Refrigerant reclamation is a multi-billion dollar industry across the United States and throughout the world. If you are working with CFC or HCFC refrigerants you are required to recover the refrigerant and either recycle or send to a refrigerant reclaimer. While the original intent of refrigerant recovery was to prevent the venting of CFCs/HCFCs into the environment it is also illegal to purposefully vent HFC refrigerants such as R-134a, R-410A, and R-404A. Recovery has become standard when working with refrigerants and will be a main part of the refrigeration industry for years to come.
Why Do We Reclaim Refrigerants?
Why do we recover refrigerants? Why must we remove all refrigerants in a machine before working on them? Why can’t I vent old refrigerant into the atmosphere? It all boils down to one thing. Chlorine. It was found in the 1970s that Chlorine when released into the atmosphere actively damages the O-Zone layer. The O-Zone protects Earth from the sun’s ultraviolet rays and also serves as an insulator.
The CFC and HCFC refrigerants of the twentieth century all contained Chlorine and as the popularity of air conditioning increased so did the amount of refrigerants. As time went on these machines broke, developed leaks, or eventually became obsolete. Once a machine was no longer of use it was trashed. The refrigerant was either left in the machine or it was vented into the atmosphere.
You can begin to see the problem here. Every year the amount of Chlorine in the atmosphere grew and grew. Eventually a hole began to form in the O-zone layer above Antarctica. Scientists and countries panicked and scrambled for a solution. After years of debate the Montreal Protocol came to being. Without getting into too much detail the Montreal Protocol was an agreement of nearly two-hundred countries that agreed to phase out all O-Zone damaging products including products that contained Chlorine. This included CFC and HCFC refrigerants.
In 1990 Congress amended the Federal Clean Air Act to include regulation of O-Zone depleting substances, and in May 14th, 1993 the EPA enacted it’s Section 608 Clean Air Act. A major part of this amendment was that all CFC and HCFC refrigerants had to be recovered and recycled or reclaimed. Any machine that is being opened would have to have it’s refrigerant evacuated in a reclamation cylinder.
The Three R’s
I’ve discussed this a bit in the above text but let’s dig a bit deeper. The three ‘R’s of refrigerant are recovery, recycle, and reclaim. What do each of these mean? What are the differences? Well, let’s take a look:
Recovery is just that, recovery. If you are opening an air conditioning unit either for maintenance, service, repair, or even disposal you are required by United States Federal law to evacuate the existing refrigerant into a recovery cylinder. It is illegal to knowingly vent ANY refrigerant into the atmosphere. Mandatory recovery typically affects service technicians, equipment operators, disposal facilities, and refrigerant manufacturers.
Recycling is taking the recovered refrigerant and cleaning it for future use. Recycling is easier than going the full reclamation route as most refrigerant recycling can either be done in the field or at the contractor’s building. When refrigerant is recycled it is cleaned using oil separation and single or multiple pass throughs on various devices. It is important to note that recycling refrigerant should only be done if you will be using the recycled refrigerant on the same owner’s equipment. (You should not recycle refrigerant and then use the recycled product on a different customer’s unit.)
Reclaim is where it gets a bit more complicated. Since you can only recycle refrigerant if it is going into the same machine reclamation is your other option. Reclaiming refrigerant is to reprocess the refrigerant to at or greater purity than the what is specified in the ARI Standard 700-1993 Specifications for Flurocarbon Refrigerants. This purity must also be verified using specialized machines at a reclamation facility. These specialized machines are not found on site or even at most automotive or HVAC contractor facilities. Once the technician has recovered the refrigerant it will need to be sent either back to the manufacturer or to a certified refrigerant reclaimer. I will be posting a listing of certified reclaimers shortly in another update.
What Kind of Venting is Allowed?
Venting is taken very seriously by the Environmental Protection Agency. Anyone who knowingly vents refrigerant into the atmosphere is in violation of the Clean Air Act and could potentially have the EPA come after you with legal action. Violators may face fines and even substantial jail time depending on the scale of the crime.
That being said there are a few exceptions to ‘venting,’ that the EPA allows.
They are as follows: (Source from EPA’s site.)
