# Memorandum

To: Julius Banks From: Bill Noel, SAI C and Nimmi Damodaran and Beth Scherer, Stratus Consulting Inc. Date: 4/19/2007 Subject: Data Collected Under California Rule 1415: Reduction of Refrigerant Emissions

from Stationary

Refrigeration and Air Con ditioning S ys tems Similar to the Environmental Protection Agency ’s requirements under Section 608 of the Clean Air Act Amendments of 1990 (CAAA), the purpose of California’s South Coast Air Quality Management District’s (SCAQMD’s) Rule 1415 is to reduce emissions of Class Iand Class II refrigerants from stationary refrigeration and air conditioning systems by requiring any

person within in SCAQMD’s jurisdiction who owns or operates a refrigeration sy stem to reclaim, recover, or recycle refrigerant and to minimize refrigerant leakage. A refrigeration s ys tem, is defined for the purposes of the rule as any non - vehicular equipment used for cooling or freezing, which holds more than 50 pounds of, any combination of Class Iand/or Class II refrigerant, including, but not limited to, refrigerators, freezers, or air conditioning equipment or systems. Under Rule 1415, SCAQMD collects the following information every two years from owners and operators of stationary refrigeration s ys tems holding more than 50 pounds o f an ozone depleting refrigerant through the use of a standard registration form (http://www.aqmd.gov/prdas/forms/1415form2.doc ).  Number of refrigeration systems in operation  Ty

pe of refrigerant in each refrigeration s ys tem  Amount of refrigerant in each refrigeration s ys tem  Date of last annual audit or maintenance performed for each refrigeration system  Amount of additional refrigerant charged every year. For the purposes of the rule, additional refrigerant charge is defined the quantity of refrigerant (in pounds) charged to a refrigeration system in order to bring the s ys tem to a full

- capacity charge and replace refrigerant that has leaked. SCAQMD provided EPA with completed registration forms spanning from 2000 to 2006. The majority of these forms are grouped into the following usage years, 2000 and 2001, 2002 and 2003, and 2004 and 2005. The sectors that are represented b y these forms include the following:  Supermarkets  Office buildingsStratus Consulting Memorandum (Dra ft, 4/19/2007)

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###  Schoo ls  Hospitals  Food processing  Pharmaceutical manufacturing. The following three tables, which summarize the SCAQMD data that was anal yz ed for the anal ys is of average leak rates for comfort cooling and refrigeration equipment and input to the regulatory

imp act anal ys is of proposed changes leak repair requirements under Section 608 of the CAAA. The tables represent data from 2004 and 2005, and are divided by the type of equipment used (i.e., commercial refrigeration, comfort cooling, and industrial process refrigeration). They

specify the number of pieces of equipment represented in each sector and the percent of the total number of each type of equipment represented in this sample. Table 1 summarizes the commercial refrigeration equipment and North American Industrial Classification System (NAI CS) codes from the SCAQMD data. Table 1. Commercial Refrigeration. NAICS Type of Entity Number of Pieces of Equipment Percent of Total

Equipment 44511 Supermarkets and Other Grocery (except Convenience) Stores 1722 100%


### Table 2 summarizes the comfort cooling equipment and NAICS codes from the SCAQMD data. Table 2. Comfort Cooling. NAICS Type of Entity Number of Pieces of Equipment Percent of Total

Equipment 71 Arts, Entertainment, & Recreation 19 0.7% 32 Building Products Manufacturing 26 1.0%

--- Colleges and Universities 167 6.2% 55 Company Management 2 0.1% 23 Construction 2 0.1% 52 Finance and Insurance 54 2.0% 31 Food Manufacturing 6 0.2% 11 Fo restry, Fishing, Hunting, and Agriculture Support 4 0.1% 62 Health Care & Social Services 106 3.9% 51 Information 451 16.7% 72 Lodging & Food Services 53 2.0%Stratus Consulting Memorandum (Dra ft, 4/19/2007)

Page 3 33 Metal Manufacturing 458 17.0%

--- Multi

-purpose 2 0.1%

--- Non

-profit entities 17 0.6% 81 Other Services 17 0.6% 54 Professional Services 80 3 .0% 53 Real Estate Rental & Leasing 481 17.8% 45 Retail Stores 176 6.5%

--- Schools, Public Administration or other Public Institutions 508 18.8% 48 Transpotration 42 1.6% 22 Utilities 30 1.1%

Total: 2,701


### Tale 3 summarizes the process refrig eration equipment by NAI CS codes from the data. Table 3. Industrial Process Refrigeration. NAICS Type of Entity Number of Pieces of Equipment Percent of Total

Equipment 3364 Aerospace Product and Parts Manufacturing 13 3.72% 311111 Animal Food Manufacturing 4 1.15% 3116 Animal Slaughtering & Processing 22 6.30% 3118 Bakeries & Tortilla Manufacturing 7 2.01% 31212 Bottled Water Manufacturing 7 2.01% 813910 Business Associations 1 0.29% 327310 Cement Manufacturing 5 1.43% 812220 Cemeteries and Crematories 3 0.86% 325 Chemical Manufacturing 6 1.72% 334 Computer and Electronic Product Manufacturing 3 0.86% 3341 Computer and Peripheral Equipment Manufacturing 8 2.29% 3222 Converted Paper Product Manufacturing 14 4.01% 3115 Dairy Product Manufacturing 3 0.86% 22111 Electricity Generation 4 1.15% 332 Fabricated Metal Product Manufacturing 9 2.58% 311 Food Manufacturing 21 6.02%
3114 Fruit & Vegetable Preservation and Specialty Food

Manufacturing 10 2.87%Stratus Consulting Memorandum (Dra ft, 4/19/2007)

Page 4 31 General Manufacturing 11 3.15% 327213 G lass Container Manufacturing 7 2.01% 325120 Industrial Gas Manufacturing 32 9.17% 3391 Medical Equipment and Supplies Manufacturing 11 3.15% 332431 Metal Can Manufacturing 3 0.86% 332116 Metal Stamping 3 0.86% 339 Miscellaneous Manufacturing 1 0.29% 3363 Motor Vehicle Parts Manufacturing 3 0.86% 2212 Natural Gas Distribution 4 1.15% 211 Oil & Gas Extraction 6 1.72% 3119 Other Food Manufacturing 2 0.57% 32511 Petrochemical Manufacturing 2 0.57% 32411 Petroleum Refineries 23 6.59% 3254 Pharmaceuti cal and Medicine Manufacturing 29 8.31% 48691 Pipeline Transportation of Refined Petroleum Products 4 1.15% 326111 Plastics Bag Manufacturing 1 0.29% 32616 Plastics Bottle Manufacturing 9 2.58% 326140 Polystyrene Foam Product Manufacturing 2 0.57% 323 11 Printing 25 7.16% 32521 Resin and Synthetic Rubber Manufacturing 18 5.16% 32562 Rubber Product Manufacturing 4 1.15%
3344 Semiconductor and Other Electronic Component

Manufacturing 1 0.29% 3312 Steel Product Manufacturing from Purchased Steel 2 0.57 % 339112 Surgical and Medical Instrument Manufacturing 3 0.86% 32562 Toilet Preparation Manufacturing 2 0.57%
3212 Veneer, Plywood, and Engineered Wood Product

Manufacturing 1 0.29% Total: 349