ODS Destruction in the United States and Abroad
April 2021
EPA 430-R-21-006
Prepared for the U.S. Environmental Protection Agency by ICF
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ODS Destruction in the United States and Abroad
April 2021
Table of Contents
Acronyms iii
Controlled substances under the Montreal Protocol 1
1. Introduction 3
2. Sources of ODS for Destruction 4
2.1. ODS-Containing Equipment 4
2.2. Bulk ODS 5
3. The Process of ODS Destruction: Best Management Practices 6
3.1. Recovery and Collection 6
3.2. Consolidation and Storage 7
3.3. Transportation 8
3.4. Destruction 8
4. ODS Destruction Technologies and Facilities in the United States and Worldwide 9
4.1. Montreal Protocol-Approved ODS Destruction Technologies 9
4.2. ODS Destruction Facilities in the United States 12
4.3. Capacity of U.S. Destruction Facilities 17
4.4. International ODS Destruction Facilities and Technologies 18
5. International Efforts to Destroy ODS 20
5.1. United States 21
5.1.1. Reported Amount and Type of ODS Destroyed 21
5.1.2. Reported ODS Imported for Destruction 22
5.2. European Union 23
5.2.1. Reported Amount and Type of ODS Destroyed 23
5.2.2. Reported ODS Imported for Destruction 24
5.3. Japan 25
5.3.1. Reported Amount and Type of ODS Destroyed 25
5.4. Destruction of ODS in Article 5 and Non-Article 5 Countries 26
6. Global ODS Recovery, Transportation, and Destruction Costs 28
6.1. ODS Recovery Costs from Products and Equipment 28
6.2. ODS Transportation Costs 29
6.3. ODS Destruction Costs 30
6.3.1. Concentrated Sources of ODS 30
6.3.2. Dilute Sources of ODS 30
7. Financing of ODS Destruction Projects 31
7.1. Producer Responsibility Programs and Taxes 31
7.2. ODS Destruction Offset Programs 32
7.2.1. Compliance Markets 32
7.2.2. Voluntary Markets 33
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7,2.3. Carbon Prices and Profitability 35
7.3. HFC-23 Destruction 37
7.4. MLF- and GEF-Funded Destruction Projects 37
8. Modeled Amounts of ODS Potentially Available for Destruction 38
8.1. ODS Recoverable from Equipment and Products 38
8.1.1. United States 39
8.1.2. European Union 40
8.1.3. Global 42
8.2. Availability of Stockpiles 42
8.2.1. CFCs and HCFCs in Refrigeration/AC Equipment 42
8.2.2. Halons in Fire Suppression Equipment 42
9. ODS Management Needs 43
lO.lmplications for Addressing HFC Disposal 45
10.1. Sources, Practices, Technologies, and Costs: Parallels to ODS 46
10.2. Current and Projected Quantities Available for Destruction 48
11.Reference s 50
12.Appendice s 62
Appendix A: Transboundary Movement of ODS 62
Appendix B: Resource Conservation and Recovery Act 63
Code F (Wastes from Non-Specific Sources) 64
Code U (Commercial Chemical Products) 64
Code K (Wastes from Specific Sources) 65
Code D (Characteristic Wastes) 65
The Mixture and Derived-From Rules 65
Appendix C: Description of ODS and/or HFC Destruction Technologies 67
Thermal Oxidation (Incineration) Technologies 67
Not Yet Approved by the Parties of the Montreal Protocol 68
Non-Incineration Technologies 69
Appendix D: Incinerability of HFCs 73
Thermal Stability Ranking System 73
Destruction Efficiency Determination, Greenhouse Gas Reporting Rule Subpart L 73
Incinerability of Fluorinated Compounds 74
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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
CNCo China Navigation Company
CSIRO Commonwealth Scientific and Industrial Research Organisation
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
EU ETS European Union Emission Trading System
FTOC Flexible and Rigid Foams Technical Options Committee
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 Halons Technical Options Committee
HWC Hazardous Waste Combustor
ICRF Inductively Coupled Radio Frequency
MCTOC Medical and Chemicals Technical Options Committee
MeBr Methyl Bromide
MLF Multilateral Fund
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MOP Meeting of the Parties
MRR Mandatory Reporting of Greenhouse Gases Rule
MT C02 Eq. Metric Tons Carbon Dioxide Equivalent
MMT C02 Eq. Million Metric Tons Carbon Dioxide Equivalent
MTOC Medical Technical Options Committee
ODP Ozone Depletion Potential
ODS Ozone-Depleting Substances
ODSTS ODS Tracking System
PCDD Polychlorinated Dibenzodioxin
PCDF Polychlorinated Dibenzofuran
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
RTOC Refrigeration, Air Conditioning and Heat Pumps Technical Options
Committee
SPREP Secretariat of the Pacific Regional Environment
TEAP Technology & Economic Assessment Panel
TFDT Task Force on Destruction Technologies
TRI Toxics Release Inventory
UL Underwriters Laboratories
UN United Nations
UNDP United Nations Development Programme
UNEP United Nations Environment Programme
UNIDO United Nations Industrial Development Organization
VCS Verified Carbon Standard (currently known as Verra)
WTE Waste to Energy
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Controlled substances under the Montreal Protocol
Annex A
CFC-11 (Trichlorofluoromethane, CFCI3)
CFC-12 (Dichlorodifluoromethane, CF2CI2)
CFC-113 (Trichlorotrifluoroethane, C2CI3F3)
CFC-114 (Dichlorotetrafluoroethane, C2CI2F4)
CFC-115 (Chloropentafluoroethane, C2CIF5)
Halon 1211 (Bromochlorodifluoromethane, CBrCIF2)
Halon 1301 (Bromotrifluoromethane, CBrF3)
Halon 2402 (Dibromotetrafluoroethane, C2Br2F4)
Annex B
CFC-13 (Chlorotrifluoromethane, CCIF3)
CFC-111 (Pentachlorofluoroethane, C2FCI5)
CFC-112 (Tetrachlorodifluoroethane, C2CI4F2)
CFC-211 (Heptachlorofluoropropane, C3CI7F)
CFC-212 (Hexachlorodifluoropropane, C3CI6F2)
CFC-213 (Pentachlorotrifluoropropane, C3CI5F3)
CFC-214 (Tetrachlorotetrafluoropropane, C3CI4F4)
CFC-215 (Trichloropentafluoropropane, C3CI3F5)
CFC-216 (Dichlorohexafluoropropane, C3CI2F6)
CFC-217 (Chloroheptafluoropropane, C3CIF7)
Carbon Tetrachloride (CCI4)
Methyl Chloroform (1,1,1-Trichloroethane, C2H3CI3)
Annex C
HCFC-21 (Dichlorofluoromethane, CHCI2F)a
HCFC-22 (Chlorodifluoromethane, CHCIF2)a
HCFC-31 (Chlorofluoromethane, CH2CIF)
HCFC-121 (Tetrachlorofluoroethane, C2HCI4F)
HCFC-122 (Trichlorodifluoroethane, C2HCI3F2)
HCFC-123 (Dichlorotrifluoroethane, C2HCI2F3)a
HCFC-124 (Chlorotetrafluoroethane, C2HCIF4)a
HCFC-131 (Trichlorofluoroethane, C2H2CI3F)
HCFC-132 (Dichlorodifluoroethane, C2H2CI2F2)
HCFC-133 (Chlorotrifluoroethane, C2H2CIF3)
HCFC-141 (Dichlorofluoroethane, C2H3CI2F)
HCFC-141b (1,1-Dichloro-l-fluoroethane, CCI2FCH3)a
HCFC-142 (Chlorodifluoroethane, C2H3F2CI)
HCFC-142b (l-Chloro-l,l-difluoroethane, CCIF2CH3)a
HCFC-151 (Chlorofluoroethane, C2H4CIF)
HCFC-221 (Hexachlorofluoropropane, C3HCI6F)
HCFC-222 (Pentachlorodifluoropropane, C3HCI5F2)
HCFC-223 (Tetrachlorotrifluoropropane, C3HCI4F3)
HCFC-224 (Trichlorotetrafluoropropane, C3HCI3F4)
HCFC-225 (Dichloropentafluoropropane, C3HCI2F5)
HCFC-225ca (3,3-Dichloro-l,l,l,2,2-pentafluoropropane, CHCI2CF2CF3)a
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HCFC-225cb (l,3-Dichloro-l,l,2,2,3-pentafluoropropane, CHCIFCF2CCIF2)a
HCFC-226 (Chlorohexafluoropropane, C3HCIF6)
HCFC-231 (Pentachlorofluoropropane, C3H2CI5F)
HCFC-232 (Tetrachlorodifluoropropane, C3H2CI4F2)
HCFC-233 (Trichlorotrifluoropropane, C3H2CI3F3)
HCFC-234 (Dichlorotetrafluoropropane, C3H2CI2F4)
HCFC-235 (Chloropentafluoropropane, C3H2CIF5)
HCFC-241 (Tetrachlorofluoropropane, C3H3CI4F)
HCFC-242 (Trichlorodifluoropropane, C3H3CI3F2)
HCFC-243 (Dichlorotrifluoropropane, C3H3CI2F3)
HCFC-244 (Chlorotetrafluoropropane, C3H3CIF4)
HCFC-251 (Trichlorofluoropropane, C3H4CI3F)
HCFC-252 (Dichlorodifluoropropane, C3H4CI2F2)
HCFC-253 (Chlorotrifluoropropane, C3H4CIF3)
HCFC-261 (Dichlorofluoropropane, C3H5CI2F)
HCFC-262 (Chlorodifluoropropane, C3H5CIF2)
HCFC-271 (Chlorofluoropropane, C3H6CIF)
HBFCs (Hydrobromofluorocarbons)
BCM (Bromochloromethane, CH2BrCI)
Annex E
Methyl Bromide (MeBr, CH3Br)
Annex F
HFC-23 (Trifluoromethane, CHF3)
HFC-32 (Difluoromethane, CH2F2)
HFC-41 (Fluoromethane, CH3F)
HFC-125 (Pentafluoroethane, C2HF5)
HFC-134 (1,1,2,2-Tetrafluoroethane, CHF2CHF2)
HFC-134a (1,1,1,2-Tetrafluoroethane, CF3CH2F)
HFC-143 (1,1,2-Trifluoroethane, CHF2CH2F)
HFC-143a (1,1,1-Trifluoroethane, CF3CH3)
HFC-152 (1,2-Difluoroethane, CH2FCH2F)
HFC-152a (1,1-Difluoroethane, CHF2CH3)
HFC-227ea (1,1,1,2,3,3,3-Heptafluoropropane, C3HF7)
HFC-236cb (1,1,1,2,2,3-Hexafluoropropane, CF3CF2CH2F)
HFC-236ea (1,1,1,2,3,3-Hexafluoropropane, CF3CHFCHF2)
HFC-236fa (1,1,1,3,3,3-Hexafluoropropane, CF3CH2CF3)
HFC-245ca (1,1,2,2,3-Pentafluoropropane, CHF2CF2CH2F)
HFC-245fa (1,1,1,3,3-Pentafluoropropane, CF3CH2CHF2)
HFC-365mfc (1,1,1,3,3-Pentafluorobutane, CF3CH2CF2CH3)
HFC-43-10mee (1,1,1,2,2,3,4,5,5,5-Decafluoropentane, CF3CF2CHFCHFCF3)
a Identifies the most commercially viable substance as prescribed in the Montreal Protocol.
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1. Introduction
The Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), adopted 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, Parties commit to phasing out specified ODS -
chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, carbon tetrachloride (CCI4), methyl
chloroform, methyl bromide (MeBr), bromochloromethane, and hydrobromofluorocarbons (HBFCs)-thereby
reducing their abundance in the atmosphere and protecting the Earth's fragile ozone layer. One-hundred-
ninety-seven United Nations (UN) Member States have ratified the Montreal Protocol and its first four
amendments. On October 15, 2016, the Parties to the Montreal Protocol agreed on the Kigali Amendment to
phase down high global warming potential (GWP) hydrofluorocarbons (HFCs), and, as of March 31, 2021, over
115 Parties have ratified, accepted, or approved the Amendment.
The global ODS phaseout is underway; however, there is a large amount of ODS in equipment and products
such as refrigerators and air conditioners (as both refrigerant and foam blowing agent), foam contained in
buildings, and fire suppression systems and fire extinguishers, as well as in stockpiles held by countries and
industrial and commercial users. Collectively, these sources are referred to as ODS banks. Unless properly
managed, ODS from these banks could be released to the atmosphere over time through equipment leaks and
other intended or unintended releases. The global ODS phaseout of production and consumption does not
control emissions at the end of the useful life of these products and equipment, but many countries including
the United States have voluntary or regulatory requirements to reduce emissions of ODS. After ODS are
recovered and collected, destruction is one of several options. Other options include recycling or reclamation
to promote the reuse of these substances. When choosing whether to recycle, reclaim, or destroy ODS,
factors to consider include costs and demand for reclaimed or recycled ODS (e.g., for servicing existing
equipment).
