usc cfc leak repair and recordkeeping procedures usc cfc leak repair and... · usc cfc leak repair...

EHS-M-46 Page 1 Issued Date: 4/27/11

Destroy Previous Revisions Approved: _RWW_

USC CFC Leak Repair and Recordkeeping Procedures

I. Introduction Chlorofluorocarbons (CFCs) released into the atmosphere can damage the ozone layer that protects the earth from the penetration of harmful ultraviolet radiation. Ultraviolet radiation can cause health and environmental concerns, including increased incidences of skin cancers, cataracts, and damage to crops and living organisms. This procedure will reduce the emissions of CFCs and HCFCs to the lowest achievable levels during the service, maintenance, and disposal of appliances at the University of South Carolina. This program is in compliance with the refrigerant recycling requirements of 40 CFR, Part 82, Subpart F, of the Clean Air Act, as amended in 2011.

II. Definitions Comfort cooling appliance any air conditioning appliance used to provide cooling in order to control heat

and/or humidity in facilities such as office buildings and computer rooms.

Commercial refrigeration appliance Any refrigeration appliance used to store perishable goods in retail food,

cold storage warehousing, or any other sector requiring cold storage. Cold storage includes refrigeration

equipment used to house perishable goods or any manufactured product requiring refrigerated storage.

Industrial refrigeration appliance Refrigeration equipment that may be complex or customized, that is used

in a manufacturing process. Industrial process refrigeration appliances include equipment that is directly

linked to a manufacturing process, such as manufacturing, power generation, ice manufacturing, etc.

Initial verification leak test is a leak test that is conducted as soon as practicable after the repair is completed.

An initial verification test requires the evacuation of the appliance, is conducted prior to the replacement of

the full refrigerant charge, and before the appliance is returned to normal operating conditions.

Follow-up verification leak test is a test that validates the effectiveness of repairs within 30 days of the

appliances return to normal operating conditions. Follow-up verification tests include, but are not limited to

the following: use of soap bubbles, electronic or ultrasonic leak detectors, pressure or vacuum tests,

fluorescent dye and black light, infrared or near-infrared tests, and handheld gas detection devices.

Major Repair is a repair that involves the removal of the compressor, condenser, evaporator, or auxiliary heat exchanger coil. A major repair requires the removal or isolation of the refrigerant charge before work is started.

Retrofit is the conversion of an appliance from a refrigerant to a substitute with a lower ozone-depleting

potential.

Leak rate is the rate at which an appliance is losing refrigerant, calculated at the time of refrigerant addition.

Leak rate is expressed in terms of the percentage of the appliances full charge since the last successful repair

over a consecutive 12-month period:



III. Basic CFC Requirements

1. Prohibition of Venting

Since July 1, 1992, intentional venting of ozone-depleting substances into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration appliances is prohibited. Small releases of refrigerant resulting from purging hoses or from connecting and disconnecting hoses are not considered as a violation of this rule.

2. Evacuation Requirements

Technicians are required to evacuate or isolate refrigerant any time major repairs are to be done. Major repairs involve opening the equipment for maintenance, service, repair, or disposal.

3. Reclamation Requirement

EPA has established that refrigerant recovered and/or recycled can be returned to the same system or other systems owned by the same owner without restrictions.

4. Refrigerant Recovery and Recycling Equipment Certification

EPA has established a certification program for refrigerant recovery and recycling equipment. EPA requires that manufacturers or importers of refrigerant recovery and recycling equipment manufactured on or after November 15, 1993, have their equipment tested by an EPA-approved testing organization to ensure it meets requirements. EPA certified equipment will have a label stating that it meets EPA requirements.

5. Refrigerant Recovery Equipment Certification

EPA regulations require facilities that service or dispose of refrigeration appliances certify that they have acquired recovery or recycling devices that meet EPA standards for these devices. To certify that you have acquired EPA certified equipment, each facility must submit EPA Form 7610-31 to their EPA Regional Office. Owners are not required to send in a new form each time they add recycling or recovery equipment. Each facility must keep a copy of this documentation for audit purposes.

6. Technician Certification

EPA has established a technician certification programs for persons who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphere. The following 4 certifications have been developed:

a. Type 1 for servicing small appliances,



b. Type II for servicing or disposing of high or very high-pressure appliances, except small appliances and MVACs,

c. Type III for servicing or disposing of low-pressure appliances, and d. Universal for servicing all types of appliances.

