ODS Destruction in the United States and Abroad
Prepared for the U.S. Environmental Protection Agency
by ICF
February 2018
EPA 430-R-18-001
-------
Table of Contents
Controlled ODS under the Montreal Protocol
Acronyms
1. Introduction
2. Sources of ODS for Destruction
2.1. ODS-Containing Equipment
2.2. Bulk ODS
3. The Process of ODS Destruction: Best Management Practices
3.1. Recovery and Collection
3.2. Consolidation and Storage
3.3. Transportation
3.4. Destruction
4. ODS Destruction Technologies and Facilities in the United States and Worldwide
4.1. Montreal Protocol-Approved ODS Destruction Technologies
4.2. ODS Destruction Facilities in the United States
4.3. Capacity of U.S. Destruction Facilities
4.4. International ODS Destruction Facilities and Technologies
5. International Efforts to Destroy ODS
5.1. United States
5.1.1. Reported Amount and Type of ODS Destroyed
5.1.2 Reported ODS Imported for Destruction
5.2. European Union
5.2.1. Reported Amount and Type of ODS Destroyed
5.2.2. Reported ODS Imported for Destruction
5.3. Japan
5.3.1. Reported Amount and Type of ODS Destroyed
5.3.2. Reported ODS Imported for Destruction
5.4. Destruction of ODS in Article 5 and Non-Article 5 Countries
6. Global ODS Recovery, Transportation, and Destruction Costs
6.1. ODS Recovery Costs from Products and Equipment
6.2. ODS Transportation Costs
6.3. ODS Destruction Costs
6.3.1. Concentrated Sources of ODS
6.3.2. Dilute Sources of ODS
7. Financing of ODS Destruction Projects
7.1. Producer Responsibility Programs and Taxes
7.2. ODS Destruction Offset Programs
7.2.1. Compliance Markets
-------
ODS Destruction in the United States and Abroad
1 February 2018
7.2.2. Voluntary Programs 29
7.2.3. Carbon Prices and Profitability 29
7.3. HFC-23 Destruction 31
7.4. MLF- and GEF-Funded Destruction Projects 32
8. Modeled Amounts of ODS Potentially Available for Destruction [[[ 32
8.1. ODS Recoverable from Equipment and Products 32
8.1.1. United States 33
8.1.2. European Union 35
8.1.3. Global 36
8.2. Availability of Stockpiles 37
8.2.1. CFCs and HCFCs in Refrigeration/AC Equipment 37
8.2.2. Halons in Fire Extinguishing Equipment 37
9. ODS Management Needs for Developing Countries [[[ 38
lO.lmplications for Addressing HFC Disposal[[[ 40
10.1. Sources, Practices, Technologies, and Costs: Parallels to ODS 41
10.2. Current and Projected Quantities Available for Destruction 42
11.Reference s 45
12.Appendices[[[ 52
Appendix A: Transboundary Movement of ODS[[[ 52
Appendix B: Resource Conservation and Recovery Act[[[ 53
Code F (Wastes from Non-Specific Sources) 54
-------
ODS Destruction in the United States and Abroad
1 February 2018
Controlled ODS under the Montreal Protocol
Class 1
Class II
CFC-11 (Trichlorofluoromethane)
HCFC-21 (Dichlorofluoromethane)
CFC-12 (Dichlorodifluoromethane)
HCFC-22 (Monochlorodifluoromethane)
CFC-13 (Chlorotrifluoromethane)
HCFC-31 (Monochlorofluoromethane)
CFC-111 (Pentachlorofluoroethane)
HCFC-121 (Tetrachlorofluoroethane)
CFC-112 (Tetrachlorodifluoroethane)
HCFC-122 (Trichlorodifluoroethane)
CFC-113 (1,1,2-Trichlorotrifluoroethane)
HCFC-123 (Dichlorotrifluoroethane)
CFC-114 (Dichlorotetrafluoroethane)
HCFC-124 (Monochlorotetrafluoroethane)
CFC-115 (Monochloropentafluoroethane)
HCFC-131 (Trichlorofluoroethane)
CFC-211 (Heptachlorofluoropropane)
HCFC-132b (Dichlorodifluoroethane)
CFC-212 (Hexachlorodifluoropropane)
HCFC-133a (Monochlorotrifluoroethane)
CFC-213 (Pentachlorotrifluoropropane)
HCFC-141b (Dichlorofluoroethane)
CFC-214 (Tetrachlorotetrafluoropropane)
HCFC-142b (Monochlorodifluoroethane)
CFC-215 (Trichloropentafluoropropane)
HCFC-221 (Hexachlorofluoropropane)
CFC-216 (Dichlorohexafluoropropane)
HCFC-222 (Pentachlorodifluoropropane)
CFC-217 (Chloroheptafluoropropane)
HCFC-223 (Tetrachlorotrifluoropropane)
Halon 1211 (Bromochlorodifluoromethane)
HCFC-224 (Trichlorotetrafluoropropane)
Halon 1301 (Bromotrifluoromethane)
HCFC-225ca (Dichloropentafluoropropane)
Halon 2402 (Dibromotetrafluoroethane)
HCFC-225cb (Dichloropentafluoropropane)
Halon 1011/CBM (Chlorobromomethane)
HCFC-226 (Monochlorohexafluoropropane)
Carbon Tetrachloride (CCI4)
HCFC-231 (Pentachlorofluoropropane)
Methyl Chloroform (1,1,1-Trichloroethane)
HCFC-232 (Tetrachlorodifluoropropane)
Methyl Bromide (MeBr)
HCFC-233 (Trichlorotrifluoropropane)
HBFCs (Hydrobromofluorocarbons)
HCFC-234 (Dichlorotetrafluoropropane)
HCFC-235 (Monochloropentafluoropropane)
HCFC-241 (Tetrachlorofluoropropane)
HCFC-242 (Trichlorodifluoropropane)
HCFC-243 (Dichlorotrifluoropropane)
HCFC-244 (Monochlorotetrafluoropropane)
HCFC-251 (Trichlorofluoropropane)
HCFC-252 (Dichlorodifluoropropane)
HCFC-253 (Monochlorotrifluoropropane)
HCFC-261 (Dichlorofluoropropane)
HCFC-262 (Monochlorodifluoropropane)
HCFC-271 (Monochlorofluoropropane)
-------
ODS Destruction in the United States and Abroad
1 February 2018
Acronyms
AC Air Conditioning
ACR American Carbon Registry
AHRI Air-Conditioning, Heating, and Refrigeration Institute
Br Bromine
CAA U.S. Clean Air Act
CAR Climate Action Reserve
CARB California Air Resources Board
CCI4 Carbon Tetrachloride
CCX Chicago Climate Exchange
CFC Chlorofluorocarbon
CO Carbon Monoxide
CTOC Chemicals Technical Options Committee
DE Destruction Efficiency
DRE Destruction and Removal Efficiency
EEA European Environmental Agency
EOL End-of-Life
EPA U.S. Environmental Protection Agency
EPR Extended Producer Responsibility
ERU Emission Reduction Equivalent
EU ETS European Union Emission Trading System
GEF Global Environment Fund
GHG Greenhouse Gas
GWP Global Warming Potential
HBFC Hydrobromofluorocarbon
HBr Hydrogen Bromide
HC Hydrocarbon
HCFC Hydrochlorofluorocarbon
HCI Hydrochloric Acid
HF Hydrofluoric Acid
HFC Hydrofluorocarbon
HTOC Halon Technical Options Committee
HWC Hazardous Waste Combustor
ICRF Inductively Coupled Radio Frequency Plasma
MeBr Methyl Bromide
MITI Ministry of International Trade and Industry
MLF Multilateral Fund
MOP Meeting of the Parties
iv
-------
ODS Destruction in the United States and Abroad
1 February 2018
MRR
Mandatory Reporting of Greenhouse Gases Rule
MTC02e
Metric Tons Carbon Dioxide Equivalent
MTOC
Medical Technical Options Committee
ODP
Ozone Depleting Potential
ODS
Ozone-Depleting Substances
ODSTS
ODS Tracking System
PCDD
Polychlorinated Dibenzodioxin
PCDF
Polychlorinated Dibenzofuran
PFC
Perfluorocarbon
PM
Particulate Matter
POHC
Principal Organic Hazardous Constituent
POP
Persistent Organic Pollutant
QPS
Quarantine and Pre-Shipment
RAD
Responsible Appliance Disposal
RCRA
Resource Conservation and Recovery Act
RMC
Refrigerant Management Canada
RRA
Refrigerant Reclaim Australia
TEAP
Technology & Economic Assessment Panel
TFDT
Task Force on Destruction Technologies
TRI
Toxics Release Inventory
UL
Underwriters Laboratories
UNDP
United Nations Development Programme
UNEP
United Nations Environment Programme
UNIDO
United Nations Industrial Development Organization
VCS
Verified Carbon Standard
WTE
Waste to Energy
v
-------
1 .Introduction
The Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), finalized in
1987, is a global agreement to protect the stratospheric ozone layer by phasing out the production and
consumption of ozone-depleting substances (ODS). By joining, the Parties commit to phasing out
specified ODS - chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, carbon
tetrachloride (CCI4), methyl chloroform, methyl bromide, bromochloromethane, and
hydrobromofluorocarbons (HBFCs) - thereby reducing their abundance in the atmosphere and
protecting the earth's fragile ozone Layer. On 16th September 2009, the Montreal Protocol and its
parent convention, the Vienna Convention for the Protection of the Ozone Layer, became the first
treaties in the history of the United Nations to achieve universal ratification.
While the global ODS phaseout is underway, a large amount of ODS is in equipment and products such
as refrigerators and air conditioners (as refrigerant and foam blowing agent), foam contained in
buildings, and fire protection systems and fire extinguishers, as well as in stockpiles held by countries
and industrial and commercial users. Together these sources are referred to as ODS banks. ODS from
these banks could be released to the atmosphere over time through slow leakage, catastrophic leaks,
and venting, unless they are recovered and properly treated. While emissions from ODS banks are not
controlled by the Montreal Protocol, many countries including the United States have voluntary or
regulatory requirements to reduce emissions of ODS at the end of the useful life of these equipment and
products. After ODS are recovered and collected, destruction is one of several options that also include
recycling or reclamation. When choosing whether to recycle, reclaim, or destroy ODS, factors that are
considered include the cost of each option and the demand for reclaimed or recycled ODS (e.g., for
servicing existing equipment).
This report discusses the sources of ODS for destruction in the United States and globally and the best
practices for the safe, environmentally sound collection, recovery, transport, and destruction of these
substances. In addition, the report identifies the technologies that are used to destroy ODS and the
challenges associated with safe destruction of ODS. This report assesses the costs for the ODS waste
management process and the primary funding sources for waste management projects. Historical and
current destruction trends for the type and quantity of ODS destroyed in the United States, and other
countries are analyzed based on available data. Projections of potentially recoverable ODS are estimated
to illustrate the volume of available ODS from banks that could be available for destruction. Finally,
parallels for collection and disposal of hydrofluorocarbons (HFCs) are discussed.
1
-------
ODS Destruction in the United States and Abroad
1 February 2018
2. Sources of ODS for Destruction
ODS that are potentially eligible for
destruction originate from a variety of
sources. Unwanted and/or contaminated
ODS may be contained in old equipment,
previously recovered from equipment, or
otherwise stored in bulk. Recovered ODS are
generally stored in tanks or cylinders in
industrial or commercial facilities. These ODS
may have market value, depending on the
quality of the recovered material, whether a
market exists in that location for used ODS,
and whether shipment to another location
makes economic sense. A significant amount
of ODS are recovered and either recycled or
reclaimed. While ODS without a market value
are good candidates for destruction, ODS
with a resale value are less likely candidates
for destruction. For instance, used HCFC-22,
which in 2020 will no longer be produced in
the United States, will likely have a resale
value because it will still be required for
servicing existing equipment.
Some ODS with market value may be destroyed because they cannot be feasibly recycled or reclaimed
for reuse. In some cases, the market value of the ODS may be lower than the value of carbon offset
credits that would be generated from their destruction (see Section 7). There are numerous reasons why
recycling or reclamation may not be possible, including contamination (e.g., ODS mixed with non-ODS
gases, mixed ODS) or a lack of access to reclamation facilities. In some cases, destruction may be
challenging due to barriers that stand in the way of effective recovery and transportation (see Box 1).
The remainder of this section describes the primary sources of unwanted ODS for destruction, including
ODS-containing equipment and bulk ODS stockpiles.
2.1. ODS-Containing Equipment
ODS recovered from equipment during servicing or decommissioning is an important source of ODS for
destruction. However, not all ODS can be easily captured and/or made available for destruction. For
example, recovering ODS foam blowing agents from building and appliance foams may be difficult and
expensive. Similarly, although portable fire extinguishers are a good source for destruction in many
Box 1. Key Barriers to Recovery and Destruction of ODS
While there is a substantial volume of unwanted ODS that
needs to be recovered and properly treated, in different
countries there can be informational, financial,
technological, logistical, and legal barriers that could stand
in the way of effective recovery and destruction.
Stakeholder outreach and technician training is essential
to ensure persons recovering ODS from equipment or in
bulk understand the environmental hazards of ODS, and
have the necessary technical skills to prevent their release
to the environment.
Another barrier is the significant cost associated with
specific tools and infrastructure needed to properly
recover, transport, store, and destroy ODS. In some
countries, a wide geographic distribution of ODS banks
compared to centralized destruction facilities presents a
significant obstacle to efficient collection. For countries
without domestic facilities, shipping ODS to another
country for destruction may present logistical and legal
barriers due to international conventions and decisions
that regulate the international movement of ODS.
2
-------
ODS Destruction in the United States and Abroad
1 February 2018
cases, there may be instances in which it may not be feasible to collect them because they are widely
dispersed and expensive to collect (ICF 2010c).1
The feasibility of recovering ODS from equipment depends on a variety of factors, including availability
of recovery equipment, relative amounts of ODS to be recovered, and technical training. The majority of
unwanted ODS that can be most easily recovered from equipment comes from the refrigeration and/or
air-conditioning (AC) sector, which primarily includes CFCs and HCFCs, and some from the fire
extinguishing sector, which primarily uses halons. Halons are infrequently available for destruction, as
they are often banked and reused in fire protection equipment to maintain existing systems and fill new
systems (see Section 8.2.2).
Within the refrigeration/AC sector, ODS may be recovered for destruction from domestic appliances
(such as refrigerators, freezers, room AC units and dehumidifiers) or from commercial or industrial
equipment (such as supermarket refrigeration systems or large building chillers). Because commercial
and industrial equipment contains greater amounts of ODS per unit, these applications may provide a
larger source of ODS for destruction at a lower level of effort and cost (MLF 2008).
In the United States, ODS-containing foam is also often recovered, particularly from refrigerated
appliances; however, this recovery effort is often more expensive and takes a higher level of effort than
recovering refrigerant. ODS-containing foam can either be destroyed whole, or the ODS blowing agent
may be separated from the foam material using special technology and then reclaimed or destroyed.
Although recovery from foams is more complex and higher cost than recovery of refrigerants, many
countries have continued to promote foam recovery, recognizing the important benefits of recovering
ODS from foams to the recovery of the ozone layer (MLF 2008). For example, the U.S. Environmental
Protection Agency's (EPA) Responsible Appliance Disposal (RAD) Program, a voluntary partnership
program, was developed to promote proper removal, recovery, and destruction of ODS in refrigerated
appliances, including ODS-containing foam. In the European Union, Regulation (EC) 1005/2009 requires
that ODS blowing agent be recovered from appliance foam and safely destroyed. The regulation also
requires that construction foam be destroyed, although recovery of blowing agent from the foam is
optional (EU 2009).
Bulk stockpiles of ODS may originate from a variety of sources. For example, small quantities of ODS that
have been evacuated from refrigeration/AC or fire extinguishing equipment during servicing or
decommissioning may be consolidated into stockpiles for storage, and ODS refrigerant recovered from
large commercial and industrial equipment at service and decommissioning may be collected in
sufficient quantities to be considered "bulk" (see Section 8). Some suppliers have active programs to
recover material from their customers. The material is analyzed for quality and either recycled or
consolidated for destruction. In addition, ODS that has been produced but never used (i.e., virgin
material) may also be stored in stockpiles for later use.
As these stockpiles remain in storage, they typically leak, and over time, significant quantities of ODS can
be emitted into the atmosphere (ICF 2010c). This is especially the case when ODS are stored in original
1 Some countries have established national programs to encourage halon recovery, and generally those programs requiring
halon owners to donate substances and pay for destruction have had limited success. Programs offering compensation for the
recovery and destruction of halons have higher recovery rates.
3
-------
ODS Destruction in the United States and Abroad
1 February 2018
containers in locations where temperature and moisture are not controlled (e.g., warehouses, fields). To
prevent bulked ODS from being emitted into the atmosphere, it is important to properly destroy it in a
timely manner. Since bulk stockpiles of ODS are already consolidated, collecting ODS from these
stockpiles for destruction is generally a cost-effective option.
3. The Process of ODS Destruction: Best Management
Practices
The process of ODS waste management
includes the collection, storage,
consolidation, transportation, and
destruction of ODS. Recovery of material
begins when ODS are recovered from
equipment or stockpiles and ends with the
actual destruction. Each of the steps that
lead to ultimate destruction should be
carried out using practices that aim to
prevent fugitive emissions.
After ODS are recovered and collected, or
even consolidated, destruction is only one
of several options that owners have; ODS
can also be sent for recycling or
reclamation (see Box 2), or it can be stored
indefinitely. When choosing whether to
recycle, reclaim, or destroy ODS, factors
that are considered include the cost of
each option and the demand for reclaimed
or recycled ODS (e.g., for servicing existing
equipment).
This section provides a guide to best
practices for ODS destruction to minimize
fugitive emissions and maximize the
amount of ODS that is destroyed.
3.1. Recovery and Collection
The first step in performing ODS destruction is the collection and/or recovery of ODS from obsolete or
non-repairable appliances, commercial or industrial equipment, or from stockpiles. Recovery of ODS
from equipment should be performed by properly trained service technician and consists of the ODS
being evacuated and recovered. Evacuation and recovery of ODS from commercial and industrial
equipment can generally be performed on site using mobile recovery equipment, whereas recovery of
ODS from household appliances is typically performed after transportation of the equipment to a waste
facility upon decommissioning. In addition, some facilities have the capability to shred entire
refrigeration units, capturing the ODS from foams and cooling systems in a sealed environment.
Box 2. ODS Recycling versus Reclamation
Recycling: To extract ODS from an appliance and clean the
ODS for reuse without meeting all of the requirements for
reclamation. In general, recycled ODS are cleaned using oil
separation and single or multiple passes through devices,
such as replaceable core filter-driers, which reduce
moisture, acidity, and particulate matter. These procedures
are usually implemented in the field at the job site. In the
United States, ODS recovered or recycled from stationary
equipment must be returned to the same system or other
systems owned by the same person. If the material changes
ownership, it must be reclaimed instead.
Reclamation: To reprocess ODS to a certain purity standard.
Reclamation is required for reuse after resale to distinguish
from recycled ODS. The process requires specialized
machinery typically not available at a particular job site or
automobile repair shop. The technician will recover the ODS
and then send it either to a general reclaimer or back to the
manufacturer. In the United States, Canada, and Mexico,
reclaimed refrigerant must be reprocessed to AHRI Standard
700, which has a purity requirement of 99.5 percent by
mole as well as other requirements for water content,
particulates, turbidity, and acidity (AHRI 2016). In the United
States, Canada, and Mexico, reclaimed halon 1211 and
halon 1301 must be reprocessed to ASTM D7673 Standard
and ASTM D5632 Standard, respectively, which have purity
requirements of 99 percent by mole (Robin 2012).
