S02 SOP-03 Management of Refrigerants.pdf

Management of Refrigerants

SOP 03

Coatesville VA Medical Center Coatesville, PA 19320

Signatory Authority:

FES Chief

Responsible Owner:

FES Chief

Service Line(s):

Facilities Engineering Service

Effective Date:

October 1, 2021

Recertification Date:

October 1, 2026

1. PURPOSE AND AUTHORITY

a. The purpose of this standard operating procedure (SOP) is to implement management practices to effectively control the purchase, use, and disposal of chlorofluorocarbons (CFC’s) and hydrochloroflurocarbons (HCFC’s), which are considered to be ozone depleting compounds.

b. The Environmental Protection Agency (EPA) requires a Refrigerant Compliance Program. It is the intent of this medical center to comply with all Federal, State, and local regulations. All equipment on the medical center campus is subject to this program. Accordingly, the medical center has assigned the General Utilities section with administrative control and record keeping requirements.

2. PROCEDURES

a. Certification

(1) Employee: All employees that perform maintenance, service, repair, or disposal of equipment that could release refrigerant into the atmosphere must attend a technician certification program approved by the EPA.

(a) Specifically, any employee whose job duties encompass the following will be required to receive certification.

1. Attaching and detaching hoses and gauges to and from the appliance to measure pressure within the appliance.

2. Adding refrigerant to or removing refrigerant from the appliance.

3. Any other activity that violates the integrity of any appliance.

(b) The EPA has approved four types of certificate programs:

1. Servicing small appliances (Type I).

October 1, 2021 SOP 03

2. Servicing or disposing of high or very high-pressure appliances, except small appliances and MVACs (Type II).

3. Servicing or disposing of low-pressure appliances (Type III).

4. Servicing all types of equipment (Universal).

(c) Federal law states that technician certifications shall never expire; however, it is the policy of the Coatesville VAMC that HVAC technicians will receive an annual in-service training provided by the Shop Supervisor. Training will be documented in the employee training record utilizing TMS, and copies of sign-in sheets will be sent to the GEMS Program Manager’s office.

(2) Equipment:

(1) Technicians servicing or disposing of air-conditioning and refrigeration equipment must certify to the EPA Region 3 office that they have acquired (built, bought, or leased) recovery or recycling equipment and that they are complying with the applicable regulations. Forms can be obtained in the GEMS Program Manager’s office.

(2) When new equipment is purchased, it shall be certified by one of the following third party representatives approved by the EPA: Air-Conditioning and Refrigeration Institute (ARI) or Underwriters Laboratories (UL). New equipment purchases will be of the latest technologies to reduce environmental impact and must comply with the evacuation levels described in Attachment A, Required Levels of Evacuation.

(3) Service contractors will certify that recovery equipment used has been properly documented, certified, labeled, and serviced according to EPA requirements.

b. Recovery - HVAC technicians will use proper equipment and follow manufacture directions when evacuating refrigerant. All recovery and recycling will be documented in accordance with recordkeeping requirements in this SOP.

(1) Technicians repairing small appliances (refrigerators, window air conditioners, etc.) must abide by the following recovery levels:

(a) 80% of the refrigerant when the technician uses recovery or recycling equipment manufactured before November 15, 1993, or the compressor in the appliance is not operating.

(b) 90% of the refrigerant when the technician uses recovery or recycling equipment manufactured after November 15, 1993, and the compressor in the appliance is operating.

c. Phase Out: The VAMC will continue to plan for Class I and Class II phase-out requirements in accordance with federal laws.

(1) Class I refrigerants are traditionally known as Chlorofluorocarbons (CFCs).

CFCs have higher ozone depleting potential and have been completely phased out in the United States. The VAMC currently uses Class I refrigerants in its daily operation. As equipment and appliances are replaced, Class I refrigerants will be phased out of operation.

(2) Class II refrigerants are hydrochlorofluorocarbons (HCFCs) and have been used as substitutes for many Class I refrigerants. HCFCs are currently being phased out or will be phased out over the coming years. For product and date phase-outs please refer to the EPA Web site or contact the GEMS Program Manager.

d. Reclamation: Refrigerant recovered and/or recycled can be returned to the same system or other systems owned by the same person without restrictions. If refrigerant changes ownership, that refrigerant must be reclaimed unless the refrigerant was used only in a Motor Vehicle Air Conditioner (MVAC) or MVAC-like appliance and will be used in the same type of appliance. A list of certified reclaimers can be found on the EPA Web site.

e. Leaks and Venting: Since July 1,1992, it has been against the law to intentionally vent refrigerants to the atmosphere while maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment.

(1) For appliances that contain a refrigerant charge of more than 50 pounds, the following regulations apply:

(a) Leaks must be repaired when the appliance leaks at a rate that would release 35% percent or more of the charge over the year. The trigger for repair requirements is the current leak rate rather than the total quantity of refrigerant lost.

