Subject: EPA Q & As on DIYers Fixed and Mobile A/C service (venting) Newsgroups: rec.autos.tech,sci.engr.heat-vent-ac Keywords: freon venting Clean-air-act $25,000-fine do-it-yourself [Email exchange between Geo. Goble and Christine Dibble @ USEPA regarding questions on DIYers (Do-it-Yourselfers), on venting and other rules for Clean Air Act (CAA) part 608 (mostly stationary refrigeration A/C) and part 609 Mobile MVAC A/C (cars, busses, tractors, etc) EPA's replies are in UPPER CASE.. Also attached is an EPA supplied Q & A factsheet (not in upper case) on DIYers, venting, etc.. Hopefully this should clear up many misconceptions.. --ghg] From DIBBLE.CHRISTINE@EPAMAIL.EPA.GOV Sat Jul 15 09:59:30 1995 From: CHRISTINE DIBBLE To: ghg@ecn.purdue.edu, LEVY.JEFFREY@EPAMAIL.EPA.GOV Subject: CAA section 609 & DIYers.. -Reply Status: R SEE ANSWERS IN ALL CAPS WITHIN THE TEXT. ALSO SEE THE ATTACHMENT, A Q&A FACTSHEET WHICH I JUST PREPARED FOR FARMERS AND OTHER DIY-ERS. THIS FACTSHEET WAS SENT FOR DISTRIBUTION AND REPUBLICATION TO AUTO. PARTS AND ACCESSORIES ASSN. AND TO MANY FARM TRADE ASSNS. SUCH AS NORTH AMERICAN EQUIPMENT DEALERS AND FARM EQUIPMENT RETAILERS ASSN. ISN'T THERE A COMEDIAN NAMED GEORGE GOBLE? >>> George Goble 07/14/95 10:24am >>> Jeff, I get hounded a lot (on the net & email) from DIYers wanting to work on cars (with R12)... CAA section 609 "for consideration" which lets DIYers get away with not having to have certified recovery equipment, etc...and reading recent FAQs (made by others whom have talked to you and the ozone hotline)..and my reading of section 609 + Fedr Reg. updates, etc.. It is still not completely clear on 609 DIYers and the "venting" situation.. Section 608 is very clear on not venting Class I or II and cert needed to do everything.. (service, repair, disposal, etc) on 609.. some say DIY venting is OK?? and others say something to the effect, that no "certified" recovery equipment is needed, but it is not legal for DIYers to vent classI or II and they must come up with some means to achieve 4" vac in a system and capture the charge...(for class I and II) Wondered if you could clarify this when you have time (no hurry)? NO VENTING ALLOWED BY ANYONE AT ANYTIME! DIY-ERS DO NOT NEED TO USE CERTIFIED EQUIPMENT HOWEVER. DIY-ERS CAN USE ANY PIECE OF HOMEMADE EQUIPMENT, JUST SO LONG AS THEY DON'T VENT. THE EQUIPMENT DOES NOT HAVE TO ACHIEVE A 4-INCH VACUUM. WHO HAS TO USE EQUIPMENT THAT ACHIEVES A 4-INCH (102 MM) VACUUM? 1. TECHNICIANS WHO PURCHASED 608 EQUIPMENT PRIOR TO 11/15/93, AND 2. ANYONE WHO RECOVERS REFRIGERANT FROM AN MVAC OR MVAC-LIKE APPLIANCE (SUCH AS HEAVY CONSTRUCTION EQUIPMENT, FARM EQUIPMENT ETC.) THAT IS DESTINED FOR DISPOSAL. --- Also after Nov 15, 1995 it becomes illegal to vent "substitutes" for class I & II (mostly HFCs) unless the EPA determines that each substance poses no threat and can be vented... So this means R-134a must be recovered at that point. This is clear. If one runs into system charged with propane (R22 replacement)or OZ-12, total hydrocarbon refrigerants 0.0 ODP, can these be vented after Nov 15? NO, UNDER 609, NO SUBSTITUTES FOR R-12 IN AN MVAC CAN BE VENTED, SO OZ-12 CANNOT BE VENTED. UNDER 608, NO SUBSTITUTES FOR ANY CLASS I OR II SUBSTANCE CAN BE VENTED. thanks.. Have a good day :) --ghg ----------------------------------------------------- FARMER.FCT file (wordperfect) converted to plain txt From Christine Dibble @ the USEPA. ---- United States Office of Air and Radiation July 1995 Environmental Protection Stratospheric Protection Division Agency 6205J __________________________________________________________________________ Qs & As FOR FARMERS AND DO-IT-YOURSELF-ERS ON MOTOR VEHICLE AIRCONDITIONING AND THE CFC-12 PRODUCTION BAN OZONE PROTECTION HOTLINE TOLL-FREE (800) 296-1996 10 A.M.--4 P.M., MON.-FRI. EST Q:Is it true that I have to become a certified technician and purchase approved recycling equipment in order to work on my own motor vehicle's air conditioning system? A: No. Under Section 609 of the Clean Air Act, only people who repair or service air conditioning systems for consideration -- that is, for payment, whether it is monetary or some other form -- are required to be properly certified and to use equipment approved by the Environmental Protection Agency. That means that a do-it-yourselfer (DIYer) can work on his own car without being certified or having to buy recovery or recycling equipment. Like service technicians, DIYers are not permitted to vent freon (R-12 refrigerant) from an a/c system. Beginning on November 15, 1995, it will also be illegal for anyone to vent R-134a, or any other R-12 substitute. In addition, only certified technicians may purchase R-12. The EPA has not yet decided whether sales of R-134a will be restricted to certified technicians only. This decision should be made by November, 1995. Q: How do I comply