Using the rolling average method, what is its leak rate, and must it be repaired under Part 82?

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 200-pound R-22 commercial refrigeration system received 30 pounds of refrigerant over the previous 365 days. Using the rolling average method, what is its leak rate, and must it be repaired under Part 82?

• A15 percent; no repair is required at the 20 percent rateCorrect answer
• B30 percent; repair is required
• C15 percent; repair is required because it exceeds the 10 percent rate
• D6.7 percent; no repair is required

Why “15 percent; no repair is required at the 20 percent rate” is correct

The rolling average method divides the pounds added over the past 365 days by the full charge: 30 / 200 = 0.15, or 15 percent. Commercial refrigeration has a 20 percent trigger rate, so this appliance is under it.

Source: 40 CFR 82.152; 40 CFR 82.157(c)

Why the other answers are wrong

• 30 percent; repair is required — 30 is the pounds added, not the percentage of the charge.
• 15 percent; repair is required because it exceeds the 10 percent rate — The 10 percent rate is for comfort cooling, not commercial refrigeration.
• 6.7 percent; no repair is required — This divides the charge by the pounds added the wrong way round.

Practice more of this

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