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EPA Reporting and Record-Keeping Requirements


Preparing Site Reports and Documentations: Chapter 3


EPA Reporting and Record-Keeping Requirements


In this module, we will discuss about the regulations to repair any leak. We will also learn some EPA regulations and recordkeeping requirements after the leak has been repaired. Skip to quiz!


Reports


Recall that refrigerant leaks can be harmful to our health and hazardous to the environment.

This is why EPA proposed to reduce the maximum allowable leak rates for appliances containing more than 50 pounds of refrigerant. Leak rate means the rate at which an appliance is losing refrigerant over a 12-month period.


The following are the maximum leak rates for a 12-month period

Appliance Type

Leak Rate

​Comfort cooling systems

​10%

​Commercial refrigeration

​20%

​Industrial Process Refrigeration (IPR)

​30%

​All other appliances

​10%

Remember these numbers!


The leak rates in the table give the maximum leak rate set by the EPA. They apply for all systems having 50 pounds or more amount of refrigerant. If the leak rate of a system exceeds the maximum leak rate given in the table, it must be repaired for leaks.


Time Frame Requirements


If a technician detects a leak in any chiller having 50 or more pounds of refrigerant, the owner or operator must get the leak repaired within 30 days of detecting it. An owner is the one who owns the appliance. An operator is the one who is using the appliance.


In addition to repairing the leak, leak verification tests must also be conducted within the 30-day period to confirm the result. Recall the two leak verification tests

  • Initial leak verification test and

  • Follow-up leak verification test.


EPA states that the follow-up leak verification test must be conducted within 10 days of the leak repair. The follow-up leak verification test is compulsory for an appliance having 200 pounds or more refrigerant.


If any of the leak verification tests fail, the owner or operator of the appliance can conduct additional repairs and repeat the process within the 30-day window.


If the owner or operator fails to repair the appliance, they must develop a retirement or retrofit plan. The plan must be executed within 12 months. The appliance can continue to operate without repair for 12 months, before which the appliance must be retrofitted or retired.


Recall that natural refrigerants like ammonia (R717) and carbon dioxide (R744) are exempt from the venting prohibitions. The owner or operator has 18 months to retrofit or retire a leaking appliance if the replacement uses a refrigerant exempt from the venting prohibition.


A retrofit or retirement plan must, at a minimum, contain the following information:

  • Identification and location of the appliance,

  • Type and full charge of the refrigerant used in the appliance,

  • Type and full charge of the refrigerant to which the appliance will be converted, if retrofitted

  • Plan for the disposition of recovered refrigerant,

  • Plan for the disposition of the appliance, if retired, and

  • A schedule, not to exceed one year, for completion of the appliance retrofit or retirement.


Extending Deadlines


The EPA allows certain situations in which the 30-day deadline can be extended. These may include extensions due to federal, state, or local regulations.


The leak repair deadline can also be extended if a component is not available at the moment. To extend the deadline, the owner or operator can request EPA.


The Extension requests must include:

We should also include the reasons why more than 30 days are needed to complete the repair; and an estimate of when the work will be completed. The owner or operator cannot use a reason that a certified service technician is unavailable.


Recordkeeping and Reporting


Now that we know the deadlines to be followed while repairing any leak, let us look at some EPA regulations.


Record keeping is the task of maintaining the complete details about

  • Leak inspections

  • Leak repairs, and

  • The tests performed to verify repairs of leaking appliances.

The technician working on the system must provide all the records.


As per the EPA, it is compulsory to keep the records for any appliance having 50 or more pounds of ozone-depleting refrigerant for a minimum of 3 years. The owner and operator of the equipment is responsible for keeping the records.


As per EPA, along with other details, the records should primarily include:

  • Location and date of the recovery

  • Type of refrigerant recovered

  • Total amount of refrigerant recovered

  • Amount sent for reclamation


The owner and operator can maintain a hard copy or an electronic copy. The records must be kept on site where the appliance is installed.


Technicians and HVAC servicing companies should also keep records of appliances having refrigerant amounts between 5 and 50 pounds when disposing of them. The records of disposal must be kept for a minimum of 3 years.


At times EPA requires the owner or operator of an appliance to record and submit a report about the leak to EPA. A report must be submitted to EPA if the systems’ leak rate in one calendar year(Jan - Dec) is higher than 125% of the total refrigerant amount in the system.


A 125% leak rate would mean that :

  • The system once leaked completely(100% leak).

  • It was repaired and filled back with refrigerant.

  • A quarter (25%) of the refrigerant leaked out again.

And all of this took place in one calendar year(Jan - Dec).


The submitted report must describe the owner or operator’s efforts to identify and repair the systems leaks. Other than this situation, it is generally not required to send a report to the EPA.


All reports and requests need to be submitted electronically to 608reports@epa.gov. The request will be considered approved unless EPA notifies the owners or operators within 60 days of request that it is not approved.


If the leak rate of a system exceeds the maximum leak rate given in the table, it must be repaired for leaks. If the owner or operator fails to repair the appliance, they must develop a retirement or retrofit plan. To extend the deadline of leak repair, the owner or operator can request EPA.


At times EPA requires the owner or operator of an appliance to record and submit a report about the leak to EPA. All reports and requests need to be submitted electronically to 608reports@epa.gov.


 

Question #1: How long do owners or operators of an chiller with a full charge of 750 pounds of R123 refrigerant have to retire the appliance if the replacement uses a refrigerant that is exempt from the venting prohibition?

  1. 3 months

  2. 6 months

  3. 12 months

  4. 18 months

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Answer: 18 months

The replacement uses a refrigerant exempt from venting prohibitions. The owner or operator has 18 months to retire or retrofit the appliance in such a case.


Question #2: Which of the following cannot be used as a reason to extend the appliance repair deadlines?

  1. Requirements of state regulations make the repair within 30 days impossible.

  2. A necessary component is not available.

  3. The appliance is located in a radiologically contaminated area.

  4. A certified service technician is not available.

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Answer: A certified service technician is not available.

Out of all the other reasons, not having a certified service technician available for service cannot be used as a reason to extend the leak repair deadline.


Question #3: How long must owners and operators of low-pressure chillers using R11 refrigerant keep records of leak inspections, initial verification, and follow-up verification tests?

  1. 2 years

  2. 3 years

  3. 5 years

  4. Life of the appliance

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Answer: 3 years

As per the EPA, it is compulsory to keep the records for any appliance having 50 or more pounds refrigerant for a minimum of 3 years.


Question #4: Who is responsible for keeping records of all leak inspections and any completed leak repair verification tests?

  1. The original installing technician’s employers.

  2. The technician who performed inspection or verification test.

  3. The owner and/or operator of the equipment.

  4. The EPA leak rate assessment division.

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Answer: The owner and/or operator of the equipment.

The owner and operator of the equipment is responsible for keeping the records.


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