I'm hoping for some insight on the annual leakage rate 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?