The Hotel Chiller Top-Up Request
A maintenance technician is called to a 96-bedroom hotel in the west of Ireland. The plant room holds one air-cooled chiller running R-410A with a nameplate charge of 38 kg, and a rooftop split serving the function room with a nameplate charge of 3.5 kg, also R-410A. Neither unit has a fixed refrigerant leak detection system. The hotel's maintenance manager says the chiller 'loses its gas most summers' and has been topped up twice in three years. He asks the technician to add gas, sign nothing, and 'leave the paperwork out of it, it's only a small system and we're not a chemical factory'. The technician notices the chiller's last leak-check entry is dated 26 months ago, and there are no entries at all for the split. Standing pressure on the chiller shows it is roughly 25% down on a normal charge. The manager refuses to authorise a leak investigation and wants the top-up done today.
1. Using the nameplate charges, calculate the CO2-equivalent of each unit and state the leak-checking obligations that apply to each. Explain your reasoning, including whether a leak detection system would change anything.
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Chiller
- 38 kg x GWP 2088 (R-410A) = 79,344 kg CO2e = 79.3 tonnes CO2e
- That falls in the 50-500 t band, so the operator must have it leak-checked at least every 6 months.
- A properly maintained fixed leak detection system would allow the interval to be doubled to 12 months. There is none fitted, so the 6-month interval stands. Its last recorded check was 26 months ago, so it is more than four intervals overdue.
Function-room split
- 3.5 kg x 2088 = 7,308 kg CO2e = 7.3 tonnes CO2e
- Above the 5 t CO2e threshold, so it needs a leak check at least every 12 months, even though it is a small system.
Key reasoning point: the thresholds apply per unit of equipment, not per site or per company. You cannot add the two together to argue the split is 'covered' by the chiller's paperwork, and you cannot round 7.3 t down to zero because it is a small split. Both units are in scope and both are overdue. The 25% shortfall also means a leak is likely to exist now, which triggers the duty to locate and repair it, not just to recharge.
2. The manager asks you to top up and not record it. Explain what records are legally required, who carries the duty, and how long they must be kept.
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- The operator carries the duty. The hotel, not the contractor, is the operator of the equipment and is required to keep records for each unit of 5 t CO2e or more. The contractor also keeps its own service records and must give the operator documentation of the work.
- What the record must contain: the type of refrigerant and the charge (R-410A, 38 kg and 3.5 kg); the CO2e; dates and results of every leak check; the location of any leak found and the date it was repaired; the quantity of gas charged or recovered at each visit; and the name of the certified company and technician who did the work.
- Retention: at least 5 years, and available to the EPA on request.
- The top-up itself must be recorded even if the quantity is small. A top-up is evidence of a leak and is exactly the information an inspector would want to see.
Agreeing to omit the entry puts the technician and their employer in breach as well as the hotel, and it destroys the evidence trail that would show the leak was known and being managed. The correct response is to refuse the work on those terms and confirm the refusal in writing.
3. If you refuse and the leak is left, what are the practical and legal consequences, and what would you do next?
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Scale of the loss: a 25% shortfall on 38 kg is roughly 9.5 kg of R-410A, about 20 tonnes CO2e per event. Two top-ups in three years is already around 40 tonnes CO2e released from one plant room.
Consequences
- The operator remains in breach of its leak-checking, repair and record-keeping duties. Sanctions sit with the operator, but knowingly assisting creates exposure for the contractor.
- The leak will worsen. Moisture and air ingress damage the compressor and oil, and repeated top-ups become more expensive than the repair.
- R-410A is subject to the HFC phase-down, so the price and availability of virgin gas will continue to tighten; an unrepaired leak is a growing cost, not a fixed one.
Next steps
- Issue written advice to the operator stating the CO2e, the interval required, the overdue status, and that a leak is suspected.
- Quote for a proper leak investigation: electronic detector sweep, nitrogen pressure test with OFN, and inspection of flare joints and the Schrader ports.
- Offer a dated plan and keep a copy of the correspondence. Do not carry out a gas-only top-up.
- If the operator continues to refuse, the matter can be reported to the EPA, which is the competent authority in Ireland.