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Jat2074

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May 7, 2001, 8:41:30 PM5/7/01
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ok check this out. i've been working for a heating/cooling company now for 1
year.
i have never taken any refrigeration class of any kind.
in the past year I've changed probably 100 a/c units and probably 25 furnaces.
i worked with someone for my first year and now i'm going to jobs by myself and
a helper. Anyway, what i wanted to know is.
1. Aren't there laws that prohibit me from handling freon? I've heard stories
on the subject but no clear answer. Someone told me that I was legal because
the people I work for are licensed. And as long as they are licensed the people
they employ are legal also.
2. What does everyone do with their old a/c units that they replace?
We just store ours outdoors and uncovered and eventually we get around to
pulling the compressor out and draining the oil into buckets (which we leave
out in the rain). we do charge a disposal fee to the h/o's but never pay to
dispose.
3. What about capisitors? i just chunk them in the trash. But I think they are
supposed to be disposed of in a diffrent way.
anyone with a clear answer on this matter? or does anyone know where i can
find info on the internet?

ftwhd

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May 7, 2001, 9:05:56 PM5/7/01
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I would suggest you call the EPA to find out the answers you've asked
us, that way you will get the straight scoop from the people in the
know.

Whats that number? 1-800 something ozone, I forget. Come on fellas
for once help someone and give him the number. LOL

Mike
UA local 370

ftwhd

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May 7, 2001, 9:10:06 PM5/7/01
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On 08 May 2001 00:41:30 GMT, jat...@aol.com (Jat2074) wrote:

>ok check this out. i've been working for a heating/cooling company now for 1
>year.
>i have never taken any refrigeration class of any kind.

snip

P.S.

Oh yea, Im sure the HVAC hobbyist will be all over this one..

Mike
UA local 370

Craig

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May 7, 2001, 9:14:25 PM5/7/01
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>
> 1. Aren't there laws that prohibit me from handling freon? I've heard stories
> on the subject but no clear answer. Someone told me that I was legal because
> the people I work for are licensed. And as long as they are licensed the people
> they employ are legal also.

Yes most definitely. You need to be EPA certified. Your employers certs do nothing
for you. Sad that your employer/hack lets you put yourself in this position.


>
> 2. What does everyone do with their old a/c units that they replace?
> We just store ours outdoors and uncovered and eventually we get around to
> pulling the compressor out and draining the oil into buckets (which we leave
> out in the rain). we do charge a disposal fee to the h/o's but never pay to
> dispose.

LOL. Ours all get picked up by the scrap man once we remove the oil, refrigerant
and properly label the unit. Seems like its time to find a new job.

Craig

J. S. Nunes

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May 7, 2001, 9:24:35 PM5/7/01
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Try the National Response Center for reporting the "hazardous waste" oil
spills at 1-800-424-8802
Your local EPA and/or DNR office will be contacting you withing just a few
short minutes :-)

"ftwhd" <ft...@usl.com> wrote in message
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Jabarco

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May 7, 2001, 10:07:04 PM5/7/01
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Jat2074 <jat...@aol.com> wrote in message
news:20010507204130...@ng-fw1.aol.com...

> 1. Aren't there laws that prohibit me from handling freon? I've heard
stories
> on the subject but no clear answer. Someone told me that I was legal
because
> the people I work for are licensed. And as long as they are licensed the
people
> they employ are legal also.


Dear Jat2074,
Call the EPA's Ozone Infomation Hotline @ 1-800-296-1996 and ask for the
Section 608 Enforcement Officer. He will be glad you called. Or you can go
to:
http://www.epa.gov/ozone/enforce/technicians.html to learn more.

Jabarco


Jat2074

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May 7, 2001, 11:36:00 PM5/7/01
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i appreciate everyones advice and input.
but i don't think i want to call and report anyone. i'm not trying to get
anyone in trouble and after all... it does pay the bills for now. i think it's
time to look for another place to work. once again, thanks for the info
everyone.

Earle Edomm

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May 7, 2001, 11:54:03 PM5/7/01
to
You've accidentally trolled into alt.hvac You should be in, no you're
needed in alt.home.repair You could be wealthy beyond your wildest dreams
over there; here you're likely to succumb to famine as Jabs lounging on his
new furniture, strums "Another One Bites The Dust" on a worn yet, quite
serviceable, obviously sentimental guitar. An interesting instrumental
juxtaposition considering only the purchasing power he leaves as a tip for a
daily morning coffee. Singularly reminiscent of the mysterious habits of
the Ferengi Patricians

BTW, Do you think I could get out of a speeding ticket if, with my finger up
my nose, I babbled on about how though I'd heard bits and pieces about this
"traffic law thing" I just didn't know......

