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1 Summary of Key Revisions to Refrigerant Management Requirements for Stationary Systems (40 CFR 82, Subpart F) (red text denotes changes made to final rule since 11/9/2015 proposal) Applicability to non-ozone depleting substance (ODS) substitutes Venting prohibition is only provision that applies and it is limited to non-ods substitutes that are not specifically exempted under (a) Substitutes are defined as refrigerants and coverage is expanded for non-ods substitutes to all provisions of rule, including sales, evacuation, recovery/ recycling equipment, technician certification, leak repair, and reclamation provisions Applicability to non-ods substitutes is same as proposed with relatively minor edits Non-ODS substitutes that are specifically listed as exempt under (a) are not subject to any provisions of the rule Compliance date for sales restrictions on new and used refrigerant, sales restrictions on appliances (process stub/servicing aperture), and revised standards for sale/import of recovery/recycling equipment = effective date of the rule Compliance date for leak repair provisions = 18 months from promulgation* Amends definition of substitute to define terms exempt substitutes and non-exempt substitutes to identify which non-ods substitutes are specifically listed as exempt in (a) and are not subject to any provisions of the rule Compliance date for sales restrictions on used refrigerant, sales restrictions on appliances (process stub/servicing aperture), and revised standards for sale/import of recovery/recycling equipment = 1/1/2017 (effective date of the rule) Compliance date for leak repair provisions = 1/1/2019 (2 years) Compliance date for all other requirements, Compliance date for all other requirements = 1 year including sales restrictions on new refrigerants = from promulgation* 1/1/2018 (1 year) For assistance with the new Refrigerant Management Requirements for Stationary Systems, please contact your local Trinity office at (800)

2 Provision or Topic Leak Provisions (applies to appliances with full charge 50 lbs) - Repair and Verification Comfort cooling Allowable leak (or repair trigger) rates No definition in rule; had to classify based on definitions of industrial process refrigeration and commercial refrigeration in and historical guidance Existing allowable leak rates: IPRAs = 35% CRAs = 35% CCAs = 15% Extent of required Requires repairs to bring the leak repairs leak rate to below the applicable allowable leak (or repair trigger) rate [see (i)(1), (i)(2), (i)(3), & (i)(5)] Adds new definition as follows, which is consistent with historical guidance: Comfort cooling means the air conditioning appliances used to provide cooling in order to control heat and/or humidity in facilities including but not limited to office buildings and commercial buildings. Comfort cooling appliances include building chillers and roof-top self-contained units. They may be used for the comfort of occupants or for climate control to protect equipment within a facility, including but not limited to computer rooms. Simplifies proposed definition in , including limiting definition to appliances used to cool spaces occupied by people (i.e., not equipment or computer rooms) Comfort cooling means the air-conditioning appliances used to provide cooling in order to control heat and/or humidity in occupied facilities including but not limited to residential, office, and commercial buildings. Comfort cooling appliances include but are not limited to chillers, commercial split systems, and packaged roof-top units. Uses term other appliances within leak rate provisions [82.157(c)(2) (iii)] and leak inspection provisions [(82.157(g)(1)(iii)] to indicate such units (e.g., units that cool equipment/computer rooms) are subject to same requirements as CCAs Compliance date = effective date Compliance date = 1/1/2017 (effective date) Revised allowable leak rates: IPRAs = 20% CRAs = 20% CCAs = 10% Other appliances = 10% Allowable leak rates revised in (c)(2): IPRAs = 30% CRAs = 20% CCAs = 10% Other appliances = 10% Requires identification and repair of all leaks; all leaks must be repaired such that there are no detectable leaks, as documented by initial and follow-up verification testing Returns to the requirement to make repairs to bring the leak rate to below the applicable allowable leak (or repair trigger) rate [see (d)(2)]; however, must repair all identified leaks to reset term when using the rolling average method to calculate the leak rate

