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AUG-31-1998 13 : 125 FRDI1 FMD EASTERN 

Air Docket No. A-92.-()} VID.H 

Page 2 

August 31, 1998 

TO 91 2025652093 P.02 

3. Ref: 82.1 S6(1)2(ii)-While TV A supports the creation of a multi-level leak-me system 

for regulating industrial proceiS remgeration systems, we bdieve that the criteria upon 

which such a multi-levelleak rate system is based should be reformulated. This 

reformulation would allow reftigerant systems (appliances) characterized by less than 

all four criteria to be exempt ftom the new 20 percent leak-rate level and thus remain 

at the 3S percent leak·rate level. Under a reformulated nrulti-rate system, refiigerat.ion 

meeting certain combinations of two or three criteria should be exempt ftom the 20 

percent leak rate siru:e the additive impact of such combinations will likely make the 

equipment so leak prone that the 20 pcroent leak rate cannot be achieved. 

4. Ref. 82..152(i)2(ii)--TV A believes that reftigeration systems that use river water to 

cool condenser tubes should be placed in a special (new) cat~ory that is aJlowed the 

3 5 percent leak rate. The erosive nature of river water results in an inherently higher 

leak rate for such systems than the leak rate for systems using treated water or air. 

Our detailed comments on these :fuur issues are provided below. 

1. Method foe caJc:ulathag leak rate (81.152 definitiollll 

The preamble discusses four methods for calculating leak rates and proposes the 

third method (i.e., the use of the method that yields the higher calculated leak rate 

between the annualizing method and the rolling avemge method) as EPA's lead 

option. At. recognized by EPA in the preamble, the use of this method penalizes 

appliance owners whose appliances leak below the appDcable leak rate but do not 

show signs of leakage until they have lost a relatively large percentage of charge. 

The use of the third option would be an unfair extension of the «<annualizing 

method,. because by placing a 365-day cap in the denominator, it allows the 

"scaling up, but not the .. scaling down,. of leaks to calculate the quantity that 

would be lost over a year-long period. 

Systems with slow leaks would be unduly penalized by the use ofEP A• s proposed 

leak option for defining leak rates. 

In view ofthe conservatism. of the method proposed by EPA as its lead option, 

TV A suggestS that the fourth option (either method for a given appliance) be 

selected to colculate leak rates. Under tlris option, appliance owners would choose 

and be required to stay with the method of their choice to calculate leak rates. 

Changing to the alternative leak.-rate method would only be allowed if technical or 

operational changes to a specific appliance are made and documented as such, to 

justifY the change ofleak-rate method. 
AUG- 31- 1998 13: 05 FR0'1 FMD EASTERN 

Air Docket No. A-92-01 VITI.H 

Page 3 

August 31, 1998 

TO 912025652003 

2. Io a..uw;e appropriAte application of the major reductions for proposed Jesk 

rates in Section 82.156, C:i).Dtrol m t hillm sbouJd he subjest to tile 50 

~eg rul!::. 

The proposed rule seeks to lower the maximum allowable leak rates fur 

rdiigeration equipment including both industrial process refiigtntion equipment 

and comfort-cooling cbillers. Since the leak thresholds (per 82.156) that trigger 

the repair requirement actions depend on the type rdiigeration equipment 

(commercial, industrial. or eomfort·cooling}, we believe it would be appropriate 

for EPA to include nuclear plant control room chillers as industrial process with 

other similar (electrical generation) chillers that are required to use the "50 percent 

test" in characterization of their use "type." This wiD assure that no undue burden 

is placed on an owner/operator of an appliance, resulting from the appli<:ation of an 

inappropriate (too low) leak-rate for the operating characteristics of that appliance. 

An inappropriate categorization of a reftigen.tion unit into a specific categoty e.g., 

comibrt cooling would result in the imposition of' a leak rate standard more 

stringent (i.e .• an undue burden) than the .,owest achievable level" reasonably 

characteristic of that appliance. 

