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On-site management in a post-CFC world.

As almost everyone involved with air conditioning systems knows by now, it became illegal last July to deliberately vent chlorofluorocarbons (CFCs) into the atmosphere during service, maintenance, or disposal. The "no-venting" ban, a provision of the 1990 Clean Air Act, has been the driving force behind the growth of on-site CFC recovery, recycling, and reclamation programs throughout the property management industry.

The legislation already has sparked dramatic changes in refrigerant manufacturing, maintenance, and service. Anyone with responsibility for the on-site management or maintenance of a building cooling system must come to terms with this new reality.

Although the Environmental Protection Agency has yet to publish final regulations, its proposed rules suggest that it is extremely serious about CFCs. The EPA will more than likely impose per-incident fines of up to $25,000 per day for anyone violating the "no-venting" provision.

To encourage the purchase and use of recycling equipment, the EPA has been seeking the help of industry groups in developing a set of basic operating standards. The agency's proposed standards for equipment and technicians were, at the time of this writing, under review by the Office of Management and Budget (OMB).

Finally, the agency has sent a strong signal that it wants to protect those who comply with the law against those who cut corners. A "bounty hunter" provision allows the EPA to offer rewards of up to $10,000 for information leading to the successful prosecution of violators. Last fall, the EPA's regional offices already had received almost 500 tips of venting incidents.

Training for the post-CFC world

Some property managers hope that the EPA's tough regulations will apply mostly to the HVAC contractors, not to the management or maintenance staff. While proposed rules do not require certification for technicians, that situation might change before rules are finalized. Nevertheless, training may be advisable.

The EPA has yet to develop certification rules or a standard test, but training is already available. Several private organizations, such as the Refrigeration Service Engineers Society, have developed tests and begun sponsoring "certification seminars" for technicians.

Should property managers send their in-house technicians to these seminars? Certainly, sending technicians to seminars shows a good-faith effort to avoid venting violations. On the other hand, once the EPA publishes its final rules, the technicians will be given "adequate time"--perhaps as much as 12 months--to become certified if this is required.


Here are the definitions of the terms "recovery," "recycle," and "reclaim," as defined by the American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE):

Recovery: To remove refrigerant in any condition from a system and store it in an external container without necessarily testing or processing it in any way.

Recycle: To clean refrigerant for reuse by oil separation and by single or multiple passes through devices, such as replaceable core filter-driers, which reduce moisture, acidity, and particulate matter. This term usually applies to procedures implemented on-site or at a local service shop.

Reclaim: To reprocess refrigerant to new product specifications by means which may include distillation. Reclamation requires chemical analysis of the refrigerant to determine that the appropriate product specifications are met. This term usually implies the use of processes available only at reprocessing or manufacturing facilities.

Recycling equipment

Since the July 1 ban on CFCs, recycling equipment has been much in the news. A recycling machine, with its separate drier section and series of filter-driers, removes impurities from refrigerants. While it does not return the refrigerant to "virgin" form, it does allow it to be reused in a system.

After maintenance or repair to a system, the recycled refrigerant is then put back into the system and "topped-off" with virgin refrigerant. (Current Clean Air Act rules require that recycled refrigerant be used only in the system from which it came or in another belonging to the same owner.)

We are often asked by customers to guide them in the purchase of a recycling machine. Several such machines are now on the market and, while they are considered by most to be very cost-effective investments, deciding which equipment is best for an on-site program requires some thought.

The purchase should first be guided by the size of the chiller. Equipment that recycles chillers using R-11 generally are more expensive than those for systems using R-12, R-22, or R-502.

You should ask your wholesale distributor or your HVAC contractor for suggestions. Once these decisions are made, we recommend that an equipment demonstration be arranged.

Remember, recycling CFCs is not a simple task and the equipment you use will be subject to an increasingly strict regulatory environment. The EPA has proposed certification rules based on the Air-Conditioning and Refrigeration Institute's performance standard 740, and any equipment purchased should conform to this standard.

The HVAC industry's technical journals are filled with debate over issues relating to recovery equipment. One issue is the recovery pressure for high-pressure systems. One proposed standard for recovery units is to bring the chiller system pressure down to that of the atmosphere.

An alternative proposal is to recover down to 17 inches Hg. This latter, far tougher standard would mean an early death for most recovery machines now being marketed with small hermetic compressors.

Thus, the current wisdom at the EPA seems to be that the agency will accept any unit that can pull a 20-to-25-inch vacuum on low-pressure systems and pull high-pressure systems down to atmospheric pressure.


Off-site cleaning of CFCs, usually called "recovery," also is an option. Our company was among the first in the industry to provide contractors and building managers with a recovery program that would accept any quantity of used refrigerant. For many smaller building managers and HVAC contractors, our recovery program has been the answer to their concerns about compliance, and ensures them a constant supply of CFCs.