4
-------
ODS Destruction in the United States and Abroad
1 February 2018
ODS may also be collected from stockpiles held at industrial facilities or other warehouses. Surplus
industrial stocks are likely to be stored in tanks, thus, collection may entail either pick-up or transfer
from tank to tank. In general, because of the costs of storage, however, industrial users may limit the
length of time that they store large quantities of ODS.
Best Practices: Recovery and Collection
ODS should be recovered from equipment by a properly trained technician using appropriate equipment in
order to minimize loss during the evacuation process, estimated at 0.5 percent to 3 percent of the charge
for refrigeration/AC equipment (ICF 2010c). In the United States, technicians must be certified under Title VI
of the Clean Air Act (CAA), obtained by passing an EPA-approved exam. In addition, the recovery equipment
used for evacuating small appliances must be certified by an EPA-approved certification agency (e.g., Air-
Conditioning, Heating and Refrigeration Institute (AHRI), Underwriters Laboratories (UL), or Intertek).
3.2. Consolidation and Storage
After ODS has been recovered and collected from domestic appliances, commercial equipment, and
industrial facilities, it is frequently consolidated into a storage tank, utilizing best practices to reduce
emissions. This step is undertaken in order to avoid shipping many smaller containers of ODS, which
leads to inventory and recordkeeping complications, damage or loss during shipment, and additional
transport expenses. After sufficient ODS has been aggregated to constitute a shipment, it may be stored
temporarily, awaiting transportation to a destruction facility. This process of consolidation prior to
shipment may occur several times at multiple levels of the supply chain (MLF 2008). For example, ODS
service companies may consolidate their recovered stocks and send them to an aggregator that further
consolidates received stocks into an even larger shipment. During consolidation, the ODS may undergo
various tests in order to determine what materials are present and if there are any contaminants.
The storage medium used generally depends on the source of the ODS. ODS recovered from appliances
is often transferred to cylinders, each with a capacity of about 14 to 22 liters (L) (about 14 to 23
kilograms (kg)) (MLF 2008). It is likely that a recipient early on in the chain (i.e., one of the first to receive
the material) will store the recovered ODS until enough is bulked together for shipment. ODS recovered
from bulk and industrial stocks, which typically are recovered in larger quantities, are generally stored in
large containers, such as pressure vessels, which range in size from 950 to 1,890 L (holding between
1,000 and 2,000 kg of refrigerant). When sufficient ODS has been aggregated to constitute a shipment, it
is often transported in ISO tanks, which can hold approximately 24,000 L (holding about 25,000 kg of
refrigerant).
During consolidation, ODS may be transferred between containers using hoses and pumping equipment.
A vacuum pump is also used to evacuate the hoses after transfer, in order to prevent the emission of
residual gas in the hoses. Depending on the number of times ODS stocks are consolidated, several
transfers may be undertaken. During consolidation, the transfer of ODS from one container to another is
a potential source for ODS loss. It is estimated that 1 percent to 3 percent of the gas is typically lost
during transfer from small cylinders to bulk storage (ICF 2010c).
The containers in which ODS are bulked and stored, such as cylinders and pressure vessels, are also a
potential source of leaks. Disposable, or "one-way," cylinders are expected to fail about 0.8 percent of
the time; these cylinders are not designed for long-term storage of ODS. Taking into account the risk of
valve leaks, a 2 percent to 3 percent annual leak rate can be assumed for cylinders. However, this leak
rate can significantly increase under improper storage conditions; cylinders can easily rust if kept
5
-------
ODS Destruction in the United States and Abroad
1 February 2018
outside, resulting in the entire contents being lost in only four or five years (ICF 2010c). By contrast,
failure of pressure vessels is extremely uncommon; the average leak rate has been estimated at 0.025
percent per year (ICF 2010c).
Best Practices: Consolidation and Storage
To avoid losses, the residual refrigerant ("heel") of the cylinder being emptied should be pumped out and all
hoses should be fully evacuated following transfer. Transfer equipment should be well maintained, and dry-
break coupling should be used for hose connections. Pressure vessels and ISO tanks should be used instead of
cylinders when possible. Temporary storage times should be kept to a minimum, and all cylinders should be
stored in a safe indoor area with leak monitoring procedures. In the United States, the Department of Defense
(DOD) ODS Reserve Program has instituted a leak monitoring and detection program that minimizes emissions
during storage using installed automated leak detection equipment and manual leak monitoring procedures.
3.3. Transportation
ODS may be transported several times from recovery to ultimate destruction. For example, ODS may be
transported from service companies to distributors for consolidation, and then shipped again to the
destruction facility. It is also possible that multiple shipments may occur during the consolidation
process. International transportation of ODS waste is subject to legal requirements in line with the Basel
Convention for transporting hazardous waste (see Appendix A).
ODS are shipped in a variety of container types (e.g., steel cylinders, bulk storage tanks, ISO containers,
tanker trucks, rail cars), which can range in size from 14 to 24,000 L (holding between 14 to 25,000 kg).
These containers are typically sent either by truck or by rail (MLF 2008). In preparation for shipment,
ODS may be transferred to a specific transportation container. Some storage containers, such as smaller
14 kg cylinders, may be transported as-is, without requiring ODS transfer. ISO shipping containers are
used for shipping an estimated 50 to 70 percent of all refrigerants delivered to customers and
transported for destruction (EIA 2014).
Best Practices: Transportation
Use of an ISO shipping container for transportation of ODS is recommended. Used ODS should be classified
with the proper waste code, and shipments should be clearly labeled. Fugitive emissions from the actual
transport of the ODS, if done correctly, can be considered negligible. When transferring ODS from pressurized
storage into an unpressurized shipping container, however, there is a risk of loss through vent holes, which
are used to equalize the pressure as the shipping container is filled. Thus, a closed loop transfer system with
dry-break couplings should be used instead. By using these two technologies, a loss of between 0.0004
percent and 0.05 percent can be assumed (ICF 2010c). This leak rate is a substantial reduction from the 5
percent loss experienced without the use of a closed loop system or dry-break couplings (ICF 2010c). In the
United States, the Resource Conservation and Recovery Act (RCRA) waste codes are used to classify hazardous
wastes, some of which include ODS (see Appendix B). RCRA facility permits specify what specific hazardous
waste codes these facilities are permitted to receive, treat, and/or store, and in what quantities.
3.4. Destruction
Typically, ODS are transported to an approved destruction facility for final destruction, although some
ODS can be destroyed on site after collection, if the facility is approved to do so. In most cases, however,
certified transporters ship consolidated ODS in large containers to the destruction facility. When ODS
6
-------
ODS Destruction in the United States and Abroad
1 February 2018
reaches the destruction facility,2 the ODS containers are commonly stored for a week to a month before
destruction. Prior to destruction, the ODS may undergo additional tests in order to determine what
materials are being destroyed and if any contaminants are present in the stocks.
Once the contents are confirmed, the ODS may be transferred to a holding tank and fed into the
destruction unit;3 alternatively, it may be fed into the destruction unit directly from the container (i.e.,
cylinder or ISO-tank) it arrives in. The allowable feed rate of ODS at any hazardous waste combustor
(HWC) facility will be site-specific, and will be influenced by the design of the unit and the amount of
other hazardous wastes being treated at the time. Hazardous waste combustors must be compliant with
numerous operating conditions and limits any time hazardous waste is being treated. These include
limits on, for example, minimum combustion zone temperature, minimum residence time, maximum
waste feed rates, and continuous compliance with a carbon monoxide (CO) limit, which is a measure of
incomplete combustion. Commercial hazardous waste combustors can only combust controlled
amounts of fluorinated and brominated compounds due to the corrosive nature of the resulting acidic
gases (hydrogen fluoride (HF) and hydrogen bromide (HBr)) and the flame quenching nature of bromine-
containing ODS.
Best Practices: Destruction
A destruction and removal efficiency (DRE)4 of 99.99 percent for concentrated sources of ODS and 95 percent
for dilute sources of ODS (i.e., foams) is recommended by the Technology & Economic Assessment Panel
(TEAP), along with other emissions limits and the use of a Montreal Protocol approved destruction
technology. Hazardous waste incinerators generally exceed the TEAP recommendations, often achieving a
DRE of up to 99.9999 percent. The DRE can be used to estimate the ODS emitted through exhaust gases. For
example, an ODS destruction technology with a DRE of 99.99 percent results in 0.01 percent of ODS
emissions. In addition, sampling of ODS shipments should be conducted, and detailed checks of arriving
containers should be carried out. The quantity destroyed should be measured or calculated and documented
(UNEP 2003). In the United States, any entity destroying ODS must report the type and quantity of ODS
destroyed annually to EPA. EPA requires that destruction be carried out using technologies approved by the
Parties to the Montreal Protocol.
2 In some cases, (e.g., a practice in Germany) ODS recovered from domestic appliances is sent for reclamation prior to
destruction since some destruction operators require purified ODS to ensure accurate process control and consistent flow rate
(MLF 2008). Process control may be easier if the destruction facility is processing pure compounds rather than ODS mixtures.
3 According to information from industry representatives, the average rate at which ODS can be fed into an HWC can vary from
around 1,000 to 4,000 kg/hour (as compared to the maximum waste feed rate for a rotary kiln unit in Arkansas, which is 93,300
kg/hour, or the maximum rate for a fixed hearth incinerator in Illinois, which is about 12,000 kg/hour). For a 60,000 kg
shipment of ODS, this would result in a total destruction time of 15 to 60 hours. For a plasma arc unit, the typical feed rate for
ODS is around 20 kg/hour (EPA 2010a).
4 DRE is a measure of the efficiency of destroying, degrading, and/or removing a chemical in a treatment device (which includes
its air pollution control system), prior to being emitted to the atmosphere via the stack. DRE is calculated by feeding a
measured mass of chemical into the system and dividing by the mass of that chemical that escapes in the exhaust stream; the
percent that has not been emitted is the DRE.
7
-------
ODS Destruction in the United States and Abroad
1 February 2018
4. ODS Destruction Technologies and Facilities in the
United States and Worldwide
This section presents the ODS destruction technologies approved by the Parties to the Montreal
Protocol at the 23rd Meeting of the Parties (MOP) in November 2011, as well as information on known
ODS destruction facilities in the United States and abroad, including the location of facilities and their
associated destruction capacities.
4.1. Montreal Protocol-Approved ODS Destruction Technologies
Parties to the Montreal Protocol have taken decisions that promote the exchange of information on the
best technologies for the destruction of ODS. TEAP, one of the three assessment panels under the
Montreal Protocol, established a Task Force on Destruction Technologies (TFDT) in response to a
decision taken by the Parties. The TFDT released a report in 2002 that established destruction efficiency
and air emissions recommendations for ODS destruction technologies and reviewed available
technologies against these criteria (TEAP 2002). At the 15th MOP in November 2003, the Parties agreed,
through Decision XV/9, to update the list of approved destruction technologies for ODS that were
evaluated in the 2002 TEAP report. At the 23rd MOP in November 2011, the Parties agreed, through
Decision XXIII/12, to further update the list of approved destruction technologies, specifically adding
Chemical Reaction with H2 and C02, Porous Thermal Reactor, Portable Plasma Arc, and Thermal Reaction
with Methane.
Although the criteria used in the TEAP report to evaluate destruction technologies were not established
by the Parties as required limits during ODS destruction, these criteria may be considered domestically.
These recommendations include specifications for:
• Destruction and Removal Efficiency (DRE);
• Emissions of polychlorinated dibenzodioxins (PCDDs) and polychlorinated dibenzofurans
(PCDFs)/dioxins and furans, hydrochloric acid (HCI), chlorine (Cl2), HF, hydrobromic acid (HBr),
bromine (Br2), particulate matter (PM), and CO; and
• Technical capability when destroying ODS on a commercial scale.
Table 1 presents the DRE and emission limits recommended by the TEAP (for concentrated ODS).
Table 1: Summary of Technical Performance Qualifications for ODS Destruction3
Efficiency/Emission
Diluted Sources
Concentrated Sources
DRE (%)
95
99.99
PCDD + PCDFs (ng/m3)
0.5
0.2
HCI/Cbfmg/m3)
100
100
HF (mg/m3)
5
5
HBr/Br2(mg/m3)
5
5
Particulate Matter (mg/m3)
50
50
CO (mg/m3)
100
100
Source: TEAP (2002).
a Emission limits are expressed as mass per dry cubic meter of exhaust gas at 0°C and 101.3 kPa corrected to 11
percent 02.
8
-------
ODS Destruction in the United States and Abroad
1 February 2018
ODS destruction technologies can be grouped into three broad categories: Incineration; Plasma; and
Other Non-incineration technologies. Within these three categories, 15 technologies were approved for
the destruction of concentrated sources of CFCs, HCFCs, methyl chloroform, and CCI4. Only six of these
technologies were approved for the destruction of concentrated sources of halons, as sufficient
evidence was not available for the other technologies to demonstrate that they could effectively destroy
halon while meeting the designated criteria (UNEP 2003).
Table 2 summarizes the list of approved technologies for destroying ODS presented in Annex I of the
Report of the 23rd MOP, as well as three non-approved technologies that are cited in a 2015 report from
the Chemicals Technical Options Committee (CTOC) as being newly in use and potentially approved by
the Parties in the future. All of these technologies are known to be used for ODS destruction, either
commercially or in demonstrations, in the United States and/or abroad. All technologies are described
further in Appendix C.
9
-------
ODS Destruction in the United States and Abroad 1 February 2018
Table 2. Approval Status of Available OPS Destruction Technologies
Applicability3 and Required Destruction and Removal Efficiency (DRE)f
Technology
Concentrated ODSb
Dilute ODSc
CFCs, HCFCs, CCU, methyl
chloroformd (99.99%)
Halons® (99.99%)
Foam (95%)
Incineration Technologies
Cement Kilns
Approved
Not Approved
Not Applicable
Gaseous/Fume Oxidation
Approved
Not Determined
Not Applicable
Liquid Injection
Incineration
Approved
Approved
Not Applicable
Municipal Solid Waste
Incineration
Not Applicable
Not Applicable
Approved
Porous Thermal Reactor
Approved
Not Determined
Not Applicable
Reactor Cracking
Approved
Not Approved
Not Applicable
Rotary Kiln Incineration
Approved
Approved
Approved
Plasma Technologies |
Argon Plasma Arc
Approved
Approved
Not Applicable
Inductively Coupled
Radio Frequency Plasma
Approved
Approved
Not Applicable
Microwave Plasma
Approved
Not Determined
Not Applicable
Nitrogen Plasma Arc
Approved
Not Determined
Not Applicable
Portable Plasma Arc
Approved
Not Determined
Not Applicable
Steam Plasma Arc
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Other Non-Incineration Technologies
Chemical Reaction with
H2 and CO2
Approved
Approved
Not Applicable
Gas Phase Catalytic De-
halogenation
Approved
Not Determined
Not Applicable
Superheated Steam
Reactor
Approved
Not Determined
Not Applicable
Thermal Reaction with
Methane
Approved
Approved
Not Applicable
Catalytic Destruction
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Conversion to Vinylidene
Fluoride
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Sources: UNEP (2011) and UNEP (2015).
a Not approved indicates the technology was reviewed and did not meet the TEAP recommendations for the process; Not
applicable indicates the technology is not feasible for the process; Not determined indicates the technology was not reviewed
for destruction of that compound; Not yet reviewed indicates the technology has not been reviewed by the Parties to the
Montreal Protocol.
b Concentrated sources of ODS refer to virgin, recovered, and reclaimed ODS.
c Dilute sources of ODS refer to ODS contained in a matrix of a solid (e.g., foam).
d Under the Montreal Protocol, these substances are listed in Annex A, Group I; Annex B; and Annex C, Group I.
e Under the Montreal Protocol, these substances are listed in Annex A, Group II.
f Per the TFDT screening process, technologies must be demonstrated to achieve the required DRE while also satisfying
emissions criteria. See TEAP (2002) for more information.
10
-------
ODS Destruction in the United States and Abroad
1 February 2018
There are also facilities in operation around
the world that employ technologies that have
either not been approved by Parties to the
Montreal Protocol or do not meet the
eligibility criteria (see Box 3 for an example of
one of these other technologies).
Incineration and plasma arc destruction
facilities are also capable of accepting HFCs for
destruction (see Section 10.1). Tsang et al.
(1998) assessed the relative thermal stability
of fluorinated compounds, including HFCs, as
compared to the thermal stability of
chlorinated compounds and concluded that
fluorinated compounds can be destroyed at
high efficiency by incineration. Modeled
required temperatures for destruction of HFCs to 99.99 percent DRE in Tsang et al. (1998) are similar to
modeled required temperatures for HCFCs and halons in Lamb et al. (2010) (see Appendix D).
4.2. ODS Destruction Facilities in the United States
Destruction facilities in the United States that have destroyed ODS can generally be grouped into three
main categories:
1. Those that commercially destroy ODS for other companies,
2. Those that destroy ODS generated as a byproduct or waste stream of chemical manufacturing
or is used on-site in a chemical production process, and
3. Those that burn waste as fuel and receive blended waste-derived fuel from outside sources.5
In order to identify U.S. facilities that destroy ODS for any of the above purposes, information was
collected from the Toxics Release Inventory (TRI) and the ODS Tracking System (ODSTS). The TRI is a
database established to provide communities with information about toxic chemical releases in
accordance with the 1990 Pollution Prevention Act; established in accordance with the Emergency
Planning and Community Right-to-Know Act of 1986, therefore, waste management activities, including
the treatment and/or destruction of hazardous waste, must be reported to TRI.6 The ODSTS is a
centralized database maintained by the U.S. EPA of company reported quantities of ODS production,
imports, exports, and destruction. In accordance with Article 7 of the Montreal Protocol, Parties are
required to report these data to the UNEP Ozone Secretariat each year. The reporting requirements are
different between the TRI and the ODSTS, but the information can be combined to generate a clear
picture of destruction activities.
Box 3. Other ODS Destruction Technologies
In addition to the ODS destruction technologies described in
Table 2, there are other destruction and emission
recapture technologies that are beyond the scope of this
report. One example is methyl bromide
recapture/destruction systems, which recapture methyl
bromide from fumigation applications that can then be
recovered and destroyed by chemical conversion or
thermally destroyed (e.g., by incineration).
Facilities in California and Florida use an alkyl halide
scrubbing system which is able to chemically destroy
captured methyl bromide through a proprietary scrubbing
process using an aqueous reagent mix that converts methyl
bromide to non-hazardous water-soluble products.
5 Because most ODS have negligible fuel value and a high halogen content (associated with corrosion and air emissions), the
ODS content of waste-derived fuel is expected to be low. Because ODS will effectively dilute the fuel value of waste feed, fuel
blending facilities do not typically accept large quantities of ODS for blending with other waste-derived fuel.
6 TRI reporting exemptions are applied to quantities below 11,340 kg/year for manufacture and processing, or 4,540 kg/year for
other use, as well as laboratory activities, and alternative transformation technologies.
11
-------
ODS Destruction in the United States and Abroad
1 February 2018
Based on data submitted to TRI from 2010 to 2016, over 35 companies that destroyed ODS hazardous
waste were identified. Many of these facilities are chemical manufacturing plants that destroy ODS
generated on-site or used on-site in a chemical production process.7 The ODSTS was referenced to help
identify whether companies were destroying ODS commercially. While there are a significant number of
non-commercial, non-byproduct destruction facilities in the United States that have destroyed ODS-
containing wastes, there are 7 companies that are thought to have destroyed ODS, either received
commercially or as ODS-containing waste-derived fuel, in 11 locations across the country. Hereinafter
these facilities are referred to collectively as "commercial facilities."
Table 3 lists the technologies, operating companies, facility locations and chemicals processed by
commercial destruction facilities reported to the TRI database from 2010-2016.