In revisions to the leak repair rule in 1995, EPA recognized that refiigeration 

equipment (commercial. industrial, or comfort-cooling) is to be distinguished for 

purposes of Section 608 by considering how the appliance is used, 60 Fed. Reg. 40 

(August 8, 1995). The definition of"industrial process refiigeration, was then 

amended to clarify that characterization of use is a met or in determining if an 

appliance is industrial process refiiBeration equipment. Despite this recognition, 

EPA has continued to insist that chillers used in part to cool nuclear control rooms 

are NOT industrial process refrigeration equipment. These chillers are in &.ct 

"dire«<y linked to the generation of electricity" si.nce they are vital to the proper 

functioning of the instruments in the control panel. If the control panel. 

temperatures were not regulated. it would be impossible to operate the nuclear 

plant. 

No other aspect of the nuc-lear process is as directly linked to the (industrial 

prooess) generation of electricity as the equipment in the control room. The mere 

fact that these particular chillers provide the incidental benefit of comfortable 

environment fur the human operators within the control room does not change 

their essential purpose. The primai)' and overriding purpose of these chillers is to 

maintain the temperature of the electrical (industrial process) equipment in the 

contTol room a:t a level w nducive to the proper functioning of this equipment. 

Additionally. the custom built parts used in these types of chillers are unique and 

not easy to replace. Furthermore, these chillers function u part of the nuclear 

process as evidenced by the NRC requirements that force our nuclear reactors to 

P.133 
AUG-31-:19'38 13 : 126 FROt1 F11D EASTERN 

Air Docket No. A-92-01 VIIl.H 

Page4 

August 31, 1998 

TO 912025652093 P.04 

be shut down in the event that the control room temperatures exceed 1 04• F due to 

the risk of failure ofthe equipment in the control room at these temperatures. 

From NRC's Reg. NUREGICR.-4191, NRC recogni~ that"instrument 

impairment" may occur in as little as 45 minutes if oooling is lost to the control 

room. During a July 1998 NRC meeting, it was noted that when control room 

tempera~s reacl1 the 90~ control room instrumentation starts behaving 

erratically. 

EPA's definition of«industrial process refrigeration» incorporates the "SO percent 

test>' which is used in deciding whether a particular mftigeration unit can be 

considered industrial prOQeSs refrigeration equipment. At, per this tes~ "where one 

appliance is used fur both industrial process refii,geration and other applications, it 

will be considered industrial process rttfrigeration equipment if 50 pezcent or more 

of its operatitlg capacity is used for industrial process refrigeration" 40 CFR 

§82.152. TVA believes that the use of the "50 percent rule" is the most eguitabl§ 

approach for detenninio.g the category in which to place an appliance used for 

multiple purposes. In fact, EPA has encoun,ged the application of the "50 percent 

rule" to appliances used as both industrial process re&igeration equipment and 

comfort cooling. See 60Fed. Reg. 40 (AugustS, 1995). Therefore it would be 

consistent for EPA to apply the "SO pen:ent rule" to determine the category "type'., 

of a cbilla- used primarily for cooling nuclear plant electrical equipment (associated 

with tbe (:Ontrol room) and only incidentally (often as little as ten peroent) for 

providing a comfurtable environment for human inhabitants of the oontrol room. 

Reliable engineering methods ate available to determine the division of the ooollng 

capacity (industrial process versus incidental environmental cooling) of a chiller 

that is being used for a dual purpose. In TV N s situation, we have determined that 

more than 90 percent of the cooling capacity of the chillers used to cool the 

control room at nuclear plants is utilized in maintaining the temper8lure of the 

electrical equipment at operable levds. With less than ten percent of the capacity 

of these cllillers used for environmental comtbrt, it is dearly unreasonable to 

categorize these units as oomfon-cooJers and not as industrial processes 

reftiger-ation equipment. 

