CH2M " WG "w IOAHO, LLC / January 25, 2011 Air Docket Environmental Protection Agency Mail Code 6102T 1200 Pennsylvania Ave., NW . Washington, DC 20460 CH2M " WG Idaho, LLC P .O . Box 1625 2525 North Fremont Ave. Idaho Falls, Idaho 83415 208.526 .0111 CCN 311376 

# FEB012011

SUBJECT: Comments on the Notice of Proposed Rulemaking (NPRM) published on December

15, 2010 (75 FR 78558-78585) Protection of Stratospheric Ozone: Amendments to the Section 608 Leak Repair Requirements To Docket Identification (ID) Number EPA-HQ-OAR-2003-0167: CH2M-WGIdaho, LLC (CWI) at the Idaho National Laboratory site is submitting the attached comments for the Environmental Protection Agency's consideration. These comments are related to the Notice of Proposed Rulemaking (NPRM) published on December 15, 2010 (75 FR 78558-78585) Protection of Stratospheric Ozone: Amendments to the Section 608 Leak Repair Requirements. Sincerely, David P. Hutchison, Director Environmental and Regulatory Services Attachment MSR:caf 

# JAN27 2011

Safely delivering the Idaho Cleanup ProjectID Number EPA-HQ-OAR-2003-0167

January 25, 2011 CCN 311376 Page 2

cc: T. L. Carlson, BEA, MS 3405 T. J. Dieter, CWI, MS 9204 J. W . Gill, BEA, MS 6172 T. L. Perkins, DOE-ID, MS 1216 T. J . Safford, DOE-ID, MS 1216 D . P. Timbes, CWI, MS 9103p. 3 CH2M-WGIdaho, LLCComments on Notice of Proposed Rulemaking

Protection of Stratospheric Ozone: Amendments to the Section 608 Leak Repair Requirements December 15, 2010 (75 FR No. 240, pages 78558-78585) (1) EPAis proposing that all service records pertinent to the leak repair required practices at 40CFR82.156 be maintained on-site, "at the physical location," ofthe appliance undergoing service for a minimum of three years (Section IV.D.1 and 4, pg 78576- 78577) . In some situations, area hazards such as radiation or restricted access conditions make it impractical to maintain records at the physical location ofthe appliance. Service records may also be accessible utilizing a variety of methods, including electronic copies ofservice records which can be viewed at multiple computer station locations. Suggest that EPA eliminate the phrase, "at the physical location of the appliance" fromthe requirement to maintain service records andjust state that these records need to be made available to EPAfor review upon request, and maintained where they may be easily retrievable for refrigeration technicians whoservice appliance(s) subject to the required practices. (2) EPA is proposing to require owners or operators to maintain records documenting the full charge determination, regardless ofthe means used to calculate or determine the appliance full charge (Section IV.D.4, pg 78577) . EPAstates that the full charge determination is required in order to calculate the leak rate upon addition of refrigerant, which implies that this additional recordkeeping requirement only applies to refrigeration units with a full charge greater than 50 pounds of refrigerant. It is requested that further clarification be provided that this proposed recordkeeping requirement only applies to refrigeration units with a full charge greater than 50pounds of refrigerant. (3) EPArequests comment on the proposal to provide clarification that follow-up verification testing shall take place at least 24 hours after repairs have been made and the appliance has operated under typical conditions. EPA identified concerns in instances where follow-up verifications were performed immediately after repairs and the initial verification (Section C .3, pg 78572) . It is suggested that EPA consider an alternative clarification requiring that follow-up verification be conducted no sooner than 24 hours but not later than 30 days after successful initial verification testing ofall leak repairs and the appliance has operated under typical conditions. This clarification may provide clearer instruction to prevent the occurrence of these types of instances in the future. Otherwise, the follow-up verification testing could still occur immediately after the initial testing and still be performed at least 24 hours after repairs are made.