Ozone Depleting Substances (ODS)/Reduction of Refrigerant Emissions Program

Summary: The UC Irvine (UCI) Environmental Health and Safety (EH&S) Ozone Depleting Substances (ODS)/Refrigerant Emissions Program facilitates compliance with the South Coast Air Quality Management District (SCAQMD) and the United States Environmental Protection Agency (USEPA) regulations which apply to stratospheric ODS's, such as chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) used in stationary and motor vehicle refrigeration and air conditioning systems.

    1. Program Description
    2. Scope
    3. Definitions
    4. Responsibilities
    5. Program Components
    6. Laws and Regulations Referenced on ODS
    7. Training Requirements and Competency Assessment

1. Program Description

The UC Irvine (UCI) Environmental Health and Safety (EH&S) Ozone Depleting Substances (ODS)/Refrigerant Emissions Program facilitates compliance with the South Coast Air Quality Management District (SCAQMD) and the United States Environmental Protection Agency (USEPA) regulations which apply to stratospheric ODS's, such as chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) used in stationary and motor vehicle refrigeration and air conditioning systems.

2. Scope

This program is applicable to the UCI campus entities, which does not include University Research Park (leasers are responsible for their own equipment), which use or store ODS/refrigerants for operations & maintenance (O&M) of air conditioning and refrigeration systems and for research. Program requirements are also applicable to outside contractors that work on such systems at UCI. The goals of the program are prioritized as follows:

2.1 To prevent and minimize releases of ODS to the environment;

2.2 To comply with applicable laws and regulations governing ODS; and

2.3 To detect, report and correct releases of ODS should they occur.

Therefore, environmental compliance regulations pertaining to ODS for UCI are broken into two general categories:

2.4 Refrigeration-Related Equipment & Appliances (RREA) , such as utility chillers, building air conditioning (AC), refrigerators and freezers (stationary or truck-mounted), dehumidifiers, MVAC-like appliances (see section 3 Definitions), etc. are regulated by Section 608 of the 1990 Amendments to the Clean Air Act (CAA); and

2.5 Motor Vehicle Air Conditioners (MVAC) are regulated by Section 609 of the 1990 Amendments to the CAA.

3. Specific Program Components

Appliance – Any device which contains and uses a Class I (CFC) or Class II (HCFC) substance as a refrigerant and which is used for household or commercial purposes including any air conditioner, refrigerator, chiller, or freezer. EPA interprets this definition to include all air conditioning and refrigeration equipment except those designed and used exclusively for military purposes.

Apprentice – Any person who is currently registered as an apprentice in service, maintenance, repair, or disposal of appliances with the U.S. Department of Labor's Bureau of Apprenticeship and Training (or a State Apprenticeship Council recognized by the Bureau of Apprenticeship and Training).

CAA – Clean Air Act and all amendments including the 1990 Amendments.

CFC – Chlorofluorocarbon – any such chemical listed as a Class I ODS in Sections 608 and 609 of the CAA.

ESS – Environmental Support Solutions

FM – UC Irvine Facilities Management Department

HCFC – Hydrochlorofluorocarbon – any such chemical listed as a Class II ODS in Sections 608 or 609 of the Clean Air Act.

Hotline – EPA's Stratospheric Ozone Hotline at 1-800-296-1996 or their website at http://www.epa.gov/ozone

Major Maintenance, Service or Repair – Maintenance, service, or repair that involves removal of the appliance compressor, condenser, evaporator, or auxiliary heat exchanger coil.

MVAC – Motor Vehicle Air Conditioner

MVAC-like Appliance – Mechanical vapor compression, open-drive compressor appliances with a normal charge of 20 lbs or less used to cool the driver or passenger's compartment of a non-road vehicle, including agricultural and construction vehicles. This definition excludes those appliances using HCFC-22.

ODS – Ozone Depleting Substance; Any group of halogenated hydrocarbon chemicals which photochemically react in the stratosphere in a way which destroys the ozone layer which protects the Earth from the excessive influx of harmful cosmic & solar radiation.

Opening – Any service, maintenance or repair on an appliance that would release class I or class II refrigerant from the appliance to the atmosphere unless the refrigerant was recovered previously from the appliance. Connecting and disconnecting hoses and gauges to and from the appliance to measure pressures within the appliance and to add refrigerant to or recover refrigerant from the appliance shall not be considered "opening."

Owner – The UCI entity which is responsible for O&M (e.g., FM Manager or Lab PI) of the RREA, MVAC or other ODS equipment at UCI.

PI – Principal Investigator in a laboratory or person in charge of equipment not O&M'd by FM.

Reclaim – To reprocess refrigerant to at least the purity specified in the ARI Standard 700-1995, Specifications for Fluorocarbon Refrigerants and to verify this purity using the analytical methodology prescribed in the Standard. Reclamation requires specialized machinery not available at a particular job site or auto repair shop. The technician will recover the refrigerant and then send it either to a general reclaimer or back to the refrigerant manufacturer.

