Policy

All University of Chicago and University of Chicago Medicine's departments involved in the purchasing and handling of refrigerants for use in an appliance (refrigerant-containing equipment) shall adhere to the requirements stated in this policy.

Under the United States Environmental Protection Agency (“US EPA”) Clean Air Act, Section 608, EPA has established regulations in 40 CFR Part 82, Subpart F.  The applicable regulations are also summarized in the campus’s Title V Clean Air Act Permit.

Equipment containing refrigerant shall be installed and maintained per the City of Chicago Municipal Code, Chapter 18 Section 28.

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Authority and Responsibility

Environmental Health and Safety (“EHS”) shall be responsible for the following:

  • Coordinating with the third-party environmental consultant (currently Mostardi Platt) who manages the University of Chicago Title V Compliance Program and submits reports and notifications to the US EPA and Illinois EPA (“IEPA”), as required by 40 CFR Part 82, Subpart F;
  • Assisting Facilities Services and Physical Plant to select an environmental consultant to manage the University of Chicago Title V compliance program; and
  • Providing guidance about compliance with this Policy to Facilities Services and Physical Plant.
  • Reviewing regulations and updating the Refrigerant Management Program Policy as appropriate. 

Facilities Services and Physical Plant Supervisors (“Engineering Shop Supervisors”) shall be responsible for the following:

  • Maintaining an inventory of all refrigerant-containing equipment/appliances;
  • Submitting a Refrigerant Registration or Modification Form to EHS for any new or modified equipment;
  • Verifying Refrigerant Management Books are being maintained and updated;
  • Ensuring the proper use of all refrigerants by certified technicians;
  • Ensuring reclamation equipment adheres with the regulations and is properly maintained;
  • Ensuring any work completed by a third-party vendor is included in the on-going leak rate calculations;
  • Notifying Mostardi Platt and EHS if a leak rate exceeds regulatory thresholds; 
  • Notifying Mostardi Platt and EHS if a major modification is planned or made to an appliance - any maintenance, service, or repair that involves the removal of any or all of the following appliance components;  
    • Compressor 
    • Condenser 
    • Evaporator 
    • Auxiliary Heat Exchange Coil 
    • Or any maintenance, service, or repair that involves uncovering an opening of more than four (4) square inches of “flow area” for more than 15 minutes. 
  • Procuring refrigerant as needed; and
  • Ensuring at least two building engineers maintain a Type IV Universal Technician Certification.

Certified Technicians at Facilities Services and Physical Plants Engineers shall be responsible for the following: 

  • Creating refrigerant service and usage records in the shop’s Refrigerant Management Book;
  • Conducting leak rate calculations as applicable;
  • Informing their supervisor when units are replaced, renovated or the refrigerant type changes;
  • Informing their Supervisor if a leak repair may exceed the 30-day limit or the deadline specified in the Retrofit or Retirement Plan for corrective action;
  • Maintaining a Type IV Universal Technician Certification; and
  • Following all policies and procedures for the safe use and handling of refrigerants.

Project Managers shall be responsible for the following: 

  • Submitting a Refrigerant Registration or Modification Form to EHS for any new or modified equipment;
  • Ensuring only contractors who are certified technicians will work on appliances; and
  • Ensuring contractors provide all records required by this policy to EHS.

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Prohibited Activities

All University of Chicago employees are prohibited from:

  • Working on appliances unless they are Type IV Universal Certified Technicians (“certified technicians”);
  • Knowingly venting refrigerants into the atmosphere while servicing, repairing, or disposing of appliances, with the exception of refrigerants according to 40 CFR 82.154(a)(1);
  • Servicing motor vehicles and motor vehicle-like air conditioners;
  • Selling used or unused refrigerant; and
  • Using refrigerant recovery and/or recycling equipment manufactured or imported prior to 1994.

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Purchasing of Refrigerants

Only University of Chicago employees who are certified technicians are authorized to purchase refrigerants that are Class I or Class II Controlled Substances (see Refrigerant Use and Handling Purchasing Guidance section in this policy for further information);

The certified technician’s certificate number will be required to purchase refrigerants, and refrigerants must be purchased from refrigerant vendors approved by Facilities Services Procurement.

Note: Physical Plant engineers must follow their facility-specific procurement practices to properly order and track refrigerant usage.

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Refrigerant Inventory Storage

Refrigerants ordered by Facilities Services certified technicians shall be delivered to Central Inventory located at the Facilities Services Building. 