TV A therefure ur~ EPA to eliminate the inequity of this situation by providing 

that the '"SO percent rule" can be applied to appliances used for the dual purpose of 

cooling nuclear plant control room electrical equipment and incidentally providing 

a comfortable environment for the human operators in the control room. 
AUG- 31- 1998 13:07 FROM FMD EASTERN 

Air Docket No. A-92-01 Vlll.H 

Page S 

August 31, 1998 

TO 912025652093 

3. RefoJ'Dlu)atioa of the criteria uooa which the multi-level leak-rate mteejs 

estab!i.sbld {8kt56 (i){l()(i-h) 

EPA has proposed bi-level leak rate system for industrial process refrigeration 

equipment (35 petcent vemJS 20 percent) based on whet.hc;r the equipment is custombuilt. the equipment's date of manufit~ compressor configuration. and number of 

refrigerant loops. More specifically, und~ the current proposal, industrial process 

refrigeration equipment would be subject to a 20 ~t leak rate unless it rne«s all 

f9m of' the following criteria: (Per Table 3 of tbe EPA Summary Fact Sheet) 

(1) The reftigeration system was built in 1992 or before; 

(2) The refiigeration equipment is custom-built; 

(3) The refiigerat.ion system has an open-drive compressor; and 

(4) The system is direct expansion (single loop). 

As proposed, systems that meet all four criteria would remain at the 35 percent peryear maximum permissible leak rate. This allowance for equipment of certain age a.nd 

de$ign appeats to have been made on the basis that the 35 percent leak rate represents 

the (~west achievable level" of leakage that such equipmEmt can attain, taking into 

aC<:OWlt the technology available and costs/benefits and lead times involved. 

While TVA applauds the creation of this allowance for equipment of certain age and 

unique desigl\ we urge EPA to reevaluate the furmulation of this allowance. We feel 

that each criteria by itself; makes a refrigeration system (appliance) sigriliica.otly more 

prone to ~e. The additive impact of just two or three of these criteria would in 

fact define a ''class'' ofrefiigeration equipment (applianoes) that bas inherently higher 

leak rate characteristics, and thus should be kept at the 35 percent leak rate level. For 

example, much of our Jarge refrigeration equipment purchased m the 1970s has, .bx ~-fcom the manufkcturer eight to ten percent leak rate characteristics due to &eS1 

lubrication design, and this, keep in mind is the new aufeli~ condition. Aging 

clearly increases these inherent leak rates (often as much as two or three times). 

Furthermore, components and service items for these older appliances are routinely 

specq) order, custom fabrication, and thus long-lead time parts. Certain combinations 

of just two or three of these criteria oould make an appliance extremely difficult to 

meet a leak rate less than 35 percent. 

For these reasons we urge EPA to consider refonnulation of the criteria requirements 

of Section 86.156 (i)(20(t-li) such that specific combinations of two or three of the 

criteria be used to qualify appliances to remain at the 35 per<:ent leak me lew!. We 

would be glad to diSCUS$ further with you tbe combinations that we believe should 

qualify to remain at the 35 percent leak rate. 

P. 05 
JG-31-1 998 13:07 FROM FMO EASTERN 

Ak Docket No. A-92-01 Vlfl.H 

Page6 

August 31, 1998 

TO 912025652093 P.06 

4. C.hillerJ using river water to provide condeauer cooling sbould be all.o~tdjo 

remain at t!te 35 qercent leak repair rate (86.156(i)(2) 

EPA bas proposed a bi-levelleak me system (35 percent versus 20 percent) for the 

industrial process sector presumably on the basis that the leak rate should be 

established at a level achievable by the equipment in question. We support the 

creation of a muJti-Jevelleak rate system since it recognizes the differences between 

refrigeration equipment based on age and design considerations. TV A urges EPA to 

add this (presently un.recognized) design consideration to those proposed for use in 

deciding the leak tate applicable to a system. This would be specifically fur those 

systems which use river water to provide condenser c:ooling. 

Due to the erosive and corrosive nature of river water, such condenser tubes are 

constantly degrading (five year life is not uncommon), resulting in the inherent leak 

rates for these systems to be much higher than for most refrigerant systems which use 

treated or potable water, closed loop cooling toVY-ers or air-cooled condensers. These 

river water cooled type systems should remain at the 35 percent leak rate. Rebuilding 

t~ systems is not a viable option since it would be a massive project and very cost 

prohibitive. 

