The Air-Conditioning and Refrigeration Institute (ARI) recently stated that approximately 50,000 of the 80,000 CFC chillers (65%) are still in service. CFC producers have sold virtually all of their virgin CFC-11 and -12 supplies, which means owners of CFC chillers must now rely on distributor stockpiles, their own stored CFC refrigerants, and previously used CFCs recovered from out-of-service chiller units.

This means 50,000 CFC chillers will be competing for existing CFCs. There's a big opportunity for contractors to replace those CFC chillers. With more than 50,000 chillers in the U.S. currently CFC-based, the retrofit-replacement market is estimated in the billions of dollars. It also offers a tremendous opportunity for facilities to save money and reduce energy costs.

New refrigerant chillers can be up to 40% more efficient than CFC units installed 20 years ago, resulting in operating savings that can pay back the investment in a few years. Replacing CFC chillers may also be a great opportunity to make load reductions and other improvements to reduce utility bills. And the chiller may be significantly downsized for still greater savings.

Handle With Care

While chiller replacements represent a great opportunity for contractors and facilities, it is important to know how to handle CFC equipment, refrigerants, and oil disposal.

Equipment that is usually dismantled on-site before disposal (i.e., retail food refrigeration, cold storage warehouse refrigeration, chillers, and industrial process refrigeration) must have the refrigerant removed and recovered prior to dismantling. Any equipment that is disposed of without being dismantled (auto air conditioners, household refrigerators, room air conditioners, etc.) have special, refrigerant-safe disposal requirements.

Under Clean Air Act regulations, in order to dispose of appliances or other equipment that contains refrigerants, all the refrigerant first must be recovered. The person disposing of or dismantling the appliance must either recover all of the refrigerant, or obtain verification that the refrigerant has already been recovered. This verification must include the date of recovery and name and address of the person/company that performed the recovery. (Note: Possession of such verification does not relieve the disposer of the appliance of the responsibility of recovering any remaining refrigerant.)

When disposing of refrigerants or refrigeration equipment, the EPA requires that records must be kept on file and made available for at least three years. These records must include the amount of refrigerant removed/recovered, prior ownership of refrigeration equipment, and the future ownership or disposition of the retired equipment.

It's wise to keep records on the type of equipment salvaged, amount of oil removed, capacitor disposition, and mercury (if any) disposition. In addition, keep technician training certificates, recovery machine information, and repair records on the recovery equipment.

Refrigerant must be cleaned or reprocessed to ARI Standard 700-88 or ARI 700-93 purity levels when reuse is intended 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 reclamation company. Such companies are governed by the salvage laws as set forth in the Salvage Section of 40 CFR 82 Subpart F of Title VI of the Clean Air Act. The reclaimer must have all of the recovered refrigerant from the salvaging activities before the refrigerant can be reprocessed, returned to the equipment, or sold for use in other refrigeration equipment.

(The federal rule for refrigeration handling [40 CFR 82 Subpart F, an expansion of Section 608 of Title VI of the U.S. Clean Air Act] explains this in more detail.)

Disposal Process

For any size appliance that contains refrigerant and is being permanently retired, as much refrigerant as possible must be recovered, any removable parts should be taken out, and the entire process should be documented and kept on file. When these steps are accomplished, turn the equipment and materials over to their final disposers.

When recovering the refrigerant, follow these guidelines.

Be aware of your recovery system's capabilities.

  • Determine where the refrigerant is in the system, and what phase or condition it's in.
  • If possible, recover the liquid refrigerant. If you're drawing any water from a system, or if recovering refrigerant in the vapor phase on a water-cooled system, the water could freeze in the tubes, creating a leak.
  • If possible, isolate the refrigerant in the receiver, receiver-condenser, or condenser.
  • Check for leaks.
  • Begin the recovery. If the system is leaking, recover to only atmospheric pressure. If the system is sound, recover to EPA-listed levels. For systems that are being completely retired/disposed of, recovery must be to the listed levels, and at least 90% of the refrigerant must be removed.

