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Get rid of CFCs—if you can afford to
If your building doesn’t have CFC refrigerants, or if they’re easily eliminated, then you’re in position to easily earn this prerequisite.
Even If your base building systems do use CFCsChlorofluorocarbons (CFCs) are a compound of carbon, hydrogen, chlorine and fluorine, once commonly used in refrigeration, that depletes the stratospheric ozone layer., you can still earn this prerequisite. You’ll need to either implement a five-year CFC phase-out plan or show that both conversion and replacement of your equipment is not economically feasible.
How old is your equipment?
CFC production was banned in the U.S. in 1996, so although you should not rely on that date as a clear cutoff (because CFC-based equipment might still have been installed later), newer buildings are likely to find that meeting this prerequisite is very easy.
If your building dates from the mid-1990s or earlier, you can still earn this prerequisite, but probably will need to invest a bit more time in identifying and managing your refrigerants.
CFC-based refrigerants were banned in 1987 by the Montreal Protocol because of their damaging effect on the ozone layer, as this satellite imagery shows. Photo – NASAHCFCs, HFCs are okay
You can focus solely on CFC-based refrigerants for this prerequisite. A lot of project teams make the mistake of going through a lot of effort to deal with the HCFC and HFC-based refrigerants in their buildings, when in fact these are compliant and not addressed by this prerequisite. EAc5: Enhanced Refrigerant Management addresses the environmental impact of all refrigerants, so consider pursuing that credit, and save your effort for it.
Identify your refrigerants
The first step is to identify all refrigerants in the building and determine whether you have CFCs or not. If you’re not sure which refrigerants are in your equipment, don’t assume. Go check the equipment nameplate or vendor documentation to confirm the refrigerant charge.
Economic analysis
If you don’t have CFCs, you’re all set. If you do, you’ll probably want to perform an economic analysis. To avoid having to phase-out CFCs, the economic analysis must show that neither conversion nor replacement of CFC-based systems is feasible. However, because the LEED Reference Guide says to analyze conversion “and/or” replacement, many project teams don’t perform a complete analysis and fail to comply with the requirements.
The payback period indicated by the economic analysis will tell you whether you need to develop a phase-out plan or not. Per the LEED requirements, a simple payback of more than ten years on equipment replacement or conversion is not considered economically feasible. If your analysis indicates a payback of less than ten years, this is considered economically feasible and you must develop and implement a plan to phase-out CFCs within five years of the end of your performance period.
Reduce leakage
If CFC-based refrigerants are used in your building, you must also reduce annual leakage to 5% or less and reduce the total leakage over the remaining life of the unit to less than 30% of its refrigerant charge. To do this, you’ll need to implement a refrigerant management plan.
Is the prerequisite cost-effective?
The cost of the prerequisite will depend on your initial refrigerant inventory and whether you determine that it is economically feasible to retrofit your CFC-based systems.
If your CFC-based equipment is nearing the end of its useful life, and will benefit from being replaced soon anyway, it is probably worthwhile to simply focus on a phase-out plan. This approach may be costly but is probably easy to justify in the context of capital investment and improved energy efficiency.
If your CFC-based equipment is relatively new, it may be worthwhile to conduct the economic analysis early in the project. The paybacks for upgrades to equipment in good condition are rarely favorable, so this analysis will probably show that it’s too expensive to retrofit your equipment, thus saving you the effort of developing a CFC phase-out plan for LEED purposes.
Consider these questions when approaching this credit
- Who is responsible for keeping records of all refrigerants used in base building systems? (Designating a building refrigerant manager is a good practice.) Does any of your equipment use CFC-based refrigerants?
- What is the age and condition of the base building equipment that contains CFC-based refrigerants? These are indicators that can help you to decide where to invest your time at the beginning of the prerequisite work. It may make more sense to phase out CFC-based refrigerants in equipment that has nearly reached the end of its useful life. Alternatively, if you have newer CFC-containing equipment, it may be better to perform the economic feasibility analysis to determine your compliance path.
LEED-EBOM EAp3 FAQs
If a project’s base-building systems do use CFCs, and an economic analysis is required, is it necessary to analyze both the conversion AND replacement of those building systems?
Yes, the economic analysis must include both the conversion AND replacement of the CFC-based building systems.
The LEED Reference Guide states that if CFCs are maintained in the building, the project building must reduce annual leakage to 5% or less, and total leakage over the remaining life to less than 30%. However, the EAp3 credit form does not request information confirming the leakage rates. Does the project need to submit documentation demonstrating the leakage rates?
