Refrigerant Use Program

Purpose

  • To establish guidelines for the appropriate health and safety requirements that must be followed by Mount Holyoke College employees when working with refrigerant.
  • To ensure compliance with the Refrigerant Recycling Rule, Section 608 of the Federal Clean Air Act.
  • To promote awareness of the potential hazards of this type of work.
  • To prevent injury and protect the environment.

Definitions

  • ARI: Air-Conditioning and Refrigeration Institute.
  • Appliance: A device that contains and uses a refrigerant, and which is for household or commercial purposes, including any air conditioner, refrigerator, chiller, or freezer.
  • Chlorofluorocarbons (CFC): Chemical compounds with both chlorine and fluorine that are known to have detrimental effects on the environment because they deplete the ozone layer and contribute to global warming.
  • EPA: Environmental Protection Agency.
  • Hydrochlorofluorocarbons (HCFC): Chemical compounds in which not all of the hydrogen has been replaced by chlorine and fluorine. These compounds are used primarily as CFC replacement because their ozone-depleting effects are not as severe.
  • Reclaim: Reprocess refrigerant to all of the specifications in Appendix A of 40 CFR part 82, subpart F, (based on ARI Standard 700-1995) and conduct chemical analysis to ensure that the standard of purity criteria is met.
  • Recover: Remove refrigerant in any condition from an appliance and store it in an external container without testing or processing it in any way.
  • Recycle: Extract refrigerant from an appliance and clean refrigerant for reuse without meeting all of the requirements for reclamation.
  • Refrigerant: Any substance consisting in part or whole of a Class I or Class II ozone-depleting substance that is used for heat transfer purposes and provides a cooling effect.
  • Technician: Any person that performs maintenance, service, disposal or repair, that could be reasonably expected to release refrigerants from appliances into the atmosphere.
  • UL: Underwriters Laboratories, Inc. 

Responsible Departments

  • Facilities Management HVAC/Steamfitters
  • Dining Services Food Service Technician

Appliances (Containing 50 Pounds or more of Refrigerant)

  • Art Building:  Two air conditioning units containing approximately 150 pounds of refrigerant, each.
  • Carr Laboratory: One air conditioning unit on the roof containing approximately 60 pounds of refrigerant.
  • Clapp Laboratory: One air conditioning unit in room 19 containing approximately 50 pounds of refrigerant.
  • Dining Services: One freezer and one refrigeration unit in the warehouse containing approximately 350 pounds of refrigerant, each.
  • Kendade:  Two chiller units in the basement mechanical room containing approximately 3000 pounds of refrigerant, each. Two air conditioning units in the lower level computer room containing approximately 60 pounds of refrigerant.
  • Skinner Hall:  One chiller unit in the basement containing approximately 340 pounds of refrigerant.
  • Williston Library: One chiller unit on the roof containing approximately 460 pounds of refrigerant.
  • Willits-Hallowell:  One chiller unit in the basement containing approximately 300 pounds of refrigerant.

Requirements and Procedures

  • Only Technicians that have been certified in accordance with 40 CFR, Part 82, Subpart F are authorized to service, maintain, and repair equipment or perform activities that could potentially release refrigerants into the atmosphere.
  • Venting, or knowingly releasing refrigerants into the atmosphere, is prohibited, with the exception of “de minimis” quantities released during good faith attempts during recovery, recycling or disposal.
  • Technicians must evacuate the refrigerant prior to servicing, disposing of, or otherwise opening the equipment. A minimum of 90 percent of the refrigerant must be recovered.
  • After evacuating an appliance and before keeping it outdoors, putting in the metal dumpster or otherwise discarding, the Technician must label the unit indicating that it has been evacuated of refrigerant, oil, and/or any other material required to render it safe for disposal.
  • Mount Holyoke College has a self-contained refrigerant recovery device that meets EPA, UL, and ARI requirements and has certified this equipment with EPA Region 1. This certification does not need to be updated, regardless of replacement of this recovery device.
  • Leaks in equipment containing charges of more than 50 pounds of refrigerant must be repaired within 30 days of discovery when the leak rate would release 15 percent or more of the charge in a one year period. Authorized HVAC/Steamfitter or Dining Services personnel are responsible for calculating leak rates, taking prompt corrective action and for following up 30 days after repair to ensure the unit is not leaking and is functioning properly.
  • Refrigerant vapors displace air and present an asphyxiation hazard in confined spaces; therefore, Mount Holyoke College employees are prohibited from working with refrigerant in confined spaces. Overexposure to refrigerant can cause dizziness and loss of concentration. The technician must ensure that there is adequate ventilation prior to working with refrigerant.
  • In accordance with Massachusetts General Law, Chapter 271, Section 46, the door or doors of refrigerators/containers originally used for refrigerative purposes will be removed before discarding or keeping outdoors.

