48 lb of R-22, Three Sources, One Buyer
A contractor's recovery cylinder is labeled R-22 and holds 48 lb drawn from three jobs: a clean residential split, a commercial unit with a burned-out compressor and a positive acid test, and a system where a previous company injected leak sealant. A helper also found an unlabeled cylinder next to it containing what appears to be R-410A. The owner of the clean system asks whether the contractor can put "his" refrigerant into a rental property he owns across town, and whether the leftover can be sold to a scrap dealer who resells refrigerant.
1. Can any of the 48 lb be reused, and under what conditions? Address the three sources separately.
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Reuse is limited to the same owner's equipment, and only if the refrigerant is actually clean.
- Clean split (same owner, same or another property he owns): possibly reusable, but only if it is recycled to an acceptable purity and is confirmed to be R-22 by identifier. Recovered-but-untested refrigerant should not go into someone's system on faith.
- Burnout with positive acid test: do not put it back in any system. Acid and burnout products will carry over and destroy the next compressor. It goes to an EPA-certified reclaimer (or is destroyed).
- Leak sealant: treat as contaminated. Sealants can plug a recovery machine, a gauge set, and the next system's TXV, and most reclaimers will reject or surcharge for it. Keep it segregated.
The controlling point: once these three are commingled in one cylinder, the whole cylinder takes the worst characteristic of its contents. The clean portion is gone. Segregation at the job site - separate cylinders for clean, burnout, and unknown - is the practice being tested here.
2. The owner wants refrigerant moved to a property he owns across town, and the scrap dealer wants to resell the leftover. What does the rule require in each case?
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Same owner, different property: recycled refrigerant may be reused in equipment owned by the same person - the rental property qualifies. Requirements: the refrigerant must meet the purity needed for that system, the batch must be identified, and the transaction documented. It is still the contractor's professional call whether the batch is clean enough to install.
Sale or transfer to another owner (the scrap dealer): this crosses the line. Refrigerant that is sold, given away, or otherwise transferred to a different owner must first be reclaimed by an EPA-certified reclaimer to the AHRI 700 standard, and the container must be labeled as reclaimed product. Recycled refrigerant may not be sold or transferred - a scrap dealer reselling "recovered" R-22 is buying a compliance problem, and the contractor supplying it is creating one.
Never vented under any of these options. If it cannot be reclaimed economically, the reclaimer destroys it; that is still the legal path.
3. What is the status of the unlabeled cylinder that appears to contain R-410A, and how should it be handled?
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Treat it as unknown until identified, and assume the worst.
Handling:
- Identify it with a refrigerant identifier - pressure/temperature comparison alone is not identification, because a mixed cylinder can mimic a pure refrigerant's pressure at one ambient.
- If it is R-410A or another single refrigerant, label it immediately with the refrigerant name and the date/source.
- If the identifier flags a mixture, the entire cylinder is mixed refrigerant. Mixed refrigerant cannot be separated in the field, cannot be installed in any system, and cannot be blended back to spec by adding anything. It goes to a certified reclaimer (distillation) or is destroyed.
- Label it "mixed" or "unknown" so the next person does not use it or add to it, and store it valve-capped and upright.
Root cause to fix: every recovery cylinder should be labeled with refrigerant type and job before the first pound goes in, and a cylinder should never be topped from a second system without confirming what it already holds. One unlabeled cylinder can contaminate an entire truckload and convert a $2,000 refrigerant inventory into disposal cost.