United States
                        Protection Agency
Office of Air and Radiation
Stratospheric Protection
Division (6205-J)
August 1998
                        SUMMARY OF
                        DETERMINATION:   Halon
                        Recovery/Recycling Equipment
The Environmental Protection Agency (EPA) issued a direct final determination (DFD) published in the
Federal Register (FR) on August 11, 1998 (63 FR 42728) regarding the need for a certification program for
equipment used to recover and recycle halons (i.e., Halon 1211, Halon 1301, and Halon 2402, and all isomers
of these chemicals). Briefly, the direct final determination states that it is neither necessary nor appropriate at
this time, under section 608 of the Clean Air Act as amended (CAA), to issue a rule establishing a certification
program for equipment used in the recovery and recycling of halons, a group of Class I ozone-depleting
substances, or to require that halons be recovered only through the use of certified equipment.

EPA stresses that nothing in this determination affects any existing legal requirements regarding halons and
strongly emphasizes the ongoing environmental need to reduce their use and emissions and maximize their
recapture and recycling. It should be  noted that all provisions, including those relating to halon disposal and
recovery and recycling practices, of a recent rule concerning halons (63 FR 11084, published on March 5,
1998) continue to fully apply. EPA urges members of the regulated community to ensure that their practices
thoroughly comply with those federal rules and all other appropriate standards and regulations. This summary
provides a brief background on halons and the August 11, 1998 regulatory action. The full text of the
determination can be retrieved at the Federal Register web site (select both Final Rules and Regulations and
Proposed Rules and use an appropriate term in the Search Terms box, e.g., halon):

http://www.access.gpo .gov/su_docs/aces/acesl40.html

Halons are gaseous or easily vaporized halocarbons
used primarily for fire and explosion protection and
are listed as Group II, Class I ozone-depleting
substances ODSs) under 40 CFR Part 82, Subpart
A. Section 608 of the CAA directs EPA to issue
regulations that reduce the use and emissions of
ozone-depleting substances to the lowest achievable
level and that maximize the recapture and recycling
of such substances.

Despite their effectiveness as a fire  fighting agent,
halons are among the most ozone-depleting
chemicals in use today. With 0.2 ozone-depleting
potential (ODP) representing the threshold for
classification as a Class I  substance, Halon 1301
has an estimated ODP of  10, Halon 2402 an
    estimated ODP of 6, and Halon 1211 an estimated
    ODP of 3.

    Several existing federal regulations address halons.
    The new production of halons has been banned in
    the U.S. since January 1, 1994. More recently,
    EPA issued a rule on March 5, 1998 (63 FR
    11084), under the authority of Section 608 of the
    CAA, establishing certain practices and
    requirements relative to halons, including training
    requirements for technicians who handle halon-
    containing equipment; and prohibitions on releases
    of halons during technician training and during the
    testing, maintenance, repair, servicing, and disposal
    of halons and halon-containing equipment. The
    March 5, 1998 rule also provided for the proper
    disposal of halons and halon-containing equipment.

   Current Practices and EPA Determination

The further environmental objective of an equipment
certification program, and associated provisions
allowing the removal of halons only through the use
of certified equipment, would be to verify that all
recycling and recovery equipment sold is capable of
minimizing emissions, and that such certified
equipment was in fact used, thereby ensuring
minimum emissions and maximum recovery during
recycling and recovery activities.

Research completed by EPA in association with this
determination suggested that the great majority of
halon recovery and recycling equipment currently in
use, and all such equipment currently on the market,
consists of highly efficient closed halon recovery
systems achieving a minimum recovery efficiency of
98%. Entities that perform the vast majority of
halon transfers employ these efficient units.
Research further indicated that the halon sector has
been instituting conservative halon practices since
the ban on halon production that occurred on
January 1, 1994. Operations utilizing less efficient
halon recycling and recovery equipment and
methods are estimated to account for less than 1%
of total annual halon emissions in the United States.
With regard to such halon emissions arising from
the use of inefficient, non-closed halon recovery and
recycling devices and methods, in sections
82.270(d) and (e) of an EPA rule issued March 5,
1998, were intended to eliminate the use of such
devices and restrict halon recovery and recycling
equipment to the highly efficient type of closed
recovery systems now widely used in industry.
Based upon these findings, EPA determined that no
further environmental advances could be made, in
regard to the CAA section 608 goals of reducing
halon use and emissions, or maximizing halon
recapture and recycling, through a halon recovery
and recycling equipment certification program.

It should be noted that EPA stated in this
determination that it will propose to amend the
March 5, 1998 rule to, among other adjustments,
clarify sections of that regulation pertaining to the
requirement for halon and halon-containing
equipment disposal to be performed in accordance
with cited industry standards.  Please see FR text of
determination for further discussion of these
anticipated clarifications.

The direct final determination will become effective
on October 13, 1998 without further notice, unless
the EPA receives adverse comment on the
determination by September 10, 1998.  If adverse
comment is received, the EPA will publish a timely
withdrawal of the direct final determination in the
Federal Register and inform the public that the
determination will not take effect. All comments
would then be addressed in a subsequent final
determination based on the proposed determination
that was published  simultaneously with the direct
final determination on August 11, 1998. Comments
on the determination should be made to EPA as
indicated in the August 11, 1998 FR text of the
determination (63 FR at 42729, under
            For Further Information

For further information, please call the
Stratospheric Protection Hotline at (800) 296-1996
or contact:

Lisa Chang
Stratospheric Protection Division
U.S. Environmental Protection Agency
Mail Code: 6205J
Washington, D.C.  20460
202/564-9742 (phone)
202/565-2096 (fax)

Information  is also available from EPA's
Stratospheric Protection Home Page at the
following URL address: