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ECAR Fact
Sheet for Minnesota
Refrigerants
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
Thirty years ago, something unexpected
was discovered about the fluids used in air conditioners. Once
they get into the air, they stay there a long time. Not much
happens to them until they gradually diffuse several miles high,
into the stratosphere. At that point, unshielded sunlight
breaks them down. It turns out that they have a devastating
effect on the ozone layer. A little bit of air conditioning
fluid vapor destroys a lot of ozone, through a chain reaction.
When that happens, the ultraviolet (burning) rays from the sun can
reach the earth, a condition that greatly increases the risk that
you and your kids will get skin cancer from being out in the sunshine.
It's hard to believe that being sloppy with refrigerants can have
that drastic an effect, but there is no longer any doubt.
As a result, refrigerants (collectively
called chlorofluorocarbons – CFCs) are now tightly regulated.
Refrigerant removal must be done with acceptable equipment, by certified
technicians, and must be handled and recycled properly. The
used filters from the operation must be treated as a hazardous
waste. You also need
to keep records.
This fact sheet will outline the
special rules that apply to refrigerant recovery and handling, and
will give you links to more detailed information.
Regulations
Refrigerants (Freon, R-12, R-22,
R-134a) are the chemicals used in vehicle air conditioning. By the
end of 1995 all manufacturers were required to stop production of
R-12. However, the use of R-12 is still permitted until supplies
are depleted.
Federal regulations state that it
is illegal to vent any refrigerant to the environment during repair,
service, maintenance, recycling or disposal of refrigeration and
air conditioning equipment because of the harmful effect of these
chemicals on our atmosphere.
Refrigerants must be processed using
one of the following methods:
- Recovery – removing refrigerant
from air conditioning units and storing it in a container without
testing or processing it; The refrigerant is recycled by being
cleaned for reuse without meeting all the purity requirements
for reclamation.
- Reclaiming – processing refrigerant,
usually by distillation, until all impurities are removed and
it meets resale specifications. This requires a chemical analysis
to see whether specifications have been met. Refer to the MPCA
Air Quality Fact Sheets
listed under Motor Vehicle Air Conditioner Disposal.
Spent refrigerants that are not recovered
or reclaimed are regulated wastes. EPA requires use of certified
refrigerant recycling equipment when servicing vehicle air conditioners.
Anyone in Minnesota who works on vehicle air conditioning systems
must also be certified by an EPA-approved organization. Each facility
must either have a certified person on-site or bring in a person
certified to perform this work.
Refrigerant Recovery. The
rules for recovery depend on whether the refrigerant will be sent
off-site to a reclamation facility or to a MVAC service center for
reuse without prior reclamation.
If the refrigerant will be sent off-site
to a reclamation facility, then refrigerant must be recovered using
equipment that reduces the system pressure to 102 mm (4 inches)
of mercury vacuum. There is no restriction on who performs the recovery.
That person does not need to be a certified technician.
If the refrigerant will be sent to
an MVAC service facility for charging or recharging into an MVAC
or MVAC-like appliance without prior reclamation, then the same
rule applies, but there is a further restriction. Prior to such
charging or recharging, the refrigerant must be recovered using
approved refrigerant recycling equipment dedicated for use with
MVACs and MVAC-like appliances. The recovery process must be performed
either by a certified technician, or by an employee, owner, or operator
of, or contractor to, the auto recycling facility.
Storage of Refrigerant. Store
refrigerant in tanks that meet the federal Department of Transportation
(DOT) or Underwriters Laboratory (UL) standards. The tanks should
be labeled "Refrigerants."
Sale of Refrigerant. The rules
for sale of refrigerant depend on whether the refrigerant will be
sent off-site to a reclamation facility or to a MVAC service center
for reuse without prior reclamation.
If the refrigerant will be sent off-site
to a reclamation facility, then it can be sent to facilities that
meet EPA standards for reclaiming refrigerants or those that buy
used refrigerant for resale to the reclaiming operations.
If the refrigerant will be sent to
an MVAC service facility for charging or recharging into an MVAC
or MVAC-like appliance without prior reclamation, then it must be
sold to a certified technician, who must recycle the used refrigerant
before recharging into an MVAC.