- “De minimis” quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.
- 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).
- 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.
- 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.
Keeping the above exceptions in mind always be careful when transitioning refrigerant from existing machines or into new machines. If not for the environment do it to avoid the legal trouble!
While we have covered the banning of venting refrigerants into the atmosphere another thing to consider is if your air conditioning unit has developed a leak. Even if the leak is tiny and you are only losing small portions of refrigerant over the year it is still worth your time to correct the problem and prevent any future refrigerant to leak out of your unit.
If your AC unit has a refrigerant charge of fifty pounds or greater you are required by Environmental Protection Agency law to repair the leak within thirty days. Now this law only applies if the leak will exceed a certain percentage of your total refrigerant charge over a year’s time. For example, for grocery store and warehouse refrigerated units leaks must be repaired within thirty days if the leak will release more than thirty-five percent of the total refrigerant charge over a year. So, if you have a unit that takes one-hundred pounds of refrigerant and you have found a leak that is leaking three pounds of refrigerant a month you would be required by law to repair the leak within thirty days. (three pounds of refrigerant times twelve months equals out to thirty six pounds of refrigerant out of one-hundred, or thirty-six percent.)
This same type of formula applies to comfort cooling units as well. (Commercial and large residential cooling units.) Except on the comfort coolers the leak must not exceed more than fifteen percent of total capacity over a year. They are stricter on the comfort cooling units mainly because while it is a inconvenience to stop cooling your building and have your comfort unit repaired it is much different than having to stop industrial manufacturing or distribution entirely due to a faulty unit. This difference is enabled to protect businesses and to provide as little financial impact as possible.
One other thing to note is that if your unit is exceeding the fifteen/thirty-five percent threshold but you do not wish to keep the machine you can have the thirty day threshold waived as long as you develop a plan for either a one year retrofit or retirement of the unit.
The last thing to mention is that if the repair of an air conditioning unit will require the complete shutdown of industrial manufacturing units the owners can extended the thirty day deadline up to one-hundred and twenty days to repair the leak. This allows business owners to plan for the appropriate time to shut down their business to fix the leak.
The Environmental Protection Agency takes enforcement of section 608 very seriously. They do random inspections of facilities, respond to tips, and pursue any other potential leads against businesses or consumers. The EPA is authorized to fine up to $37,500 per day to businesses that are in violation. Think about that. $37,500 A DAY. It is not worth it to try and skirt around these rules. Stay compliant, and document everything you can.
I was browsing the EPA’s website and found a link that shows all of the cases the EPA has pursued against violators of the Clean Air Act. I wrote an article on one of these that hit just recently in May of this year. On top of the Enviro safe case you can view all of their cases against Clean Act violators.
If you are on the other side of the coin and are looking to report violators of the Clean Air Act you can visit this link to begin the process.
Now in order for a technician to actively work on a unit they are going to need recovery cylinders. There are numerous places to purchase recovery tanks but the standard tank you are going to find will work for most all refrigerants and typically can hold up to thirty pounds of recovered refrigerant.
One thing to mention is to be sure not to mix any refrigerants when recovering or storing recovered refrigerants in these tanks. If you have two different types of refrigerant then use two tanks! Otherwise you have cross contaminated the refrigerants and they will need to be sent to a certified reclaimer. Always be sure that the tank you have is rated to accept the refrigerant that you will be recovering.
I purchase most of my products from Amazon and found the recovery tank below. It is the highest rated recovery cylinder on Amazon and has a 4.3 star rating.
I won’t spend too much time on this but it goes without saying that if you are going to be recovering refrigerants that you’re going to need a recovery machine. Again, I will refer to Amazon. I found the below machine from there and it has an eighty-three percent positive rating. This particular unit will recover CFC, HCFC, and HFC refrigerants. Yes, that includes R-22, R-134a, R-410A, R-404A, and many more.
The EPA’s Clean Air Act is nothing to mess around with. It should be taken seriously and the impact that you can have on the environment when handling refrigerants should be taken just as serious. Ensure that all refrigerant that you handle is recovered and recycled or reclaimed. Do it for the environment, do it for the government, and do it for yourselves.