Yes, even though it is not explicitly requested by the LEED Online form, you are required to include documentation demonstrating that the project has reduced annual leakage to 5% or less, and the total leakage over the remaining life to less than 30%.
Can a project use default leakage rate values or leakage values specified by the manufacturer for equipment rather than actual leakage rate values based on the credit calculations?
Always use the actual calculated value for the leakage rate of each piece of HVAC equipment in the project building that has more than 0.5 pounds of refrigerant. You can calculate the actual leakage rate values by tracking the amount of additional refrigerant that has been added during the maintenance activities throughout the performance period. Note that if the actual leakage rate of a piece of equipment is less than 0.5% (i.e., 0%), use the minimum default value of 0.5% in your leakage rate calculation instead of the actual leakage rate.
Do small appliances (such as refrigerators and water coolers) that have greater than 0.5 pounds of refrigerant have to be included in order to achieve EAp3?
Per the LEED Reference Guide, standard refrigerators, small water coolers, and small HVAC units with less than 0.5 pounds of refrigerant are not considered base building equipment and are exempt from the prerequisite.
However, if you have larger versions of these pieces of equipment, like a large refrigerator or larger window air-conditioning unit, that has more than 0.5 pounds of refrigerant, you do need to address those in your refrigerant management plans. The key factor is not so much the equipment type, but the amount of refrigerant. This is discussed in LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #10127 dated 11/1/2011.
If there is no recorded leakage over the last 12 months, you must use 0.5% for the Lr value, which represents the low end of the allowable range. However, if the equipment is under separate management control (for example, a refrigerator owned by a tenant), you may use the 10% exemption to ignore that equipment (up to 10% of the floor area can be ignored if it is under separate management control).
Legend
- Best Practices
- Gotcha
- Action Steps
- Cost Tip
Before the Performance Period
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Collect information on all base building systems that use refrigerants, including manufacturer, model number, installation date, refrigerant type, and the amount of refrigerant used in the equipment. See the Documentation Toolkit for a sample inventory form.
Equipment that contains less than 0.5 pounds of refrigerant is not considered part of the base building system and is exempt from this prerequisite. Examples may include small HVAC units, standard refrigerators, and small water coolers. On the other hand, if any of this equipment does use more than 0.5 pounds of refrigerant, you must include it in your data for this prerequisite.
Equipment listed in EAp3 and EAc5 must be consistent.
U.S. production of CFCs stopped in 1996, although there was no hard cutoff date for manufacture or installation of CFC-based equipment. So if your building was built in the late 1990s or later, your HVAC systems are less likely to contain CFCs and you are a step ahead with this prerequisite. However, it’s still a good idea to inventory all equipment to verify the refrigerant information, especially if you’re not completely sure. You’ll need that data to document the credit, anyway.
The credit forms for EAp3 and EAc5 are linked. If you are pursuing EAc5, make sure that the credit form version is the same as EAp3. If the credit forms for EAp3 and EAc5 are different versions (which would potentially happen if you attempted the EAc5 in LEED Online at a later date that when you had attempted EAp3) the form for EAc5 will not auto-populate, and you will not be able to complete the credit form. The best thing to do is to request updated forms from GBCI before submitting your application.
Project teams often confuse CFCs, HCFCs, and HFCs.
- Chlorofluorocarbons (CFCs) have been completely phased out of new equipment in the U.S.
- Hydrochlorofluorocarbons (HCFCs), the transitional substitutes for CFCs, are in the process of being phased out.
- Hydrofluorocarbons (HFCs) are another class of refrigerants that are used as substitutes for CFCs and HCFCs. Currently, there are no federal regulations to phase out the production of HFCs.
- This prerequisite addresses only CFC use in base building equipment.
- EAc5: Enhanced Refrigerant Management deals with all refrigerants, including CFCs, HCFCs, and HFCs.
A list of common refrigerants and their applications is included below:

If CFC-based refrigerants are used in the building, you must either commit to a comprehensive CFC phase-out plan or complete an economic analysis to determine whether conversion or replacement of the HVAC system is economically feasible.
Before deciding which compliance path to follow, consider the age and condition of your base building system. It may make more sense to develop a phase-out plan for CFC-based refrigerants in equipment that has nearly reached the end of its useful life. Alternatively, if you have newer CFC-containing equipment that is still performing very well, it may be better to perform the economic feasibility analysis to determine the payback period for retrofitting your equipment.
The CFC phase-out plan must replace base building systems or convert the equipment so that it can use a non-CFC refrigerant. The phase-out procedures must be completed within five years of the end of the project’s performance period.