(b) Any leak over the 35% must be repaired within 30 days of the discovery of the leak. If repairs cannot be made in this time period, then Engineering Service will develop a one-year retrofit plan for the leaking equipment.

(c) Tracking Leaks: To track leak rates of equipment containing more than 50 lbs. of refrigerant, General Utilities will maintain records and keep records of the quantity of refrigerant added to their equipment during services and maintenance procedures in accordance wit the recordkeeping requirements of this policy. The locations of units containing 50 lbs. or more of refrigerant are as follows:

1. Building #5 – 2 roof top units

2. Building #39 – computer room (2 units)

3. Building #58 – 2 retherm units in kitchen

4. Building #139 – 3 walk-in units

5. Building #138E – 2 roof top units

6. Building #17 – 2 chillers

7. Building #11 – 1 chiller and 1 DX unit

(2) Allowable Venting: The following are acceptable releases of refrigerant into the environment:

(a) De Minimus quantity released in the course of making a good faith attempt to recapture, recycle, or safely dispose of refrigerant. An example of a De Minimus leak would be the quantity of refrigerant released while disconnecting a manifold gauge set.

(b) Refrigerants emitted in the course of normal operation of air conditioning and refrigeration equipment (as opposed to during the maintenance of this equipment) such as from mechanical purging and leaks.

(c) Releases of CFCs or HCFs that are not used as refrigerants such as mixtures of nitrogen and trace quantities of R-22 that are used as a holding charge or as a leak test gas because in these cases they are not used as refrigerant.

(3) Accidental release shall be documented on the Leak Tracking Form (Attachment C) and reported to the GEMS Program Manager.

f. Recordkeeping: The following records and documentation must be kept onsite for a minimum of 7 years.

(1) Purchases: The following acquisitions will be documented on an approved form:

(a) Equipment: New equipment purchased by the VAMC will be documented on Attachment E and maintained by the user shop. Additionally, a new EPA Recovery Equipment Certification will be completed and sent to the GEMS Program Manager.

(2) The General Utilities Shop, having oversight of equipment that contains 50 or more pounds of refrigerant, will keep service records documenting the date and type of service as well as the quantity added.

(3) HVC Mechanics and contractors servicing appliances that contain 50 or more pounds of refrigerant must provide the VAMC with an invoice that indicates the amount of refrigerant added to the appliance. A copy of this invoice must be maintained by the COR/shop supervisor of the contract for a period of 7 years.

(4) HVAC Mechanics will record all refrigerant losses on Attachment C and report them to their supervisor.

(5) Leak test and recovery unit maintenance will be completed per manufacturer recommendations, and invoices will be maintained by the General Utilities Shop.

(6) Names and addresses of persons reclaiming recovered material, as well as the amount and type of refrigerant, must be maintained by the General Utilities shop.

g. Disposal

(1) Equipment that is dismantled on-site before disposal (e.g., refrigerators, air conditioning units, and chillers) must have the refrigerant recovered prior to disposal. A signed statement that the appliance no longer holds a charge must be sent with the equipment to the final disposal site.

(2) Equipment that is not dismantled on-site must have refrigerant recovered by the final person in the disposal chain (e.g., scrap metal recycler or landfill owner) prior to final disposal. A record of recovery from the disposal site must be retained by the General Utilities Shop Supervisor.

(3) Refrigerants that have been recycled or reclaimed are not considered hazardous waste. In addition, used oils contaminated with refrigerants are not hazardous.

(4) Refrigerants that have been recovered shall be sent to a certified reclamation site listed through the EPA or returned to the vendor.

Documentation of reclamation or return shall be kept in the General Utilities shop.

(5) Containers that once held refrigerant and are now empty will be disposed of in the scrap metal yard at T-21. Containers are considered empty when they are atmospheric pressure; however, valve stems should be removed from the cylinder prior to disposal.

3. DEFINITIONS

None

4. REFERENCES

a. EPA, Clean air Act of 1990 (and as amended), Section 608, Refrigerant Recycling Rule.

b. CEOSH GEMS Guidebook

c. Code of Federal Regulations (CFR), Section 609 of the Clean Air Act of 1990.

5. REVIEW

Review of this SOP occurs every five years during the recertification process.

6. RECERTIFICATION

This SOP is scheduled for recertification on or before the last working day of October 2026. In the event of contradiction with national policy, the national policy supersedes and controls.

7. SIGNATORY AUTHORITY

Richard F. Crumley Chief, Facilities Engineering Service Date Approved: Month Day, Year

NOTE: The signature remains valid until rescinded by an appropriate administrative action.

