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Complying With The
Section 608 Refrigerant Recycling Rule
OZONE PROTECTION HOTLINE TOLL-FREE (800)
296-1996
This fact sheet provides an overview of the
refrigerant recycling requirements of Section 608
of the Clean Air Act of 1990, as amended (CAA), including final
regulations published on
May 14, 1993 (58 FR 28660), August 19, 1994 (59 FR 42950), and
November 9, 1994 (59 FR
55912). The fact sheet also describes the prohibition on venting
that became effective on July
1, 1992.
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).
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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.
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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.
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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.
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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.
A longer fact sheet about leak repair is also available from the
hotline.
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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 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."
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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.
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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.
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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.
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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 $25,000 per day
for any violation of these regulations.
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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.
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