Table 3. Commercial Destruction Facilities and Technologies in Use in the United States
Company
Location
Technology in Use3
ODS Processed in 2010-
2016
A-GAS Americas
Bowling Green, OH
Plasma Arc
CFC-11, CFC-12, CFC-113,
Halon 1301, Halon 1211,
HCFC-22
Clean Harbors Aragonite
LLC
Grantsville, UT
Rotary Kiln with Liquid
Injection Unit Afterburner
CFC-11, CCI4
Clean Harbors Deer Park
LLC
La Porte, TX
Gas/Fume Oxidation (2 units)
CFC-11, CFC-12, CFC-13,
CFC-113, CCI4, Me Br, HCFC-
21, HCFC-22, HCFC-124,
HCFC-141b, HCFC-225
Clean Harbors El Dorado
LLC
El Dorado, AR
Rotary Kiln Incineration with
Single Thermal Oxidation Unit
(2 units) and Rotary Kiln
Incineration with Secondary
Combustion Chamber
CFC-11, CCI4, HCFC-22
Clean Harbors
Environmental Services
Inc.
Kimball, NE
Fluidized Bed Incinerator
CFC-11, CCI4
Eco-Services Operations
Baton Rouge, LA
Liquid Injection Incineration (2
units)
CCI4
Heritage Thermal
Services
East Liverpool, OH
Rotary Kiln Incineration
CFC-11, CFC-113, CCU,
MeBr
Recleim
Graniteville, SC
Catalytic Destruction15
CFC-11, CFC-12, HCFC-22,
HCFC-141bc
Ross Incineration Services
Inc.
Grafton, OH
Rotary Kiln with Liquid
Injection Unit
CCU
Veolia ES Technical
Solutions LLC
Sauget, IL
Fixed Hearth Incineration
CFC-12, CFC-113, CCU
Veolia ES Technical
Solutions LLC
Port Arthur, TX
Fixed Hearth Incineration
CFC-11, CFC-12, CFC-113,
CCU, HCFC-21, HCFC-22,
HCFC-123
Sources: EPA (2017a) and ICF (2009a).
a Technologies that are not present in the list of Montreal Protocol approved destruction processes are described in Appendix C.
7 These facilities generally use fume/vapor incinerators or other types of air emissions control devices to destroy ODS.
12
-------
ODS Destruction in the United States and Abroad
1 February 2018
b Recleim is a de-manufacturing company that receives shipments of old appliances (refrigerators, freezers, dehumidifiers, and
AC units) and processes them in the only U.S. plant to employ a combination of physical destruction technologies and catalytic
destruction in a closed loop system. This system avoids the leakage to the environment that occurs during de-manufacturing of
appliances and shipment of ODS (Sirkin 2016).
c Based on the refrigerants and foam blowing agents recovered by RAD partners.
In addition to those facilities that destroy ODS commercially, Table 4 lists destruction companies that
destroyed ODS on-site from 2010 to 2016, either as a by-product of fluorochemical manufacture or
when it is used as raw material in a manufacturing process. Facilities that destroy ODS-containing
byproducts from chemical manufacture generally do not have the capacity, infrastructure, or permitting
to accept ODS wastes generated offsite. Some of these facilities have indicated that they do accept
offsite waste for destruction, but only wastes generated at other facilities operated by the same entity.
ODS destruction units at these facilities may have additional capacity available to destroy ODS
generated by other entities, but the facilities may not have adequate hazardous waste storage and
handling infrastructure or the appropriate regulatory permits to do so.
Table 4. Facilities that Destroy Byproduct ODS or Utilize Raw Material ODS in the United States (Non-
Commercial)
Company
Location
Technology in Use3
ODS Processed in
2010-2016
Arkema Inc.
Calvert City, KY
Liquid Injection Incineration
HCFC-22, HCFC-141b
Axiall LLC
Plaquemine, LA
Fume/Vapor
CCI4
BASF Corp.
Geismar, LA
NA
CCI4
BASF Corp. - Hannibal Site
Palmyra, MO
NA
MeBr
BAYER Cropscience
Kansas City, MO
Fume/Vapor
MeBr
Blue Cube Operations LLC -
Plaquemine, LA
NA
CCU, MeBr
Plaquemine Site
BP AMOCO Chemical Co. -
Wando, SC
Other Incineration/Thermal
MeBr
Cooper River Plant
treatment
BP AMOCO Chemicals
Decatur, AL
Fume/Vapor
MeBr
BP Chemical Co. - Cooper River
Wando, SC
NA
MeBr
Plant
Chemours Belle Plant
Belle, WV
Fume/Vapor
CCU
Chemours Washington Works
Washington, WV
NA
HCFC-22
Daikin America Inc.
Decatur, AL
NA
HCFC-22
DAK Americas LLC - Columbia
Gaston, SC
NA
MeBr
Site
Dow/DuPont Chemical Co.
Pittsburg, CA
Liquid Injection Incineration
CCU
Dow/DuPont Chemical Co.
Freeport, TX
Rotary Kiln with Liquid
CFC-12, CCU, MeBr,
Freeport Facility
Injection Unit
HCFC-22
Dow/DuPont Louisiana
Plaquemine, LA
Other Rotary Kiln
CCU, MeBr
Operations
Rotary Kiln with Liquid
Injection Unit
Other Incineration/Thermal
Treatment
Dow/DuPont Sabine River
Orange, TX
Rotary Kiln with Liquid
CCU
Works
Injection Unit
13
-------
ODS Destruction in the United States and Abroad
1 February 2018
Company
Location
Technology in Use3
ODS Processed in
2010-2016
Dow/DuPont Washington
Works
Washington, WV
Other Incineration/Thermal
Treatment
HCFC-22
Eagle US 2 LLC
Westlake, LA
Liquid Injection Incineration
Fume/Vapor
CCI4
Eastman Chemical Co. South
Carolina Operations
Gaston, SC
Other Incineration/Thermal
Treatment
MeBr
Eastman Chemical Co.
Tennessee Operations
Kingsport, TN
Rotary Kiln with Liquid
Injection Unit
Other Incineration/Thermal
Treatment
MeBr
Evoqua Water Technologies LLC
Parker, AZ
NA
CCI4
Evoqua Water Technologies
Darlington Facility
Darlington, PA
NA
CFC-11, CCI4
Flint Hills Resources Joliet LLC
Channahon, IL
Fume/Vapor
MeBr
Formosa Plastics Corp. Louisiana
Baton Rouge, LA
Fume/Vapor
CCU
GB Biosciences Corp.
Houston, TX
Fume/Vapor
CCU
Georgia Gulf Lake Charles LLC
Westlake, LA
Fume/Vapor
CCU
Honeywell International Inc.
Geismar Plant
Carville, LA
Other Incineration/Thermal
Treatment
CFC-13, CFC-113,
CFC-115, HCFC-22
Honeywell International Inc.
Baton Rouge Plant
Baton Rouge, LA
NA
HCFC-22
Indorama Ventures Xylenes and
PTA LLC
Decatur, AL
NA
MeBr
LaFarge Midwest Inc. (Including
Systech Environmental)
Fredonia, KS
NA
CCU
Mexichem Fluor Inc.
Saint Gabriel, LA
Other Incineration/Thermal
Treatment
HCFC-22
Occidental Chemical Corp.
Wichita, KS
Fume/Vapor
CCU
Occidental Chemical Corp.
Gregory, TX
Fume/Vapor
Liquid Injection Incineration
CCU
Occidental Chemical Holding
Corp. - Geismar Plant
Geismar, LA
Liquid Injection Incineration
CCU
Olin Blue Cube Freeport TX
Freeport, TX
NA
CCU, MeBr
Oxy Vinyls LP Deer Park - VCM
Plant
Deer Park, TX
Fume/Vapor
CCU
Oxy Vinyls LP La Porte - VCM
Plant
La Porte, TX
Fume/Vapor
CCU
Rubicon LLC
Geismar, LA
Fume/Vapor
CCU
Shintech Plaquemine Plant
Plaquemine, LA
NA
CCU
Solvay Specialty Polymers USA
LLC
Thorofare, NJ
Liquid Injection Incineration
HCFC-141b
Syngenta Crop Protection LLC
Saint Gabriel, LA
Gas/Fume Oxidation
CCU
Velsicol Chemical LLC
Memphis, TN
Liquid Injection Incineration
CCU
Westlake Vinyls Co.
Geismar, LA
Fume/Vapor
CCU
14
-------
ODS Destruction in the United States and Abroad
1 February 2018
Company
Location
Technology in Use3
ODS Processed in
2010-2016
Westlake Vinyls Inc.
Calvert City, KY
Other Incineration/Thermal
Treatment
ecu
Source: EPA (2017a).
NA = Not Available.
a Information on destruction technologies is taken from pre-2005 TRI reports, as available; starting in 2005, TRI no longer
required companies to report this information.
Approximately 90 percent of the facilities in Table 4
report destruction of CCI4 and/or methyl bromide to
the TRI. These chemicals are commonly
manufactured for use in pharmaceutical and
agrochemical applications. They are also used as a
raw material or processing agent for the
manufacture of other chemicals and products. CCI4
was the dominant ODS feedstock substance in the
1990s and early 2000s, however, HCFCs (e.g., HCFC-
22) and CFCs (e.g., CFC-11, CFC-12, CFC-13, CFC-113,
and CFC-115) are now the globally dominant
feedstocks (Touchdown 2012). These feedstocks are
commonly used to produce HFCs, fluoropolymers,
and other ODS. After the feedstock is used, the
waste stream (containing traces of these
compounds) is sent for destruction to a third party
or destroyed on-site (see Box 4).
4.3. Capacity of U.S. Destruction Facilities
The capacity for hazardous waste incineration at U.S. commercial HWC facilities varies greatly, from
about 500 kg/hour to about 14,000 kg/hour. On an annual basis, total destruction capacity for a single
facility can be upwards of 40,000 metric ton (MT) of material per year. However, this capacity does not
directly translate to a facility's potential capacity to destroy ODS, because all facilities (with the
exception of the plasma arc facility) process ODS as a small part of a much larger variety of hazardous
wastes.
In 2015, according to EPA's National Biennial RCRA Hazardous Waste Report, 3,365,000 MT of hazardous
wastes were destroyed in the United States (EPA 2017c),8 compared to approximately 2,100 MT of ODS
destroyed in that year. It is expected that in the event of a surge in need for ODS destruction, there is
significant available capacity in facilities that do not have RCRA permits. These facilities, many of which
are cement kilns that destroy non-hazardous waste, could be retrofitted and apply for permits to accept
ODS.
8 This includes hazardous wastes that were destroyed by the following management methods: incineration (H040), defined as
"thermal destruction other than use as a fuel"; energy recovery (H050), defined as "used as fuel (includes on-site fuel blending
before energy recovery)"; and fuel blending (H061), defined as "waste generated either onsite or received from offsite" (see
Appendix B).
Box 4. Companies That Destroy ODS But Do Not
Report to the TRI
In addition to the ODS destruction facilities
identified in Table 3 and Table 4 based on the TRI
database, several other types of companies
reported destruction activities to the ODSTS. These
are:
• Pharmaceutical Companies
• Laboratories
• Semiconductor Manufacturers
• Specialty Chemical Manufacturers
These companies may not report to the TRI
database for several reasons (e.g., due to threshold
limits, laboratory activity exemptions, or
alternative transformation technologies used), but
limited information is available.
15
-------
ODS Destruction in the United States and Abroad
1 February 2018
The plasma arc unit in Bowling Green, OH is the only destruction facility in the United States currently
dedicated to destroying ODS, including CFCs, HCFCs, and halons, but the facility has also investigated
using the unit to destroy other wastes. The facility does not have a RCRA permit, so any waste they
destroy must be classified as non-hazardous. The capacity of the plasma arc unit ranges from 34 to 36
kg/hour of a 100 percent ODS feed, and they have indicated that additional units could be added to
meet requirements for additional capacity.
4.4. International ODS Destruction Facilities and Technologies
About 155 destruction facilities are known to have operated in 28 countries around the world since
2008 (MLF 2008). While there has not been a comprehensive study to update this list since 2008, there
are some known cases of new facilities or facilities that stopped destroying commercially. For example, a
retrofit cement kiln in Cuba, a retrofit rotary kiln in Colombia, and new destruction technologies in Brazil
have all recently begun operation with assistance by the United Nations Development Programme
(UNDP) (Alves 2015). Conversely, at least one facility has stopped accepting ODS on a commercial scale:
the rotary kiln in Swan Hills, Alberta, Canada. Table 5 lists countries with known commercial destruction
facilities, as well as the type of technologies they use, their capacities to destroy ODS, destruction costs
in U.S. dollars.9 Data on the amounts of ODS destroyed at each facility are not readily available.
Table 5. Commercial Destruction Facilities and Technologies around the World
Country
Number of
Known ODS
Destruction
Facilities in
Operation
Known Technologies
Utilized
ODS Destruction
Capacity
Typical
Destruction
Costs
(US$)
1.
Algeria
1
Cement Kiln
NA
NA
2.
Argentina
2 or more
NA
NA
NA
3.
Australia
2
Argon Plasma Arc
600 MT/year
$7/kg
4.
Austria
1
NA
NA
NA
5.
Belgium
2
Rotary Kiln
NA
NA
6.
Brazil
4 or more
Rotary Kiln
Cracking Reactor
Argon Plasma Arc
Chemical Reaction with H2 and CO2
NA
NA
7.
Canada
1
Rotary Kiln
Not accepting
ODS for
commercial
destruction
$12/kg
8.
Colombia
1
Rotary Kiln
NA
NA
9.
Cuba
1
Cement Kiln
NA
NA
10.
Czech
Republic
1
Rotary Kiln
40 MT/year
NA
11.
Denmark
4
Catalytic Cracking
NA
NA
12.
Estonia
1
NA
NA
NA
13.
Finland
1
Rotary Kiln
545 MT/year
NA
9 Estimated costs here and throughout the report have not been adjusted to account for inflation because the costs are typical
and expected to shift as the market fluctuates and operational costs change.
16
-------
ODS Destruction in the United States and Abroad
1 February 2018
Country
Number of
Known ODS
Destruction
Facilities in
Operation
Known Technologies
Utilized
ODS Destruction
Capacity
Typical
Destruction
Costs
(US$)
14. France
2
NA
NA
NA
15. Germany
7
Hazardous Waste Incinerator
Reactor Cracking
Porous Reactor
1,600 MT/yearb
(Reactor
Cracking)
NA
16. Hungary
5
Rotary Kiln
Liquid Injection Incineration
75 MT/yeara
(Rotary Kiln)
13 MT/year
(Liquid Injection
Incineration)
NA
17. Indonesia
1
Cement kiln
600 MT/year
NA
18. Italy
12
NA
NA
NA
19. Japan
80
Cement Kilns/Lime Rotary Kilns (7)
Nitrogen Plasma Arc (8)
Rotary Kiln Incineration/ Municipal
Solid Waste Incinerators (24)
Liquid Injection Incineration (7)
Microwave Plasma (5)
Inductively Coupled Radio
Frequency Plasma (1)
Gas-Phase Catalytic
Dehalogenation (1)
Superheated Steam Reactors (25)
Solid-Phase Alkaline Reactor (1)
Electric Furnace (1)
36 MT/year (one
catalytic facility)
2,600 MT/yearb
(one incinerator)
Rotary Kilns:
$4/kg
Superheated
Steam: $5/kg
Plasma Arc:
$9/kg
Reactor
Cracking: $4-
6/kg
Gas Phase
Catalytic
Dehalogenation
: $5-7/kg
20. Netherlands
6
NA
NA
NA
21. Poland
1
NA
NA
NA
22. Slovakia
1
NA
NA
NA
23. Spain
1
NA
NA
NA
24. Sweden
4
Air Plasma, among others
100 MT/year
NA
25. Switzerland
4 or more
Rotary Kiln, among others
910 MT/yearb
(Rotary Kiln)
> 320 MT/year
(others)
NA
26. United
Kingdom
2
High-Temperature Incineration
NA
NA
27. United
States
11
Rotary Kilns
Plasma Arc
Fixed Hearth Units
Liquid Injection Units
Cement Kilns
Lightweight Aggregate Kilns
318 MT/year
(Plasma Arc)
$2 - $13/kg
28. Venezuela
2 or more
NA
NA
NA
Sources: ICF (2010c), Alves (2015), and UNEP (2015).
NA= Not available.
17
-------
ODS Destruction in the United States and Abroad
1 February 2018
a Number represents approximate ODS destruction capacity based on known overall plant capacity and typical ODS feed rates
for rotary kilns.
b Capacity is not specific to ODS; value shown refers to capacity for all hazardous wastes and/or other types of wastes.
5. International Efforts to Destroy ODS
There is no comprehensive publicly available data on the destruction of ODS globally. This section
presents ODS destruction data from U.S., European, and Japanese government agencies in addition to
estimates of CFC and halon destruction in other Article 5 and non-Article 5 countries.
5.1. United Slates
The U.S. EPA has two reporting programs that are relevant to the management of ODS and related
chemicals. The first, the TRI Program, is covered under Title 40, Part 372 of the Code of Federal
Regulations (CFR) and tracks the management of toxic chemicals, including ODS from certain sources,
and requires facilities in certain industry sectors to report annually on the volume of toxic chemicals
managed as waste. The volume of chemicals destroyed falls under the TRI categories of "disposal,"
which include disposal in landfills, surface impoundments, underground injections, and off-site
transfers, and "treatment" which include methods such as biological treatment, incineration, and
chemical oxidation. These methods result in varying degrees of destruction of the chemicals.
The second is covered under Title 40, Part 82 of the CFR and requires that any person who destroys a
Class I or Class II ODS controlled substance reports the name and quantity of the substance destroyed
for each control period to the ODSTS in quarterly and annual reports. These data are compiled and sent
annually to the UNEP Ozone Secretariat consistent with Article 7 of the Montreal Protocol.
5.1.1. Reported Amount and Type of ODS Destroyed
As shown in Figure 1, destruction of ODS in the United States has decreased from 2010 to 2016 by over
50 percent, with the greatest reduction in the quantity of Class I ODS10 destroyed. Class I ODS
destruction has decreased by nearly 61 percent in this period, from a total of approximately 3,690 MT in
2010 to approximately 1,440 MT in 2016. Class II ODS11 destruction has varied but remained relatively
stable since 2010 with a maximum of 749 MT of destruction in 2010 and a minimum of 437 MT of
destruction in 2013.
10 Per 40 CFR 82, Class I chemicals include chemicals listed under Montreal Protocol Annex A Group 1 (CFCs) and Group 2
(halons); Annex B Group 1 (CFCs), Group II (CCI4), and Group III (methyl chloroform); Annex C Group II (HBFCs); and Annex E
Group I (MeBr).
11 Per 40 CFR 82, Class II chemicals include chemical listed under Montreal Protocol Annex C Group I (HCFCs).
18
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 1. U.S. Destruction of Class I and Class II ODS (2010-2016)
5000
4500
4000
P
^ 3500
3000
o
tS 2500
-------
ODS Destruction in the United States and Abroad
1 February 2018
Figure 2. U.S. Imports for Destruction of Class I and Class II ODS (2010-2016)
tn 300
Other C ass
Source: EPA(2017d).
5.2. European Union
5.2.1. Reported Amount and Type of ODS Destroyed
As shown in Figure 3, the total destruction of ODS in the European Union decreased from 2010 to 2012,
increased from 2012 to 2015, and decreased in 2016. The initial decrease is a result of the stockpiling of
CCI4 produced as an unintentional by-product from 2010 to 2012, and the subsequent destruction of the
stockpiles in 2013. Since 2012, the stockpiling of CCI4 has ceased which has increased destruction
activity, but it should also be noted that the unintentional by-production of CCI4 has decreased since
2013.
From 2013 to 2016, approximately 75 percent of all the ODS destroyed in the European Union was CCI4
(exact data is not available from 2010 to 2011) which accounts for the increase in Europe's destruction
activity during this time. Figure 3 also illustrates that although the destruction of CFCs and Class II are
similar, the destruction of CFCs decreased in 2015 while the destruction of Class II has been increasing
since 2012. Table 6 presents the total quantity of ODS destroyed in the European Union from 2010 to
2016 as well as the quantity of CFCs, CCI4, halons, and Class II destroyed from 2012 to 2016.