This report provides information concerning the sources of ODS for destruction in the United States and
globally and the technologies, best practices, and challenges for the safe and environmentally sound
collection, recovery, transport, and destruction of these substances. In addition, this report provides
information on potential costs for the ODS waste management process and discusses 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 HFCs are discussed.
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2. Sources of ODS for Destruction
ODS that are potentially available 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.
Because CFCs and halons have been globally phased out
since 2010,1 production and consumption of some
HCFCs2 has now been phased out by non-Article 5, and
ODS are required for servicing legacy equipment,
recovered 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 as of 2020 is no longer
produced in the United States, will likely have a resale
value because it will still be required for servicing
existing equipment. As another example, production of
halon 1301 was phased out globally for fire suppression
applications in 2010; however, unless too contaminated
for use, recycled halon 1301 continues to be used in
important applications such as military legacy equipment, commercial aircraft, and oil and gas facilities.
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 collection, 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 insulation foams may be difficult and
expensive. Similarly, although halon 1211 portable fire extinguishers are a seemingly good source for
1 Parties are required, under the Montreal Protocol, to reduce their consumption and production by 100 % (with possible essential use
exemptions) of Annex C Group II and III substances by 1996, Group E substance by 2002, and of Annex A and Annex B substances by
2010.
2 Non-Article 5 countries are required, under the Montreal Protocol, to decrease HCFC consumption and production to at least 99.5 %
below baseline levels in 2020.
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Box 1. Key Barriers to Recovery and Destruction of
ODS
While there may be 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 equipment, training, 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.
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destruction in many cases given the wide use of other alternatives, 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).3
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 suppression sector,
which primarily uses halons. Halons are infrequently available for destruction, as they are often banked and
reused in fire suppression 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 household 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.
ODS-containing foam may also be recovered, particularly from refrigerated appliances; however, this recovery
effort may be more expensive and could require 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 expensive than recovery of refrigerants, many countries have continued to promote foam
recovery, recognizing the important benefits of avoided ODS emissions from foams to the recovery of the
ozone layer. For example, the U.S. Environmental Protection Agency's (EPA) Responsible Appliance Disposal
(RAD) Program is a voluntary partnership program to promote proper removal, recovery, and destruction of
ODS in refrigerated appliances, including ODS-containing foam. Estimated RAD benefits from proper disposal
of 1,000 old refrigerators include 1,920 metric tons carbon dioxide equivalent (MT C02 Eq.) avoided foam
emissions (EPA 2020a). In 2019, the RAD program partners collected more than 600,000 household
refrigeration and air conditioning appliances and achieved a reduction of 2.3 million MT C02 Eq. emissions
(EPA 2020e). 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, European Commission
2019).
2.2. Bulk ODS
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 suppression 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 containers
in locations where temperature and moisture are not controlled (e.g., warehouses, fields). To prevent bulked
3 Some countries have established national programs to encourage halon recovery, and generally programs that require 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.
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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.
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.
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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 Air-
Conditioning, Heating and Refrigeration Institute (AHRI)
Standard 700, which has purity requirements specific to the
reclaimed refrigerant (e.g., 99.5 wt% for R-ll) as well as
other requirements for water content, particulates, turbidity,
and acidity (AHRI 2017). 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).
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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., AHRI,
Underwriters Laboratories (UL), or Intertek).
3.2. Consolidation and Storage
After ODS has been recovered and collected from household 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 are
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 are 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 have been aggregated to constitute a shipment, they are 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 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).
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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
ODS should be destroyed at an approved facility which typically means the collected ODS are transported. In
most cases, certified transporters ship consolidated ODS in large containers to the destruction facility. When
ODS reaches the destruction facility,4 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.
4 In some cases, (e.g., a practice in Germany) ODS recovered from household 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.
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ODS Destruction in the United States and Abroad
April 2021
Once the contents are confirmed, the ODS may be transferred to a holding tank and fed into the destruction
unit;5 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)6 of 99.99 percent for concentrated sources of ODS and 95
percent for dilute sources of ODS (i.e., foams) is recommended by the Montreal Protocol's 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.
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 30th Meeting of the Parties (MOP) in November 2018, where Parties agreed, through Decision XXX/6, to
further update the list of approved destruction technologies in Previous Decision (i.e., V/26/ VI1/35, and
XIV/6). This section also presents 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 (e.g., Decision XV/9, Decision XXIII/12, and Decision
XXIX/4) that promote the exchange of information on the best technologies for the destruction of ODS.
Recently, at the 30th MOP in November 2018, the Parties agreed, through Decision XXX/6, to further update
5 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).
6 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.
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ODS Destruction in the United States and Abroad
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the list of approved destruction technologies (UNEP 2018).7 For the United States, in 2020 domestic
regulations (i.e., 40 CFR 82.3, 82.104, and 82.270) were updated to expand the list of destruction technologies
to be consistent with the Montreal Protocol.
While not included in the Montreal Protocol decisions, there are additional criteria discussed in the 2002 TEAP
report to evaluate destruction technologies that may be considered by countries for their domestic
requirements. These include specifications for:
1.1.1.Destruction and Removal Efficiency (DRE);
1.1.2.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
1.1.3.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-ITEQ/m3)b
0.5
0.2
HCI/Cb (mg/m3)
100
100
HF (mg/m3)
5
5
HBr/Br2(mg/m3)
5
5
Total Suspended Particles (mg/m3)
50
50
CO (mg/m3)
100
100
Source: TEAP (2018a).
a Emission limits are expressed as mass per dry cubic meter of exhaust gas at normal
conditions (i.e., 0°C and 101.3 kPa) corrected to 11 percent 02.
b ITEQ refers to the international toxic equivalency used for PCDDs and PCDFs.
ODS destruction technologies can be grouped into three broad categories: Thermal Oxidation (Incineration);
Plasma; and Conversion (or Non-incineration) technologies. Within these three categories, 16 technologies
were approved for the destruction of concentrated sources of CFCs, HCFCs, methyl chloroform, CCI4, and
methyl bromide. 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 II of the Report
of the 30th MOP, as well as nine non-approved technologies that are described in the 2018 reports from the
2018 Task Force on Destruction Technologies (TFDT), a subsidiary body established by TEAP, as being
evaluated and potentially approved by the Parties in the future. Most, if not all, of these technologies are
known to be used for ODS destruction, either commercially or in demonstrations, in the United States and/or
abroad (TEAP 2018a). All technologies are described further in Appendix C.
7 Decision XXX/6 can be accessed at: https://ozone.unep.ore/treaties/montreal-protocol/meetines/thirtieth-meetine-
parties/decisions/decision-xxx6-destruction-technoloeies-controlled-substances?a=treaties/montreal-protocol/meetines/thirtieth-
meetine-parties/decisions/decision-xxx6-destruction# ftnrefl
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ODS Destruction in the United States and Abroad April 2021
Table 2. Approval Status of Available Destruction Technologies
Applicability3 and Required Destruction and Removal Efficiency (DRE)b
Concentrated ODSc
Dilute ODSd
Technology
CFCs, HCFCs, CCI4,
methyl chloroform®
(99.99%)
Halonsf (99.99%)
Methyl Bromide®
(99.99%)
Foam (95%)
Thermal Oxidation (Incineration) Technologies
Cement Kilns
Approved
Not Approved
Not Determined
Not Applicable
Gaseous/Fume Oxidation
Approved
Not Determined
Not Determined
Not Applicable
Liquid Injection Incineration
Approved
Approved
Not Determined
Not Applicable
Municipal Solid Waste Incineration
Not Applicable
Not Applicable
Not Applicable
Approved
Porous Thermal Reactor
Approved
Not Determined
Not Determined
Not Applicable
Reactor Cracking
Approved
Not Approved
Not Determined
Not Applicable
Rotary Kiln Incineration
Approved
Approved
Not Determined
Approved
Thermal Decay of Methyl Bromide
Not Applicable
Not Applicable
Approved
Not Applicable
Electric Heater
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Fixed Hearth Incinerator
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Furnaces Dedicated to
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Manufacturing
Plasma Technologies
Argon Plasma Arc
Approved
Approved
Not Determined
Not Applicable
Inductively Coupled Radio
Approved
Approved
Not Determined
Not Applicable
Frequency Plasma
Microwave Plasma
Approved
Not Determined
Not Determined
Not Applicable
Nitrogen Plasma Arc
Approved
Not Determined
Not Determined
Not Applicable
Portable Plasma Arc
Approved
Not Determined
Not Determined
Not Applicable
Steam Plasma Arc
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Air Plasma Arc
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Alternating Current Plasma
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
CO2 Plasma
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Conversion (Non-Incineration) Technologies
Chemical Reaction with H2 and C02
Approved
Approved
Not Determined
Not Applicable
Gas Phase Catalytic De-
Approved
Not Determined
Not Determined
Not Applicable
halogenation
Superheated Steam Reactor
Approved
Not Determined
Not Determined
Not Applicable
Thermal Reaction with Methane
Approved
Approved
Not Determined
Not Applicable
Catalytic Destruction
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Solid Alkali Reaction
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Sources: UNEP (2011), UNEP (2015b), HTOC (2018a), TEAP 2018a, and UNEP (2018).
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 fully reviewed by the
Parties to the Montreal Protocol.
b 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.
c Concentrated sources of ODS refer to virgin, recovered, and reclaimed ODS.
d Dilute sources of ODS refer to ODS contained in a matrix of a solid (e.g., foam).
e Under the Montreal Protocol, these substances are listed in Annex A, Group I; Annex B; and Annex C, Group I.
'Under the Montreal Protocol, these substances are listed in Annex A, Group II.
g Under the Montreal Protocol, this substance is listed in Annex E, Group I.
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ODS Destruction in the United States and Abroad
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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).
Box 3. Other ODS Destruction Technologies
In addition to the ODS destruction technologies
described inTable 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.
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.8
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.9 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 United Nations Environment
Programme (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.
Based on data submitted to TRI from 2010 to 2019, over 70 facilities that destroyed ODS hazardous waste
were identified.10 Many of these facilities are chemical manufacturing plants that destroy ODS generated on-
site or used on-site in a chemical production process.11 The ODSTS was referenced to help identify whether
companies were destroying ODS commercially. While there are a significant number of non-commercial, non-
8 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.
9 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.
10 Facilities that reported under the TRI categories "treatment" and "energy recovery" were assumed to destroy ODS.
11 These facilities generally use fume/vapor incinerators or other types of air emissions control devices to destroy ODS.
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ODS Destruction in the United States and Abroad
April 2021
byproduct destruction facilities in the United States that have destroyed ODS-containing wastes, there are 19
companies that are thought to have destroyed ODS, either received commercially or as ODS-containing waste-
derived fuel, in 26 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 2010-2019.
Table 3. Commercial Destruction Facilities and Technologies in Use in the United States
Facility3
Location
Technology in Useb
ODS Processed in 2010-2019
A-Gas US Inc.
Bowling Green,
OH
Plasma Arc
CFC-11, CFC-12, CFC-113, Halon
1301, Halon 1211, HCFC-22
Ash Grove Cement
Foreman, AR
NA
Methyl Chloroform
Buzzi Unicem USA-
Cape Girardeau
Cape Girardeau,
MO
NA
CCI4
Buzzi Unicem USA-
Greencastle Plant
Greencastle, IN
NA
Methyl Chloroform
Chemical Waste
Management Inc.
Kettleman City,
CA
NA
Methyl Chloroform
Chemical Waste
Management of the
Northwest Inc.
Arlington, OR
NA
CFC-11, CFC-113, CCU, Methyl
Chloroform
Chill-Tek, Inc.
Las Vegas, NV
Refrigerant Destruction
System (RDS©)cd
CFC-11, CFC-126
Clean Harbors
Aragonite LLC
Aragonite, UT
Rotary Kiln with Liquid
Injection Unit Afterburner
CFC-11, CCU, Methyl Chloroform,
HCFC-253
Clean Harbors Deer
Park LLC
La Porte, TX
Gas/Fume Oxidation (2 units)
CFC-11, CFC-12, CFC-13, CFC-113,
CCU, MeBr, Methyl Chloroform,
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, CFC-12, CFC-114, CCU,
HCFC-22, HCFC-142b, HCFC-253,
Methyl Chloroform
Clean Harbors
Environmental
Services Inc.