3 Requirement to perform initial and follow-up verification tests Applicable only to IPRAs, federally owned Expands coverage to include all types of CRAs, and federally owned CCAs subject appliances subject to the leak repair provito leak repair provisions sions, including non-federally owned CRAs and non-federally owned CCAs Same as proposed [see (e)] Available extensions to 30-day repair window Available extensions vary by appliance type as follows: Non-federally owned CRAs/CCAs = 1) system mothballing Federally owned CRAs/CCAs = 1) system mothballing, and 2) delays due to radiological contamination issues (no limit to extension that can be requested) IPRAs = 1) system mothballing, 2) industrial process shutdown (extends repair window to 120 days), and 3) for delays beyond your control (can request up to 1 year extension) Creates more standard list of available extensions across all appliances subject to the leak repair provisions, which includes: 1.xxIndustrial process shutdown required xxxx(still only applicable to IPRAs and xxxxtriggers 120-day repair window) 2.xxMothballing 3.xxAppliance located in an area subject to xxxxradiological contamination 4.xxFederal, state, or local regulations make xxxxrepair within allowable window xxxximpossible 5.xxNecessary parts are unavailable Same as proposed with relatively minor wording changes [see (f)] Removes the 30 day window regarding EPA approval of extension requests Owner/operator must submit request to EPA within the applicable repair window to obtain extensions #3-#5; request is considered approved unless EPA notifies owner/ operator within 30 days of receipt of the request

4 Leak inspections None Requires proactive leak inspections as follows: > IPRAs & CRAs 500 lbs xxxquarterly > All other appliances 50 lbs xxxannually Inspections only required for appliances that exceed applicable allowable leak rate as follows [see (g)]: > IPRAs & CRAs 500 lbs quarterly, until there are 4 consecutive quarters xxxwith no leaks above applicable allowable leak rate > All other appliances 50 lbs annually until one year with no leaks above xxxapplicable allowable leak rate Inspections must be performed on all Inspection must be performed on all visible and accessible components with visible parts of the appliance 3 exceptions (i.e., insulated/iced/inaccessible, require 2 meter elevation of inspector above support service, or unsafe to inspect components) Includes provisions to allow owners/ operators of federally owned appliclarifies that activity must identify leak location (not just determine whether ances to request alternative schedule, appliance is leaking) but cannot be < than every 3 years Requires inspections to be performed by certified technicians Can forego inspections if install and calibrate automatic leak detection Eliminates alternative schedule provision for federally owned appliances systems Can forego inspections if install and calibrate automatic leak detection systems Chronic leaker provision None Requires retirement of appliances that Requires submittal of report for appliances that leak 125% of full charge in leak 75% of full charge in 2 consecu- calendar year; report due 3/1 of following year [see ( j)]; calculation tive 12-month periods is based on amount of refrigerant added in calendar year divided by the full charge (i.e., does not follow standard leak rate calculation methods in )

5 Seasonal variance provisions None Amends definition of full charge to account for seasonal variances and allows additions of refrigerant due to a change in season to be excluded from leak rate provisions if followed by subsequent removal of equal amount of refrigerant in the corresponding change in season, where both the addition and removal occurs within one consecutive 12-month period Same as proposed with minor revisions Amends definition of full charge to account for seasonal variances and allows for removal of refrigerant due to a change in season to be excluded from leak rate provisions if followed by subsequent addition of an amount that is less than or equal to amount removed in prior change in season, where both the removal and addition occurs within one consecutive 12-month period [see & (b)]

