTIONS
ANSWERS
Must I repair all leaks on a system
to comply?
Repair efforts must 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 leak(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 time?
Yes, you are allowed to try to repair the leak(s) 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 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.
Do 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 E-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. Time extensions are not available for
other refrigeration systems except for system
mothballing (see Module H).
E-5
-------
REFRIGERANT RECYCLING AMENDMENTS
Activity (on ODS refrigeration system)
Evacuating the refrigerant
Adding refrigerant
Changing the oil
Adding oil
Replacing a gauge
Changing or calibrating a DP cell
Changing a pressure-relief valve
Drawing a sample of refrigerant or oil
Helping dismantle a system for disposal, if that person's work
may reasonably result in a release of refrigerant
Any of the tasks listed above, performed under the direct
supervision of a certified technician
Maintenance that would not reasonably release refrigerant
(such as painting; leak-checking; some electrical work; and
some insulation work)
Fixing leaks by tightening nuts or bolts, if no specific reason to
think the activity may go wrong and increase the rate of release
Any work on the system after the refrigerant has been
evacuated to the extent required by § 82.156
Is technician1
certification
required?
YES2
^
^
^
^
^
^
^
^
^
^
NO
^
^
^
Technician Certification Amendment to the National Recycling Program FR 55912 (11/9/93) (see Module K)
A certified technician is required unless the system (or isolated portion) has been evacuated to the level listed
in the rule
E-6
-------
F. RETROFIT AND RETIREMENT
OF LEAKING REFRIGERATION SYSTEMS
-------
EPA300-B-95-010
DECISION POINT!
Repair
Retrofit
or
Retire
EXCEPTION:
If you switched from repair to retrofit
or retire, you must notify EPA within
30 days from the day you switch.
However, you are still under the
12-month period provision from the trjne
the leak was discovered.
More time may be available.
F. 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
50 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
this 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 than 30 weeks from when
the order is placed. In this case, an additional 12-
month period is allowed. To receive this
extension, you must notify EPA within six
October 1995
F-l
-------
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.
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 think 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. You 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 the 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 failed 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 that you are
now below the trigger rate (see Module G).
October 1995
F-2
-------
EPA300-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 delivery time.
How do I obtain more time
to retrofit or retire the
system?
Within six months of 30 days after discovery of the
leak, notify EPA that you need the second 12-month
period and why and include the estimate for
completion of the work. (See Module G for
recordkeeping or reporting information.)
I followed the procedures
for obtaining the second 12-
month period to complete
my retrofit or retirement.
Several months later, I 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?
Notify EPA within 30 days of discovery of the new
completion date.
What happens if I follow the
procedures for obtaining a
second 12-month period to
perform a retrofit or
retirement, and then I am
told by the manufacturer of
a critical component that
the delivery will not allow
me to complete my retrofit
within two 12-month
periods?
You have until the end of the ninth month of the
second 12-month period to submit a request to EPA
for additional time.
October 1995
F-3
-------
EPA300-B-95-010
QUESTIONS
ANSWERS
I have developed a retrofit
plan and notified EPA of a
failed follow-up verification
test. During the second
repair effort, however, I
managed to successfully
repair the same leak(s).
Must I implement the
retrofit plan?
No, you are relieved of the obligation to retrofit but
you must 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
verify 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 you will use to
establish the leak rate. Submit those parameters
to EPA for approval (as described in Module
G, Recordkeeping and Reporting).
2. Take any further action necessary to reduce
leaks. Further action to reduce leaks might
include repairing smaller leaks that 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 proven impractical. In some cases, the
leak rate may be below the trigger rate
without further action, even though one or
more of the original repairs did not pass a
follow-up verification test.
3. Determine the new leak rate, using the approved
parameters. For example, this may include
filling the system, waiting for a defined
period of time, and seeing how much
refrigerant is needed to fill the system again.
NOTE: 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. You do not
get an extra 180 days added to that period.
October 1995
F-4
-------
EPA300-B-95-010
G. RECORDKEEPING AND REPORTING
REQUIREMENTS
October 1995
-------
FPA -3nn-R-QS.nl n
G. RECORDKEEPING AND
REPORTING REQUIREMENTS
It is advisable in ALL cases to
maintain records of the leak rate
and full charge.
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
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.