Kimball, NE
Fluidized Bed Incinerator
CFC-11, CCU, Methyl Chloroform
Continental Cement
Co LLC
Hannibal, MO
NA
CFC-11, CFC-113, CCU, Methyl
Chloroform
Eco-Services
Operations
Baton Rouge, LA
Liquid Injection Incineration
(2 units)
CCU
Giant Cement Co.
Harleyville, SC
NA
CCU
Heritage Thermal
Services
East Liverpool,
OH
Rotary Kiln Incineration
CFC-11, CFC-12, CFC-113, CFC-
114, CCU, MeBr, Methyl
Chloroform
Holcim (US) Inc Holly
Hill Plant
Holly Hill, SC
NA
Methyl Chloroform
Keystone Cement Co.
Bath, PA
NA
Methyl Chloroform
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ODS Destruction in the United States and Abroad April 2021
Table 3. Commercial Destruction Facilities and Technologies in Use in the United States
Facility3
Location
Technology in Useb
ODS Processed in 2010-2019
LaFarge Midwest Inc.
(Including Systech
Environmental)
Fredonia, KS
NA
CCI4
Lehigh Cement Co.
Logansport, IN
NA
Methyl Chloroform
Norlite LLC
Cohoes, NY
NA
CFC-113, CCU, Methyl
Chloroform
Recleim
Graniteville, SC
Catalytic Destruction'
CFC-11, CFC-12, HCFC-22, HCFC-
141bg
Ross Incineration
Services Inc.
Grafton, OH
Rotary Kiln with Liquid
Injection Unit
CCU, Methyl Chloroform
Safety-Kleen Systems
Inc
Smithfield, KY
NA
Methyl Chloroform
Veolia ES Technical
Solutions LLC
Sauget, IL
Fixed Hearth Incineration
CFC-12, CFC-113, CCU
Veolia ES Technical
Solutions LLC Port
Arthur Facility
Port Arthur, TX
Fixed Hearth Incineration
CFC-11, CFC-12, CFC-113, CCU,
HCFC-21, HCFC-22, HCFC-123,
HCFC-142b, Methyl Chloroform
Wayne Disposal Inc.
Belleville, Ml
NA
CFC-11
Sources: EPA (2020d), EPA (2018c), and ICF (2009a).
NA = Not available.
a Facility names listed are from the latest TRI report; however, they may vary throughout report years.
bTechnologies that are not present in the list of Montreal Protocol approved destruction processes are described in Appendix C.
c Chill-Tek, Inc. (2020a).
d The RDS© system used by Chill-Tek, Inc. destroys ODS through incineration (Chill-Tek, Inc. 2020b).
e Chill-Tek, Inc. began destroying "ODS and other mixed HCFC and HFC refrigerant[s]" that cannot be reclaimed in 2015 (Chill-Tek,
Inc. 2020b). Chill-Tek, Inc. primarily destroys CFC-11 and CFC-12 (Chill-Tek, Inc. 2020b).
f Recleim is a de-manufacturing company that receives shipments of old appliances (refrigerators, freezers, dehumidifiers, and AC
units) and processes them in a plant that employs a combination of physical destruction technologies and catalytic destruction in
a closed loop system. This system avoids the leakage to the environment that can occur during de-manufacturing of appliances
and shipment of ODS (Sirkin 2016).
g 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 report
on-site ODS destruction from 2010 to 2019 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.
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ODS Destruction in the United States and Abroad
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Table 4. Facilities that Destroy Byproduct ODS or Utilize Raw Material ODS in the United States
(Non- Commercial)
Facility3
Location
Technology in Useb
ODS Processed in 2010-
2019
3M Cottage Grove Center
Cottage Grove, MN
NA
HCFC-142b
Arkema Inc.
Calvert City, KY
Liquid Injection Incineration
HCFC-22, HCFC-124,
HCFC-132b, HCFC-133a,
HCFC-141b, HCFC-142b,
Methyl Chloroform
Axiall LLC
Plaquemine, LA
Fume/Vapor
CCU, Methyl Chloroform
BASF Corp.
Geismar, LA
NA
CCU
BASF Corp. - Hannibal Site
Palmyra, MO
NA
MeBr
BAYER Cropscience
Kansas City, MO
Fume/Vapor
MeBr
Blue Cube Operations LLC -
Plaquemine Site
Plaquemine, LA
NA
CCU, MeBr
BP AMOCO Chemicals
Decatur, AL
Fume/Vapor
MeBr
BP Chemical Co. - Cooper River
Plant
Wando, SC
Other Incineration/Thermal
treatment
MeBr
Calgon Carbon Corp
Catlettsburg, KY
NA
CCU
Chemours Belle Plant
Belle, WV
Fume/Vapor
CCU
Chemours Co.
Gregory, TX
NA
CFC-113, CFC-114, CFC-
115, HCFC-124, CCU
Chemours El Dorado
El Dorado, AR
NA
CCU
Chemours Washington Works
Washington, WV
Other Incineration/Thermal
Treatment
CFC-114, HCFC-22,
HCFC-124, HCFC-124a
Daikin America Inc.
Decatur, AL
NA
HCFC-22, HCFC-124,
HCFC-124a
DAK Americas LLC - Columbia
Site
Gaston, SC
NA
MeBr
DDP Specialty Electronic
Materials US Inc. - Plaquemine
Met
Plaquemine, LA
NA
CCU
Dover Chemical Corp
Dover, OH
NA
CCU
Dow Agrosciences LLC
Pittsburg, CA
Liquid Injection Incineration
CCU
Dow Chemical Co. Freeport
Facility
Freeport, TX
Rotary Kiln with Liquid
Injection Unit
CFC-12, CCU, MeBr,
Methyl Chloroform,
HCFC-22
Dow Chemical Co. Louisiana
Plaquemine, LA
Other Rotary Kiln
CCU, MeBr
Operations
Rotary Kiln with Liquid
Injection Unit
Other Incineration/Thermal
Treatment
DuPont Sabine River Works
Orange, TX
Rotary Kiln with Liquid
Injection Unit
CCU
Eagle US 2 LLC
Westlake, LA
Liquid Injection Incineration
CCU, Methyl Chloroform
Fume/Vapor
Eastman Chemical Co. South
Carolina Operations
Gaston, SC
Other Incineration/Thermal
Treatment
MeBr
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ODS Destruction in the United States and Abroad
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Table 4. Facilities that Destroy Byproduct ODS or Utilize Raw Material ODS in the United States
(Non- Commercial)
Facility3
Location
Technology in Useb
ODS Processed in 2010-
2019
Eastman Chemical Co.
Tennessee Operations
Kingsport, TN
Rotary Kiln with Liquid
Injection Unit
MeBr
Other Incineration/Thermal
Treatment
Evoqua Water Technologies LLC
Parker, AZ
NA
CCI4
Evoqua Water Technologies
Darlington Facility
Darlington, PA
NA
CFC-11, CCU, Methyl
Chloroform
Flint Hills Resources Joliet LLC
Channahon, IL
Fume/Vapor
MeBr
Formosa Plastics Corp. Louisiana
Baton Rouge, LA
Fume/Vapor
CCU, Methyl Chloroform
Formosa Plastics Corp. Texas
Point Comfort, TX
NA
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-
114, CFC-115, HCFC-22,
HCFC-124, HCFC-124a,
HCFC-133a
Honeywell International Inc.
Baton Rouge Plant
Baton Rouge, LA
NA
HCFC-22
Indorama Ventures Xylenes and
PTA LLC
Decatur, AL
NA
MeBr
Ineos Joliet LLC
Channahon, IL
NA
MeBr
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
CCU
Liquid Injection Incineration
Occidental Chemical Holding
Corp. - Geismar Plant
Geismar, LA
Liquid Injection Incineration
CCU
Olin Blue Cube FreeportTX
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, HCFC-142b
Spruance Plant
Richmond, VA
NA
CFC-11
Syngenta Crop Protection LLC
Saint Gabriel Facility
Saint Gabriel, LA
Gas/Fume Oxidation
CCU
US Magnesium LLC
Grantsville, UT
NA
CCU
Velsicol Chemical LLC
Memphis, TN
Liquid Injection Incineration
CCU
16
-------
ODS Destruction in the United States and Abroad
April 2021
Table 4. Facilities that Destroy Byproduct ODS or Utilize Raw Material ODS in the United States
(Non- Commercial)
Facility3
Location
Technology in Useb
ODS Processed in 2010-
2019
Westlake Lake Charles North
Westlake, LA
NA
ecu
Westlake Vinyls Co.
Geismar, LA
Fume/Vapor
ecu
Westlake Vinyls Inc.
Calvert City, KY
Other Incineration/Thermal
Treatment
ecu
Source: EPA(2020d).
NA = Not Available.
a Facility names listed are from the latest TRI report; however, they may vary throughout report years (e.g., Dow/DuPont Chemical
Co. to Dow Chemical Co.).
b 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 83 percent of the facilities in Table 4 reported destruction of CCI4 and/or methyl bromide to
the TRI between 2010 and 2019. Additionally, CFCs and HCFCs used as feedstocks to produce HFCs,
fluoropolymers, and other ODS may generate de minimis amounts of ODS containing waste which may be
subject to reporting under TRI in that the waste stream (containing trace quantities of ODS) may be required
to be 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 2017, according to EPA's National Biennial RCRA Hazardous Waste Report, 3,307,000 MT of hazardous
wastes were destroyed in the United States (EPA
2018b),12 compared to approximately 2,581 MT of ODS
destroyed in that year. In 2017, ODS destruction volumes
were less than 0.1% of hazardous waste destruction and
as such, there is no expected need for additional facilities
to meet ODS destruction demand. However, 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.
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
12 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).
17
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.
-------
ODS Destruction in the United States and Abroad
April 2021
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
In 2008, about 155 destruction facilities were known to be in operation in 28 countries around the world (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.
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.
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.13 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 (1)
Cement Kiln (1)
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. China
5
Plasma technology (1)
Rotary Kiln (3)
Local hazardous waste facility (1)
NA
Rotary kiln: $8-
13/kga
9. Colombia
1
Rotary Kiln
NA
High temperature
incineration: $5-
6/kga
10. Cuba
1
Cement Kiln
NA
NA
13 Estimated costs here and throughout the report have not been adjusted to account for inflation because the costs are typical
and expected to shift as the market fluctuates and operational costs change.
18
-------
ODS Destruction in the United States and Abroad April 2021
Table 5. Commercial Destruction Facilities and Technologies around the World
Country
Number of
Known ODS
Destruction
Facilities in
Operation
Known Technologies
Utilized
ODS Destruction
Capacity
Typical
Destruction Costs
(US$)
11. Czech
Republic
1
Rotary Kiln
40 MT/year
NA
12. Denmark
4
Catalytic Cracking
NA
NA
13. Estonia
1
NA
NA
NA
14. Finland
1
Rotary Kiln
545 MT/year
NA
15. France
2
NA
NA
NA
16. Germany
7
Hazardous Waste Incinerator
Reactor Cracking
Porous Reactor
1,600 MT/yearb
(Reactor Cracking)
NA
17. Hungary
5
Rotary Kiln
Liquid Injection Incineration
75 MT/yearc (Rotary
Kiln)
13 MT/year (Liquid
Injection
Incineration)
NA
18. Indonesia
1
Cement kiln
600 MT/year
NA
19. Italy
12
NA
NA
NA
20. 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
21. Mexico
2
Plasma Arc
Cement Kiln
NA
Plasma Arc:
$8/kga
Cement Kiln:
$6/kga
22. Netherlands
6
NA
NA
NA
23. Nigeria
1
Rotary Kiln
NA
$30/kga
24. Poland
1
NA
NA
NA
25. Slovakia
1
NA
NA
NA
26. Spain
1
NA
NA
NA
27. Sweden
4
Air Plasma, among others
100 MT/year
NA
28. Switzerland
4 or more
Rotary Kiln, among others
910 MT/yearb
(Rotary Kiln)
> 320 MT/year
(others)
NA
19
-------
ODS Destruction in the United States and Abroad April 2021
Table 5. Commercial Destruction Facilities and Technologies around the World
Country
Number of
Known ODS
Destruction
Facilities in
Operation
Known Technologies
Utilized
ODS Destruction
Capacity
Typical
Destruction Costs
(US$)
29. United
Kingdom
2
High-Temperature Incineration
NA
NA
30. 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
31. Venezuela
2 or more
NA
NA
NA
Sources: ICF (2010c), Alves (2014), UNEP (2015b), Government of Australia (2020), and MLF (2018b).
