Refrigerant Recycling

Overview

Under Section 608 of the CAA, EPA has established regulations that:

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.

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

Restrict the sale of refrigerant to certified technicians.

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.

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

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).

The Prohibition on Venting

Effective July 1, 1992, Section 608 of the Act prohibits individuals from knowingly venting ozone-depleting compounds (generally CFCs and HCFCs) used as refrigerants into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment (appliances). Only four types of releases are permitted under the prohibition:

1. "De minimis" quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.
   
   
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, EPA requires the repair of leaks above a certain size in large equipment (see Refrigerant Leaks).
   
   
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 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 1. 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.
   
   
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.

Regulatory Requirements

Service Practice Requirements

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 1. 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 1, and the recovery or recycling equipment must have been certified by an EPA-approved equipment testing organization. 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 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.
   
   
2. Exceptions to Evacuation Requirements
   
   EPA has established limited exceptions to its evacuation requirements for 1) repairs to leaky equipment and 2) repairs that are not major and that are not followed by an evacuation of the equipment to the environment.
   
   If, due to leaks, evacuation to the levels in Table 1 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 to the levels in Table 1; 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.
3. Reclamation Requirement
   
   EPA has also established that refrigerant recovered and/or recycled can be returned to the same system or other systems owned by the same person without restriction. If refrigerant changes ownership, however, that refrigerant must be reclaimed (i.e., cleaned to the ARI 700-1993 standard of purity and chemically analyzed to verify that it meets this standard) 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. (Refrigerant used in MVACs and MVAC-like appliances is subject to the purity requirements of the MVAC regulations at 40 CFR Part 82 Subpart B.) EPA updates the list of reclaimers as new companies are added.

Equipment Certification

The Agency has established a certification program for recovery and recycling equipment. Under the program, EPA requires that equipment manufactured on or after November 15, 1993, 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, which is included in the final rule as Appendix B. Recovery equipment intended for use with small appliances must be tested under either the ARI 740-1993 protocol or Appendix C of the final rule.

The Agency requires recovery efficiency standards that vary depending on the size and type of air-conditioning or refrigeration equipment being serviced. For recovery and recycling equipment intended for use with air-conditioning and refrigeration equipment besides small appliances, these standards are the same as those in the second column of Table 1. 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.

EPA has approved both the Air-Conditioning and Refrigeration Institute (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 may be obtained by contacting ARI at 703-524-8800 and UL at 708-272-8800 ext. 42371.

Equipment Grandfathering

Equipment manufactured before November 15, 1993, including home-made equipment, may be grandfathered if it meets the standards in the first column of Table 1. Third-party testing is not required for equipment manufactured before November 15, 1993, but equipment manufactured on or after that date, including home-made equipment, must be tested by a third-party (Equipment Certification).

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. For the commercial and industrial process refrigeration sectors, leaks must be repaired when the appliance leaks at a rate that would release 35 percent or more of the charge over a year. For all other sectors, including comfort cooling, 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 30 days of discovery. This requirement is waived if, within 30 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 of leaky industrial process refrigeration equipment should see the Compliance Assistance Guidance Document for Leak Repair (available from the hotline) for additional information concerning time extensions and pertinent recordkeeping and reporting requirements. EPA anticipates putting this document on the web site, but does not have an estimated date for when that will happen.

Technician Certification

EPA has established a technician certification program for persons ("technicians") who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphere. The definition of "technician" specifically includes and excludes certain activities as follows:

Included:

• 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 refrigerant circuit while there is refrigerant in the appliance.

Excluded:

• activities that are not reasonably expected to violate the integrity of the refrigerant circuit, such as painting the appliance, re-wiring an external electrical circuit, replacing insulation on a length of pipe, or tightening nuts and bolts on the appliance;
  
  
• maintenance, service, repair, or disposal of appliances that have already been evacuated in accordance with EPA requirements, unless the maintenance consists of adding refrigerant to the appliance;
  
  
• servicing motor vehicle air conditioners (MVACs), which are subject to the certification requirements of the MVAC refrigerant recycling rule; and,
  
  
• disposing of MVACs, MVAC-like appliances, and small appliances.