Alternatively, if an economic analysis shows that neither conversion nor replacement of the base building systems is feasible, the CFC phase-out plan is not required. This analysis must be conducted by a qualified third party who is not directly employed by the building owner or property manager.
Replacement or conversion of a chiller is considered not economically feasible if the simple payback of the work will take longer than 10 years.
Remember that the economic analysis must investigate both conversion and replacement scenarios. Many project teams mistakenly complete only half of the analysis.
Equipment vendors are qualified to perform these analyses and are usually willing to perform them for free, so check with them first. In general, any HVAC engineer is qualified to perform the economic analysis.
Develop a refrigerant management program to minimize leakage of CFC-based refrigerants, if you have them, and employ equipment maintenance best practices.
Reduce annual CFC-based refrigerant leakage to 5% or less. Refer to the Refrigerant Inventory in the Documentation Toolkit for help calculating annual leakage rates.
Reduce total leakage of CFC-based refrigerants over the remaining life of the unit to less than 30% of its refrigerant charge.
Refrigerant management best practices should include clear and simple procedures for recording and collecting refrigerant recharge data for each piece of equipment.
Ensure that your refrigerant management program adheres to the regulations and guidelines specified under the Clean Air Act, Title VI, Rule 608. Refer to the EPA’s summary Web page for more information on the regulatory requirements, including information on venting restrictions, service practice requirements, technician certification, and recordkeeping requirements. (See Resources.)
Preventive maintenance and inspection is key to minimizing ongoing refrigerant leakage. It’s a good idea to add appropriate items to the building preventive maintenance plan (developed for EAp1: Energy Efficiency Best Management Practices—Planning, Documentation and Opportunity Assessment).
Monitor equipment performance to prevent and identify leaks. While actual maintenance must be performed by a certified technician, building personnel who interact with the equipment on a daily basis are the first line of defense against leaks and performance problems.
The capital costs associated with replacing or converting HVAC equipment are typically high, so it is common for the economic analysis to indicate that the payback of conversion or replacement is not favorable and therefore is not economically feasible.
There will be ongoing costs associated with inspection and maintenance of HVAC equipment, but effective preventive maintenance can help to minimize technician costs associated with repairing significant refrigerant leaks.
There are also costs associated with equipment replacement required by a CFC phase-out plan, but these may vary depending on the configuration and age of the base systems in your building. The economic feasibility analysis should help to identify these costs for your specific situation. However, if your equipment is old and will benefit from retrofitting, it probably makes more sense to skip the feasibility analysis and simply focus on the phase-out plan.
During the Performance Period
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Ensure that preventive maintenance is performed on any base building equipment using CFC-based refrigerant. Communicate building goals for minimizing refrigerant leakage to appropriate building personnel to aid inspection and tracking of system performance.
If your building will undergo commissioning, incorporate refrigerant inspection and maintenance tasks into commissioning and into ongoing commissioning plans.
USGBC
Excerpted from LEED 2009 for Existing Buildings: Operations & Maintenance
COPYRIGHT © 2009 BY THE U.S. GREEN BUILDING COUNCIL, INC. ALL RIGHTS RESERVEDEA Prerequisite 3: Fundamental refrigerant management
Required
Intent
To reduce stratospheric ozone depletion.
Requirements
Zero use of chlorofluorocarbon (CFC)-based refrigerants in heating, ventilating, air conditioning and refrigeration (HVAC&R) base building systems unless a third-party audit (as defined in the LEED Reference Guide for Green Building Operations & Maintenance, 2009 Edition) shows that system replacement or conversion is not economically feasible or it is demonstrated that a phase-out plan for CFC-based refrigerants is in place.
Required economic analysis: The replacement of a chiller is considered not economically feasible if the simple payback of the replacement is greater than 10 years. To determine the simple payback, divide the cost of implementing the replacement by the annual cost avoidance for energy that results from the replacement and any difference in maintenance costs. If CFC-based refrigerants are maintained in the building, reduce annual leakage to 5% or less using EPA Clean Air Act, Title VI, Rule 608 procedures governing refrigerant management and reporting, and reduce the total leakage over the remaining life of the unit to less than 30% of its refrigerant charge.
Small HVAC&R units (defined as containing less than 0.5 pounds of refrigerant), standard refrigerators, small water coolers and any other cooling equipmentThe equipment used for cooling room air in a building for human comfort. that contains less than 0.5 pounds of refrigerant are not considered part of the base building system and are exempt.