Yours in utter amazement,

Earle


Jat2074 <jat...@aol.com> wrote in message
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server12

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May 8, 2001, 1:17:54 AM5/8/01
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You're kidding right?
-s12


"Jat2074" <jat...@aol.com> wrote in message
news:20010507204130...@ng-fw1.aol.com...

Dave & Nicole Herrington

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May 8, 2001, 2:10:40 AM5/8/01
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What do you do with asbestos and lead?

Does this mean we will have to recover the 6000 lbs out of our ice rink when we
dump the system next month?

Actually - I rarely work with refrigerants or asbestos, but they still require me
to hold a universal card and a 40 hr abatement license.

Dave

Jabarco

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May 8, 2001, 11:41:04 AM5/8/01
to
Jat2074, relax. I found what you wanted to hear from us and it's current as
of May 4, 2001.

40 CFR - CHAPTER I - PART 82
§ 82.161 Technician certification.
(6) Apprentices are exempt from this requirement provided the apprentice is
closely and continually supervised by a certified technician while
performing any maintenance, service, repair, or disposal that could
reasonably be expected to release refrigerant from appliances into the
environment. The supervising certified technician is responsible for
ensuring that the apprentice complies with this subpart.

For more info, click the link below:
http://ecfrback.access.gpo.gov/otcgi/cfr/otfilter.cgi?DB=1&SORTBY=%42%49%42%
53%52%54&ACTION=View&QUERY=&RGN=%42%54%49&OP=and&QUERY=%74%65%63%68%6E%69%63
%69%61%6E%20%63%65%72%74%69%66%69%63%61%74%69%6F%6E&OP=and&QUERY=&OP=and&QUE
RY=&OP=and&SUBSET=SUBSET&FROM=1&SIZE=10&ITEM=7

Jat2074 <jat...@aol.com> wrote in message

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Jabarco

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May 8, 2001, 11:47:00 AM5/8/01
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Jat2074, you might have to copy and paste the entire hyperlink below to your
address bar to get there.
Jabarco

Jabarco

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May 8, 2001, 12:23:27 PM5/8/01
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CTV

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May 8, 2001, 1:57:29 PM5/8/01
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Jat2074: You shouldn´t take any chance on that. You must be certified to do
that type of work. The fine is $27,500, and any customer that is aware of
the law will call EPA as they will get a $10,000 reward for turning you in.
If you need additional information please let me know. I will be glad to
help you with any information regarding this subject.


"Jat2074" <jat...@aol.com> escribió en el mensaje
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Earle Edomm

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May 8, 2001, 3:22:08 PM5/8/01
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Before he relaxes he might want to check with the EPA. I went down that
road several years ago and got it in writing for my own protection when
training apprentices. An apprentice is only an apprentice if he is in a
registered federal program. Furthermore if he works by himself he is in no
way "closely and continually supervised"

He's got a computer and figured out how to get to a newsgroup but with more
than a years experience in the trade he knows so little about the industry
that he asks that question here. I think I hear a trolling motor.......


Earle

Jabarco <bul...@hotmail.com> wrote in message
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Don Ocean

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May 8, 2001, 5:02:07 PM5/8/01
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Too late!! 65 people here are now fighting over the bounty($10,000)
for turning him in. ;-)

Greg

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May 7, 2001, 11:10:20 PM5/7/01
to
Run, don't walk to another job before the EPA gets you and your employer!!
Do you have a spare $10,000 or more laying around to pay your fines?
You need to be certified to handle refrigerants, your employers license does
not cover you!
Your employer is breaking hazardous waste disposal laws also!
Greg


"Jat2074" <jat...@aol.com> wrote in message

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CTV

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May 9, 2001, 2:48:29 PM5/9/01
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Too bad! There will be 65 losers. I will only turn in someone who is
breaking the laws being congnizant of it; never someone that did it for
ignorance and is seeking information to comply with the laws. I hope you
were kidding!


"Don Ocean" <doc...@qwest.net> escribió en el mensaje
news:3AF85ECF...@qwest.net...

Feyd

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May 9, 2001, 6:53:09 PM5/9/01
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Ignorance of the law is no excuse. I don't always agree with the law,
but who am I to change things. I am neither female or gay and it seems
that those are the are the only people they listen too.

