## Docket ID No: EPA

- HQ

- OAR

- 2003

- 0167

Comments of the General Electric Company On the Proposed Amendments to the Section 608 Refrigerant Leak Repair Requirements

February 14, 2011

The General Electric Company (GE) is a very large global infrastructure and finance company with manufacturing and service operations in numerous industries including power generation, energy, water, oil & Gas, aviation, transportation, healthcare, appliances and lighting. As such, GE has more than 1,000 locations in the US that use industrial process and/or comfort cooling refrigeration appliances of various sizes and types.

GE understands that with these proposed rules, EPA intends to make the Section 608 Leak Repair requirements more stringent. However, we are
concerned that EPA is proposing amendments that will increase the cost of repairing refrigeration appliances that may not provide any real benefit. We are referring to the following three provisions that will significantly increase leak repair costs when taken together :

1. Change to the definition of “Follow

- up Verification Test” at §82.152 Definitions, in which EPA is proposing to require that follow

- up verification tests be performed no sooner than 24 hours after completion of repairs.

2. Change to the requirements at §82 .156 Required Practices, Paragraph (i), in which owners and operators are required to perform an initial and
follow

- up verification test (after 24 hours) following leak repair to comfort cooling appliances with greater than 50 pounds of refrigerant.

3. Chang e to the requirements at §82.156 Required Practices, Paragraph (j), in which owners and operators are required to perform an initial and
follow

- up verification test (after 24 hours) following leak repair to commercial and industrial process refrigeration a ppliances with greater than 50 pounds of refrigerant.

GE is not concerned with the extension of the initial and follow

- up verification tests to comfort cooling and commercial appliances. It makes sense that verification be required following leak repairs for comfort cooling and commercial appliances in the same manner as with the industrial process refrigeration appliances. In fact, GE currently recommends that its sites perform verification tests following comfort cooling appliance leak repairs as a Bes t Practice. Our concerns focus on the requirements in §82.152, §82.156 (i) and §82.156 (j) toperform the follow

- up verification test no sooner than 24 hours after completion of repairs. This provision automatically requires that any leak repair to
indus trial process, comfort cooling or commercial refrigeration appliances must be performed over two days.

To understand our concerns, it is important to understand how GE sites, and we presume sites of other companies, perform leak repairs on appliances. G E sites perform repairs in the following three different ways:

1. A limited number of large manufacturing GE sites employ certified refrigeration technicians and maintain the needed refrigerant recovery equipment. These sites can easily schedule the follow

- up verification tests on subsequent days because the needed certified technician and recovery equipment will be readily available. The 24

- hour delay provisions will not significantly impact these sites.

2. Some GE sites hire qualified refrigeration contract ors who employ the certified refrigeration technicians and maintain the needed refrigerant recovery equipment. If the site is sufficiently large and has numerous industrial process refrigeration and/or comfort cooling appliances, the site may hire the ref rigeration contractor on an extended agreement such that the contractor routinely comes to the site on a periodic basis. These sites can easily schedule the follow

- up verification tests on subsequent days when the refrigeration contractor is already sched uled to come to the site (if they are scheduled to come more frequently than monthly to assure that the 30 day limitation is met). Again, the 24

- hour delay provisions will not significantly impact these sites.

3. However, the great majority of GE sites hire a refrigeration contractor on an as needed basis. This is particularly the case, if the site is an office facility or small to medium manufacturing or service site. These sites call a refrigeration contractor when one or more appliances on site need to be serviced. The refrigeration contractor travels to the site and typically completes the needed service or repairs in one day, including any initial
and follow

- up verification tests. In this situation, the needed certified refrigeration technician and n eeded recovery equipment are not available on site, nor will they likely be routinely available on site within 30 days. The refrigeration contractor will have to schedule a second visit to the site to complete the follow

- up verification tests because of t he proposed 24

- hour delay provision. This will increase the cost because two service visits will be required for every leak repair to comfort cooling, commercial and industrial refrigeration appliances.

These additional costs could easily be $200 or more per visit. If GE conservatively assumes that there is at least one service repair requiring a
second visit under the 24

- hour delay provision at 500 GE sites in the US withrefrigeration appliances greater than 50 pounds, then the cost increase of perform ing the follow

- up verification test on a subsequent day instead of the same day would be at least $100,000. The cost increase would likely be much higher since many GE sites have numerous industrial process refrigeration and/or comfort cooling appliances with greater than 50 pounds of refrigerants.

§82.156 (i) and §82.156 (j) extend the initial and follow

- up verification tests to comfort cooling and commercial refrigeration appliances with greater than 50 pounds of refrigerant. This means that many comme rcial and institutional organizations will be required to perform initial and follow

- up verification tests for the first time. It is likely that most of these organizations hire refrigeration contractors on an as needed basis in the same manner as the maj ority of GE sites. Therefore, many of these commercial and institutional organizations will
incur the same cost increases that GE will incur from the additional contractor travel time costs to visit the site on the second day.

GE questions whether this increase in cost for two refrigeration contractor visits for every repair will be justified. Under the current provisions, a refrigeration contractor is required to perform an initial verification tests on an industrial process refrigeration system immed iately after the repair to prove that the repair is successful. The contractor is not permitted to recharge the equipment or to operate the equipment (if the refrigerant was not removed) until the initial verification test indicates that the system is tig ht. Then, if the repair is successful, the refrigeration contractor must perform a follow

- up verification test after the system has been turned on and brought up to its normal operating conditions (temperature and pressure). §82.156 (i) and §82.156 (j) e xtend these requirements to comfort cooling and commercial refrigeration appliances. GE maintains that the current provision allowing the refrigeration contractor to perform the follow

- up verification test on the same day of the repair is sufficient to

as sure that the repair was successful. If a repair was successful as indicated by a successful initial verification tests on the day of the repair, is should not make
much difference if the follow

- up verification test is performed on the same day or
24 hour s later.

EPA is not likely to achieve any significant refrigerant release reductions by delaying the follow

- up verification for 24 hours. In fact, the 24 delay may lead to an increase in refrigerant releases. For example, imagine a situation in which a refrigeration contractor performs a repair that is followed by a successful initial verification, and the appliance is then turned on and brought up to normal operating conditions and the appliance then starts to leak at the normal operating
conditions. I n this case, the follow

- up verification test will not be performed until 1 to 30 days after the repair because of the proposed 24

- hour delay provision. A significant quantity of refrigerant could be released from the appliance before the
follow

- up verific ation test is performed at a later date. This leak would likely be
identified sooner if the follow

- up verification test were performed on the day of the repair.GE agrees that §82.152, §82.156 (i) and §82.156 (j) should be revised to require
initial and f ollow

- up verification tests for all appliances (comfort cooling, commercial and industrial refrigeration) with greater then 50 pounds of refrigerant. However, the 24

- hour delay for the follow

- up verification test should be removed from all provisions beca use it will increase costs and provide little benefit.

Please contact Bob Schenker at (203) 373

- 2691 or Bob.Schenker@ge.com if you have any questions.