Changes to Refrigerant Leak Rate Requirements

If you wonder what some of the most important changes are per the EPA 608 Update, they have to do with your refrigerant leak rate calculation and requirements.

That’s why, in this post, we will 1) explore in detail how the EPA 608 Update changed the allowable refrigerant leak rate thresholds for various applications as well as 2) introduced new reporting requirements for certain appliances.

Let’s get started.

Refrigerant Leak Rate Calculations

Before we delve into new allowable refrigerant leak rate thresholds, let’s first discuss what refrigerant leak rate means, plus when and how it must be calculated per EPA Section 608.

What Does Refrigerant Leak Rate Mean?

While refrigerant leak rate may have different meanings for different stakeholders, in this article, we are talking about it exclusively as it pertains to EPA 608. As such, if we go to the definitions section of 40 CFR Part 82 Subpart F, Section 152, you will find that it states the following about refrigerant leak rate: “40 CFR Part 82 Subpart F, Section 152.”

Leak rate means the rate at which an appliance is losing refrigerant, measured between refrigerant charges. The leak rate is expressed in terms of the percentage of the appliance’s full charge that would be lost over a 12-month period if the current rate of loss were to continue over that period.

This is the very foundation of leak rate to EPA 608, and it’s important to keep it in mind as we move along in this article. Therefore, as of Jan. 1, 2019, HVAC-R system owners and/or operators of appliances containing 50 or more pounds of controlled refrigerant must adhere to refrigerant leak rate calculation requirements. NOTE: On Feb. 26, 2020, the EPA finalized revisions to Section 608 Refrigerant Management Regulations and rescinded the maintenance and leak repair requirements at 40 CFR 82.157 for non-exempt substitute refrigerant (e.g., HFCs and HFOs).

When and How is the Refrigerant Leak Rate Calculated?

The refrigerant leak rate must be calculated when you add refrigerant to the regulated appliance

“unless the addition is made immediately following a retrofit, installation of a new appliance, or qualifies as a seasonal variance.”

Now, the next question is how to calculate such a refrigerant leak rate, and that is where EPA’s two leak rate calculation methods come into play:

Leak Rate Calculation Methods

Indeed, you must perform the refrigerant leak rate calculation using one of two methods: 1) the Annualizing method or 2) the Rolling Average method.

Annualizing Method

Per EPA 608, this is the annualizing leak rate calculation method:

If you choose to use this annualizing method, for the first refrigerant addition in calendar year 2019, the second term would be 365/365 (or “1).

Rolling Average Method

And, this is the rolling average leak rate calculation method:

If you choose to use the rolling average method, for refrigerant additions in calendar year 2019, the numerator is “the pounds of refrigerant added since the shorter of January 1, 2019 or the last successful follow-up verification test, if one was conducted in 2019.”

And, “for additions in 2020 and beyond the numerator would be the pounds of refrigerant added since the shorter of 365 days or the last successful follow-up verification test.”

Choose a Method, and Stick With It

While you may prefer one refrigerant leak rate calculation method over the other, the most important thing is that you stick with. That is, the same method must be applied for all regulated HVAC-R appliances at your facility.

This is a crucial nuance that should not be overlooked; You cannot haphazardly choose one method for one appliance and then another method for another appliance. For full details on performing the 2019 leak rate calculations, see this EPA fact sheet.

Allowable Refrigerant Leak Rate Thresholds

Now, let’s move on to why you must perform these calculations in the first place.

Why Are These Calculations Performed?

Namely, these calculations are performed to make sure you have not exceeded the allowable refrigerant leak rate threshold. As we previously mentioned, EPA 608 sets allowable leak rate thresholds based on appliance type, and the appliance types are 1) commercial refrigeration equipment; 2) industrial process refrigeration (IPR) equipment; and 3) comfort cooling appliances or other appliances.

See the chart below for a full depiction of the leak rate changes per appliance type:

As you can see, starting January 1, 2019, the thresholds were changed and became more stringent. In fact, the new allowable leak rate thresholds can be summarized as follows:

  • 20% for commercial refrigeration equipment;
  • 30% for industrial process refrigeration (IPR) equipment; and
  • 10% for comfort cooling appliances or other appliances.

It’s important for you to identify which appliances at your facility contain 50 or more pounds of controlled refrigerant as well as what kind of appliance type they are.

What Happens If the Threshold Is Surpassed?

The fact of the matter is, if your HVAC-R appliance has a leak rate over the applicable leak rate, you must repair the appliance in accordance with 40 CFR Part 82 Subpart F (unless you choose to retrofit or retire the appliance). See the flowchart below for a general summary of a refrigerant leak repair:

As you can see, if your HVAC-R system exceeds the acceptable refrigerant leak rate, you basically have three choices: repair, retrofit or retire the system. It starts, of course, with repair, at which point you find yourself using one of these refrigerant leak detection methods.

Mandatory Leak Inspections

Importantly, as a part of leak repair, you must now conduct mandatory leak inspections in accordance with the following schedule of any HVAC-R appliance that exceeds the applicable leak rate:

In sum, for commercial refrigeration industrial process refrigeration (IPR) equipment with a full charge of 500 or more pounds, leak inspections must be conducted once every 3 months, and, with a full charge between 50 and 500 pounds, once per calendar year.

In addition, for comfort cooling appliances and/or other appliances with a full charge of 50 or more pounds, leak inspections must also be conducted once per calendar year.

We’ve now explored in detail the new acceptable refrigerant leak rate thresholds. The last thing to discuss now is the new reporting requirements for certain appliances—those appliances being a new term per the EPA 608 Update called chronically leaking appliances:

Chronically Leaking Appliances

Per the EPA 608 Update, there’s a new classification of chronically leaking appliances under appliance maintenance and leak repair.

In essence, if a regulated appliance leaks 125 percent or more of its full charge in a calendar year, it’s a chronically leaking appliance; You must now submit a report to the EPA by March 1 of the subsequent year and describe efforts to identify leaks and repair the appliance.

With this new reporting requirement, it’s all the more important that you closely record your refrigerant leak rates, and there’s all the more incentive to reduce your refrigerant leak rate, which leads us to our final point:

Minimize Your Leak Rates for Best Results

Ultimately, the lesson here is that monitoring and minimizing your refrigerant leak rates at your facility is all the more crucial now. You must familiarize yourself now with the new leak rate calculation and reporting requirements, and we hope you find this article helpful in complying with the changes.

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