DISTRIBUTION: Medical Center Policies are available here. Medical Center Policy Attachments are available here.

https://dvagov.sharepoint.com/sites/VHACOAvamc/policies/default.aspx https://dvagov.sharepoint.com/sites/VHACOAvamc/policies/MCP%20Attachments/Forms/AllItems.aspx

Attachment A

Required Levels of Evacuation

Table 1- Required Levels of Evacuation

REQUIRED LEVELS OF EVACUATION FOR APPLIANCES EXCEPT FOR SMALL APPLIANCES, MVACS, AND

MVAC-LIKE APPLIANCES

Type of Appliance

Inches of Mercury Vacuum* Using Equipment Manufactured:

Before Nov. 15, On or After

Nov. 15, 1993

HCFC-22 appliance** normally containing less than 200 pounds of refrigerant 0 0

HCFC-22 appliance** normally containing 200 pounds or more of refrigerant 4 10

Other high-pressure appliance** normally containing less than 200 pounds of refrigerant (CFC-12, -500, -502, -114) 4 10

Other high-pressure appliance** normally containing 200 pounds or more of refrigerant (CFC-12, -500, -502, -114) 4 15

Very high-pressure appliance (CFC-13, -503) 0 0

Low-pressure appliance (CFC-11, HCFC-123) 25 25 mm Hg absolute

* Relative to standard atmospheric pressure of 29.9” Hg ** Or isolated component of such an appliance

Attachment B

Refrigerant Inventory

VAMC Refrigerant Inventory: Below is a list of the refrigerants currently being used or stored at the VAMC Facilities. This inventory is subject to change prior to recertification of this SOP.

The inventory is categorized by facility location, refrigerant, chemical name, Chemical Abstracts Service (CAS) Number and United Nations (UN) Number.

Table 2 - List of refrigerants used/stored at VAMC Chiller Plant (Bldg. #17)

Refrigerant Chemical Name CAS Number

UN

Number

502 R-22/R-115 Blend

Chlorodifluoromethane/chloropentafluoroethane

75-45-6

76-15-3

UN1973

12 Dichlorodifluoromethane (CCl2F2) 75-71-8 UN1028

22 Chlorodifluoromethane (CHClF2) 75-45-6 UN1018

134A 1,1,1,2-tetrafluoroethane (CH2FCF3) 811-97-2 UN1956

404A R-125/R-143a/R-134a Blend

Pentafluoroethane/1,1,1-Trifluoroethane/1,1,1,2-tetrafluoroethane

N/A UN1956

408A Chlorodifluoromethane (HCFC-22)

1,1,1-Trifluoroethane (HFC-143a)

Pentafluoroethane (HFC-125)

75-45-6

420-46-2

354-33-6

UN3163

416A 1,1,1,2-Tetrafluoroethane (R134a)

1-Chloro-1,2,2,2-tetrafluoroethane (R124)

N/A UN1078

410A Difluoromethane

Pentafluoroethane

75-10-5

354-33-6

UN3163

407C Difluoromethane (HFC-32)

Pentafluoroethane (HFC-125)

1,1,1,2-Tetrafluoroethane (HFC-134a)

75-10-5

354-33-6

811-97-2

UN3340

500 Dichlorodifluoromethane (CFC-12)

1,1 Difluoroethane (HFC-152a)

75-71-8

75-37-6

UN2602

409 Chlorodifluoromethane (HCFC-22)

Chlorodifluoroethane (HCFC-142b)

Chlorotetrafluoroethane (HCFC-124)

75-45-6

75-68-3

2837-89-0

UN3163

Main Kitchen (Bldg. #139)

Refrigerant Chemical Name CAS Number

UN

Number

12 Dichlorodifluoromethane (CCl2F2) 75-71-8 UN1028

502 R-22/R-115 Blend

Chlorodifluoromethane/chloropentafluoroethane

75-45-6

76-15-3

UN1973

404A R-125/R-143a/R-134a Blend

Pentafluoroethane/1,1,1-Trifluoroethane/1,1,1,2-tetrafluoroethane

N/A UN1956

416A 1,1,1,2-Tetrafluoroethane (R134a)

1-Chloro-1,2,2,2-tetrafluoroethane (R124)

N/A UN1078

4082 Chlorodifluoromethane (HCFC-22)

1,1,1-Trifluoroethane (HFC-143a)

Pentafluoroethane (HFC-125)

75-45-6

420-46-2

354-33-6

UN3163

(Location) VAMC

Attachment C

Leaks Tracking Form

Attachment D

Refrigerant Tracking Form

Table 3 - Blank Refrigerant Tracking Form Cylinde r ID #

Refrigera nt

Refrigera nt New/ Recycled

Cylinder/ Weight Out (lbs/oz)

Amount Taken From Inventory

Equipmen t Number or Unit Number

Cylinder Weight Checked In (lbs/oz)

Certifie d Handler ’s Name

Date Added/ Remove d

**Keep this record for seven years

Attachment E

Appliance Disposal Input Form

Date: ________________________

Technician Name: ____________________________________________

Address: ____________________________________________________

Appliance Equipment Number: __________________________________

Compressor Running? Yes / No

Factory Charge on Data Plate: _____________Lbs. ____________Oz.

Refrigerant Type: _____________________________________________

Refrigerant Removed: ______________Lbs. ____________Oz.

I certify that this appliance has had the refrigerant recovered in accordance with section 608 of the CAAA 1990.

Signature: __________________________________________________

Supervisor: _________________________________________________