Don Ocean

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May 9, 2001, 8:54:06 PM5/9/01
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Of course I was kidding.... But the message is: Someone,
somewhere just may do just that. Get it straightened out
before disaster hits. Ignorance in this field can financially
destroy a small business. And if your business insurance
gets wind your not certified... They will drop you from
your liability....even though fines are not covered by
the policy. Always have your financial back covered.
I don't know about the rest of the folks here, but I
play poker, hunt and fish etc with my competitors.
We are family in this business.. Okay! Okay! so we
have a few family spats from time to time. But thats
mostly educational and to relieve the boredom. ;-)
Don Ocean
Sioux Falls, SD

PS This ole Maverick turns nobody, notime, in!! That doesn't preclude pioneer
justice though.;-)

Feyd

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May 9, 2001, 10:03:16 PM5/9/01
to
Thank God it is that way where you live. Where I live it's a dog eat
dog world. The back stabbing runs rampant around this area. I can
remember back about 7 years ago when it was a family; then it turned
into a business. I long for the good old days.

On Wed, 09 May 2001 19:54:06 -0500, Don Ocean <doc...@qwest.net>
wrote:

Earle Edomm

unread,
May 9, 2001, 11:13:22 PM5/9/01
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Gosh, officer I wasn't cognizant of the fact and it was ignorance of the law
when I ran that red light and killed three kids. That makes it okay, right.
Oh and by the way, it's a shame when a guy makes a post like that and has to
come back and explain he was kidding. If we got everybody here to type
slower would that help your understanding in the future?

Earle


CTV <t@t.t> wrote in message news:3af98ff4@news...

ftwhd

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May 11, 2001, 7:30:32 PM5/11/01
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Gosh officer I didn't see the motorcyclist I killed while making a
left turn in front of him..

Officer; That's ok, its not your fault. No ticket, no charges, have a
nice day.

Gosh officer I didn't see the car stopped in the street and Im sure
sorry it blew up killing all the occupants.

Officer: Your going to jail for involuntary manslaughter bub.

Moral: its ok to kill a biker but you better not kill anyone in a car.
Happens every day and I don't get it.

Mike
UA local 370

On Wed, 9 May 2001 22:13:22 -0500, "Earle Edomm" <co...@directlink.net>
wrote:

gerry

unread,
May 11, 2001, 8:01:42 PM5/11/01
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Although I would never recommend it, it is completely legal to replace an AC
unit without any certification (from an EPA perspective, local regulations
may be stricter).

The way:

1 - Scrap the old system. Technician certification is not required for
individuals removing refrigerant from appliances in the waste stream. EPA
certified recovery equipment and methods must still be used.

2 - Install a precharged split system which meets the EPA requirements under
the 1995 stay on sale of refrigerants regarding pre-charged systems.

I said legal, not practical, cost effective or sensible! The one time cost
of recovery equipment and disposal of the recovered refrigerants would
probably cost a lot more than any savings. I didn't even mention the cost of
a botched job.

gerry
.......

gerry misspelled in my email address to confuse robots

gerry

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May 11, 2001, 8:45:30 PM5/11/01
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[original post is likely clipped to save bandwidth]

On Sat, 12 May 2001 00:01:42 GMT, gerry <gerr...@gogood.com> wrote:


>The way:
>
>1 - Scrap the old system. Technician certification is not required for
>individuals removing refrigerant from appliances in the waste stream. EPA
>certified recovery equipment and methods must still be used.

Arguing with myself, depending upon which EPA page document you read, this
is either true as stated or restricted to equipment "typically" disposed
with its charge intact. That would exclude most central air systems which
are not "typically" disposed with their charge intact.

ftwhd

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May 12, 2001, 4:52:15 AM5/12/01
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What equipment is typically disposed of with the charge intact?

Mike
UA local 370

gerry

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May 12, 2001, 9:39:49 AM5/12/01
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[original post is likely clipped to save bandwidth]

Refrigerators, window units, automobiles... Somebody in the waste stream
must remove the charge before the appliance reaches it's final resting place
or is destroyed and that person does not need an EPA certification. They can
even use home made equipment provided it meets (and form filed) the same
requirements as new EPA certified equipment.

I found two references at the EPA site - the first just stated "appliances
in the waste stream". The 2nd prefaced it with "typically disposed..."

Both references were under venting regulations, not certification
requirements.

gerry

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May 12, 2001, 10:20:08 AM5/12/01
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[original post is likely clipped to save bandwidth]
On Sat, 12 May 2001 04:52:15 -0400, ftwhd <ft...@usl.com> wrote:


>
>What equipment is typically disposed of with the charge intact?

The document I feel is most likely accurate is

http://www.epa.gov/Ozone/title6/608/608fact.html#disposal

but it is a fact sheet, not a regulation.

it states:

"
Safe Disposal Requirements

Under EPA's rule, equipment that is typically dismantled on-site before
disposal (e.g., retail food refrigeration, central residential air
conditioning, chillers, and industrial process refrigeration) has to have
the refrigerant recovered in accordance with EPA's requirements for
servicing. However, equipment that typically enters the waste stream with
the charge intact (e.g., motor vehicle air conditioners, household
refrigerators and freezers, and room air conditioners) is subject to special
safe disposal requirements.

Under these requirements, the final person in the disposal chain (e.g., a
scrap metal recycler or landfill owner) is responsible for ensuring that
refrigerant is recovered from equipment before the final disposal of the
equipment. However, persons "upstream" can remove the refrigerant and
provide documentation of its removal to the final person if this is more
cost-effective.

The equipment used to recover refrigerant from appliances prior to their
final disposal must meet the same performance standards as equipment used
prior to servicing, but it does not need to be tested by a laboratory. This
means that self-built equipment is allowed as long as it meets the
performance requirements. For MVACs and MVAC-like appliances, the
performance requirement is 102 mm of mercury vacuum and for small
appliances, the recovery equipment performance requirements are 90 percent
efficiency when the appliance compressor is operational, and 80 percent
efficiency when the appliance compressor is not operational.

Technician certification is not required for individuals removing
refrigerant from appliances in the waste stream.
"

gerry

ftwhd

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May 12, 2001, 7:42:00 PM5/12/01
to

I read this and your other post and all I have to say is that your
interpretations of the regs are full of more shit than a Christmas
turkey and are not grounded in reality. Have you ever considered
woodworking as a past time?

Mike
UA local 370

gerry

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May 12, 2001, 10:02:53 PM5/12/01
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[clipped as a courtesy to other readers]
On Sat, 12 May 2001 19:42:00 -0400, ftwhd <ft...@usl.com> wrote:


The only question you asked was:

>What equipment is typically disposed of with the charge intact?

then stated, after my replies:

>I read this and your other post and all I have to say is that your

>interpretations...

I exactly quoted

http://www.epa.gov/Ozone/title6/608/608fact.html#disposal

No interpretation was included. Perhaps you could be a bit more specific as
to the point you intended to make.

Earle Edomm

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May 12, 2001, 10:12:11 PM5/12/01
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Come on Mike, rotating electrically driven cutting tools.... be nice

Earle

J. S. Nunes

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May 12, 2001, 10:28:32 PM5/12/01
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gotta be qualified on something sharper than a crayon first

"Earle Edomm" <co...@directlink.net> wrote in message
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CBHVAC

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May 13, 2001, 1:39:45 AM5/13/01
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But..wait..but..you mean...oh no...you mean....oh heaven forbid that
recovery and recycle certificate is bogus....

How in the heck did you get that a person removing refrigerants does NOT
have to be certified in handling from that? It says NO PLACE that they do
NOT have to have a cert....

--

"gerry" <gerr...@gogood.com> wrote in message
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ftwhd

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May 13, 2001, 7:32:46 AM5/13/01
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My points are;

1. There is no way a scarp yard or SE (sanitation engineer) is going
to take a refrigerator, freezer, window shaker ect without it first
being properly recovered, tagged as such with the EPA number of the
person who did said recovery.

2. You just cant make some hookey home made recovery machine and call
it good. You have to send to the EPA the make, model and serial
number, and year of manufacture to the EPA.

3. You have to be certified to recover refrigerant, and break into
all refrigeration systems.

4. The little snippets you quote are largely out of context, meaning
that the final person in the disposal chain makes sure that the
refrigerant was properly recovered by a certified technician. So
there are not actually disposed of with refrigerant intact.

5. The regs are full of catch 22's.

6. You spend way too much time reading into the regs what you view as
facts to validate what ever position you want to take at the time.

7. Your post indicates that recovery does not have to be preformed by
a certified technician on the equipment you listed which is absolute
BS.

8. Your a HVAC hobbyist and not qualified to give professional
advice, your posts should be prefaced with some type of disclaimer
stating that you have very limited hands on experience and most of
what you have learned has been the result of hanging around here for
years and spending countless hours surfing the net for information.

9. You need to find another hobby and quit trying to mislead people
about EPA regs by posting small snippets of the regulations.

10. It is highly probable that there is no EPA certified personnel in
the employ of any scrap yard or land fill to do legal recovery.

Mike
UA local 370


gerry

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May 13, 2001, 9:08:03 AM5/13/01
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[original post is likely clipped to save bandwidth]
On Sun, 13 May 2001 01:39:45 -0400, "CBHVAC" <in...@carolinabreezehvac.com>
wrote:

>But..wait..but..you mean...oh no...you mean....oh heaven forbid that
>recovery and recycle certificate is bogus....
>
>How in the heck did you get that a person removing refrigerants does NOT
>have to be certified in handling from that? It says NO PLACE that they do
>NOT have to have a cert....


