10.1 Equipment Disposal Requirements
Key Takeaways
- The last person in the disposal chain is responsible for ensuring refrigerant recovery
- Recovery must be documented — signed statements, amounts, and refrigerant type
- All components containing refrigerant must have it recovered before disposal
- Both shipper and receiver share responsibility when equipment is transported for disposal
- Failure to recover refrigerant before disposal carries the same penalties as venting
10.1 Equipment Disposal Requirements
Proper disposal of refrigeration and air conditioning equipment is a critical aspect of EPA Section 608 compliance. Failure to follow disposal rules carries the same penalties as other Section 608 violations.
Who Is Responsible for Disposal Recovery?
The final person in the disposal chain is responsible for ensuring refrigerant has been properly recovered. This includes:
- Scrap metal dealers and recyclers who accept equipment
- Appliance retailers who take back old equipment
- Waste management companies handling refrigerant-containing equipment
- Building demolition contractors who encounter HVAC equipment
- Property owners who dispose of equipment
Disposal Requirements by Appliance Type
| Appliance Type | Recovery Requirement | Who Must Be Certified |
|---|---|---|
| Small appliances (≤5 lbs) | Recover refrigerant before disposal | Type I or Universal technician |
| Equipment with >5 lbs | Recover to required evacuation levels | Appropriate certification (Type II, III, or Universal) |
| Self-contained equipment | Same as above based on charge size | Appropriate certification |
| Comfort cooling systems | Recover to required levels | Type II or Universal |
| Low-pressure chillers | Recover to 25 mm Hg absolute | Type III or Universal |
Verification of Recovery
The person disposing of the equipment must either:
- Recover the refrigerant themselves (if properly certified), OR
- Verify that recovery was completed by a certified technician
Acceptable verification includes:
- A signed statement from the certified technician who performed the recovery
- Documentation showing the amount and type of refrigerant recovered
- Records from the recovery service provider
Appliance Components Containing Refrigerant
When disposing of equipment, be aware that refrigerant may be present in multiple components:
- Compressor — contains refrigerant dissolved in oil
- Condenser — may contain liquid refrigerant
- Evaporator — may contain liquid refrigerant
- Receiver — stores liquid refrigerant
- Filter-drier — may contain small amounts of refrigerant
- Refrigerant piping — throughout the system
All components must have refrigerant recovered before they are scrapped, recycled, or landfilled.
Equipment Being Shipped for Disposal
When equipment is shipped to another location for disposal:
- The shipper must ensure refrigerant has been recovered OR
- Must provide documentation that the receiving facility will recover refrigerant before processing
- The receiving facility must have the equipment and certifications to recover refrigerant
- Both parties share responsibility for proper handling
For the Exam: The last person in the disposal chain is responsible. Recovery must be documented. All components containing refrigerant must have it recovered. Both shipper and receiver share responsibility when equipment is transported for disposal.
Who bears ultimate responsibility for ensuring refrigerant is recovered from equipment before disposal?
A demolition contractor encounters an old rooftop AC unit during a building teardown. What must they do?