Potential Technologies & Strategies
Specify only non-CFC-based refrigerants in all new building HVAC&R systems. Identify all existing CFC-based refrigerant uses and upgrade the equipment if economically feasible and/or develop a phase-out plan that identifies a schedule for future replacement.
Publications
U.S. EPA, Ozone Layer Depletion
This website includes information about the science of ozone depletion, EPA’s regulatory approach to protecting the ozone layer, and alternatives to ozone-depleting substances.
Facility Management, Coping with the CFC Phase-out
This magazine’s website provides various articles on the issues of CFC phase-out.
Complying with The Section 608 Refrigerant Recycling Rule
Summary of the EPA regulations and guidelines for compliance with the Refrigerant Recycling Rule. This webpage includes information on the regulatory requirements, including information on venting restrictions, service practice requirements, technician certification, and recordkeeping requirements.
Refrigerant Inventory and Leakage Rate Calculations
Use this worksheet to help track and record information on all building refrigerants, and to calculate refrigerant leakage rates (Lr).
Refrigerant Inventory Data
Check the nameplates on your mechanical equipment, as in this example, for information on refrigerant type and charge.
CFC Phase-Out or Conversion
This template provides a structure for the phase-out or conversion of all HVAC base building systems that used CFC-based refrigerants that contain 0.5 pounds of refrigerant or more.
LEED Online Forms: EBOM-2009 EA
The following links take you to the public, informational versions of the dynamic LEED Online forms for each EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems.-2009 EA credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.
Version 4 forms (newest):
- EAp2: Minimum Energy Peformance
- EAp3: Fundamental Refrigerant Management
- EAc2.1: Commissioning—Investigation & Analysis
- EAc4: Onsite and Offsite Renewable Energy
- EAc5: Enhanced Refrigerant Management
Version 3 forms:
- EAp1: Energy Efficiency Best Mngt. Practices
- EAp2: Minimum Energy Peformance
- EAp3: Fundamental Refrigerant Management
- EAc1: Optimize Energy Performance
- EAc2.1: Commissioning—Investigation & Analysis
- EAc2.2: Commissioning—Implementation
- EAc2.3: Commissioning—Ongoing Commissioning
- EAc3.1: Perf. Measurement—BAS
- EAc3.2: Perf. Measurement—System-Level Monitoring
- EAc4: Onsite and Offsite Renewable Energy
- EAc5: Enhanced Refrigerant Management
- EAc6: Emissions Reduction Reporting
These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions for these forms; for more information, visit LEED Online and click "Sample Forms Download."


55 Comments
Timeline on reports
I have a third party report and analysis on my CFC eliminiation options. However, the report was conducted in 2009. Is there a timeline to how long I can use this report to complete the EA P3 credit? i.e. i.e. Can I use this report if I try to complete my LEED project in 2019?
Refrigerant Management Plan
I have completed a Refrigerant Management Plan for a building and when I go to upload it to the EAp3 credit there is nowhere to place it. In the template we have chosen the second option "Operations and Maintenance Submittal Path". Any assistance will be appreciated.
Thank you!
Refrigerant Gas AB-22- Compliance
Hi,
Does anyone knows if the Refrigerant Gas AB-22-A comply with the CFC´s - EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. requirements?
Is there any Leed adenda in order to confirm this?
Thanks in advance.
Fabiano, I'm not familiar with that refrigerant, and Google wasn't very helpful. What is the chemical?
DHC Plant with CFC refrigerant
Our project is served by district heat and cilled water plant. The plant, owned by different componay from our project owner, uses CFC refrigerant for some of chillers. It is difficult to do feasibility study for replacement of equipment by ourselves as well as to request the plant owner company to write a phase out plan. Is it possible for our project to meet this prerequisite requirement?
Per the District Energy Guidelines for EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems., when a third party owns the district energy system, the EAp3 and EAc5 requirements apply to the downstream equipmentDownstream equipment consists of all heating or cooling systems, equipment, and controls located within the project building and site associated with transporting thermal energy into heated or cooled spaces. This includes the thermal connection or interface with the district energy system, secondary distribution systems in the building, and terminal units. but not the upstream equipmentUpstream equipment consists of all heating or cooling systems, equipment, and controls that are associated with a district energy system but are not part of the project building's thermal connection or do not interface with the district energy system. It includes the central energy plant and all transmission and distribution equipment associated with transporting the thermal energy to the project building and site.. So you're not obligated to try to convince a different company to change the way they do business with refrigerants. So, as long as you meet all of the EAp3 requirements for your own downstream equipment and make reference to the district energy guidelines, you will have the opportunity to meet this prerequisite. You can download a copy of the DES Guidelines for EBOM here: https://www.usgbc.org/ShowFile.aspx?DocumentID=8697
Let me ask one more question. Is it possble to pursue LEED-CI certification for future tenant to occupy the same building served by the DHC plant using CFC?
