EPA rules on CFCs in chillers.

How do EPA's new refrigerant recycling requirements affect owners of chillers for plastics processing? Equipment suppliers report there is some confusion and misinformation circulating about the new rules (implementing Section 608 of the Clean Air Act), which appear to put little new burden on most plastics processors.

The new rules are intended to eliminate venting of ozone-depleting compounds (ODCs) into the atmosphere. These include CFCs 11, 12 and 502, as well as HCFC-22 and other HCFCs. The rules address prevention of leaks and proper reclamation of refrigerants so as to prevent their release during servicing or disposal of used equipment.

Since July 1, 1992, individuals have been prohibited from knowingly venting ODCs while maintaining, servicing, repairing, or disposing of refrigeration or air-conditioning equipment. On May 14, 1993, the EPA published new rules (58 CFR 28660) requiring practices that maximize recycling of CFCs and HCFCs during equipment servicing and disposal. They also require persons servicing or disposing of refrigeration or air-conditioning equipment to certify to EPA that they have acquired ODC recycling or recovery equipment and are complying with the regulation. The new rules also require repair of substantial leaks in air-conditioning/refrigeration equipment containing more than 50 lb of ODCs.

The regulations set certification requirements for recycling and recovery equipment and for service technicians and reclaimers. By law, sale of refrigerant is now restricted to certified technicians. Finally, EPA has established safe disposal rules. For chillers and other industrial equipment that is typically dismantled on-site before disposal, the refrigerant must be recovered according to EPA's requirements.

FEW ALTERNATIVES

Tom Benson, v.p. of sales and marketing for Thermal Care/Mayer in Niles, Ill., points out that better than 99% of plastics chillers today use HCFC-22. While CFCs will be banned from refrigerant use in 1995, HCFCs will be permitted until 2020, with a freeze on production and consumption slated for 2010. Says Benson, "Some people looking to purchase new chillers are concerned about how long use of HCFC-22 will be permitted, but the fact is that most chillers don't last 20 years."

Harry Short, v.p. of Advantage Engineering Co., Greenwood, Ind., confirms processors' concerns: "They hear that refrigerant may not be available for them to recharge their chillers, or that there will be shortages. We are telling people that for the next 15 years or so, there won't be a problem."

Meanwhile, all suppliers concede the lack of an adequate replacement for HCFC-22 today. Ozone-friendly HFC-134a, they say, is much more expensive and a poor substitute. Says Short, "You lose 25-40% of the chiller's efficiency with HFC-134a." According to Thermal Care/Mayer's Benson, "There is no substitute in our industry for HCFC-22 except ammonia, which is unsafe and corrosive." According to Short, the American Refrigeration Institute is currently evaluating 10 potential replacements, including blends of existing refrigerants or new compounds. Results are expected in late 1994 or early '95.

HIGHER SERVICE COSTS

Chiller service is becoming more expensive as equipment suppliers and independent service agencies have had to acquire recycling and recovery equipment. They must also certify their technicians by November 14, 1994. "For that, you are looking at about $2000-3000 a person," says Al Fosco, v.p. of Conair Tempro, Elgin, Ill. Suppliers see the cost of warranties going up by about 3-5% to cover these expenses.

WHO'S RESPONSIBLE?

Responsibility for compliance with the new regulations depends on how equipment is serviced. Typically, plastics processors utilize local independent service companies and they, along with equipment suppliers, are the ones who have had to acquire recovery and recycling equipment and certify their technicians. But Short cautions, "Ultimately, the equipment owner is responsible for ensuring that refrigerant is recovered and not vented."

There are basically two ways a plastics processor can get into trouble under the new rules. One is by an intentional release of refrigerant. Explains Short, "If a chiller needs a small repair, and an employee proceeds to do it himself and intentionally vents refrigerant, the owner could face a fine of up to $25,000 per occurrence."

The other way a processor can get into trouble is if he owns a badly leaking chiller that contains more than 50 lb of refrigerant. In plastics, reminds Conair's Fosco, only large, central chillers contain over 50 lb of refrigerant. Owners must keep records of the quantity of refrigerant added to such equipment during servicing and maintenance, and they must repair leaks when the annual release rate is more than 35%.