More of a solution than a question I suppose;  I was recently provided the following review comment:

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The Requirements section of EAp3 in the LEED-EB O+M v2009 Reference Guide states that if CFCbased

refrigerants are maintained in the building, the annual leakage must be reduced to 5% or less using

EPA Clean Air Act, Title VI, Rule 608 procedures governing refrigerant management and reporting, and

the total leakage over the remaining life of the unit must be reduced to less than 30% of its refrigerant

charge. Confirmation of this has not been provided. Provide documentation, which must be a narrative at

minimum, to confirm that EPA Clean Air Act regulatory requirements are in place for the remaining CFCBased

systems. The annual refrigerant leakage rate (Lr) must be calculated using a method recognized by

the U.S. EPA pursuant to the EPA Clean Air Act Title VI, Rule 608, and must be based on the most recent

amount of refrigerant added, independent of the performance period start and end date. The time elapsed

is the number of days in between the two most recent refrigerant charges, regardless of whether refrigerant

is checked on a regular basis (e.g., annually). The maximum 30% end of life leakage rate must be

calculated based on the total amount of refrigerant lost over the life of the equipment through the end of

the performance period. Please refer to LEED Interpretation ID # 10392 for additional guidance.

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In 7 years of exclusive LEED EB project consulting, I have never been asked to do this for EAp3 - Fundamental Refrigerant Management.  Interpretation ID#10392 did not offer much of a solution either, only more questions.  Calculation methodology was eventually found HERE.  The Solution?:  The project team elected to utilize the default leakage rate, assuming the worst case of 2%, because there had been no recent history of leaks on the CFC containing chiller.  This methodology was accepted without further issue.

This review comment seems to go above an beyond the typical "Check Box", surpassing the project teams expectations.  Have I just gotten lucky on past projects where I was never asked to take this extra step, or is this a very standard response to CFC containing equipment for EAp3?  There is nowhere on the form that asks to explain leakage in this much additional detail.  Should we expect all future projects to ask for the same detail and list this as a "Special Circumstance" to preemptively address this concern? This seems more like a comment that may have come back for EAc5 - Enhanced Refrigerant Management than EAp3.