Refrigerant Use Program

Purpose

  • To establish guidelines for the appropriate health and safety requirements that must be followed by Hampshire 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  • Hydrochlorofluorocarbons (HCFC): Chemical compounds in which not all of the hydrogen has been replaced by chlorine and fluorine.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. The HVAC/mechanical foreman and the HVAC/mechanical specialist are the only authorized technicians at Hampshire College.
  • UL: Underwriters Laboratories, Inc. 

Responsible Department

  • Hampshire College HVAC/mechanical department

Appliances (Containing 50 Pounds or more of refrigerant)

  • Adele Simmons Hall: One direct expansion (DX) unit containing approximately 50 pounds of refrigerant.
  • Cole Science Center: Two chiller units containing approximately 250 pounds of refrigerant, each.
  • Dining Common: Two DX units containing approximately 100 pounds of refrigerant, each.
  • Franklin Patterson Hall: One chiller unit containing approximately 60 pounds of refrigerant.
  • Harold Johnson Library: Two chiller units on the roof containing approximately 120 pounds of refrigerant, each; One DX unit on the ground level containing approximately 50 pounds of refrigerant.
  • Music and Dance: One chiller unit containing approximately 89 pounds of refrigerant.
  • Robert Crown Center: One DX unit containing approximately 120 pounds of refrigerant.

Requirements and Procedures

  • Only technicians who 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 attach a label or tag to the unit indicating that it has been evacuated of refrigerant, oil and/or any other material required to render it safe for disposal.
  • Hampshire 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 that 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. The HVAC/mechanical foreman is 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, Hampshire College employees are prohibited from working with refrigerant in confined spaces. Overexposure to refrigerant can cause dizziness and loss of concentration. The HVAC/mechanical foreman 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 is stored in the HVAC shop at facilities and grounds, a mechanical room at the music and dance building and in the filter room at Franklin Patterson Hall. Recovered, used refrigerant is stored in cylinders in the HVAC/mechanical foreman's locked storage trailer at facilities and grounds.
  • 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/mechanical foreman is responsible for inspecting cylinders and valves 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 Hampshire College-owned systems without restriction.
  • In the event that Hampshire 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 the HVAC/mechanical shop at facilities and grounds. Additionally, technicians must provide environmental health and safety with a copy of proof of certification to keep on file.

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 appliance/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 of outside contractors servicing appliances containing 50 pounds or more of refrigerant at hampshire 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.
  • At the end of each year, the HVAC/mechanical foreman must give the completed "refrigerant use log" to environmental health and safety, where it will be kept for a minimum of three years.

Annual Program Review

  • This program will be reviewed on an annual basis by the HVAC/mechanical foreman and the director of facilities and grounds. The review will consist of:
    • A review of the Refrigerant Recycling 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 Hampshire 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 Hampshire College community?

EH&S 6/2010

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