NA= Not available.
a Destruction cost calculated based on actual ODS destroyed and not destruction capacity (MLF 2018b).
b Capacity is not specific to ODS; value shown refers to capacity for all hazardous wastes and/or other types of wastes.
c Number represents approximate ODS destruction capacity based on known overall plant capacity and typical ODS feed rates for
rotary kilns.
5. International Efforts to Destroy ODS
Twelve Article 5 parties and twenty-two non-Article 5 parties reported an estimated 57,800 MT of ODS
destruction14 to UNEP between 2009 and 2019 (UNEP 2020). ODS destruction in Article 5 parties (over 7,200
MT of ODS from 2009 to 2019) is significantly lower than in non-Article 5 parties (over 50,500 MT of ODS from
2009 to 2019). In 2009, Article 5 parties reported total annual destruction of approximately 5,800 MT, more
than 12 times the amount reported in other years between 2009 and 2019. The larger destruction in 2009 is
primarily a result of an increase in CFC destruction in Romania, which accounted for approximately 99% of all
ODS destruction by A5 countries in 2009. Non-Article 5 parties reported total annual destruction volumes
ranging from approximately 5,000 MT in 2009 to more than 8,000 MT in 2019. The large destruction volume in
2019, is primarily the result of the destruction of approximately 4,000 MT of CCI4 by France, twice as much as
in previous years, and made up almost half of all ODS destroyed in non-Article 5 countries in that year. Figure
1 shows global ODS destruction from 2009 to 2019.
14 ODS destruction estimates determined based on negative ODS production, a detailed description of the methodology used to
calculate the quantity of ODS destroyed is explained in detail in Section 5.4 below.
20
-------
ODS Destruction in the United States and Abroad
April 2021
Figure 1. Estimated Global ODS Destruction (MT)
12,000
1-
10,000
c
o
4—»
8,000
+->
lO
0)
6,000
Q
"O
in
2,000
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
A5 NA5 Total ODS
Source: UNEP (2020).
The remainder of 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 States
Under Title 40, Part 82 of the Code of Federal Regulations (CFR), the U.S. EPA 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. The ODSTS data are
evaluated, aggregated, and are included as part of the United States' annual reporting consistent with Article
7 of the Montreal Protocol.
In addition, under Title 40, Part 372 of the CFR, the U.S. EPA 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 ODS destroyed falls under the TRI categories of
"energy recovery," which can include combustion of chemicals in an industrial furnace or boiler, and
"treatment" which includes methods such as incineration and chemical oxidation (EPA 2018a). These methods
result in varying degrees of destruction of the chemicals.
5.1.1. Reported Amount and Type of ODS Destroyed
As shown in Figure 2 destruction of ODS in the United States has decreased from 2010 to 2018 by over 40
percent, with the greatest reduction in the quantity of Class I ODS15 destroyed. Class I ODS destruction has
decreased by 45 percent in this period, from a total of approximately 3,690 MT in 2010 to approximately
2,030 MT in 2018. Class II ODS16 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.
15 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).
16 Per 40 CFR 82, Class II chemicals include chemical listed under Montreal Protocol Annex C Group I (HCFCs).
21
-------
ODS Destruction in the United States and Abroad April 2021
Figure 2. U.S. Destruction of Class I and Class II ODS (2010-2018)"
"O
-
O
to
Q
+-1
c
=J
o
E
<
2010 2011 2012 2013 2014 2015
¦ Class II ¦ CFCs BOther Class I
2016
2017 2018
Source: EPA (2019).
a "Other Class \" includes CCU.
5.1.2. Reported ODS Imported for Destruction
ODS may be imported for destruction as a result of equipment decommissioning, unwanted stockpiles, or
mixed substances. For instance, many U.S. companies assist other countries in the decommissioning of ODS-
containing equipment that is being phased out. Once the equipment has been decommissioned and the ODS
recovered, companies might export the ODS to the United States for destruction, especially if the country
where the ODS originated does not have destruction capabilities or wants to earn offset credits on the
voluntary carbon exchanges, such as Verra (formerly the Verified Carbon Standard or VCS) or the Climate
Action Reserve (CAR). ODS may also arrive in the United States in the form of mixtures from other countries.
Bulk refrigerant and halon waste are occasionally mixed for consolidation purposes and shipped to the United
States for destruction.
Current EPA regulations govern the import of used and virgin ODS for the sole purpose of destruction, through
a shipment-by-shipment petition process petition process called a Certification of Intent to Import ODS for
Destruction (40 CFR Part 82, 85 FR 15258). Additionally, the Basel Convention regulates the shipment of ODS
across international boundaries (see Appendix A). ODS importers are required to submit a copy of the
destruction verification within 30 days after the destruction is complete (40 CFR Part 82, 85 FR 15258).
The reported import of all ODS for destruction in the United States has decreased from 2010 to 2018 by 98
percent. In this period, the quantity of Class I ODS imported for destruction decreased by 97 percent, from a
total of approximately 460 MT in 2010 to less than 15 MT in 2018. Approximately 97 percent of all Class I ODS
imported for destruction throughout this period were CFCs. Similarly, Class II ODS imports for destruction
have decreased greatly in this period, from 105 MT in 2010 to zero MT in 2017 and 2018. Figure 3 below
presents the reported quantity of ODS imported for destruction from 2010 to 2018.
22
-------
ODS Destruction in the United States and Abroad April 2021
Figure 3. Imports for Destruction of Class I and Class II ODS (2010-2018)a
600
2010 2011 2012 2013 2014 2015 2016 2017 2018
Class II ¦ CFCs BOther Class I
Source: EPA (2019).
a "Other Class I" includes CCI4.
5.2. European Union
5.2.1. Reported Amount and Type of ODS Destroyed
As shown in Figure 4, 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 CCI4has ceased which has increased destruction activity, but it should
also be noted that the unintentional by-production of CCI4 has decreased since 2013. Unintentional
production of CCI4 decreased by 5% between 2017 and 2018 (EEA 2019) driving a decrease in ODS destruction.
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. In 2018, CCI4 destruction accounted for 85% of total ODS destruction in that year. Figure 4
also illustrates that although the destruction of CFCs and Class II ODS 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.
23
-------
ODS Destruction in the United States and Abroad
Figure 4. Destruction of Class I and Class II ODS in the EU (2010-2018)3
April 2021
10,000
5 8,000
¦o
-
2 6,000
V,
O)
Q
| 4,000
o
£
<
2,000
0
2010 2011 2012 2013 2014 2015 2016 2017 2018
¦ Class II BCFCs ¦ Other Class I HCCU ¦ Total
Sources: EEA (2012), EEA (2013), EEA (2014), EEA (2015), EEA (2016), EEA (2017), EEA (2018),
and EEA (2019).
a Values for 2017 are from EEA (2018) which are underestimated since the total ODS
destruction value for 2017 varied significantly from EEA (2018) to EEA (2019).
Table 6. ODS Destroyed in the EU (MT) (2010-2018)a
Chemical
2010
2011
2012
2013
2014
2015
2016
2017
2018
CFCs
NA
NA
868
1,060
1,061
957
1,030
858
739
CCI4
NA
NA
1,275
4,036
6,946
7,955
5,633
4,129
7,708
Halons
NA
NA
31
14
22
C
32
NA
C
Other Class lb
NA
NA
35
36
35
52°
23
NA
C
Total, Class 1
NA
NA
2,210
5,145
8,063
8,965
6,719
4,987
8,447
Total, Class II
NA
NA
635
738
1,102
1,143
1,034
735
578
Total, All ODS
9,863
6,016
2,845
5,882
9,969
10,439
7,753
9,743
9,056
Sources: EEA (2012), EEA (2013), EEA (2014), EEA (2015), EEA (2016), EEA (2017), EEA (2018), and EEA (2019).
NA = Not available. C = Confidential.
a The chemical breakout data in this table for 2012 to 2018 are sourced directly from the European Environment Agency's Ozone-
Depleting Substances annual reports for those years (EEA 2012-2019). The total values for 2010 to 2011 are sourced exclusively from the
2016 report as the 2010 to 2011 numbers have been updated in the 2016 report (EEA 2017). The total values for 2012 to 2018 are
sourced exclusively from the 2019 report as the 2012 to 2018 numbers have been updated in the 2019 report (EEA 2019).
b "Other Class I" includes other CFCs, HBFCs, methyl bromide, and methyl chloroform.
c "Other Class I" includes other CFCs, HBFCs, methyl bromide, methyl chloroform, and halons.
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. Table 7 shows the volume of ODS imported relevant for consumption and the
percent of the total volume of imported ODS that could be destroyed. The European Environment Agency
(EEA) has not specified the intended use of the remaining material, but the quantity remaining which could be
for destruction decreased from 2012 to 2016 and remained constant in 2017 and 2018.
24
-------
ODS Destruction in the United States and Abroad April 2021
Table 7. OPS Imported in the EU (MT) (2012-2018)a
Chemical
2012
2013
2014
2015
2016
2017
2018
Total Imported
9410
8461
6843
6046
5127
6287
8712
Imported relevant for
consumption
3844
3149
2142
550
423
502
504
Percent intended for
feedstock use, process
agents, quarantine and
59%
63%
69%
91%
92%
92%
94%
pre-shipment (QPS)
service
Source: EEA(2019).
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 (MLF) 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. With MLF funding, 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 future exports of ODS waste (MLF 2017a).
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, 85 percent of recovered CFCs and 64 percent of recovered HCFCs were destroyed in 2019
(Japan MOE 2020). As shown in Figure 5, the total destruction of ODS in Japan stayed constant at 2,500 MT
from 2010 to 2015 and decreased in 2016 to 2018.17
17 It is assumed that controlled substance destruction reported to UNEP is for ODS destruction.
25
-------
ODS Destruction in the United States and Abroad April 2021
Figure 5. Destruction of OPS in Japan (2010-2018)
3000
p 2500
-o 2000
-
0
¦K 1500
a;
~
1 1000
o
£
< 500
0
2010 2011 2012 2013 2014 2015 2016 2017 2018
¦ CFCs ¦ Other MP Controlled Substances
Source: UNEP (2020).
5.4. Destruction of ODS in Article 5 and Non-Article 5 Countries
The following section provides the values of ODS destruction as reported by countries to UNEP, excluding the
United States, Japan, and countries in the European Union, and which is available through the Data Access
Centre (Table 8). In addition, estimates for CFC, Halon, and HCFC destruction in select countries are provided
in Table 9, Table 10, and Table 11, respectively.
Table 8. Reported Destruction of ODS in Select Countries (MT)a
Country
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
Australia
298.95
296.07
172.12
44.75
74.35
42.85
38.11
47.54
29.42
32b
Brazil
16.46
-
-
-
-
-
-
-
-
-
Cameroon
6.00
8.00
11.00
-
-
-
-
-
-
-
China
-
-
11.18
10.79
18.52
17.81
12.53
168.11
16.01
101.16
Colombia
-
-
-
-
3.21
0.17
0.83
-
-
-
Costa Rica
-
-
-
-
0.20
-
-
0.81
0.80
0.95
Cuba
-
-
-
-
-
0.52
0.53
-
-
0.05
Ecuador
-
-
0.04
-
-
-
-
-
0.95
1.79
Georgia
-
-
-
-
1.47
-
-
-
-
-
India
-
-
16.33
19.82
-
34.12
-
7.65
15.29
9.05
Malaysia
-
-
-
-
-
-
4.93
-
1.50
0.68
Mexico
-
-
-
-
3.03
62.85
39.07
-
-
-
Nigeria
-
-
-
-
-
-
-
-
1.50
-
Norway
0.42
1.20
-
-
-
-
-
-
-
-
Republic of Korea
2,950.20
4,075.40
4,674.20
4,622.70
4,499.40
3,799.20
3,839.70
3,698.50
4,228.80
3,563.80
Russian Federation
-
-
-
-
-
-
230.02
-
0.29
-
Viet Nam
-
-
-
-
-
-
0.12
-
-
-
Source: UNEP (2020), unless otherwise noted.
a As of 2019, destruction volumes reported to UNEP for controlled substances may include HFC destruction volumes as well
as ODS destruction volumes. Unless otherwise noted, it is assumed that reported controlled substance destruction is ODS
destruction.
b Reported controlled substance destruction to UNEP is 417 MT of which approximately 385 MT are HFC destruction and 32
MT are ODS destruction (Government of Australia 2020a).
