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 

FEB 0 12011 

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-WG Idaho, 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 

JAN 27 2011 

Safely delivering the Idaho Cleanup Project 
ID 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 9103 
p. 3 

CH2M-WG Idaho, LLC Comments 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) EPA is proposing that all service records pertinent to the leak repair required practices 

at 40 CFR 82 .156 be maintained on-site, "at the physical location," of the 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 of the appliance. Service 

records may also be accessible utilizing a variety of methods, including electronic copies 

of service records which can be viewed at multiple computer station locations. Suggest 

that EPA eliminate the phrase, "at the physical location of the appliance" from the 

requirement to maintain service records and just state that these records need to be made 

available to EPA for review upon request, and maintained where they may be easily 

retrievable for refrigeration technicians who service 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 of the means used to calculate or determine the 

appliance full charge (Section IV.D.4, pg 78577). EPA states 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 50 pounds of refrigerant. 

(3) EPA requests 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 of all 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 .