6 Leak Provisions (applies to appliances with full charge 50 lbs) - Retrofit and Retirement Retrofit and retirement plans Existing rule does not contain definitions of retrofit or retire, but indicates that retrofits and replacements of retired appliances must use refrigerant with a lower or equivalent ODP [see (i)(6)] Existing rule does not have any specific content requirements for retrofit and retirement plans and does not require repair of leaks as part of retrofits Adds definitions of retrofit and retire that eliminate restriction to use refrigerant with a lower or equivalent ODP as follows: Retire, when referring to an appliance, means the disassembly of the entire appliance including its major components, such that the appliance as a whole cannot be used by any person in the future. Same as proposed [see & (h)] with minor revisions to definition of retire: Retire, when referring to an appliance, means the removal of the refrigerant and the disassembly or impairment of the refrigerant circuit such that the appliance as a whole is rendered unusable by any person in the future. Retrofit means to convert an appliance from one re- frigerant to another refrigerant. Retrofitting includes the conversion of the appliance to achieve system compatibility with the new refrigerant and may include, but is not limited to, changes in lubricants, gaskets, filters, driers, valves, o-rings or appliance components. Includes minimum specific content requirements for retrofit and retirement plans (ID/location, existing type and full charge, type and full charge of new refrigerant, itemized procedure for retrofit, disposition plan for recovered refrigerant, disposition plan for retired appliance, schedule, and signature of authorized company official) and includes requirement that all identified leaks must be repaired as part of retrofit

7 Available off-ramps Available off-ramps vary by applifrom implementing ance type as follows: retrofit or retirement plan Non-federally owned CRAs/CCAs = None Eliminates all available off-ramps Consolidates existing off-ramp provisions into one option for all appliances subject to leak repair provisions, which requires owner/operator to establish within 180 days of plan s date that the appliance no longer exceeds the applicable allowable leak rate and agree to repair all identified leaks within 1 year of plan s date [see (h)(5)(ii)] IPRAs and federally owned CRAs/ CCAs = 1) repair within 2nd 30-day (or 120-day) window (i.e., 2nd attempt at repair), and 2) repair within 180 days (i.e., 6 month repair plan) Available extensions Available extensions vary by applifor implementing ance type as follows: retrofit or retirement plan Non-federally owned CRAs/CCAs = None Federally owned CRAs/CCAs = 1) federal procurement process complications result in delivery time of > 30 weeks, and 2) appliance is located in area subject to radiological contamination and creating safe working environment will require > 30 weeks IPRAs = 1) delay caused by other regulations, 2) delay due to unavailability of suitable replacement refrigerant, and 3) critical component for custom built unit has delivery time > 30 weeks from order Adds language to indicate that off-ramp requests will be considered approved unless EPA notifies the owner/operator within 60 days of receipt of request that it is not approved Modifies available extensions by appliance type as follows: All appliances = automatically allowed 18 months to retire an appliance if replacement uses exempt substitute Same as proposed [see (i)] Federally owned equipment = 1) federal procurement process complications result in delivery time of > 30 weeks, and 2) appliance is located in area subject to radiological contamination and creating safe working environment will require > 30 weeks IPRAs = 1) delay caused by other regulations, and 2) component for custom built appliance or custom built appliance has delivery time > 30 weeks from order (adds provision to require installation of said component/appliance within 120 days after delivery)

8 Leak Provisions (applies to appliances with full charge 50 lbs) - Recordkeeping and Reporting Leak repair recordkeeping Existing rule recordkeeping provisions include: >xxservicing records (date and type of xxxservice, amount of refrigerant added, xxxand date and amount of refrigerant xxxpurchased) >xxfull charge recordkeeping if using xxxestablished range method >xxverification test records (date, type, xxxand results) for applicable units >xxpurged refrigerant records (when xxxexempting from leak rate calculations) >xxcopies of reports/notifications (i.e., xxxfailed follow-up verification test xxxreports, repair window extension xxxrequests, and retrofit/retirement plan xxxextension notifications) >xxcopy of retrofit/retirement plans Only provision that clarifies what records technicians must provide to owners/ operators is requirement to provide documentation of amount of refrigerant added [82.166( j)] Revises recordkeeping provisions to include: >xxexpanded servicing records (ID/location of appliance, date of xxxservice, parts of appliance serviced and type of service made xxxto each part, name of person performing the service, amount xxxand type of refrigerant added to or removed, full charge, leak xxxrate, leak rate method used) >xxexpanded full charge records (full charge, method used, xxxrevisions, and date of revisions) for all full charge methods >xxexpanded verification test records (location of repairs tested, xxxdate, type, and results) >xxadds explicit records for mothballing (date and return to xxxservice) >xxpurged refrigerant records (when exempting from leak rate xxxcalculations) >xxadds explicit records for seasonal variance (dates of removal xxxand corresponding addition) >xxadds records of leak inspections (date, method used, leak xxxlocations, and certification that all visible parts inspected) >xxadds records for automatic leak detection systems xxx(installation, annual audit and calibration, and date/location of xxxleaks detected) >xxcopies of reports and requests submitted to EPA >xxcopies of retrofit/retirement plans Same as proposed with minor revisions [see (l)] Further clarifies exact service records that technicians must provide owners/operators such that owners/operators can comply with recordkeeping provisions; includes service documentation, inspection documentation, and verification test documentation, but excludes full charge, leak rate, and leak rate method Clarifies that technicians must provide owners/operators service documentation necessary for owners/operators to comply with recordkeeping provisions at conclusion of each service

