A rooftop unit holds 100 pounds of R-410A, an HFC. Does the Part 82 leak repair section, 40 CFR 82.157, apply to it?

Leak repair requirements · EPA 608 Type II. The correct answer, and the reasoning behind it.

Leak-rate thresholds, repair deadlines, extensions and records.

The question

A rooftop unit holds 100 pounds of R-410A, an HFC. Does the Part 82 leak repair section, 40 CFR 82.157, apply to it?

• AYes, because it holds more than 50 pounds
• BYes, at the 20 percent commercial rate
• CNo, it covers only ozone-depleting refrigerantsCorrect answer
• DNo, because rooftop units are exempt from all leak rules

Why “No, it covers only ozone-depleting refrigerants” is correct

Since April 10, 2020, 82.157 applies only to appliances with 50 or more pounds of a class I or class II refrigerant, and not to appliances containing only substitutes such as HFCs. An HFC appliance like this may instead fall under the separate 40 CFR Part 84 leak repair rule, which started January 1, 2026.

Source: 40 CFR 82.157(a); 40 CFR 84.106(a)

Why the other answers are wrong

• Yes, because it holds more than 50 pounds — The 50-pound threshold counts only class I or class II refrigerant under Part 82.
• Yes, at the 20 percent commercial rate — A rooftop unit is comfort cooling, and Part 82 leak repair does not cover HFCs anyway.
• No, because rooftop units are exempt from all leak rules — Rooftop units have no blanket exemption; an R-22 rooftop unit of 50 pounds or more is covered by 82.157.

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