The New CFC Recovery Requirement--Impact on Waste Refrigerator
Management in Washington State
DISCUSSION PAPER
January 1992
Introduction:
Household refrigerators contain up to several pounds of
chlorofluorocarbons (CFCs). CFCs are gases under ambient
They are nontoxic,
pressures and normal temperatures.
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nonflammable and noncorrosive ; however, once released, they
gradually drift into the earth's upper atmosphere where they
stimulate a chemical breakdown of the ozone layer that protects
the earth from harmful ultraviolet radiation.
Domestic refrigeration has been a minor but significant source of
used CFCs released in the United States: about 6 percent of
combined release from the total
refrigeration and air
conditioning sector in 1985.2 Releases of CFCs typically do not
occur when the refrigerator is operating, but when the
refrigerator is serviced, recycled, or disposed. Special
recovery equipment must be employed to avoid a CFC release.
The state's Clean Air Act of 1991 would restrict releases of CFCs
from refrigerators in July 1993; however, federal law preempts
the state requirement by moving the effective date one year
sooner. Section 608 of the U.S. Clean Air Act Amendments of 1990
establishes the following:
"Effective July 1, 1992, it shall be unlawful for any
person, in the course of maintaining, servicing, repairing,
or disposing of an appliance or industrial process
refrigeration, to knowingly vent or otherwise knowingly
release or dispose of any class I or class II substance
[includes CFCs] used as a refrigerant in such appliance (or
industrial process refrigeration) in a manner which permits
such substance to enter the environment."
The U.S. EPA is currently developing a rule to implement this
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Used CFCs may contain small concentrations of
hydrocarbons and acids, which are accumulated through use.
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toxic
This compares with 55% from car air conditioning. Intentional
venting of CFCs from car air conditioning systems is now banned by
the state and federal laws.
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requirement.
The rule will establish equipment and staffing
certification standards for CFC recovery operations. A draft of
the rule is expected in April 1992.
The optimum system for complying with the new requirement is not
yet clear. Experience is available from other states with a
system of transporting refrigerators to one central station that
specializes in refrigerator processing, including CFC recovery.
This model may not, however, be readily applicable to Washington.
Decentralized processing is most consistent with Washington's
solid waste institutional arrangements. Some cities and counties
are already laying preliminary plans to comply with the new
Unfortunately, little guidance is available to
requirement.
assist this planning. With this decentralized approach, rapid
technology transfer between counties and cities is crucial to
timely compliance with the new requirement.
While the technological issues will conceivably be resolved soon,
a potential exists to worsen the problem of white good dumping or
white good abandonment, which is already a prominent solid waste
problem in many rural areas of the state. If solid waste
managers fund their CFC recovery efforts through rate increases
for refrigerator or white good disposal (already indicated by one
county), there will be an increased financial incentive to
household generators to improperly manage or dispose their
refrigerators or white goods.
Generation, collection, and recycling of refrigerators in
Washington today:
Refrigerators are used by virtually all households. Their
average life expectancy is 12 years. The average unit weight is
225 pounds. Extrapolating from this information, an estimate of
the annual Washington generation of retired refrigerators would
be 120,000 units or 13,500 tons. Retired refrigerators comprise
about 34 percent by weight of the state's waste white good
stream.
White goods have been recycled at a rate of 50 - 52 percent over
the last four years. The refrigerator recycling rate separate
from the white good rate is unknown. About 60 percent of a
refrigerator by weight is desirable feedstock for scrap steel
recycling. Plastics, rubber seals, non-ferrous metals (aluminum
and copper), and insulating materials in the refrigerator
carcass, although allowed into the scrap metal stream, are
generally considered contaminants. The compressor unit,
containing approximately 15 pounds of steel and 5 pounds of
copper is widely believed by scrap metal recyclers to contribute
PCB oil to the scrap metal stream and is not accepted. Scrap
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metal recyclers in Washington only accept refrigerators with the
compressor already removed.
Solid waste receiving stations and scrap metal recyclers are
primary drop-off points for retired refrigerators. Some
appliance repair pick-up will provide pick-up services for
unwanted refrigerators, usually at a fee. The l-800-RECYCLE
hotline database shows about 60 drop-offs in the state available
to the public. Tipping fees vary from no charge to $40 per unit.
Local solid waste managers may contract with a recycler to remove
the refrigerator and other white goods or may landfill them.
Scrap metal recyclers may accept or charge upwards to $3 per unit
to accept refrigerators without compressors.
Washington refrigerator carcasses are transported in either
bailed or non-compacted form to one of three regional scrap
Carcasses from
ferrous shredding or smelting facilities.
eastern counties go to Plymouth, Utah. Carcasses from Columbia
River Counties go to Portland. Carcasses from western counties
go to Tacoma.
