3-PAGE VECTOR A4 STUDIO
EPA 40 CFR Part 84 & Section 608 Quick Reference Summary Citation: 40 CFR Part 84, Subpart C (High-GWP Commercial Refrigeration Priority Enforcement)

Printable R-404A 10-Ton Dual-Circuit Commercial RTU EPA Compliance Log Sheet & Verification Certificate

For a 10-Ton Dual-Circuit Commercial RTU charged with 31 lbs 0 oz (31.00 lbs) of R-404A (GWP 3922, ASHRAE Class A1), the 2026 EPA 40 CFR Part 84 maximum leak rate threshold is 10% (Comfort Cooling (10% Max EPA Leak Rate)). Adding more than 3 lbs 2 oz (3.10 lbs) in 12 months (Rolling Average) or 0 lbs 12 oz (0.76 lbs) within 90 days (Annualizing) triggers a mandatory 30-day repair clock and 10-day follow-up verification test.

Exact R-404A Addition Weights That Trigger a 30-Day EPA Repair on a 10-Ton Dual-Circuit Commercial RTU

Pre-computed for a nominal factory full charge of 31 lbs 0 oz under the 10% Comfort Cooling (10% Max EPA Leak Rate) limit:

Days Since Last Charge Annualizing Multiplier Max Addition Before 10% Trigger (Annualizing) Max 12-Mo Addition (Rolling Avg) 125% Chronic Leaker EPA Report Limit
30 Days 12.17x 0 lbs 4 oz (0.25 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)
60 Days 6.08x 0 lbs 8 oz (0.51 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)
90 Days 4.06x 0 lbs 12 oz (0.76 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)
180 Days 2.03x 1 lbs 8 oz (1.53 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)
270 Days 1.35x 2 lbs 5 oz (2.29 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)
365 Days 1.00x 3 lbs 2 oz (3.10 lbs) 3 lbs 2 oz (3.10 lbs) 38 lbs 12 oz (38.75 lbs)

R-404A (Suva HP62 / Genetron AZ-50) Thermodynamic & Safety Profile

Global Warming Potential
3922 (AR4 100-Yr)
ASHRAE 34 Safety Class
Non-Flammable (ASHRAE Class A1)
Charging Phase & Glide
Liquid Only (into receiver or through sight-glass throttling valve) (0.8 degF Glide)
Lubricant & Thread Spec
POE (Polyolester Synthetic Oil) • Standard 1/4-inch Right-Hand Flare (RH)

R-404A Saturation Pressure-Temperature (PT) Reference (PSIG)

-10 degF 23.6 PSIG
0 degF 33 PSIG
20 degF 56.8 PSIG
40 degF 89.2 PSIG
60 degF 131.6 PSIG
85 degF 201.2 PSIG
105 degF 273.5 PSIG
125 degF 362.1 PSIG

R-404A DOT Recovery Cylinder 80% Maximum Safe Fill Weights (at 130 degF)

DOT Cylinder Specification Water Capacity (WC) Typical Tare Wt R-404A SG @ 130 degF Max 80% Net R-404A Charge Max Safe Gross Scale Reading
30-lb DOT-4BA400 Refrigerant Recovery Cylinder 26.2 lbs 17.8 lbs 0.84 17 lbs 10 oz (17.61 lbs) 35 lbs 7 oz (35.41 lbs)
50-lb DOT-4BA400 Refrigerant Recovery Cylinder 47.6 lbs 28.5 lbs 0.84 32 lbs 0 oz (31.99 lbs) 60 lbs 8 oz (60.49 lbs)
125-lb DOT-4BW400 Commercial Recovery Cylinder 123.0 lbs 62.0 lbs 0.84 82 lbs 10 oz (82.66 lbs) 144 lbs 10 oz (144.66 lbs)

Engineering & EPA Part 84 Field Compliance Protocol for R-404A 10-Ton Dual-Circuit Commercial RTU

Under the US EPA AIM Act Subsection (h) rule (40 CFR Part 84, Subpart C) effective January 1, 2026, any 10-Ton Dual-Circuit Commercial RTU operating with R-404A (Suva HP62 / Genetron AZ-50, AR4 GWP 3922) holding 15.0 pounds or more of refrigerant is subject to mandatory federal leak rate calculations and 3-year recordkeeping. With a nominal factory charge of 31 lbs 0 oz (31.00 lbs), this 10-Ton Dual-Circuit RTU exceeds the 15-pound threshold by 16.0 lbs and falls under the 10% maximum annual leak rate limit for Comfort Cooling (10% Max EPA Leak Rate).

SAFETY & OIL COMPATIBILITY: R-404A carries an ASHRAE Class A1 non-flammable classification and utilizes Standard 1/4-inch Right-Hand Flare (RH) service connections. This system circulates POE (Polyolester Synthetic Oil), which is highly hygroscopic in POE applications—requiring evacuation verification below 500 microns using an electronic thermistor or capacitance micron gauge prior to recharging.

CHARGING & PINPOINT VERIFICATION: With a negligible glide of 0.8 degF and a normal boiling point of -51.2 degF, R-404A maintains stable saturation pressures (89.2 PSIG at 40 degF evaporator coil; 273.5 PSIG at 105 degF condensing temperature). During EPA initial and follow-up verification tests, inspect Walk-in freezer liquid-line solenoid valves, receiver Rotolock service valve packing glands, EPR pressure regulators, and defrost hot-gas headers..

Frequently Asked Questions: R-404A 10-Ton Dual-Circuit RTU Compliance

How many pounds or ounces of R-404A trigger an EPA leak repair on a 10-Ton Dual-Circuit Commercial RTU?

For a 10-Ton Dual-Circuit Commercial RTU holding 31 lbs 0 oz (31.00 lbs) of R-404A under the 10% Comfort Cooling (10% Max EPA Leak Rate) limit, adding more than 3 lbs 2 oz (3.10 lbs) over a rolling 365-day period triggers the mandatory 30-day EPA repair clock. Under the Annualizing Method, if only 90 days have elapsed since the last charge, adding just 0 lbs 12 oz (0.76 lbs) will exceed the 10% annualized threshold.

Is a 10-Ton Dual-Circuit Commercial RTU using R-404A regulated under the 2026 EPA AIM Act 15-pound rule?

Yes. Because R-404A has a GWP of 3922 (greater than 53) and this 10-Ton Dual-Circuit RTU holds 31 lbs 0 oz (31.00 lbs) (at or above the 15-pound threshold effective January 1, 2026 under 40 CFR Part 84), the building owner and servicing contractor must calculate leak rates on every addition, perform initial and 10-day follow-up verification tests, and keep records for 3 years.

What triggers a mandatory EPA Chronic Leaker Report for this R-404A 10-Ton Dual-Circuit RTU?

Under 40 CFR 84.106(j), if cumulative refrigerant additions to this 31 lbs 0 oz (31.00 lbs) 10-Ton Dual-Circuit RTU reach or exceed 125% of its full charge (38 lbs 12 oz (38.75 lbs)) within a single calendar year, the owner/operator must submit a Chronic Leaker Report to the EPA by March 1 of the following year describing the root cause and corrective plan.