Applicability
Owner/operator leak-repair duties attach to any appliance using a regulated substance with a full charge of 15 or more pounds. Coverage is established by charge, not assumed.
The most rigorous §84.106 refrigerant leak-repair record a multi-site operator can hold.
LeakPack Clear turns a contractor invoice into a documentation-complete Completeness Pack — the leak-rate math, the 30/20/10 threshold check, the 30-day repair clock, the chronic percentage, and the three-year record — computed in deterministic code and released by a human, with an EPA Section 608-credentialed reviewer on every threshold trip.
Every field tied to a verbatim source quoteLeak rates in deterministic code, dual-method checkedAnalyst signs every release; 608-credentialed reviewer on red3-year, appliance-indexed Portfolio Leak RegisterFirst pack in 72 hours
Why records fail
An addition you can't compute today is a record that never existed.
Since January 1, 2026, any walk-in, rack, or ice machine holding 15+ pounds of HFC refrigerant carries owner-side federal leak-repair duties under 40 CFR §84.106 — the leak-rate math after every addition, the 30-day repair clock, verification tests, three years of records, and the March 1 chronic-leaker report.
But the invoice that should feed that record says 'topped off walk-in, 2 jugs,' it lives in an AP inbox, and nobody at a 5-to-80-location operator has computed a leak rate all year. Leak rates need the quantity, the date, and the full charge at the time — none of it reconstructable later.
LeakPack Clear closes that gap with one deterministic standard applied to every service event, every appliance, every time.
15 lb
of HFC charge is all it takes to trigger the full §84.106 duty
The benchmark
Measured against the letter of 40 CFR §84.106 — provision by provision.
We do not summarize the rule and hope. Every pack is scored against a versioned rule pack tied to the exact text of the AIM Act leak-repair regulation. These are the provisions each pack is held to.
Leak-rate thresholds
The annualized leak rate is compared against the exact category threshold — 30% industrial process refrigeration, 20% commercial refrigeration, 10% comfort cooling and other. The category drives the trip.
The repair window
A leak over threshold must be repaired within 30 days — 120 where an industrial process shutdown is required — with the clock computed from the addition date, not the discovery date.
Chronic-leaker report
An appliance whose cumulative annual leak reaches 125% of full charge triggers a report to EPA by March 1 of the following year. The chronic percentage is tracked calendar-year, portfolio-wide.
Full-charge determination
Full charge is set by nameplate, manufacturer specification, calculation, or established range, and attested by the owner. No full charge on evidence caps the pack — never a guessed number.
TRU exclusion
The final rule published May 26, 2026 excludes road and intermodal container transport refrigeration units from the leak-repair regime. Stationary walk-ins and racks remain fully in scope.
How a pack is built
Invoice to release, with deterministic gates the AI cannot overrule.
AI extracts fields with verbatim source quotes. Deterministic, unit-tested code computes every leak rate, clock, and chronic figure. A human analyst signs every release; a 608-credentialed reviewer approves every red pack. That order is never reversed.
01
Intake: forward the invoice
Forward the contractor invoice, work order, or email exactly as it arrived. It gets a document ID and hash on arrival, the vendor resolves through the alias table, and the appliance matches against your registry — ambiguous matches go to a human, not a guess.
02
Extract with source quotes
AI pulls the §84.106-relevant fields — service date, refrigerant type, quantity added, technician, nature of service — each with a verbatim source quote and a confidence score. Anything below the bar routes to analyst triage.
03
Compute in deterministic code
Leak rate by your locked method (annualizing and rolling average, both computed for comparison), the 30/20/10 threshold check, the repair-clock start and deadline, and the calendar-year chronic percentage — versioned, unit-tested code. No figure comes from a language model.
04
Full-charge and hard-fail gates
The full-charge value is verified against one of the four permitted evidence paths. Hard fails — no full charge, no quantity, unknown category — block a green release rather than shipping a guess.
05
Human release gate
An analyst signs every green and yellow release. Threshold trips, method switches, dual-regime appliances, chronic watchlines, and first packs for a new customer are red — an EPA Section 608-credentialed reviewer must approve before anything ships.
