The Cold, Hard Facts of Freon
Freon, like Kleenex, Coke, SkilSaw, Scotch Tape, Tupperware, and Band-Aid is a brand name that has become a household name. Freon is actually a class of refrigerants manufactured by the Chemours Company. Freon, or refrigerants, generally contain chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), or hydrofluorocarbons (HFCs). Auto recyclers are required to recover Freon (regardless of type) and changes to recovery requirements took effect on January 1, 2018. VET prepared the following guide to help you understand the recent update.
Why is the USEPA concerned with refrigerants?
The ozone layer is part of Earth’s atmosphere, approximately 6.2 miles high, that absorbs ultraviolet radiation (UV) from the sun. When refrigerants are released to the atmosphere they degrade the ozone layer allowing more UV to enter.
What are Sections 608 and 609?
Sections 608 and 609 are parts of the Clean Air Act (CAA) that pertain to the handling of stationary appliances (608) and motor vehicle air conditioning (MVAC) (609). EPA is authorized to assess fines up to $37,500 per day for violations of these sections.
What should I know about the Section 608 update?
Section 608 includes stationary appliances such as, refrigerators, heating ventilation air conditioning (HVAC) equipment and dehumidifiers. It prohibits the intentional release of refrigerants. Safe disposal requirements included in Section 608 include:
- The final entity in the waste disposal chain is responsible for refrigerant removal.
- Recovery equipment must be certified and meet USEPA requirements.
- 80 to 90 percent of refrigerant must be recovered from appliances or you must obtain a signed statement stating all refrigerants were removed prior to arrival on your site.
- Updated record keeping requirement for disposal of appliances include:
- Where did the appliance come from?
- When was the refrigerant recovered?
- What type of refrigerant was it?
- How much refrigerant was recovered, by type, per calendar month?
- How much refrigerant was transferred for reclamation or destruction?
- Who it was transferred to and the date it was transferred?
What should I know about the Section 609 update?
Section 609 includes motor vehicles, off-road and agricultural vehicles, mechanical vapor compressors and open-drive compressors. Like Section 608, it prohibits the intentional release of refrigerants. Section 609 has the same safe disposal requirements as section 608 with some exceptions:
- Sale of small cans (less than 20 pounds) of CFC-12 is restricted to EPA certified technicians.
- Evacuation equipment must meet the following criteria:
- The equipment must reduce pressure below 102 mm of mercury.
- The equipment must have a shut-off device and a mechanical pressure relief valve to prevent overcharge.
- Portable tanks must meet Department of Transportation (DOT) standards.
- Refillable tanks shall be marked with the first retest date, which shall be five years.
- Service hoses must have shutoffs located within 12-inches of the connection point.
- The equipment must be able to separate lubricant from recovered refrigerant and accurately indicate the amount removed during the process.
- The equipment must be capable of continuous operation.
- The equipment should be compatible with leak detection material.
What if I receive a partially crushed appliance or one with a cut line?
Written verification of proper removal must be obtained from the customer and retained in your records for three years. Accepting these appliances without a signed statement may lead to fines.
What if I receive an appliance with a sticker or an “X”?
In many markets these markings identify appliances with their refrigerants removed. These markings do not satisfy EPA verification requirements. A signed written statement is still necessary to accept these appliances.
What if a load with appliances or end-of-life-vehicles without documentation comes in?
The load should be refused, or the refrigerant should be removed at your facility.
What can I do with the refrigerant I remove?
Refrigerant may not be sold for direct reuse in most cases. The exception is refrigerant removed from MVAC. Refrigerant removed from MVAC units must only be collected from motor vehicles and must only be used in motor vehicles. All other refrigerant must to go to reclaimers.
What’s the difference between recovery and reclaiming?
Recovering is removing the refrigerant and transferring it into a storage container. Reclaiming is taking the used refrigerant and processing it to restore it to like-new condition.
What if my facility receives heavy equipment or trucks?
The USEPA calls this “MVAC-like” equipment and the refrigerant must be recovered. This refrigerant may only be reused in MBACs or sent for reclamation.
VET Environmental Engineering, LLC (VET), established in 2011, is an environmental engineering and consulting firm specializing in permitting, environmental and safety compliance, wetlands and water resources, and sophisticated mapping services. VET's one-of-a-kind compliance mentorship programs for the auto recycling industry have been emulated both nationally and internationally.