Those are interesting interpretations. The way I read it, is than anything under 50 lbs. comes under a 15% formula. I'm not saying you guys are wrong, I'd just like to know where I am misunderstanding the section.
"For the commercial and industrial process refrigeration sectors, leaks must be repaired when the appliance leaks at a rate that would release 35 percent or more of the charge over a year. For all other sectors, including comfort cooling, leaks must be repaired when the appliance leaks at a rate that would release 15 percent or more of the charge over a year."
Later, it says: "EPA is performing random inspections, responding to tips, and pursuing potential cases against violators. Under the Act, EPA is authorized to assess fines of up to $32,500 per day for any violation of these regulations." Does that mean the building owner would get fined, and not the contractor?
Owners of equipment with charges of greater than 50 pounds are required to repair leaks in the equipment when those leaks together would result in the loss of more than a certain percentage of the equipment's charge over a year. "
That first sentence states that the charge must be greater than 50#. It has always been that way. So unless the system you are working on contains more that 50 #, leak location and repair is not required. That pretty much eliminates the requirement for all residential equipment.
You could be close to trouble by telling a customer that a leak must be located and repaired. If you say it is company policy OK. If you say the EPA requires, then you may be in trouble.