with the law and service a/c systems on a tractor, or a car that is up on blocks, or any other vehicle that is difficult to move to a service facility? A: Topping Off. A farmer or other DIYer must become a certified technician in order to purchase freon to "top off" his own tractor, truck or other vehicle. If he becomes certified, he can purchase any size container of refrigerant and perform the topping off himself. Of course, farmers and DIYers should take all reasonable steps to avoid the release of refrigerant when topping off a system. Intentional venting is illegal, but should not normally occur during the topping off procedure if it is done properly. Other Servicing. Should a farmer or other DIYer wish to do more than merely top off, such as replace leaky or worn out components of an a/c system, then in order to avoid venting refrigerant when opening up the a/c system, the farmer or DIYer must make sure that the refrigerant gets recovered first. The refrigerant does not need to be extracted into EPA-approved recover/ recycling equipment -- it can be extracted into homemade equipment, for example -- but it must not be vented! Venting refrigerant can lead to fines of $25,000 per violation. If the farmer or DIYer does not own recovery equipment, he can drive the vehicle to a service facility, or hire a certified technician who has recover/recycle equipment to come to the vehicle and service it. Q: Apart from R-134a, what are some other refrigerants approved by EPA? Do I need to be certified to purchase them or install them in my vehicle's a/c system? Are there refrigerants that EPA considers unacceptable? A: EPA has approved R-134a and FRIGC*, a blend manufactured by Intermagnetics General Corporation of Latham, New York. FRIGC's manufacturer has informed EPA that FRIGC will initially be marketed for use in vehicle fleets only. Only certified technicians may purchase FRIGC, since it contains a chemical that depletes the ozone layer (although it does far less damage than R-12). You can call the Ozone Hotline in order to determine if other substitutes are approved by EPA in the future. Two refrigerants, OZ-12 and HC-12a, have been declared unacceptable by EPA, because of unanswered flammability concerns. It is illegal to use these refrigerants. They are both manufactured by OZ Technology, Inc. of Post Falls, Idaho. EPA has also stated that all flammable substitutes are unacceptable for use in vehicle a/c conversions. Q: I'm not a certified technician and so I cannot purchase R-12. I've been thinking about converting my motor vehicle air-conditioning system to use R-134a, since I can purchase that refrigerant. What facts should I know before I convert? A: First, EPA may restrict the sale of R-134a to certified technicians only. The proposed rule which would contain this provision (should EPA decide to propose a sales restriction) should be published in August, and, after thirty days of taking comment from the public, the final rule should be published in November. Check with the Ozone Hotline after the publication of the proposal to see if the sales restriction provision is contained in the proposed rule. If the provision becomes part of the final rule, then sales of R-134a will be limited to certified technicians shortly after publication of the rule. EPA recommends that you consult your vehicle manufacturer, an authorized dealer or a reputable service facility about conversion procedures. Many manufacturers have made retrofit guidelines available. To convert to R-134a, you will need at a minimum to change all the lubricant to a PAG or POE (ester) oil, since R-134a is not compatible with mineral oil, and you will have to put new fittings and a new label on the system. You may also need to replace the accumulator or receiver/drier, and other components of the system. EPA rules require that any substitute only be used with fittings unique to that refrigerant; that the person performing the conversion apply a specific label to the system; and that the substitute not be used to "top-off" a system that uses another refrigerant, without first extracting the old refrigerant. Q: I have heard that R-134a does not cool nearly as well as CFC-12. Is this true? A: Vehicle manufacturers have designed air-conditioning systems for new vehicles that use R-134a while maintaining reliability and cooling performance. Conversion specifications for a/c units using R-134a are also being designed to maintain performance, but this may vary depending on the condition of the unit prior to the conversion, and on other factors. Should you feel that your a/c system does not perform as well after converting to R-134a, you should contact the vehicle manufacture and/or a reputable service technician. They may be able to recommend further changes to the system so that it performs to your satisfaction. Q: Why can't I use R-22 in my