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ODS Destruction in the United States and Abroad
April 2021
Destruction estimates for CFCs, halons, and HCFCs are based on an analysis of production data reported to
UNEP, given that the Montreal Protocol defines production as the "amount of controlled substances
produced, minus the amount destroyed by technologies approved by the Parties and minus the amount
entirely used as feedstock in the manufacture of other chemicals" (UNEP 2019). Equation 1 illustrates the
Montreal Protocol's definition of production:
Net Production = Gross Production — Destruction — Feedstock Equation 1
Net production = production reported to UNEP
Gross production = total produced by the country
Destruction = amount destroyed by the country
Feedstock = amount transformed for feedstock uses by the country
This report estimates that any production of CFCs, halons, and HCFCs 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.
Table 9. Estimated CFC Destruction in Select Countries (MT)a
Country
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
Australia
22.71
28.60
15.24b
7.48b
14.58b
8.90b
7.18b
7.54b
1.37b
3.10b
Cameroon
5.70
7.60
10.45
-
-
-
-
-
-
-
China0
NA
NA
NA
165.87
NA
14.73
3.33
203.40
11.88
31.45
Colombia
-
-
-
-
2.66
0.19
0.38
-
-
-
Cuba
-
-
-
-
-
0.29
0.48
-
-
0.10
Ecuador
-
-
-
-
-
-
-
-
0.95
1.52
India0
NA
-
14.63
18.81
-
32.40
-
-
-
-
Mexico
-
-
-
-
-
37.81
11.02
-
-
-
Norway
0.29
0.10
-
-
-
-
-
-
-
-
NA = Not applicable.
Source: UNEP (2020), unless otherwise noted.
a Data converted from Ozone Depletion Potential (ODP) Tonnes to MT using 0.95 conversion factor, representative of a
mixture of CFCs.
b Government of Australia (2020b).
c In 2010, 2011, 2012, and 2014, China and India reported positive production data, potentially due to production of CFCs
under an essential use exemption for use in metered dose inhalers (UNEP 2015a). These data are not presented because it
is not possible to estimate destruction quantities when the production value is positive.
Table 10. Estimated Halon Destruction in Select Countries (MT)a
Country
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
Australia
18.67
-
23.26b
_b
_b
_b
_b
_b
_b
0.04b
China
-
-
0.27
0.13
0.17
-
-
0.33
-
-
India
-
-
-
-
-
-
-
92.17
50.97
425.87
Russian Federation
-
-
-
-
-
-
-
-
0.93
-
Source: UNEP (2020), unless otherwise noted.
a Data converted from ODP Tonnes to MT using 0.33 conversion factor, representative of halon 1211 destruction (Verdonik 2017).
b Government of Australia (2020b).
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ODS Destruction in the United States and Abroad April 2021
Table 11. Estimated
HCFC Destruction
n Select Countries
MT)a
Country
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
Australia
236.90
266.27
133.62b
37.27b
59.78b
33.95b
30.93b
39.99b
28.04b
29.11b
Colombia
-
-
-
-
0.73
-
0.91
-
-
-
Costa Rica
-
-
-
-
0.18
-
-
0.73
0.73
0.36
Malaysia
-
-
-
-
-
-
4.91
-
1.46
0.73
Norway
-
1.09
-
-
-
-
-
-
-
-
Source: UNEP (2020), unless otherwise noted.
a Data converted from ODP Tonnes to MT using 18.2 conversion factor, representative of HCFC-22 destruction (OzonAction n.d.).
b Government of Australia (2020b).
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 United Nations Industrial Development Organization (UNIDO) collaborated with the government of Ecuador
and the private sector on ODS related projects. As a first stage in 2011, a project for the replacement of 330,000
obsolete refrigerators was implemented and 2.7 MT of CFC-12 were recovered and stored. In addition, some
HFC-134a was also recovered. As a second stage in 2015, technological capacity was developed for the
destruction of CFCs and the 2.5 MT recovered earlier in the project were destroyed (UNIDO 2018, UNIDO 2019)
If additional ODS is collected in the future, the system is capable of reprocessing or destroying (UNIDO 2019).
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 potential mitigation is approximately three
times larger than the estimated reduction from phase-out management plans. GIZ estimates that if all
measures are implemented to the full extent, approximately 1,500 million metric tons carbon dioxide
equivalent (MMT C02 Eq.) will be avoided (GIZ 2018, GIZ 2019).
GIZ collaborated with the Colombian Ministry of Environment and Sustainable Development, the Colombian
Ministry of Mines and Energy, and national implementing partners on Colombia's NAMA for the Domestic
Refrigeration Sector (NAMA Facility 2020). It is estimated that an annual reduction of approximately 3.8 MT CO2 Eq.
by 2030 will be achieved through the phase-in of new fridges and proper waste management (NAMA Facility 2020).
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).
6. Global ODS Recovery, Transportation, and Destruction
Costs
Costs are incurred throughout the 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.
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
suppression), 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 12 presents the
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ODS Destruction in the United States and Abroad
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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) and by the
American Carbon Registry (ACR 2019). For example, while ODS recovery from refrigeration/AC and fire
suppression 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 12. Range of Costs for Recovery, Transport, and Processing of ODS in Products and Equipment3
End-Use
Segregation/
Collection Costs'3
(US$/kg)
Transport Costs
(Recovery)
(US$/kg)
Recovery Processing Costs
(US$/kg)
Household 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 Suppression (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
Sources: TEAP (2009), EOS Climate (2016).
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 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). The costs have been confirmed by ACR (2019).
Older estimates from TEAP (2009) indicate that the international average cost of transporting ODS between
200 to 1000 kilometers ranges from $8 to $60 per MT of ODS ($0.04 to $0.06 per MT per km). According to
more recent information, an ODS destruction project in Brazil, it costs approximately $3,000 per MT to
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ODS Destruction in the United States and Abroad
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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 (approximately
$0.4 per MT per km) (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 (approximately $0.2 to $0.9 per MT per km) (MLF 2017a). According to an ODS destruction project in
Mexico, the cost of transportation and consolidation of ODS waste within Mexico was $1,400 per MT (MLF
2018b).
6.3. ODS Destruction Costs
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 was confirmed by ACR (2019). 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. In addition, the estimated cost to
destroy liquid bulk ODS provided by a destruction company was within the ranges provided by MLF (2008) and
TEAP (2009) with higher costs for ODS streams containing higher concentrations (Veolia 2021).
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. ODS
destruction costs in pilot projects (i.e., in China, Colombia, Georgia, Mexico, Turkey, and the ECA Region)
ranged from $1.87 to $12.50 per kg (MLF 2018b). In addition, a pilot project in Nigeria had ODS destruction
costs of $29.82 per kg; this high cost was likely due to the lower than expected quantity of ODS destroyed
(MLF 2018b).
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.
Most recently, another facility indicated that destruction costs for solids (which could include foam and foam-
containing products) could typically be below $5 per kg of ODS depending on factors such as pH, reactivity,
and volatility (Veolia 2021). 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). A
pilot program in Colombia that destroyed ODS-containing foams through rotary kiln incineration noted a
destruction cost of $5.20 per kg of foam (MLF 2018b).
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7. Financing of ODS Destruction Projects
Globally, there are a variety of mechanisms for funding or offsetting the cost for ODS destruction. For
example, in some countries, taxes on ODS or the availability of carbon offset credits may be available
resources. In some cases, there may be relevant projects funded by the MLF or the Global Environment Fund
(GEF). However, the Refrigeration, Air Conditioning and Heat Pumps Technical Options Committee (RTOC)
states that there is currently little financial incentive for ODS destruction and, because of this, destruction is
only successful when it is regulatory driven (RTOC 2018). Requirements to destroy obsolete ODS where
resources are unavailable may create an unfunded mandate to collect and properly dispose ODS. Market
based incentive schemes (voluntary or compliance) may provide a financing stream for ODS destruction.
7.1. Producer Responsibility Programs and Taxes
In some countries, ODS destruction can be funded through voluntary or government-mandated programs that
encourage or require producers to manage ODS contained in their products over the lifetime of the product
and create financial and behavioral incentives for stakeholders in the process.
Extended producer responsibility (EPR) programs, used in countries such as Australia, Germany, and France,
often rely on levies or licensing fees (usually on the production/import of ODS-containing equipment), and
rebates (for the return of recovered ODS). These programs can be used to encourage producers to safely
manage the manufacture, operation, and decommissioning of ODS-containing equipment. For example,
Australian industry created Refrigerant Reclaim Australia (RRA) in 1993 to develop a recovery program for
Australian ODS and, eventually, synthetic greenhouse gas refrigerants. It worked with companies for
reprocessing and destruction of recovered refrigerant (RRA n.d.). Recovery was done on a voluntary basis
from 1993 to 2004 when the Ozone Protection and Synthetic Greenhouse Gas Management Act took effect
and made recovery compulsory (RRA 2012, RRA n.d.). Subsequently, a condition on licenses was implemented
which required companies to exercise product stewardship over imported products (RRA 2012). From 1993 to
2017 the RRA had recovered approximately 6,500 MT of ODS and synthetic greenhouse gas refrigerants of
which 91% was destroyed (RRA n.d.). The RRA is fully funded from money derived through an industry levy on
import of refrigerants in bulk or in pre-charged equipment (89% of total revenue) (Miller and Batchelor 2012b,
RRA 2019, Government of Australia 2020).
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 from 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). Some Member States (e.g., Germany and France) have made
producer responsibility mandatory (European Commission 2019). It was expected that, given Regulation (EC)
1005/2009 and other parallel provisions, 14,000 ODP tonnes would be recovered annually in the European
Union (European Commission 2019).
An example of an EPR 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
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April 2021
ODS. RMC organizes the export of ODS to the United States and earns offset credits based on successful
destruction.
While EPR programs are designed to incentivize ODS management, there are four key issues they may face:
share of responsibilities and dialogue between stakeholders; defining costs to be covered; fair competition;
and transparency and surveillance (Deloitte 2014).
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 equipment. Taxes can also
be imposed, for instance, on the production of new equipment containing ODS. As with EPR programs, taxes
imposed on the production of ODS-containing equipment may introduce the potential for unfair competition
from other producers not subject to the tax (e.g., foreign companies) (OECD 2011).
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. Similarly, Denmark established a fee by installers and refrigerant wholesalers to cover the cost of
destruction (European Commission 2019).
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).
7.2. ODS Destruction Offset Programs
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
are not mandatory and thus, operate outside the compliance market. In voluntary markets 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 by law are not eligible to generate offset credits because there is
no additionality. Legal requirements to destroy ODS in those countries creates a disincentive to collect and
destroy obsolete ODS because the economic incentive (i.e., generating ODS offset credits) is removed.
7.2.1. Compliance Markets
Compliance markets exist at an international level and at regional (e.g., Western Climate Initiative [WCI]),
national (e.g., South Korea and Japan) and subnational levels (e.g., Regional Greenhouse Gas Initiative [RGGI]
and California) through legally-binding policy instruments. The key aspect of compliance markets is that there
is a legal requirement for covered entities18 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
18 Covered entities are those, defined per regulations, that have a legal requirement to maintain emissions under a set target.
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ODS Destruction in the United States and Abroad
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eligible19 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 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 WCI. This has allowed the California
and Quebec governments to hold joint auctions of GHG emission allowances and to harmonize regulations
and reporting. In 2017, the Ontario and Quebec governments enlisted help from CAR to develop a protocol for
ODS foam and refrigerant destruction (CAR 2017). By July 2019, Quebec had issued 534,618 carbon credits
from ODS destruction 70% of which were from ODS in foams or used as refrigerants (Government of Quebec
2019).
Following successful implementation of Ontario's cap and trade system in 2016, the Ontario market joined the
WCI regional carbon market in January 2018. That same year, Nova Scotia joined the WCI in order to use its IT
system and manage its new cap and trade program which will be administered independently from the
California and Quebec programs (Matheson and Tamblyn 2018). In July 2018 Ontario eliminated its cap-and-
trade carbon tax, citing a burden on families and businesses, and left the WCI (Ontario Ministry of the
Environment 2018).
In addition to the North American compliance markets discussed above, Table 13 shows the progress of
several countries and regions in implementing emissions trading systems. These systems do not currently
award offset credits for ODS destruction; however, they may approve similar protocols in the future.