06
Deliver, register, watch
The PDF pack and a CSV register row land the same day as release; the Monday digest tracks open clocks, chronic percentages, and — from December — the March 1 countdown across the whole portfolio.
The bar we hold
Rigor you can measure.
100%
Human-released
No pack auto-releases; a named analyst signs every one.
0
Model-computed figures
Every leak rate, clock, and chronic percentage is deterministic code.
72 hrs
First-pack SLA
Standard packs release within 3 business days of complete intake.
3 yrs
Register retained
Appliance-indexed and hash-stamped, mirroring the §84.106 records duty (plus a 6-month buffer).
Why LeakPack Clear
A factory, not a dashboard.
Documentation-complete, by design
The deliverable is completeness itself — every §84.106 field sourced or explicitly logged as a gap with a risk score. A SaaS seat logs what your team types; at 5-80 locations, nobody types.
Deterministic and dual-method
Every leak rate is computed in versioned code — annualizing and rolling average both, with disagreements over 2 percentage points flagged. The record renders the calculation; it does not describe it.
In its lane, on purpose
LeakPack Clear provides documentation support only. It performs no repairs, sells or handles no refrigerant, is not affiliated with the EPA, and never signs as the customer's regulatory representative — the owner/operator stays the duty holder.
Engagement
Per pack, per appliance. Never hourly, never a fine-avoidance contingency.
Outcome-based pricing anchored to one hour of a facilities manager's time and the cost of an empty binder at diligence — not to any regulatory outcome.
- A free AIM Exposure Diagnostic — upload an appliance list or 1-3 recent invoices and get a human-reviewed Gap Score across five axes within 24 hours.
- Standard Completeness Packs, complexity-tiered: Green $149, Yellow $249, Red $399 (Red includes 608-credentialed review).
- Portfolio Register Retainer: $12-$28 per appliance per month (minimum $791/mo), with weekly clock-and-chronic digests and 3-year retention.
- March 1 Chronic Pack, only if triggered: $791-$2,500 per reporting entity per year — you review, approve, and submit to EPA as the duty holder.
FAQ
Questions, answered precisely.
Doesn't our HVAC contractor handle the EPA stuff?
The §84.106 duties sit on the owner or operator of the appliance. Your technician does the physical work and keeps their own service records, but the leak-rate calculation after every addition, the repair-clock record, the verification evidence, and the three-year file are owner-side records — and most contractor invoices don't even contain the fields the math needs.
Are we going to be defending an AI-drafted federal record?
No number in a pack comes from a language model. AI extracts fields with verbatim source quotes and drafts narrative from structured input only; leak rates, clocks, and chronic percentages come from versioned deterministic code; a named human signs every release. If a source isn't attached, the field ships as an explicit gap.
Do you sign as our regulatory representative or file with EPA?
No. You remain the owner/operator of record and the duty holder under §84.106. Our analyst signs the release and the 608-credentialed reviewer attests to calculation-method application on red packs; you attest full-charge determinations, and anything sent to EPA — including March 1 chronic-leaker reports — is reviewed, approved, and submitted by you.
What if the contractor won't provide the missing fields?
We chase them with two courteous, templated requests five business days apart. If the vendor is still silent after 10 business days, the pack ships at the quoted tier with an explicit gap register and a risk score instead of invented data — we never downgrade to hourly chase billing.
How are you priced?
Per pack and per appliance, on published tiers — never hourly, and never a contingency on avoided penalties, which is a framing we prohibit here.
Find out whether a 30-day federal clock just started.
Forward one refrigerant invoice for your first Completeness Pack in 72 hours, or run the free AIM Exposure Diagnostic for a human-reviewed Gap Score across the five things an inspector asks for.
Documentation-support service · not legal advice, not an EPA filing · the owner/operator remains the duty holder.
[PLACEHOLDER] Pilot pack turnaround against the 30/120-day AIM Act repair clock — the real measured completion rate appears here once the first pilot facilities run a full leak-repair cycle. No number is claimed before it exists.
[PLACEHOLDER] First facility reference — added only with a named pilot client's written permission. LeakPack Clear never invents a testimonial or a facility logo.
[PLACEHOLDER] Total leak-repair packs completed to date — a live, auditable count once real verification-test packs have shipped; blank until then.