Leak Repair (Industrial Process
Refrigeration)
If you complete all the required repairs successfully
without needing additional time, the amendments do not
require any new recordkeeping or reporting. This means
that 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 and follow-up verification tests. If more time is
needed, or if the repairs do not pass follow-up verification
tests, additional recordkeeping and reporting are 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 failed follow-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;
October 1995
-------
EPA300-B-95-010
October 1995
• any repair work that has already been
completed; and the date when that work was
completed;
• the date(s), type(s) and results of the failed
follow-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 the parameters on how the 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 failed follow-up
verification test. You must keep the plan on-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 making the determination
that you need extra time, you must keep on-site,
and report to EPA:
• 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;
• 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
G-2
-------
EPA300-B-95-010
NOTE: You only get the amount of
extra time that is reasonably
necessary.
b) Notify EPA if you discover that the repairs will
take longer than you have previously told EPA.
Send this 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, the amendments do not
require any new recordkeeping or reporting. However,
you are still required to develop and maintain, on-site, a
retrofit or retirement plan.
The amendments have some additional requirements for
situations where you need an extension of time to
complete the retrofit or retirement, and for situations
where you are relieved of the duty to retrofit or retire a
system. These are described below.
1. If you are completing your retrofit or retirement
within the 12-month period, you must:
• maintain the retrofit or 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 there 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 full charge;
October 1995
-------
EPA300-B-95-010
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 the 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
how much time; and
• a copy of your retrofit or retirement
plan.
b) If you have already notified EPA, and then you
discover that the work will take longer to
complete than you have previously told EPA, you
must submit documentation with the reasons
within 30 days after discovering that more time is
needed. Include a new estimate of when the work
will be completed and the date of your original
notification to EPA.
If you have been required to follow the retrofit or
retirement timeline because repairs failed a follow-up
verification test, then:
a) If you complete the retrofit or retirement within
12 months after the 30 day period from
discovery of the leak, there are no additional
reporting requirements;
b) If you intend to be released from the requirement
to retrofit or retire the system by demonstrating
(within 180 days after the failed follow-up
verification test) that you have brought the leak
rate below the 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
October 1995
G-3
-------
EPA300-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 them 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 the follow-up
verification test?,.
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 that you are no longer required to retrofit or
retire the system.
Include in your notification to EPA:
• the identification of the facility;
• a description of the refrigeration system;
• the date of your original notification to EPA;
and
• the date work was completed on the system.
If your system is custom-built and you want the one-
year extension, then 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-I
-------
EPA300-B-95-010
the method used to determine the leak rate and
full charge;
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 the date of completion;
the reasons why you need an extension of time.
Include records sufficient for EPA to determine
that you qualify for the extra year. This means
you must demonstrate that the new or retrofitted
system is custom-built, and that a vendor has
quoted a delivery time of more than 30 weeks
from when an order is placed, for the system or
a critical component;
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 that you will
need more time (beyond a total of two years), then 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
-------
EPA300-B-95-010
Full Charge
If the full charge of an industrial process refrigeration
system is determined by establishing a range or combining
the use of an established range with any other acceptable
method (discussed in Module C), records must be
maintained.
These records must include:
• Identification of the owner or operator of the
system;
• Location of the system;
• Original range for the full charge of the system, its
midpoint, and how the range was determined;
• Any and all revisions of the full charge range and
how 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:
• Flow rate;
• Quantity or concentration of the 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
October 1995
G-6
-------
EPA300-B-95-010
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 following 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 the trigger rate and require
an extension, 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
the leaky 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 than a 12-month period is necessary
there will be additional recordkeeping and
reporting requirements.
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
You 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
October 1995
G-7
-------
EPA300-B-95-010
was successfully repaired during a
second repair effort, what should I
do?
follow-up verification test.
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 are met:
1. Additional time is requested because the new
or the retrofitted industrial process
refrigeration system is custom-built; and
2. 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
3. The owner or operator notifies EPA within six
months of the 30-day period following the
original discovery of a leak rate higher than 35
percent; and
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-8
-------
EPA300-B-95-010
H. SYSTEM MOTHBALLING
October 1995 G'9
-------
EPA300-B-95-010
Important Note:
System mothballingreqaires the
refrigerant to be removed from the
system to at leastatmospheric pressure
If the owner or operator intends to make
repairs to the system that require
opening the system, the refrigerant
must be removed to the 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 and follow-up verification
tests.
Applicability
When a system is mothballed, the time suspensions are
available for all types of systems, including commercial,
industrial process, and any other systems containing
more than 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 that may
be allowed in specific circumstances for industrial process
refrigeration systems.