The replacement of these systems with systems using treated water or air is equaJly 

expensive and would constitute a change far in excess of that necessary to meet the 

"lowest achievable level" when considering technology available, and costlbene.fit 

ratios. We therefore suggest that Section 82.156(i}(2) of the proposed regulations be 

~ed ruch that industrial process re.fiigeration equipment using river water fur 

cooling condenser tubes reg\n subject to the 35 percent leak rat~ instead of the 

proposed 20 p!UOOnt tate. 

If you have any questions concerning these comments, please contact Lee F. Graser at 

(423) 632-8517, or e-mail at lfgraser@tva.gov. 

Sinc«dy, 

Jon "'~ . r-.rn\l!'!V 

Manager 

Environmental Management 
AUG- 31- 1998 13: 00 FROt1 FMD EASTERN 

rm 

August 31' 1998 

Air Docl<et No. A-92-01 Vlll.H 

U.S. Environmeot:al Protecticn Agency 

401 M Street, SW 

Waslllngton, DC 20460 

To Whom It May Concern: 

TO 912825552093 P.0? 

R£: PROTECTION OF STRATOSPHERIC OZONE; REFRIGERANT RECYCLING; 

SUBSTITUTE REFRIGERANTS (PROPOSED RULE, 63 fR 32043-32099, JUNE 11. 

1998) 

The Tennessee Valley Authority (TV A) appreciates the opportunity to convnent on EPA's 

Proposed Rule; Protection of Stratospheric Ozone; Refrigerant Recycling; and Substitute 

Refiiserants. 

Our comments address four specific areas of the proposal 

I. Ref. 82.15 2--TV A suggests that, from among the different options discussed for tb.e 

calculation of' ••teak rate," EPA select. the fourth option (a~ of annualizing or 

rolling average) instead of the third option (the more conservative of the two methods) 

as proposed. The EPA proposed option would not be equitable in that it would 

unduly penalize owners of refrigeration systems with slow leaks. 

2. Ref. 82.15()......Some of the newly proposed teak rates are 66-71 percent less than 

current leak rates e.g., comfort cooling current leak rate 15 percent, proposed leak 

rateS pemmt, per Table 3 of EPA's Fact Sheet Summary. It thus, is of paramount 

importance that every effort be made to assure that each specific appliance is classified 

into the "Type" (commercial, industrial process, comfort cooling) that most closely 

fits. This will assure that no undue burden is placed on an owner/operator of an 

appliance, resulting in the application of an inappropriate (too low) ltAk-rate for the 

operating cha.racteristics of the appliance. We seek to eliminate semantic distinctions 

that currently prevent ehillers designed primarily to cool electrical equipment (essential 

to the electrical generation industrial process) in the nuclear plant control rooms .from 

being considered industrial process reftigeration equipment. For this reason we 

strongly urge EPA to extend the "SO percent test" (industrial process load vs. comfort 

cooling load) that applies on other electrical generation refrigeratron systems to 

nuclear plant control room chillers. This will assure an equitable application of the 

new leak rates as proposed m Section 82.156. 
RUG- 31- 1998 13: 03 FROM FI1D EASTERN 

Air Docket No. A-92..01 VIltH 

Page2 

August 31, 1998 

TO 9 12025652093 P. 08 

3. Ref. 82.156(i)2(ii)-Wbi.le TV A supports the creation of a multi-level leak-rate &ystem 

for regulating industrial process refrigeration systems, we believe that the criteria upon 

wblch such a multi-level leak rate system is based should be reformulated. This 

reformulation would allow refiiguant systems (appliances) characterized by less than 

an four aiteria to be exempt from the new 20 percent leak-rate level and thus remain 

at the 3S percent leak-rate le\.-el. Under a reformulated rtrulti-rate system, refrigeration 

meeting <::ertain combinations of two or th.""e.e criteria should be exempt from the 20 

percent leak rate since the additive impact of such combinations will likely make the 

equipment so leak prone that the 20 percent leak rate cannot be achieved. 