Tacoma's General Metals is the largest ferrous scrap receiver,in
the state. Twelve percent of their feedstock is white good
scrap. One half of this stream is in bailed form. Bailed white
goods are primarily shipped without further processing to Asian
markets. Their value is about $0.02 per pound. The other half
of the General Metal's white good stream is received as noncompacted white goods. These carcasses are shredded at General
Metals into fist-size bits. Mechanical sorting following
shredding results in three streams: ferrous metals, non-ferrous
metals, and "fluff." The ferrous stream is 96 percent pure and
is worth about $0.045 per pound. This material is an attractive
feedstock to domestic scrap smelters. Some non-ferrous metal (at
a maximum of about 5 pounds per refrigerator) may also be
recovered from this shredding, which has a value upwards to $0.60
per pound. "Fluff", consisting of plastic, rubber, foam, and
fibers (about 33 percent of the weight of a refrigerator) is
landfilled at a charge of $0.02 per pound. Other costs include
the energy, maintenance, and capital costs of operating a 3,000
horsepower shredder. The products that are produced from white
good ferrous metal include concrete reinforcement bars and steel
construction beams.
Existing models of refrigerator CFC recovery programs.
Appliance Recycling Centers of America in operation now for four
years is the longest standing appliance recycling service that
recovery CFCs from refrigerators. They operate centers in
Minneapolis/St. Paul, St. Louis, and Cleveland. ARCA picks up
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appliances at curbside and transfer stations and provides a range
of inspection and processing steps to enhance the recycling of
the appliances, including removal of CFCs, PCB-laden capacitors,
mercury-containing electrical switches. Copper components and
insulation materials may also be removed. Customers for the
service include private haulers, municipalities, and landfills.
In 1989, an ARCA representative visited Ecology and King County
staff to discuss the possibility of establishing a regional ARCA
station in the King County area. ARCA requires a contract
establishing a minimum supply of appliances and a set rate of per
unit reimbursement before they will establish a center in a new
region.
British Columbia Hydro, an electrical utility in British
Columbia, recently contracted with ARCA to establish an retired
refrigerator processing center near Vancouver. The program was
originally established as a pilot to serve Vancouver, but is now
being expanded to serve all of British Columbia. The program
includes a $50 rebate to the generator (to encourage them give up
their second refrigerator ("beer frig") or inefficient
refrigerator), curbside pick-up, long-haul transfer, and
processing at the ARCA center. BC Hydro provides curbside pickup
(estimated $30 cost) and long-haul transfer (estimated $20 cost).
BC Hydro pays ARCA a $30,000 per month fixed facility cost and
$14-$17 per unit processing cost. At the rate of 12,000 units
per year, the program now operates at a total cost of about $105
per refrigerator recycled, not including the $50 rebate given to
the generator. Once the program is at full capacity (40,000
units per year), this cost should decrease to about $85 per unit.
A scrap value of $25,000 for 14,000 refrigerator carcasses ($1.80
per carcass) has provided only slight cost-offsetting income to
BC Hydro for the program.
Despite a total current cost approaching $160 per unit (including
generator rebate and rebate administration), BC Hydra's
investment models show the program to effectively reduce cost per
kilowatt-hour provided. This would indicate a potential for
Washington's electric utilities (which are also economically
motivated to employ electrical demand management strategies) to
form a complimentary financial partnership with Washington's
solid waste sector in retirement of older, inefficient
refrigerators.
The ARCA model is a centralized processing model for white good
management. ARCA's promotional literature makes a case that
optimum processing and disposal of the detrimental-components of
white goods and optimum processing and marketing of the
recyclable metals is best done through a specialized and well-.
equipped facility.
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Some current efforts to comply with the new requirement in
Washington:
Many local solid waste jurisdictions are working to find ways to
comply with the imminent ban on refrigerator CFC venting:
a) Whatcom County: A work group consisting of local government,
business, and non-profit organization representatives have been
meeting once or twice per month since September 91 to explore
technologies and possible partnership arrangement to accomplish
CFC recovery from white goods. Island County and Skagit County
representatives have also participated in the effort. Currently
refrigerators are accepted by Recomp Inc., Whatcom County's
primary solid waste contractor, at a charge of $40 to the
generator. These refrigerators are transported to a landfill
outside the county. Recomp may discontinue accepting
refrigerators because of the imminent CFC venting ban.
