RESTRICTIONS ON THE USE OF HYDROFLUOROCARBONS

Revision Date: 9/00
Process Code: Navy/Marines: SR-04-99; Air Force: FA03; Army: N/A
Usage: Navy: Medium; Marines: Medium; Army: Medium; Air Force: Medium
Compliance Impact: None
Alternative for: Chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs)
Applicable EPCRA Targeted Constituents: Dichlorodifluoromethane (CAS: 75-71-8), Chlorotrifluoromethane (CAS: 75-72-9), Dichlorotetrafluoroethane (CFC-114) (CAS: 76-14-2), Monochloropentafluoroehtane (CAS: 76-15-3)

Overview:

Hydrofluorocarbons (HFCs) are being developed to replace Chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs) for use primarily in refrigeration and air conditioning equipment. HFCs are the next generation of refrigerants. They will substantially replace all the CFCs and HCFCs, since they do not have ozone depletion potential.

Under section 608 of the Clean Air Act, it has been illegal since November 15, 1995, to knowingly vent substitutes for CFC and HCFC refrigerants during the maintenance, service, repair and disposal of air-conditioning and refrigeration equipment. On June 11, 1998, EPA proposed a regulation to fully implement this statutory venting prohibition.

In brief, the proposed regulations would:

  • Exempt certain substitute refrigerants from the venting prohibition;
  • Extend to HFC and PFC refrigerants the requirements currently in place for CFC and HCFC refrigerants, including required practices, certification programs for recovery/recycling equipment, reclaimers, and technicians, a prohibition on the sale of refrigerant to anyone but certified technicians, leak repair requirements, and safe disposal requirements;
  • Make minor changes to the required practices, recovery equipment standards, and refrigerant purity standards for CFCs and HCFCs to accommodate the addition of the HFC and PFC refrigerants; and lower the maximum allowable leak rates for comfort cooling chillers, commercial refrigeration, and industrial process refrigeration. The new maximum allowable leak rates would apply to equipment containing CFCs, HCFCs, HFCs, and PFCs.

Section 608 directly prohibits the venting of substitute refrigerants during the maintenance, service, repair, and disposal of air-conditioning and refrigeration equipment unless EPA determines that the release of the substitute does not pose a threat to the environment. EPA is considering a number of factors in making this determination, including the substitute's toxicity, flammability, long-term environmental impact (such as global warming potential), and regulation under other authorities (such as OSHA or other EPA requirements). Based on these considerations, the following refrigerants are subject to the venting prohibition, and EPA is proposing to cover them under the regulations:

  • hydrofluorocarbons (HFCs)
  • perfluorocarbons (PFCs)

EPA is proposing to exempt the following refrigerants from the venting prohibition:

  • ammonia that is used in absorption systems or in commercial or industrial process refrigeration systems
  • hydrocarbons that are used in industrial process refrigeration systems for processing hydrocarbons
  • chlorine that is used in industrial process refrigeration systems for processing chlorine or chlorine compounds
  • CO2, nitrogen, and water

This proposed exemption applies only to applications of these refrigerants that have been approved under EPA's Significant New Alternatives Policy (SNAP) Program. The applicability of recycling requirements to these substitutes in other applications (e.g., hydrocarbons in household refrigerators) will be considered when the substitutes in those applications are submitted for SNAP review.

It may be dangerous to use CFC and HCFC recovery equipment to recover ammonia, hydrocarbons, or chlorine. However, users of hydrocarbon, ammonia, and pure chlorine refrigerants must continue to comply with all other applicable federal, state, and local restrictions on emissions of these substances.

As is the case for CFC and HCFC refrigerants, only four types of releases of HFCs and PFCs are permitted under the prohibition:

  1. "De minimis" quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.
  2. Refrigerants emitted in the course of normal operation of air-conditioning and refrigeration equipment such as from mechanical purging and leaks.
  3. Releases of HFCs and PFCs that are not used as refrigerants (note that heat transfer fluids are considered refrigerants).
  4. Small releases of refrigerant that result from purging hoses or from connecting or disconnecting hoses to charge or service appliances.
More information on permitted releases may be found in the "Final Rule Summary: Complying with the Section 608 Refrigerant Recycling Rule," which can obtained from the Stratospheric Ozone Protection Hotline at 1-800-296-1996.


Compliance Benefit:

None noted.


Materials
Compatibility:


Materials compatibility is based on the alternative procedure or chemical implemented. Considerations include the possibility of corrosion, swelling, deformation, and damage to coatings and adhesives. Testing will reveal particular types of damage to parts: stress, embrittlement, and total immersion corrosion.


Safety and Health:

Consult your local Industrial Health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing any of these technologies.


Benefits:
  • Facilitates compliance with the Clean Air Act.
  • Reduce the amount of ozone-depleting substances and EPCRA-targeted chemicals going into the environment.
  • Reduce the exposure to constituents that have adverse effects to human health.


Disadvantages:
  • Expensive capital costs during replacement phase may be encountered.
  • Requires specialized training in handling HFC refrigerants.


Economic Analysis: Any replacements need to be evaluated for a given application in order to determine the economic impact. Regardless of any substitute’s cost, taxes on CFCs will continue to rise.


Approving Authority:

Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.


NSN/MSDS:
Product NSN Unit Size Cost MSDS*
None Identified $  

*There are multiple MSDSs for most NSNs.
The MSDS (if shown above) is only meant to serve as an example.


Points of Contact:

EPA:
Stratospheric Ozone Protection Hotline
U.S. Environmental Protection Agency
Mail Code 6205J
401 M St., SW
Washington, DC 20460
Phone: (800)-296-1996 or (301)-614-3396

Navy:
Mr. Peter Mullenhard
Navy Shipboard Environmental Information Clearinghouse, GEO-CENTERS, Inc.
1755 Jeff Davis Highway
Suite 910
Arlington, VA 22202
Phone: (703) 416-1023 ext 109 or (703) 416-1132
FAX: (703) 416-1178


Vendors:

National Concrete Products
P.O. Box F
Greenwood,  DE   19950
Phone: (302) 349-5528 
FAX: (302) 349-9435
Contact: Mr. Mac McCombs


Sources:

http://www.epa.gov/ozone/title6/608/subvent.html
http://www.epa.gov/spdpublc/title6/608/608fact.html
http://www.epa.gov/spdpublc/title6/608/subrecpr.html
Peter Mullenhard September 1998.


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