Recover – To remove refrigerant in any condition from an appliance and store it in an external container without necessarily testing or processing it in any way.

Recycle – To extract refrigerant from an appliance and clean refrigerant for reuse without meeting all of the requirements for reclamation. In general, recycled refrigerant is refrigerant that is cleaned using oil separation and single or multiple passes through devices, such as replaceable core filter-dryers, which reduce moisture, acidity and particulate matter. For MVACs, refrigerant can be removed from one car's air conditioner, recycled on site, and then charged into a different car.

Refrigerant Circuit – The parts of an appliance that are normally connected to each other (or are separated only by internal valves) and are designed to contain refrigerant.

RREA – Refrigeration Related Equipment & Appliances

SCAQMD – South Coast Air Quality Management District

Small Appliance – Any of the following products that are fully manufactured, charged, and hermetically sealed in a factory with five pounds or less of refrigerant: refrigerators and freezers designed for home use, room air conditioners (including window air conditioners and packaged terminal air conditioners), packaged terminal heat pumps, dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.

Significant New Alternatives Policy (SNAP) – Program developed pursuant to section 612 of the Clean Air Act; designed to identify, evaluate, promote use of, publish lists of, and access overall risk to human/environmental communities from acceptable substitutes for ODSs.

Split System – An air conditioning system where the cold side ( expansion valve and the cold coil) is generally placed inside of the structure being cooled, and the hot side (condensing unit) is outside of the structure being cooled.

Technician – Any person, including contractors, who performs maintenance, service, or repair that could reasonably be expected to release class I (CFC) or class II (HCFC) substances from appliances, except for MVACs, into the atmosphere. Technician also means any person performing disposal of appliances; except for small appliances, MVACs, and MVAC-like appliances, that could be reasonably expected to release class I or class II refrigerants from appliances into the atmosphere.

USEPA – United States Environmental Protection Agency

4. Responsibilities

For a successful ODS/Reduction of Refrigerant Emissions Program at UCI, the following responsibilities have been defined from the bottom up. A flow chart (Figure 1) of the responsibilities is also provided.

4.1 Owners (of ODS's) will be responsible for notifying the proper party (e.g. FM HVAC Technicians, or EHS) of any leaks as soon as possible. The notification will by done by either:

4.1.1 Contacting EH&S at (949) 824-6200

4.1.2 Submitting a Facilities Maintenance Request Form (FMR).

4.2 Refrigerant Technician will be responsible for compliance with USEPA and SCAQMD requirements and the UCI ODS/Reduction of Refrigerant Emissions Program, specifically the following:

4.2.1 Complete required records for all refrigerant related activities;

4.2.2 Ensure recovery units meet evacuation requirements as detailed in USEPA regulations;

4.2.3 Follow procedures to eliminate refrigerant contamination and mixing;

4.2.4 Perform proper refrigerant recovery procedures as required;

4.2.5 Perform initial leak tests using an acceptable method prior to charging refrigerant into a system;

4.2.6 Perform annual leak audits on all equipment with greater than 50 pounds of refrigerant, and

4.2.7 Notify their Department Coordinator if a contractor is observed violating regulatory requirements.

4.3 Department Coordinator will have responsibility for following the ODS/Reduction of Refrigerant Emissions Program, specifically the following:

4.3.1 Ensure all technicians in their department follow the ODS/Reduction of Refrigerant Emissions Program,

4.3.2 Completely enter all data from refrigerant work done on campus in a timely manner into the RCM software,

4.3.3 Report any violations of the ODS/Reduction of Refrigerant Emissions Program by technicians or contractors to the Refrigerant Coordinator;

4.3.4 Maintain refrigerant recovery equipment certification;

4.3.5 Provide the equipment owner a record and/or invoice that indicates the amount of refrigerant added to all ODS appliances; and

4.3.6 Bi-annually maintain, check, leak test and document recovery unit maintenance pursuant to manufacturer's recommendations.

4.4 EH&S Refrigerant Coordinator will have the daily responsibility for implementing the ODS/Reduction of Refrigerant Emissions Program and shall communicate the refrigerant compliance issues to all affected UCI utility owners (e.g., appointed representative for each school/department), and Department Coordinators, for their respective area of responsibilities, specifically the following:

4.4.1 Implement the UCI ODS/Reduction of Refrigerant Emissions Program for UCI;

4.4.2 Working knowledge of USEPA and SCAQMD refrigerant regulations;

4.4.3 Prepare reports/documents that are required by USEPA and SCAQMD;

4.4.4 Maintain refrigerant equipment inventory list for the entire UCI campus;

4.4.5 Collect, maintain and input the contractor records from repair activities;

4.4.6 Maintain contact with Department Coordinators and service contractors;

4.4.7 Monitor HVAC, Central Plant, and Fleet Services Technician Certifications;

4.4.8 Identify equipment and services required to comply with regulations;

4.4.9 Assist in the transportation and disposal of used refrigerant, used oil, and parts;

4.4.10 Provide input to budget planning process for refrigerant management;

4.4.11 Ensure that proper training is provided for the HVAC, Central Plant and Fleet Services technicians;

4.4.12 Conduct periodic internal audits, using the attached checklist;

4.4.13 Assist in refrigerant safety equipment deployment; and

4.4.14 Report to the Environmental Programs Specialist .

4.5 EH&S Environmental Programs Specialist (EPS) will have the following responsibilities:

4.5.1 Lead a cross-organizational refrigerant compliance team with a goal of ensuring that all UCI facilities are aware of and comply with USEPA and SCAQMD requirements. Team members shall include representatives from HVAC/Central Plant, D&CS, Shop Stores, and any college representative with refrigerants in use and not under the HVAC/Central Plant shop's control;

4.5.2 Conduct periodic refrigerant compliance team meetings with selected team members and other refrigerant coordinators from various departments;

4.5.3 Provide regulatory assistance to the various campus groups in meeting their obligations in the area of refrigerant management, with the assistance of the Refrigerant Coordinator ;

4.5.4 Make certain that the Refrigerant Coordinator is certified and disseminate updates annually to the HVAC Technicians;

4.5.5 Interface with any regulatory agency which requests access to the campus;

4.5.6 Ensure proper reporting is made to the CARB and SCAQMD;

4.5.7 Process SCAQMD equipment registration every two years and report refrigerant usage activity;

4.5.8 Perform or arrange annual auditing of overall program performance;

4.5.9 Ensure, implement and maintain the refrigerant program;

4.5.10 Notify all non Utility Operations controlled facilities or UCI entities of this requirement;

4.5.11 Ensure that all UCI facilities that are not under control of the Utility Operations department are in compliance with USEPA and SCAQMD refrigerant regulatory requirements; and

4.5.12 Update the Director of Environmental Health and Safety on a regular basis of the compliance status of the campus refrigerant plan.

4.6 Assistant Vice Chancellor of Facilities Management (AVCFM) will be responsible for overall facilities operations and has the budget and authority to designate resources that enable the HVAC Technician(s) to be able to carry out responsibilities detailed in this program.

4.7 Director of Environmental Health and Safety (DEHS) shall delegate the responsibility of implementing the UCI ODS/Reduction of Refrigerant Emissions Program to the EPS.

Figure I - Responsibility Flow Chart

5. Program Components

5.1 The following is an overview of ODS management requirements for Refrigerant Related Equipment & Appliances. In addition, Table I summarizes the Groups in detail.

5.1.1 Require service practices that maximize recycling of ozone-depleting compounds (both chlorofluorocarbons [CFCs] and hydrochlorofluorocarbons [HCFCs] and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment.

5.1.2 Set certification requirements for recycling and recovery equipment, technicians, and reclaimers.

5.1.3 Restrict the sale of refrigerant to certified technicians.

5.1.4 Require persons servicing or disposing of air conditioning and refrigeration equipment to certify to EPA that they have acquired recycling or recovery equipment and are complying with the requirements of the rule.

5.1.5 Require the repair of substantial leaks in air conditioning and refrigeration equipment with a charge of greater than 50 pounds.

5.1.6 Establish safe disposal requirements to ensure removal of refrigerants from goods that enter the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, and room air conditioners).

5.2 The Prohibition on Venting of ODS's

Since July 1992, it has been unlawful to knowingly vent ODS refrigerants into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment (appliances). Only four types of ODS releases are now lawful:

5.2.1 “De minimis” quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.

5.2.2 Refrigerants emitted in the course of normal operation of air-conditioning and refrigeration equipment (as opposed to during the maintenance, servicing, repair, or disposal of this equipment) such as from mechanical purging and leaks. However, the repair of leaks is required for large equipment above a certain size (see Refrigerant Leaks).

5.2.3 Releases of CFCs or HCFCs that are not used as refrigerants. For instance, mixtures of nitrogen and R-22 that are used as holding charges or tracer gases used as leak test gases may be released because in these cases, the ozone-depleting compound is not used as a refrigerant. However, a technician may not avoid recovering refrigerant by adding nitrogen to a charged system; before nitrogen is added, the system must be evacuated to the appropriate level in Table II(http://www.epa.gov/ozone/title6/608/608evtab.html). Otherwise, the CFC or HCFC vented along with the nitrogen will be considered a refrigerant. Similarly, pure CFCs or HCFCs released from appliances will be presumed to be refrigerants and their release will be considered a violation of the prohibition on venting.

5.2.4 Small releases of refrigerant that result from purging hoses or from connecting or disconnecting hoses to charge or service appliances will not be considered violations of the prohibition on venting. However, recovery and recycling equipment manufactured after November 15, 1993 must be equipped with low-loss fittings.