Noriko, I'm not sure I understand your question. Are you talking about a LEED-CI certification within the LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. certified building? That would depend on the specifics.
Include portable equipment?
Comments below say portable equipment that is not base building (but with greater than 0.5 pounds of refrigerant) can be excluded from this prerequisite, but the FAQ section reads:
"Yes, small appliances that carry a refrigerant charge over 0.5 pounds, like water coolers and refrigerators, must be included in your inventory and calculations."
Can anyone clarify this for me?
EBI, can you give an example of equipment that you're wondering about?
We are working with a vocational school that has 3, large stand-alone plug in refrigerators and freezers. They use CFC refrigerant (greater than 0.5 pounds) and I'm unsure whether to include them in our documentation for the prereq (we will not be pursuing EAc5). They are commercial grade, and I wouldn't call them portable, but they are also not base building.
Backup Unit
I am working on a project where the main unit is new and thus in compliance but there is a backup unit which uses CFCsChlorofluorocarbons (CFCs) are a compound of carbon, hydrogen, chlorine and fluorine, once commonly used in refrigeration, that depletes the stratospheric ozone layer.. I am assuming the replacement of a backup unit would be economically infeasible and thus we will only have to ensure that leakage is minimized. Is this correct?
You will still need to conduct an assessment of the economic feasibility of both converting and replacing that backup unit and provide the results as your documentation for the prerequisite.
Tenant owned chiller with R-11?
I am working with a large building in New York. This building has a tenant that has their own chiller that utilizes R-11 refrigerant. Since the property team has no control over the tenants chiller, and therefore cannot conduct studies, implement refrigerant plans, etc., can we exempt the tenant's equipment, or would this still have to fall under the 10% multi-tenant exemption rule? Has anyone run into similar situations?
That's a tricky one. It's tough to say whether the chiller in question would be considered base-building equipment or not. Typically, the prerequisite should address all refrigerants in the building, but if you have a non-cooperative tenant who is unwilling to participate in this process, you may be able to speak to GBCI to arrange some alternative compliance path.
Phase Out Plan
EA credit 5 - Enhanced Refrigerant Management is currently denied in our project for the Refrigerant Impact per ton value exceed the allowable 100. We are implementing a phase out plan for the project, but we still don't know what characteristics a phase aout plan have. Where can we take basis on how to fill this plan? What characteristcs does a plan like this have?
Thank you!
Paola, it is important to understand that the CFC phase out plan is more important for the documentation for EAp3, Fundamental Refrigerant Management. If the calculations for EAc5 show that the refrigerant impact per ton is greater than 100 during the performance period, it will not change the measured outcome of that credit if you submit a CFC phase out plan during your final review.
However, a CFC phase out plan may be necessary depending on the analysis you performed for EAp3 - was that prerequisite also denied during your preliminary review? Essentially, if your building uses CFC-based refrigerants and the required economic analysis for EAp3 shows that it will be economically feasible to either convert or replace the existing equipment with an alternative that does not use CFCsChlorofluorocarbons (CFCs) are a compound of carbon, hydrogen, chlorine and fluorine, once commonly used in refrigeration, that depletes the stratospheric ozone layer., THEN you are required to provide a plan that shows how your will phase out those CFC-based refrigerants within 5 years. The requirements of the phase-out plan are described on pages 146-148 of the 2009 Edition of the Reference Guide.
Jason, first of all thank you for helping us.
I believe the situation we described is not so clearly exposed. In our project we are using the refrigerants R-22 and R-407c. The prerequisite for this credit is earned, however the credit is denied for the Refrigerant Impact per ton value exceeds the allowable. We intend to also earn this credit, this is why we are planning to provide a phase out plan, and some piece of equipment which uses R-22, change for the R-134a use, then the Refrigerant Impact per ton value would decrease. Do you believe this situation is feasible? Or should we try something else?
Hi Paola,
Thanks for clarifying, but unfortunately, my response still holds true. The documentation for EAc5 is based on the observed performance in your project building during your defined performance period and the performance period may not be extended for this particular credit. You are correct in stating that the refrigerant impact per ton would decrease if you replaced or converted the equipment that is currently using R-22, but your EAc5 documentation for this certification project must be based on actual performance during the performance period and not on a promise to modify the refrigerant inventory at some future point. I'm sorry to say it, but you should consider this credit to be unachievable for this current project, and look ahead to a future re-certification project while considering any potential retrofits to your chiller equipment to ensure that you will be able to meet the requirements at that time.