    Refrigerant must be stored in approved, labeled containers. If the refrigerant is contaminated, it must be taken off-site to a reclamation facility for reprocessing. Otherwise, recycle the refrigerant and bank it for future use. In either case, keep records of the quantities processed.

    After the refrigerant has been recovered, properly remove the oil, filters, capacitors, and any mercury switches.

    Before surrendering the retired equipment for salvage, obtain or provide a written agreement that states that the refrigerant has been recovered, and all other appropriate materials have been properly removed. This agreement should be between you and the final disposer.

    The following information should be documented and maintained in the project files for a minimum of three years:

    • Date of recovery;
    • Job name and address;
    • Appliance serial number(s);
    • Number of appliances disposed of;
    • Refrigerant type and amount recovered;
    • Recycling unit used;
    • Quantity of oil recovered;
    • Disposal location; and
    • Evacuation level.

    All date-sensitive records should be kept for three years. An Environmental Disposal Tag should be attached to the equipment being disposed.

    In order to comply with the regulations that went into effect July 13, 1993, when disposing of appliances (except for small appliances, motor vehicle air conditioners, and MVAC-like appliances), technicians must evacuate the refrigerant in the entire unit to a certified recovery or recycling machine. Applicable evacuation levels specified in Table 1 must be met. Appliances excluded from these provisions face special requirements.



    Refrigerant Waste Oils

    In order to dispose of the refrigerant oils, collect the "off-spec" oil from the recovery unit and appliance by draining it until it is no longer free flowing. Be aware that oil from a/c equipment may contain halogens, but if this oil is separated from other waste oils, it is not classified as a hazardous waste.

    Measure and record the quantities of oil recovered, then deposit the oil in the properly labeled 55-gal drums or other appropriate containers. Do not fill these containers more than 90% full; leave the remaining space for expansion.

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

    If testing of the used oil reveals that it exceeds the regulatory limits of the toxicity characteristic rule, it is then classified as hazardous waste. It's your responsibility to safely and legally dispose of the hazardous oil. If you produce no more than 100 kg (about 220 lb, or 25 gal) of hazardous waste oil, and no more than 1 kg (about 2.2 lb) of acutely hazardous waste oil in any calendar month, you are a "conditionally exempt, small-quantity generator."

    The federal hazardous waste law requires you to:

    • Identify all hazardous waste you generate;
    • Send this waste to an approved facility; and
    • Never accumulate more than 1,000 kg 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 "100-1,000 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, federal hazardous waste laws require that you comply with all applicable hazardous waste management rules. (Note: A properly licensed waste oil handler can help you get set up with the required EPA paperwork.)



    Refrigerant Oil Filters

    The EPA has determined that properly drained (oil no longer flows freely) and crushed used oil filters do not exhibit the toxicity characteristic, and therefore are not hazardous and need not be regulated when recycling or disposing of them.

    However, EPA encourages the recycling of used oil, used filters, and their components (such as the canister, gasket, and filter paper). Collect the properly drained oil filters and other parts in an approved container and contact a properly licensed waste oil handler for recycling.

    Many capacitors contain polychlorinated biphenols (PCBs), especially those found in older systems. A capacitor is an energy-storage device. It stores an electrical charge on two plates or large sheets of metal foil, separated by a dielectric (PCB-oiled paper). 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 is 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.

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



    Update

    In addition to refrigerant issues and the energy savings offered by the removal of old, CFC-using equipment and replacement with new, non-CFC, higher-efficiency systems, a bill introduced in the U.S. House of Representatives on July 14, 1999 may provide additional incentives for replacement of CFC chillers.

    This bill would offer rewards for early emission cuts. Companies and communities that take steps to reduce emissions of greenhouse gases before being required to do so under federal law would be rewarded. ES

    Useful Documents

    1. "EPA Update: Changing Refrigerant Oil" www.environ.com/EPA_Regs_Resource_Pages/oil.html
    2. "Complying with the Section 608 Refrigerant Recycling Rule" earth1.epa.gov./ozone/title6/608/608fact.html
    3. "Responsible Practices: Servicing and Disposing of Refrigeration Equipment, EPA 305-V-97-001." es.epa.gov/oeca/ccsmd/profile.html