Argue with the EPA, I didn't author the last sentence:

"Technician certification is **not required** for individuals removing


refrigerant from appliances in the waste stream."

Again, I didn't write it, or interpret it - those are EPA words, not mine. I
added the "**" so you would see it this time. That is the only modification.

Earle Edomm

unread,
May 13, 2001, 9:45:50 AM5/13/01
to
Do you know of any of any scrap or junkyards that observe that rule? Every
single one that I know of WILL NOT under any circumstances accept these
items without the "certificate of certified refrigerant removal" from an EPA
certified person. I'm not saying your wrong here Jerry, just that for
practical purposes they won't do it. My understanding from them is that if
they did it the EPA would be all over them like a duck on a June bug to make
sure they followed the rules correctly. While they may be able to do it,
they would be subject to EPA record-keeping and EPA audits. For a pittance
they may as well use a certified employee thus ensuring the employee knows
the proper procedures. While everyone is subject to EPA rules and
record-keeping anyway an uncertified person who recovers legally is kind of
like an poor innocent uninsured motorist in an old jalopy who has a wreck
with an insured motorist, whose at fault, in a new luxury car. The jalopy
guy might be right but can he afford the defense against a wealthy insurance
company.
The EPA certification is nothing more than a minimum standard that is a
measure of proof that an individual understood the important rules well
enough to pass a test. Compare that to someone that has no proof other than
an interpretation in the Federal Register. Remember that the EPA compliance
officers will move quickly to ensure the safety of the environment, as they
should, and move slowly to approve something that may hurt it. Six or seven
years ago I asked the regional EPA office for a clarification of the term
apprentice, as used to allow non-certified persons to handle refrigerants in
a learning environment. After three weeks of waiting for an answer I
started pressing harder and harder and after about six weeks I got the
answer verbally. It took another six weeks to get it in writing. Could a
business tolerate a shutdown for that period of time while they sorted
everything out. Why not just have certified employees? It would be too
easy for someone to complain about the business to the EPA, the EPA check
and find no certified employees, then stop everything while they audit
records.

Earle .


be certified as spend the time to be certified and ensure circumvent


gerry <gerr...@gogood.com> wrote in message

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gerry

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May 13, 2001, 10:07:44 AM5/13/01
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[original post is likely clipped to save bandwidth]
On Sun, 13 May 2001 07:32:46 -0400, ftwhd <ft...@usl.com> wrote:


>My points are;
>
>1. There is no way a scarp yard or SE (sanitation engineer) is going
>to take a refrigerator, freezer, window shaker ect without it first
>being properly recovered, tagged as such with the EPA number of the
>person who did said recovery.

Funny, every town dump in MA is REQUIRED to take them or make other
provisions for residents. $0 charge. In MA, it is illegal to dispose of
refrigerators otherwise without proper documentation.

>
>2. You just cant make some hookey home made recovery machine and call
>it good. You have to send to the EPA the make, model and serial
>number, and year of manufacture to the EPA.

Those are EPA words, not mine.



>
>3. You have to be certified to recover refrigerant, and break into
>all refrigeration systems.

Those are EPA words, not mine.

>
>4. The little snippets you quote are largely out of context, meaning
>that the final person in the disposal chain makes sure that the
>refrigerant was properly recovered by a certified technician. So
>there are not actually disposed of with refrigerant intact.

I quoted the ENTIRE "Safe Disposal Requirements" section, not a snippet.


>
>5. The regs are full of catch 22's.

We certainly agree with that one. This one by no way affects the service
industry. I would not attempt to defend the logic of many EPA regulations.
You can't vent propane used as a refrigerant (more common in other
countries) but the gas delivery guy is required to vent to check for
overfill!


>
>6. You spend way too much time reading into the regs what you view as
>facts to validate what ever position you want to take at the time.

Perhaps a *FEW* pros need to read a bit more also rather than just toss out
statements with no references.


>
>7. Your post indicates that recovery does not have to be preformed by
>a certified technician on the equipment you listed which is absolute
>BS.

Those are EPA words, not mine.


>
>8.

>9.

Perhaps you can quote the EPA reg that makes the "Safe Disposal Requirement"
invalid.


>10. It is highly probable that there is no EPA certified personnel in
>the employ of any scrap yard or land fill to do legal recovery.


It would appear the EPA knows that and thus made it legal.

My, or your opinion still do not change regulations we may feel are stupid
or inconsistent.

