EPA Regulations and CFC Chiller Retirement

Maintenance and disposal of CFC-, PFC- and HCFC-containing appliances are regulated by the Clean Air Act.

Refrigerant Recovery and Dismantling Process

Equipment that is usually dismantled on-site before disposal -- for example, cold storage warehouse refrigeration, chillers and industrial process refrigeration -- must have the refrigerant recovered before the equipment is dismantled.

Under the regulations, the person who disposes or dismantles an appliance must either recover all refrigerant or obtain verification that the refrigerant already has been recovered. This verification must include the date of the recovery as well as the name and address of the person who performed the recovery. Keep in mind that proof of verification does not relieve the disposer of the responsibility of recovering any remaining refrigerant.

When disposing of refrigerants or refrigeration equipment, the Environmental Protection Agency requires that records be kept on file and made available for at least three years. These records must include the amount of refrigerant recovered, prior ownership of the equipment and the future ownership or disposition of the retired equipment. It also is wise to keep records on the type of equipment salvaged and the amount of oil removed as well as technician training certificates, recovery machine information and repair records on the recovery equipment.

Refrigerant must be cleaned or reprocessed to standard ARI-700-99 when reused in equipment other than the original owner's equipment. Once the refrigerant is recovered, you can sell or deposit it with a refrigeration wholesaler who represents and collects for a parent reclaiming company. The Salvage Section of 40 CFR 82 Subpart F of Title VI of the Clean Air Act governs reclamation companies. The reclamation company must have all of a system's recovered refrigerant before the refrigerant can be reprocessed and then returned to your equipment or sold for use in other refrigeration equipment.

Disposal of Refrigerant Waste Oils

To dispose of refrigerant oils, collect the oil from the recovery unit and appliance by draining it until it is no longer free-flowing. Be aware that oil from air-conditioning equipment may contain halogens. However, when refrigerant oils are separated from other waste oils, they are not classified as hazardous waste. Be sure to measure and record the quantities of oil recovered, then deposit the oil in a properly labeled 55-gal drum or other appropriate container. Do not fill containers more than 90% full; leave the remaining 10% for expansion.

Do not mix refrigerant oil with other waste oils. If you must store the oil prior to removal off-site, hold these containers in a diked area or a containment vessel. When you have recovered enough refrigerant waste oil to validate disposal, contact a properly licensed waste oil company to remove the used oil from your facility. The company can test the oil to determine its condition.

If testing reveals that the used oil exceeds regulatory limits for toxicity, it then must be classified as hazardous waste. It is your responsibility to safely and legally dispose of the hazardous oil. If you produce no more than 100 kg (about 220 lbs. or 25 gal) of hazardous waste oil, or no more than 1 kg (about 2.2 lbs.) of acutely hazardous waste oil, in any calendar month, you are a "conditionally exempt small quantity generator." The Resource Conservation and Recovery Act (RCRA) requires you to:

  • Identify all hazardous waste you generate.
  • Send this waste to an approved facility.
  • Never accumulate more than 1,000 kg (2,205 lbs.) of hazardous waste on your property at any one time.
If you produce more than 100 kg of hazardous waste in any calendar month, you become subject to all requirements applicable to 100 to 1,000 kg/month generators. You must comply with the 1986 rules for managing hazardous waste, including accumulation, treatment, storage and disposal requirements.

If you produce more than 1,000 kg/month, the federal hazardous waste laws require you to comply with all applicable hazardous waste management rules. Your properly licensed waste-oil handler can assist you in obtaining the required EPA and Department of Transportation paperwork.

Filter Disposal

EPA has determined that properly drained (oil no longer flows freely) and crushed used oil filters do not exhibit toxicity and therefore are not hazardous. Recycling or disposing of filters is not regulated. However, EPA encourages the recycling of both the used oil as well as the used filters and their components: canister, gasket and filter paper. Collect the properly drained oil filters and other parts in an approved container and contact a licensed waste oil handler for recycling.

Capacitors also can pose a hazard. A capacitor is an energy-storage device that stores an electrical charge on two plates or large sheets of metal foil, separated by a dielectric PCB-oiled paper that most often is found in systems built before 1978. PCBs are thought to cause cancer in humans, so any wastes that may contain them must be disposed of properly.

If the capacitor does not say "Contains no PCBs," you should assume that it does contain them. If the capacitor case is not damaged, remove it normally. If it is damaged or leaking, handle the case and any waste material with rubber gloves. Any waste materials that contain PCBs must be turned over to a facility that can properly incinerate them.

Refrigeration equipment may have pressure switches, power contactors or thermostats that contain mercury. You are responsible for making sure that any mercury-containing components reach the proper reprocessing facility.

Proper recovery of ozone-depleting refrigerants and disposal of chiller components, while tedious, will bring the benefits of increased energy efficiency and give contractors the satisfaction of knowing they are in compliance with EPA regulations.

A Followup

Shortly after my last column went to press (May/June 2001, p.21) the Air-Conditioning and Refrigeration Institute (ARI) released its figures for 2000. The latest conversion survey report confirms that of 50.7% of the 40,560 units still in operation in 2000, 3,235 units were replaced and another 913 units were converted. While replacements were lower between the months of January 2000 to January 2001 than anticipated, ARI's estimate that 517 centrifugal, screw, reciprocating and absorption chillers would be converted was surpassed by nearly 400 units. Year-end estimates for 2001 currently stand at more than 450 conversions and 3,324 replacements of CFC-based chillers, bringing the estimated year-end total to 39,440 nonCFC-based chillers.