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Manage a Chronic-Leaker Classification

A chronic-leaker classification fires automatically when a unit's calendar-year top-off losses cross 125% of its full charge (with full charge ≥ 15 lb and Subpart C applying). Once classified, the unit owes the EPA a §84.106(m)(4) report by March 1 of the following year.

This guide covers the three actions you take from the unit's compliance panel after classification: downloading the report packet, marking the filing as complete, and — if the data was wrong — withdrawing the classification.

Before you start​

  • The unit is already classified. The classification is automatic; you don't trigger it manually.
  • You have compliance.view to see the banner.
  • You have compliance.manage_chronic_leaker_record to mark a classification as EPA-reported.
  • You have compliance.override_chronic_leaker_classification to withdraw a classification.

Steps​

  1. Open the unit's compliance panel

    Select Units in the top navigation bar, then select the Edit action for the affected unit. The compliance panel sits below the standard fields. The chronic-leaker banner is amber while the report deadline is in the future, and red after the deadline passes without filing.

  2. Read the classification basis

    The banner shows:

    • Calendar year :year — the year the classification covers.
    • Calendar-year loss X% of full charge (threshold 125%). Classified YYYY-MM-DD. — the exact ratio that tripped the rule.
    • The report due date and current filing status.

  3. Download the EPA packet

    Select Download (m)(4) packet. TuffOps generates a frozen JSON snapshot of the classification: the unit details, the YTD additions, the threshold math, and the cert / equipment context for each event in the year.

  4. File with the EPA

    Upload the packet to the EPA Agency reporting platform yourself. TuffOps does not transmit on your behalf. Keep a copy for your records.

  5. Mark the classification as EPA-reported

    Return to the unit's compliance panel and select the green Mark as EPA-reported button. Confirm the prompt. The banner flips to a blue badge: EPA-reported on time YYYY-MM-DD (or EPA-reported (late) YYYY-MM-DD if you mark after the deadline).

What happens next​

  • The packet you downloaded is frozen at the moment of download. Future charge events on the unit do not change it. Re-download to refresh if the year is still open.
  • Marking as reported records who marked, when, and the on-time / late determination. The audit ledger keeps both the classification record and the filing event.
  • A new chronic-leaker classification can fire next calendar year if losses cross 125% again. Each year is a separate record on the audit ledger.
  • The unit's leak-rate calc continues to run normally. Chronic classification does not block service — it documents the regulatory state.

Common situations​

SituationWhat to do
The classification fired but you've already filed for the yearDownload the packet, compare against your filed copy, then mark as EPA-reported with today's date.
The classification fired on data you know is wrong (back-dated correction, voided events posted late)Use the Supervisor: withdraw chronic classification disclosure at the bottom of the banner. Type a reason of at least 20 characters. The classification is voided for that year only — prior years on the ledger stay intact.
The deadline passed and the banner went redFile the late report immediately, then mark as EPA-reported. The badge captures that the filing was late. The classification record itself remains.
You need the same year's packet again next monthDownload again any time. The packet is regenerated from the audit ledger, so it always reflects what's on the unit at download time.
A unit is classified for two years in a rowEach year is a separate record. The banner shows the most recent. To download or mark prior years, scroll to the chronic-leaker history section under the banner.

Troubleshooting​

The Mark as EPA-reported button is missing.

Either the year is already marked as reported, or you don't have compliance.manage_chronic_leaker_record. The banner shows a blue badge once the classification is marked, and the button hides automatically.

The Withdraw disclosure isn't visible.

You don't have compliance.override_chronic_leaker_classification. The withdraw flow is intentionally restricted because withdrawing voids a regulatory record. Ask a supervisor with the permission.

Withdraw fails with a reason-too-short error.

The withdrawal reason must be at least the minimum configured length (the textarea shows the exact minimum in its label). The reason becomes part of the audit ledger, so it must be substantive.

A unit I expected to be classified hasn't been.

The classification fires only when calendar-year top-off additions cross 125% of full charge and full charge is at least 15 lb and Subpart C applies. If any one fails, no classification fires. Check the unit's leak-rate calc and the refrigerant catalog row to see which condition isn't met.

Withdrawal removed the classification but the banner still shows.

Refresh the page. The banner reads from the audit ledger, which is updated synchronously, but the page-level cache may be stale. If it persists after a hard reload, the chronic-classification setting may be re-evaluating; check Settings → Compliance for the chronic-classification toggle.