Refrigerants can impact our environment when emissions from equipment are released. Refrigerants can contain ozone-depleting chlorofluorocarbons (CFC) and hydrochlorofluorocarbons (HCFC) or substitutes that include hydrofluorocarbons (HFC), Hydrofluro-Olefins (HFO) or perfluorocarbons (PFC). HFCs were introduced as a less toxic alternative to CFCs because they do not contribute as severely to the destruction of the ozone layer; however, HFCs are powerful greenhouse gasses that can contribute to global warming.
The College is highly committed to the safety of employees and the entire MHC community, as well as environmental health and sustainability. We comply with the Massachusetts Department of Environmental Protection (DEP) and U.S. Environmental Protection Agency (EPA) regulations governing refrigerant emissions and equipment: Section 608 of the Clean Air Act . Massachusetts is banning certain HFCs in phases (310 CMR 7.76) and the College will ensure that new installations meet these requirements.
Certified Technicians from Facilities Management and Dining Services maintain all campus systems that contain refrigerants. Technicians must be trained and pass an EPA-approved test given by an approved certifying organization to become certified under Section 608 - these certification credentials do not expire. Technicians must keep a copy of their proof of certification at their shop.
In 2020, the EPA modified their refrigerant management regulations to cover only ozone-depleting refrigerants. Substitute refrigerants (HFCs, HFOs and PFCs) that are not ozone-depleting substances (ODS) are no longer subject to some of the requirements of the National Refrigerants Management Program; however, the College continues to track this information for Greenhouse Gas (GHG) reporting requirements and our sustainability efforts. EPA continues to monitor and update their Unacceptable Substitute Refrigerants list on the basis of potential for ozone depletion, global warming or other environmental and health risks.
Recordkeeping requirements apply to appliances that contain 50 pounds or more of refrigerant. Again, EPA only requires this for ODS, but the College tracks this information for all affected appliances. Technicians must maintain a “Refrigerant Use Log”, which must be kept for 3 years. The log must detail the appliance location, date of service, description of service, amount and type of refrigerant added and any other information relevant to the service performed or repair made. Technicians must also track refrigerant purchases by recording the date, type and amount of refrigerant purchased on the log.
Outside contractors servicing appliances containing 50 pounds or more of refrigerant must provide the College with an invoice or other record detailing the date, amount of refrigerant added and the service performed. Contractors must provide the College with these records even if the refrigerant is not an ODS. The Technician will keep these records for 3 years.
Appliances containing 50 pounds or more of refrigerant are located in the following areas:
- Art Building: Two air conditioning units containing approximately 150 pounds of refrigerant, each.
- Carr Laboratory: One air conditioning unit on the roof containing approximately 60 pounds of refrigerant.
- Clapp Laboratory: One air conditioning unit in room 19 containing approximately 50 pounds of refrigerant.
- Dining Services: One freezer and one refrigeration unit in the warehouse containing approximately 350 pounds of refrigerant, each.
- Kendade: Two chiller units in the basement mechanical room containing approximately 3000 pounds of refrigerant, each. Two air conditioning units in the lower level computer room containing approximately 60 pounds of refrigerant.
- Williston Library: One chiller unit on the roof containing approximately 460 pounds of refrigerant.
- Willits-Hallowell: One chiller unit in the basement containing approximately 300 pounds of refrigerant.
MHC Technicians must work in a manner that protects themselves and the community and follow all precautions pertaining to working with refrigerants, including proper handling of compressed gasses, working with proper ventilation, protection from frostbite and other job safety requirements. Only Technicians that have been certified in accordance with 40 CFR, Part 82, Subpart F are authorized to service, maintain, and repair equipment or perform activities that could potentially release refrigerants into the atmosphere.
- Venting, or knowingly releasing refrigerants into the atmosphere, is prohibited, with the exception of “de minimis” quantities released during good faith attempts during recovery, recycling or disposal.
- Technicians must evacuate the refrigerant prior to servicing, disposing of, or otherwise opening the equipment. A minimum of 90 percent of the refrigerant must be recovered.
- After evacuating an appliance and before keeping it outdoors, putting in the metal dumpster or otherwise discarding, the Technician must label the unit indicating that it has been evacuated of refrigerant, oil, and/or any other material required to render it safe for disposal.
- Mount Holyoke College has a self-contained refrigerant recovery device that meets EPA, UL, and ARI requirements and has certified this equipment with EPA Region 1. This certification does not need to be updated, even if the recovery device is replaced.
- Leaks in equipment containing charges of more than 50 pounds of refrigerant must be repaired within 30 days of discovery when the leak rate would release 15 percent or more of the charge in a one year period. Authorized HVAC/Steamfitter or Dining Services personnel are responsible for calculating leak rates, taking prompt corrective action and for following up 30 days after repair to ensure the unit is not leaking and is functioning properly.
- 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.
- Refrigerant vapors displace air and present an asphyxiation hazard in confined spaces; therefore, Mount Holyoke College employees are prohibited from working with refrigerant in confined spaces. Overexposure to refrigerant can cause dizziness and loss of concentration. The Technician must ensure that there is adequate ventilation prior to working with refrigerants.
- 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.
- Recovered refrigerant can be returned to the same system or other Mount Holyoke College-owned systems without restriction.
- In the event that Mount Holyoke College was to release ownership of the refrigerant to another party, the refrigerant would have to be reclaimed.
- Refrigerants that are recycled or reclaimed are not considered hazardous waste, as long as they are not mixed with used oils or other waste.
- Refrigerant-contaminated oil is hazardous waste. This waste cannot be mixed with other waste oils. Refrigerant-contaminated waste oil will be collected in a properly labeled hazardous waste container and will be shipped off site for disposal, documented by a hazardous waste manifest.
This program will be reviewed by the Facilities Management and Dining Services Technicians and EH&S and will be updated if our processes or regulatory requirements change. The review will also evaluate if there are ways to improve worker safety and further minimize environmental impacts.
If you want to learn more about refrigerants in your own home, please reference EPA’s Stationary Refrigeration Resources for Homeowners.
If you have questions about this policy, please write to ehs@mtholyoke.edu.