Table I

Responsibility breakdown by group for work done on RREA's
Group Responsibilities

Facilities Management

•  HVAC

•  Fleet Services

•  Central Plant

•  Follow all Federal, State and Local guidelines for service, maintenance, repairs and recordkeeping pertaining to RREA's.

•  Fix leaks on equipment with a 50 lb or more charge within 14 days.

•  Ensure that all records are updated periodically in RM software.

•  Fix all leaks prior to charging system regardless of size of charge.

School Entities that use contractors to repair refrigerant containing devices

•  Ensure that leaks are repaired within 14 days of discovery on equipment with a 50 lb or more charge.

•  Report any emergencies and releases of refrigerant not covered by section 5.2 in the UCI ODS/Reduction of Refrigerant Emissions Program to the EH&S Refrigerant Coordinator.

•  Submit repair requests to EH&S via the website at http://ehs.uci.edu.


5.3 Service Practice Requirements Refrigerant Related Equipment & Appliances

5.3.1 Evacuation Requirements – Since July 13, 1993, technicians have been required to evacuate air-conditioning and refrigeration equipment to established vacuum levels when opening the equipment. If the technician's recovery or recycling equipment was manufactured any time before November 15, 1993, the air-conditioning and refrigeration equipment must be evacuated to the levels described in the first column of Table II ( http://www.epa.gov/ozone/title6/608/608evtab.html ). If the technician's recovery or recycling equipment was manufactured on or after November 15, 1993, the air-conditioning and refrigeration equipment must be evacuated to the levels described in the second column of Table II, and an EPA-approved equipment testing organization must have certified the recovery or recycling equipment. Persons who simply add refrigerant to (top-off) appliances are not required to evacuate the systems.

Technicians repairing small appliances, such as household refrigerators, window air conditioners, and water coolers, must recover:

80 percent 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;

OR

90 percent of the refrigerant when:

  • the technician uses recovery or recycling equipment manufactured after November 15, 1993; and
  • the compressor in the appliance is operating.

In order to ensure that they are recovering the correct percentage of refrigerant, technicians must use the recovery equipment according to the directions of its manufacturer. Technicians may also satisfy recovery requirements by evacuating the small appliance to four inches of mercury vacuum.

5.3.2 Exceptions to Evacuation Requirements – There are limited exceptions to the evacuation requirements for 1) repairs to leaky equipment and 2) repairs that are not major and not followed by an evacuation of the equipment to the environment.

If due to leaks, evacuation is not attainable or would substantially contaminate the refrigerant being recovered, persons opening the appliance must:

  • isolate leaking from non-leaking components wherever possible;
  • evacuate non-leaking components; and
  • evacuate leaking components to the lowest level that can be attained without substantially contaminating the refrigerant. This level cannot exceed 0 psig.

If evacuation of the equipment to the environment is not to be performed when repairs are complete and if the repair is not major, then the appliance must:

  • be evacuated to at least 0 psig before it is opened if it is a high or very high-pressure appliance; or
  • be pressurized to 0 psig before it is opened if it is a low-pressure appliance. Methods that require subsequent purging (e.g., nitrogen) cannot be used except with appliances containing R-113.

5.3.3 Reclamation Requirement – Refrigerants recovered and/or recycled can be returned to the same system or other systems owned by the same entity without restriction. If refrigerant changes ownership, however, that refrigerant must be reclaimed (i.e., cleaned to the Air Conditioning and Refrigeration Institute (ARI) 700-1993 standard of purity and chemically analyzed to verify that it meets this standard) unless the refrigerant was used only in a MVAC or MVAC-like appliance and will be used in the same type of appliance. Visit the EPA Hotline for an updated list of reclamation companies.

5.4 Recovery and Recycling

5.4.1 Equipment Certification – There is an established EPA certification program for recovery and recycling equipment. Under the program, all equipment manufactured on or after November 15, 1993 must be tested by an EPA-approved testing organization to ensure that it meets EPA requirements. Recycling and recovery equipment intended for use with air-conditioning and refrigeration equipment, besides small appliances, must be tested under the ARI 740-1993 test protocol. Recovery equipment intended for use with small appliances must be tested under either the ARI 740-1993 protocol or the protocol in Appendix C of 40 CFR Part 82 Subpart F.

Recovery efficiency standards vary depending on the size and type of air-conditioning or refrigeration equipment being serviced. Recovery equipment intended for use with small appliances must be able to recover 90 percent of the refrigerant in the small appliance when the small appliance compressor is operating and 80 percent of the refrigerant in the small appliance when the compressor is not operating. The EPA has approved both the ARI and Underwriters Laboratories (UL) to certify recycling and recovery equipment. Certified equipment can be identified by a label reading: “This equipment has been certified by ARI/UL to meet EPA's minimum requirements for recycling and/or recovery equipment intended for use with [appropriate category of appliance—e.g., small appliances, HCFC appliances containing less than 200 pounds of refrigerant, all high-pressure appliances, etc.].” Lists of certified equipment can be obtained by contacting ARI at 703-524-8800 and UL at 708-272-8800 ext. 42371.

