FSU Refrigerant Management

Florida State University is required by the Environmental Protection Agency (EPA) to keep three (3) years of records for any work involving the addition, removal, recycling, recovery, or reclamation of refrigerant to any appliance. FSU must additionally keep records of the installation and/or disposal of refrigerant-containing appliances and their associated refrigerant. These recordkeeping requirements achieve compliance with EPA regulations 40 CFR Part 82, Subpart F and Clean Air Act, Title VI – Stratospheric Ozone Protection, Section 608. Noncompliance can result in fines up to $37,500 per day, per appliance, per violation.

The following forms have been developed in accordance with Section 608 regulations as well as updates to the regulations that went into effect as of January 1, 2018 and additional updates that will go into effect as of January 1, 2019. The forms will be used to keep records of refrigerant as well as to trigger EPA leak-reporting and appliance retirement/retrofit reporting requirements. In the following forms, a “medium” appliance refers to a refrigerant-containing appliance that contains 5-50 lbs. of refrigerant and a “large” appliance refers to a refrigerant-containing appliance that contains >50 lbs. of refrigerant. Please find descriptions of each of the forms below.

Each of these forms must be completed in full and submitted within three (3) days of completion of any associated maintenance or inspection. Submit completed forms in electronic or paper format to the Air Resource Manager.

Form 1: Scheduled Preventative Maintenance/Corrective Maintenance is required for any maintenance (preventative and/or corrective) for medium and large appliances (medium appliances are exempt from sections II.D-II.G). If Form 1 is being completed in response to a leak that constitutes 10% or more of a large appliance’s full charge, additional leak tests are required quarterly until the appliance has leaked under 10% for one full year. If, throughout the course of a calendar year, the appliance leaks 125% or more of its full charge, a report must be submitted to the EPA before March 1 of that reporting year. Notify FSU’s Air Resource Manager if a leak of this magnitude is detected or suspected (see Forms 6 & 7).

Form 2: Initial Leak Verification Test is required after the repair of large appliances with a refrigerant leak of 10% or more. The Initial Leak Verification Test is to be conducted after the repair is finished to verify that a leak or leaks have been repaired before the appliance is recharged with refrigerant. The repair(s) and test must be completed within 30 days of discovering a leak that constitutes 10% or more of an appliance’s full charge of refrigerant. The successful completion of the Initial Leak Verification Test triggers the requirement to complete a Follow-up Verification Test (see Form 3) within 10 days. The Initial Leak Verification Test may be completed as many times as necessary within the 30-day timeline until completed successfully (i.e. leak(s) repaired). In the event that it cannot be completed successfully within 30 days, either because of an unidentifiable leak or continued leak after repair, contact FSU’s Air Resource Manager to complete either: 1) a request to be submitted to the EPA for an extension, or 2) a retrofit or retirement plan to be executed within one year (see Form 6).

Form 3: Follow-up Leak Verification Test is required for large appliances with a refrigerant leak of 10% of more. The Follow-up Leak Verification Test must be completed within 10 days from the successful completion of the Initial Leak Verification Test and after the appliance has been recharged with refrigerant and returned to normal operating characteristics and conditions.

Form 4: Medium & Large Appliance Disposal Information is required upon disposal of medium and large appliances. The purpose is to track the disposal of the appliance and the refrigerant that it contains.

Form 5: Medium & Large Appliance Installation Information is required upon installation of medium and large appliances. The purpose is to track the installation of the appliance and the refrigerant that it contains.

Form 6: Large Appliance Retrofit or Retirement Plan is required when proposing the retrofit or retirement of any large refrigerant-containing appliance for any reason. The retrofit or retirement plan must be: signed by an authorized FSU official, accessible at the site of the appliance (paper copy or electronic format), and available for EPA inspection upon request. Retrofit or retirement may be due to the end of the appliance’s lifecycle, an upgrade of equipment, chronic maintenance issues, or as a result of exceeding the EPA-defined annual trigger leak rate of 125%. If the retrofit or retirement is due to exceeding EPA-defined annual leak rate, the plan must be created within 30 days of the discovery that the annual leak rate threshold was exceeded.

Additional documents that need to be submitted along with either plan include: documentation of all repairs completed and attempted (all instances of Forms 2 & 3 associated with the appliance) and a schedule for completion of the plan within a year’s time. In the case of a retrofit, the plan must include records of the repair of all identified leaks and an itemized procedure for converting the appliance to a different refrigerant, including changes required for compatibility with the new substitute. Unless granted additional time by the EPA, all work performed in accordance with the preset plan for retrofit or retirement must be executed within one year of the plan’s creation. If an extension is needed, a request must be submitted to the EPA within seven months of discovering the appliance exceeded the applicable leak rate.

Form 7: Large Appliance 125% Leak Reporting is required when a large appliance has leaked 125% or more of its full charge in one calendar year (Jan. 1st – Dec. 31st). This report must be submitted by the FSU Air Resource Manager electronically to 608reports@epa.gov by March 1st of the subsequent year and describe all efforts to identify leaks and repair the appliance.

Additional documents that need to be submitted along with this report include: All records of maintenance (all instances of Form 1), records of all initial leak verification tests (all instances of Form 2), and records of all follow-up leak verification tests (all instances of Form 3). For more information, see the Code of Federal Regulations, Title 40, §82.166 – Reporting and recordkeeping requirements for leak repair.

Form 8 & Form 9: Transfer of Custody of Small Appliance and Certification of Refrigerant Recovery from Small Appliance is required for the transfer of custody of any small refrigerant-containing appliances owned by Florida State University to an approved, EPA Certified vendor. Specifically, it confirms that these appliances have not yet had the refrigerant recovered from them, and that any future recovery, reclamation, or disposal of refrigerant from any of these devices is now the responsibility of the vendor. Further, it confirms that when recovery, reclamation, or disposal of refrigerant from any of these appliances is conducted, it will be conducted by an EPA certified technician and disposed of/used in a manner compliant with EPA regulations.