Do You Know How to Handle and Dispose of Contaminated Refrigerants?

Reprinted from “The Contaminator,” Summer 1998, Volume 3 Issue 2, with permission from Neutronics Inc.

Back in the summer of 1999, we published an article designed to cover issues related to servicing air-conditioning (A/C) systems in dealerships and, in particular, the complex matter of handling, recycling and disposing of the increasing number of EPA- acceptable refrigerants. Because this topic never grows old, we thought this AWARE article was “Worth Repeating.”

Now that you are able to identify refrigerants, you are faced with the next step: Handling and disposing of blended refrigerants. According the EPA’s “Handling Contaminated and Unfamiliar Automotive Refrigerants,” there are several things you need to remember.

You may not want to turn away a good customer who comes to your shop with contaminated R-12 or R-134a, or with a substitute refrigerant for which you have no dedicated recovery or recycling equipment. What do you do?

Recovering refrigerant. As a first step, the contaminated or unfamiliar refrigerant must be recovered. EPA prohibits venting any automotive refrigerants (including “unacceptable” refrigerants), no matter what combination of chemicals is in the refrigerant. The best way today that a tech can recover contaminated or unfamiliar refrigerant is to dedicate a recover-only unit to anything that is not pure R-12 or pure R-134a. Some equipment manufacturers may also be marketing new types of recover-only stations specifically designed to remove these refrigerants. If the refrigerant you extract into a recovery unit contains a high level of flammable substances such as propane and butane, a fire hazard may result if the refrigerant comes into contact with an ignition source within the equipment. Whether you are purchasing a new piece of equipment to handle your contaminated and unfamiliar refrigerants, or you are converting a piece of existing equipment for this purpose, make sure you talk to your sales representative about what features have been incorporated into the equipment to guard against risk of ignition. Refrigerant should be recovered into the standard DOT-certified, gray-with-yellow-top recovery tank, and if the tank is not equipped with a float valve (which serves as overfill protection), make sure it never gets filled beyond 60% of its gross weight capacity, as specified in the SAE J1989 and J2211 standards.

If A/C service is not a large percentage of your business, then you may be reluctant to invest in another piece of recovery equipment. If this is the case, consider calling a local A/C specialty shop that may have the equipment necessary to service contaminated refrigerants or refrigerants that are unknown to you.

Recycling refrigerant. Once recovered, refrigerant should not be recycled on-site unless it is uncontaminated R-12 or R-134a. Recovering contaminated R-12 or R-134a refrigerant into recycling equipment may damage the equipment. In addition, EPA regulations currently prohibit technicians from recycling blend substitute refrigerants (contaminated or not). EPA is working with independent testing laboratories and with equipment manufacturers to determine whether it is possible to develop recycling equipment to service these blends that protects both the health and safety of the technician, and the integrity of the A/C system.

Storage and disposition of contaminated or unfamiliar refrigerants. Once the refrigerant has been recovered, if you can’t recycle it, what do you do with it? The answer, naturally, is that it depends.

Storage. If the refrigerant in your “junk” tank contains significant amounts of flammable substances, it may be considered hazardous and you should make sure you follow any local ordinances that govern the storage of combustible mixtures. In addition, if your shop generates more than 100 kilograms (220 pounds) of hazardous wastes per month (including used coolant, paint, rust removers, solvents, degreasers and battery acids), then your shop must meet certain storage and transportation requirements under the Resource, Conservation and Recovery Act (RCRA). For information, visit the “RCRA Cleanup” web site.

Disposition. If the refrigerant in your “junk” recovery tank is a chemical “soup” — either contaminated R12and R-l34a or a mixture of those contaminated refrigerants and some blend refrigerants that you are unfamiliar with — then the contents should be reclaimed or destroyed. You should investigate all your options and pick the one that makes the most economic sense for you. [EAN Note: Of course, the option selected should comply with all federal, state and local laws.] If you have a contract in place with a waste hauler, contact the hauler to see if they can handle the material. Waste haulers may require that the contents be identified first and may charge you for this identification procedure. They are most likely to send the tank to an incinerator for destruction. You may also want to contact one or more reclaimers, who will send the refrigerant off-site either for destruction, or for reclamation, which involves breaking it up into its chemical components and purifying each of the components.

Some reclaimers can handle tanks sent to them from anywhere in the nation. A reclaimer does not necessarily have to be located in your area.

Due to the expense involved in reclaiming, some reclaimers may not accept less than 500 or 1,000 pounds of contaminated or mixed refrigerant. In addition, you should be aware that not all reclaimers have the technology to handle all contaminated or mixed refrigerants. However, if one tells you that he is not interested in receiving your tank, don’t necessarily assume that the next reclaimer you call will say the same thing.

Before you enter into any agreement with either your waste hauler or a reclaimer, make sure you understand all of the costs involved; there may be separate charges for identifying the soup, understanding it and destroying it. If you are responsible for shipping the tank, make sure that the hauler or receiver explains to you how to comply with any applicable DOT, state and local requirements relating to shipping.

EPA maintains a list of reclaimers. The Web site address for this list is: http://www.epa.gov/ozone/title6/608/reclamation/reclist.html.