Leak checking, record keeping and reporting obligations
This domain examines the frequency and quality of leak checks, the records an operator must keep, and what must be reported and to whom. It rewards precise use of tCO2e thresholds.
Leak-check intervals and methods
For non-hermetic equipment: 5–50 tCO2e every 12 months; 50–500 tCO2e every 6 months; ≥500 tCO2e every 3 months. An automatic leak detection system doubles these intervals. Hermetically sealed equipment below 10 tCO2e is exempt from periodic checks. Use a calibrated electronic detector plus soap or UV confirmation, and check valves, flare and brazed joints, Schrader cores, and connections. Never pressure-test with oxygen or air.
Records and reporting
Operators keep records for at least 5 years for equipment ≥5 tCO2e: refrigerant type and charge, tCO2e, leak checks and results, repairs, recovery, and technician certification. Records must be available to the EPA on request. A detected leak must be repaired without undue delay and rechecked within one month.
Worked example: A 25 kg R-410A system: 25 × 2088 ÷ 1000 = 52.2 tCO2e. This is 50–500 tCO2e, so checks are every 6 months; with automatic leak detection, every 12 months. If a leak is found in March, repair and recheck by April. Record the March result, repair and April recheck for 5 years.
Traps
Rounding 52.2 down to “under 50”; forgetting the detection-system doubling; checking only accessible joints; treating a top-up as a repair; failing to record the tCO2e and the technician’s certification.