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-1

Purpose ............................................................................................................................A-1

Intended Audience........................................................................................................A-1

What the Guidance Covers ..........................................................................................A-1

What the Guidance Does Not Cover..........................................................................A-1

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-1

Affected Operations .......................................................................................................B-1

Applicability Triggers ....................................................................................................B-1

Questions and Answers...................................................................................................B-2

C. FULL CHARGE..........................................................................................................C-1

Determining Full Charge..............................................................................................C-1

Questions and Answers..................................................................................................C-2

D. LEAK RATE............................................................................................................... D-1

Calculating a Leak Rate................................................................................................D-1

Timing..............................................................................................................................D-2

Purged Refrigerant........................................................................................................D-2

Recordkeeping and Reporting ....................................................................................D-2

Questions and Answers..................................................................................................D-3

E. LEAK REPAIR............................................................................................................ E-1

Leak Repair Requirement .............................................................................................E-1

Situations Where More Than 30 Days Are Required........................................E-1

Industrial Process Shutdown........................................................................................E-1

Unavailable Repair Parts or Other Regulations

That Require Additional Time ..............................................................................E-1

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-1

Time Extensions For Retrofit or Retirement of Industrial Process

Refrigeration Systems ....................................................................................................F-1

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-1

Leak Repair.....................................................................................................................G-1

Retrofit or Retirement...................................................................................................G-3

Full Charge......................................................................................................................G-7

Purged Refrigerant........................................................................................................G-7

Questions and Answers..................................................................................................G-8

H. SYSTEM MOTHBALLING..................................................................................... H-1

Applicability ...................................................................................................................H-1

Example of System Mothballing.................................................................................H-1

Questions and Answers..................................................................................................H-2

I. OIL CHANGES...........................................................................................................I-1

J. GLOSSARY .................................................................................................................J-1

K. REFERENCES............................................................................................................ K-1

Stratospheric Ozone Information Hotline .......................................................................K-1

Stratospheric Protection Division’s INTERNET Home Page.......................................K-1

Stratospheric Ozone Protection Rulemaking Summary ...............................................K-1

Stratospheric Ozone Protection Final Rule Summary...................................................K-1

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-1
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 freestanding, 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 “noventing 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

START

STOP

Is my 

refrigeration system 

subject to EPA's leak 

repair requirements?

(Module B)

Is there

 enough leakage to 

trigger the amendment's 

requirement to take 

action?

(Module C, D)

Mandatory repair, 

retrofit or retirement of 

system

No specific

action required

STOP

No Yes Yes

Decide 

whether to repair, 

retrofit, or retire 

the system

Deadlines & Extensions (Module E-1)

Verification Testing (Module E-2)

Recordkeeping & Reporting (Module G-1)

What to do if you pass/fail

the tests (Module E-2)

Switching to retrofit/retirement

of the system (Module E-2)

Mothballing (Module H-1)

Deadlines & Extensions (Module F-1)

Recordkeeping & Reporting (Module G-2)

Switching to repair the leak(s) (Module F-2)

Release from obligation to

retrofit/retire the system (Module F-2)

Mothballing (Module H-2)

Repair Retrofit or

Retirement

A-4

No

EPA 300-B-95-010

October 1995
B. APPLICABILITY
B. APPLICABILITY

In this guidance document, the

term “systems” is used to refer

to refrigeration appliances and

equipment.

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 hydrochlorofluorocarbon (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.

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%

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

S OR

EXCLUSIONS

Leak repair provisions of this

regulation do NOT affect systems

normally containing 50 pounds or

less of refrigerant.

B-1
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 appliances as householdtype 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
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.

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-1
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 charge?

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
D. LEAK RATE

The trigger rate for industrial

process refrigeration systems

is 35 percent.

REPAIR

RETROFIT

RETIRE

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 %= pounds of refrigerant added x 

365 days x 100

pounds of Full charge #days since refrigerant last added

D-1
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).

