Memorandum

To:	Julius Banks

From:	Bill Noel, SAIC and Nimmi Damodaran and Beth Scherer, Stratus
Consulting Inc.

Date:	4/19/2007

Subject:	Data Collected Under California Rule 1415: Reduction of
Refrigerant Emissions from Stationary Refrigeration and Air Conditioning
Systems

Similar to the Environmental Protection Agency’s requirements under
Section 608 of the Clean Air Act Amendments of 1990 (CAAA), the purpose
of California’s South Coast Air Quality Management District’s
(SCAQMD’s) Rule 1415 is to reduce emissions of Class I and Class II
refrigerants from stationary refrigeration and air conditioning systems
by requiring any person within in SCAQMD’s jurisdiction who owns or
operates a refrigeration system to reclaim, recover, or recycle
refrigerant and to minimize refrigerant leakage. A refrigeration system,
is defined for the purposes of the rule as any non-vehicular equipment
used for cooling or freezing, which holds more than 50 pounds of, any
combination of Class I and/or Class II refrigerant, including, but not
limited to, refrigerators, freezers, or air conditioning equipment or
systems.

Under Rule 1415, SCAQMD collects the following information every two
years from owners and operators of stationary refrigeration systems
holding more than 50 pounds of an ozone depleting refrigerant through
the use of a standard registration form (  HYPERLINK
"http://www.aqmd.gov/prdas/forms/1415form2.doc" 
http://www.aqmd.gov/prdas/forms/1415form2.doc ).

Number of refrigeration systems in operation

Type of refrigerant in each refrigeration system

Amount of refrigerant in each refrigeration system

Date of last annual audit or maintenance performed for each
refrigeration system

Amount of additional refrigerant charged every year. For the purposes of
the rule, additional refrigerant charge is defined the quantity of
refrigerant (in pounds) charged to a refrigeration system in order to
bring the system to a full-capacity charge and replace refrigerant that
has leaked.

SCAQMD provided EPA with completed registration forms spanning from 2000
to 2006. The majority of these forms are grouped into the following
usage years, 2000 and 2001, 2002 and 2003, and 2004 and 2005. The
sectors that are represented by these forms include the following:

Supermarkets

Office buildings

Schools

Hospitals

Food processing

Pharmaceutical manufacturing.

The following three tables, which summarize the SCAQMD data that was
analyzed for the analysis of average leak rates for comfort cooling and
refrigeration equipment and input to the regulatory impact analysis of
proposed changes leak repair requirements under Section 608 of the CAAA.
 The tables represent data from 2004 and 2005, and are divided by the
type of equipment used (i.e., commercial refrigeration, comfort cooling,
and industrial process refrigeration). They specify the number of pieces
of equipment represented in each sector and the percent of the total
number of each type of equipment represented in this sample.

Table 1 summarizes the commercial refrigeration equipment and North
American Industrial Classification System (NAICS) codes from the SCAQMD
data.

Table 1. Commercial Refrigeration.

NAICS	Type of Entity	Number of Pieces of Equipment	Percent of Total
Equipment

44511	Supermarkets and Other Grocery (except Convenience) Stores	1722
100%



Table 2 summarizes the comfort cooling equipment and NAICS codes from
the SCAQMD data.  

Table 2. Comfort Cooling.

NAICS	Type of Entity	Number of Pieces of Equipment	Percent of Total
Equipment

71	Arts, Entertainment, & Recreation	19	0.7%

32	Building Products Manufacturing	26	1.0%

---	Colleges and Universities	167	6.2%

55	Company Management	2	0.1%

23	Construction	2	0.1%

52	Finance and Insurance	54	2.0%

31	Food Manufacturing	6	0.2%

11	Forestry, Fishing, Hunting, and Agriculture Support	4	0.1%

62	Health Care & Social Services	106	3.9%

51	Information	451	16.7%

72	Lodging & Food Services 	53	2.0%

33	Metal Manufacturing	458	17.0%

---	Multi-purpose	2	0.1%

---	Non-profit entities	17	0.6%

81	Other Services	17	0.6%

54	Professional Services	80	3.0%

53	Real Estate Rental & Leasing	481	17.8%

45	Retail Stores	176	6.5%

---	Schools, Public Administration or other Public Institutions	508
18.8%

48	Transpotration	42	1.6%

22	Utilities	30	1.1%

 	   Total:	2,701

	

Tale 3 summarizes the process refrigeration equipment by NAICS codes
from the data.

Table 3. Industrial Process Refrigeration.

NAICS	Type of Entity	Number of Pieces of Equipment	Percent of Total
Equipment

3364	Aerospace Product and Parts Manufacturing	13	3.72%

311111	Animal Food Manufacturing	4	1.15%

3116	Animal Slaughtering & Processing	22	6.30%

3118	Bakeries & Tortilla Manufacturing	7	2.01%

31212	Bottled Water Manufacturing	7	2.01%

813910	Business Associations	1	0.29%

327310	Cement Manufacturing	5	1.43%

812220	Cemeteries and Crematories	3	0.86%

325	Chemical Manufacturing	6	1.72%

334	Computer and Electronic Product Manufacturing	3	0.86%

3341	Computer and Peripheral Equipment Manufacturing	8	2.29%

3222	Converted Paper Product Manufacturing	14	4.01%

3115	Dairy Product Manufacturing	3	0.86%

22111	Electricity Generation	4	1.15%

332	Fabricated Metal Product Manufacturing	9	2.58%

311	Food Manufacturing	21	6.02%

3114	Fruit & Vegetable Preservation and Specialty Food Manufacturing	10
2.87%

31	General Manufacturing	11	3.15%

327213	Glass Container Manufacturing	7	2.01%

325120	Industrial Gas Manufacturing	32	9.17%

3391	Medical Equipment and Supplies Manufacturing	11	3.15%

332431	Metal Can Manufacturing	3	0.86%

332116	Metal Stamping	3	0.86%

339	Miscellaneous Manufacturing	1	0.29%

3363	Motor Vehicle Parts Manufacturing	3	0.86%

2212	Natural Gas Distribution	4	1.15%

211	Oil & Gas Extraction	6	1.72%

3119	Other Food Manufacturing	2	0.57%

32511	Petrochemical Manufacturing	2	0.57%

32411	Petroleum Refineries	23	6.59%

3254	Pharmaceutical and Medicine Manufacturing	29	8.31%

48691	Pipeline Transportation of Refined Petroleum Products	4	1.15%

326111	Plastics Bag Manufacturing	1	0.29%

32616	Plastics Bottle Manufacturing	9	2.58%

326140	Polystyrene Foam Product Manufacturing	2	0.57%

32311	Printing	25	7.16%

32521	Resin and Synthetic Rubber Manufacturing	18	5.16%

32562	Rubber Product Manufacturing	4	1.15%

3344	Semiconductor and Other Electronic Component Manufacturing	1	0.29%

3312	Steel Product Manufacturing from Purchased Steel	2	0.57%

339112	Surgical and Medical Instrument Manufacturing	3	0.86%

32562	Toilet Preparation Manufacturing	2	0.57%

3212	Veneer, Plywood, and Engineered Wood Product Manufacturing	1	0.29%

 	    Total:	349

	

		

Stratus Consulting		Memorandum (Draft, 4/19/2007)

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