A contracted recycler currently processes.
b) Skagit County:
refrigerators received at Skagit county solid waste receiving
facilities. The carcasses without compressors are accepted by
Skagit River Steel at a charge of $3 per unit, whereupon they are
bailed with other white goods and routed to General Metals. The
contractor intends to purchase equipment for CFC recovery but is
holding off until EPA releases a rule (expected in
February 1992) that will clarify equipment and operator
Skagit County raised their
certification standards..
refrigerator disposal fee from $6 to $22 at the beginning of 92
in anticipation of higher refrigerator processing costs following
from the CFC venting ban. The recycling contractor reports that
there has been a significant decrease in refrigerators coming
into the solid waste receiving stations since the first of the
year increase.
c) City of Spokane: The-city of Spokane recently purchased CFC
recovery equipment and intends to begin CFC recovery this
January. Staff have received training in CFC recovery through a
one-day workshop put on in Spokane by the International Mobile
Air Conditioning Association. The city intends to transfer the
recovered CFCs to Spokane Community College for use in their air
conditioning/refrigeration program. Compressors will be removed
and landfilled; however, any capacitors on the compressors will
be managed as hazardous waste on the assumption that the
capacitor may contain PCB oil. The City intends to maintain its
$5 disposal charge for refrigerators.
d) Thurston County: Thurston County is currently in the process
of renewing its recycling contract. It has released an RFP
requesting services and bids to recovery refrigerator CFCs at
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Thurston County solid waste receiving stations. Responses are
expected in March 92.
Further cost and processing considerations:
Solid waste managers will likely plan to train staff to
accomplish the CFC recovery or contract a specialized service to
provide the service at regular intervals or at request. The cost
of recovery equipment such as purchased by the City of Spokane
(Robinair 17500 B) is about $4000. The equipment is typically
mounted to a hand cart and conceivably could be used at more than
one solid waste receiving facility. The cost of training staff
can not be estimated until EPA provides a rule establishing the
certification requirements for persons that legally may recover
CFCs. Appliance repair specialists estimate that up to 15
minutes of staff time per refrigerator may be needed accomplish
the recovery, and have suggested a cost of $25 per refrigerator.
Only 0.5 to 1 pound of CFC will be generated per unit. This will
need an outlet. One important variable in recovery equipment is
whether the equipment will only extract the used CFC and pump it
into a pressurized container or go further and reclaim the used
CFC to some purity standard. Extracting and containing the used
CFC without reclaiming may be preferable in terms of simplifying
an in-house CFC recovery operation. This assumes that an offsite market will exist for the unreclaimed CFCs. DuPont and
other major refrigerant providers intend to collect used CFCs in
100 pound quantities and transport them to centralized
distillation facilities in the eastern United States. There, the
collected CFCs will be brought up to established specifications.
Washington's dangerous waste designation (more discussion later),
however, may be an impediment to this market.
The other option may be to reclaim the used CFC up to a purity
standard on-site and market locally--perhaps, to a community
college refrigeration training program. EPA's rule thatwould
establish such purity standards is not expected to April. This
probably does not leave adequate time to purchase equipment and
train staff up to the standards in the rule in time for July
refrigerator CFC venting ban. A variation of this option would
be for a contractor to reclaim the CFC on-site and then use the
reclaimed CFC in its appliance repair work.
Compressors must be removed currently if the refrigerator carcass
is to be recycled. City of Seattle staff had estimated the cost
of this operation to be $6.50. (This cost could conceivably be
less if combined with CFC recovery-- the compressor is tied into
the CFC bearing tubing.
These units are usually landfilled;
however, proper management may entail further steps.
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Some compressors have a capacitor attached to their exterior,
typically about the size of two D-cell batteries. Normally,
household refrigerators and freezers will not have PCB
capacitors; EPA has found, however, that several manufacturers of
pre-1978 household refrigerators and freezers occasionally used
PCB capacitors.
(PCB capacitors are more common in air
conditioning units.) One option is to assume that all capacitors
contain PCBs and manage separately as, hazardous waste. This
would result in upwards of $0.50 per capacitor hazardous waste
disposal cost.
Compressors also contain about six ounces of lubricating oil
within their casing. It may be optimal to 3drain this oil prior
to recycling or landfilling the compressor.
The oil may contain
CFCs (a halogenated compound), possibly causing it or other oil
that is commingled with it to exceed the maximum halogen content
for used oil that is exempt from hazardous waste designation.
One refrigeration specialist offered that if the CFCs are
recovered when the compressor is at room temperature or above,
CFC content in the oil will not be a problem. EPA has discussed
in their recent Used Oil Regulatory Proposal (Federal Register,
September 23, 1991, page 48047) to include refrigeration
compressor oil in the exempt used oil category if recycled and if
CFC recovery has occurred. A decision on this is forthcoming in
May 1992.
One complexity is if the compressor motor has short circuited
through failure of internal seals (a common reason to retire a
refrigerator), fluoric acid may be present. This contaminated
oil may present a health risk to the processor of the compressor.
Whether equipment or a procedure could be developed that would
address compressors with contaminated oil and would be
appropriate for local-level processing is unknown.
