Minimizing R-22 Shortfalls Through More Recovery
January 7, 2008
Refrigerant recovery, reclamation, and recycling are three processes critical to minimizing an R-22 shortfall as the 2010 phaseout deadline approaches. Therefore, it is important for the HVACR industry to have a clear understanding of what each of these terms means and the regulatory requirements for each.
Recovery is the removal of a refrigerant in any condition from a system and the placement of that refrigerant into a container without testing or processing it in any way. Refrigerant recovery is conducted whenever technicians need to open or dispose of air conditioning or refrigeration equipment. Since venting or releasing HCFCs into the atmosphere is illegal, recovery is an important part of equipment service and maintenance.
Reclamation is the process of purifying used refrigerant to industry specifications. This procedure is recommended when a refrigerant will be used in equipment other than the equipment from which it was removed, or in equipment with a different owner.
According to Environmental Protection Agency (EPA) regulations issued under Section 608 of the Clean Air Act (CAA), if the recovered refrigerant will be used in equipment with different ownership, it must be cleaned to the ARI 700 standard of purity and chemically analyzed by an EPA-listed refrigerant reclaimer to verify that it meets this standard.
Recycling takes place when used refrigerants are processed to reduce contaminants and subsequently reused without reclaiming. This is recommended only when the refrigerant will be used in the same owner’s equipment.
In implementing Section 608 of the CAA, the EPA has outlined specific regulations regarding reclamation and future use. When reclaiming refrigerants, reclaimers cannot release more than 1.5 percent of the refrigerant and must dispose of any waste properly.
They must also certify to the Section 608 recycling program manager at EPA headquarters that they are complying with these requirements. This certification must include the name and address of the reclaimer and a list of all equipment used to reprocess and analyze the refrigerant. If the reclaimed refrigerant will be destroyed, environmentally acceptable technologies (i.e., liquid injection incineration, reactor cracking, gaseous/fume oxidation, rotary kiln incineration, cement kilns, and radio frequency plasma) must be used. Reclaimers are also required to keep records that show the names and addresses of persons sending material for reclamation.
Within 30 days of the end of the calendar year, reclaimers must report to the 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.
The EPA enforces these regulations through random inspections and pursuit of potential violators, and can assess fines of up to $32,500 for any violation.
REDUCING LOSSESEquipment owners and contractors are jointly responsible for taking steps to maximize the amount of refrigerant that can be recovered throughout the lifetime of the equipment, as well as when the equipment is decommissioned.
One of the most important practices in R-22 recovery is minimizing leaks. Equipment owners should rely only on trained contractors to install and maintain equipment properly in order to reduce incidences of major leaks. This includes repairing leaks in air conditioning and refrigeration equipment with a charge of greater than 50 pounds. Currently, the maximum annual leak rate is 15 percent of the full charge for comfort cooling appliances and 35 percent of the full charge for commercial and industrial refrigeration appliances. When these maximum legal emissions rates are exceeded, contractors must avoid topping off the equipment and instead take immediate action to repair the leaks within 30 days to ensure an adequate supply of used refrigerant.
Contractors and equipment owners should be aware that the EPA has announced intentions to propose a future ruling to lower maximum leak rates for refrigeration equipment with a charge size of 50 pounds or more in an effort to reduce carbon emissions. This proposed rule would make it more difficult to disregard any equipment malfunctions and would encourage greater use of alternative equipment technologies or refrigerants. The EPA is expected to announce the lower leak limits in 2008.
During servicing and decommissioning equipment, contractors must avoid venting refrigerant as venting is illegal.
In addition to these maintenance and repair practices, contractors and equipment owners can stockpile supplies of R-22 to minimize future shortages. Recycled R-22 can be collected and stored for future use in equipment owned by the same company; however, this approach presents two significant challenges.
First, a large end user that banks R-22, which could otherwise be reused by others in the market after being reclaimed, could contribute to a premature shortage. Second, given likely changes in refrigeration technology, it is too soon to determine whether this approach will be feasible or beneficial in the future.
Publication date: 01/07/2008