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ECAR Fact
Sheet for Missouri
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
The common refrigerant used in automotive
air-conditioning (a/c) units is chlorofluorocarbon-12, also known
as CFC- 12, R-12, or Freon. In December 1995 production
of CFC-12 in the United States ended. CFC-12 can still be used,
but it is no longer produced. CFCs are chlorine-containing compounds
that react with sunlight in a way that destroys the protective ozone
layer in the earth's atmosphere. This allows the amount of ultraviolet
(UV) radiation reaching the earth's surface to increase. Overexposure
to UV rays may cause skin cancer, eye cataracts and a weakened immune
system.
As
a result, refrigerants (collectively called chlorofluorocarbons
– CFCs) are now tightly regulated. Refrigerant removal must
be done with acceptable equipment 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.
The
Missouri Department of Natural Resources has prepared a salvage
guidance document to help auto recyclers manage refrigerants. Much
of that information is included in the fact sheet below. You can
access the link to the Department’s salvage guidance document under “Other
Relevant Resources.”
Regulations
If you open an a/c system, you must
contain all of the refrigerant using equipment approved by the Environmental Protection
Agency (EPA). This includes CFC-12 and alternative refrigerants such as
HFC-134a. You must recover the refrigerant before discarding, reselling or recycling
the a/c unit as part of a dismantling or crushing operation.
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; or
- Reclaiming
– processing refrigerant, usually by distillation, until all
impurities are removed and it meets resale specifications.
Spent
refrigerants that are not reclaimed or recycled are regulated wastes.
EPA requires use of certified refrigerant recycling equipment when
servicing vehicle air conditioners.
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. *An employee of a salvage
operation who recovers refrigerant from vehicles bound for disposal
does not have to be a certified technician. Technicians servicing
or repairing motor vehicle a/c systems must be trained and certified
by an EPA-approved organization.
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.
When recycling refrigerant, do
not mix CFCs and HFCs. Recycle these separately. Do
not add alternate refrigerants (HFCs) to a system using CFC-12.
Under federal law, recycled or reclaimed refrigerants are not hazardous
if they are not mixed.
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.” Federal law requires labeling of products
containing ozone-depleting substances such as CFCs. Therefore, CFC-12
a/c units, refrigerant equipment and any containers must be labeled
clearly. The label must read "WARNING Contains CFC-12, a substance
which harms public health and the environment by destroying ozone
in the upper atmosphere." An a/c system retrofitted to use
an alternate refrigerant must have a label telling what refrigerant
is in the system.
It is a good idea to label empty
refrigerant containers with the word "EMPTY." Check with refrigerant suppliers to see
if the containers can be returned for reuse or recycling. If that
is not possible, dispose of empty containers in the landfill.
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 motor vehicle air conditioning (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.
If
a customer buys a salvage a/c system, you might suggest that the
customer consider having the system retrofitted to use an EPA-approved
alternative refrigerant. Currently hydrofluorocarbon-134a, also
known as HFC-134a and R-134a, is the only alternative to CFC-12
approved by EPA and fully tested and specified by auto manufacturers
in their retrofit guidelines.
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. If you do not recover the refrigerant
yourself, you must keep copies of signed statements that the refrigerant
was removed by someone else before you got the vehicle.
- 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 units when recharging or
removing refrigerants.
- Remove and recover refrigerants prior to crushing and
dismantling vehicles.
- Verify that all vehicles entering the facility without
refrigerant have had the refrigerant removed using proper methods.
- Employ certified technicians for refrigerant recovery. *An
employee of a salvage operation who recovers refrigerant from
vehicles bound for disposal does not have to be a certified technician.
Technicians servicing or repairing motor vehicle a/c systems must
be trained and certified by an EPA-approved organization.
- 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.
- Don’t allow Freon to mix with oil prior to reclamation
or recycling.
- Sell refrigerant to certified technicians or to certified
reclamation facilities that will reclaim the refrigerant to its
original purity specifications.
- Dispose of filters from CFC recapture as hazardous waste.
- Keep accurate records for at least 3 years.
Contacts
- For
more information, call U.S. EPA’s Ozone Protection Program at
1-800-296-1996.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Pollution Prevention During Vehicle Salvage
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