Rating System

LEED O+M: Existing Buildings

Rating System Version

v3 - LEED 2009

Inquiry

There is significant confusion around the requirements for calculating and documenting refrigerant leakage rates for existing equipment. The EPA has published three different formulas, two of which are contained in the reporting rules and one which is in a guidance document about the reporting rules for industrial refrigeration systems. Additionally, the Rating System refers to the “EPA Clean Air Act, Title VI, Rule 608 procedures governing refrigerant management and reporting” but those procedures are actually contained in 40 CFR Part 82, Subpart F. These rules provide triggers and requirements when annual refrigerant leakage rates exceed a threshold, with the required corrective actions including repair, decommissioning, and retrofit/replacement. Some project teams report that refrigerant pressures are checked on regular intervals but that refrigerant is only added when the loss is significant. Please clarify what methods may be used to calculate refrigerant leakage rates, whether the rates should be calculated for the performance period only or the rate calculated for the most recent refrigerant addition should be used, and what project teams are required to do if the 5% annual and 30% lifetime leakage rates are exceeded.