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Leak Repair in Type 3 HVAC Equipment

EPA Type 3 Chapter 3


Leak Repair


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!


Leak Repair Regulations


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


Recall that refrigerant charge is the term used for the total amount of refrigerant present in the system. It is necessary to calculate the refrigerant charge while calculating the leak rate and filling the system with refrigerant.

EPA allows calculations based on component and pipe sizes. The method includes getting the refrigerant charge from the system's nameplate and adding excess refrigerant based on the system's pipe sizes and accessories. A technician need not memorize any formula, but the calculation method must be kept in mind.


Recall that topping off means adding additional refrigerant to the appliance without checking for, and fixing, any leaks. While topping off refrigerant in any system containing more than 50 pounds of refrigerant, it is compulsory to calculate the leak rate first.


Seasonal variance is the process of adding/removing refrigerant from an appliance during different seasons. Addition/removal of refrigerant is needed as external environmental conditions change in different seasons. Calculating leak rate is not required while adding refrigerant for seasonal variance.


Recordkeeping and Reporting


Record keeping is the task of maintaining the complete details about

  1. Leak inspections

  2. Leak repairs, and

  3. 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 are responsible for keeping the records.


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

  1. Location and date of the recovery

  2. Type of refrigerant recovered

  3. Total amount of refrigerant recovered

  4. 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 :

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

  2. It was repaired and filled back with refrigerant.

  3. 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/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.


 

Leak Repair Regulations


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!


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

  1. Initial leak verification test and

  2. 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.


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 not 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

  1. Leak inspections

  2. Leak repairs, and

  3. 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:

  1. Location and date of the recovery

  2. Type of refrigerant recovered

  3. Total amount of refrigerant recovered

  4. 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 :

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

  2. It was repaired and filled back with refrigerant.

  3. 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/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.


 

Question #1: To determine if the system is leaking more than the maximum rate, the EPA allows the use of which methods to calculate the full charge?

  1. Calculations based on power consumption, in kWh.

  2. Calculations based on tonnage.

  3. Calculations based on component and pipe sizes.

  4. Calculations based on the BTU capacity of the system.

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Answer: Calculations based on component and pipe sizes.

EPA allows the use of calculations based on component and pipe sizes to determine the full charge in the system.


Question #2: Which of the following refrigerant additions, to an appliance that contains 50 or more pounds of an ozone-depleting refrigerant, triggers the requirement to calculate the leak rate?

  1. Following a retrofit

  2. During the installation of a new appliance

  3. During a qualified seasonal variance

  4. When topping off the system

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Answer: When topping off the system

The requirement to calculate the leak rate gets triggered while topping off refrigerant in any system containing more than 50 pounds of refrigerant.


Question #3: How long must owners and operators of regulated appliances normally containing 50 or more pounds of CFC refrigerant keep records of leak inspections, initial leak 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

Owners and operators of regulated appliances containing 50 or more pounds of regulated refrigerant should maintain all records for at least 3 years.


Question #4: For what period should an HVAC servicing company keep records for a disposed appliance with a charge between 5 and 50 pounds?

  1. 2 years

  2. 3 years

  3. 5 years

  4. 10 years

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Answer: 3 years

An HVAC servicing company disposing of an appliance with a charge between 5 and 50 pounds must keep the records for a minimum period of 3 years.


Question #5: 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 #6: 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 #7: 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 #8: 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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