Done regularly, system inspections, leak checks, and systemrepairs save money. Yes, they cost money up front, but you save money in thelong run. Finding and repairing leaks as soon as possible avoids wastingrefrigerant and energy. A system operating undercharged loses capacity andefficiency – which ultimately costs the building owner in the form of higherutility bills. Neglecting system repairs can also shorten the equipment life. Theproblem is that these avoided costs feel a bit hypothetical: this is what couldhappen if....
So, the EPA has come up with a more tangible cost as an extraincentive: fines. If saving on the cost of refrigerant, energy, and systemrepairs is not enough incentive, consider the recent case of SoutheasternGrocers. They recently agreed to a $300,000 civil penalty and to spend to $4.2million over the next three years to reduce refrigerant leaks and improvecompany-wide compliance of EPA regulations. But Southeastern Grocers is certainlynot alone. Safeway agreed to a $600,000 civil penalty and $4.1 million in systemremediation costs, COSTCO agreed to $335,000 civil penalty and $2 million insystem remediation costs, and Trader Joe’s agreed to $500,000 civil penalty and$2 million in system remediation costs. So I thought now might be a good timeto review some of the basics in terms of what is expected.
As of January, 2019
Leaks in industrial process refrigeration (IPR), commercialrefrigeration, and comfort cooling appliances containing 50 pounds or more ofrefrigerant must be repaired within 30 days if they exceed the EPA establishedleak rate. The trigger rates are 30% for IPR, 20% for commercial refrigeration,and 10% for comfort cooling. Note that this is a leak rate – you don’t get towait until 30% of your refrigerant has leaked out. The leak rate must be calculatedevery time refrigerant is added to a system.
After repairing the leak, you are required to perform aninitial and follow up test to verify that the leaks have in fact been fixed andthe system is operating below the established leak rate. The initialverification is done before adding refrigerant and the follow-up is done afterthe system has been in service. Theverification tests must demonstrate that leaks were successfully repaired. You mayconduct as many additional repairs and verification tests as needed within the30 day repair period. Note- you don’t get another 30 days every time you figureout it still leaks. The process must be completed within 30 days.
You are required to perform regular leak inspections onsystems that have exceeded the applicable leak rate until the calculated leakrates found during the inspection indicate the leak rate is below the EPAtrigger rate. Commercial Refrigeration and Industrial Process Refrigerationequipment that holds more than 500 lbs of refrigerant must be checked everythree months. Commercial Refrigeration andIndustrial Process Refrigeration equipment holding between 50 and 500 pounds ofrefrigerant must be checked annually. Comfort cooling equipment must also bechecked annually.
For more details, check out the EPA fact sheet here