Table 13. Emission Trading Systems
Subnational Level
Country Level
Regional Level
Established Emissions
Trading Systems
Established Emissions
Trading Systems
Establishing Emissions
Trading Systems
Established Emissions
Trading Systems
California (USA)
Japan
China
European Union
Shenzen, Shanghai, Beijing,
Guangdong, Tianjin, Hubei,
Chongqing, Fujian (China)
Kazakhstan
Colombia
WCI
RGGI
New Zealand
Mexico
South Korea
Ukraine
Switzerland
Source: ICAP (2019).
7.2.2. Voluntary Markets
Voluntary markets allow organizations to offset carbon emissions on a voluntary basis. Voluntary carbon
markets have been used as a funding source for ODS destruction projects (see Box 7). ODS destruction
projects are attractive due to the permanence of the reductions and the messaging around the rationale. The
market demand for voluntary offsets is driven by buyers' interest and credits from these sources have been
19 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.
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ODS Destruction in the United States and Abroad
April 2021
used by businesses and events to offset their emissions. For example, the Aviation sector has adopted the
Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) to complement their measures
to achieve the global aspirational goal of becoming carbon-neutral from 2020 onwards (ICAO n.d.). The
adoption of CORSIA is estimated to increase demand for voluntary offsets by 3,000 MMT C02 Eq. from 2020 to
2035 (World Bank 2019).
The three most widely traded voluntary offset programs in the United States with ODS destruction protocols
are the Verra, CAR, and the ACR. Verra represents more than 60% of the total credits issued from the three
voluntary markets, as of October 2019. From 2010 to 2019 CAR registered 110 projects related to ODS
Destruction resulting in 1,375 MT of ODS destroyed (CAR 2020). Likewise, ACR registered 77 projects related
to ODS from 2013 to 2019 (ACR 2020a). As shown in Figure 6, the volume of issued carbon credits grew from
2008 to 2012 and recovered from a 2014 dip with rapid growth from 2015 to 2017 at which point there were
97 million MT C02 Eq. issued in credits. In addition, carbon credits issued almost doubled from 2018 to 2019;
however, this increase was not observed for credits issued for ODS specific projects which have remained
constant at 2.7 million of MT C02 Eq. since 2016.
Figure 6. Annual Volume Issued (MMT C02 Eq.)a
Sources: CAR (2020), Verra (2020), and ACR (2020a).
a The totals presented in this figure for ODS Specific Projects from 2008 to 2017 are the sum of the
credits issued for ODS projects in CAR and ACR. For 2018 the totals for ODS Specific Projects considers
CAR, ACR, and Verra.
The estimated number of ODS destruction projects in the United States will likely remain constant in the near
future and the number of international projects is estimated to increase (ACR 2020b)20.
Offset prices in voluntary carbon markets can range as a result of project costs, buyer's preferences and type
of transaction. In the first quarter of 2018 prices ranged from 0.1-70 US$ per MT C02 Eq. with an average of 3-
6 US$ per MT C02 Eq. (Ecosystem Marketplace 2018). Table 14 presents a breakdown of the voluntary carbon
markets with ODS destruction protocols in 2018.
20 Because of the timelines and processes in project development and verification, the impacts of COVID-19 on U.S. ODS destruction
projects are expected to be negligible while COVID-19 impacts on international projects will be more significant (in part as a result of
international and in-country travel restrictions) (ACR 2020b, Tradewater 2020).
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ODS Destruction in the United States and Abroad April 2021
Table 14. Breakdown of Voluntary Markets and ODS Destruction Protocols in 2018
Offset Program
Total Credits
Issued (millions
of MT C02 Eq.)a
Total Value
Traded (US$
Millions)313
Total Credits
Issued for ODS
Projects (millions
of MT CO2 Eq.)
Total Value
Traded for ODS
Projects (US$
Millions)313
Protocol for
ODS
Destruction
ODS Sou reed
Internationally
Verra
49.6
$140
0.020
$0.1
Yes
Yes
Climate Action
Reserve
18.9
$54
1.60
$4.6
Yes
Yes
American Carbon
Registry
11.9
$34
1.07
$3.1
Yes
No
Sources: Ecosystem Marketplace (2019), CAR (2020), Verra (2020), and ACR (2020a).
a The totals presented in this column account for all offset projects eligible under the voluntary program, of which a small portion are
ODS destruction projects.
bThe traded value is calculated based on the credits issued and there may be variations with actual traded value since it does not
consider credits transacted more than once or credits issued which were not sold. In addition, the traded value was calculated
considering the weighted average credit price of 2.84 US$ per MT C02 Eq. as reported in Ecosystem Marketplace (2019) for 2018.
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 2016, approximately 1.4 million MT C02 Eq. from gases (i.e., ODS and N20) projects
were transacted globally in the voluntary market for a total value of $8 million (Ecosystem Marketplace
2017).21 There are additional costs associated with the preparation, validation, and verification of ODS
destruction projects, which are summarized in Table 15.
Table 15. Transaction Costs to Prepare an ODS Destruction Project
Project Phase
Cost (US$)
Project Preparation3
Approx. $60,000
Third-Party Validation and Verification
Up to $20,000
Offset Marketplace Fees
Up to $1,000
Issuance/Registration Fee
$0.12-0.20/MT CO2 Eq.
Source: ACR (2019).
a Project preparation costs vary according to the financing model used and the
approach of companies performing collection/aggregation, in some cases, costs could
be much higher.
While the financial prospects of funding ODS destruction projects through the sale of carbon offset credits are
available, there are challenges. One of the main challenges is that projects generate revenue only once the
offset credits have sold. In s 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).
21 Disaggregated data for ODS projects was reported by Ecosystem Marketplace 2017.
35
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ODS Destruction in the United States and Abroad
April 2021
Box 7. Case Study: International ODS Destruction Project in the Voluntary Carbon Market
An ODS destruction project between private industry in Ghana and a third-party aggregator sought to
destroy a CFC stockpile of more than 15 MT in Ghana by exporting the ODS for destruction to the United
States. Costs were to be funded through offsets under the voluntary carbon market. In 2017, a first phase
of the project resulted in the generation of 20,000 carbon offset credits and the successful destruction of
over 1.8 MT of CFCs following the Verra protocol. The sale of those carbon credits enabled the funding of a
second phase in which 13.6 MT of ODS were destroyed in April 2019 and will result in 130,000 additional
carbon offset credits (Berwald 2019, Tradewater 2019).
Figure 7 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 7 presents three different collection
programs: refrigerator collection, ODS stockpiles, and large stationary AC.
Figure 7. Break-Even Costs Compared to Average Price of Offset
o
-t—'
(D +-»
CuO u
M—
CD O
cr u
Based on average price of offset
in California Cap and Trade
Based on average price of gases
offset in Voluntary Markets3
Q.
U
O
-t—1
LD
CO
o
o
u
<
>-
L_
— 03
c
(D O
CuO -t—1
ro -t—1
—I CO
Sources: ICF (2010b), Ecosystem Marketplace (2017), and CARB (2019).
a This average price includes both ODS and N20.
36
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ODS Destruction in the United States and Abroad
April 2021
7.3. HFC-23 Destruction
HFC-23 is generated as a byproduct from HCFC-22 production. HFC-23 destruction 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 certified emission reduction
(CER) credits from HFC-23 destruction, which significantly lowered the value of credits obtained from HFC-23
abatement projects. Likewise, Verra announced in 2014 that it would no longer approve new methodologies
and projects relating to HFC-23 destruction (Verra 2014). 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). Historically,
nineteen HFC-23 destruction projects were approved by the Clean Development Mechanism (CDM) Executive
Board (MLF 2017b). During the CDM period (i.e., 2003-2014) a cumulative HFC abatement of approximately
53,3000 MT was achieved (Stanley et al. 2020).
It is likely that abatement measures are not being implemented as CDM finance sources are no longer
available. For example, as of 2017, Argentina and Mexico, which in previous years had CDM projects, have
resumed venting practices of HFC-23 byproduct (MLF 2017b, MLF 2018a). Specifically, recent studies indicate
that abatement measures are not yet successfully being implemented and/or HCFC-22 production is larger
than reported because of an increase in the atmospheric HFC-23 concentration growth rate from 2016 to
2018 (Stanley etal. 2020).
Under the Kigali Amendment to the Montreal Protocol, Parties agreed, starting in 2020, to destroy HFC-23
emissions to the extent practicable using destruction or conversion technologies approved by the Parties. In
addition, there are also some national requirements to reduce HFC-23 emissions. For example, in 2016, India
announced a requirement for the destruction of HFC-23 using an efficient and proven technology such as
thermal oxidation (MLF 2017b, Ozone Cell 2016). It is expected that the atmospheric HFC-23 concentration
growth rate will be reduced as abatement measures are implemented as a result of national requirements
and the Kigali Amendment provisions.
7.4. MLF- and GEF-Funded Destruction Projects
In some cases, international organizations (e.g., MLF and GEF) fund projects that assist in ODS collection,
management, and destruction. Demonstration projects have been funded by these organizations to show that
ODS destruction is viable, develop lessons learned, and establish replicability. Due to the varying comparative
advantages of the MLF and GEF, each organization has focused funding on different aspects within the
process of ODS waste management. Projects by UNIDO, GIZ and others are presented in Box 6. As of 2016,
UNIDO had completed over 1,340 ODS projects through the MLF, GEF, and bilateral contributions, some of
which were focused on or had an element of ODS destruction (UNIDO 2018, UNIDO 2016).
The MLF demonstration projects focused 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 2017a, MLF 2018b, MLF
2019). Most recently, in 2017 and 2018, ODS waste management and disposal projects (i.e., in China,
Colombia, Georgia, Mexico, Nepal, Nigeria, and Turkey) funded by the MLF resulted in the destruction of more
than 350 MT of ODS (MLF 2018b). 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 instances, international organizations collaborated with the private sector to monetize projects. For
example, in 2012, UNDP, in collaboration with EOS Climate, funded the collection and transport for
destruction of waste ODS from Nepal to the United States using MLF resources. EOS Climate acted as a project
aggregator and facilitated the sale of 82,400 Verified Emission Reductions (VER) in the CAR (UNEP 2017).
37
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ODS Destruction in the United States and Abroad
April 2021
The GEF focuses funding on legal and informational aspects of ODS offset destruction 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). By 2012, the GEF had invested $235 million across 18
economies in transition in 29 projects to phaseout ODS (GEF 2017a). In 2017, the GEF approved for
implementation a regional demonstration project for the collection and destruction of POPs and ODS, in
Ukraine, Belarus, Kazakhstan and Armenia, which aimed to destroy at least 418 MT of ODS (GEF 2017b).The
project, implemented by UNIDO, has evaluated legal frameworks and technologies, it will result in three new
ODS destruction facilities and is expected to begin destruction activities before 2021 (GEF 2020).
8. Modeled Amounts of ODS Potentially Available for
Destruction
While under the Montreal Protocol production and consumption of ODS are being phased out, large amounts
of ODS currently installed in equipment and products, and existing in stockpiles, could be released to the
atmosphere given emissions are not controlled. Alternatively, 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.
8.1. ODS Recoverable from Equipment and Products
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. RTOC (2018) estimates
global refrigeration banks to be ten to twenty times larger than the annual refrigerant demand and states that
the largest bank is for HCFC-22, which is estimated to be larger than 1 million MT for unitary air conditioners.
In the fire suppression 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).
Recovery from appliance foams is also feasible; however, the recovery effort may be more expensive and
could require a higher level of effort than for refrigerants. Specifically, recovery from construction foam is
lower than for the refrigeration/AC sector as the quantity of original blowing agent that is actually recoverable
is relatively lower. The Flexible and Rigid Foams Technical Options Committee (FTOC) estimates that global
banks of blowing agents in foams will exceed 5 million MT by 2020 and states that if they enter the waste
streams, they will become broadly unreachable (FTOC 2019). This highlights the importance of establishing
additional mechanisms for ODS containing foam collection and eventual destruction. To address this,
countries promote foam recovery via different mechanisms such as the United States, which established the
RAD Program, and the European Union, which established regulation to recover appliance foam. In addition,
some regions treat ODS in foams as a hazardous waste to promote recovery; however, difficulties in
determining the blowing agent within the foam results in an inability to monitor shipments and hinders these
efforts (FTOC 2019). Furthermore, treatment as hazardous waste creates additional burdens since destruction
in hazardous-waste-permitted facilities is more costly and if regulated, the destruction would not trigger the
additionality requirement to qualify projects for emission reduction credits (ICF 2010a).
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.