20
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 3. Destruction of Class I and Class II OPS in the EU (2010-2016)
10000
6000
.J,j l'i
2010
2012
2014
2016
Class II Other Class I BCFCs CCL4 ®Total
Sources: EEA (2012), EEA (2013), EEA (2014), EEA (2015), EEA (2016), and EEA (2017).
Table 6. ODS Destroyed in the EU (MT) (2010-2016)"
Chemical 2010 2011 2012 2013 2014 2015 2016
CFCs
NA
NA
868
1,060
1,061
957
1,030
ecu
NA
NA
1,275
4,036
6,946
7,955
5,633
Halons
NA
NA
31
14
22
C
32
Other Class lb
NA
NA
35
36
35
52c
23
Total, Class 1
NA
NA
2,210
5,145
8,063
8,965
6,719
Total, Class II
NA
NA
635
738
1,102
1,143
1,034
Total, All ODS
9,863
6,016
2,845
5,883
9,970
10,456
7,753
Sources: EEA (2012), EEA (2013), EEA (2014), EEA (2015), EEA (2016), and EEA (2017).
NA = Not available.
C = Confidential.
a The chemical breakout data in this table for 2012 to 2016 is sourced directly from the European Environment Agency's
Ozone-Depleting Substances annual reports for those years (EEA 2012-2017). The total values for 2010 to 2016 are
sourced exclusively from the 2016 report as the 2010 to 2015 numbers have been updated in the 2016 report (EEA 2017).
b "Other Class I" includes other CFCs, HBFCs, methyl bromide, and methyl chloroform.
c "Other Class I" includes other CFCs, FIBFCs, methyl bromide, methyl chloroform, and halons.
21
-------
ODS Destruction in the United States and Abroad
1 February 2018
5.2.2. Reported ODS Imported for Destruction
Per Regulation (EC) No 1005/2009 of the European Parliament and of the Council on substances that
deplete the ozone layer, imports of controlled substances (ODS) are prohibited, with several exceptions
including imports of controlled substances for destruction. However, all imports of controlled
substances, including for destruction, require a license. In Europe, the majority of ODS imported are
intended for use as feedstock or re-export for refrigeration. In 2016, 96 percent of the over 5,000 MT
imported was intended for these uses, as well as 91 percent in 2015, 69 percent in 2014, 61 percent in
2013, and 54 percent in 2012 (data is not available from 2010 to 2011). The European Environment
Agency (EEA) has not specified the intended use of the remaining material, but the quantity remaining
which could be for destruction has decreased from 2012 to 2016.
Transfers of ODS between European countries do not require licenses, so some European countries with
destruction capabilities such as France, Germany, and the United Kingdom receive ODS both in bulk and
in equipment (e.g., whole refrigerators) for destruction from other European countries that lack
destruction capacity (MLF 2008) (see Box 5).
Box 5. European Union Import of ODS from Georgia
A recent Multilateral Fund project in the country of Georgia, Pilot demonstration project for ODS waste
management and disposal, demonstrated the potential to overcome barriers to the destruction of unwanted
ODS through synergies between ODS and persistent organic pollutant (POP) disposal processes. Under the
Stockholm Convention, Georgia is obliged to destroy hazardous waste including POPs, so the MLF project
identified a waste subcontractor to collect, aggregate, pack, and transport the ODS and POPs together to a
destruction facility in France, which allowed for overall savings and increased efficiency. The project disposed
of 1.2 MT of unwanted ODS wastes and Georgia is in the process of establishing a National Environmental Fund
to fund with future exports of ODS waste (MLF 2017).
5.3. Japan
5.3.1. Reported Amount and Type of ODS Destroyed
In Japan, CFCs and HCFCs are controlled and they must be recovered from home appliances, cars, and
commercial equipment when the equipment containing these gases is decommissioned. According to
the Law Concerning the Recovery and Destruction of Fluorocarbons, recovered refrigerants must be
either recycled or destroyed. Approximately, 84 percent of recovered CFCs and 77 percent of recovered
HCFCs were destroyed in 2015 (Japan MOE 2016). As shown in Figure 4, the total destruction of ODS
refrigerants in the Japan has stayed constant at 2500 MT from 2010 to 2015.
22
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 4. Destruction of CFC and HCFC Refrigerants in Japan (2010-2015)
¦ HCFCs
Source: Japan MOE (2016).
5.3.2. Reported ODS Imported for Destruction
Japan operates approximately 80 ODS destruction facilities with a mixture of incineration, plasma arc,
and non-incineration technologies. The Japanese Ministry of Environment has provided assistance to
other countries seeking to construct or retrofit their own destruction equipment. For example, in 2007
the Japanese Ministry of Environment provided technical assistance to Holcim Indonesia for the retrofit
of a cement kiln to process ODS. It is unknown whether Japan accepts imported ODS for destruction (ICF
2010b).
5.4. Destruction of ODS in Article 5 and Non-Article 5 Countries
The following section provides estimates of the ODS destroyed based on an analysis of production data,
given that the Montreal Protocol defines production as "amount of controlled substances produced,
minus the amount destroyed by technologies to be approved by the Parties and minus the amount
entirely used as feedstock in the manufacture of other chemicals" (UNEP 2017a).
Table 7 and Table 8 provide estimated values for CFC and halon destruction in select countries,
excluding the United States and countries in the European Union. This report estimates that any
production of CFCs and halons in these countries will be used as feedstock in the producing country;
therefore, these values would cancel each other out in the above formula. As a result, a negative
reported ODS production value should closely resemble the amount of ODS destroyed in that country.
Since the values are reported for each calendar year, a negative production value is also possible if the
feedstock value exceeds the production value for a given reporting period.
23
-------
ODS Destruction in the United States and Abroad
1 February 2018
Table 7. Estimated CFC Destruction in Select Countries (MT)a
Country
2010
2011
2012
2013
2014
2015
Australia
22.7
28.6
14.4
7.1
13.9
8.5
India"
NA
NA
14.6
18.8
NA
32.4
Mexico
-
-
-
-
-
37.8
Source: UNEP (2017a).
a Data converted from ODP Tonnes to MT using 0.95 conversion factor, representative of a mixture of CFCs.
b In 2010, 2011, and 2014, India reported positive production data, potentially due to production of CFCs under an
essential use exemption for use in metered dose inhalers (UNEP 2014a). These data are not presented because it is
not possible to estimate destruction quantities when the production value is positive.
Table 8. Estimated Halon Destruction in Select Countries (MT)a
Country
2010
2011
2012
2013
2014
2015
Australia
18.7
-
23.3
-
-
-
China
-
-
0.3
0.1
0.2
-
Source: UNEP (2017a).
a Data converted from ODP Tonnes to MT using 3.0 conversion factor, representative of halon 1211 destruction
(Verdonik 2017).
In addition to the data available through the Data Access Center, some information is available through
international projects focused on ODS destruction, as highlighted in Box 6.
Box 6. International ODS Destruction Projects
The Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ) project Management and Destruction of
Ozone Depleting Substances aims to establish policy framework conditions to establish national ODS banks
management and technology cooperation. GIZ estimates that if all measures are implemented to the full
extent, emissions of 2 MMTCOze per year and per country will be avoided (GIZ 2014).
GIZ collaborated with the Brazilian Ministry of the Environment on the Introduction of a Comprehensive
Refrigerator Recycling Programme in Brazil to establish a pilot recovery and recycling system for old household
refrigerators and freezers. A state-of-the-art refrigerator recycling facility established through the program
recovers ODS refrigerant and foam-blowing agents from up to 400,000 units annually, ensuring the proper
destruction of up to 120 MT of CFC-11 and CFC-12 each year (GIZ 2011).
The Japanese Ministry of Environment provided technical assistance to Holcim Indonesia for the retrofit of a
cement kiln to process ODS. By 2009, the facility had destroyed over 16 MT of ODS, a rate of 8 MT of ODS per
year. The vast majority of the amount was CFC-11, with the remainder being CFC-12, HCFC-22, and blends (ICF
2010b).
6. Global ODS Recovery, Transportation, and
Destruction Costs
Costs are incurred throughout the entire process of ODS destruction, including for transportation and
recovering ODS from products and equipment. This section presents estimates of these costs based on
information received from personal communication with destruction project developers, the 2009 TEAP
Decision XX/7 Task Force report, and other sources.
24
-------
ODS Destruction in the United States and Abroad
1 February 2018
6.1. ODS Recovery Costs from Products and Equipment
For ODS that are contained in products (e.g., appliance foam) and equipment (e.g., refrigeration/AC, fire
extinguishing), there are additional costs associated with the collection of equipment, transportation of
the ODS-containing products/equipment to processing facilities prior to shipment of the recovered ODS
waste to a destruction facility, and the actual recovery of ODS from those products/equipment. Table 9
presents the range of estimated costs by end-use for segregation/collection, recovery transport, and
recovery processing based on TEAP (2009) and confirmed by a destruction project developer EOS
Climate (2016). For example, while ODS recovery from refrigeration/AC and fire protection equipment
requires a low level of effort and relatively low cost, the separation and collection of ODS are more
difficult and costly for foams contained in appliances, and even more so for foams contained in
buildings.
Table 9: Range of Costs3 for Recovery, Transport, and Processing of ODS in Products and Equipment
End-Use
Segregation/
Collection Costs'3
(US$/kg)
Transport Costs
(Recovery)
(US$/kg)
Recovery Processing
Costs (US$/ kg)
Domestic Refrigeration (refrigerant &foam
blowing agent)
$6-10
$6-40
$10-20 for refrigerant;
$20-30 for blowing agent
Commercial Refrigeration (refrigerant &
foam blowing agent)
$8-20
$8-50
$8-15 for refrigerant;
$25-35 for blowing agent
Transport Refrigeration (refrigerant)
NA
NA
$15-20
Industrial Refrigeration (refrigerant)
$4-6
Air Conditioning (refrigerant)
$1-2°
NA
$4-35
Fire Protection (halon)
Steel-faced Panels (foam blowing agent)
$75-90
$5-10
Block - Pipe (foam blowing agent)
$10-15
$15-20
$30-40
Block-Slab (foam blowing agent)
$80-100
$5-10
Source: TEAP (2009).
NA = Not Available.
a Note that the range of costs for each sector reflects the estimated costs for collection, recovery, and transport of ODS from
sources in densely and sparsely populated areas, requiring low or medium effort. In general, ODS recovery in sparsely
populated areas involves medium effort and higher costs, while recovery from densely populated areas involves low effort and
lower costs. Thus, the costs associated with low effort recovery is reflected in the lower bound of the cost range and medium
effort recovery in the upper bound of the cost range.
b Costs are generally higher for equipment with smaller charge sizes because it requires the same amount of effort to collect
smaller volumes of refrigerant or blowing agent.
c Awareness raising for recovery schemes.
6.2. ODS Transportation Costs
Costs associated with transporting ODS to a destruction facility can vary greatly depending on distance,
quantity, and whether the transport is within or beyond national borders. In some countries, the only
viable means of transporting ODS to a destruction site is by sea or by plane, which can add significant
costs.
In the United States, bulk quantities of ODS in-state are generally the most economical to transport.
According to one destruction company, a railcar carrying 86 MT (190,000 lb) of waste-containing ODS
costs approximately $800 for in-state shipments (about $9 per MT of ODS); these costs approximately
double for out-of-state shipments. The same source estimates that a tank truck carrying 19 MT (42,000
25
-------
ODS Destruction in the United States and Abroad
1 February 2018
lb) of waste can cost up to $700 for in-state shipments ($35 per MT). Prices for out-of-state shipments
were not provided by the source, as they are highly variable (ICF 2009a). Another destruction company
reported the cost to transport waste refrigerant varies from $300 to $600 per MT, depending on the
refrigerant type. Another company charges $3 per kilometer for transport in a pressurized ISO tanker, or
a tanker can be leased (with a minimum 1-year lease) for $1,000 per month (ICF 2009a).
According to TEAP (2009), the international average cost of transporting ODS between 200 to 1000
kilometers ranges from $8 to $60 per MT of ODS. According to a ODS destruction project in Brazil, it
costs approximately $3,000 per MT to transport bulk waste ODS to the European Union by sea and an
additional $1,000 per MT for transaction costs related to the Basel Convention for transporting
hazardous waste into the European Union (UNDP 2014). According to an ODS destruction project in the
country of Georgia, it costs approximately $1,000 per MT to transport bulk waste ODS by land and
$3,600 per MT by sea to the European Union (MLF 2017).
/¦ ' structio ¦
The price of bulk ODS destruction depends on several factors including the type of ODS,
composition/purity, quantity, the type of container the ODS are stored in, technology used, and
transportation needs. ODS destruction costs are difficult to estimate, because each of the cost factors
also vary due to indirect factors such as geographical location, firms contracted, and demand for
services. For example, if a destruction facility has a large amount of refrigerant to destroy in a given
week, prices may increase or the facility may even refuse to accept additional shipments.
6.3.1. Concentrated Sources of ODS
According to MLF (2008), the average estimated cost to destroy concentrated ODS in the United States
ranges from $1.50 to $12.50 per kg. This range is in line with TEAP (2009), which estimates that
international average costs to destroy ODS ranges from $4 to over $6 per kg for concentrated
refrigerant or blowing agent, or $6 to $8 per kg for halon. Actual destruction costs will depend on the
amount of ODS sent for destruction (with bulk quantities generally costing less) and the technology
used. In general, commercial facilities using incineration technologies (e.g., rotary kilns, cement kilns,
reactor cracking) have lower costs than facilities using plasma arc technologies.
6.3.2. Dilute Sources of ODS
The average estimated cost to destroy dilute ODS was not analyzed separately from concentrated ODS
in MLF (2008) or TEAP (2009). Typically, dilute ODS will cost more to destroy than concentrated ODS.
Dilute sources of ODS include foam blocks removed from appliances or buildings. For example, in the
United States, appliance foam is sometimes recovered manually in large chunks, placed into large plastic
bags (which are sealed to capture any off-gassing ODS), and then destroyed in municipal solid waste
combustors or waste-to-energy facilities. One U.S. municipal waste-to-energy (WTE) facility reported
charging $0.18 per kg for destruction of bulk appliance foam; another facility reportedly charges $0.14
per kg plus an additional $120 per load (ICF 2009a). To put these costs in perspective, if the average U.S.
refrigerator contains 5 kg of foam, destruction of the bagged foam in a WTE facility will cost roughly
$830 to $910 for 1,000 units. In the United States, municipal solid waste destruction facilities may
charge lower prices when compared to private facilities since their prices are resolved on a no-profit
basis (ICF 2009a).
26
-------
ODS Destruction in the United States and Abroad
1 February 2018
7. Financing of ODS Destruction Projects
There are a variety of different mechanisms for funding ODS destruction projects, including producer
responsibility programs or taxes on ODS, the generation of carbon offset credits which can be sold on
the global carbon market, or support from the Multilateral Fund (MLF) and the Global Environment Fund
(GEF) for both financial and project planning assistance.
' " : '-iclueer Respi.- - V • -r ' -. < .
ODS destruction can be funded through voluntary or government-mandated programs that create
financial and behavioral incentives for stakeholders in the process. If regulations are in place to require
the collection and destruction of ODS, the collection and destruction of that ODS may not be considered
"additional" (i.e., already required by law or otherwise commonly practiced) on certain carbon markets,
and therefore would not be eligible for credits.
Extended producer responsibility (EPR) programs, which often rely on levies or licensing fees (usually on
the production/import of ODS-containing equipment), and rebates (for the return of recovered ODS),
can be used to encourage producers to safely manage the manufacture, operation, and
decommissioning of ODS-containing equipment. Producer responsibility programs are thought to work
best in countries with strong public support and/or government support, and in situations where few
players are involved (MLF 2008). For example, Australia created Refrigerant Reclaim Australia (RRA) to
develop and manage the Australian ODS recycling and destruction program. RRA operated on a
voluntary basis from 1993-2004 until the Ozone Protection and Synthetic Greenhouse Gas Management
Act took effect and required companies to exercise product stewardship over imported products (RRA
2012). The RRA is completely funded by the industry from money derived through an industry levy on
import of refrigerants in bulk or in pre-charged equipment.
The European Union mandates the recovery for reclamation, recycling, or destruction of ODS when it is
technically and economically feasible to do so according to Regulation (EC) 1005/2009 (EU 2009). The
European Union provides a directive for the collection of waste electrical and electronic equipment
(WEEE) (e.g., potentially ODS-containing refrigerators, freezers, and other cooling appliances). General
guidelines are set at the Union level, however Member States can develop financing programs based on
national preference. Member States are encouraged to make producers take full responsibility for the
WEEE collection, in particular by financing the collection of WEEE throughout the entire waste chain,
including from private households, in order to avoid separately collected WEEE becoming the object of
suboptimal treatment and illegal exports, to create a level playing field by harmonizing producer
financing across the European Union and to shift payment for the collection of this waste from general
tax payers to the consumers of EEE, in line with the 'polluter pays' principle (EU 2012).
An example of a voluntary partnership is Refrigerant Management Canada (RMC), an industry
partnership that organizes the collection, transport, and destruction of ODS waste in Canada. It was
established in 2000 as an industry-led EPR organization with the goal of managing Canada's surplus bank
of ODS. RMC organizes the export of ODS to the United States and earns offset credits based on
successful destruction.
Fees and taxes can also be assessed outside of a producer responsibility program to generate revenue to
fund ODS collection, recycling, and disposal. For example, disposal fees can be added to the cost of new
appliances containing ODS, which also encourages consumers to purchase non-ODS containing
27
-------
ODS Destruction in the United States and Abroad
1 February 2018
equipment. Taxes can also be imposed, for instance, on the production of new equipment containing
ODS.
Japan requires the recovery and recycling or destruction of fluorocarbons from commercial equipment
during service and disposal events. At the time of disposal, consumers pay a fee that covers collection,
transport, and recycling - which costs approximately $40 for a refrigerator and $30 for an AC unit. The
Japanese law mandates that the fee for fluorocarbon recovery and destruction be paid by end-users (ICF
2010a). Because there is a legal requirement to destroy the refrigerant, offset credits for the destruction
of the ODS cannot be awarded.
Another possibility is leveraging the interest of producers of ODS substitutes as a means of funding ODS
destruction. In Italy, for example, a producer of halon alternatives offered to collect and destroy halons
from users who committed to using the alternative. In China, a fire extinguisher program was developed
that gave a new alternative-based fire extinguisher to those needing to refill their halon extinguishers
(ICF 2010b).
' 'V-: " struction ^ .'grams
Carbon markets can be broadly divided into two key segments—the compliance market and the
voluntary market. The key difference between the two types of carbon markets is the existence of a
legal requirement for certain industries to reduce and/or offset their emissions. As a result, the price of
carbon offset credits sold on the compliance market is approximately 2 to 10 times higher than credits
sold on the voluntary market, depending on the type of project. Compliance markets are created and
regulated by mandatory regional, national, or international greenhouse gas (GHG) emissions reduction
programs. Voluntary markets operate outside the compliance market, where organizations can offset
carbon emissions on a voluntary basis. Projects are not eligible for offset credits if they are not going
above the level of compliance required by the corresponding national law. Therefore, companies
operating in countries where ODS destruction is required are not eligible to generate offset credits
because of additionality and double-counting of emission reductions.
7.2.1. Compliance Markets
Compliance markets exist at an international level and at national and regional levels through legally-
binding policy instruments. The key aspect of compliance markets is that there is a legal requirement for
those bodies covered to keep their emissions under a set target. They can do so by either decreasing
their own emissions, or purchasing allowances or carbon offset credits that are considered eligible12 for
compliance purposes from a marketplace. Several compliance markets have approved protocols for ODS
destruction.
