Per EPA 608, a chronically leaker is an appliance that contains 50 pounds or more of refrigerant and leaks 125 percent or more of the full charge in a calendar year. If an appliance is deemed to be chronically leaking, the owner/operator of that appliance must now submit a report to the agency.
The first compliance reporting deadline for affected equipment is March 1, 2020.
“Owners or operators of appliances containing 50 pounds or more of refrigerant that leak 125 percent or more of the full charge in a calendar year must submit a report to EPA.”40 CFR 82.157(j)
Notice that the 125 percent is based on calendar year, so that owners / operators do not need to calculate refrigerant additions on a rolling basis (81 FR 82272).
In essence, this means that the leak rate calculation method for a chronic leaker is different than the leak rate calculation method for when refrigerant is added to an EPA 608 regulated appliance (for further comparison, see the Annualizing Method and / or Rolling Average Method).
What is the Reporting Requirement?
An appliance that is a chronic leaker must submit a report to the EPA by March 1 of the subsequent year and “describe efforts to identify leaks and repair the appliance” (40 CFR 82.157(j).
Notice the phrase describe efforts to identify leaks and repair the appliance, as this is where adherence to EPA 608 recordkeeping requirements becomes critical. If one is keeping proper records for each appliance, then describing such efforts would not prove difficult.
It should be noted that the first chronically leaking appliance reports are due March 1, 2020, and this compliance deadline applies to chronic leakers in the 2019 calendar year.
|Appliance||Leak Rate||Reporting Deadline|
|EPA 608 Regulated Appliances (e.g., air conditioner, refrigerator, chiller, freeze, etc.)||≥125% of Full Charge in a Calendar Year||March 1st|
Reports should be submitted electronically to the EPA unless the notification contains confidential business information.
Ensure Compliance and Maintenance Best Practices Now
The EPA’s goal with this reporting requirement is to help improve enforcement and compliance of Section 608 as well as “incentivize many owners and operators to improve their systems to ensure that they do not trigger this reporting requirement” (81 FR 82272).
The chronically leaking appliance reporting requirement highlights the importance of properly tracking refrigerant usage and adhering to compliant service activity and preventative maintenance best practices. ∎