Done regularly, system inspections, leak checks, and system
repairs save money. Yes, they cost money up front, but you save money in the
long run. Finding and repairing leaks as soon as possible avoids wasting
refrigerant and energy. A system operating undercharged loses capacity and
efficiency – which ultimately costs the building owner in the form of higher
utility bills. Neglecting system repairs can also shorten the equipment life. The
problem is that these avoided costs feel a bit hypothetical: this is what could
happen if....
So, the EPA has come up with a more tangible cost as an extra
incentive: fines. If saving on the cost of refrigerant, energy, and system
repairs is not enough incentive, consider the recent case of Southeastern
Grocers. They recently agreed to a $300,000 civil penalty and to spend to $4.2
million over the next three years to reduce refrigerant leaks and improve
company-wide compliance of EPA regulations. But Southeastern Grocers is certainly
not alone. Safeway agreed to a $600,000 civil penalty and $4.1 million in system
remediation costs, COSTCO agreed to $335,000 civil penalty and $2 million in
system 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 time
to review some of the basics in terms of what is expected.
As of January, 2019
Leaks in industrial process refrigeration (IPR), commercial
refrigeration, and comfort cooling appliances containing 50 pounds or more of
refrigerant must be repaired within 30 days if they exceed the EPA established
leak 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 to
wait until 30% of your refrigerant has leaked out. The leak rate must be calculated
every time refrigerant is added to a system.
Verification Tests
After repairing the leak, you are required to perform an
initial and follow up test to verify that the leaks have in fact been fixed and
the system is operating below the established leak rate. The initial
verification is done before adding refrigerant and the follow-up is done after
the system has been in service. The
verification tests must demonstrate that leaks were successfully repaired. You may
conduct as many additional repairs and verification tests as needed within the
30 day repair period. Note- you don’t get another 30 days every time you figure
out it still leaks. The process must be completed within 30 days.
Leak Inspections
You are required to perform regular leak inspections on
systems that have exceeded the applicable leak rate until the calculated leak
rates found during the inspection indicate the leak rate is below the EPA
trigger rate. Commercial Refrigeration and Industrial Process Refrigeration
equipment that holds more than 500 lbs of refrigerant must be checked every
three months. Commercial Refrigeration and
Industrial Process Refrigeration equipment holding between 50 and 500 pounds of
refrigerant must be checked annually. Comfort cooling equipment must also be
checked annually.
For more details, check out the EPA fact sheet here
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