Apprentices (person who is currently registered as an apprentice in service, maintenance, repair, or disposal of appliances with an Apprenticeship Council recognized by the Bureau of Apprenticeship and Training) are exempt from certification requirements provided they are closely and continually supervised by a certified technician. Certified technicians must keep a copy of their certificate at their place of business.

7. Refrigerant Sales Restrictions

The sale of ozone-depleting refrigerant in any size container has been restricted to EPA certified technicians.

8. Appliance Self Disposal Requirements Refrigeration appliances that are dismantled on-site before disposal must have the refrigerant recovered in accordance with EPA requirements for servicing prior to disposal. When a technician has removed the refrigerant and is disposing of the appliance, the technician must provide a signed statement to the disposal company which includes the following:

a. Name and address of person recovering refrigerant, b. Date the refrigerant was recovered, or c. Copy of contract stating the refrigerant will be removed prior to delivery.

IV. USC Review and Documentation of Existing CFC Equipment

1. All areas, departments, and campuses must review their areas and develop:

a. A list of all cooling units with more than 50 pounds of refrigerant charge with the following

information:

i. Description of appliance,

ii. Location of appliance,

iii. Type of refrigerant and number of pounds of charge,

iv. Complete records of any required service information that you have not

documented.

b. The numbers of window cooling units for each building in your department/campus.

(According to EPA, each window unit contains as much as 1.4 pounds of refrigerant.)

c. The number of cooling units with 1.5 pounds to 50 pounds of refrigerant, when

information is readily available.

d. Send this information to the person responsible for maintaining your area, department, or

campus CFC leak repair records.

2. Each department or campus will also send the following records to the person responsible for

maintaining their CFC leak repair records:

a. Type of refrigerant purchased, number of pounds purchased, and date obtained,



b. Information on any refrigerants reclaimed and disposed through recycling vendors,

including type of refrigerant, number of pounds, vendor, and date disposed.

c. Updated list of EPA certified recovery and recycle equipment maintained by each

department.

d. Information on new refrigeration systems as they are installed/replaced in buildings.

3. The individual responsible for maintaining your CFC leak repair records will:

a. Record and maintain this information into their CFC program. Develop the following lists:

i. Active appliance list of all units with more than 50 pounds of refrigerant charge,

ii. Departmental buildings with the number of AC window units in each building,

iii. Known cooling units containing 1.5 pounds to 50 pounds of refrigerant.

b. Maintain copies of technician certification cards for each technician,

c. Maintain list of refrigerant types and quantities purchased,

d. Maintain list of refrigerants reclaimed and vendors who reclaimed them.

e. Maintain list of refrigerant recovery and recycle equipment by department.

V. USC Procedure for CFC Employee Repairs in Facility-Serviced Departments for Appliances With Greater Than 50 Pounds Refrigerant

1. When a supervisor receives a work order from FAMIS (or other appropriate work order system), the

supervisor will assign the work to a certified technician. (See the flow chart attached as Appendix C.)

2. The technician identifies the unit to be serviced, evaluates the units operational status, and checks the refrigerant level. The technician will use the USC Refrigerant Activity Report to record all work done on a refrigeration appliance. (A copy of the USC Refrigerant Activity Report is attached as Appendix A.)

a. If there is a leak and this is a major repair, the technician will recover or isolate the refrigerant before the repair is begun. Once a leak is determined, the units with more than 50 pounds of refrigerant must be repaired within 30 days, if possible.

b. After the repair, the technician will complete an initial verification leak test before replacing the refrigerant charge.

c. When the leak repair is confirmed, the technician will recharge the refrigerant and add any additional amount of refrigerant to fully charge the appliance.

d. Within 30 days, the technician will complete a follow-up verification leak test while the appliance is operating at normal operating conditions.

e. The technician will then fully complete the USC Refrigerant Activity Report and give a copy to his/her supervisor.

f. The supervisor will: i. Complete his review of the Refrigerant Activity Report to ensure it is completely filled

out, ii. Verify refrigerant type and account for quantity used by the technician,

iii. Sign the form, and forward the Refrigerant Activity Report to the person responsible for maintaining the area, department, or campus CFC leak repair records.

g. If the supervisor requires management decisions for work completion, he/she will follow up with the manager, superintendent, or Director responsible for maintaining the equipment.

h. When decisions have been finalized, the supervisor will send the completed Refrigeration Activity Report to the person responsible for maintaining CFC leak repair records. The person responsible for CFC leak repair records will:



i. Post the information into their management software or program, and ii. Calculate a leak rate for all appliances with greater than 50 pounds of refrigerant.

iii. Maintain all records required by EPA.

