For example, if a system containing 100 pounds of refrigerant loses 5 pounds of refrigerant over a month’s period, it would exceed the 35 percent trigger rate. Although a 5-pound loss is only 5 percent of the total system charge, if left unrepaired, it would lose 60 pounds over a year, which is 60 percent of the total system charge.
In order to comply with this regulation, equipment owners must keep accurate service records documenting the date and type of service as well as the quantity of refrigerant added to these systems. These records should be maintained on site for a minimum of three years. There are several refrigerant log booklets and software programs available to aid an owner in these record-keeping requirements.
In order to determine the leak rate of a system, the full refrigerant charge of the system must first be determined. This full charge value will be used as the baseline when determining the leak rate of a system. There are several ways an owner can determine the full refrigerant charge of a system.
If available, they can rely on the documentation provided by the equipment manufacturer. They could record the amount of refrigerant added to a system after all the refrigerant has been recovered, the system evacuated, and then recharged. They can calculate the full charge based on the component sizes, refrigerant density, volume of piping, and other considerations. They could use other baseline data available as long as they document how they determine the full charge of the system.
This exceeds the EPA’s 35 percent trigger rate, and the refrigerant leak would need to be located and repaired - which the owner has 30 days to do. This requirement can be waived if, within 30 days of discovery, the owner develops a one-year retrofit or retirement plan for the leaking system.
For more information on complying with the EPA’s regulation on refrigerant leaks as well as other refrigerant regulations, go to www.epa.gov.