9 Leak repair reporting Non-federally owned CRAs and CCAs = purged refrigerant reports (when exempting from leak rate calculations) IPRAs and federally owned CRAs/CCAs = failed follow-up verification test reports, leak repair window extension requests, retrofit/retirement plan off-ramp reports, retrofit/retirement plan extension requests, and purged refrigerant reports (when exempting from leak rate calculations) All reports must be submitted via hardcopy to applicable EPA regional office Expands reporting provisions to all appliances subject to leak repair provisions Same as proposed rule except for changes to required reports to correspond with changes to other rule provisions [see (m)] Required reports include: >xxrepair window extension requests >xxretrofit/retirement plan extension xxxrequests >xxalternative inspection schedule requests >xxpurged refrigerant reports (when xxxexempting from leak rate calculations) All reports submitted electronically to 608reports@epa.gov (unless contain CBI) Required reports include: >xxrepair window extension requests >xxretrofit/retirement plan off-ramp requests >xxretrofit/retirement plan extension requests >xxreports for appliances that leak 125% of full xxxcharge in calendar year >xxpurged refrigerant reports (when exempting xxxfrom leak rate calculations) Other Provisions Appliances with multiple independent circuits Not addressed in rule; 10/1995 guidance (Compliance Guidance for Industrial Process Refrigeration Leak Repair Regulations Under Section 608 of the Clean Air Act) for IPRAs indicated that each individual circuit is considered a separate appliance N/A Amends definition of appliance to clarify that for systems containing multiple circuits, each independent circuit is considered a separate appliance (see ) Compliance date = 1/1/2017 (effective date)

10 Definition of disposal Current rule definition of disposal includes: 1) disposing appliance to land/ water, 2) disassembly of appliance to dispose of discarded components to land/ water, and 3) disassembly of appliance for reuse of its component parts (see ) Amends definition to include a fourth provision addressing destruction of appliance such that refrigerant would be released into environment if it had not been recovered prior to the destructive activity; language change targets vandalism or the cutting of refrigerant lines, both to steal metal and to vent refrigerant Same as proposed except for minor revisions to definition (see ) Compliance date = effective date Disposal means the process leading to and including: (1) The discharge, deposit, dumping, or placing of any discarded appliance into or on any land or water; (2) The disassembly of any appliance for discharge, deposit, dumping, or placing of its discarded component parts into or on any land or water; (3) The vandalism of any appliance such that the refrigerant is released into the environment or would be released into the environment if it had not been recovered prior to the destructive activity; (4) The disassembly of any appliance for reuse of its component parts; or (5) The recycling of any appliance for scrap Compliance date = 1/1/2017 (effective date) Disposal requirements for small appliances, MVACs, and MVAC-like appliances Final disposers must: 1) recover any remaining refrigerant from such appliances or 2) verify that any remaining refrigerant has been evacuated from such appliances prior to receipt (verifications can be signed statements or contract terms) [see (f) & (i)] Relocates requirements to (a)-(c) Compliance date for ODS-containing refrigerants effective date Compliance date for non-exempt substitutes = 1 year Minor edits to regulatory language including addition of requirement to obtain a signed statement in the event that all refrigerant in an appliance has leaked out prior to delivery due to unavoidable occurrences [see (b)(2)(iii)] Compliance date for ODS-containing refrigerants effective date Compliance date for non-exempt substitutes = 1/1/2018 (1 year)