system? A: There are three good reasons not to use R-22 in your system. First, R-22 is not compatible with the polymer and rubber products used in vehicle a/c systems such as O-rings and hoses, and can cause these products to det- eriorate. In addition, the small size of the molecules in R-22 often causes the chemical to leak through hoses. Second, R-22 has significantly higher operating pressures than R-12 -- at normal atmospheric temper- atures, R-22 pressures can be double those of R-12. Although R-134a also operates at higher pressures than R-12, the difference in the pressures is much smaller than the difference between R-22 and R-12 operating pressures. The control circuits, evaporative assemblies, and other components in a/c systems designed for use with R-12 may not be able to withstand these higher pressures, and system failure may result. Third, it's illegal. Any chemical proposed for use as a substitute to R-12 must first be submitted to EPA for review of its health and environmental effects. If EPA determines that the chemical is safe for use in a particular application, the chemical may then be used as a substitute for R-12. Until that happens, it is illegal to use the substitute in that application. To date, no one has submitted R-22 to EPA for review for automotive use (most likely because of the other two reasons set forth above). Q: Why does freon cost so much now? I used to purchase a can of freon for $1.00. A: The price of refrigerant has increased over the last few years largely because of the tax on the production of ozone-depleting chemicals enacted by Congress as part of the Omnibus Trade and Recon- ciliation Act of 1989. The tax rates were increased by Congress in the Energy Policy Act of 1992. The tax rate per pound of freon for 1995 is $5.35. This summer, freon is retailing at auto parts stores and warehouse stores at about $7.00 per pound (which includes the tax). Q: I'm not convinced that R-12 and other chlorofluorocarbons (CFCs) are responsible for the thinning of the ozone layer. I'm not even sure that the ozone layer is really thinning. How can I find out more about these issues? EPA has a great deal of information you can receive on these subjects by calling the toll-free Ozone Protection Hotline number listed at the top of this factsheet. This information includes a factsheet entitled "Ozone Depletion: The Facts Behind the Phaseout" and a brochure entitled "Reports to the Nation: Our Ozone Shield." -------------------------------------------------------------------------- END of EPA FARMERS.FCT file -------- Comments from ghg on DIY recovery equipment. Some easy ways to recover refrigerant are to take a recovery cylinder (or even a propane BBQ grill tank - it is DOT legal) and pull a vacuum on it just before the first use.. A "50lb" recovery cyl is the same size as the 20lb propane BBQ grill tank. For these purposes, a 30lb recovery cylinder would work better (dont use a DOT39 "throw away" refrigerant cylinder). Get a Rubbermaid 5 gallon water cooler, and stick the 30lb cylinder in it, and add dry ice around the edges.. This cools the cylinder so both R-12 and R-22 can be removed, and it will draw a vacuum on the system if left on long enough. If you can get it, liquid nitrogen works nicely also (-312F). Both dry ice and liquid nitrogen are very cold and can cause frostbite burns.. be careful. Precooling a cylinder in a freezer is usually not sufficient, it has to be colder than -21F to extract a charge from an R-12 system down to 0 PSIG. THe cylinder will warm up as the charge is removed... Wrapping a recovery cylinder with slightly flattened 3/8" copper tubing (on the outside), slowly venting liquid CO2 through the tubing would also be cold enough. Although an extreme fire danger would result, venting liquid propane in the same setup to cool a recovery cylinder would cool it enough for R-12 recovery but not R-22 recovery (about -40F). Care must be taken to remove the vented propane from the area with a very long hose and/or burn it off (flare it) safely at the release point to prevent a buildup of a "cloud" of gas which would cause an explosion if ignited. Don't try this one, unless you are already setup for handling explosive gasses. There are probably a zillion regulations with this option. Be very careful not of "overfill" the cylinder, use scales and dont exceed 70% of the "water capacity" (marked as WC), typically a BBQ grill tank will be WC 47.7, subtract out the tare weight (listed as TW), typically 12-13 lbs on a BBQ grill tank. JC Whitney sells propane level gauges which are temp strips which stick on the side of the tank, pour hot water on it, and the liquid level becomes visible. If the cylinder is overfilled, thermal expansion may result in 100% liquid full, when the cylinder warms up, causing the safety (popoff) to vent or the cylinder to explode. --ghg