  • Refrigerant cylinders shall be stored in a secure location and shall not be stored on below-grade floors.Oxygen monitors shall be installed where leaks from appliances or containers of refrigerant can cause an oxygen-deficient atmosphere.

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Recordkeeping

Appliance Inventory

EHS maintains an inventory of appliances with a full charge of 50 pounds or more of refrigerant.  For each appliance, the inventory identifies the following information:

  • Location of unit (building and room number);
  • Asset number of unit (Maximo or Client Service Management system);
  • Refrigerant type (e.g. R-22, R-134a, etc.);
  • Full charge of the appliance and the method for how it was determined (see Refrigerant Use and Handling Recordkeeping Guidance for further information);
  • Range for the full charge, midpoint, and how the range was determined if using an established range determine the full charge;
  • Any revisions of the full charge, how they were determined, and the dates of revisions; and
  • Use (comfort cooling, process, industrial, other).

Refrigerant Management Book

Engineering shops shall maintain a Refrigerant Management Book which contains the following records for at least 3 years:

  • Logs for disposal of appliances with a full charge of 5 pounds or more but less than 50 pounds;
  • Automatic leak detection systems records;
  • Contractor service records (see Refrigerant Use and Handling Recordkeeping Guidance for further details);
  • Certifications for refrigerant recovery and/or recycling equipment; and
  • Records associated with the maintenance of appliances with a full charge of 50 pounds or more of refrigerants which are Class I or Class II controlled substances (see following section).

Records of Appliances with 50 lbs or more of Refrigerant

The engineering shop’s Refrigerant Management Book must also maintain the following records for appliances with a full charge of 50 pounds or more of refrigerants that are Class I or Class II controlled substances:

  • Leak inspections records;
  • Leak repair verification testing records;
  • Retrofit or retirement plans submitted to the EPA;
  • Retrofit and/or extension requests submitted to the EPA;
  • Records associated with appliances that were mothballed to suspend leak repair deadlines;
  • Copies of the submitted reports and any responses from EPA; and
  • Documentation for recovery of Class I or Class II controlled substances from disposed appliances.

See Refrigerant Use and Handling Recordkeeping Guidance for further details.

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Disposal of Appliances

Refrigerant must be recovered by a certified technician prior to disposal of all appliances.  Please see the Small Appliance Disposal Guidance for further information on the procedure for disposing refrigerators, freezers, or other small appliances containing less than 5 pounds of refrigerant.

Disposal of Small Appliances

A small appliance is any appliance that is fully manufactured, charged, and hermetically sealed in a factory with five (5) pounds or less of refrigerant. Please see the Small Appliance Disposal Guidance for examples of small appliances.

The certified technician will recover the refrigerant to the following conditions prior to disposal of a small appliance:

  • 90% refrigerant recovery if the compressor in the appliance is functioning;
  • 80% refrigerant recovery if the compressor is the appliance is not functioning; or
  • Certified Technicians may also evacuate the small appliance to four inches of mercury vacuum.

After completing the refrigerant recovery, the certified technician shall complete and affix Small Appliance Disposal Record to the appliance.

Refrigerant recovered from small appliances can be either:

  • Reused in another appliance using the same refrigerant, provided the refrigerant is in good condition; or
  • Disposed as hazardous waste in accordance with the Hazardous Waste Disposal Procedures policy.  

Appliances with more than 5lbs and less than 50 lbs of Refrigerant Disposal 

Prior to disposal of appliances with a full charge of more than 5 pounds and less than 50 pounds of refrigerant, a certified technician must recover refrigerants to the levels specified in 40 CFR 82.156 Table 1.

For each disposed appliance with a full charge of more than 5 pounds but less 50 pounds, the following information must be documented in the Refrigerant Management Book:

  • The company name for the certified technician performing the refrigerant recovery;
  • Location of the appliance;
  • Date of refrigerant recovery;
  • Type and amount of refrigerant recovered from the appliance
  • Disposition of the recovered refrigerant (e.g. recycled or reused, disposed, etc.).

Appliances with 50 lbs or more of Refrigerant Disposal

Disposal of appliances with a full charge of 50 pounds or more of refrigerant will be performed by refrigerant contractors. Prior to disposal of appliances with a full charge of 50 pounds or more of refrigerant, a certified technician must recover refrigerants to the levels specified in 40 CFR 82.156 Table 1.