11 Recordkeeping provisions None for disposal of appliances with full charge > 5 lbs and < 50 lbs Requires records of: >xxcompany name >xxlocation of the equipment >xxdate of recovery >xxamount and type of refrigerant xxxrrecovered for each appliance >xxthe quantity and type of refrigerant xxxtransferred for reclamation and/or xxxdestruction >xxto whom it was transferred >xxthe date of transfer Requires records of [see (a)(3)]: >xxcompany name >xxlocation of the appliance >xxdate of recovery >xxtype of refrigerant recovered for each appliance >xxthe quantity of refrigerant, by type, recovered xxxfrom all disposed appliances in each calendar xxxmonth >xxthe quantity of refrigerant, by type, transferred xxxfor reclamation and/or destruction >xxthe person to whom it was transferred >xxthe date of transfer Compliance date = 1 year Evacuation levels for certifying recovery/ recycling equipment Tables 2 and 3 of contain required evacuation levels for certifying recovery/ recycling equipment that depend on manufacture date of recovery/recycling equipment and type of appliance; types of appliances listed in these 2 tables not entirely consistent with required evacuation levels that technicians must achieve in field as contained in Table 1 within Compliance date = 1/1/2018 (1 year) Consolidates Tables 2 and 3 into a single Same as proposed Table 2 within ; for improved consistency with Table 1 in , adds two ap- Compliance date = 1/1/2017 (effective date) pliance type categories not included in original tables (i.e., medium-pressure appliances < 200 lbs full charge and medium-pressure appliances 200 lbs full charge) and assigns same evacuation levels as other high-pressure appliances Note that required evacuation levels for certifying some other high-pressure appliances more stringent than required evacuation levels that technicians must achieve in field for high-pressure appliances as contained in Table 1 within Compliance date = effective date

12 Certifying organizations providing list of certified equipment Existing rule requires list to be provided to EPA within 30 days of organization s approval by EPA and annually thereafter [see (c)] One-time notification of acquisition of certified recovery/recycling equipment Replaces existing provisions with requirement to publish online a list of certified equipment (name of manufacturer and name and/or serial number of the model line) and update list annually Same as proposed [see (e)(1)] Compliance date = effective date Compliance date = 1/1/2017 (effective date) Existing rule requires one-time notification Eliminates requirement that certified recovery/recycling equipment has been acquired (82.162) Compliance date = effective date Certifying organizations None making list of certified technicians available to the public Requires organizations, excluding federally-run programs, to create and maintain publicly searchable database of technicians they certify after 1/1/2017 Gives technicians ability to opt out of being included in database Compliance date = 1/1/2018 Adds clarification that online lists must contain certified equipment until 3 years after that equipment is no longer offered for sale Same as proposed Compliance date = 1/1/2017 (effective date) Requires organizations, excluding federally-run programs, to publish online a list of technicians they certify on or after 1/1/2017 [see (b)(6)] Gives technicians ability to opt out of being included in such lists List must be updated at least annually Compliance date = 1/1/2018 (1 year)

13 Self-sealing valves on small None cans of MVAC refrigerant Proposed definition of self-sealing valve Requires small cans ( 2 lbs) of MVAC refrigerant to be equipped with self-sealing valve [see (c)] Requires small cans ( 2 lbs) of MVAC refrigerant to be equipped with self-sealing valve Requires all small cans manufactured and placed into initial inventory or imported prior to compliance date must be sold by 2 years from final rule Eliminates requirement to sell older, small cans by 2 years from final rule Compliance date = 1/1/2018 (1 year) Compliance date = 1 year *Reference to 1 year, 2 years, or 18 months for compliance dates included within proposed rule refer to the amount of time from the date the final rule is published in the FR IPRA = industrial process refrigeration appliance CRA = commercial refrigeration appliance CCA = comfort cooling appliance For assistance with the new Refrigerant Management Requirements for Stationary Systems, please contact your local Trinity office at (800)