In addition, apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician.

The Agency has developed four types of certification:

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).

Technicians are required to pass an EPA-approved test given by an EPA-approved certifying organization to become certified under the mandatory program. The Stratospheric Ozone Hotline distributes lists of approved testing organizations.

Refrigerant Sales Restrictions

Under Section 609 of the Clean Air Act, sales of CFC-12 in containers smaller than 20 pounds are restricted solely to technicians certified under EPA's motor vehicle air conditioning regulations. Persons 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 refrigerant 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.

More detailed information is available in an EPA fact sheet titled "The Refrigerant Sales Restriction."

Certification by Owners of Recycling and Recovery Equipment

EPA requires that persons servicing or disposing of air-conditioning and refrigeration equipment certify to the appropriate EPA Regional Office that they have acquired (built, bought, or leased) recovery or recycling equipment and that they are complying with the applicable requirements of this rule. This certification must be signed by the owner of the equipment or another responsible officer and sent to the appropriate EPA Regional Office. A sample form for this certification is attached. Although owners of recycling and recovery equipment are required to list the number of trucks based at their shops, they do not need to have a piece of recycling or recovery equipment for every truck. Owners do not have to send in a new form each time they add recycling or recovery equipment to their inventory.

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 that 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 to analyze the refrigerant.

EPA encourages reclaimers to participate in third-party reclaimer certification programs, such as that operated by the Air-Conditioning and Refrigeration Institute (ARI). 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.

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. (Vehicle air conditioners utilizing HCFC-22 are not included in this group and are therefore subject to the requirements outlined above for HCFC-22 equipment.) 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 standards in Appendix A to 40 CFR Part 82, Subpart B. 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.

More detailed information is presented in an EPA fact sheet titled "Servicing Farm and Heavy-Duty Equipment."

Safe Disposal Requirements

Under EPA's rule, 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 (e.g., a scrap metal recycler or landfill owner) is responsible for ensuring that refrigerant is recovered from equipment before the final disposal of the equipment. However, persons "upstream" can remove the refrigerant and provide documentation of its removal to the final person if this is more cost-effective.

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 for individuals removing refrigerant from appliances in the waste stream.

The safe disposal requirements went into effect on July 13, 1993. Equipment must be registered or certified with the Agency. A sample form is attached.

Major Recordkeeping Requirements

Technicians servicing appliances that contain 50 or more pounds of refrigerant must provide the owner with an invoice that indicates the amount of refrigerant added to the appliance. Technicians must also keep a copy of their proof of certification at their place of business.

Owners of appliances that contain 50 or more pounds of refrigerant must keep servicing records documenting the date and type of service, as well as the quantity of refrigerant added.

Wholesalers who sell CFC and HCFC refrigerants must retain invoices that indicate 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.

Hazardous Waste Disposal

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.
  
  
• 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. Individuals with questions regarding the proper handling of these materials should contact EPA's RCRA Hotline at 800-424-9346 or 703-920-9810.

Enforcement

EPA is performing random inspections, responding to tips, and pursuing potential cases against violators. Under the Act, EPA is authorized to assess fines of up to $27,500 per day for any violation of these regulations.

Planning and Acting for the Future

Observing the refrigerant recycling regulations for Section 608 is essential in order to conserve existing stocks of refrigerants, as well as to comply with Clean Air Act requirements. However, owners of equipment that contains CFC refrigerants should look beyond the immediate need to maintain existing equipment in working order. EPA urges equipment owners to act now and prepare for the phaseout of CFC production and import, scheduled for January 1, 1996. Owners are advised to begin planning for conversion or replacement of existing equipment with equipment that uses alternative refrigerants.

To assist owners, suppliers, technicians and others involved in comfort chiller and commercial refrigeration management, EPA has published a series of short fact sheets and expects to produce additional material. Copies of material produced by the EPA Stratospheric Protection Division are available from the Stratospheric Ozone Information Hotline (see hotline number below).

For Further Information

For further information concerning regulations related to stratospheric ozone protection, please call the Stratospheric Ozone Information Hotline: 800-296-1996. The Hotline is open between 10:00 AM and 4:00 PM, Eastern Time.