Example of System Mothballing
If a comfort-cooling system with over 50 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 must be retrofitted or
retired within a 12-month period. However, if after
discovery of the exceedance of the leak rate, the owner of
the system voluntarily mothballs the system for a period
October 1995
H-l
-------
EPA300-B-95-010
of time, the requirement to repair leaks or retrofit or
retire the 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 from 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 while a system is
mothballed, and there is no time limit to make 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
process refrigeration 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?
No, system mothballing does not require a report to
EPA. However, the 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 that 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 other 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 you must
notify EPA of the extension of the completion date.
October 1995
H-2
-------
EPA300-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 are suspended during
mothballing. In the example you have given,
initial verification tests could be performed at any
time before bringing the 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 that, if you have evacuated the
system only to atmospheric pressure during
mothballing, a deeper vacuum will generally be
required before you open the mothballed system
to perform repairs.
October 1995
H-3
-------
EPA300-B-95-010
I. OIL CHANGES
October 1995
-------
EPA300-B-95-010
Why are we talking about oil
changes? That has nothing to do
with leak repair!
Maximum allowable pressure:
5 psig
NOTE: Changing oil at higher
than 5 psig is considered a violation
of the 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 the
refrigerant is recovered. The maximum pressure allowed
is 5 psig. This greatly reduces refrigerant emissions while
still allowing a slight positive pressure to force the oil
from the compressor.
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 minimize the loss of refrigerant from:
a) the oil, and b) the interior of the refrigeration system as
the oil comes out. EPA allows a slight positive pressure
to help expel the oil.
October 1995
1-1
-------
EPA300-B-95-010
J. GLOSSARY
October 1995
-------
EPA300-B-95-010
Appliance
Class I refrigerant
Class II 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 II
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 II substance as a refrigerant is an "appliance."
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 II substances are hydrochlorofluorocarbons
(HCFCs). A complete listing of class II 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 that 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 1995
J-l
-------
EPA300-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 in 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 the 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. Determining the full charge by appropriate
calculations based on component sizes, density
of refrigerant, volume of piping, and all relevant
considerations;
3. Using actual measurements of the amount of
refrigerant added or evacuated from an industrial
process refrigeration system; and/or
4. Using an established range based on the best
available data, regarding the normal operating
characteristics and conditions for the system,
where the midpoint of the range will serve as the
full charge and where records are maintained in
accordance with 40 CFR 82.166 (q).
October 1995
J-2
-------
EPA300-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 50 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 normally 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
that would release class I or class II 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
-------
EPA300-B-95-010
Reclaim refrigerant
Recover refrigerant
Refrigerant circuit
Sound professional judgment
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 the 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 that 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
undertaken 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
-------
EPA300-B-95-010
Technician
Any person who performs maintenance, service, or
repair that could be reasonably expected to release class
I or class II 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 MV AC-like
appliances, that could be reasonably expected to release
class I or class II 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
-------
EPA300-B-95-010
K. REFERENCES
October 1995
-------
EPA300-B-95-010
K. REFERENCES
STRATOSPHERIC OZONE INFORMATION HOTLINE: 800-296-1996
The hotline is open between 10:00 a.m. and 4:00 p.m. Eastern time.
STRATOSPHERIC PROTECTION DIVISION'S INTERNET HOME PAGE:
HTTP:\\WWW.EPA.GOV\DOCS\OZONE\INDEX.HTML
STRATOSPHERIC OZONE PROTECTION RULEMAKING SUMMARY
Section 608 - National Recycling Program
58 FR 28660 (5/14/93)
I. Technical Amendments to the National Recycling Program:
FR 42950 (8/19/94)
A. Amends the final rule by making clarifications and making
technical corrections.
II. Technician Certification Amendment to the National Recycling
Program: FR 55912 (11/09/94)
A. Establishes the process by which EPA can review and approve
voluntary technician certification programs that apply by December
9,1994 to be "grandfathered."
B. 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 fact 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
-------
EPA300-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 facility/unit/process.
Applicability determinations are made available through either the
Technology Transfer Network (TTN) or the Stratospheric Ozone Information
Hotline. The TTN can be accessed via computer modem at (919) 541-5742; for
more information regarding the TTN, call (919) 541-5384 between 1:00 p.m.
and 5:00 p.m. Eastern time.
October 1995 K'2
------- |