4. Ref. &2.152{i)2(ii)-TV A belle'leS that refrigeration systems that Use river water to 

cool condenser tubes should be placed in a special (new) category that is allowed the 

35 ~ Jeak cate. The erosive natul"e of river wate.r resuJts in an inherently higher 

l¢.ak rate for such yst~s. than the leak rate fur systems using ~ed water or air. 

Our detailed comments on these four wues are provided below. 

1. :Method for ukulatiog leak rate (82.152 defiuitlons) 

T~ preamble discusses four methods for calculating leak rates 'and proposes the 

third method (i.e., the use of the method that yields the higher calculated leak me 

between the annuali:r.ing method and the rolling average method) as EPA's lead 

option. As recopized by EPA in the preamble, the use of this method penalizes 

appliance owners whose appliances leak below the applicable leak rate but do not 

show signs ofteakage until they have lost a relatively large: percentage of charge. 

The use of the third option would be an unfair extension of the "annualizing 

method" because by placing a 365-day cap in the denominator, it allows. the 

.. scaling up" but not the c<scaling down~ of leaks to calculate the quantity that 

would be lost over a year-long period. 

Systems with slow leaks would be unduly penalized by the use ofEPA's proposed 

leak option for defining leak rates. · 

In view of the conservatism of the method proposed by F.P A as its.le.ad option, 

TVA suggests that tbe fuurtb option (either method for a given apptiance) be 

selected tO calculate leak rates. Under this option, appliance owners would choose 

and be required to stay with the method of their cboioe to calculate leak rates. 

Changing to the alternative leak-rate method would only be allowed if technical or 

operational changes to a specific appliance are mack and documented as su~ to 

justifY the change ofleak~rate method. 
AUG-31- 1998 13:09 FROM FMD EASTERN 

Air Docket No. A-92-0 1 Vfii.H 

Page3 

Augu$t Jl, 1998 

TO 912025552093 P.09 

Z. I o anure appropriate application 9f the major reductions fw propostd !eak 

mtq in Section 8Z.156.. control room millers should be subject to the SO 

.;ett_ent rule. 

Tbe proposed rule seeks to lower the maximum allowable leak rates for 

refrigeration equipment including both industrial process reliigeration equipment 

and comfon~oling chillers. Since the leak thresholds (per 82.155) that trigger 

the repair requirement actions depend on the type refrigeration equipment 

(commercial. industrial, or com.fort-coofing), we believe it WQuld be appropriate 

for EPA to include nuclear plant e<>ntrol room.chillers as industrial process with 

other similar (electrical generation) chillers that are required to use the .. 50 percem 

test" in cbaracterization of their use "type." This will assure that no undue burden 

is placed on an owner/operator of an appliance, resulting from the application of an 

inappropriate (too low) leak-rate for the operating characteristics of that appliance. 

An inappropriate categorizati<>n of a refrigeration unit into a specific category g.~ 

comfort cooling would result in the imposition of a leak rate standard more 

stringent {i.e., an undue burden) than the "lowest achievable level" reasonably 

characteristic of that appliance. 

In revisions to the leak repair rufe in 1995, EPA recognized that refrigeration 

equipment (commercial, industrial, <>r comfon-cootiog) is to be distinguished for 

purposes of Section 608 by considering how the appliance is used, 60 Fed. Reg. 40 

(August 8, 1995). The definition of"industrial process refiigeration" was then 

amended to clarify that cbaracterization of use is a factor in determining if an 

app6ance is industrial proeess refrigeration equipment. Despite this recognition, 

EPA has continued to insist that chillers used in part to cool nuclear control rooms 

are NOT industrial process refrigeration equipment These chillers are in fact 

"directly linked to the generation of electricit}'' since they are v.ital to the proper 

functioning of the instruments in the control panel. ffthe control panel 

temperatures were not" regulat~ it would be impossible to operate the nuclear 

plant. 