Cylinders, Labels and Markings

  • New, unused refrigerant as well as recovered, used refrigerant will be stored in cylinders securely on a rack in the HVAC/Steamfitters storage area at Facilities Management. Additionally, the Food Service Technician stores refrigerant in a secure area at the shop at Dining Services.
  • When moving heavy cylinders, secure them on an appropriate wheeled device. Never roll a cylinder on its base or on its side. Technicians must ensure that cylinders are labeled, upright and securely strapped inside the vehicle prior to transporting. Never transport the cylinders in the passenger compartment of the vehicle.
  • Technicians must also consider temperatures that cylinders could be exposed to on vehicles or in storage areas. If cylinders will be exposed to temperatures above 120 degrees, they should not be filled more than 60 percent.
  • The HVAC/Steamfitter Supervisor and Food Service Technician are responsible for inspecting the cylinders and valves in their areas for leaks, signs of dents, damage and/or corrosion, and for ensuring that all cylinders are in good condition and properly labeled.
  • The maximum allowable gross (filled) weight should be clearly marked on the cylinder. Technicians must monitor pressure carefully during filling and ensure that the maximum service pressure is not exceeded.
  • Cylinders containing recovered refrigerant will be labeled as follows:
    WARNING: Contains CFC/HCFC which harms public health and environment by destroying ozone in the upper atmosphere.
  • All refrigerant cylinders must also be labeled with Department of Transportation (DOT) green “non-flammable gas” label.

 Storage and Disposal

  • Recovered refrigerant can be returned to the same system or other Mount Holyoke College-owned systems without restriction.
  • In the event that Mount Holyoke College was to release ownership of the refrigerant to another party, the refrigerant would have to be reclaimed.
  • Refrigerants that are recycled or reclaimed are not considered hazardous waste, as long as they are not mixed with used oils or other waste.
  • Refrigerant-contaminated oil is hazardous waste. This waste cannot be mixed with other waste oils. Refrigerant-contaminated waste oil will be collected in a properly labeled hazardous waste container and will be shipped off site for disposal, documented by a hazardous waste manifest.

Personal Protective Equipment (PPE)

  • Refrigerant mist can be an irritant and can cause frostbite when in liquid form.
  • Insulated or lined butyl gloves and splash goggles are required when the Technician determines that they are necessary.

Training

  • Technicians must be trained and pass an EPA-approved test given by an EPA-approved certifying organization to become certified under Section 608. These certification credentials do not expire.
  • Technicians must keep a copy of their proof of certification at their shop.  

Recordkeeping

  • Technicians must record all service performed on appliances that contain 50 or more pounds of refrigerant on the “Refrigerant Use Log.” This information must include the chiller unit/location, date of service, description of service, amount and type of refrigerant added and any other information relevant to the service performed.
  • Technicians must also keep track of any refrigerant purchases and record the date, type and amount of refrigerant purchased and record this information on the “Refrigerant Use Log.”
  • Technicians must keep their completed “Refrigerant Use Logs” for a minimum of three years.
  • Technicians of outside contractors servicing appliances containing 50 pounds or more of refrigerant at Mount Holyoke must provide the College with an invoice detailing the date, amount of refrigerant added and the service performed. The College will keep these records with the Refrigerant Use Logs for at least three years.

Annual Program Review

  • This program will be reviewed on an annual basis by the HVAC/Steamfitters Supervisor and the Food Service Technician. The review will consist of:
    • A review of the Refrigerant Reycling Rule, Section 608 of the Federal Clean Air Act.
    • A review of the Refrigerant Use Log.
    • Evaluation of the refrigerant recovery device.
    • Evaluation of the cylinders used to store new and recovered refrigerant.
    • An evaluation of the appliances containing 50 pounds or more of refrigerant  and determination on whether additional appliances/locations should be added to the program, or if any existing appliances/locations should be removed from the program.

Goals for Reduction

  • In addition to the annual program review, the following items will be considered in the continuing efforts of Mount Holyoke College to reduce our impact on the environment:
    • Is it feasible to replace CFC/HCFC equipment with non-CFC/HCFC equipment or convert to non-CFC/HCFC alternatives?
    • When feasible, is new equipment purchased non-CFC/HCFC?
    • Are there additional steps we can take to protect the environment as well as the health of our employees and the Mount Holyoke College community?

EH&S 4/2010