5.4.2 Equipment Grandfathering – Equipment manufactured before November 15, 1993, including homemade equipment, may be grandfathered if it meets the standards in the first column of the EPA Table II ( http://www.epa.gov/ozone/title6/608/608evtab.html ), Required Levels of Evacuation for Appliances Except For Small Appliances, MVACs, and MVAC-like Appliances . Third party testing is not required for equipment manufactured before November 15, 1993, but equipment manufactured on or after that date, including homemade equipment, must be tested by a third-party (see Equipment Certification).

Table II

EPA 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, 1993

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

5.4.3 Refrigerant Leaks – Owners of equipment with charges of greater than 50 pounds are required to repair leaks in the equipment when those leaks together would result in the loss of more than a certain percentage of the equipment's charge over a year. Leaks must be repaired when the appliance leaks at a rate that would release 15 percent or more of the charge over a year.

The trigger for repair requirements is the current leak rate rather than the total quantity of refrigerant lost. For instance, owners of a commercial refrigeration system containing 100 pounds of charge must repair leaks if they find that the system has lost 10 pounds of charge over the past month; although 10 pounds represents only 10 percent of the system charge in this case, a leak rate of 10 pounds per month would result in the release of over 100 percent of the charge over the year. To track leak rates, owners of air-conditioning and refrigeration equipment with more than 50 pounds of charge must keep records of the quantity of refrigerant added to their equipment during servicing and maintenance procedures.

Owners are required to repair leaks within 14 days of discovery for RREA that has a charge of 50 pounds or greater (SCQAMD Rule 1415 (d)(3)). This requirement is waived if, within 14 days of discovery, owners develop a one-year retrofit or retirement plan for the leaking equipment. Owners of industrial process refrigeration equipment may qualify for additional time under certain circumstances. For example, if an industrial process shutdown is required to repair a leak, owners have 120 days to repair the leak. Owners or operators of leaky industrial process refrigeration equipment should see Section 608: Leak Repair fact sheet (http://www.epa.gov/ozone/title6/608/leak.html) and promptly notify EH&S. EH&S will assist with information concerning time extensions and pertinent recordkeeping and reporting requirements.

5.5 Technician Certification and Activities

Any maintenance, service, or repair of RREA at UCI (that could reasonably be expected to release refrigerants into the atmosphere) must only be performed by EPA-certified technicians. Technicians are required to pass an EPA-approved test given by an EPA-approved certifying organization to become certified under the mandatory program. The Hotline distributes current lists of approved testing organizations.

Any group on campus that performs any of the work above must have technicians who are properly certified to work on RREA.

5.1.1 The four types of EPA-certification are as follows:

  • For servicing small appliances (Type I);
  • For servicing or disposing of high or very high-pressure appliances except small appliances and MVACs (Type II);
  • For servicing or disposing of low-pressure appliances (Type III);
  • For servicing all types of equipment (Universal);
  • In addition, apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician.

5.5.2 EPA regulated activities specifically include the following:

  • Attaching and detaching hoses and gauges to and from the appliance to measure pressure within the appliance;
  • Adding refrigerant to or removing refrigerant from the appliance;
  • Any other activity that violates the integrity of the MVAC-like appliances, and small appliances.

5.6 Refrigerant Sales Restrictions

The sale of CFC-12 in containers smaller than 20 pounds is restricted solely to technicians certified under EPA's motor vehicle air conditioning regulations. EPA-certified technicians servicing appliances other than motor vehicle air conditioners may still buy containers of CFC-12 larger than 20 pounds. Effective November 14, 1994, the sale of refrigerants in any size container is restricted to technicians certified either under the program described in Technician Certification above or under EPA's motor vehicle air conditioning regulations. The sales restriction covers refrigerant contained in bulk containers (cylinders or drums) and pre-charged parts. The restriction excludes refrigerant contained in refrigerators or air conditioners with fully assembled refrigerant circuits (such as household refrigerators, window air conditioners, and packaged air conditioners), pure HFC refrigerants, and CFCs or HCFCs that are not intended for use as refrigerants. In addition, a restriction on sale of pre-charged split systems has been stayed (suspended) while EPA reconsiders this provision.

5.7 Certification by Owners of Recycling and Recovery Equipment

Technicians servicing or disposing of air-conditioning and refrigeration equipment at UCI must certify to EPA Region IX that they have acquired (e.g., built, bought, or leased) recovery or recycling equipment and are complying with the applicable requirements of this rule. A copy of the EPA Refrigerant Recovery or Recycling Device Acquisition Certification Form can be found at the following website: http://www.epa.gov/ozone/title6/608/recoveryform.pdf. This certification form must be filled out by the owner of the equipment, e.g., an FM Manager, who will then forward it to the EH&S Refrigerant Coordinator for review. The form will then be reviewed/approved, and signed by the EPS. EH&S will return a signed copy of the form back to the equipment O&M entity when sending it on to the EPA Region IX Office.