In 2012, the California Air Resources Board (CARB) enacted a cap and trade program that establishes a
statewide ceiling on carbon emissions, which declines each year. Companies operating within the state
have to lower their emissions or purchase offset credits. Under the CARB protocols, emissions
reductions for offset credits must be based in the United States. Currently, ODS destruction projects are
12 Eligibility criteria for offsets in compliance markets are different from market to market. Certain vintages, types of projects,
geographical origin of the credits are considered when deciding on eligibility of credits.
28
-------
ODS Destruction in the United States and Abroad
1 February 2018
only available for credits if they source the materials from within the United States, and the destruction
takes place within the United States (CARB 2017).
In 2012, Quebec enacted an independent cap and trade system similar to California. Due to their similar
or identical GHG emission allowances law and regulation, Quebec and California linked their two
programs in 2014, thus forming a joint carbon market within the framework of the Western Climate
Initiative (WCI). Following successful implementation of Ontario's cap and trade system in 2016, the
Ontario market will join the WCI regional carbon market in January 2018. This will allow all three
governments to hold joint auctions of GHG emission allowances and to harmonize regulations and
reporting. At this time, Quebec has developed a protocol for the destruction of ODS foams, while
Ontario has not yet developed any protocols targeting ODS destruction. In 2017, the Ontario and
Quebec governments enlisted help from the CAR to develop a protocol for ODS foam and refrigerant
destruction (CAR 2017).
In addition to the North American compliance markets discussed above, several countries and cities
have implemented emissions trading systems including the European Union, China, South Korea, Japan,
Kazakhstan, Switzerland, Australia and New Zealand. These systems do not currently award offset
credits for ODS destruction, however they may approve similar protocols in the future.
7.2.2. Voluntary Programs
Voluntary programs operate outside of compliance markets and allow organizations to offset carbon
emissions on a voluntary basis. The voluntary carbon market has been used as a funding source for ODS
destruction. The market demand for voluntary offsets is driven by buyers' interest. The credits have
been used by businesses and events to balance their emissions. The three most widely traded voluntary
offset programs in the United States with ODS destruction protocols are the VCS, CAR, and the American
Carbon Registry (ACR). Table 10 presents a breakdown of the voluntary carbon markets with ODS
destruction protocols.
Table 10. Breakdown of Voluntary Markets and ODS Destruction Protocols in 2016
Offset Program
Total Transacted
Volume (millions
of MTCChe)3
Total Value
Traded(US$
Millions)3
Protocol for
ODS Destruction
ODS Sou reed
Internationally
Verified Carbon Standard
33.1
$76.4
Yes
Yes
Climate Action Reserve
4.4
$13.2
Yes
Yes
American Carbon Registry
1.8
$0.9
Yes
No
Sources: Ecosystem Marketplace (2017) and ACR (2017).
a The totals presented in this table account for all offset projects eligible under the voluntary program, of which a small
portion are ODS destruction projects.
7.2.3. Carbon Prices and Profitability
The sale of carbon credits on the compliance and voluntary markets is one potential method for funding
ODS destruction projects. In 2015, approximately 300,000 MTC02e from ODS destruction projects were
transacted globally in the voluntary market (Ecosystem Marketplace 2016). There are additional costs
associated with the preparation, validation, and verification of ODS destruction projects, which are
summarized in Table 11.
29
-------
ODS Destruction in the United States and Abroad 1 February 2018
Table 11. Transaction Costs to Prepare an OPS Destruction Project
Project Phase
Cost (US$)
Project Preparation
Up to $60,000
Third-Party Validation
Up to $40,000
Third-Party Verification
$20,000
Offset Marketplace Fees
Up to $1,000
Issuance/Registration Fee
$0.05-0.20/MTC02e
Source: ICF (2010b).
While the financial prospects of funding ODS destruction projects through the sale of carbon offset
credits are promising, there are challenges throughout the process. One of the main challenges is that
projects generate revenue only once the offset credits have sold. In developing countries, upfront
capital is rarely available to support an ODS destruction project. Some firms previously provided upfront
financing to companies and reclaimed their investment once the credits were sold; however, this
business model is no longer effective because of the drop in offset prices. Other firms provide funding
by brokering the sale of credits to potential buyers. In the voluntary market, offset-buying firms often
assist in the development of specific projects that match their corporate responsibility profile. In 2015,
an estimated 4 percent of total transactions represented early-stage financing in the voluntary market.
Payment-on-delivery and spot contracts were the most common contract types in 2015 (Ecosystem
Marketplace 2017).
Figure 5 shows the break-even costs of ODS destruction projects based on the recovery, transport,
destruction, and project development costs from ICF (2010b). The break-even cost represents the price
that would have to be generated in the carbon market in order to cover the full costs of the project. As
shown, the break-even price decreases as the project size increases, as a result of realizing project
economies of scale associated with the mostly fixed project development costs. The projects are
compared on a sectoral basis because it is often the most efficient way of collecting ODS. Figure 5
presents three different collection programs: refrigerator collection, ODS stockpiles, and large stationary
AC.
30
-------
ODS Destruction in the United States and Abroad
Figure 5. Break-Even Costs Compared to Average Price of Offset
1 February 2018
g $30.00
u
1SY
LT)
z>
Based on average price of offset
in California Cap and Trade
Based on average price of ODS
offset in Voluntary Markets
$50.00
$45.00
$40.00
$35.00
$25.00
$20.00
$15.00
$10.00
o
m C
£ o
CD '-M i
¦5? a
a.
(D
CC
00
00
O
o
u
<
>
ro_
c
aj o
Ctf) '-P
ru
(T3 4->
—I 00
Sources: ICF (2010b), Ecosystem Marketplace (2016), and Thomson (2017).
7.3. HFC-23 Destruction
HFC-23 generated as a byproduct from HCFC-22 production was a source of carbon credits on a variety
of international carbon markets starting in 2005. In 2013, the European Union Emissions Trading System
(EU ETS), New Zealand, and Australia imposed a ban on the use of CER credits from HFC-23 destruction,
which significantly lowered the value of credits obtained from HFC-23 abatement projects. This step was
taken because it was determined that allowing credits from the destruction of HFC-23 could create a
perverse incentive to increase production of HCFC-22, a gas which both depletes the ozone layer and is a
powerful GHG (Levitan 2010).
Under the Kigali Amendment, Parties commit, starting in 2020, to destroy HFC-23 emissions to the
extent practicable in specified facility types using technology approved by the Parties. Facilities can also
opt to install incinerators or conversion technology which converts HFC-23 to useful high-purity
byproducts (e.g., CO and HF). These conversion technologies can generate positive revenue streams.
31
-------
ODS Destruction in the United States and Abroad
1 February 2018
sstruction Projects
In some cases, international organizations (e.g., MLF and GEF) fund projects that assist in ODS collection,
management, and destruction. Demonstration projects are funded by these organizations to show that
ODS destruction is viable, develop lessons learned, and establish replicability. Due to the varying
capabilities of the MLF and GEF, each organization focuses funding on different aspects within the
process of ODS waste management.
The MLF focuses funding on financial, technological, and logistical aspects by developing demonstration
projects that assist countries in building/retrofitting destruction facilities or assist with the collection
and transport of ODS to countries with destruction facilities (GIZ 2015). In 2014, the MLF funded a
cement kiln retrofit in Algeria, which has led to the destruction of approximately 31 MT of ODS per year
(GIZ 2015). In 2011, the MLF funded the collection and transport for destruction of 8.8 MT of bulk ODS
from Ghana to the European Union (UNDP 2011). In some situations, the international organizations
collaborated with the private sector to monetize the project. For example, in 2012, the MLF, in
collaboration with EOS Climate, funded the collection and transport for destruction of waste ODS from
Nepal to the United States. EOS Climate acted as a project verifier and facilitated the sale of 82,400
Verified Emission Reductions (VER) in the CAR (UNEP 2017b).
The GEF focuses funding on legal and informational aspects by developing policy and legislation to
support the phaseout of ODS and responsible end-of-life (EOL) practices. From the late 1990s to the late
2000s, the GEF funded the development and implementation of policy and legislation in Eastern Europe
and Central Asia to phase out consumption and promote responsible ODS recovery, recycling,
reclamation, and destruction (Batchelor 2010).
8. Modeled Amounts of ODS Potentially Available for
Destruction
The large amount of ODS currently installed in equipment and products, and existing in stockpiles, could
be released to the atmosphere given emissions from ODS banks are not controlled by the Montreal
Protocol. ODS banks can be recovered and properly treated, i.e., reused (after recycling or reclamation)
or destroyed. To demonstrate the scope of available ODS banks, the sections below present modeled
estimates of the amount of ODS potentially available for destruction in the United States, European
Union, and globally from 2010 through 2050 via recovery from equipment and products, and from
stockpiles.
"V . ' 1 •' '--v :\TI6 ¦ ;
As discussed in Section 3.1, ODS refrigerant from refrigeration/AC equipment is typically relatively easy
to recover, making the refrigeration/AC sector one of the largest accessible ODS banks. In the fire
protection sector, halons may also be recovered, including halon 1211, which is most commonly found
in hand-held extinguishers, and halon 1301, commonly used in total flooding systems (NFPA 2008). ODS
recovery from appliance foams is also feasible, however, the level of effort to recover ODS from
construction foams is high, and the quantity of original blowing agent that is actually recoverable is
relatively lower than for the refrigeration/AC sector. The following sections present modeled estimates
of the amount of ODS potentially recoverable in the United States, European Union, and globally from
2010 through 2050.
32
-------
ODS Destruction in the United States and Abroad
1 February 2018
8.1.1. United States
The U.S. EPA Vintaging Model (VM)13 was used to develop estimates of available banks of ODS for
recovery in the United States. The VM estimates consumption and emissions from six industrial sectors:
refrigeration/AC, foams, aerosols, solvents, fire extinguishing, and sterilization. The model, named for its
method of tracking annual "vintages" of new equipment that enter into service, models the
consumption and emissions of chemicals based on estimates of the quantity of equipment or products
sold, serviced, and retired each year, and the amount of the chemical required to manufacture and/or
maintain the equipment.
The amount of chemical potentially recoverable from equipment/products being disposed of is modeled
in the VM with varying recovery rates depending on the end-use and vintage of equipment. According to
assumptions in the VM, the amount of ODS recoverable from equipment at disposal varies by
equipment and gas type, ranging from about 90 percent of the original charge recovered at disposal for
large equipment such as chillers or cold storage to about 65 percent recovered for small equipment like
small retail food units (e.g., display coolers and freezers). Additionally, the VM assumes that ODS are not
recoverable from retired U.S. equipment at EOLfrom foam applications.
Only ODS potentially recoverable from refrigeration, AC, and fire protection equipment are estimated in
this analysis. Estimated quantities of HFCs potentially recoverable from retired equipment at EOL are
presented in Section 10.2.
Figure 6 presents the breakdown of total CFCs potentially recoverable from retired U.S. equipment at
EOL by end-use from 2010 through 2020. The model's assumptions on equipment lifetimes dictate that
CFCs will only be available from three end-uses: commercial refrigeration, industrial process
refrigeration (IPR) and cold storage (CS), and commercial stationary AC, specifically chillers. All other
end-uses that previously used CFC refrigerant (e.g., motor vehicle air conditioners) were modeled to
reach their EOL before 2010. After 2020, CFCs are no longer expected to be available for recovery from
any end-use in the United States.
1310 version 4.4 (08.31.17).
33
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 6. Quantity of CFCs Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2020)a
2.500
2,000
1;500
> 1,000
500
2010
Commercial Refrigeration
2015 2020
IPR/CS ¦ Commercial Stationary AC
Source: EPA (2017b).
a After 2020, CFCs are no longer expected to be available for recovery for destruction.
Figure 7 presents the breakdown of total HCFCs potentially recoverable from retired U.S. equipment at
EOL by end-use from 2010 through 2050. From 2010 to 2020, most of the HCFCs potentially recoverable
will have come from the retirement of residential stationary AC equipment, as well as some from
commercial stationary AC, IPR/CS, and commercial refrigeration. The model's assumptions on
equipment lifetimes dictate that the majority of HCFCs will have been collected by 2030. Commercial
stationary AC and IPR/CS remain as the dominant end-uses from which HCFC refrigerants may be
potentially recoverable from equipment at EOL through 2050.
Figure 7. Quantity of HCFCs Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2050)
25,000
_ 20,000
15,000
^ 10,000
5,000
I . .
2010 2015 2020 2025
¦ Commercial Refrigeration
¦ Commercial Stationary AC
Other
2030 2035 2040 2045 2050
¦ IPR/CS
¦ Residential Stationary AC
Source: EPA (2017b).
34
-------
ODS Destruction in the United States and Abroad
1 February 2018
8.1.2. European Union
The technical and economic feasibility of recovering ODS from equipment and products at EOL in the
member states of the EU was assessed in ICF (2010a). Figure 8 and Figure 9 show the quantities of CFCs
and HCFCs estimated to be potentially recoverable from equipment at EOL in 2010, 2020, and 2050,
based on a bottom-up modeling methodology used to estimate banks. This analysis assumes that ODS
from foam applications is potentially recoverable. By 2050, CFCs and HCFCs from refrigeration/AC
equipment are no longer expected to be available for recovery. Approximately 2,000 MT of CFCs and
HCFCs will be potentially recoverable from foam products at EOL by 2050, although ODS recovery from
foam applications typically require a medium to high effort.
Figure 8. Quantity of CFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
- ¦ Mobile AC
¦ Stationary AC
¦ Refrigerators/Freezers
¦ Commercial Refrigeration
¦ Refrigerated Transport
XPS Foam Boards
¦ PL) Rigid: Spray Foam
PL) & PIR Rigid: Boardstock
¦ PL) Rigid: Sandwich Panels
¦ PL) Rigid: Commercial
Refrigeration
bPU Rigid: Domestic
Refrigerators/Freezers
2050
Source: ICF (2010a).
7,000
6,000
j§" 5,000
5 4,000
>
O
0
<1)
%. 3,000
1
CD
o 2,000
CL
1,000
2010
2020
35
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 9. Quantity of HCFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
¦ Stationary AC
¦ Refrigerators/Freezers
i Commercial Refrigeration
¦ Refrigerated Transport
¦ Industrial Refrigeration
¦ XPS Foam Boards
¦ PU Rigid: Spray Foam
PU & PIR Rigid: Boardstock
i PU Rigid: Sandwich Panels
¦ PU Rigid: Commercial
Refrigeration
¦ PU Rigid: Domestic
Refrigerators/Freezers
Source: ICF (2010a).
8.1.3. Global
Global estimates are based on EPA's VM and data from the European Commission of ODS potentially
recoverable from retired equipment at EOL (ICF 2010b). As shown in Figure 10, the majority of ODS for
destruction is expected to be CFCs from refrigeration/AC equipment, particularly from Article 5
countries. HCFCs are not modeled in Article 5 countries because it is assumed that they would be
recovered for reuse. All recoverable ODS will likely not be recovered due to several factors including lack
of necessary recovery equipment, geographical dispersion of equipment, and cost. ODS potentially
available at equipment EOL in the United States and European Union was modeled in ICF (2010b);
however, the results are not included in Figure 10 because other studies are referenced. The rate of
recovery is expected to vary significantly by country, with a higher proportion of material likely
recovered in non-Article 5 countries and in Article 5 countries with more established recovery
infrastructure or denser population centers (ICF 2010b).
7,000
6,000
5,000
i—
¦
T3 3,000
a)
o
2,000
1,000
0
2010
2020
2050
36
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 10. Global Estimates of ODS Potentially Available from Retired Equipment at EOL in MMTC02e,
(2010-2050)
350
¦ Other Non-A5: Ref/AC (CFC)
¦ Other Non-A5: Ref/AC (HCFC)
¦ Other Non-A5: Foams (CFC)
I Other Non-A5: Foams (HCFC)
¦ Other Non-A5: Fire Protection
(Hal on)
I A5: Ref/AC (CFC)
¦ A5: Foams (CFC)
¦ A5: Fire Protection (Halon)
2050
Source: ICF (2010b).
"Other Non-A5" does not include estimates for the United States and EU.
8.2. Availability of Stockpiles
8.2.1. CFCs and HCFCs in Refrigeration/AC Equipment
The estimates of ODS potentially available for destruction in Figure 6, Figure 7, Figure 8, Figure 9, and
Figure 10 do not account for any stockpiles since currently there is little information available on existing
or future ODS stockpiles. Preliminary research indicates that the likelihood of ODS users having large
stockpiles for which future planned use is not imminent is quite low because of the costs required to
store surplus ODS and the current demand for most ODS. The most likely holders of surplus ODS are
service companies that possess "empty" cylinders of ODS that were used to service equipment and that
actually still contain a heel of up to 5 percent of the original contents (ICF 2009a). Further, there is
potential to stockpile virgin ODS for future servicing needs (e.g., HCFC-22 manufactured prior to 2020 in
the United States). Such stockpiling may be a risky business practice due to the uncertainty associated
with market trends, although in the future, R-22 supplies will continue to be more limited and costs to
service equipment with R-22 may rise (ICF 2009b).
8.2.2. Haions in Fire Extinguishing Equipment
Halons can be easily collected and stored for reuse and disposal. Existing stockpiles of halon can be
reclaimed for reuse, destroyed, or transformed to other useful chemical products. There is, however,
continued global demand for halons so the TEAP has recommended that destruction should be avoided
when possible and should only be considered if the halons are cross-contaminated and cannot be
reclaimed to an acceptable purity level (UNEP 2014b).
300
o
u
250
200
_Q
0)
>
O
u
-------
ODS Destruction in the United States and Abroad
1 February 2018
Given destruction of halon 1301 is highly discouraged, halon stockpiles will not likely be available for
destruction. Regardless, the ACR revised its ODS destruction project standard in 2017 to include halons
1211 and 1301 (ACR 2017).
9. ODS Management Needs for Developing Countries
Developing countries face the challenge of maintaining sound management of ODS through equipment
operation and throughout the process of collection, consolidation and storage, transportation, and
destruction of waste ODS (see Exhibit 1). In every step of the process, project management, training,
recordkeeping, and legal and logistical infrastructure are key to efficient ODS disposal.
Exhibit 1. The Process of ODS Destruction and Illustrative Recordkeeping
Requirements
Equipment jWj Mixed/Contaminated
Banks yMv Stocks
Examples of Common Recordkeeping Requirements
• Documentation on source of ODS (e.g. use, location)
• Proof of ownership
• Recovery rate for specific equipment
• Quantity and types of ODS
• Shipping manifests
• International transport and Customs documents, as applicable
• Distance traveled by each mode of transport
• Fuel economy for each mode of transport
• Emission factor for each fuel type used
• Quantities of ODS
• Type of ODS (e.g, through gas chromatography)
• Proof that facility is certified for ODS destruction
• Destruction and Removal Efficiency
• Amount fed into destruction unit
• Electricity consumption by destruction facility
• Emission factor for grid electricity, including grid losses
• Fossil fuel consumption of destruction facility
• Fossil fuel emission factor
Source: ICF (2010b).
Collection
Most countries lack a network of collection facilities to utilize economies of scale when developing
national or regional projects for storing and transporting ODS. One territory in Brazil manages waste
CFCs across several companies and reclamation centers with different storage standards. Their logistical
|[ Confiscated Virgin ODS
Iv Stocks /MY Stocks
Collection
Consolidation
and Storage
A
Transport
Testing
Destruction
38
-------
ODS Destruction in the United States and Abroad
1 February 2018
need was addressed by placing recycling centers in 120 cities, four of which were advanced centers that
are capable of consolidating, identifying, and transferring ODS waste to labelled cylinders. Brazil also
purchased a fleet of refillable cylinders for collecting ODS because non-refillable cylinders previously
made up the refrigerant market (MLF 2014). Streamlining the ODS waste collection process is key to the
success of the subsequent technical steps of ODS disposal.