Hi Jason,
Again, thanks for answering us so fastly.
You have just confirmed what one of our project team members said. We will not try to earn this credit for this project anymore, but this serves as a lesson, and for a future re-certification we are going to start planning since now what we are going to do.
Once again, thank you for your help !
Refrigerant Management Plan
Does anyone know of a good resource to use as a template for developing a refrigerant management plan for a building? I am currently working with multiple projects that do have cfc-based refrigerants.
Hi Chris,
Did you check out LEEDuser's Phase-out/Conversion Plan Template that's included in the Documentation Toolkit for this credit? Seems like that might be what you're looking for.
CFC-Based Refrigerant Annual Leakage Rate
I'm hoping for some insight on the annual leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). calculation, the reference guides reference to EPA Clean Air Act, Rule 608, and the Refrigerant Management Plan.
On page 145 of the reference guide it state, "If CFC-based refrigerants are maintained in the building, reduce annual leakage to 5% or less using EPA Clean Air Act, Title VI, Rule 608 procedures governing refrigerant management and reporting, and reduce the total leakage over the remaining life of the unit to less than 30% of its refrigerant charge."
A building considering LEED had refrigerant added 6 months ago, according to the annual leakage rate calculation using Te, around 8%. Since the leak was detected and refrigerant was added and issue repaired, the building has experienced no leaks and 0 lbs of refrigerant has been added. They have implemented a Refrigerant Management Plan per EPA Clean Air Act, Rule 608, and have REDUCED their leak to "0" %. We feel that they have met the intent of this prerequisite since they have effectively reduced the leak to 0, followed the Standard reference in the requirement (which, btw when read closely allows 15% annual leakage rate, not the 5% in the requirement) and implement the plan with the purpose of reducing their leakage rate.
The language used is unclear if implementing a management plan to reduce to 5% is acceptable, or if a bad purge valve 6 months ago will continue to haunt us until a full year has passed and the refrigerant added is no long relevant. Oh, and as Chris Munn mentioned above, the credit doesn’t even require you to upload this calculation, so how hard and fast is this 5% cutoff? It doesn’t seem right that just waiting a year will give us the green light if we have made the corrective actions already and 0 refrigerant has been added since. Any help?
I haven't seen this situation before, but based on how the requirements are presented in the RG, at some point you would be able to move on from your leaky history and use more current, post-fix leakage data. Since at this point you have 6 months of leak free data, it seems you could establish that the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). is now (or better, at the end of the performance period), still zero.
However, since this is a prereq, it might be worth getting a clear path forward from GBCI so that you don't run into trouble during the review phase.
Standard path vs alternative compliance approach?
How do I decide which one to pick?
Danielle, I think how you approach this credit depends a lot on your building. Are you looking at a situation with an economic feasibility question? Can you give a few more particulars?
Sorry Tristan for the late response. I was unable to login for a while for some unknown reason. This is an existing building (Non profit org) and we are trying to get them LEED certified. There's one big refrig with HCFC. All the other eqt (window A/C) have less than 0.5 lbs refrig and are exempt. LEED online asks to explain why an alternative path is used vs standard. I have not seen that in any manual. Thanks if you can help.
Danielle, it doesn't seem that you would need to use an alternative compliance path. If you only have one piece of equipment that has more than 0.5 pounds of refrigerant, and that equipment does not use a CFC-based refrigerant, then you would simply use the standard compliance path and indicate that the building does not use CFCsChlorofluorocarbons (CFCs) are a compound of carbon, hydrogen, chlorine and fluorine, once commonly used in refrigeration, that depletes the stratospheric ozone layer.. Note that HFCs and HCFCsHydrochlorofluorocarbons (HCFCs) are refrigerants that cause significantly less depletion of the stratospheric ozone layer than chlorofluorocarbons. are a different class of refrigerants than CFCs, and have a reduced environmental impact.
Does the 10% exclusion rule apply to this credit?
Does the 10% exclusion rule apply to this credit? We have a multi-tenant high rise without CFCsChlorofluorocarbons (CFCs) are a compound of carbon, hydrogen, chlorine and fluorine, once commonly used in refrigeration, that depletes the stratospheric ozone layer., but one restaurant (5% of floor spce) does have an isolated CFC-based system (yes, greater than 0.5 pounds of refrigerant). Can we simply exclude this area, or must we perform the economic analysis?