Earle Edomm

unread,
May 13, 2001, 10:14:08 AM5/13/01
to
Without any malice in my heart towards Gerry, Mike's post is extremely well
thought out and dead on. Gerry is so close and yet so far......... If he
weren't so darned eager to be what he's not he'd likely discover complete
acceptance and respect for what he is becoming a valuable resource here.
You never know what transformations the future brings but I'm beginning to
doubt this guy ever will. He's kind of like a guy who wants to hang out
with dumb friends so he can feel smart but just can't find any dumb enough.
I'm sure he's got a lot of education, the whole hydro / hygro debacle
notwithstanding. Which by the way I'll dig into if I can ever get the time
and right resources, for my own edification. He on the other hand will
never be convinced and has stated, in so many words, that the really elite
find such mundane facts trivial. Don't you just love an engineer who finds
any facts trivial, reminiscent of Challenger, eh? The difference between us
is I'm still learning. To wit, and I'm quoting "I'm thinking that hydro
refers to water specifically whilst hygro refers not to the water but
something that relates to the water, i.e. a crystal that absorbs water".
That's from a conversation I had, where I asked the question without any
preface, with my son yesterday over venison burgers and chicken fried ribeye
(only in Texas) at my daughters graduation dinner. His track record to date
makes him seem like a more credible source than Jerry.

Do the disclaimer...


Earle

ftwhd <ft...@usl.com> wrote in message
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gerry

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May 13, 2001, 10:57:21 AM5/13/01
to
[original post is likely clipped to save bandwidth]
On Sun, 13 May 2001 08:45:50 -0500, "Earle Edomm" <co...@directlink.net>
wrote:

>Do you know of any of any scrap or junkyards that observe that rule? Every


>single one that I know of WILL NOT under any circumstances accept these
>items without the "certificate of certified refrigerant removal" from an EPA
>certified person. I'm not saying your wrong here Jerry, just that for
>practical purposes they won't do it.

Every town dump in MA is required to by MA law. Actually it is a state
"white metal recycling" law, not a refrigerant law. I know my town dump has
no EPA technician and the things get torn up before leaving as scrap steel.
Also, every auto junk yard in MA. They have a certified oiless recovery
machine (too much labor to build one and prove it works?) and use those
simple piercing modified "vise grips". They only touch "small appliances"
Big stuff must have a tag. I have no idea how much money they might waste by
accidentally mixing recovered refrigerants.

> My understanding from them is that if
>they did it the EPA would be all over them like a duck on a June bug to make
>sure they followed the rules correctly. While they may be able to do it,
>they would be subject to EPA record-keeping and EPA audits.

I am not defending the consistency of EPA rules but the "Safe disposal"
regulations clearly are very different than service regulations which most
folks in this forum are accustomed to. After I found the more complete safe
disposal requirements, there seems to be a very close match up on types of
equipment covered under this exemption. The type of equipment covered
closely matches that (in general) of that covered by open book mail order
EPA certifications - MVAC and HVAC small appliance.

Those certifications seem only to exist to be sure the regs were read at
least once and certainly not to demonstrate competency.

>Why not just have certified employees?

That would make complete sense to me - anybody who can't pass the open book
MVAC or HVAC type I exams is in real trouble. But, as soon as the got that
they wouldn't be working in this kind of "dump"

But, I didn't make the rules.

BTW - as a courtesy to others would you use "Gerry". I do use both and know
who you mean but others may think it is two different persons.

gerry

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May 13, 2001, 11:08:03 AM5/13/01
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[original post is likely clipped to save bandwidth]
On Sun, 13 May 2001 09:14:08 -0500, "Earle Edomm" <co...@directlink.net>
wrote:


>Don't you just love an engineer who finds
>any facts trivial, reminiscent of Challenger, eh?

With Challenger, the engineers said "don't launch, the o-rings will fail",
management said "launch"

You might want to check your disinformation before you post it.

Earle Edomm

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May 13, 2001, 1:53:23 PM5/13/01
to
Ok, Ok I'll defer to the use of Gerry, but I've got a book that lists it
spelled the other way

;-).

Earle


gerry <gerr...@gogood.com> wrote in message

news:3d5tft00qq41alqmn...@4ax.com...

Earle Edomm

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May 13, 2001, 1:55:18 PM5/13/01
to
All the engineers? What about the ones that were managers? Myself as the
general public wouldn't make much distinction there. But your point is well
taken I won't post in that arena again with a disclaimer.....

