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. Change 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 appliances 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 Best Practice. Our 

concerns focus on the requirements in §82.152, §82.156 (i) and §82.156 (j) to 
perform the follow-up verification test no sooner than 24 hours after completion of 

repairs. This provision automatically requires that any leak repair to 

industrial 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. GE 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 contractors 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 refrigeration 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 scheduled 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 needed 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 the 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 with 
refrigeration appliances greater than 50 pounds, then the cost increase of 

performing 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 commercial 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 majority 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 immediately 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 tight. 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) extend 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 

assure 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 hours 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. In 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 verification 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 follow-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 because 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.