Deciding Whether a Leak Repair Is 'Undue Delay' on a Busy System
A small supermarket has a central plant with 55 kg of R-449A (GWP 1397). During a routine 6-monthly check you detect a leak on a joint in the plant room. The store manager says they cannot shut down the refrigeration for at least three weeks because of stock and trading, and asks you to 'just keep it running and come back when convenient'. The leak is small but continuous. The system has a fixed leak detection system installed and functioning. You have already recorded the leak in the logbook.
1. Calculate the CO2e, state the applicable leak-check interval, and advise on whether a three-week delay is acceptable.
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CO2e: 55 kg × 1397 = 76,835 kg CO2e ≈ 76.8 t - in the 50–500 t band.
Leak-check interval: with a fixed leak detection system installed and functioning, the interval for this band is 12 months; without detection it would be 6 months. (The check that found the leak was a 6-monthly check, which is fine - more frequent than required.)
Is three weeks acceptable? The duty is to repair a detected leak without undue delay. A three-week delay is not automatically a breach, but it must be justified and managed:
- The leak must be assessed for severity - a small continuous leak on a joint may be repairable with a planned shutdown, or isolated and repaired sooner.
- The store should be advised of the emissions cost of delay: at ~77 t CO2e for the full charge, even a fraction lost over three weeks is significant.
- The delay should be documented with a reason and a firm repair date, and the system monitored in the interim.
Advice: agree a definite repair date, consider temporary measures (isolate the affected section, reduce charge loss), and record the justification. 'When convenient' is not acceptable - a firm, reasoned date is.
2. What must happen after the repair, and what records must be updated?
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After repair:
- Carry out a verification leak check within one month to confirm the repair has been effective.
- Check the fixed leak detection system still functions correctly (it should be function-checked regularly).
Records to update:
- The leak entry: date detected, location (joint in plant room), severity.
- The repair entry: date, work done, parts used, and the reason for any delay.
- The verification check result and date.
- Any refrigerant added during the repair, by weight.
- The next leak-check due date, recalculated from the verification check.
Retain records for at least 5 years and make them available for inspection. The judgement point is that the delay itself must be evidenced, not merely asserted, and that the verification check closes the loop.