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ODS Destruction in the United States and Abroad
April 2021
8.1.1. United States
The U.S. EPA Vintaging Model (VM)22 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 suppression, 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 suppression equipment are estimated in this
analysis. Estimated quantities of HFCs potentially recoverable from retired equipment at EOL are presented in
Section 10.2.
Figure 8 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.
Figure 8. Quantity of CFCs Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2020)a
2,500
5 2,000
_0J
_Q
<5 1,500
>
11,000
(0
c
-------
ODS Destruction in the United States and Abroad April 2021
Figure 9 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 9. Quantity of HCFCs Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2050)
25,000
20.000
XI
£ 15,000
>
O
o
-------
ODS Destruction in the United States and Abroad April 2021
Figure 10. Quantity of CFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
7,000
6,000
5,000
_0
¦9
a> 4,000
>
o
0
0)
ai
^ 3,000
1
c
<1)
o 2,000
cl '
1,000
0
Mobile AC
Stationary AC
i Refrigerators/Freezers
i Commercial Refrigeration
i Refrigerated Transport
XPS Foam Boards
i PU Rigid: Spray Foam
PU & PIR Rigid: Boardstock
PU Rigid: Sandwich Panels
i PU Rigid: Commercial
Refrigeration
i PU Rigid: Domestic
Refrigerators/Freezers
2010
2020
2050
Source: ICF (2010a}.
Figure 11. Quantity of HCFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
7,000
6,000
5,000
_0)
I
0
o 4,000
O
0
cd
2>
1 3,000
c
0
O
2,000
1,000
0
¦
2010
_
2020
2050
Stationary AC
i Refrigerators/Freezers
Commercial Refrigeration
i Refrigerated Transport
i Industrial Refrigeration
XPS Foam Boards
i PU Rigid: Spray Foam
PU & PIR Rigid: Boardstock
PU Rigid: Sandwich Panels
PU Rigid: Commercial
Refrigeration
i PU Rigid: Domestic
Refrigerators/Freezers
Source: ICF (2010a).
41
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ODS Destruction in the United States and Abroad April 2021
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 12, 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.
GIZ (2018) estimates that the Article 5 countries with the largest ODS banks are China (i.e., approx. 1,200,000
MT ODS), Republic of Korea (i.e., approx. 180,000 MT ODS), Saudi Arabia (i.e., approx. 100,000 MT ODS), Brazil
(i.e., approx. 100,000 MT ODS), and India (i.e., approx. 100,000 MT ODS).
Figure 12. Global Estimates of ODS Potentially Available from Retired Equipment at EOL in MMT C02 Eq.,
(2010-2050)
350
d 300
O
U
250
I Other Non-A5: Ref/AC (CFC)
I Other Non-A5: Ref/AC (HCFC)
I Other Non-A5: Foams (CFC)
tc
i—
CD
>
8 150
QC
c
0)
+-»
o
CL
100
50
Other Non-A5: Foams (HCFC)
I Other Non-A5: Fire Protection
(Halon)
A5: Ref/AC (CFC)
A5: Foams (CFC)
A5: Fire Protection (Halon)
2010
2020
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 8, Figure 9, Figure 10, Figure 11, and Figure
12 do not account for any stockpiles since currently there is little information available on existing or future
ODS stockpiles. Preliminary research indicates such stockpiles are likely small given the costs required to store
surplus ODS and existing demand. The most likely holders of surplus ODS are service companies with cylinders
of ODS that were used to service equipment and contain small residual amounts of up to 5 percent of the
original contents (ICF 2009a). It is possible that stockpiled materials intended for servicing needs of equipment
will not be required. Any such stockpiled material would be eligible for destruction.
8.2.2. Halons in Fire Suppression 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. In order to maximize halon supply,
some countries have implemented halon banks which act as virtual or physical centralized management for
42
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ODS Destruction in the United States and Abroad
April 2021
ODS and may involve recovery, reclamation, reissue, transfer and/or storage (HTOC 2018b). Argentina (2 MT
stockpile of Halon 1301 in 2018), Australia23 (94 MT stockpile of Halon 1211 and 168 MT stockpile of Halon
1301 in 2018), China (2,000 MT stockpile of Halon 1211), Japan (16,250 MT of Halon 1301 in 2018), South
Africa (30 MT stockpile from 2006 to 2010), South Korea (2,500 MT stockpile of Halon 1301 in 2018) and the
United States (North America has an estimated Halon 1301 stockpile of 11,502 MT in 2019) are among those
with halon banks (HTOC 2018b, HTOC 2018c). According to the Halons Technical Options Committee (HTOC)
estimates, the worldwide bank of Halon 1301 is 37,750 MT (HTOC 2018c).
There is continued global demand for halons particularly for high-value, niche applications such as aviation.
Given this continued demand, it may only be appropriate to consider destroying halons that are cross-
contaminated and cannot be reclaimed to an acceptable purity level (UNEP 2014a, HTOC 2018a).Regardless,
the ACR revised its ODS destruction project standard in 2017 to include halons 1211 and 1301 with eligibility
limited to halon 1211 and 1301 sourced from equipment or systems in the United States and halon 1301 not
originating from stockpiles (ACR 2017).
9. ODS Management Needs
Many countries may face the challenge of maintaining sound management of ODS through equipment
operation and throughout the process of collection, consolidation and storage, transportation, and
Exhibit 1. The Process of ODS Destruction and Illustrative Recordkeeping Requirements
[ Confiscated |VjrVirgin ODS
X Stocks JM\. 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
23 The Australian National Halon Bank, established in 1993, was set up to maintain a stock of halon for non-defense uses until the
transition to alternatives was complete and for the stock to be managed under controlled conditions to prevent accidental releases
(Commonwealth of Australia 2019). It also collects and disposes of halon recovered from decommissioned systems.
43
CI Equipment 11
Banks JI
Collection
«nT
Mixed/Contarr
Stocks
Consolidation
and Storage
Transport
J
Testing
s
Destruction
-------
ODS Destruction in the United States and Abroad
April 2021
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.
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 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
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 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 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 countries with destruction capabilities is a preferred option.
44
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ODS Destruction in the United States and Abroad
April 2021
Although this is usually the easiest method for destruction, some countries ban the 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).
International Cooperation
Countries collaboration may facilitate ODS management 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).
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 2017). See
Appendix A for further information on transboundary movement (TBM) of ODS.
An additional example of ongoing international cooperation for the disposal of ODS is the "Moana Taka
Partnership" signed in March 2018. This partnership between the Secretariat of the Pacific Regional
Environment (SPREP) and the China Navigation Company (CNCo) will result in pro bono transportation of ODS,
among other recyclable waste, from Pacific island countries (27 eligible countries) to ports in Asia Pacific to be
sustainably treated and recycled (SPREP 2018).
10. Implications for Addressing HFC Disposal
In October 2016, Parties agreed on the Kigali Amendment to the Montreal Protocol to phasedown HFC
production and 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.
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ODS Destruction in the United States and Abroad
April 2021
10.1. Sources, Practices, Technologies, and Costs: Parallels to ODS
Sources
The sources of recoverable HFCs are similar to those for ODS, although the time period in which they will be
available for recovery varies based on the country. Projections of the potential sources of recoverable HFCs
and when they will become available are addressed in the next section.
Practices
The best installation, handling, recovery, recycling, reclamation, and disposal practices are identical between
ODS and HFCs (see Section 3). However, individual governments do not necessarily regulate the refrigerant
management practices the same between ODS and HFCs.
Several countries have implemented HFC refrigerant management practices. The European Union introduced
an updated F-gas regulation in 2015 that helps to prevent emissions in existing equipment by requiring
checks, proper servicing, and recovery of the gases at the end of the equipment's life, similar to what was
already required for ODS (EU 2014). In 2017, Canada issued its Regulations Amending the Ozone-depleting
Substances and Halocarbon Alternatives Regulations, which requires the proper destruction or recovery for
recycling and reclamation of HFCs that are no longer in use, as well as outlines the schedule for HFC
phasedown (Government of Canada 2017). In the United States, Section 608 of the Clean Air Act prohibits the
knowing release of refrigerant during the maintenance, service, repair, or decommissioning of
refrigeration/AC equipment. In 2016, the U.S. EPA updated the existing requirements related to ODS
refrigerants and extended them to include HFCs (EPA 2016a). In February 2020, the U.S. EPA issued the final
rule Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program's Extension to
Substitutes that rescinds the 2016 extension of the leak repair provisions to appliances using substitute
refrigerants (e.g., HFCs) (EPA 2020c). The U.S. EPA 2020 rule maintains provisions on the sales restriction and
technician certification requirement, safe disposal requirements, evacuation requirements, reclamation
standards, and requirement to use certified recovery equipment for substitute refrigerants (e.g., HFCs) (EPA
2020c).
Technologies
Incineration and plasma arc destruction facilities that destroy ODS are also capable of accepting HFCs for
destruction. 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).
Other non-incineration technologies are also feasible for destruction/conversion of HFCs. Some of these
technologies use chemical reactions or catalysts to dissociate chemical bonds.
Parties to the Montreal Protocol approved, at the 30th MOP and through Decision XXX/6, approved
destruction technologies for HFCs. These technologies were evaluated by the 2018 TFDT and include
technologies approved for ODS destruction and other technologies such as Electric Heater and Furnaces
Dedicated to Manufacturing. A total of 12 and eight destruction technologies were approved for group I and
group II (i.e., HFC-23) concentrated sources, respectively, and two for group I diluted sources. HFC destruction
technologies are included in Table 16 and all technologies are described in Appendix C.
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ODS Destruction in the United States and Abroad April 2021
Table 16. Approva
Status of Available Destruction Technologies
Applicability3 and Required Destruction and Removal Efficiency (DRE)b
Technology
Concentrated HFCsc
Dilute ODSd
HFCs® (99.99%)
HFC-23f (99.99%)
HFCs® (95%)
Thermal Oxidation (Incineration
Technologies
Cement Kilns
Approved
Not Determined
Not Applicable
Gaseous/Fume Oxidation
Approved
Approved
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
Approved
Not Applicable
Rotary Kiln Incineration
Approved
Approved
Approved
Thermal Decay of Methyl Bromide
Not Applicable
Not Applicable
Not Applicable
Electric Heater
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Fixed Hearth Incinerator
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Furnaces Dedicated to Manufacturing
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Plasma Technologies
Argon Plasma Arc
Approved
Approved
Not Applicable
Inductively Coupled Radio Frequency
Plasma
Not Determined
Not Determined
Not Applicable
Microwave Plasma
Not Determined
Not Determined
Not Applicable
Nitrogen Plasma Arc
Approved
Approved
Not Applicable
Portable Plasma Arc
Approved
Not Determined
Not Applicable
Steam Plasma Arc
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Air Plasma Arc
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Alternating Current Plasma
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
CO2 Plasma
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Conversion (Non-Incineration) Technologies
Chemical Reaction with H2 and C02
Approved
Approved
Not Applicable
Gas Phase Catalytic De- halogenation
Approved
Not Determined
Not Applicable
Superheated Steam Reactor
Approved
Approved
Not Applicable
Thermal Reaction with Methane
Not Determined
Not Determined
Not Applicable
Catalytic Destruction
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Solid Alkali Reaction
Not Yet Reviewed
Not Yet Reviewed
Not Yet Reviewed
Sources: UNEP (2011), UNEP (2015b), HTOC (2018a), TEAP (2018c), and UNEP (2018).
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 fully reviewed by the
Parties to the Montreal Protocol.
b 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.
Concentrated sources of HFC refer to virgin, recovered, and reclaimed HFCs.
d Dilute sources of HFCs refer to HFC contained in a matrix of a solid (e.g., foam).
e Under the Montreal Protocol, these substances are listed in Annex F, Group I.
'Under the Montreal Protocol, these substances are listed in Annex F, Group II.
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Costs
Costs associated with HFC waste management are expected to be similar to that of ODS. HFCs are collected
from appliances and other sectors using the same procedures outlined for ODS. In addition, HFC destruction
costs are expected to be similar because the incineration and plasma arc destruction technologies are capable
of destroying the chemical at the existing operating conditions.
HFCs are currently often destroyed as part of mixed refrigerant projects, where ODS destruction is the focus.
For example, a private company acquired shipments of mixed refrigerant through its buyback program
consisting of CFCs, HCFCs, HFCs, and hydrocarbons (HCs). Containers received from the buyback program
were consolidated into larger tanks and shipped to a destruction facility. The company received carbon credits
from the Chicago Climate Exchange (CCX) for the destruction of the ODS components of the mixture (ICF
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 can be a method of
financing HFC destruction if they are no longer produced and when there are no country-specific regulatory
requirements for 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.