If you are the

OWNER OR OPERATOR:

Recordkeeping/Reporting

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
E. LEAK REPAIR

D E C I S I O N P O I N T !

R e p a i r R e t r o f i t

 o r

 R e t i r e

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.

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 E6 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-1
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-23
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)

Is technician1

certification

required?

YES2 NO

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

 

1

 Technician Certification Amendment to the National Recycling Program FR 55912 (11/9/93) (see Module K)

2

 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
EPA 300-B-95-010

October 1995

F. RETROFIT AND RETIREMENT

OF LEAKING REFRIGERATION

SYSTEMS

D E C I S I O N P O I N T !

R e p a i r R e t r o f i t

 o r

 R e t i r e

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 time

 the leak was discovered.

More time may be available.

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

F-1
EPA 300-B-95-010

October 1995

An industrial process

shutdown does not extend the

deadline for notification to

EPA if more time is needed.

Even MORE TIME may be

available!

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.

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.

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).

F-2
EPA 300-B-95-010

October 1995

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.

F-3
EPA 300-B-95-010

October 1995

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.

F-4
EPA 300-B-95-010

October 1995

G. RECORDKEEPING AND REPORTING

REQUIREMENTS
EPA 300-B-95-010

October 1995

It is advisable in ALL cases to

maintain records of the leak rate

and full charge.

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.

G. RECORDKEEPING AND

REPORTING REQUIREMENTS

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

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;
EPA 300-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-12
EPA 300-B-95-010

October 1995

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 onsite; 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;

NOTE: You only get the amount of

extra time that is reasonably

necessary.
EPA 300-B-95-010

October 1995

• 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.

3. 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

G-3
EPA 300-B-95-010

October 1995

• 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 tests.

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.

4. If your system is custom-built and you want the oneyear 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;

G-45
EPA 300-B-95-010

October 1995

• 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.

5. 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.
EPA 300-B-95-010

October 1995

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

• 

G-6
EPA 300-B-95-010

October 1995

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 preexisting 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

G-7
EPA 300-B-95-010

October 1995

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.

G-8
EPA 300-B-95-010

October 1995

H. SYSTEM MOTHBALLING

G-9
EPA 300-B-95-010

October 1995

H. SYSTEM MOTHBALLING

Important Note:

System mothballing requires the

refrigerant to be removed from the

system to at least atmospheric 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.

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

H-1
EPA 300-B-95-010

October 1995

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.

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EPA 300-B-95-010

October 1995

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. Followup 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.

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EPA 300-B-95-010

October 1995

I. OIL CHANGES
EPA 300-B-95-010

October 1995

I. OIL CHANGES

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.

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.

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EPA 300-B-95-010

October 1995

J. GLOSSARY
EPA 300-B-95-010

October 1995

J. GLOSSARY

The glossary provides important terms used in this

guidance.

Appliance 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.”

Class I refrigerant 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 refrigerant 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.

Commercial refrigeration 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.

Critical component 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.

Custom-built 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.

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EPA 300-B-95-010

October 1995

Follow-up verification test 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.

Full charge 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).

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EPA 300-B-95-010

October 1995

Industrial process refrigeration 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.

Industrial process shutdown An industrial process or facility temporarily ceases to

operate or manufacture whatever is being produced at

the facility.

Initial verification test 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.

Normal operating characteristics

or conditions

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.

Opening 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.”

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EPA 300-B-95-010

October 1995

Reclaim refrigerant 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.

Recover refrigerant To remove refrigerant in any condition from an

appliance without necessarily testing or processing it in

any way.

Refrigerant circuit 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.

Sound professional judgment 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.

Suitable replacement refrigerant 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.

System mothballing 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.

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EPA 300-B-95-010

October 1995

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 MVAC-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.

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EPA 300-B-95-010

October 1995

K. REFERENCES
EPA 300-B-95-010

October 1995

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 .

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EPA 300-B-95-010

October 1995

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.

K-2