3. If either the initial verification leak test or the follow-up verification leak test is not successful, the technician will determine the problem and report the findings to his/her supervisor.

4. The technicians supervisor, along with the owner manager or superintendent will determine whether the leaking appliance is repairable or if it should be retired or retrofitted with a lower ozone-depleting refrigerant.

a. If it is determined that the appliance cant be repaired within 30 days and the appliance contains more than 50 pounds of refrigerant, the owner supervisor/manager must develop a written and dated retrofit or retirement plan.

b. A copy of the written and dated retirement or retrofit plan must be kept at the location of the appliance.

c. Having the retirement and retrofit plan provides up to 6 months, and possibly up to 1 year (depending on documented circumstances) to complete the project.

VI. USC Procedure for CFC Employee Repair in Non-Facility Serviced Departments and Senior/Regional campuses For Appliances With Greater Than 50 Pounds Refrigerant 1. When a technician works on an appliance, the technician will:

a. Identify the unit to be serviced, evaluate the units operational status, and check the refrigerant level. The technician will document all work performed on cooling appliances using the USC Refrigerant Activity Report (See Attachment A).

b. If there is a leak and this is a major repair, the technician will recover or isolate the refrigerant before the repair is begun. Once a leak is determined, the units with more than 50 pounds of refrigerant must be repaired within 30 days, if possible.

c. After the repair, the technician will complete an initial verification test before replacing the refrigerant charge.

d. When the leak repair is confirmed, the technician will recharge the refrigerant and add any additional amount of refrigerant to fully charge the appliance.

e. Within 30 days, the technician will complete a follow-up verification leak test while the appliance is operating at normal operating conditions.

f. The technician will then fully complete the USC Refrigerant Activity Report and send a copy of the form to his/her supervisor.

g. The supervisor will i. Complete his/her review of the Refrigerant Activity Report to ensure it is

completely filled out, ii. Verify refrigerant type and account for the quantity used by the technician,

iii. Sign the form, and iv. Forward the Refrigerant Activity Report to the person responsible for maintenance

of CFC leak repair records. h. If the supervisor requires management decisions for work completion, he/she will follow

up with the manager, superintendent, or director responsible for maintaining the equipment.

i. When decisions have been finalized, the supervisor will send the completed Refrigeration Activity Report to the person responsible for maintaining CFC leak repair records. The person responsible for CFC leak repair records will:



i. Post the information into their management software or program ii. Calculate a leak rate for all appliances with greater than 50 pounds of

refrigerant. iii. Maintain all required records and data required by EPA.

2. If either the initial verification test or the follow-up verification test is not successful, the

technician will determine the problem and report the findings to his/her supervisor. 3. The supervisor, along with the owner manager or superintendent will determine whether the

leaking appliance is repairable, or if it should be retired or retrofitted with a lower ozone-depleting refrigerant.

a. If it is determined that the appliance cant be repaired within 30 days and the appliance contains more than 50 pounds of refrigerant, the supervisor/manager must develop a written and dated retrofit or retirement plan.

b. A copy of the written and dated retirement or retrofit plan will be kept at the location of the appliance.

c. Having the retrofit and retirement plan provides up to 6 months, and possibly up to 1 year (depending on documented circumstances) to complete the project.

VII. USC Procedure for Contractor CFC Leak Repairs For Appliances With Greater Than 50 Pounds Refrigerant 1. The Columbia Energy Department will use the following process to manage their CFC work. (See

the flow chart in Appendix D for contractor repairs.)

a. A licensed contractor will be called to service chillers and other equipment. In these areas, the supervisor or shift manager will contact a contracting HVAC company for repair.

b. When the repair has been completed, the supervisor or shift manager will ensure that the

contractor completely fills out the USC Refrigerant Activity Report (See Appendix A), including the initial leak-repair verification and the follow-up leak test verification sections. The supervisor or shift manager will sign the report and give it to the assistant superintendent of Energy.

c. The assistant superintendent will review and sign the Refrigerant Activity Report and

forward it to the person responsible for maintaining CFC leak repair information.

d. If the assistant superintendent requires management decisions for work completion, he will follow up with the superintendent or director responsible for maintaining the equipment.

e. When decisions have been finalized, the assistant superintendent will send the completed Refrigeration Activity Report to the person responsible for maintaining CFC leak repair records. The person responsible for CFC leak repair records will:

i. Post the information into their management software or program ii. Calculate a leak rate for all appliances with greater than 50 pounds of

refrigerant. III. Maintain all required records and data required by EPA.