;-)

Earle

gerry <gerr...@gogood.com> wrote in message

news:2m8tftk7qi74q2i3h...@4ax.com...

ftwhd

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May 14, 2001, 5:15:11 PM5/14/01
to
On Sun, 13 May 2001 14:07:44 GMT, gerry <gerr...@gogood.com> wrote:


>>
>>2. You just cant make some hookey home made recovery machine and call
>>it good. You have to send to the EPA the make, model and serial
>>number, and year of manufacture to the EPA.
>
>Those are EPA words, not mine.
>

Heres some other EPA words

Refrigerant recovery/recycling equipment for use on stationary
refrigeration equipment (non-motor vehicle
equipment) must be certified to meet EPA standards
as specified in 40 CFR 82F. Under the certification
program, EPA requires that equipment manufactured
on or after November 15, 1993, be tested by an
EPA-approved testing organization to ensure that it
meets EPA requirements. Recycling and recovery
equipment intended for use with air-conditioning
and refrigeration equipment besides small appliances
must be tested under the ARI 740-1993 test
protocol, which is included in 40 CFR 82F as Appendix B.
Recovery equipment intended for use with small
appliances must be tested under either the ARI 740-1993
protocol or Appendix C of 40 CFR 82F.

Now that more or less prevents some crane operator from attaching a
homemade junk yard machine to recover refrigerant don't it.


>>
>>3. You have to be certified to recover refrigerant, and break into
>>all refrigeration systems.
>
>Those are EPA words, not mine.

and some more
>
EPA has established a technician certification program for persons
("technicians") who
perform maintenance, service, repair, or disposal that could be
reasonably expected to
release refrigerants into the atmosphere. The definition of
"technician" specifically includes
and excludes certain activities as follows:

Included:

attaching and detaching hoses and gauges to and from the
appliance to measure pressure
within the appliance;

adding refrigerant to or removing refrigerant from the appliance

any other activity that violates the integrity of the MVAC-like
appliances, and small
appliances.

In addition, apprentices are exempt from certification
requirements provided the apprentice
is closely and continually supervised by a certified technician.

The Agency has developed four types of certification:

For servicing small appliances (Type I).

For servicing or disposing of high- or very high-pressure
appliances, except small
appliances and MVACs (Type II).

For servicing or disposing of low-pressure appliances (Type III)

For servicing all types of equipment (Universal).

You see that universal type? That's me. Heres my # from the
University of Toledo, #07181015. I indeed know the rules and don't
spend time trying to find a loop hole that don't exist. Quit trying
to propagate false or misleading information concerning the air we
breath some dumb as a rock homemoaner or crane operator will read your
posts and cut the lines venting an ozone depleting substance making
the world a worse place than it already is.


>>
>>4. The little snippets you quote are largely out of context, meaning
>>that the final person in the disposal chain makes sure that the
>>refrigerant was properly recovered by a certified technician. So
>>there are not actually disposed of with refrigerant intact.
>
>I quoted the ENTIRE "Safe Disposal Requirements" section, not a snippet.
>

If I quote one paragraph from Moby Dick is it the whole book or just a
snippet?


>>
>>5. The regs are full of catch 22's.
>
>We certainly agree with that one. This one by no way affects the service
>industry. I would not attempt to defend the logic of many EPA regulations.
>You can't vent propane used as a refrigerant (more common in other
>countries) but the gas delivery guy is required to vent to check for
>overfill!
>
>
>>
>>6. You spend way too much time reading into the regs what you view as
>>facts to validate what ever position you want to take at the time.
>
>Perhaps a *FEW* pros need to read a bit more also rather than just toss out
>statements with no references.
>
>

I didn't feel a real need to quote references because the real
licensed guys here already know what's up and what the regs are. Its
old news to most of us but apparently not to you.

Perhaps the hobbyists need to study the entire document and understand
that it is illegal to vent refrigerant of any kind from any
refrigeration machine regardless of size.


>>
>>7. Your post indicates that recovery does not have to be preformed by
>>a certified technician on the equipment you listed which is absolute
>>BS.
>
>Those are EPA words, not mine.
>
>>
>>8.
>
>>9.
>
>Perhaps you can quote the EPA reg that makes the "Safe Disposal Requirement"
>invalid.
>

ok how is this..

(c) PROHIBITIONS.-(1) 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 used as a
refrigerant
in such appliance (or industrial process refrigeration) in a
manner
which permits such substance to enter the environment. De
minimis
releases associated with good faith attempts to recapture and
recycle or safely dispose of any such substance shall not be
subject to the prohibition set forth in the preceding sentence.
For purposes of this paragraph, the term
'appliance' includes any device which contains and uses as a
refrigerant a substitute substance and which is used for
household
or commercial purposes, including any air conditioner,
refrigerator, chiller, or freezer.


>
>>10. It is highly probable that there is no EPA certified personnel in
>>the employ of any scrap yard or land fill to do legal recovery.
>
>
>It would appear the EPA knows that and thus made it legal.

Again I think your looking for loopholes and interpreting them out of
context to validate your opinions.


>
>My, or your opinion still do not change regulations we may feel are stupid
>or inconsistent.
>

Do you feel the regs are stupid? I don't. I don't really think
there's that much inconsistency to them. the bottom line is NO
VENTING PERIOD. Which is the simple part you fail to grasp.


