I have a project on a looped DES with a couple of non-compliant CFC-chillers upstream/on the same loop.

A 3rd-party audit has determined that phase-out is not economically beneficial in 10-years or less, so we will be filing for the alternative compliance path and including this assessment for the reviewers.

BUT, per the DES guidance document "Treatment of District or Campus Energy in LEED . . . 2009-Design & Construction," the owner is also required to reduce any CFC leakages to 5% or less using the EPA Clean Air Act, Title VI, Rule 608.

Using the required EPA calculation (as also explained in the LEED EBOM 2009 reference guide on page 148), how do we "set the time" for the calculation?

To be clear, do we perform this calc for each piece of CFC-equipment and set T for time to the last time refrigerant was added OR 365 days, whichever is shorter? Or does the time start at some other benchmark, such as the project registration date?

Please clarify--thanks very much!