Stationary Refrigeration Leak Repair Requirements

DISCLAIMER: The following information provides an overview of EPA’s leak repair requirements. However, persons responsible for complying with these requirements should consult the actual regulations (40 CFR Part 82, Subpart F) under Section 608 of the Clean Air Act for specific instructions to ensure compliance. EPA has recently updated these requirements.

General Leak Repair Requirements

Owners or operators must take corrective action when an appliance with a full charge of 50 or more pounds is discovered to be leaking ozone depleting refrigerant at a rate that exceeds the applicable trigger rate. Starting January 1, 2019, these requirements will also apply to appliances containing substitute refrigerants.

Trigger Rates

The following trigger leak rates apply for a 12-month period:

Appliance Type Current Leak Rate Leak Rate Effective 1/1/2019
Industrial process refrigerationa 35% 30%
Commercial refrigeration 35% 20%
Comfort cooling 15% 10%
All other appliances 15% 10%

Industrial process refrigeration- Thesed are complex customized appliances that are directly linked to the processes used in, for example, the chemical, pharmaceutical, petrochemical, and manufacturing industries. This sector also includes industrial ice machines, appliances used directly in the generation of electricity, and ice rinks. Where one appliance is used for both industrial process refrigeration and other applications, it will be considered industrial process refrigeration equipment if 50 percent or more of its operating capacity is used for industrial process refrigeration.

Commercial refrigeration- These are refrigeration appliances used in the retail food and cold storage warehouse sectors. Retail food appliances include the refrigeration equipment found in supermarkets, convenience stores, restaurants and other food service establishments. Cold storage includes the refrigeration equipment used to store meat, produce, dairy products, and other perishable goods.

Comfort cooling- These are air-conditioning appliances used to provide cooling in order to control heat and/or humidity in occupied facilities including but not limited to residential, office, and commercial buildings. Comfort cooling appliances include but are not limited to chillers, commercial split systems, and packaged roof-top units.

Corrective Action

In general, owners or operators of an appliance that is leaking refrigerant above the applicable trigger rate must either:

  • Repair leaks within 30 days from the date the leak was discovered, or
  • Develop, within 30 days, a plan to retrofit or retire the appliance and complete the actions under that plan within 1 year.

Owners or operators of 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. Starting January 1, 2019, this requirement will apply to owners and operators of all appliances subject to the leak repair requirements. 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 appliance that requires additional time may be subject to recordkeeping/reporting requirements.

When Additional Time Is Necessary

Additional time is permitted for conducting repairs on industrial process refrigeration equipment and federally owned equipment where the necessary repair parts are unavailable or if other applicable federal, state, or local regulations make a repair within required timeline (e.g., 30 or 120 days) impossible. Starting January 1, 2019, these extensions will become available to all commercial refrigeration and comfort cooling appliances as well.

Retrofitting or Retiring Appliances

Owners or operators who choose to retrofit or retire appliances must develop a retrofit or retirement plan within 30 days of detecting a leak 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 1 year from the date of the plan.

EPA will permit additional time to retrofit or retire industrial process refrigeration equipment and federally owned appliances as follows:

  • The owners or operators must make a request within six months from the expiration of the initial 30-day period.
  • EPA will permit additional time to the extent reasonably necessary if a delay is caused by the requirements of other applicable federal, state, or local regulations, or if a suitable replacement refrigerant in accordance with the Significant New Alternatives Policy (SNAP) regulations is not available.
  • EPA will permit one additional 12-month period if the appliance is custom-built and the supplier of the appliance or a critical component 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 12-month extension period if a request is made by the end of the ninth month of the extension.

Relief from Retrofit/Retirement Requirements

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 the trigger rate. 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.

Starting January 1, 2019, this relief mechanism will become available to all commercial refrigeration and comfort cooling appliances as well.

System Mothballing

For all appliances subject to the leak repair requirements, the timelines may be suspended if the appliance has been mothballed. Mothballing means to evacuate refrigerant from an appliance, or the affected isolated section or component of an appliance, to at least atmospheric pressure, and to temporarily shut down that appliance. However, the timelines pick up again as soon as the system is brought back on-line.