Consolidation and Storage
Data tracking on the size of remaining ODS stock and the amount of destroyed ODS are important for
managing the consolidation and storage of waste ODS. Carbon credits can only be earned if proper data
tracking procedures are employed throughout the entire project. Another challenge in waste
consolidation is the proper and consistent classification of different types of ODS waste. This needs to
be addressed in some developing countries such as China, where waste ODS are classified differently in
each province (GIZ 2015). In a project in Indonesia, officials were not able to identify the types of ODS
found in unlabeled cylinders, which complicated project management and storage activities (ICF 2013).
Consistent tracking of waste from the beginning can help avoid logistical issues later in the waste
management process.
Transport
Depending on the land area and available infrastructure, transportation of waste ODS can be the biggest
obstacle to proper management. Some developing countries do not have a road or rail network that
would facilitate waste ODS transportation. For instance, Brazil initially lacked proper vehicles or
transport containers for ODS waste transport, but invested in the required transportation equipment in
order to collect and transport waste from a widespread project area (MLF 2014). Technical standards
should be established for handling, labelling, and transportation of ODS waste and may include legal
requirements if waste ODS are classified as a hazardous substance in the country or if the waste is
shipped abroad.
Testing
Properly trained personnel are often needed at each aggregation and destruction facility to test
incoming shipments of waste ODS. Mandatory training and certification for technicians can help ensure
best practices are followed; however, some countries do not require such training (GIZ 2015). In the
country of Georgia, for example, skilled personnel are needed to operate the gas chromatograph used
for analysis of incoming waste ODS (MLF 2015). The composition of incoming waste is important
because it can determine whether the shipment is eligible for carbon offset credits or if it contains an
elevated level of contaminants.
Destruction
A key component in ODS destruction plans is the determination of a suitable facility for the destruction
to take place. Consultation with experts is often helpful to select the appropriate means for ODS
destruction, because the pros and cons for each option vary depending on the region, resources, and
volume of waste ODS. Options to destroy ODS include exporting ODS to other countries, using mobile
destruction units, retrofitting existing waste destruction facilities, or building new ODS destruction
facilities.
Few developing countries have existing capacity to destroy ODS, and building or retrofitting new
destruction facilities is not always feasible, cost-effective, or environmentally-sound, given the carbon
footprint of new construction. In these countries, exporting waste ODS to developed countries is a
preferred option. Although this is usually the easiest method for destruction, some countries ban the
39
-------
ODS Destruction in the United States and Abroad
1 February 2018
import or export of ODS. For instance, Saudi Arabia faces a need for ODS waste management, but it is
illegal to export ODS, which means that all waste disposal must happen domestically (ICF 2010b).
Another option is to use mobile destruction units, current models of which can destroy hazardous waste
at rates of 5 kg/hour and can provide a cost-effective destruction option for small stockpiles of ODS
(MLF 2008). Mobile destruction units are small in size and can be used on one-off projects without the
need to secure stable sources of ODS.
Instead of exporting ODS waste or using small mobile units, it can be more cost effective in some cases
to build or retrofit a destruction facility if a large volume of ODS is expected to be available for
destruction. Retrofitting is an option if there is a cement kiln or a similar facility that can be easily
converted. Algeria and Indonesia approached the need for an ODS destruction facility by modifying
existing cement kilns to destroy ODS waste after analyzing the cost-benefits of each option. Existing kilns
contain similar infrastructure to what is needed to destroy ODS, which simplifies the conversion process
(MLF 2014).
Coordination with Developed Countries
Developed countries may be able to facilitate ODS management in developing countries by utilizing
existing infrastructure and minimizing the need for construction of new facilities. For example, the
Nordic Environmental Financing Corporation planned an initiative to recover and destroy ODS from
appliances at EOL in the greater Moscow region, using an existing retailer network for collection. The
units were intended to be transported to Finland for recovery and destruction using existing idle
capacity of Finnish trucks that deliver new refrigerators to Russia and return empty. Projects like this,
which minimize the implementation of new infrastructure by utilizing existing capacity, are a way to
destroy ODS at lower cost (ICF 2010b).
Developed and developing countries can work to facilitate compliance with the legal requirements
relevant for the transport of waste ODS, as in the case of a UNDP-subsidized project in Nepal that used a
third party company to execute the collection and transport of confiscated ODS to the United States for
destruction. It was reported that a primary challenge during project implementation was the lengthy
process to get approval for the export of the ODS to the United States because of the need for Nepalese
parliamentary clearance (UNEP 2017b). See Appendix A for further information on transboundary
movement (TBM) of ODS.
10. Implications for Addressing HFC Disposal
In October 2016, Parties agreed in the Kigali Amendment to the Montreal Protocol to phasedown HFC
production and consumption. Under the Montreal Protocol, destroyed amounts are subtracted from the
definition of consumption. The Amendment also includes provisions to destroy HFC-23 emissions
generated in HFC and HCFC production facilities to the extent practicable using technology approved by
the Parties. This section discusses the similarities in waste management between ODS and HFCs and the
current and projected quantities of HFC available for destruction.
40
-------
ODS Destruction in the United States and Abroad
1 February 2018
3 etiv-. .¦ » . ,
-------
ODS Destruction in the United States and Abroad
1 February 2018
2010b). Although the destruction of HFC material was not eligible for offset credits, it was successfully
destroyed as part of the refrigerant mixture.
The sale of carbon offset credits earned through compliance and voluntary markets may continue to be
a method of financing HFC destruction. Currently, credits are available through the ACR which
developed a protocol for the destruction of high-GWP (e.g., CFC-11, CFC-12, HCFC-22, HFC-134a, and
HFC-245fa) insulation foams from appliances, buildings or other sources (ACR 2017). The blowing agent
must be destroyed according to the procedures detailed in the protocol in order to be eligible for
credits.
¦ , jantit'. •• * -1 '¦ Me ' ¦ -.struction
In developing countries, which have only recently begun transitioning to HFCs, ODS are still commonly
used in systems and equipment. In developed countries, HFCs have largely replaced ODS in equipment.
Equipment containing HFCs have lifetimes up to 30 years. New HFC-containing equipment is entering
the market so the installed base of HFC-containing equipment and amount of HFCs recovered at EOL is
expected to grow for another 20 years.
Some systems or equipment that were charged with HFCs and are nearing EOL are expected to be
decommissioned with the remaining charge to be recovered. Most recovered material is expected to be
reclaimed or recycled to service existing systems15 in the installed base. However, materials that are
recoverable from equipment and products may also be available for destruction.
Using the same methodology discussed in Section 8, the VM was used to develop estimates of recovery
quantities of HFC refrigerants, foam blowing agents, and fire suppression agents potentially available for
destruction from retired equipment from 2010 through 2050 for the United States (see Figure 11). As
expected, the quantity of HFCs recoverable from retired equipment/products at EOL is expected to
continue to increase through 2030, when ODS are completely phased out, and then become relatively
stable.
The model's assumptions dictate that mobile AC is the primary driver in potentially recoverable HFCs
until 2020. In 2030, potential recovery of HFCs at EOL reaches a maximum at approximately 38,000 MT
due to the commercial stationary AC equipment. From 2030 to 2050, most of the HFCs potentially
recoverable will come from commercial and residential stationary AC equipment, IPR/CS, and
commercial refrigeration.
15 Reclamation is important when handling HFC blends (e.g., R-404A, R-407C, R-410A) because previous evaporation of different
components at different rates during leaks or other releases may lead to the refrigerant remaining in the equipment to be off-
specification (i.e., one component may be present in higher or lower amounts than allowed)..
42
-------
ODS Destruction in the United States and Abroad 1 February 2018
Figure 11. Quantity of HFC Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2050)
40,000
_ 35,000
i—
- 30,000
0
| 25,000
§ 20,000
*
2? 15,000
1 10,000
£™ I I I I
2010 2015 2020 2025 2030 2035 2040 2045 2050
¦ Commercial Refrigeration ¦ Domestic Refrigeration bIPR/CS
¦ Transport Refrigeration i Commercial Stationary AC ¦ Residential Stationary AC
¦ Mobile AC
Source: EPA (2017b).
As another example, Figure 12 shows the quantities of HFCs estimated to be potentially recoverable in
the EU from equipment at EOL in 2010, 2020, and 2050, based on a bottom-up modeling methodology
used to estimate banks (ICF 2010a). This analysis is based on relevant EU regulations and assumes that
ODS from foam applications is potentially recoverable. These estimates demonstrate that less than
43,000 MT of HFCs will be potentially recoverable from refrigeration/AC equipment at EOL in 2050.
Approximately 360 MT of HFCs will be potentially recoverable from foam products at EOL in 2050 (and
higher amounts in 2020), although recovery from foam applications typically require a medium to high
effort.
43
-------
ODS Destruction in the United States and Abroad
1 February 2018
Figure 12. Quantity of HFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
45,000
40,000
j_
35,000
2
0
30,000
"8
>
25,000
o
0
CH
20,000
1
C
0)
15,000
o
CL
10,000
5,000
2010
2020
2050
Mobile AC
Stationary AC
i Refrigerators/Freezers
i Commercial Refrigeration
i Refrigerated Transport
i Foams
Source: ICF (2010a).
The capacity at destruction facilities in the United States, European Union, and globally are expected to
be sufficient to destroy the potentially available HFC banks.
44
-------
ODS Destruction in the United States and Abroad
1 February 2018
11. References
Air-Conditioning, Heating, and Refrigeration Institute (AHRI). 2016. AHRI Standard 700-2016 with
Addendum 1, Specifications for Refrigerants. September 2016. Available online at:
http://www.ahrinet.org/App Content/ahri/files/STANDARDS/AHRI/AHRI Standard 700-
2016 with Addendum l.pdf
Alves, Anderson. April 7-11 2014. ODS Destruction Montreal Protocol Unit/Chemicals. UNDP. Available
online at:
http://www.pnuma.org/ozono/Reuniones%20Anuales%20Coniuntas%20v%20Talleres/SURINAME%202
014/Presentaciones Dia 2/Anderson Alves UNDP Presentation SRV Destruction.pdf
American Carbon Registry (ACR). 2017. Methodology for the Quantification, Monitoring, Reporting and
Verification of Greenhouse Gas Emissions Reductions and Removals from the Destruction of Ozone
Depleting Substances and High-GWP Foam. July 2017. Available online at:
http://americancarbonregistrv.org/carbon-accounting/standards-methodologies/destruction-of-ozone-
depleting-substances-and-high-gwp-foam/acr-destruction-of-ods-and-high-gwp-foam-iulv-2017-vl-
O.pdf
ASADA. Undated. Technical Information. Undated. Available online at:
http://www.asada.co.ip/english/e-catalog/hvac/index f.html#106
Batchelor, T.A. and V. Smirnov. 2010. Evaluation of GEF-Funded UNEP and UNDP Projects that Phased
Out Ozone-Depleting Substances in Countries with Economies in Transition. Terminal Evaluation. Report
to the UNEP Evaluation and Oversight Unit, Nairobi. March 2010. 749 pp.
California Air Resources Board (CARB). 2017. Early Action Offset Credits. March 2017. Available online
at: https://www.arb.ca.gov/cc/capandtrade/offsets/earlyaction/credits.htm
Climate Action Reserve (CAR). 2017. ODS Destruction Protocol Stakeholder Meeting: Ontario and
Quebec. Presented on March 3rd, 2017.
Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ). 2011. Capturing ozone-depleting
substances and greenhouse gases form household refrigerator: Introduction of a comprehensive
refrigerator recycling programme in Brazil. Available online at:
https://www.giz.de/expertise/downloads/Fachexpertise/giz2011-en-proklima-proiectsheet-brazil.pdf
Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ). 2014. ODS Banks Global Project:
Management and destruction of ozone depleting substances. Available online at:
https://www.giz.de/expertise/downloads/giz2014-en-QDS WEB.pdf
Duetsche Gesselschaft fur Internationale Zusammenarbeit (GIZ). 2015. Management and Destruction of
Existing Ozone Depleting Substances Banks. August 2015. Available online at:
https://www.giz.de/expertise/downloads/giz2015-en-studv-ods-banks-management.pdf
Duetsche Gesselschaft fur Internationale Zusammenarbeit (GIZ). 2017. Guideline for the Transboundary
Movement of ODS Waste. March 2017. Available online at:
https://www.giz.de/expertise/downloads/giz2017-en-no4-guideline-transboundarv-movement.pdf
45
-------
ODS Destruction in the United States and Abroad
1 February 2018
Ecosystem Marketplace. 2016. Raising Ambition: State of the Voluntary Carbon Markets 2016. May
2016. Available online at: http://www.forest-trencls.org/clocuments/files/cloc 5242.pdf
Ecosystem Marketplace. 2017. Unlocking Potential: State of the Voluntary Carbon Markets 2017. May
2017. Available online at: http://www.forest-trencls.org/clocuments/files/cloc 5591.pdf#
Environmental Investigation Agency (EIA). 2014. New Trends in ODS Smuggling. Presented to the 26th
Meeting of the Montreal Protocol. 17-21 November 2014. Available online at: https://eia-
international.org/wp-content/uploads/EIA-New-Trends-in-ODS-Smuggling-lo-res.pdf
EOS Climate. 2016. Personal Communication between Jeff Cohen, EOS Climate, and ICF. December 13,
2016.
European Environment Agency (EEA). 2012. Ozone-depleting substances 2011: Aggregated data
reported by companies on the production, import, export, destruction and use of ozone-depleting
substances in the European Union - Summary. Available online at:
https://www.eea.europa.eu/publications/ozone-depleting-substances-2011-summarv
European Environment Agency (EEA). 2013. Ozone-depleting substances 2012: Aggregated data
reported by companies on the import, export, production, destruction and feedstock and process agent
use of ozone-depleting substances in the European Union. Available online at:
https://www.eea.europa.eu//publications/ozone-depleting-substances
European Environment Agency (EEA). 2014. Ozone-depleting substances 2013: Aggregated data
reported by companies on the import, export, production, destruction and feedstock and process agent
use of ozone-depleting substances in the European Union. Available online at:
https://www.eea.europa.eu//publications/ozone-depleting-substances-2013
European Environment Agency (EEA). 2015. Ozone-depleting substances 2014: Aggregated data
reported by companies on the import, export, production, destruction and feedstock and process agent
use of ozone-depleting substances in the European Union. Available online at:
https://www.eea.europa.eu//publications/ozone-depleting-substances-2014
European Environment Agency (EEA). 2016. Ozone-depleting substances 2015: Aggregated data
reported by companies on the import, export, production, destruction and feedstock and process agent
use of ozone-depleting substances in the European Union. Available online at:
https://www.eea.europa.eu//publications/ozone-depleting-substances-2015
European Environment Agency (EEA). 2017. Ozone-depleting substances 2016: Aggregated data
reported by companies on the import, export, production, destruction and feedstock and process agent
use of ozone-depleting substances in the European Union. Available online at:
https://www.eea.europa.eu//publications/ozone-depleting-substances-2016
European Parliament and the Council of the European Union (EU). 2009. Regulation (EC) No 1005/2009
on Substances that Deplete the Ozone Layer. Official Journal of the European Union. September 2009.
Available online at: http://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:32009R1005&from=EN
46
-------
ODS Destruction in the United States and Abroad
1 February 2018
European Parliament and the Council of the European Union (EU). 2012. Directive (EU) 2012/19/EU on
Waste Electrical and Electronic Equipment (WEEE). Official Journal of the European Union. July 2012.
Available online at: http:
content/EN/TXT/HTML/?uri=CELEX:32012L0Q19&from=EN
European Parliament and the Council of the European Union (EU). 2014. Regulation (EU) No 517/2014
on Fluorinated Greenhouse Gases and Repealing Regulation (EC) No 842/2006. Official Journal of the
European Union. April 2014. Available online at:
PDF/?uri=CELEX:32014R0S17&from=EN
ICF International. 2009a. ODS Destruction in the United States of America and Abroad. Prepared by ICF
International for the U.S. Environmental Protection Agency. May 2009. Available online at:
http://unep.ch/ozone/data reporting/USA-Decision-XX-7-ODS-Destruction.pdf
ICF International. 2009b. The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. Air-
Conditioning and Refrigeration Sector. Prepared by ICF International for the U.S. Environmental
Protection Agency. December 2009. Available online at:
https://pdfs.semanticscholar.org/81af/flb8435fdccdb45b71f5bdcaafea897711fc.pdf
ICF International. 2010a. Identifying and Assessing Policy Options for Promoting the Recovery and
Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (F-Gases)
Banked In Products and Equipment. Prepared by ICF International for the European Commission. May
2010. Available online at: https://ec.europa.eu/clima/sites/clima/files/ozone/docs/ods f-
gas destruction report en.pdf.
ICF International. 2010b. Study on Financing the Destruction of Unwanted Ozone-Depleting Substances
through the Voluntary Carbon Market. Final Report. Prepared by ICF International for the World Bank.
February 2010. Available online at:
http://www.multilateralfund.Org/sites/61/Document%20Library2/l/61lnf2.pdf.
ICF International. 2010c. Destruction of Ozone-Depleting Substances in the United States. Prepared by
ICF International for the U.S. Environmental Protection Agency. April 2010.
ICF International. 2013. Prepared by ICF International for the World Bank. Establishment of a Private-
Public Financing System for Disposal of ODS for the Philippines.
Japan Ministry of the Environment (MOE). 2016. Let's Protect the Ozone Layer 2016 Edition. 2016.
Available online at: https://www.env.go.ip/en/earth/ozone/leaf2016/Full.pdf
Lamb, C., Dellinger, B., Wagner, M., &, Lanza, R. (2008). Incinerability of Halons and HCFCs: Theoretical
Calculations of DRE and Ozone-Depleting or Global-Warming Gases, Paper # 13. Presented at Twenty-
seventh Annual International Conference on Thermal Treatment Technologies, Montreal, Canada, May
12-16, 2008.
Lamb, C., Dellinger, B., Wagner, M., &, Lanza, R. (2010). Incinerability of Halons and HCFCs: Theoretical
Calculations of DRE and Ozone-Depleting or Global-Warming Gases, Environmental Engineering Science,
Volume 27, Number 7, 2010.
47
-------
ODS Destruction in the United States and Abroad
1 February 2018
Levitan Dave. 2010. China, India Opposed to Closing $5 Billion Loophole in Kyoto Treaty. Inside Climate
News. June 2010. Available online at: https://insideclimatenews.org/news/2010Q616/china-india-
opposed-closing-5-billion-loophole-kyoto-treatv?page=show
Midwest Refrigerants. 2017. Groundbreaking Fluorocarbon Conversion Technology Advances under
Montreal Protocol. December 2017. Available online at: http://www.midwestrefrigerants.com/MWR-
UNDP PRESS RELEASE 12-6-17.pdf
Multilateral Fund (MLF). 2008. Study on the Collection and Treatment of Unwanted Ozone-Depleting
Substances in Article 5 and Non-Article 5 Countries. Prepared by ICF International for the Multilateral
Fund of the Montreal Protocol. May 2008.
Multilateral Fund (MLF). 2014. Pilot Demonstration Project on ODS Waste Management and Disposal.
April 2014. Available online at: http://www.multilateralfund.Org/72/English/l/7219.pdf
Multilateral Fund (MLF). 2015. Desk Study on the Evaluation of the Pilot Demonstration Projects On ODS
Disposal and Destruction. October 2015. Available online at:
http://www.multilateralfund.Org/75/English/l/7510.pdf
Multilateral Fund (MLF). 2017. Executive Committee of the Multilateral Fund for the Implementation of
the Montreal Protocol: Seventy-ninth Meeting-Reports on Projects with Specific Reporting
Requirements. 3-7 July, 2017. Available online at:
http://www.multilateralfund.Org/79/English/l/7914.pdf
National Fire Protection Association (NFPA). 2008. Halon Frequently Asked Questions. 2008. Available
online at: http://www.nfpa.it/d faq.htm.