10.2. Current and Projected Quantities Available for Destruction
In Article 5 countries, ODS are still commonly used in systems and equipment. In non-Article 5 countries, HFCs
have largely replaced ODS in equipment. Equipment containing HFCs have lifetimes up to 30 years. 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 older systems or equipment containing HFCs, or retrofitted with HFC containing blends, are nearing
their EOL and 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 systems24 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 13). 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 (MACs or MVAC) is the primary driver in potentially
recoverable HFCs until 2020. In 2030, potential recovery of HFCs at EOL reaches a value of approximately
41,000 MT due mainly to commercial and residential 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.
24 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).
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ODS Destruction in the United States and Abroad April 2021
Figure 13. Quantity of HFCs Potentially Recoverable from Retired U.S. Equipment at EOL (2010-2050)3
50,000
.||||
l l l l l
I | | ¦ | |
h 111111 -
2010 2015 2020 2025 2030 2035 2040 2045 2050
¦ Commercial Refrigeration ¦ Domestic Refrigeration bIPR/CS
¦ Transport Refrigeration Commercial Stationary AC ¦ Residential Stationary AC
¦ MVAC
Source: EPA (2020b).
a As of October 2019, HFCs are not being systematically recovered for destruction in the United
States.
As another example, Figure 14 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.
Figure 14. Quantity of HFCs Potentially Recoverable from Retired EU Equipment at EOL (2010-2050)
45,000
40,000
„ 35,000
I—
IE
ji) 30,000
2
I 25,000
o
o
* 20,000
_>>
76
| 15,000
o
10,000
5,000
0
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.
Mobile AC
Stationary AC
¦ Refrigerators/Freezers
i Commercial Refrigeration
i Refrigerated Transport
i Foams
2010 2020 2050
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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 2014b). 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 2017b). 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) 1013/2006, 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
2014b). 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.25
25 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).
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Appendix B: Resource Conservation and Recovery Act
In addition to the stratospheric ozone protection regulations for ODS under the CAA, several ODS and HFCs
are identified 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 and/or HFCs that meet the definition of hazardous waste.26 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 and HFCs
(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);27 or
• Wastes from specific sources (Code K).
However, the majority of ODS and HFCs 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."28 According to 56 FR 5913, this
exemption includes CFC and HCFC refrigerants.
Table 17 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 and HFCs may be considered hazardous wastes under RCRA.
26 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.
27 Any ODS-containing and HFC-containing waste must be characterized with respect to RCRA waste codes.
28 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."
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Table 17. RCRA Hazardous Waste Codes for Selected ODS and HFCs
Chemical Name
Hazardous Waste Codes
Ua
F
D
K
CFC-11 (Trichlorofluoromethane)
U121
F001F002
-
-
CFC-12 (Dichlorodifluoromethane)
U075
F001
-
-
Other CFCs and HCFCs
-
F001
-
-
CCI4
U211
F001
DO 19
-
Methyl Chloroform (1,1,1-Trichloroethane)
U226
F001F002
-
-
Methyl Bromide
U029
-
-
-
HFC-152a
-
-
D001
-
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 261.31:29
• 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 often 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. Unlike ODS substances, HFCs are not specified under waste
codes F001 and F002 as they are not "chlorinated fluorocarbons" and do not meet the classification criteria.
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 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:
29 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.
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• 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.30
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. No HFC substances are identified
under 40 CFR 261.33(e) and (f), and, therefore, HFCs are not classified as Code U hazardous wastes.
Code K (Wastes from Specific Sources)
ODS-contaminated wastes which may be generated from specific sources, such as the production of CCI4 or
pesticides, may be classified under several K waste codes (e.g., K016, K018, K021, K028, K029, K073, K095,
K096, K131, K132, K150). It is possible, but unlikely, that HFCs be classified under K waste codes as the specific
sources (e.g., organic chemical, metallurgical, and pesticide production processes) do not normally use or
produce HFCs, and any HFCs would likely be introduced as a contaminant to the process. 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.
Code D (Characteristic Wastes)
Code D includes wastes that exhibit any of the four characteristics—ignitability (D001), corrosivity (D002),
reactivity (D003), and toxicity (D004 through D043)—as described in 40 CFR 261.21 to 261.24. ODS and HFC
waste may classified under several D waste codes according to the waste-specific characteristics. The most
likely characteristics to apply to ODS or HFC waste are the toxicity characteristic (TC) and ignitability. HFC-152a
is designated a waste code D001 as it meets the characteristics of ignitability described in 40 CFR 261.21(a).
CCI4 is designated as waste code D019 if it has enough concentration under the Toxicity Characteristic
Leaching Procedure (TCLP) to be considered hazardous. That is, if an extract from a representative sample of a
solid waste contains a concentration of CCI4 equal to or greater than the regulatory threshold level of 0.5
mg/L, it is considered a hazardous waste. Additionally, used ODS or HFC contaminated with any of the other
Code D chemicals are considered hazardous wastes if an extract contains any of the contaminants listed in 40
CFR 261.24 at a concentration equal to or greater than the specified values, for example, ODS or HFC solvent
waste contaminated with metals from electronics or metal cleaning.
The Mixture and Derived-From Rules
According to 40 CFR 261.3(a)(2)(iv), any combination of a listed hazardous waste with non-hazardous waste is
defined as a listed hazardous waste. Even if a small amount of listed hazardous waste is mixed with a large
quantity of non-hazardous waste, the resulting mixture bears the same RCRA waste code and regulatory
status as the original listed component of the mixture. The mixture rule applies differently to listed wastes and
30 Unless the container is empty, as defined in 40 CFR 261.7(b). According to this section, "a container that has held a hazardous waste
that is a compressed gas is empty when the pressure in the container approaches atmospheric." Therefore, any heels in containers
that held ODS would most likely not be considered hazardous waste.
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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.
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Appendix C: Description of ODS and/or HFC 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) and UNEP (2018). Nine additional
technologies which may be suitable for ODS and/or HFC destruction but that have not been fully evaluated by
TEAP are also described. Of these, fixed hearth incineration is commonly used in the United States and air
plasma arc is used in an experimental facility in Sweden. In addition, conversion to vinylidene fluoride is also
described; however, it was determined this is not a destruction technology by TEAP (TEAP 2018a).
Thermal Oxidation (Incineration) 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.
Approved by the Parties of the Montreal Protocol
Reactor Cracking
CFCs and HCFCs are broken down or "cracked" into HF, H20, HCI, C02, and Cl2 in 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).
Liquid Injection 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.
Cement Kilns31
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
31 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."
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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).
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 2015b).
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).
Thermal Decay of Methyl Bromide
This technology, submitted to TEAP by one company in Australia, involves the capture and destruction of
methyl bromide, used as a fumigant, in a portable system (TEAP 2018). In this process, air containing methyl
bromide is fed into a diesel engine at a controlled rate where combustion occurs as a single pass destruction
step. During combustion, pressures and temperatures of about 60 atm and 2,600 °C, respectively, are
reached. After destruction of methyl bromide, the exhaust gases (e.g., HBr) are converted through a multi-
stage water-based scrubbing system into bromine salts (TEAP 2018b, STIMBR 2019). Once residual water and
particulate matter are removed, the airstream is vented to the atmosphere (STIMBR 2019).
Not Yet Approved by the Parties of the Montreal Protocol
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).
Electric Heater
Electric heater technology, from Japan, is intended for use in the destruction of HFCs. It is a flameless
combustion process in which HFCs are fed to a reactor with operating temperatures ranging from 900 °C to
1,200 °C. Exhaust gases from the reactor are then passed through a wet scrubber prior to release (TEAP
2018a). The 2018 TFDT indicates that Electric Heater has a high potential for HFC destruction (TEAP 2018a).
Furnaces Dedicated to Manufacturing
Furnaces dedicated to manufacturing were proposed as a destruction technology for HFCs when the
temperatures in the oxidation chamber were 1,200 °C or higher and when the HFC retention time was greater
than two seconds (in addition to other TEAP criteria); however, there is no concrete data on HF levels and
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furnace susceptibility to this byproduct. The 2018 TFDT indicates that there are insufficient data available on
this technology and as such, it is unable to be assessed (TEAP 2018a).
Non-Incineration Technologies
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.
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). Nine different types of plasma technologies are
described below.
Approved by the Parties of the Montreal Protocol
Argon Plasma Arc
Argon plasma arc technology uses an electric plasma torch such as the patented PLASCON™ torch to create a
3,000 °C plasma arc in the presence of argon to destroy ODS (TEAP 2018a). 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 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, argon plasma arc technology to destroy ODS (i.e., CFCs, HCFCs, and halons) as well as other
greenhouse gases (i.e., HFCs) was developed by SRL Plasma Ltd. and the Commonwealth Scientific and
Industrial Research Organisation (CSIRO). The argon plasma arc plant run by Cleanaway was commissioned by
the Australian National Halon Bank in 1996 for ODS destruction (Girgis 2018, Government of Australia 2020).
Other plasma arc facilities (supplied by SRL Plasma Ltd.) are located in Mexico, Japan, and the United States
(Girgis 2018, TEAP 2018a).
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 is one
unit known to be commercially destroying ODS in China (TEAP 2018a). Because of their compact size (9 m x
4.25 m), these units can be used as mobile destruction facilities (TEAP 2002).
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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 upwards of 6,000°C plasma, which is created using argon and microwave
energy, to break down CFCs into HCI, HF, CO, and C02 (TEAP 2018a). 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
reaction 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).
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).
Not Yet Approved by the Parties of the Montreal Protocol
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.
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 later 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 2015b).
Alternating Current Plasma Arc
Alternating current (AC) plasma technology is a process similar to that of ICRF Plasma technology; however,
AC plasma is produced directly with 60 Hz high-voltage power (TEAP 2018a). AC Plasma technology was
designed for hazardous waste destruction; however, a demonstration showed that CFCs were destroyed to
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non-detectable limits (TEAP 2002). The 2018 TFDT indicates that there are insufficient data available on this
technology and as such, it is unable to be assessed (TEAP 2018a).
C02 Plasma Arc
C02 plasma arc technology destroys ODS by injecting the substance directly to the plasma generation point at
over 5,000 °C and (TEAP 2018a). After ODS decomposition, in the reactor, the atoms are reacted with 02 and
the products (e.g., C02) are cooled to 70 °C (TEAP 2002). In this process, C02 produced is later used as the gas
which sustains the plasma and other exit gas is cleaned by conventional chemical scrubbing (TEAP 2018a). The
2018 TFDT indicates that there are insufficient data available on this technology and as such, it is unable to be
assessed (TEAP 2018a).
Conversion (Non-Incineration) Technologies
Non-incineration technologies are those that destroy substances via chemical transformation (TEAP 2018a).
Approved by the Parties of the Montreal Protocol
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.
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 H2 and C02
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, CHCIF2and 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).
Not Yet Approved by the Parties of 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
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2015b). 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.
Solid Alkali Destruction
In this process destruction of ODSs and HFCs occur via a vapor phase reaction using alkali metal vapor and/or
alkaline earth metal vapor in a heated reactor (TEAP 2018a). The 2018 TFDT indicates that there are
insufficient data available on this technology and as such, it is unable to be assessed (TEAP 2018a).
Not Approved by the Parties of the Montreal Protocol
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.
The 2018 TFDT concluded that the technology is not a destruction process but rather part of a chemical
manufacturing process (TEAP 2018b).
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Appendix D: Incinerability of HFCs
April 2021
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 constituents (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 18 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 18. 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,l,l- trifluoroethane
39
Lamb et. al, 2008
Stability Class III
CFC-113
1,1,2-Trichloro-l, 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, Greenhouse Gas Reporting Rule
Subpart L
U.S. EPA established procedures for fluorinated gas producers to report the destruction efficiency (DE) for
thermal oxidation destruction of fluorinated gases under Subpart L of the Greenhouse Gas Reporting Rule 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 2010b). EPA has determined
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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 DE 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 18). Therefore, for these other fluorinated GHGs, the
DE 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 19, and are similar to modeled Stability Class I and Stability Class II index rankings for these compounds.
Table 19. Modeled Required Temperatures to Achieve 99.99 Percent DRE for Fluorinated Compounds
Compound
Time
Required
Temperature
Index Ranking
seconds
K
0
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. 1
2010)
C2HCI2F3
2,2-Dichloro-l,l,l-
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)
74
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