Note that this certification is a one-time requirement. Therefore, if a shop purchased a piece of CFC-12 recycling equipment in the past and sent the certification to EPA, the shop does not need to send a second certification to EPA when it purchases a second piece of equipment, no matter what refrigerant that equipment is designed to handle. Although owners of recycling and recovery equipment are required to list the number of trucks (or "service vehicles") based at their shops; they do not need to have a piece of recycling or recovery equipment for every truck. Outside contractors should certify their own equipment.

5.8 Reclaimer Certification

Reclaimers are required to return refrigerant to the purity level specified in ARI Standard 700-1993 (an industry set purity standard) and to verify this purity using the laboratory protocol set forth in the same standard. In addition, reclaimers must release no more than 1.5 percent of the refrigerant during the reclamation process and must dispose of wastes properly. Reclaimers must certify to the Section 608 Recycling Program Manager at EPA Headquarters that they are complying with these requirements and the information given is true and correct. Certification must also include the name and address of the reclaimer and a list of equipment used to reprocess and analyze the refrigerant. EPA encourages reclaimers to participate in a voluntary third-party reclaimer certification program operated by the Air-Conditioning and Refrigeration Institute (ARI). The voluntary program offered by ARI involves quarterly testing of random samples of reclaimed refrigerant. Third-party certification can enhance the attractiveness of a reclaimer's product by providing an objective assessment of its purity. EPA maintains a list of approved reclaimers that is available from the Hotline. In addition, a checklist helps prospective reclaimers provide appropriate information for EPA to review.

5.9 MVAC-Like Appliances

Some of the air conditioners that are covered by this rule are identical to motor vehicle air conditioners (MVACs) but they are not covered by the MVAC refrigerant recycling rule (40 CFR Part 82, Subpart B) because they are used in vehicles that are not defined as "motor vehicles." These air conditioners include many systems used in construction equipment, farm vehicles, boats, and airplanes. Like MVACs in cars and trucks, these air conditioners typically contain two or three pounds of CFC-12 and use open-drive compressors to cool the passenger compartments of vehicles. The EPA is defining these air conditioners as "MVAC-like appliances" and is applying the MVAC rule's requirements for the certification and use of recycling and recovery equipment to them. That is, technicians servicing MVAC-like appliances must "properly use" recycling or recovery equipment that has been certified to meet the MVAC standards. In addition, EPA is allowing technicians who service MVAC-like appliances to be certified by a certification program approved under the MVAC rule, if they wish.

5.10 Safe Disposal Requirements

Equipment that is typically dismantled on-site before disposal (e.g., retail food refrigeration, central residential air conditioning, chillers, and industrial process refrigeration) has to have the refrigerant recovered in accordance with EPA's requirements for servicing. However, equipment that typically enters the waste stream with the charge intact (e.g., motor vehicle air conditioners, household refrigerators and freezers, and room air conditioners) is subject to special safe disposal requirements. Under these requirements, the final person in the disposal chain at UCI (e.g., the HVAC Department Supervisor) is responsible for ensuring that refrigerant is recovered from equipment before the final disposal of the equipment, except for refrigerators, whereby the entire unit should be sent to the EH&S Hazardous Waste Yard and managed accordingly. Additional information on how to dispose of a household refrigerator can be found at https://ehs55.ehs.uci.edu:8443/waste/refrigcollect.jsp. However, persons (e.g., outside contractors) "upstream" can remove the refrigerant and provide documentation of its removal to the final person if this is more cost-effective.

If refrigerants are recycled or reclaimed, they are not considered hazardous under federal law. In addition, used oils contaminated with CFCs are not hazardous on the condition that:

  • They are not mixed with other waste;
  • They are subjected to CFC recycling or reclamation; or,
  • They are not mixed with used oils from other sources.

Used oils that contain CFCs after the CFC reclamation procedure, however, are subject to specification limits for used oil fuels if these oils are destined for burning. These oils are considered as hazardous waste. Individuals with questions regarding the proper handling of these materials should contact UCI EH&S at (949) 824-6200.

The equipment used to recover refrigerant from appliances prior to their final disposal must meet the same performance standards as equipment used prior to servicing, but it does not need to be tested by a laboratory. This means that self-built equipment is allowed as long as it meets the performance requirements. For MVACs and MVAC-like appliances, the performance requirement is 102 mm of mercury vacuum; and for small appliances, the recovery equipment performance requirements are 90 percent efficiency when the appliance compressor is operational and 80 percent efficiency when the appliance compressor is not operational.

