All University of Chicago and University of Chicago Medicine's departments involved in the purchasing and handling of refrigerants for use in an appliance (equipment) shall adhere to the requirements stated in this policy.
Under the United States Environmental Protection Agency (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 should be installed and maintained per the City of Chicago Municipal Code, Chapter 18 Section 28.
Authority and Responsibility
Facilities Services and Physical Plant Supervisors shall be responsible for the following:
- Maintaining an inventory of all refrigerant-containing equipment/appliances and alerting Environmental Health and Safety;
- Maintaining current records in the Refrigerant Management Book;
- 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;
- Informing Mostardi Platt and Environmental Health and Safety if a leak exceeds regulatory thresholds;
- Procuring refrigerant as needed;
- Maintaining Type IV Universal Technician Certifications; and
- Ensuring at least two building engineers maintain a Type IV Universal Technician Certification.
Facilities Services Engineers and Physical Plants Engineers listed as Certified Technicians 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 may exceed the 30 day limit for corrective action;
- Maintaining a Type IV Universal Technician Certification; and
- Following all policies and procedures for the safe use and handling of refrigerants.
Facilities Services Capital Program Development and University of Chicago Medicine's Construction and Design groups shall be responsible for the following:
- Updating Mostardi Platt and Environmental Health and Safety when new refrigerant-containing equipment is being removed or installed as part of a renovation and/or demolition;
- Evaluating acceptable non-ozone depleting refrigerants when feasible;
- Ensuring that any units containing refrigerants that may be impacted by construction/renovation are purged, moved, and recharged in line with the applicable regulations; and
- Ensuring that any third-party vendors are certified technicians and all documentation is submitted to the engineering shop which manages the zone.
Environmental Health and Safety shall be responsible for the following:
- Coordinating a third-party vendor who will manage the Title V Compliance and submit deviation reports to Federal and State regulators.
The procurement of all refrigerants shall be the responsibility of a Type IV Universal Technician Certification. Purchases of refrigerants shall be made with the use of the refrigerant technician's certificate number.
See Procurment for a list of approved refrigerant vendors.
Inventory and Storage
All orders of refrigerant shall be delivered to Central Inventory located at the Facilities Services building. Refrigerant Managers shall be notified when their shipment arrives. Refrigerant shall not be released by Central Inventory until a refrigerant tracking sheet has been given to them indicating the contents of the bottle has been used.
Install proper ventilation and if necessary oxygen monitors in areas where large quantities of refrigerant will be stored.
Physical Plant engineers must follow their facility specific procurement practices to properly order and track refrigerant usage.
The equipment inventory records must contain:
- Location of unit (building and room number)
- Asset number of unit (maximo or client service management system)
- Refrigerant type (R-22, R-134a)
- Charge (50 pounds)
- Use (Comfort cooling, process, industrial, other)
All shops shall maintain a Refrigerant Management Book. It is the responsibility of the supervisor to ensure the refrigerant books are being maintained properly by certified technicians. The work conducted by outside contractors must be captured in the refrigerant management book. Refrigerant cylinders shall be weighed upon receiving a new shipment, prior to and after each use. All usage records shall be maintained in the Refrigerant Management Book. Each refrigerant cylinder shall have a tracking sheet that stays with the cylinder. After the completion of the refrigerant from the cylinder, the tracking sheet shall be submitted to the supervisor for inclusion in the Refrigerant Management Book.
- Document monthly total quantity and type of refrigerant recycled
At a minimum, service records must contain:
- Date of service
- Unique ID Number for equipment being serviced
- Name of technician
- Techician's certification number
- Quantity and type of refrigerant added, recycled, or removed
- Description of services provided
- Leak repair procedure
- Leak testing method and results
- Equipment certification used for reclamation
Units with less than 5 pounds or refrigerant
A small appliance is any of the following products that are fully manufactured, charged, and hermetically sealed in a factory with five pounds or less of refrigerant:
- Refrigerators and freezers designed for home use;
- Room air conditioners (including window air conditioners and packaged terminal air conditioners);
- Packaged terminal heat pumps;
- Ender-the-counter ice makers;
- Vending machines; and
- Drinking water coolers.
When disposed of, a certified technician must remove the refrigerant for recovery or recycling. Other than refrigerant reclamation no recordkeeping or reporting required.
- 80% of the refrigerant must be recovered if the unit is not functioning or was manufactured prior to 1993.
- 90% of the refrigerant must be recovered if the unit is functioning or was manufactured after 1993.
- Refrigerants shall be recovered from all window air conditioning units and refrigerators prior to their disposal. All refrigerant recovered from window air conditioning units and refrigerators shall be tested utilizing an acid test kit prior to recovery of the refrigerant. Refrigerant that does not pass the acid test shall be filtered using filter dryers to remove the acid and other impurities. Refrigerant shall be repeatedly filtered until it passes the acid test. Non-contaminated refrigerant shall be stored in a recovery cylinder until that cylinder is full.
- Refrigerant that does not pass the acid test shall be disposed of as a contaminated refrigerant in an appropriate labeled container. Non-contaminated refrigerant shall be stored in a recovery cylinder until that cylinder is full.