Refrigerator foam used in more recent units may contain as much
as three times more CFC gas than the refrigerator coils. (Pre1980 refrigerators most frequently used fiberglass or mineral
wool insulation.) The Clean Air Act does not require this source
to be addressed; however, it would be ideal to design a
refrigerator management system to address this source both to
anticipate any further extension of regulation and to demonstrate
maximum environmental responsibility. Equipment, developed in
Germany, may soon become available to extract CFCs from
refrigerator foam. This equipment is expected to cost upwards to
$1 million per machine. Appliance Recycling Centers of America
has expressed intent to import and market such equipment. An
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The compressor oil can usually be drained through the cut
tubes that originally connected the
compressor with the
refrigeration heat-transfer coils.
Drilling a hole in the
compressor can in some cases facilitate oil draining.
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alternative to using the equipment might be to remove the
refrigerator foam manually and then route for centralized foam
processing or controlled incineration; however, manual
dismantling or refrigerators is reported to be highly labor
intensive.
Pending Issues:
Several federal and state regulatory issues need to be resolved
to facilitate compliance with the July refrigeration CFC venting
ban:
a) Forthcoming EPA Rule. This rule is expected in April. It
should help solid waste managers decide whether it is preferable
to train existing staff to recover refrigerator CFCs or to enlist
a contractor with appliance servicing experience. The rule will
contain equipment standards and certification standards for
operators. Sharon Wilson, Region 10 EPA, (206) 553-0295, is
maintaining a mail list of individuals who would be interested in
receiving the rule once it is available.
b) Status of CFCs under Ecology's Dangerous Waste Regulations.
In February 1991, the EPA established an interim rule to exempt
recovered CFCs from the federal hazardous waste designation
procedure (Toxicity Characteristic Leachate Procedure). The
rationale for the exemption was that hazardous waste designation
might provide an increased
incentive for venting and would
inhibit recycling.4 CFCs, however, are still considered
dangerous waste in Washington state, under WAC 173-303-102 (the
criteria for persistent dangerous wastes).
This dangerous waste designation may be an impediment to
marketing CFCs originating in Washington in the national CFC
recycling system, according to CFC producing companies that
intend to collect used CFCs for recycling. State-level hazardous
waste designation is not removed following transfer to another
state, they explain, and permitted hazardous waste transporters
must be employed, at additional cost over common carriers, to
move Washington's used CFCs to the available CFC distillation
facilities in the eastern United States. For this reason and
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The EPA expects that there will be a national recycling market
for secondary CFCs once federal production limits and taxes on
primary CFCs become fully effective.
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possibly others, CFC producers that intend to provide used CFC
collection services nationwide have expressed a disinclination to
provide collection services within Washington state. Ecology
regulatory staff have countered that removal of hazardous waste
status for transportation purposes is possible once the used CFCs
have exited the state. The primary out-of-state result from the
state's listing of used CFCs, they maintain, is that the
reclaiming facility receiver would need to report to the
generator that the material had been received and properly
recycled.
Conceivably, the exemption for household waste in the Dangerous
Waste Regulation could be used to assist entry of used household
refrigerator CFC into the national CFC recycling system. Most
counties are beginning to implement moderate risk waste programs,
as required by RCW 70.105.220(8), for collection and management
of household and business (typically small business) wastes that
have dangerous waste characteristics but are generally exempt
from the Dangerous Waste regulation. Management of refrigerator
CFCs could be incorporated into these programs. Even if the
household exemption is clearly established, national CFC buyers
may not be willing to directly collect, or to provide industrystandard containers for collection, for household used CFCs inWashington state, as is expected in other states--the quantity of
exempt used CFC available in the state may not be large enough to
justify their setting up a collection program here. Without this
collection service, counties could probably use their hazardous
waste contractor as an outlet for their used refrigerator CFC,
who could arrange for the material to enter the national
recycling system. This may involve, however, payments to the
contractor for the service or loss of recycling payments to the
moderate risk waste program.
Further research needs:
To best inform local and state policy-makers, more information
and analysis is needed in the following areas:
a) A survey of local jurisdictions on current management of white
goods and current or planned activities to comply with the
refrigerator CFC venting ban.
b) Available CFC recovery methods applicable to household
refrigerators.
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c) A best management practice for refrigerator compressors.
d) Optimum processing of refrigerators that considers both
potential recycling returns and best possible management of the
toxic components and the CFCs (in both the refrigerator tubing
and the insulating foams).
e) Possible financial partnerships between the electrical utility
and solid waste sectors in conducting refrigerator retirement
programs.
f) Design changes to refrigerators that would encourage
recycling-- optimally rebuilding- -once the units reach retirement.
Comments may be directed to Steve Barrett, Department of Ecology,
Waste Reduction, Recycling, and Litter Control Program, MS 7600,
Olympia, WA 98504-7600, (206) 459-6286.
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