No other aspect of the nuclear process is as directly linked to the (industrial 

pr~) generation of electricity as the equipment in the control room. the mere 

fact that these particular chillers provide the incidental benefit of comfortable 

environment for the human operators within the control room does not change 

their essential purpose. The primary and overriding purpose of these chiilers is to 

maintain the temperature of the electrical (industrial process) equipment in the 

comrol room at a level conducive to the proper functioning of this equipment. 

Additionally, the custom built parts used in these types of c.billers are unique .and 

not eas.y to replaee. Furthermore, these chillers function as part of the nut-lear 

process as eviden<:ed by the NRC requirements that fbrce our nuclear reactors to 
AUG-31-1998 13:09 FROM FMD EASTERN 

Nr Docket No. A-92-01 VIII.H 

Page4 

August31~ 1998 

TO 912025552093 P .10 

be shut dovm in the event that the control room temperatures exceed 1 ~ P due to 

the risk of failure of the equipment in the control room at these temperatures. 

From NRCs Reg. Nt.JREG/CR-4191, NRC recogniz;ed that .. instrument 

impairment" may occur in as little as 45 minutes if oooling is lost to the control 

room. During a July 1998 NRC meeting, it was noted that when conttol room 

temperatures reach the 90s, control room instrumentation starts behaving 

erratically. · 

EPA's definition of"industrial proc-ess retiigeration'' incorporates the "50 percent 

test"' which is used in deciding whether a particular refiigeration unit can be 

cons ~ industrial process reftigeration equipment. As per tbis test, ~here one 

appliance is used for both industrial process refrigeration and otbet applications, it 

wiU be considered industrial process refiigeration equipment if 50 percent or more 

of its operating capacity is used for industrial process refii,geration" 40 CFR 

§32.152. TV A believes that the use of the «so percent rut~· is the most egjlitable 

approadt for detenniniag the category in wbidi to place an appliance used fO! 

rnultiple purposes. In fact. EPA has enc:ouraged the application of the ·•so percent 

rule" to appliances used as both industrial process refrigeration equipment and 

comfort cooling. See 60Fed. Reg. 40 (AugustS, 1995). Therefore it would be 

consistent for EPA to apply the "SO percent rule" to determine the category ype'' 

of a chiller used primarily for cooling nuclear plant electrical equipment (associated 

with the control room) and only incidentally (often as little as ten percent) for 

providing a comfortable environment for human inhabitants of the control room. 

Reliable engineuing methods are available to determine the division of the cooling 

c:apaciry (mdustrial prooess versus ineide.ntal environmental cooling) of a du11ec 

that is being used for a dual purpose. tn TV A's situation, we have det~ that 

more than 90 percent of the cooling capacity of the chitters used to cool the 

control room at nuclear plants is utilized in maintaining the temperature of the 

electrical equipment at openble levels. With less than ten percent of the capacity 

of these chillers used for environmental comfort, it is clearly unreasonable to 

categorize these units as comfort-coolers and not as industrial processes 

refrigeration equipment. 

TV A therefore urges EPA to eliminate the inequity of this situation by providing 

that the "SO percent ruJe,' ean be applied to appliances used for the dual purpose of 

cooling nuclear plant control room electrical equipment and incidentally providing 

a comfortable environmeat for the human operators in the oontrol room. 
AUG 31~1 998 13:10 FROM FMD EASTERN 

Air Docket No. A-92-0 1 Vlll.H 

Page S 

August 31, 1998 

TO 912025552093 P. 11 

3. l.efom.ula.tign ofj l,?e_g:iteria U,POO whkh the muld-levelleak-rate SyStem is 

m2blished (82.156 (i}(20Ci·iil 

EPA has proposed bi-level leak rate system for industrial process refrigeration 

equipment (35 percent versus 20 percent) based on whether the equipment is custombwlt~ the equipment's date ofmaoufacture, oompressor configu.rati~ and number of 

miigerant loops. More specifically, undu the current proposal. industrial process 

refrigeration equipment would be subject to a 20 percent leak rate unCis it meets all 

&Y! of the following criteria: (Per Table 3 of the EPA Summary Fact Sheet) 

(1) The refiigeration system was built in 1992 or before; 

(2) The remge.ration equipment is custom-built; 

(3) The refrigeration system has an open-drive compressor; and 

(4) The system is direct expansjon (single loop). 

