7.2 Leak Repair Requirements and Trigger Rates

The Trigger Rates Are the Single Most-Tested Numbers

EPA Section 608 does not require that an appliance never leak. It requires that, once an appliance's calculated annual leak rate exceeds a threshold tied to how the appliance is used, the owner or operator must act. These three trigger (threshold) leak rates appear on nearly every Type II exam form, so commit them to memory:

A memory hook: the more critical and harder-to-shut-down the process, the higher the tolerated rate — comfort cooling 10, commercial 20, industrial 30. The rates are annualized (see Section 6.3): a system can trip the rule even if the technician only watched it for a few weeks, because the loss is projected to a full 12 months.

Which Appliances Are Covered

Coverage depends on charge size and refrigerant type, and this is where the HFC rule that took effect in 2026 matters:

• Legacy ODS rule — 40 CFR Part 82, Subpart F: applies to appliances normally containing a full charge of 50 or more pounds of an ozone-depleting refrigerant (e.g., R-22, R-11, R-123).
• HFC rule — 40 CFR 84.106 (2024 Emissions Reduction & Reclamation, ER&R, rule): beginning January 1, 2026, the same leak-repair framework applies to appliances with a charge of 15 or more pounds of an HFC or certain HFC substitutes (e.g., R-410A, R-404A, R-448A). Two important carve-outs: the residential and light-commercial AC and heat-pump subsector is exempt, and substitutes with a GWP/exchange value of 53 or below are not covered.

The 30-Day Repair Clock

Once a leak-rate calculation done at the time refrigerant is added shows the appliance is over threshold, the owner/operator must identify and repair the leaks within 30 days of that determination. The repair must bring the leak rate back below the applicable threshold — a partial fix that still leaves the system over 10/20/30% is not compliant.

• The deadline extends to 120 days where an industrial-process shutdown is required to make the repair.
• More time is allowed when needed repair parts are unavailable, when other federal, state, or local rules make a timely repair impossible, or in radiological-contamination areas (some extensions must be requested from EPA).
• The clock is suspended while the appliance is mothballed (evacuated and shut down).

Verification Tests: Initial AND Follow-Up

A repair is not "done" until it is proven. EPA requires two verification tests at the conclusion of repair efforts for each leak repaired:

1. Initial verification test — performed while the relevant components are still open/at the repair, confirming the specific leak is sealed (e.g., a pressure or electronic test on the repaired joint).
2. Follow-up verification test — performed after the appliance is brought back to normal operating characteristics and conditions, confirming the repair holds under real running pressures and temperatures.

If either test shows the repair failed, the owner may perform additional repairs and additional initial/follow-up tests within the allowed time window until the appliance is below threshold.

When Repair Fails: Retrofit or Retire

If the leaks cannot be repaired — or the owner simply chooses not to repair — a retrofit-or-retirement plan is required:

• The plan must be created within 30 days of deciding to retrofit/retire, of failing to act on the leak, or of the appliance continuing to leak above threshold after repairs and verification.
• The plan must include a schedule to complete the retrofit or retirement within one year of the plan's date.
• Owners may request additional time, or ask EPA to be relieved of the plan, if defined conditions are met.

Leak Inspections After a Trigger

Under both Part 82 (ODS appliances of 50 lb or more) and Part 84 (HFC appliances of 15 lb or more), an appliance found over threshold also enters a periodic leak-inspection schedule until it stays clean:

Example: A supermarket rack holds 800 lb of R-448A (commercial refrigeration, 20% threshold). A leak-rate calculation at the last top-off comes out at 26%, over the 20% limit. The owner must repair within 30 days, run an initial and a follow-up verification test, and — because the charge is 500+ lb — inspect the rack every 3 months until it logs four consecutive quarters under 20%. If the rack keeps leaking above 20% after repair attempts, the owner has 30 days to write a retrofit-or-retirement plan and one year to finish it.