Technician certification is not required, but is recommended, for individuals removing refrigerant from small appliances in the waste stream. The safe disposal requirements went into effect on July 13, 1993. Equipment must be registered or certified with the EPA (link to the sample form , or http://www.epa.gov/ozone/title6/608/recoveryform.pdf).

5.11 Major Recordkeeping Requirements

Technicians servicing RREA must provide the equipment owner (e.g., the building facilities manager or Lab PI) with a written invoice or record that indicates the amount of refrigerant added to the appliance.

Technicians must provide a copy of their proof of certification to UCI-EHS. (i.e., forward to EH&S Refrigerant Coordinator)

EH&S on behalf of the owners of appliances that contain ODS's will keep servicing records documenting the date and type of service, as well as the quantity of refrigerant added for a minimum of 5 years.

Wholesalers who sell CFC and HCFC refrigerants must retain invoices indicating the name of the purchaser, the date of sale, and the quantity of refrigerant purchased. Reclaimers must maintain records of the names and addresses of persons sending them material for reclamation and the quantity of material sent to them for reclamation. This information must be maintained on a transactional basis. Within 30 days of the end of the calendar year, reclaimers must report to EPA the total quantity of material sent to them that year for reclamation, the mass of refrigerant reclaimed that year, and the mass of waste products generated that year.

5.12 Requirements For Motor Vehicle Air Conditioners (MVACs)

One of the largest uses of CFC-12 refrigerant in the U.S. is in motor vehicle air conditioners (MVACs). The EPA has delegated to the South Coast Air Quality Management District (SCAQMD) the authority to establish requirements to prevent the release of refrigerants during the servicing of MVACs and to require recycling of refrigerants. Widespread refrigerant recycling reduces the demand for virgin ODS refrigerants and thus extends the time that they will be available. The following sections describe the requirements of the law and its potential impact on UCI.

5.12.1 Recycling vs. Reclamation – In the discussion below, recycling means the use of a machine to remove impurities and oil and then recharge the refrigerant into either the same car or a different car. Recycled refrigerant is not as pure as reclaimed refrigerant. Recycling occurs in the service shop.

Reclamation means the removal of all oil and impurities beyond that provided by on-site recycling equipment, and reclaimed refrigerant is essentially identical to new, unused refrigerant. Reclamation cannot be performed in the service shop. Rather, the shop generally sends refrigerant either back to the manufacturer or directly to a reclamation facility.

5.12.2 Requirements For All MVAC Refrigerants

  • Venting refrigerants containing any ODS is prohibited.
  • Approved Equipment – Technicians who repair or service MVACs must recover the refrigerant and either recycle it on-site, or send it off-site to a reclamation facility. Technicians must use EPA-approved equipment to perform the refrigerant recovery and recycling. A list of approved recover/recycle and recover-only equipment is available from the Hotline. Certain EPA-approved models can recycle both CFC-12 and HFC-134a refrigerants.

Note: Some CFC-12 recovery/recycling equipment can be converted for use with HFC-134a. However, technicians are prohibited from changing fittings on the same unit back and forth so that the unit is used for CFC-12 in the morning, HFC-134a in the afternoon, then back to CFC-12 again, etc. For refrigerant blends, see the Requirements Specific to Refrigerant Blends below.

  • Technician Training and Certification – Technicians who repair or service MVACs must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12, he does not need to be recertified to handle HFC-134a or refrigerant blends. A list of approved MVAC training and certification programs is available from the Hotline.

  • Recordkeeping Requirements – Service shops must certify to EPA that they own EPA-approved refrigerant recovery or recycling equipment. Note that this certification is a one-time requirement. Therefore, if a shop purchased a piece of CFC-12 recycling equipment in the past and sent the certification to EPA, the shop does not need to send a second certification to EPA when it purchases a second piece of equipment, no matter what refrigerant that equipment is designed to handle. If refrigerant is recovered and sent to a reclamation facility, the shop must retain the name and address of that reclaimer.

  • Sales Restrictions - The sale of ODS refrigerants is restricted to only EPA-certified technicians.