If the restaurant is under separate management control than the rest of the building and the equipment in question is used only for the restaurant, then, yes, it could be excluded from EAp3. Make sure you note this in Table PIf3-1 on Project Information Form for PIf3.
No Manufacturer and No Model Name.
Our project is a multi tenant spaceTenant space is the area within the LEED project boundary. For more information on what can and must be in the LEED project boundary see the Minimum Program Requirements (MPRs) and LEED 2009 MPR Supplemental Guidance. Note: tenant space is the same as project space. and consist few restaurant. we unable to identify the manufacturer and model name of the refrigerator but we able to know the type of refrigerant used. in LEED template, can i ignore the "manufacturer" and "model" column? i have about 15 types of refrigerator without this details.
as long as you include a narrative explaining the situation and describe the steps you took to try to track down the manufacturer and model name, this should be fine.
I would also suggest uploading photos of the existing equipment so the reviewer can get an idea of what's in the building.
CFCs vs HCFCs
Are HCFCsHydrochlorofluorocarbons (HCFCs) are refrigerants that cause significantly less depletion of the stratospheric ozone layer than chlorofluorocarbons. considered to be CFC based?
leakage rate
Do we need to use actual values based on calculations provided for this (p221 of manual) or can we use default of 2% or 0.5% (if specified by manufacturer)?
This issue has always been a little confusing and has become a bit more muddled in light of recent rulings made by GBCI that further defined the allowable values for leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). (Lr). Here's the low-down:
*The "default" value of 2% should never be used. Ever. This is a LEED-NC concept that was never appropriately aligned for the EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. rating system. If a project team is unable to calculate their actual leakage rate for a building that is currently occupied with operational equipment, they would not meet the minimum requirements for the prerequisite. Likewise, do not use manufacturer specifications for anticipated leakage rates. Anything can happen once a piece of equipment is installed and operational, so the manufacturer's estimates may not accurately capture the actual performance.
*Bottom line - always use the actual calculated value for leakage rate of each piece of HVAC equipment in the project building with more than 0.5 pounds of refrigerant. You can calculate these values by tracking how much additional refrigerant has been added during maintenance activities throughout the performance period.
*There is only one caveat to this rule: If the actual measured leakage rate of a piece of equipment is less than 0.5%, you must use the minimum default value of 0.5% in your calculations for Lr. You cannot use 0% in your calculations; if you do, the reviewer will adjust your calculations and report the updated Refrigerant Impact per Ton. This minimum default value is specified in the Rating System language for EAp3, so it's pretty much set in stone. This requirement has recently been enforced much more consistently and the reviewers are on the lookout for incorrect calculations, so make sure you use the correct values.
Jason -
Can you direct me to "the recent rulings" by GBCI that you refer to in this comment stream regarding the allowable values for leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).? I've looked in the addenda (up through 11/3/10), the CIRs, and the reference guide but have not found anything that says you cannot use the 2% leakage rate as a default. On page 223 of the Reference Guide, Sample Calculation 2, describes a scenario that uses actual leakage rate and the 2% default - indicating it would be ok for us to do so as well.
As I understand it, EPA only requires an owner of appliances that contain 50 or more pounds of refrigerant to tracking the amount of refrigerants, which may mean the some organizations will not have this information at their fingers tips and I do not see where it says you should track your leakage rate for the performance period (which as it could be as short as 3 months).
On the other hand, if you have appliances that are less than 50 pounds but more the 0.5 pounds and have not had to put refrigerant in them over the past year, then you could accurately say your annual leakage rate is 0%, but you would use the LEED required minimum of 0.5%
Thanks for providing this valuable information. I guess Im just looking for the actual documentation from GBCI before we head down the actual leakage rate route.
Per page 221 of the LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. Reference Guide, "Refrigerant Leakage RateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). (Lr) must be based on actual leakage rates experienced in the project building..." The suggestion that project teams can use a default of 2% and not even bother tracking leakage from their equipment is misleading and incorrect. I can tell you unequivocally that the review team will send the credit back to you and ask for clarification if you do not use actual leakage rates and provide some documentation substantiating your claim.
Your note about using 0.5% Lr when you have not had to recharge any equipment is correct - that is exactly how you should manage that scenario.
Thanks for getting back to me Jason. I really appreciate it. We'll move forward by tracking our leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608)..
Thanks again!
My question is how do you change the default rates to .5%?? The field cannot be edited directly and is based on the refrigerant added and the days since refrigerant last added column.
It looks like if I use .05% of the total refrigerant in the lbs of refrigerant added column and 365 in the days since refrigerant last added colum, the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). changes to .5%. Is this what I should be doing?