Recordkeeping and Reporting.
The following are recordkeeping and reporting requirements related
to recovery, and sale of refrigerant:
- Anyone who recovers refrigerant
from MVACs or MVAC-like appliances for purposes of disposal must
certify to EPA by submitting a section 608 form that their equipment
meets refrigeration recovery standards.
- Maintain records for 3 years showing
that for each vehicle with a air conditioning unit that refrigerants
were either (1) recovered at your facility or (2) that the vehicle
was brought into the facility free of refrigerants and that the
refrigerants were removed prior to entering your facility using
proper methods.
- Anyone who sells or distributes
any ozone-depleting refrigerant must retain invoices for at least
three years that indicate the name of the purchaser, the date
of sale, and the quantity of refrigerant purchased.
Links to the Regulations. Use
the following links to view the regulations pertaining to refrigerants.
Clean
Air Act Sec. 609. Servicing Of Motor Vehicle Air Conditioners
EPA's
Final Rule Governing Substitutes for CFC-12 Refrigerant in MVACs
EPA-Certified Refrigerant Reclaimers
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit
Policy Page).
Use
the following list to audit your procedures for refrigerant/CFC
management.
- If
the refrigerant will be sent off-site to a reclamation facility,
verify that:
- The
refrigerant was recovered using equipment that reduces the
system pressure to 102 mm (4 inches) of mercury vacuum.
- A
section 608 certification form has been completed for the
recovery equipment.
- The
refrigerant was sold to facilities that meet EPA standards
for reclaiming refrigerants or to a company that buys used
refrigerant for resell to reclaiming companies.
- You
have retained invoices that indicate the name of the purchaser,
the date of sale, and the quantity of refrigerant purchased.
- If
the refrigerant will be sent to an MVAC service facility for charging
or recharging into an MVAC or MVAC-like appliance without prior
reclamation, verify that:
- The
refrigerant was recovered using equipment that reduces the
system pressure to 102 mm (4 inches) of mercury vacuum.
- A
section 608 certification form has been completed for the
recovery equipment.
- The
refrigerant was sold to facilities that meet EPA standards
for reclaiming refrigerants or those that buy used refrigerant
to resell to the reclaiming operations.
Best
Management Practices (BMPs)
Most regulations tell you what you
have to do to be in compliance, but they don’t explain how to do
it. That’s where "best management practices" come into play.
BMPs are proven methods that help you to get into compliance and
stay there.
The following BMPs are recommended
for management and recycle of refrigerant/CFCs:
- Use only approved reclaiming and
recycling units when recharging or removing refrigerants.
- Remove and recover refrigerants
prior to crushing and dismantling vehicles.
- Employ certified technicians for
refrigerant recovery.
- Avoid mixing R-12 and 134a since
contaminated refrigerant can’t be put back into the vehicle and
must be sent to a recycling facility.
- Do not use alternative refrigerants
containing liquefied petroleum (LP). These refrigerants not only
cause contamination, but pose a health risk due to explosions.
- Be sure to use the proper O-rings,
lubricants, etc. when retrofitting automobile air conditioning
systems.
- Don’t allow Freon to mix with
oil prior to reclamation or recycling.
- Dispose of filters from CFC recapture
as hazardous waste.
- Keep accurate records for at least
3 years.
Contacts
- For more information, call the
Stratospheric Ozone Information Hotline at 800-296-1996.
Related
ECAR Fact Sheets
None.
Other
Relevant Resources
- MPCA
Fact Sheet - Motor Vehicle Air Conditioner Disposal
- Motor Vehicle Air Conditioner Audit Checklist
- Motor Vehicle Air Conditioner Servicing (2 pgs)
- List of Approved Section 609 Certifying Organizations (2 pgs)
- EPA Fitting Sizes and Label Colors for Motor Vehicle Refrigerants (2 pgs)
- EPA Recycling of Blend Refrigerants Used in Motor Vehicles (2 pgs)
- EPA Motor Vehicle Air Conditioning: What Consumers and Service Technicians Want to Know (2 pgs)
- Motor Vehicle Air Conditioning Recovery/Recycle or Recovery Equipment Certification Form & Instructions (1 pg)
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