What makes a recovery program appealing is the fact that the refrigerant is being cleaned off-site. This means, for example, that oil containing CFCs will be vented during the reclamation process by someone else. By contrast, during recycling, on-site oil is separated by the machine and goes into a separate cylinder, from which it must be disposed under a strictly regulated procedure by the user.

As part of a wholesaler's recovery program, a company takes the responsibility of processing the paperwork, including the necessary Department of Transportation shipping documents.

Going, going, gone

Certainly, recycling, recovery, and reclamation are at the heart of any on-site strategy for preserving dwindling refrigerant supplies. Maintaining in-house supplies through a recycling and recovery program is essential. By participating in a recovery program, an on-site manager not only can preserve existing supplies, but also is assured of being in compliance.

How real is the prospect of a CFC shortage? Quite real, if you look at certain facts and listen to the industry experts.

President Bush already had accelerated the end of CFC production from the year 2000 to 1995 by the time he left office in January. This means that, with a few possible exceptions, CFCs will not be produced after 1995.

Already, many prominent manufacturers of refrigerants and equipment that use CFCs have willingly halted their own production. This will certainly have an effect on supplies, perhaps reducing them seriously before 1996.

In addition, two other facts might lead one to suspect that a shortage is possible:

* In 1992, manufacturers produced only half the volume of CFCs they did in 1986.

* CFCs were being taxed at $1.67 per pound last year, and the tax jumped by nearly $1.00 on New Year's Day, 1993.

The most obvious strategy for eliminating the headache to come, and one that property managers are beginning to take, is the retrofitting or replacement of equipment that uses CFCs.

Such a strategy should be enacted quickly because, according to industry insiders, shortages may occur as early as 1994, thanks to potential additional limits placed on CFC production by the EPA.

Clearly, the primary strategy behind in-house CFC recovery program is, and will continue to be, the preservation of a dwindling supply of refrigerants. The purchase of recycling equipment for on-site recycling will no doubt continue to grow.

As we all know, there is an important global issue behind the move toward the "post-CFC world." The fact is, recent discoveries by NASA and others have found that ozone depletion is taking place faster than expected. Under existing timetables, worldwide stratospheric levels of ozone-destroying chlorine will not drop to 1988 levels until the year 2063.

Thus, as we begin to make important technical decisions about the future of our cooling environments, let's remind ourselves from time to time how these decisions will affect the future well into the next century and act responsibly, as always.

John Rynecki is vice president of Sid Harvey Industries, an authorized Du Pont wholesale distributor, based in Garden City, New York.

Tips for Selecting Recovery Equipment

Selecting recovery and recycling equipment requires some thought. As most refrigerant and HVAC manufacturers also provide recovery and recycling equipment, there is now a relatively good selection available. Some items to consider are:

1 Do you want to buy recovery equipment or recycling equipment? Obviously, recycling equipment can recover refrigerants as well as recycle them, but it is more expensive.

2 What is the recovery efficiency? Since all the information coming out of the EPA indicates a desired recovery rate of 80 to 90 percent of system capacity, it would not be prudent to purchase equipment with less efficiency.

3 What size of equipment and type of job will the unit be required to handle? Some units can handle only liquid (found in low-pressure chillers), while other units can handle only vapor. Some units can handle both, and some can handle more than one refrigerant. Also, recovery rates vary among equipment types. Again, consider cost when comparing, and be sure that the storage unit is large enough to accommodate all refrigerant.

4 How portable is the equipment, and how portable do you need it to be? Operations that will service units in multiple locations, even if only on different floors of the same high-rise, must have more portable equipment than that purchased for one location. Even a "portable" unit mounted on wheels may be too heavy for a technician to carry up stairs or a ladder.

5 At what speed can the equipment perform? Typically, it should be able to transfer refrigerant and clean/recycle between two and five pounds per minute. The speed will vary depending on whether the system is used for liquid or vapor refrigerant.

6 Finally, while equipment manufactured to meet the guidelines of "before January 1, 1993" must be retired by January 1, 1998, there is no reason why equipment manufactured before 1993 that meets the standards required after that date should be retired at any set point. Thus, when evaluating capabilities and costs associated with recovery and recycling equipment, consider the useful life of the product.

The above was excerpted from A Guide to CFC Reclamation and Retrofit, published by the Institute of Real Estate Management. Copies are available for sale by calling IREM at (312) 661-1953.
COPYRIGHT 1993 National Association of Realtors
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Title Annotation:Operating Techniques & Products Bulletin 419; includes related article
Author:Rynecki, John
Publication:Journal of Property Management
Date:Mar 1, 1993
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