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Chronic-Leaker Classification

The chronic-leaker classification is TuffOps' implementation of EPA §84.106(j). A unit is classified when, over a single calendar year, its top-off additions cross 125% of its full charge — and the unit is large enough and in scope to count.

The classification is not a diagnostic — it's a regulatory state with a §84.106(m)(4) reporting obligation. This page explains how it gets set and what shape it takes.

The 125% rule​

For each calendar year, TuffOps sums the unit's top-off additions where the event is:

  • non-voided,
  • not flagged with the part84_leak_rate_exception flag, and
  • of positive quantity.

If that sum, divided by the unit's full charge, is 125% or more, the year qualifies for classification — provided the eligibility floor is also met.

Removals, retrofits, and initial-charge events are excluded. The math is "how much fresh refrigerant did you have to add in this calendar year, as a percentage of what the unit holds."

Eligibility floor: 15 lb full charge​

The classification only fires for units with full charge ≥ 15 lb. Smaller units fall outside §84.106 entirely (they're below the §84.106(a) threshold), so the chronic clock doesn't run on them.

This is a hard gate. A unit with full charge of 14.9 lb that has lost 200% of its charge in a year is not classified — it's just leaking.

The Subpart C check​

The classification only fires for units where the policy resolver returns applies for Subpart C. Units flagged ODS-only, units carved out by RLCA, and units with unknown classification do not get classified.

This means the Part 84 remediation queue is the prerequisite. If your queue is full of unknown units, none of them can become chronic — even if they're losing all their charge.

The lifecycle​

A classification moves through three states.

1. Active (amber)​

The classification fires automatically on the addition that crosses the 125% threshold. The unit's compliance panel shows an amber banner with:

  • Calendar year :year — the year the classification covers.
  • Loss percentage — the calendar-year sum divided by full charge.
  • Threshold — 125%.
  • Classification date — when the threshold was crossed.
  • Report due date — March 1 of the following year per §84.106(m).

The unit gets a record on the audit ledger (regulatory_chronic_leaker_records) at the moment of classification. The record is append-only.

2. EPA-reported (blue badge)​

When you've filed the §84.106(m)(4) packet via the EPA Agency reporting platform, you mark the classification as EPA-reported in TuffOps. This:

  • Records the filing date and the user who marked it.
  • Stamps the classification as on-time or late based on whether the mark date is before or after the report due date.
  • Flips the banner to a blue "EPA-reported on time YYYY-MM-DD" badge.

The mark is the audit anchor. It says "we knew, we filed, we documented."

3. Overdue (red)​

If the report due date passes without an EPA-reported mark, the banner flips to red and the badge says "§84.106(m) report overdue." This is the §84.106(j) breach state — visible to anyone who opens the unit.

The breach state is the system telling you to file urgently. Marking after the fact still works — it stamps the classification as EPA-reported (late), which is better than leaving it red.

Withdrawal​

A supervisor with compliance.override_chronic_leaker_classification can withdraw a classification. The withdrawal:

  • Requires a written reason of at least 20 characters.
  • Voids the classification for that year only.
  • Preserves prior-year classifications on the ledger.
  • Records the withdrawing supervisor and the reason.

The withdrawal is for data corrections, not for relief. If the underlying additions were real, withdrawal is wrong — file the (m)(4) packet. Withdrawal is right when, for example, a back-dated catalogue change retroactively flipped events from removal to top_off and inflated the loss math.

Why the classification is automatic​

Manual classification would either be too lenient (the supervisor decides whether to record) or too strict (every unit with high losses gets classified, regardless of context). The §84.106(j) rule is mechanical: 125%, 15 lb, Subpart C. TuffOps applies the rule on every charge event and stamps the result, leaving the supervisor to act on the regulatory state rather than determine it.

The override path is then narrowly scoped: a supervisor can withdraw a classification (with reason), but cannot prevent one from firing in the first place.

Annual reset​

The classification is per-calendar-year. On January 1, the math restarts for every unit. A unit classified in 2026 stays classified for 2026 forever (it's on the ledger), but its 2027 math starts at zero.

A unit can be classified for two years in a row — that's two records on the ledger. Each year's record is filed separately.