R-22 chillers: reusing recovered HCFC to keep one running
A city-centre hotel has two air-cooled R-22 chillers, each with a 60 kg charge. Chiller A has been losing pressure for two years and the last contractor simply topped it up. The hotel wants you to transfer 8 kg of R-22 recovered from Chiller B, which is due to be decommissioned next month, into Chiller A so that it survives one more summer before the planned replacement. The recovered R-22 sits in a cylinder in the plant room labelled 'R-22' in marker pen, with 12 kg shown on the tag. The maintenance manager asks you to 'do it while you are here' and to sign the waste transfer note for the remainder.
1. Can you legally use the recovered R-22 to top up Chiller A? Justify your answer by reference to the type of substance and the rules on reusing it.
Read the worked answer
No.
Why
- R-22 is an HCFC, which is an ozone-depleting substance (ODP about 0.055) controlled by the ODS Regulation, not an HFC controlled only by the F-gas Regulation.
- The use of virgin or reclaimed HCFC for the maintenance or servicing of equipment containing HCFC has been prohibited since 1 January 2015. Permitted destinations are essentially destruction, feedstock, or specified process uses. The fact that the gas came from the client's own site, or that it was recovered rather than bought, makes no difference.
Practical argument on top
- The purity of recovered R-22 is unknown; moisture, acid and oil carried over can cause copper plating, slugging and compressor failure.
- The two-year leak history means the system needs a repair or a replacement decision, not another charge.
What you should offer
- Repair the leak or provide a documented repair timetable, quote for replacement or retrofit, and explain that continued top-up is not an option.
2. What must happen to the R-22 in Chiller A and the 60 kg in Chiller B, and what records and checks does the ODS/containment regime require for this plant?
Read the worked answer
Chiller A (leaking, in service)
- The leak must be repaired without undue delay; where repair is not immediately possible, a documented repair programme and a follow-up check within one month of the repair being completed.
- Because each unit holds well over 3 kg of controlled substance, written records of the charge and of any additions or recovery must be kept, and the equipment should carry a label identifying the refrigerant.
- Realistically the correct advice is containment plus a dated plan to replace or retrofit; further top-ups simply postpone the decision.
Chiller B (to be decommissioned)
- All 60 kg must be recovered before the circuit is opened or the plant is cut up, using dedicated recovery equipment into suitably rated and labelled cylinders.
- The recovered ODS must not be vented, sold on for reuse, or used for maintenance – it goes to a permitted waste contractor for destruction.
Common failure point
- Technicians record the gas leaving site but not the gas that was originally charged, so the audit trail cannot be reconciled. Record both.
3. The cylinder on site is hand-labelled and holds 12 kg of recovered R-22. How should it be handled and consigned, and what must not be done with it?
Read the worked answer
Handling
- Cylinder upright, valve cap fitted, secured against falling, in a ventilated area away from heat and ignition sources, and below the manufacturer's maximum storage temperature.
- Weigh it rather than trusting the tag; confirm the tare weight and that the fill limit (typically 80% water capacity) is not exceeded.
- Label permanently with the refrigerant identity, the quantity, the date, and the source equipment. 'R-22' in marker pen is not adequate.
Consignment
- Treated as hazardous/controlled waste: consigned to a permitted waste contractor using a waste transfer note, with the destination recorded (destruction, not reuse).
Must not
- Vent to atmosphere, decant into a cylinder marked for a different refrigerant, mix with HFC recovered gas, or hand it to the client 'for spares'.
Judgement point
- Signing a waste transfer note certifies what is in the cylinder. If the contents and weight are not verified, do not sign – have the cylinder identified and weighed first.