2. Other departments and campuses which use contractors to service cooling appliances will use the following process:

a. A supervisor or shift manager will contact a contracting HVAC company for repair.

b. When the repair has been completed, the supervisor or shift manager will ensure that the

contractor completely fills out the USC Refrigerant Activity Report (See attachment A), including the initial leak-repair verification, the follow-up leak test verification sections, and technician signature. The supervisor or shift manager will sign the report.

c. If the department or campus contracts with the USC Columbia Facility department, the

department will send the Refrigerant Activity Report to the Columbia Facilities person designated to keep CFC leak repair records.

d. If the department or campus is not serviced by the USC Columbia Facility department, the

department or campus will be responsible for keeping all required CFC leak repair records. (See Appendix B: Reporting and Recordkeeping Requirements for Appliances with Greater than 50 Pound Charge.)

VIII. Refrigerant Reclaim Operations

1. Columbia facility refrigerant reclaim operations will be supervised or completed by the Columbia lead HVAC technician. The lead HVAC technician will oversee the following operations for refrigerant which requires cleaning or recovery:

a. Equipment is properly evacuated of refrigerant, b. Refrigerant that requires cleaning is sent to a certified refrigerant reclaimer, and c. Records of reclaimed refrigerant (pounds, type of refrigerant, date reclaimed, and vendor

information) are sent to the person responsible for maintaining CFC leak repair information.

2. Other departments and senior and regional campus groups will have an HVAC technician who

performs these functions for their department or campus. 3. Technicians opening appliances, except for small appliances and MVACs, must evacuate the unit to

the following levels (in inches of mercury vacuum relative to standard atmospheric pressure of 29.9 inches of Hg):

Type of Appliance Recovery/Recycling Equipment Manufactured Before 11/15/93 1 (Inches of Hg)

Recovery/Recycling Equipment Manufactured After 11/15/93 1 (Inches of Hg)

HCFC-22, containing less than 200 pounds

0 0

HCFC-22, containing 200 pounds or more

4 10

Very high pressure equipment 0 0

Other high pressure equipment, containing less than 200 pounds

4 10

Other high pressure equipment, containing more than 200 pounds

4 15

Low pressure equipment 25 25 1 Except for small appliances, MVACs, and MVAC-like appliances



Attachment A:

USC REFRIGERANT ACTIVITY REPORT

Unit Serviced Department Building Date

Location Work order No.

Manufacturer Model No. Serial No.

Serial No. Refrigerant Type

Duty Type Comfort Cooling Industrial/Commercial Other (Explain Below)

Charge 50 Lbs.

Duty Type, if other:

Service Performed Minor Maintenance Major Maintenance Confirm Charge Refrigerant Conversion Unit Disposal Other (explain below)

Service Description:

Refrigerant Activity Recovery Unit: Vacuum (inches)

Recover

From

Appliance

Cylinder Name Lbs. Oz. Condition Reused Reclaim Total Lbs. Total Oz.

Refrigerant Added to Appliance Added to

Appliance

Cylinder Name Lbs. Oz. New Recovered Total Lbs. Total Oz.

Leak Repairs Location(s)

Leak Found? Yes No Date Any Additional Information:

Leak Repaired? Yes No Date If no, was owner notified? Yes No Customers Initials: _________

Initial Leak test? Yes No Date Method: Pressurizing Electronic Deep Vacuum Soap Bubble Other: ________________________________

Follow Up LeakTest? Yes No

(> 50 Pounds Refrigerant)

Date Method: Electronic Soap Bubble Other: ________________________________

Accidental Release? Yes No Approx. Amt.

Explain situation

Comments for Future Services

Signatures Technicians Signature (Required) Date

Owner: Supervisor/Manager (Required) Date

Owner: Superintendent (only if decisions required) Date

When fully completed, send one copy to technicians supervisor. After review and any required follow-up,

the supervisor will send a copy to person who maintains CFC Leak Repair information.