Kim, there's been an ongoing battle with GBCI and USGBC over the usability of the EAc5 credit form. My guess is that you may not be upgraded to the most recent version of the form. You can request a form upgrade by calling or emailing GBCI customer service. Once you have Version 4.0 of this form, the field for Lr is an editable field that you can adjust.
refrigerant charge
Based on actual calculations of the refrigerant charge value (lb/ton) some of the values are higher than the "default maximum allowable equipment refrigerant charge" according to table 2 of the manual (p220). This is due to smaller equipment (lower tonnage compared to the refrigerant in pounds). We will enter actual values in the templates but will this be accepted by LEED?
Pablo, good for you for taking actual measurements of your refrigerant values. Please go ahead and use the actual values in your LEED documentation. The table provided on P. 220 of the Reference Guide is simply a design tool to help inexperienced users verify that their refrigerant data is falling within the traditionally accepted ranges. However, actual values should always be used for refrigerant calculations in order to accurately document the conditions at your project building.
We have refrigerant re-charge data for most equipment. However, there are a few new equipment, as well as old refrigerators.
My queries:
1) For the former (new A/C's), we have not yet recharged refrigerants. For the latter (old refs), we have not charged over time. Are we allowed to make assumptions for these?
2) Which assumptions are we allowed to make? - from the LEED EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. manuals?
conversion “and/or” replacement
As stated under "Economic Analysis" in Bird's Eye View, "...the LEED Reference Guide says to analyze conversion “and/or” replacement, many project teams don’t perform a complete analysis and fail to comply with the requirements." So what is the course of action here if we only completed a replacement analysis? Do we need to really have another analysis for conversion?
In a word—yes. That's what we've found, despite the ambiguous reference guide language.
It makes sense to me—if you haven't looked at conversion why should you get a pass on the prereq?
CFC-Refrigerant Submittals
In the requirements of this credit, the reference guide states that if CFC-based refrigerants are maintained in the building, reduce annual leakage to 5% or less, and total leakage over the remaining life to less than 30% of its refrigerant charge.
However, there is no place in the LEED Online form that asks for documentation regarding this. In addition, there are no uploads whatsoever required for this credit. Do you simply have to fill-in the credit form and the table in the form based on the results of the chiller replacement and refrigerant conversion to comply with this credit, even if you use R-11, or will reviewers ask for further documentation of the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).?
Yes, it looks like that's the case. I double-checked both the EAp3 and EAc5 LEED Online credit forms, and they are remarkably simple in just focusing on the equipment inventory. The leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). documentation is a good idea to compile and I would have it in my back pocket in case the reviewer asks for it.
We have 7 HVAC equipment, 6 of them are R-22 and 1 R-410A, is it acceptable for EAp3 and EAc5 requirements? Or we really need to replace all of them under R-410A just to comply on the requirement.
thanks,
R-22 is an HCFC so it will be fine for the prerequisite. There's a chance you could earn EAc5, but it will really depend on your leakage rates over the 12-month period preceding your application submittal.
On page 221 of the LEED Reference Guide it shows the formula for calculating Leakage RateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608).....a part that confuses me is the "Days Since Refrigerant Last Added". Is this the number of days between the date last added and the current date, or the date last added and the date last added before that?
Also when entering the data for LR does this only pertain to activities for the last 12 months before submittal? I have over 90 RTUs and only 7 or 8 will have problems in that time span so I would just put the .5% for the rest?
I am also having an issue finding a place to document the leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). (compliance of EPA's rule 608.) The only option available looks like "alternative compliance approach". Is this what others are going? We've never had this question come back before.
Submittal Inventory Table ?
The building contains no CFC's. For the required submittal inventory table, do I need to list all 250 heat pumps in the building? Or do I only need to include the chiller information?
It seems that you do - the tempate requires that you list all mechanical cooling equipmentThe equipment used for cooling room air in a building for human comfort. serving the building. You may be able to provide this information in clusters if you have the same heat pumpA type of heating and/or cooling equipment that draws heat into a building from outside and, during the cooling season, ejects heat from the building to the outside. Heat pumps are vapor-compression refrigeration systems whose indoor/outdoor coils are used reversibly as condensers or evaporators, depending on the need for heating or cooling. In the 2003 CBECS, specific information was collected on whether the heat pump system was a packaged unit, residential-type split system, or individual room heat pump, and whether the heat pump was air source, ground source, or water source. (same refrigerant, install date, etc...) in portions of the building (under equipment location you might note Floors X-Y) but the expectation is that the template will capture/list all equipment in some form or fashion.
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