EPA Proposes New Refrigerant Recycling Rules

The Environmental Protection Agency proposes to regulate the recycling of refrigerants used as substitutes for HCFC and HFC refrigerants. This new rule, which was published in the Federal Register as Air Docket No A-92-01 VIII.H on June 11, 1998, proposes to prohibit venting substitute refrigerants to the air and to require that substitute refrigerants be evacuated from refrigeration systems before those systems are discarded.

EPA proposes to alter existing leak repair requirements in recognition of design changes to refrigeration equipment that have resulted in achievement of lower leak rates. The agency says the new rule is designed to minimize environmental harm that might result during the transition phase away from CFC and HCFC refrigerants. This potential harm includes ozone depletion and a new emphasis on global warming.

EPA justifies extending the leak rate and leak repair regulations to HFCs and PFCs by stating that to do otherwise would result in dual regulations. The agency argues that equipment operators who were not required to repair leaks in HFC or PFC equipment might well neglect repairs to CFC- or HCFC-charged refrigeration systems. EPA says that no substantial technological differences exist between refrigeration systems charged with HFCs or PFCs and those charged with CFCs or HCFCs. Therefore, leak repair regulations for HFC or PFC systems would impose no new economic burdens.

EPA already has rules prohibiting release of CFC and HCFC refrigerants. The proposed rule extends this ban to first and second generation substitutes. In the proposed rule, a substitute is any chemical that is used in place of CFC or HCFC refrigerants whether that chemical was intended as a substitute or not. This includes chemicals used directly to replace a CFC or HCFC and compounds used to replace chemicals that originally replaced CFCs or HCFCs. Under this proposed rule, EPA says that ammonia would be considered a substitute because some cold storage warehouses have used ammonia to replace CFC or HCFC refrigerants.

The new rule proposes to extend the existing regulatory framework governing CFCs and HCFCs to cover HFCs and PFCs (perfluorocarbons). This extension would prescribe evacuation levels for refrigeration systems containing HFCs or PFCs. Recycling and recovery equipment used with these compounds would have to be certified as would the technicians who work with them. Sales of HFCs or PFCs would be restricted to certified technicians. Used refrigerant would have to be tested to ensure that it meets minimum purity standards. Refrigeration systems charged with these compounds would have to be evacuated prior to disposal.

Although EPA defines ammonia and chlorine as substitute refrigerants, it does not propose to call their release a threat to the environment. Release of these gases is adequately controlled by other regulations, the agency says. The same proposals apply to hydrocarbons such as propane that are sometimes used as refrigerant gases.

EPA's proposal would require certification of refrigerant recovery and recycling equipment to the same refrigerant evacuation standards for HFC or PFC refrigerants that such equipment already must meet for CFC or HCFC refrigerants. For compliance with the Clean Air Act, refrigeration service technicians must make a good faith effort to recover refrigerants by using equipment that minimizes release of refrigerants to the atmosphere. Certified recovery equipment for substitute refrigerants would help reach EPA goals, the proposal says.

Properly certified recovery equipment would be able to clear itself when it is switched from one refrigerant to another. Refrigerants that become mixed in a recovery device are almost impossible to reclaim and extremely expensive to destroy, EPA says. Contaminated or mixed refrigerants are much more likely to be vented as a method of disposal.

Certification of recovery equipment used for HFC or PFC refrigerants should maximize recovery and recycling of CFCs and HCFCs, EPA's proposal says. A technician could use a recovery system certified for HFCs and PFCs to recycle CFCs and HCFCs, because no physical difference exists between the four classes of refrigerants that would prevent use of the same equipment.

All equipment should be certified, EPA says, because uncertified equipment is likely to be less expensive than certified equipment. This price differential could persuade some technicians to purchase uncertified equipment for use with CFCs and HCFCs. Failure to require certification for recovery equipment used for HFCs and PFCs would undermine the certification program for equipment used to recover CFCs and HCFCs, and result in more releases of the ozone-depleting chemicals , the agency argues.

EPA makes the same argument for technician certification. Without technician certification, an economic incentive could arise for technicians who work only with HFCs or PFCs. Without proper training and certification, these technicians might be more likely to release refrigerants into the atmosphere.

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