A3 proposed, systems that meet all four criteria would remain at the 3 5 percent peryear rnaxmmm penniSSl"ble leak rate. This allowance for equipment of certain age and 

design appears to have been made on the basis that the 3 5 percent leak rate represents 

the «Jowest achievable level" ofleakage that such equipment can attain, taking into 

account the technology available and costs/benefits and lead times involved. 

While TV A applauds the creation of this allowance for equipment of certain age and 

unique desian, we urge EPA to reevaluate the formulation of this allowance. We fee1 

that each aiteria by itself. makes a refrigeration system (appliance) significantly more 

prone to leakage. The add"rtive impact of just two or three of these criteria would in 

&ct define a "class'' of refrigeration equipment (appliances) that has inherently higher 

leak rate characteristics, and thus should be kept at the 35 percent leak rate level. For 

example, much of our large refrigeration equipment purchased in the 1970s has, 2y 

d~sim from the manufacturer eight to t~ percent leak rate characteristics due to seal 

lubrication design, and this, keep in mind is the new as delivered condition. Aging 

clearly increase3 these inherent leak rates (often as much as two or three times). 

Furthermore. components and service items for these older appliances are routinely 

special order, custom fabrication, and t1tus long-lead time parts. Certain combinations 

of just two or three of these criteria could make an appliance extremely difficult to 

meet a kale rate Jess than 35 percent 

For these reasons we urge EPA to consider refommlation of the criteria requirements 

of Section 86.156 (iX20(,..ii) such that specific combinations of two or three of the 

criteria be used to qualifY applia.n<:es to remain at the 3 5 percent leak rate level. We 

would be glad to discuss further with you the combinations that we believe should 

qualifY to remain at the 35 percent leak rate. 
AUG-31- 19'38 13: 11 FROM FI1D EASTERN TO 912025652093 P.t2 

AirDocket No. A-92-01 Vlll.H 

Page6 

August 31, 1998 

4. ChiU.tt:t.,Usine river wat« to p.mide condenser coolin: should be aUowed to 

remain 1_t t!!e.A5z~t£ntJ~air .. nate (86.156(i)(2) 

EPA bas proposed a bi-levelleak rate system (35 percent versus 20 percent) for the 

industrial process sector presumably on the basis that the leak rate should be 

established at a level achievable by the equipment in question. We support the 

creation of a multi-level leak: rate system since it recognizes the differences between 

refrigeration equipment oased on age and design considerations. TV A urges EPA to 

add this (presently unrecognized) design consideration to those proposed for use in 

deQdiug the leak rate applicable to a system. This would be specifically fur those 

systems which use riYer wat,g to provide condenser cooling. 

Due to the erosive and corrosive nature of river water, such cond~nsu tubes are 

constantly degrading (five year lifu is oot uncommon), resulting in the inherent leak 

rates for these systems to be much higher than fur most reftigeram systems which use 

treated or potable water, closed loop cooling towers or air-cooled oondensen. These 

river water cooJed type systems should remain at the 35 percent Jea.k rate. Rebuilding 

these systems is not a viable option since it would be a massive project and very oost 

prohibitive. 

The replacement of these systems with systems using treated water or air is equally 

expensive and would constitute a change tar in ~xcess of that necessary to meet the 

.. lowest achievable level"' when considering technology available, and cost/benefit 

ratios. We therefore suggest that Section 82.156(i)(2) of the proposed regulations be 

redrafted such that industrial proeess refrigeration equipment using river water for 

cooling condenser tubes ~ subject to the 3 5 percent leak rate, inttead of the 

proposed 20 percent rate_ 

If you have any questions concerning these commentst please contact Lee F. Graser at 

(423) 632·8517, or e-mail at tfgraser@tva.gov. 

Sincerely, 

Jon ~ 

Manager 

Environmental 'M2nagement 

TOTAL P.12