Refrigerant Reclaim Australia (RRA). 2012. Destruction of Waste ozone Depleting Substances and
Synthetic Greenhouse Gases Program. 2012. Available online at: https://refrigerantreclaim.com.au/wp-
content/uploads/2013/02/RRA-Destruction-Consultation-Paper-Response.pdf
Robin, Mark. 2012. DuPont Chemicals and Fluoroproducts. ASTM Standards for Halon 1211. November
2012. Available online at: https://www.fire.tc.faa.gov/pdf/systems/Novl2Meeting/Robin-1112-
Halonl211ASTMStds.pdf
Sirkin, Sam. 2016. Personal communication between Sam Sirkin and ICF. November 18, 2016.
Technology and Economic Assessment Panel (TEAP). 2002. Report of the UNEP Technology and
Economic Assessment Panel (TEAP), Report of the Task Force on Destruction Technologies. Montreal
Protocol on Substances That Deplete the Ozone Layer. United Nations Environment Programme. Volume
3B, April 2002. Available online at
http://ozone.unep.org/Assessment Panels/TEAP/Reports/Other Task Force/TEAP02V3b.pdf.
Technology and Economic Assessment Panel (TEAP). 2009. UNEP Technology and Economic Assessment
Panel (TEAP) Task Force Decision XX/7 - Phase 2 Report. Environmentally Sound Management of Banks
of Ozone-Depleting Substances. October 2009. Available online at
http://ozone.unep.org/Assessment Panels/TEAP/Reports/TEAP Reports/teap-october-2009-
decisionXX-7-task-force-phase2-report.pdf
48
-------
ODS Destruction in the United States and Abroad
1 February 2018
Thomson Reuters. 2017. Carbon Market Monitor: A new hope dispelled. Review of Global Markets in
2016. January 2017. Available online at: http://climateobserver.org/reports/11660/
Tran, Richard; Kennedy, Eric; Dlugogorski, Bogdan. 2000. A Process for Conversion of Halon 1211.
University of Newcastle. May 2000. Available online at:
https://www.nist.gov/sites/default/files/documents/el/fire research/R0002203.pdf
Tsang, W., Burgess Jr., D. R., and Babushok, V. (1998) On the Incinerability of Highly Fluorinated Organic
Compounds, Combustion Science and Technology, 139:1, 385-402.
United Nations Development Program (UNDP). 2011. Pilot Demonstration Project on ODS-Waste
Management and Disposal. 18 February 2011. Available online at:
http://www.undp.org/content/dam/ghana/docs/Doc/Susdev/UNDP GH SUSDEV Pilot%20demostratio
n%20proiect%20on%20QDS%20waste%20mgt.pdf
United Nations Development Program (UNDP). 2014. Prepared by Ministry of Environment (MMA). Pilot
Demonstration Project on ODS-Waste Management and Disposal. March 2014. Available online at:
https://info.undp.org/docs/pdc/Documents/BRA/72ExCom UNDP%20BRA%20QDS%20Waste%20MgtDi
sposal%20Proiect%20-%20FINAL.docx.
United Nations Environment Programme (UNEP). 2003. Report of the Fifteenth Meeting of the Parties to
the Montreal Protocol on Substances that Deplete the Ozone Layer. United Nations Environment
Programme. OzL.Pro.15/9. Fifteenth meeting of the Parties to the Montreal Protocol on Substances that
deplete the Ozone Layer. Nairobi. 11 November 2003.
United Nations Environment Programme (UNEP). 2011. Decision XXI11/12: Adoption of New Destruction
Technologies for Ozone-Depleting Substances. 2011. Available online at:
https://ozone.unep.org/new site/fr/Treaties/decisions text.php?m id=152&show all
United Nations Environment Programme (UNEP). 2014a. Report of the Medical Technical Options
Committee (MTOC). February 2015. Available online at:
http://ozone.unep.org/Assessment Panels/TEAP/Reports/MTOC/MTOC-Assessment-Report-2Q14.pdf
United Nations Environment Programme (UNEP). 2014b. Report of the Halons Technical Options
Committee (HTOC). 2014. Volume 1, 2014 Assessment Report. December 2014. Available online at:
http://ozone.unep.org/Assessment Panels/TEAP/Reports/HTOC/HTOC%202014%20Assessment%2QRep
ort.pdf
United Nations Environment Programme (UNEP). 2014c. Basel Convention on the Control of
Transboundary Movements of Hazardous Wastes and Their Disposal. August 2014. Available online at:
http://www.basel.int/Portals/4/Basel%20Convention/docs/text/BaselConventionText-e.pdf
United Nations Environment Programme (UNEP). 2015. Report of the Chemicals Technical Options
Committee (CTOC). June 2015. Volume 1, 2014 Assessment Report. June 2015. Available online at:
http://conf.montreal-protocol.org/meeting/oewg/oewg-
36/presession/Background%20Documents%20are%20available%20in%20English%20only/CTOC%20Asse
sssment%20Report%202014.pdf
49
-------
ODS Destruction in the United States and Abroad
1 February 2018
United Nations Environment Programme (UNEP). 2017a. The Montreal Protocol on Substances that
Deplete the Ozone Layer. 2017. Available online at:
http://ozone.unep.org/sites/ozone/files/Publications/Handbooks/Montreal-Protocol-English.pdf
United Nations Environment Programme (UNEP). 2017b. Report of the Technology and Economic
Assessment Panel: Volume 4 Assessment of the Funding Requirement for the Replenishment of the
Multilateral Fund for the Period 2018-2020. May 2017. Available online at: http://conf.montreal-
protocol.org/meeting/oewg/oewg-39/presession/Background-Documents/TEAP-XXVIII 5-TF-Report-
Mav%202017.pdf
United States Environmental Protection Agency (EPA). 1989. Handbook - Guidance on Setting Permit
Conditions and Reporting Trial Burn Results - Volume II of the Hazardous Waste Incineration Guidance
Series, U.S. Environmental Protection Agency, Office of Research and Development, Office of Solid
Waste and Emergency Response, EPA/625/6-891019 January 1989. Available online at:
https://www.wbdg.org/FFC/EPA/EPACRIT/epa625 6 89 019.pdf
United States Environmental Protection Agency (EPA). 2010a. Technical Support Document for
Emissions from Production of Fluorinated Gases: Final Rule for Mandatory Reporting of Greenhouse
Gases, Office of Air and Radiation, U.S. Environmental Protection Agency, November 5, 2010. Available
online at: https://www.epa.gov/sites/production/files/2015-02/documents/subpart-l techsuppdoc.pdf
United States Environmental Protection Agency (EPA). 2010b. Fact Sheet: Fluorinated Gas Production
Information Sheet Subpart L, Mandatory Reporting of Greenhouse Gases. 40 CFR Part 98, Subpart L. U.S.
Environmental Protection Agency. November 2010. Available online at:
https://nepis.epa.gov/Exe/ZyPDF.cgi/P100BBRP. PDF?Dockey=P100BBRP. PDF
United States Environmental Protection Agency (EPA). 2014. Global Mitigation of Non-C02 Greenhouse
Gases: 2010-2030. March 2014. Available online at: https://www.epa.gov/global-mitigation-non-co2-
greenhouse-gases/global-mitigation-non-co2-ghgs-report-download-report
United States Environmental Protection Agency (EPA). 2016a. The EPA's Updated Refrigerant
Management Requirements. September 2016. Available online at:
https://www.epa.gov/sites/production/files/2016-09/documents/608 fact sheet technicians O.pdf
United States Environmental Protection Agency (EPA). 2016b. International Agreements on
Transboundary Shipments of Hazardous Waste. December 2016. Available online at:
https://www.epa.gov/hwgenerators/international-agreements-transboundarv-shipments-hazardous-
waste#basel
United States Environmental Protection Agency (EPA). 2017a. Toxics Release Inventory (TRI) Program.
Database last accessed on July 20, 2017. Available online at: https://www.epa.gov/toxics-release-
inventorv-tri-program
United States Environmental Protection Agency (EPA). 2017b. Vintaging Model. Version VM 10
file_v4.4_08.31.17.
United States Environmental Protection Agency (EPA). 2017c. Resource Conservation and Recovery Act
2015 Biennial Report Summary. Accessed: August 2017.
-------
ODS Destruction in the United States and Abroad
1 February 2018
United States Environmental Protection Agency (EPA). 2017d. Ozone Depleting Substances Tracking
System (ODSTS). Accessed: December 2017.
Verdonik, Daniel. 2017. Personal communication between Daniel Verdonikand ICF. September 6, 2017.
51
-------
ODS Destruction in the United States and Abroad
1 February 2018
12. Appendices
Appendix A: Transboundary Movement of ODS
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their
Disposal (Basel Convention), is an international treaty that was designed to reduce the movements of
hazardous waste between nations, specifically to prevent transfer of hazardous waste from developed
to less developed countries. Entering into force in 1992, the Basel Convention states that Parties shall
take the appropriate measures to ensure that the TBM of hazardous and other wastes is reduced to the
minimum consistent with the environmentally-sound and efficient management of such wastes (UNEP
2014c). The United States is not a Party to the Basel Convention. As hazardous substances, ODS wastes
fall under the Basel Convention and are subject to the regulations for TBM. Countries without the means
for domestic destruction of ODS usually export ODS waste for destruction.
The national legislation of the importing and exporting countries must be reviewed on a case-by-case
basis, as they may contain additional or slightly different provisions than the Basel Convention. Each
Party has the right to pass stricter legislation and can, for example, prohibit the import of hazardous or
other wastes, including ODS (GIZ 2017). Several regional agreements have been devised that only allow
the import of waste from other member countries of the agreement. The Bamako Convention is a treaty
between 25 African nations prohibiting the import of any hazardous waste. The Waigani Convention is a
treaty between 10 Pacific Islands Forum countries prohibiting the import of any hazardous waste.
The European Union, through Regulation (EC) 1013/2016, established procedures and control regimes
for the shipment of waste between Member States, within the Community or via third countries; waste
imported into and exported from the Community to third countries; and waste in transit through the
Community, on the way from and to third countries. All CFCs, HCFCs, and HFCs are considered and
treated as hazardous waste according to Title II, Article 3.1.b.iii, because they are not explicitly listed as
a "green waste" in Annex III (UNEP 2014c). Consequently, shipment of ODS requires prior written
notification and consent. In addition, this regulation includes labelling requirements. Because many
Member States have few, if any, ODS and F-gas destruction facilities, these gases are often shipped
across Member State borders, which triggers the administrative requirements of this regulation (ICF
2010a).
Generally, TBM is only allowed between Parties of the Basel Convention. It is, however, possible to enter
into bilateral, multilateral, or regional agreements with non-Parties, e.g. to cooperate on ODS waste
management and destruction. Such agreements must comply with the principle of environmentally-
sound management. Examples include agreements several Parties to the Basel Convention have with
the United States.16
16 The United States is party to the OECD Council Decision c(2001)107/FINAL as amended, the US-Mexico bilateral agreement,
the US-Canada bilateral agreement, and import-only agreements with the Philippines, Malaysia, and Costa Rica (EPA 2016b).
52
-------
ODS Destruction in the United States and Abroad
1 February 2018
Appendix B: Resource Conservation and Recovery
Act
In addition to the stratospheric ozone protection regulations for ODS under the CAA, several ODS that
are classified as hazardous wastes and are thus also regulated under RCRA in the United States.
Therefore, the regulations that apply to facilities that handle these hazardous wastes apply to U.S.
facilities that destroy ODS that meet the definition of hazardous waste.17 Subtitle C of RCRA (42 USC,
Section 6921-6930) requires that facilities that store, treat, or dispose of hazardous waste are subject to
permitting requirements implementing regulatory standards that apply to all aspects of a hazardous
waste's management. Combustion of hazardous waste, including combustion of ODS that are identified
or listed as hazardous wastes under the subtitle C regulations, is subject to regulation as a form of
hazardous waste treatment.
Wastes are identified as hazardous either because they are a listed hazardous waste or because they
exhibit a hazardous waste characteristic. There are four characteristics defined by regulation:
ignitability, corrosivity, reactivity, and toxicity. The characteristic hazardous wastes are labeled with a D
code. There are four lists of hazardous wastes as well. The following RCRA listed hazardous waste codes
may apply to some ODS (see 40 CFR Part 261, sections 261.31-33):
• Wastes from non-specific sources (Code F);
• Commercial chemical products (Code U);
• Characteristic wastes (Code D); or
• Wastes from specific sources (Code K).
However, the majority of ODS likely to be destroyed are not classified as RCRA hazardous waste.
According to 40 CFR 261.4(b)(12), refrigerants that meet the following definition are exempt from
classification as hazardous wastes: "used chlorofluorocarbon refrigerants from totally enclosed heat
transfer equipment, including mobile air conditioning systems, mobile refrigeration, and commercial
and industrial air conditioning and refrigeration systems that use chlorofluorocarbons as the heat
transfer fluid in a refrigeration cycle, provided the refrigerant is reclaimed for further use."18 According
to 56 FR 5913, this exemption includes CFC and HCFC refrigerants.
Table 12 summarizes the RCRA hazardous waste codes that may apply to controlled substances (i.e., not
including ODS byproducts or ODS-containing wastes from chemical manufacture). The remainder of this
appendix discusses the circumstances in which ODS may be considered hazardous wastes under RCRA.
17 While the stratospheric ozone protection regulations (40 CFR Part 82, Subpart A) apply to ODS controlled substances, RCRA
regulations and the CAA NSPS and MACT standards are universally applicable to the destruction of ODS, regardless of whether
the ODS are deemed a controlled substance under 40 CFR 82.3.
18 Reclamation is defined in 40 CFR 82.152 as "to reprocess refrigerant to all of the specifications in Appendix A to 40 CFR Part
82, Subpart F...that are applicable to that refrigerant and to verify that the refrigerant meets these specifications using the
analytical methodology prescribed in Section 5 of Appendix A of 40 CFR Part 82, Subpart F."
53
-------
ODS Destruction in the United States and Abroad 1 February 2018
Table 12. RCRA Hazardous Waste Codes for Selected ODS
Hazardous Waste Codes
Ua
F
D
K
CFC-11 (Trichlorofluoromethane)
U121
F001
F002
CFC-12 (Dichlorodifluoromethane)
U075
F001
-
-
Other CFCs and HCFCs
-
F001
-
-
CCI4
U211
F001
D019
-
Methyl Chloroform (1,1,1-
Trichloroethane)
U226
F001
F002
-
-
Methyl Bromide
U029
-
-
-
a Code U only applies to the controlled substances listed above if they were manufactured
and subsequently disposed of without ever being used.
Code F (Wastes from Non-Specific Sources)
ODS may be classified under hazardous waste codes F001 or F002 if they meet one of the following
listing descriptions under 40 CFR 261.31:19
• F001—Applies to the following spent halogenated solvents used in degreasing:
tetrachloroethylene, trichloroethylene, methylene chloride, methyl chloroform, CCI4, and
chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing,
before use, a total of ten percent or more (by volume) of one or more of the above halogenated
solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of
these spent solvents and spent solvent mixtures.
• F002—Applies to the following spent halogenated solvents: tetrachloroethylene, methylene
chloride, trichloroethylene, methyl chloroform, chlorobenzene, l,l,2-trichloro-l,2,2-
trifluoroethane, ortho-dichlorobenzene, CFC-11, and 1,1,2-trichloroethane; all spent solvent
mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or
more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
In short, CCI4, methyl chloroform, and all CFCs and HCFCs may be classified as Code F hazardous wastes
if they have been used as solvents prior to disposal. The generator of the waste is responsible for
determining whether the waste is to be classified as hazardous versus non-hazardous and if hazardous,
assigning the waste code. Additionally, any destruction facility receiving waste is responsible for
verifying that the waste is correctly identified (ICF 2010c).
Code U (Commercial Chemical Products)
ODS may be classified as Code U hazardous wastes (as defined in 40 CFR 261.33) if they are commercial
chemical products or manufacturing chemical intermediates that are discarded or intended to be
discarded (i.e., abandoned by being disposed of; burned/incinerated; or accumulated, stored, or treated
but not recycled before or in lieu of being abandoned by being disposed of, burned, or incinerated, see
19 Waste codes F024 and F025 also apply to hazardous wastes that could contain ODS; however, these would not be considered
controlled substances as they are byproducts of manufacturing processes.
54
-------
ODS Destruction in the United States and Abroad
1 February 2018
40 CFR 261.2(a) and (b)). A commercial chemical product/manufacturing chemical intermediate is
defined in 40 CFR 261.33(c) and (d) as:
• a chemical substance that is manufactured or formulated for commercial or manufacturing use
which consists of the commercially pure grade of the chemical;
• any technical grades of the chemical that are produced or marketed;
• all formulations in which the chemical is the sole active ingredient; and
• any residue remaining in a container or in an inner liner removed from a container that has held
any commercial chemical product or manufacturing chemical intermediate named in this section
of the regulations.20
Thus, while CCI4, methyl chloroform, methyl bromide, CFC-11, and CFC-12 have designated U waste
codes—U211, U226, U029, U121, and U075 respectively—this code is limited to container residues and
products that were manufactured but never used. Therefore, refrigerants removed from equipment
(which are not classified as hazardous wastes) and used solvents (some of which do fall under waste
Code F) would not fall under hazardous waste Code U; a controlled substance that was manufactured
and never used would be considered a Code U waste if it was discarded or intended to be discarded.
^ v . * ¦ r astes ' -us)
ODS-contaminated wastes which may be generated from specific sources, such as the production of
CCI4, may be classified under several K waste codes (e.g., K016, K018, K021, K028, K029, K073, K095,
K096, K131, K132, K150). These waste codes apply mainly to wastes/residues from the production of
various chemicals, and therefore these wastes will not fall under the definition of controlled substances.
However, RCRA regulations would still apply to any such wastes being sent for destruction.
/
-------
ODS Destruction in the United States and Abroad
1 February 2018
differently to listed wastes and characteristic wastes. A mixture involving characteristic wastes is
hazardous only if the resulting mixture itself exhibits a characteristic (i.e., ignitability, corrosivity,
reactivity, or toxicity). Once a characteristic waste no longer exhibits one of the four regulated
properties, it is no longer regulated as hazardous provided it is also not a listed hazardous waste.
However, EPA places certain restrictions on the manner in which a waste can be treated, including a
dilution prohibition (see the Land Disposal Restrictions regulations in 40 CFR Part 268).
Furthermore, hazardous waste treatment, storage, and disposal processes often generate waste
residues (i.e., "derived-from" wastes). Residues produced from the treatment of listed hazardous wastes
are generally still themselves considered hazardous wastes under the RCRA derived-from rule (see 40
CFR 261.3(c)(2)), which states that any material derived from a listed hazardous waste is also a listed
hazardous waste. For example, ash created by incinerating a listed hazardous waste is considered
derived-from that hazardous waste. Thus, such ash bears the same waste code and regulatory status as
the original listed waste that was treated in the incinerator, regardless of the ash's actual properties.
56
-------
ODS Destruction in the United States and Abroad
1 February 2018
Appendix C: Description of ODS Destruction
Technologies
This section provides brief descriptions of each of the ODS destruction technologies that have been
approved by the Parties to the Montreal Protocol, as reported in UNEP (2011). Three additional
technologies that have not been evaluated by TEAP are also described, which may be suitable for ODS
destruction. Fixed hearth incineration, commonly used in the United States and air plasma arc, used in
an experimental facility in Sweden, are also described in this section.
ration Technologies
Incineration technologies utilize "a controlled flame to destroy ODS in an engineered device" (TEAP
2002). Temperatures in these reactors reach over 1,000 °C in order to break down the ODS.
Reactor Cracking
CFCs and HCFCs are broken down or "cracked" into HF, H20, HCI, C02, and Cl2in a 2,000 °C reaction
chamber. After the products are broken down, they are moved to the absorber for cooling. The entire
process results in waste gases consisting mainly of C02, 02, water vapor, and technical grade quality HF
and HCI. The reactor cracking process results in few emissions since hydrogen and oxygen are used as
the fuel and oxidant, resulting in a reduced volume of flue gas. The reactor cracking process is only
designed to destroy fluorocarbons and cannot destroy foams or halons (TEAP 2002).
