Leak Repair

The EPA has established trigger leaks rate requirements based on the current leak rate projected over a consecutive 12-month period, rather than the total quantity of refrigerant lost. For example, a leaking commercial refrigeration system containing 100 pounds of charge must be repaired if the system has lost 10 pounds of charge over the past month. Although 10 pounds represents only 10 percent of the system charge in this case, a leak rate of 10 pounds per month would result in the release of over 100 percent of the charge over the year.


Trigger Rates
 Trigger Leak RateFor all systems that have a refrigerant charge of more than 50 pounds, the following leak rates for a 12-month period apply:

In general, owners or operators must either repair leaks within 30 days from the date the leak was discovered, or develop a dated retrofit/retirement plan within 30 days and complete actions under that plan within one year from the plan's date. However, for industrial process refrigeration equipment and some federally-owned chillers, additional time may be available.

Industrial process refrigeration is defined as a complex customized system used in the chemical, pharmaceutical, petrochemical, and manufacturing industries. These systems are directly linked to the industrial process. This equipment also includes industrial ice machines, systems used directly in the generation of electricity, and ice rinks. If at least 50 percent of a system's capacity is used in an industrial process refrigeration application, the system is considered industrial process refrigeration equipment and the trigger rate is 35 percent.

Industrial process refrigeration equipment and federally-owned chillers must conduct initial and follow-up verification tests at the conclusion of any repair efforts. These tests are essential to ensure that the repairs have been successful. In cases where an industrial process shutdown is required, a repair period of 120 days is substituted for the normal 30-day repair period. Any system that requires additional time may be subject to recordkeeping/reporting requirements.


When Additional Time is Necessary
Additional time is permitted for conducting leak repairs where the necessary repair parts are unavailable or if other applicable federal, state, or local regulations make a repair within 30/120 days impossible. If owners or operators choose to retrofit or retire systems, a retrofit or retirement plan must be developed within 30 days of detecting a leak rate that exceeds the trigger rates. A copy of the plan must be kept on site and the original plan must be made available to EPA upon request. Activities under the plan must be completed within 12 months (from the date of the plan).

If a request is made within six months from the expiration of the initial 30-day period, additional time beyond the 12-month period is available for owners or operators of industrial process refrigeration equipment and federally-owned chillers in the following cases:
  • EPA will permit additional time to the extent reasonably necessary where a delay is caused by the requirements of other applicable federal, state, or local regulations; or
  •  Where a suitable replacement refrigerant, in accordance with the regulations promulgated under Section 612, is not available; and
  • EPA will permit one additional 12-month period when a system is custom-built and the supplier of the system, or a critical component of it, has quoted a delivery time of more than 30 weeks from when the order was placed (assuming the order was placed in a timely manner).
In some cases, EPA may provide additional time beyond this extra year where a request is made by the end of the ninth month of the extra year.


Relief from Retrofit/Retirement
The owners or operators of industrial process refrigeration equipment or federally-owned chillers may be relieved from the retrofit or repair requirements if:
  • Second efforts to repair the same leaks that were subject to the first repair efforts are successful; or
  • Within 180 days of the failed follow-up verification test, the owners or operators determine the leak rate is below 35 percent.

In this case, the owners or operators must notify EPA as to how this determination will be made, and must submit the information within 30 days of the failed verification test.


System Mothballing

For all systems subject to the leak repair requirements, the timelines may be suspended if the system has undergone system mothballing. System mothballing is the intentional shutting down of a refrigeration system for an extended period of time, where the refrigerant has been evacuated from the system or the affected isolated section of the system to at least atmospheric pressure. However, the timelines pick up again as soon as the system is brought back on-line.