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Technician Certification

The Clean Air Act requires that technicians responsible for the purchasing, maintenance, service, repair, or disposal of refrigerant equipment be certified. The University requires that at least two building engineers must receive and maintain an EPA Type IV Universal Certification. Hard copies of certifications from an EPA-approved certifying organization shall be maintained and be made readily available for inspection.  

According to Section 608 of the Clean Air Act, a technician is an individual who performs any of the following:  

  • Attaching and detaching hoses and gauges to and from an appliance to measure pressure within the appliance.  
  • Adding refrigerant to or removing refrigerant from an appliance.  
  • Any other activity that violates the integrity of a motor vehicle air conditioner (MVAC)-like appliance or small appliance (other than disposal).  

Apprentices (as defined here) may perform maintenance, service, repair, or recovery of a refrigerant as long as they are doing so under close supervision of a certified technician.

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Refrigerant Recovery and/or Recycling Equipment

Labeling

Refrigerant recovery and/or recycling equipment used during the maintenance, service, repair, or disposal of appliances must contain the following label:

[THIS EQUIPMENT HAS BEEN CERTIFIED BY [APPROVED EQUIPMENT TESTING ORGANIZATION] TO MEET EPA’s MINIMUM REQUIREMENTS FOR RECYCLING OR RECOVERY EQUIPMENT INTENDED FOR USE WITH [APPROPRIATE CATEGORY OF APPLIANCE]

The label shall also display the date of manufacture and the equipment’s serial number (if applicable). The label must be placed in a readily visible or accessible location and be made of a material expected to last the lifetime of the equipment. 

Certified technicians must operate and maintain the refrigerant recovery and/or recycling equipment in accordance with the equipment manufacturer’s recommendations.

Equipment Certification 

When working on appliances manufactured before November 15th, 1993, Certified Technicians shall only use recovery equipment that is certified according to EPA standards. To ensure recovery equipment is certified, all recovery equipment shall have a label that states:  

“This equipment has been certified by AHRI/UL to meet EPA's minimum requirements for recycling and/or recovery equipment intended for use with [appropriate category of appliance].” 

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Maintenance and Leak Repairs

Appliances with 50 lbs or more of Refrigerant

Appliances with a full charge of 50 pounds or more of refrigerant will be maintained by certified technicians from a refrigerant contractor. Certified Technicians must evacuate air-conditioning and refrigeration equipment to established vacuum levels when opening the equipment for maintenance, service, repair, or disposal. 

For appliances with a full charge of 50 pounds or more of refrigerants that are Class I or Class II controlled substances, refrigerant contractors must:

  • Provide service records each time an appliance is maintained, serviced, repaired, or disposed of; 
  • Provide leak calculations to the engineering shop whenever they add refrigerant to an appliance; 
  • Immediately notify engineering shop supervisors if the leak rate exceeds the threshold; 
  • Conduct leak investigations; 
  • Repair leaks and conduct follow-up verification testing; 
  • Notify engineering shop supervisors if leaks cannot be repaired within 30 days of discovery or by the extended deadline; and 
  • Notify engineering shop supervisors if appliance retrofit or retirement plans cannot be completed by the deadline specified to the EPA. 

If the appliance is leaking at a rate at which the loss of refrigerant will exceed 35% of the total charge during a 12-month period, repairs must bring the annual leak rate to below 35%. 

The engineering shop supervisor must immediately notify EHS and Mostardi Platt when: 

  • An appliance is found to have a leak rate greater than 10%; 
  • Contractor starts and completes leak investigations; 
  • Leak is repaired  
  • Contractor determines the leak cannot be repaired within 30 days of initial discovery; 
  • Appliance retrofit or retirement plans have been completed; 
  • Contractor determines the retrofit or retirement plan cannot be completed by the deadline specified to the EPA; 
  • The results of the leak repair verification test and leak inspection results are available; or 
  • The engineering shop decides to “mothball” the appliance. 

Mostardi Platt will submit the following to the EPA:

  • Request for an extension of time to repair the leak if it cannot be completed within 30 days of discovery;
  • Retrofit or retirement plans if the leak will be addressed by retrofitting or retiring the appliance;
  • Request for extensions if repairs cannot be completed by the deadline specified in the retrofit or retirement plan;
  • Request for relief from the retrofit or retirement plan; or
  • Reports of chronically leaking appliances that leak 125% or more of the full charge in a calendar year.

Reviewed: February 2023

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