Gas/Fume Oxidation
The gas/fume oxidation process destroys CFCs, HCFCs, halons, and other wastes in a heat-resistant
combustion chamber using fume steam at temperatures around 1,000 °C. An external fuel such as
natural gas or fuel oil is used to heat the steam. In general, most gas/fume incinerators are associated
with fluorochemical production plants which do not offer destruction services to outside entities (UNEP
2006).
Rotary Kiln Incineration
Rotary kilns utilize a rotating cylinder to destroy hazardous wastes such as CFCs, halons, other ODS, and
ODS-containing foams. The cylinder is set at an incline to allow the ash/molten slag to fall out. The
afterburner uses temperatures around 1,000 °C to ensure the breakdown of all the exhaust gases.
Rotary kiln incinerators are not specifically designed to destroy ODS, so the feed must be regulated to
prevent an excess of fluorine from harming the equipment (TEAP 2002).
L ection incineration
Liquid injection incinerators inject either liquid or vapor wastes into a chamber together with sufficient
combustion air to maintain proper combustion efficiency. Liquid wastes are typically fed to the
incinerator through atomizers that convert liquid feeds into fine liquid droplets which enhances
combustion efficiency (TEAP 2002). These types of incinerators are most typically used to destroy wastes
such as ODS, oils, solvents, and wastewater at manufacturing sites.
57
-------
ODS Destruction in the United States and Abroad
1 February 2018
Cement Kilns22
Cement kilns are primarily used to produce clinker from the conversion of calcium, silica, alumina, and
iron to tricalcium silicates, dicalcium silicates, tricalcium aluminate, and tetracalcium aluminoferrite.
Gypsum is then typically added to the clinker during the grinding process to make cement. Due to the
intense heat of a cement kiln (up to 1,500 °C), some cement kilns are also used to destroy organic
compounds, such as ODS. However, the fluorine and chlorine content of the raw material fed into the
kiln must be monitored and controlled in order not to affect the quality of the clinker. Cement kilns
generally consist of tilted, rotating cylinders that are heated on one end. The raw material is fed into the
higher, cooler end of the kiln and falls down towards the heated end. The heated gases used to convert
the raw materials into clinker travel from the hot end of the cylinder and out of the higher (cold) end of
the kiln. The gases then pass through a pollution control device that removes the particulate matter and
other pollutants from the gases (TEAP 2002).
Fixed Hearth incinerator
Fixed hearth incinerators function similarly to rotary kiln incinerators but utilize fixed combustion
chambers to destroy liquid wastes at temperatures ranging from 760 - 980 °C. Solid wastes are placed in
the primary combustion chamber where they are burned; the residue ash is removed from the primary
chamber, and the by-product gases move into the secondary combustion chamber for further
destruction. While fixed hearth incinerators are typically utilized to incinerate sewage sludge, medical
wastes, and pathological waste, they can also be used to destroy ODS (ICF 2009a).
Porous Thermal Reactor
Porous reactors are high-temperature systems with a porous layer that facilitates the decomposition of
ODS and other industrial waste gases. Destruction takes place in an oxidizing atmosphere with a
continuous supply of an auxiliary gas. Appropriate heat transfer is critical to the proper function of the
reactor. The solid structure and porous layer ensure that the heat is spread evenly and reduces the
volume of the unit. A commercial plant is operating in Germany (UNEP 2015).
Municipal Solid Waste Incineration
This process employs moving grates for the destruction of solid materials including foams containing
ODS. Waste is dumped into a refuse pit and then transferred mechanically to a bin that feeds the waste
in a controlled manner onto the moving grate which moves through the combustion zone. Combustion
air is drawn through the refuse pit and introduced into the combustion zone. ODS waste is fed into the
incinerator with other solid waste (TEAP 2002).
Non- I ncineration Tech noIog ies
Non-incineration technologies do not necessarily utilize very high temperatures to destroy ODS,
although elevated temperatures are used to assist the breakdown of the ODS. Although they reach
higher temperatures than incineration technologies, plasma technologies are considered to be non-
incineration technologies because they involve the thermo-chemical decomposition of organic material
in a limited oxygen environment.
22 The listing of cement kilns under incineration technologies in this section is not intended to imply that cement kilns are
defined under U.S. regulations as "incinerators."
58
-------
ODS Destruction in the United States and Abroad
1 February 2018
Plasma Technologies
Plasma technologies utilize plasma, which produces intense heat, to destroy ODS. A plasma arc is
created from the discharge of a large electric current between a separate cathode and anode or in a
magnetic field while an inert gas is present. ODS destruction occurs when the ODS is heated to a
gaseous state and passed through the plasma arc (4,700 -19,700 °C) and subsequently ionized (or
decomposed into its basic molecular structure). Plasma destruction units are generally designed to be
relatively small, compact, and transportable. They consume a large amount of energy in order to
generate the plasma, but tend to have very high destruction efficiencies and low gas emissions (TEAP
2002). Seven different types of plasma technologies are described below.
Air Plasma Arc
Air plasma arc technology destroys CFCs and HCFCs by injecting them into a reaction chamber filled with
air, liquefied petroleum gas, and water. The air is heated to about 1,300°C in a plasma generator, and
the CFCs and HCFCs are broken down into H2, H20, CO, C02, HCI, and HF. These resulting gases are
cooled by water injection once they leave the reaction chamber and are scrubbed in a spray tower. The
acids are washed out of the gases as calcium chloride and fluorspar by adding calcium hydroxide to the
mixture. The gas is washed a second time in a packed bed to ensure that all acids are removed. The gas
is released through a stack after passing through a wet electrostatic precipitator, the fluorspar is
removed as sludge in a settling tank, and the calcium chloride solution is either used for dust reduction
on gravel roads or is disposed (ICF 2009a).
An experimental air plasma destruction facility is in Sweden destroying CFC-11, CFC-12, and HCFC-22 at
a rate of about 300 kg/hour (ICF 2009a). This is the only known air plasma facility.
Argon Plasma Arc
Argon plasma arc technology uses the patented PLASCON™ torch to create a 10,000 °C plasma arc in the
presence of argon to destroy ODS. The ODS are almost instantaneously broken down through a heat-
degradation process called pyrolysis, during which the molecules are broken down into their constituent
atoms and ions. This causes the ODS to be converted into an ionized gas, which is then moved into a
reaction chamber or flight tube, located below the PLASCON™ torch, in order to be cooled to below 100
°C with water. The process is followed by rapid alkaline quenching that prevents the formation of dioxins
and furans. An alkaline scrubber located downstream of the quench is used to neutralize waste acid
formation. The final solid and liquid by-products of the process are halide salts and water, which can be
released into the municipal sewage system. The final gaseous by-products include C02, argon, and trace
amounts of other gases, which are released into the atmosphere.
In Australia, the Department of Administrative Services Centre for Environmental Management
(DASCEM), which currently manages the Australian National Halon Bank, uses argon plasma arc
technology to destroy both halons and CFCs. Other plasma arc facilities are located in Mexico and the
United States (TEAP 2002).
Nitrogen Plasma Arc
Similar to argon plasma arc technology, nitrogen plasma arc technology utilizes nitrogen plasma created
by a plasma torch to break down liquefied fluorocarbon gases into CO, HF, and HCI. The CO is then
combined with air to form C02, which along with the HCI and HF are absorbed by a calcium hydroxide
solution. There are five units known to be commercially destroying ODS in Japan. Because of their
compact size (9 m x 4.25 m), these units can be used as mobile destruction facilities (TEAP 2002).
59
-------
ODS Destruction in the United States and Abroad
1 February 2018
Inductively Coupled Radio Frequency (ICRF) Plasma
ICRF plasma technology uses 10,000 °C plasma created using an inductively coupled radio frequency
torch to destroy ODS. Gaseous ODS and steam are placed into the destruction unit through the plasma
torch, heated, and then moved into a reactor chamber where the gases are broken down. Inductively
coupled plasma devices use radio frequency to produce plasma therefore eliminating the need for
electrodes or the need for cooling. The gases are then cleaned with a caustic solution to remove the acid
gases (TEAP 2002).
An ICRF plant in Ichikawa City, Japan has operated commercially since 1995 (TEAP 2002). This is the only
ICRF plasma destruction facility known to be in operation in the world.
Microwave Plasma
Microwave plasma technology uses 5,700 °C plasma, which is created using argon and microwave
energy, to break down CFCs into HCI, HF, CO, and C02. There are two types of microwave plasma
gasifiers; the plasmatron based system, and the direct injection system. The plasmatron is a microwave
driven torch and the direct injection system is a process where microwaves are injected into a small area
within a reaaction chamber. The final byproducts of the destruction process that are released into the
atmosphere consist only of halide salts and C02, as the acid gases are removed by a scrubber and the CO
is combusted with air in order to convert it to C02 (TEAP 2002).
Steam Plasma Arc
Steam plasma arc technology injects ODS and high temperature steam into a 1,300 °C reactor. H2 and
CO are formed under the plasma plume and laterd oxidized to C02 and H20 through addition of small
amounts of air in a separate zone. The gas stream is then rapidly quenched to prevent any reformation
of dioxins and furans. The DRE was over 99.9999 percent when CFC-12 was applied (UNEP 2015). This
technology has not been approved by the Parties to the Montreal Protocol.
Portable Plasma Arc
The portable technology utilizes torch plasma technology to destroy ODS and eventually produce halide
salts and C02. The unit has been used to destroy ODS in Ghana and several countries in Latin America.
The unit takes the flue gases and bubbles them through a neutralization process, before dehydrating the
resulting solution. It has a capacity of 1-2 kg/hour of ODS (ASADA Undated).
Other Non-Incineration Technologies
Some non-incineration technologies are considered conversion technologies, because they chemically
react the ODS to make useful byproducts.
Superheated Steam Reactor
The superheated steam reactor destroys CFC, HCFCs, and HFCs in a reactor with walls that are
electrically heated to 850 - 1,000 °C. The fluorocarbons are first mixed with steam and air and
preheated to about 500°C before being placed in the reactor. The byproducts of the process, HF, HCI,
and C02, are quenched with a calcium hydroxide solution to neutralize the acid gases and minimize
dioxin and furan emissions. Because of their compact size, superheated steam reactors can be used as
mobile destruction facilities (TEAP 2002).
There are 11 known units in operation in Japan (TEAP 2002). It is not clear whether these units destroy
ODS commercially.
60
-------
ODS Destruction in the United States and Abroad
1 February 2018
Gas Phase Catalytic Dehalogenation
The gas phase catalytic dehalogenation process destroys CFCs at 400 °C, which requires less energy
consumption than incineration technologies. The process emits no dioxins or furans and very small
amounts of other pollutants (TEAP 2002). It is unknown whether this technology is currently in use for
commercial ODS destruction.
Chemical Reaction with Hb and CO2
This process operates at a temperature range of 300 - 1,000 °C and a pressure range of 1 - 30
atmospheres and converts ODS and HFCs to HF, HCI, CO, and H20. A catalyst is used to assist the
conversion of the organic halide to anhydrous hydrogen halide and carbon monoxide. The technology is
used by a company in the United States and is being supported by the Multilateral Fund for a China
demonstration project for HFC-23 conversion. The reaction technology separates and collects the
byproducts at a high purity and sells them to recoup operating costs (Midwest Refrigerants 2017).
Thermal Reaction with Methane
The reaction of methane and ODS occurs in a plug flow reactor at atmospheric pressure and high
temperature (up to 800 °C). In the case of halon destruction, the reaction occurs when the relatively
week CCIF2-Br bond is cleaved, producing two radicals that react with methane to form HBr, methyl
bromide, CHCIF2 and CCIF2. The reaction kinetics for this process have been studied, however it is
unknown whether the technology is currently in use for commercial ODS destruction (Tran 2000).
Conversion to Vinylidene Fluoride
Conversion of HFC-152a to vinylidene fluoride (or vinyl fluoride) is a commercial chemical production
process that is being used at chemical production plants in the United States. HFC-152a is either a
feedstock or a chemical intermediate in these production processes. A Chemours facility in Louisville,
Kentucky uses HFC-152a as a feedstock for vinyl fluoride production (Louisville 2016). Other commercial
processes have been developed to produce vinylidene fluoride from HFC-152a. The HFC-152a undergoes
a chlorination and dechlorination process to produce the vinylidene fluoride. The technology is being
used in the United States as a commercial process that uses HFC-152a as a feedstock to make either
vinyl fluoride or vinylidene fluoride. This technology has not been approved by the Parties to the
Montreal Protocol.
Catalytic Destruction
In this process fluorocarbons and hydrocarbons are destroyed at modest temperatures using a catalyst
to assist the conversion. Several commercial plants are operating in Sweden, Denmark, and the UK
(UNEP 2015). An appliance recycling plant with ODS destruction capabilities is operating the technology
in the United States (Sirkin 2016). This technology has not been approved by the Parties to the Montreal
Protocol, however it has been demonstrated to operate in accordance with the guidelines outlined by
TEAP for destruction technologies.
61
-------
ODS Destruction in the United States and Abroad 1 February 2018
Appendix D: Incinerability of HFCs
Thermal Stability Ranking System
U.S. EPA established a system for ranking the thermal stability of hazardous wastes for the purposes of
developing methods for testing the DRE of hazardous waste incinerators. Hazardous waste incinerators
in the U.S. are required to demonstrate the ability to destroy hazardous wastes (including chlorinated
and fluorinated compounds that are regulated as hazardous wastes) to a DRE of > 99.99 percent (40 CFR
266.104 Standards to Control Organic Emissions). In general, hazardous waste incinerator operators test
the incinerator using one or more principle organic hazardous constituent (POHCs) as surrogates for all
other hazardous waste compounds; once the incinerator demonstrates the ability to destroy the POHCs
that are tested to a DRE of > 99.99 percent, it is assumed that the incinerator also has the ability to
destroy any other compounds that are ranked lower on the U.S. EPA's thermal stability index. For
example, chlorobenzene is a Stability Class I compound ranked 20th on the incinerability scale, methyl
bromide is a Stability Class I compound ranked 31st - 33rd, and HCFC-123 is a Stability Class I compound
ranked 39th. If the incinerator is demonstrated to achieve a DRE of > 99.99 percent when tested using
chlorobenzene, it is assumed that the incinerator would also destroy tetrachloroethylene and methyl
bromide (lower ranked compounds) to at least a 99.99 percent DRE. Table 13 provides a summary of
thermal stability rankings from the U.S. EPA Incinerability Index (EPA, 1989), from Theoretical Estimation
of Incinerability ofHalons and HCFCs (Lamb et. al, 2008.), and from Incinerability of Halons and HCFCs:
Theoretical Calculations of DRE and Ozone-Depleting or Global-Warming Gases (Lamb et. al. 2010).
Table 13. Thermal Stability Ranking of Selected Compounds
Compound
Thermal Stability
Ranking
Source
Stability Class 1
SFs
Sulfur Hexafluoride
4
EPA 1989
CsHsCI
Chlorobenzene
20
EPA 1989
CHsCI
Methyl Chloride
30-31
EPA 1989
CHsBr
Methyl Bromide
31-33
Lamb et. al, 2010
Stability Class II
HCFC-123
2,2-Dichloro-l, 1,1-
trifluoroethane
39
Lamb et. al, 2008
Stability Class III
CFC-113
1,1,2-Trichloro-1,2,2-
trifluoroethane
85-88
EPA 1989
CFC-12
Dichlorodifluoromethane
85-88
Lamb et. al, 2010
CFC-11
Trichlorofluoromethane
89-91
Lamb et. al, 2010
Halon 1301
Bromotrifluoromethane
116
Lamb et. al, 2008
Halon 2402
1,2-Dibromotetrafluoroethane
131
Lamb et. al, 2008
HCFC-22
Chlorodifluoromethane
133
Lamb et. al, 2008
Halon 1211
Bromochlorodifluoromethane
143
Lamb et. al, 2008
Destruction Efficiency Determination, GHGRP Subpart L
U.S. EPA established procedures for fluorinated gas producers to report the destruction efficiency for
thermal oxidation destruction of fluorinated gases under Subpart L of the Greenhouse Gas Reporting
Rule (GHGRP) or the Mandatory Reporting of Greenhouse Gases Rule (MRR) based on the results of the
thermal destruction system performance tests that are based on EPA's thermal stability index (EPA
62
-------
ODS Destruction in the United States and Abroad
1 February 2018
2010b). EPA has determined that carbon tetrafluoride (CF4) is more thermally stable and therefore more
difficult to destroy than sulfur hexafluoride (SF6) which has a thermal stability ranking of 4 (only
benzene, cyanogen, and hydrogen cyanide are ranked higher). U.S. EPA therefore required under
Subpart L that a destruction efficiency determination must be developed specifically for CF4, SF6, and all
other fully saturated perfluorinated compounds (i.e., any fluorinated compound having no hydrogen
atoms, e.g., tetrafluoroethylene and hexafluoropropene) for the purposes of Subpart L reporting.
U.S. EPA also concluded that fluorinated compounds having hydrogen atoms (e.g., 1,2-difluoroethane
(HFC-152)) are not likely to be as thermally stable as CF4 and SF6, and therefore would not be as difficult
to destroy by thermal oxidation. This is because these compounds can be dissociated at the C-H and C-C
bonds that are not as strong as C-F and C-S bonds. U.S. EPA concluded that these other fluorinated
compounds are less difficult to destroy than the Stability Class I compounds (e.g., chlorobenzene and
methyl bromide) that are listed in the U.S. EPA's thermal stability index (see Table 13). Therefore, for
these other fluorinated GHGs, the destruction efficiency may be developed for the purposes of Subpart
L reporting using incinerator performance test data for any Stability Class I compound on the U.S. EPA's
Thermal Stability Rankings List (75 FR 74793; EPA 1989). Incinerators that have been tested using one or
more Stability Class I compounds as POHCs and that demonstrate a DRE of > 99.99 percent for the
Stability Class I POHCs tested are deemed capable of destroying fluorinated GHGs to at least a 99.99
percent DRE based on the results of the tests conducted for the Stability Class I POHCs.
Incinerability of Fluorinated Compounds
Tsang et al. (1998) assessed the thermal stability of fluorinated compounds (i.e., HFCs) under
combustion conditions based on chemical kinetic properties and computer simulations and provided
comparisons to chlorinated hydrocarbons (i.e., HCFC and halons). Tsang et al. (1998) concluded that
fluorinated compounds are generally more thermally stable than chlorinated compounds, but that
conditions achievable in incinerators are capable of destroying fluorinated compounds at high levels of
efficiency. Tsang et al. (1998) provided chemical kinetics calculations of the temperature required to
achieve 99.99 percent destruction in one second for fluorinated compounds including HFC-23, HFC-125,
and HFC-161. The modeled required temperatures for 99.99 percent destruction for these fluorinated
compounds are similar to modeled temperatures for 99.99 percent destruction for HCFCs and halons
modeled in Lamb et al. (2010), as shown in Table 14, and are similar to modeled Stability Class I and
Stability Class II index rankings for these compounds.
Table 14. Modeled Required Temperatures to Achieve 99.99 Percent DRE for Fluorinated Compounds
Compound
Time
Required
Temperature
Index Ranking
seconds
°K
°C
Tsang et al. (1998)
CFsH
Trifluoromethane
HFC-23
1
1,200
927
Stability Class II
C2HF5
Pentafluoroethane
HFC-125
1
1,137
864
Stability Class II
C2H5F
Fluoroethane
HFC-161
1
1,068
795
Stability Class III
Lamb et al. (2010)
C2HCI2F3
2,2-Dichloro-l,l, 1-
trifluoroethane
HCFC-123
2
1,182
909
39 (Class II)
CFsBr
Bromotrifluoromethane
Halon 1301
2
1,040
767
116 (Stability Class III)
CHF2CI
Chlorodifluoromethane
HCFC-22
2
978
705
133 (Stability Class III)
63
------- |