If small appliances are functional; not leaking; and; were manufactured after 1983, then the ownership maybe transferred without removing the refrigrerant. Upon transfer, the equipment should be removed from our inventory. Per the regulations, the final person in the disposal chain (such as a scrap metal recycler or landfill owner) is responsible for ensuring that refrigerant is recovered from equipment before its final disposal. If the final person in the disposal chain accepts an appliance that no longer holds a refrigerant charge, that person is responsible for maintaining a signed statement from the person who dropped off the appliance. The signed statement must include the name and address of the person who recovered the refrigerant, and the date that the refrigerant was recovered. Alternatively, this could be a copy of a contract stating that the refrigerant will be removed prior to delivery.
Units with 5-50 Pounds of refrigerant
When disposed of, a certified technician must remove the refrigerant for recovery or recycling
- Keep detailed records (for 3 years) of recycling and disposal; and
- Recover refrigerant to 10” of mercury for units manufactured after 1993.
Units with Greater than 50 Pounds of Refrigerant
The recovery of refrigerant from systems that have greater than fifty pounds of refrigerant shall be done by a properly certified contractor.
Recovery from a Disabled System
When disabling a system, all refrigerant shall be recovered by a certified technician prior to disposal.
Recovery from Equipment Burnout
All refrigerant recovered from equipment that is burnout shall be considered contaminated and shall be filtered using filter dryers until it passes the acid test and is no longer contaminated. Contaminated refrigerant shall not be mixed with non-contaminated refrigerant.
Engineers who perform maintenance, service, repair or disposal of systems or appliances that could be reasonably expected to release refrigerants into the atmosphere shall maintain an USEPA Type IV Universal Technician certification. Technicians shall keep proof of certification readily available for inspection.
Supervisors shall maintain proper equipment necessary to perform tasks related to the recovery and use of refrigerants. Such equipment shall include: hoses with shut off valves, electronic scales, acid test kits, reclaiming machine, Department of Transportation (DOT) tanks for each refrigerant used and a tank designated for contaminated refrigerant. All reclaiming machines shall be purged with nitrogen before each use to prevent the contamination of refrigerants. Utilizing reclamation equipment manufactured prior to 1993 is prohibited per Federal regulations.
All systems shall have color-coded tags to match the cylinder of refrigerant that is utilized in that system. Technicians shall ensure that the proper refrigerant is being used in each system. There shall be no blending of refrigerants for equipment.
The EPA does not specify any particular leak detection methods. Therefore, as long as sound professional judgment is employed by the certified technician, the method used is deemed acceptable.
- The leak rate should be calculated each time refrigerant is added to any system with a full charge of 50 pounds or more, or any time your professional judgment indicates that the system may be leaking at a rate that would trigger repair requirements;
- Best practice would be to check each unit on annual-basis, at minimum;
- Any unit with greater then 500 pounds of refrigerant must be checked quarterly or an automatic leak detection system has to be installed;
- There is no requirement to check the leak rate on a routine basis for units with <500 pounds of refrigerant. However, once a leak is found which exceeds the leak rate threshold values then periodic leak inspections would be required until leak is below limits; and
- The allowable leak rate varies based on the refrigerant and unit’s purpose (10% of total charge for comfort cooling and 15% of total charge for commercial or industrial refrigeration processes).
If a leak has exceeded the regulatory limits, then you must conduct leak inspections per the frequency outlined below.
- Comfort cooling (>50 pounds) - Once per calendary year until the owner/operator can demonstrate through the leak rate calculations that the leak rate has not exceeded 10% for one year.
- Commercial or Industrial Process Refrigeration (50 to 500 pounds) - Once per calendar year until the owner/operator can demonstrate through the leak rate calculations that the leak rate has not exceeded 15% for one year.
- Commercial or Industrial Process Refrigeration (> 500 pounds) - Once every three months until the owner/operator can demonstrate through leak rate calculations that the leak rate has not exceeded 15% for four quarters in a row.
Once you've successfully kept leak below the limits for the specified period of time, then you can discontinue the scheduled leak testing and go back to calculating only when you add refrigerant or when your professional judgement determines a leak may be present.
If the leak rate is greater than allowed, leak must be repaired within 30 days, followed by verification tests and inspections.
If a unit is not repaired within 30 days or it leaks more than 125% in a year (i.e., chronic leaker) it must be reported to EPA. If a unit continues to exceed the allowable leak rate, a retrofit or retirement plan must be written and implemented within one year.
A copy of the retirement plan must be kept on site and the original plan must be made available to the EPA as requested. Activities under the plan must be completed within 12 months (from the date of the plan.)
Please contact Environmental Health and Safety if a leak needs to be reported to the EPA. Environmental Health and Safety will work with Mostradi Platt to create and submit a deviation report to both the State and Federal EPA.
For all appliances subject to the leak repair requirements (>50 pounds), the timelines may be suspended if the appliance has undergone "system mothballing." System mothballing means the intentional shutting down of a refrigeration appliance undertaken for an extended period of time where the refrigerant has been evacuated from the appliance or the affected isolated section of the appliance to at least atmospheric pressure. However, the timelines resume as soon as the system is brought back on-line.
Prohibition on Venting
Individuals are prohibited from knowingly venting refrigerants into the atmosphere while servicing, repairing, or disposing of appliances.
Reviewed: December 2018