Refrigerant Use and Handling

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 should 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.

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

  • Maintaining an inventory of all refrigerant-containing equipment/appliances;
  • 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; 
  • Procuring refrigerant as needed; 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 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 are responsible for:

  • Notifying EHS about projects which may involve the removal, modification, and/or installation of appliances;
  • 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 certified Universal Certified Technicians (“certified technicians”);
  • Knowingly venting refrigerants into the atmosphere while servicing, repairing, or disposing of appliances, with the exception of those refrigerants specifically exempted by 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 which 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 purchases 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 and 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 in below-grade floors; and
  • 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 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 for Appliances with Full Charge of 50 pounds 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 which 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 which 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
  • Evacuation of the appliance to a pressure of 4 inches Hg 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.  

Disposal of Appliances with Full Charge of More Than 5 and Less Than 50 Pounds of Refrigerant

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.).

Disposal of Appliance with Full Charge of 50 Pounds or More of Refrigerant

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

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 US EPA Type IV Universal Technician certification. Certified technicians shall keep proof of certification readily available for inspection.

Apprentices can perform maintenance, service, repair or refrigerant recovery prior to disposal of appliances provided they are closely and continually supervised by a certified technician.

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Refrigerant Recovery and/or Recycling Equipment

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]

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

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Appliance Maintenance and Leak Repairs for Appliances with Full Charge 50 pounds 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. For appliances with a full charge of 50 pounds or more of refrigerants which are Class I or Class II controlled substances, refrigerant contractors must:

  • Provide service records each time an appliance is maintained, serviced, repaired, or disposed;
  • Provide leak calculations to the engineering shop whenever they add refrigerant to appliance;
  • Immediately notify engineering shop supervisors if leak rate exceeds 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.

For appliances with a full charge of 50 pounds or more of refrigerants which are Class I or Class II controlled substances, 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 repairs the leak or determines the leak cannot be repaired with 30 days of initial discovery;
  • Contractor starts and completes leak investigations;
  • 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 leak repair verification test and leak inspection results are available; and
  • The engineering shop decides to “mothballed” the appliance.

Mostardi Platt will submit the following to the EPA:

  • Request for 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 which leak 125% or more of the full charge in a calendar year.

Reviewed: March 2020

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