5.12.3 Requirements Specific to Refrigerant Blends

  • Using Older Equipment to Recover Blends - Technicians have a number of choices in recovering blend refrigerants. One option is that a technician may permanently dedicate an older piece of equipment he owns to recovering one or more blend refrigerants. The technician may also use this equipment to recover contaminated CFC-12 and HFC-134a and other "mystery mixtures." This equipment, however, may no longer be used to recover uncontaminated CFC-12 or HFC-134a. Refrigerant recovered using this kind of "junk" tank must then be shipped off-site for reclamation or destruction.
  • Using New Equipment to Recover Blends - Another option for recovering a blend refrigerant is to use a new piece of EPA-approved equipment designed to recover, but not recycle, any single specific blend refrigerant.
  • Recycling Blends - Recycling of refrigerant blends used in motor vehicle air conditioning systems (MVACs) is allowed, provided that: a) recycling equipment meets a new Underwriters Laboratories (UL) standard (Standard 2964) and, b) refrigerant is returned to the vehicle from which it was removed. The only exception to item b) is for fleets of vehicles with a common owner; recycled blend refrigerant may be moved among vehicles within such a fleet. The EPA adopted a new UL standard into regulation and grandfathered any equipment that (1) meets the UL standard and (2) is purchased before the date on which EPA published the UL standard rule.
  • Converting CFC-12 or HFC-134a Recycle Equipment for Use with Blend Substitutes - Conversion of existing CFC-12 or HFC-134a recycling equipment for either temporary or permanent use with a blend refrigerant is prohibited unless the equipment is used only to recover, but not to recycle, the refrigerant. In the future, the EPA may issue regulations allowing these conversions but placing certain restrictions on who performs the conversions, what models may be converted, etc.

5.12.4 Retrofitting Vehicles to Alternative Refrigerant – When retrofitting a MVAC for use with another refrigerant (e.g., replacing CFC-12 with a blend), the technician must do the following:

  • Extract the CFC-12;
  • Cover the CFC-12 label with a label that indicates the new refrigerant in the system and other information;
  • Affix new fittings unique to that refrigerant;
  • In addition, if a technician is retrofitting a vehicle to a refrigerant that contains R-22, the technician must make certain that only barrier hoses are used in the A/C system; and
  • Finally, if the system includes a pressure relief device, the technician must install a high-pressure compressor shutoff switch to prevent the compressor from increasing pressure until the refrigerant is vented.

More information about the Significant New Alternatives Policy program and about retrofitting procedures is available in a fact sheet called "Choosing and Using Alternative Refrigerants" through the EPA's Ozone Hotline (800-296-1996).

6. Laws and Regulations Referenced on ODS

6.1 State Laws

6.1.1 Authority, Permits and New Source Requirements

•  Air Resources Board Powers, Duties, And Requirements

Health and Safety Code §§39608-39650

•  Local Air Pollution Control District or Local Air Quality Management District Powers, Duties, and Requirements

Health and Safety Code §§40150-43020

6.1.2 Toxic Air Contaminants

•  Identification of Toxic Air Contaminants

Health and Safety Code §§39660.5-39664

6.1.3 Air Toxic Hot Spots

•  Facilities Subject to Rules and Emission Inventories

Health and Safety Code §§44300-44346

•  Risk Assessment

Health and Safety Code §§44360-44384

6.2 Federal Laws

6.2.1 Authority, Permits and New Source Requirements

•  Clean Air Act

42 USC §§7401-7642

6.3 State Regulations

6.3.1 Authority, Permits and New Source Requirements

•  Air Resources Board Powers, Duties, And Requirements

17 CCR §§60000-60053

•  Local Air Pollution Control District or Local Air Quality Management District Powers, Duties, and Requirements

17 CCR §§80100-90623


6.3.2 Toxic Air Contaminants

•  Identification of Toxic Air Contaminants Identification Procedures

17 CCR §§91200-91220; 94100-94145


6.3.3 Air Toxic Hot Spots

•  Facilities Subject to Rules and Emission Inventories

17 CCR §§90700-90704. [§93300 et seq. were repealed 9/96 and replaced with non-regulatory “Emissions Inventory Criteria and Guidelines”]

6.4 Local Regulations

6.4.1 Authority, Permits and New Source Requirements

•  South Coast Air Quality Management District – SCAQMD

SCAQMD Rules 1411 & 1415 [Recovery or Recycling of Refrigerants from Motor Vehicle Air Conditioners & Reduction of Refrigerant Emissions from Stationary Refrigeration and Air Conditioning Systems, respectively]


6.5 Federal Regulations

6.5.1 Authority, Permits and New Source Requirements

•  Air Programs, Generally

40 CFR §§50-99

•  Title VI of The Clean Air Act

40 CFR §§82, Sections 608 & 609

•  New Source Performance Standards

40 CFR §§60

•  Hazardous Air Pollutant Standards

40 CFR §§61

7. Training Requirements and Competency Assessment

7.1 Technician Certification.

7.1.1 See Section 5.7

7.1.2 HVAC Technicians to receive any changes/updates to EPA regulations from Refrigerant Coordinator

7.2 Refrigerant Coordinator

7.2.1 Attend annual refresher training sponsored by an EPA-approved institution (e.g., Environmental Support Solutions)

7.3 Questions regarding training should be directed to the Environmental Programs Specialist at (949) 824-6200.

Self - Audit Checklist (For Internal Use Only)

INITIATOR: Dick T. Sun
DATE: 10/2014

University of California, Irvine Environmental Health & Safety
4600 Bison Avenue, Irvine, CA 92697-2725 (949) 824-6200, Fax (949) 824-8539
Copyright@2014