Type II: High-Pressure Systems and Leak Rules

Type II is the section most residential and light commercial technicians need, and it carries the most numbers: pressure categories, an evacuation table with a 200 lb split, and leak repair rates with deadlines. The good news is that the numbers follow a pattern. Learn the pattern and you stop memorizing rows.

What Type II covers (more than the name says)

EPA's page calls Type II "high-pressure." The regulation is wider. Under 40 CFR 82.161, Type II is required for technicians who maintain, service, repair or dispose of medium-, high- or very high-pressure appliances, except small appliances, MVACs and MVAC-like appliances. So an R-134a system, which is medium-pressure, is Type II work.

The pressure categories

EPA sorts appliances by the refrigerant's liquid phase saturation pressure at 104 °F, in 40 CFR 82.152:

Source: EPA Section 608, 40 CFR 82.152 and 40 CFR 82.161.

The evacuation table

Before opening an appliance, you evacuate it to the level in Table 1 of 40 CFR 82.156, using certified recovery equipment, and verify the level before you open it. Levels are in inches of mercury vacuum relative to standard atmospheric pressure of 29.9 inches of Hg.

Source: EPA Section 608, 40 CFR 82.156(a), Table 1.

The pattern

• Lower pressure category, deeper vacuum. Medium-pressure rows ask for more vacuum than high-pressure rows.
• Bigger charge (200 lb or more), deeper vacuum.
• Newer recovery equipment (on or after November 15, 1993), deeper vacuum.
• Very high-pressure and small high-pressure systems are 0 in either column.

Two more rules from 82.156 that show up on tests. For non-major repairs not followed by evacuation to the environment, medium-, high- and very high-pressure appliances may be evacuated to no higher than 0 psig before opening. If leaks make the table level impossible, isolate the leaking parts where you can, evacuate the non-leaking parts to the table level, and evacuate the leaking parts to the lowest level you can reach without substantially contaminating the refrigerant, never above 0 psig.

And one about equipment: system-dependent recovery equipment, which relies on the appliance's own components, may not be used on appliances with a full charge of more than 15 pounds unless it is a permanently attached pump-out unit (82.156(e)).

Leak repair: rates and deadlines

EPA's test topics page lists Leak Detection and Leak repair requirements for Type II. The rule is 40 CFR 82.157. Its scope is specific: since April 10, 2020 it applies to appliances with a full charge of 50 pounds or more of a class I or class II (ozone-depleting) refrigerant, and it does not apply to appliances containing only substitute refrigerants.

The leak rate is the share of the full charge that would be lost over 12 months at the current rate, calculated each time refrigerant is added. The key deadlines:

• 30 days to identify and repair leaks after a refrigerant addition that exceeds the rate, or 120 days if an industrial process shutdown is needed.
• An initial verification test to confirm the repair worked, and a follow-up verification test within 10 days of a successful initial test, or within 10 days of reaching normal operating conditions if the appliance was evacuated.
• Leak inspections after an exceedance: quarterly for commercial refrigeration and industrial process refrigeration with 500 lb or more, once a calendar year for those from 50 to under 500 lb and for comfort cooling, until the leak rate stays below the threshold for the required period.
• Chronic leakers: an appliance that leaks 125 percent or more of its full charge in a calendar year must be reported to EPA by March 1 of the following year.
• Instead of repairing, an owner may develop a retrofit or retirement plan within 30 days and generally complete it within one year.

Source: EPA Section 608, 40 CFR 82.157 and EPA's leak repair requirements page.

Why the rates are 20, 30 and 10

They used to be higher. EPA's regulatory updates page explains that the November 18, 2016 rule lowered them: industrial process refrigeration from 35 to 30 percent, commercial refrigeration from 35 to 20 percent, comfort cooling from 15 to 10 percent. That rule also extended leak repair to substitutes, but a rule signed on February 26, 2020 rescinded that extension, effective April 10, 2020. That is why the current text covers only ozone-depleting refrigerants. If a practice question uses R-22, the leak rules apply. If it uses only R-410A, the Section 608 leak repair rules do not.

A Type II question to try

Three more Type II questions are in the free quiz.

Frequently asked questions

Does Type II cover medium-pressure appliances?

Yes. 40 CFR 82.161 says Type II is required for medium-, high- or very high-pressure appliances, except small appliances, MVACs and MVAC-like appliances.

What are the leak repair trigger rates?

For appliances with 50 lb or more of an ozone-depleting refrigerant: 20 percent for commercial refrigeration, 30 percent for industrial process refrigeration, and 10 percent for comfort cooling and other appliances.

How long does an owner have to repair a leak?

30 days, or 120 days if an industrial process shutdown is needed, under 40 CFR 82.157.

Do the 608 leak repair rules apply to R-410A systems?

Since April 10, 2020, 40 CFR 82.157 applies only to appliances with 50 lb or more of class I or class II refrigerant, and not to appliances containing only substitutes such as R-410A. Other EPA rules under the AIM Act are separate.