>gerry
>.......
>
>gerry misspelled in my email address to confuse robots

Now as I see no further need to go on about this and there is no way
to get you to pull your head out I'll let you find some more quotes
from "fact sheets" or what ever to show how right you are and how full
of it we are.

Mike
UA local 370

P.S. Your poor me there trying to run me out post was pathetically
laughable. Please spare us from your wallowing in self pity.

gerry

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May 14, 2001, 7:33:09 PM5/14/01
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[original post is likely clipped to save bandwidth]
On Mon, 14 May 2001 17:15:11 -0400, ftwhd <ft...@usl.com> wrote:


This seems to contain a valid discussion, regarding the EPA rules. Also a
very reasonable quote.

You are quoting the technician's certification rules as far as I can see and
have no disagreement with those. I've seen them before, my EPA Universal
number is my social security number (not going to post that) ssn0625.

Please let's inject some humor, this has been enough of a drag - mine's
longer than yours <VBG> It's also most likely an infant in age compared to
yours <VBG>

Previously I posted it in it's entirety (this is a snippet - these things
get way too long

from

http://www.epa.gov/Ozone/title6/608/608fact.html#disposal

{
Safe Disposal Requirements

Under EPA's rule, equipment that is typically dismantled on-site before
disposal (e.g., retail food refrigeration, central residential air
conditioning, chillers, and industrial process refrigeration) has to have
the refrigerant recovered in accordance with EPA's requirements for
servicing. However, equipment that typically enters the waste stream with
the charge intact (e.g., motor vehicle air conditioners, household
refrigerators and freezers, and room air conditioners) is subject to special
safe disposal requirements.

... clipped part

Technician certification is not required for individuals removing
refrigerant from appliances in the waste stream.
}

Please note "special safe disposal requirements".

The fact that the EPA can be confusing as heck is not a surprise. They have
technician certification definitions and also created "special safe disposal
requirements"

I see no reason someone already certified should go looking for the special
requirements. Perhaps the special requirements provision is the source of
confusion?


gerry

Don Ocean

unread,
May 14, 2001, 7:45:28 PM5/14/01
to
Our local dump has a certified reclaimer and machine on staff.
Paid for by tax dollars. this is to insure compliance with EPA
regulations, as interpreted by our city attorney. Our local
scrapyards will accept nothing that does not have a reclaimer
tag on it. What more is there to say? Personally I like this setup.
I don't have to mess up my gear with burn-outs. ;-)

Don Ocean
Sioux Falls, SD

HVACMAN

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May 14, 2001, 7:59:16 PM5/14/01
to

Earle Edomm wrote:


> all over them like a duck on a June bug


That's a good one Earle... May I take it and use it as my own??

--
Address munged to confuse spammers

Reply to: hva...@qwest.net

ftwhd

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May 14, 2001, 8:17:35 PM5/14/01
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On Mon, 14 May 2001 23:33:09 GMT, gerry <gerr...@gogood.com> wrote:

> [original post is likely clipped to save bandwidth]
>On Mon, 14 May 2001 17:15:11 -0400, ftwhd <ft...@usl.com> wrote:
>
>
>This seems to contain a valid discussion, regarding the EPA rules. Also a
>very reasonable quote.
>
>You are quoting the technician's certification rules as far as I can see and
>have no disagreement with those. I've seen them before, my EPA Universal
>number is my social security number (not going to post that) ssn0625.
>

I think that the use of the word "technician" is a catch all phrase
use to refer to all persons doing recovery. I think this should
become clear as you sift through the entire document and the
definitions.

As I said, read it all then we can discuss the parts you feel are
applicable. Somehow maybe this thread could be of an educational
value but most of us don't have the time to read and digest almost 500
pages of government speak and fine print at this time of year so if
you want the job, its yours.

I read it when it first came out and it was quite a lengthy read. I
know there has been amendments and some changes through out the years
but I think the link is an updated version which includes the
amendments. But I could be wrong about that.

I've already spent way more time on it than I had originally planned
and I for one don't intend to dwell on it any further but I will
discuss it in the future after you have some more ammo.

Bear in mind when you find statements that concur with your train of
thought, also go back to other sections and cross reference it to
section 608 where it states that all persons (technicians) have to be
certified, and see if your train is derailed or not. :)

It is a very complex document and open to many interpretations but the
bottom line reason for it is,

1. They do not want refrigerant vented and...

2. They want to make sure that the persons operating the
recovery/reclaiming/recycling equipment know what is required of them.

Have fun

Mike
UA local 370

Earle Edomm

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May 14, 2001, 9:03:44 PM5/14/01