Appendix B: Required Practices and Recordkeeping for Appliances With Greater Than 50 Pounds of Refrigerant Charge

1. Required Practices For Appliances With Greater Than 50 Pounds of Refrigerant The EPA has revised the trigger level for repairing leaks in cooling appliances having greater than 50 pounds of

refrigerant for:

Comfort cooling appliances 10% of full charge (instead of previous 15%)

Commercial refrigeration and industrial process refrigeration 20% of full charge (instead of previous

35%)

1. For comfort cooling appliances, commercial refrigeration, and industrial process refrigeration with a

full charge greater than 50 pounds of refrigerant, all leaks (at EPA trigger level) must be repaired

within 30 days.

2. Owners may have more than 30 days to repair a leak (at EPA trigger level) if equipment is:

a. Located in an area subject to radiological contamination;

b. Necessary parts are unavailable and statement from component manufacturer is maintained;

c. Other regulations make a repair impossible where such records are maintained.

3. The leak rate must be calculated immediately upon each addition of refrigerant after repair, unless the

addition is due to seasonal variance where records justify the addition.

4. An initial verification test must be conducted immediately upon completion of repairs. Methods and

results must be maintained.

5. A follow-up verification test must be conducted within 30 days of completion, but no sooner than 24

hours after repair and recharge of the appliance. The follow-up verification test must be conducted at

normal operating characteristics and conditions. Methods and results of all follow-up tests must be

maintained.

6. If the initial or follow-up verification test is NOT successful and leaks remain, an additional repair

attempt must be made within 30 days of the failed verification; and additional initial and follow-up

verification tests must be completed as described.

7. Comfort cooling appliances, commercial refrigeration, and industrial process refrigeration systems

which have experienced 3 failed verifications tests within a 6-month period must be retired or

retrofitted with a lower ozone-depleting potential coolant.

8. Owners are not required to repair equipment within 30 days if they develop a written and dated

retrofit or retirement plan. Retrofit or retirement plan must include:

a. Six month schedule to permanently retire or retrofit equipment for use with lower ozone-

depleting potential coolant.

b. Plan must be maintained at physical location of equipment.

c. More than 6 months may be available if a supplier quotes a time of more than 12 weeks

delivery and the written statement is maintained.



Appendix B: (Continued)

2. Reporting and Recordkeeping Requirements for Appliances With Greater Than 50 Pounds

Charge

1. Persons servicing appliances with a full charge greater than 50 pounds of refrigerant must provide

owner with documentation which includes:

a. Quantity and type of refrigerant added,

b. Identity and location of the appliance,

c. Date and service performed,

d. Physical location of any leaks,

e. Amount and type of any refrigerant recovered,

f. Date, method, and results of initial verification and follow-up verification tests.

2. Owners of appliances with a full charge greater than 50 pounds of refrigerant must keep records for a

period of 3 years which document:

a. Quantity and type refrigerant added,

b. Full charge of equipment,

c. Calculated leak rate,

d. Identity and location of equipment,

e. Date and type of service,

f. Physical location of any leaks,

g. Types and quantities of refrigerant recovered from appliances, address of facility accepting

used refrigerant, and date refrigerant was transferred,

h. Date, method, and results of initial verification and follow-up verification tests, and

i. Written and dated retrofit or retirement plan that establishes 6-month schedule to retrofit or

retire leaking appliance. This must include:

i. Identification and location of equipment;

ii. Type and full charge of refrigerant used by leaking appliance;

iii. Location of all leaks and efforts taken to address leaks;

iv. Type and full charge of substitute to which appliance will be converted;

v. If retrofitted, is there an itemized procedure for retrofit, including procedure for

flushing old refrigerant and lubricant, changes in lubricants, filters, gaskets, o-rings or

valves;

vi. Plan for disposition of recovered refrigerant;

vii. Plan for disposition of appliance, if retired; and

viii. Six-month schedule for complete retrofit or retirement of appliance.

3. Owners of appliances who are unable to complete repairs in 30 days due to radiological conditions,

unavailability of components, or government regulations must maintain following records:

a. Written statement describing radiological conditions or government regulations that prevent

repair;

b. Written statement from manufacturer or distributor estimating date of delivery for required

parts;



c. Documenting date of delivery of required component.

4. Certified technicians must keep a record of certificate on-site, at place of business.

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