What are the refrigerant leak rates of your HVAC systems?
25%...? 35%...? 45%...? Or just not sure?
Heads up: You might want to NEED to know your refrigerant leak rates because, on Jan. 1, 2019, the new EPA regulations on refrigerant leaks take effect.
Is your facility prepared?
Find out in this post, which covers the new (1) lower leak rate thresholds, (2) mandatory leak inspections, (3) verification tests for all EPA 608 appliance types, and (4) reporting requirement for chronically leaking appliances. Get this information as a PDF.
Here's What You Need to Know About the New EPA Regulations on Refrigerant Leaks
In 2016, changes to EPA 608, the National Refrigerant Management Program, were finalized, and as of Jan. 1, 2017, they went into effect.
The new refrigerant regulations have staggered compliance dates—namely, Jan. 1, 2017; Jan. 1, 2018; and Jan. 1, 2019.
And on Jan. 1, 2019, changes to the EPA regulations on refrigerant leak thresholds take effect; here's all the nitty-gritty details you need to know:
1. Leak rate thresholds are lowered.
The refrigerant leak rate thresholds, which trigger the duty to repair your appliances, will be lowered.
Right now, the thresholds are
- 35% for industrial process refrigeration (IPR)
- 35% for commercial refrigeration
- 15% for comfort cooling and other
On 2019, the thresholds will lower to
- 30% for IPR
- 20% for commercial refrigeration
- 10% for comfort cooling and other
Remember: Leak rates are calculated by using the annualizing method formula or the rolling average method formula. If you're unsure of how to project your leak rate, please see this page of ours on the topic.
It's important to know your refrigerant leak rates now to be prepared for the coming regulatory changes, which leads us to our next point:
2. Leak inspections are mandatory if you exceed the applicable leak rate.
Yes, starting Jan. 1, 2019, if your appliance exceeds the applicable leak rate (defined in #1), then you must conduct leak inspections per the following requirements:
- For commercial refrigeration and IPR systems with a full charge of 500 or more pounds, you must conduct a leak inspection once every three months until you can demonstrate through leak rate calculations that the leak rate has not exceeded the applicable limit for four quarters in a row.
- For commercial refrigeration and IPR systems with a full charge of 50 or more pounds but less than 500 pounds, you must conduct a leak inspection once per calendar year until you can demonstrate through leak rate calculations that the leak rate has not exceeded the applicable limit for one year.
- For comfort cooling systems with 50 or more pounds of full charge, you must conduct a leak inspection once per calendar year until you can demonstrate through leak rate calculations that the leak rate has not exceeded 10% for one year.
Now do you see why it's crucial to know your leak rates?
There's a big difference in the requirements for a commercial refrigeration system with a 15% leak rate versus a system with a 40% leak rate.
3. Leak repairs on all three appliance types must include both an initial verification and a follow-up verification test.
Before the EPA 608 update, there was some confusion about which appliance types had to do both an (1) initial verification test and a (2) follow-up verification test.
With the update, this issue has been clarified.
Indeed, the leak repair requirements were amended to clarify that owners/operators of all three appliance types must perform and document both an initial and follow-up verification test of leak repairs, for appliances that exceed the applicable leak rate.
In general, an initial verification test must be performed within 30 days of an appliance exceeding the applicable leak rate (§ 82.157(e)(1)).
And, a follow-up verification test "must be performed within 10 days of the successful initial verification test or 10 days of the appliance reaching normal operating characteristics and conditions (if the appliance or isolated component was evacuated for the repair(s)"(§ 82.157(e)(2)).
4. New reporting requirements for chronically leaking appliances.
An appliance that contains 50 pounds or more of refrigerant and leaks 125% percent or more of full charge in a calendar year is classified as a chronically leaking appliance.
Chronically leaking appliances must submit a report to the EPA by March 1st of the subsequent year and "describe efforts to identify leaks and repair the appliance" (§ 82.157(j)).
If you enjoyed this article, you might want to check out our other articles on this topic and more: