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7 <br />DECEIVED 0 <br />MAY 18 2015 RECEIVED APR 16 2015 <br />RAf0T,6' ftC0VERY`' <br />In conducting refrigerant abatement, we follow all rules as set forth in Section 608 of the Clean Air Act, <br />including, but not limited to the following: <br />All technicians and equipment used to recover used refrigerants are EPA certified. All recovered <br />refrigerants are consolidated into batch quantities and shipped to EPA certified reclaim facilities for final <br />processing. <br />o Technicians are certified through The ESCO Institute, an independent certifying authority. You <br />may learn more about ESCO online @ http://www.escoinst.com/. <br />o Equipment is certified through ARI (Air -Conditioning and Refrigeration Institute) in conjunction <br />with Intertek. You may learn more about ARI & Intertek online by accessing their web pages; <br />http://www.ari.ore/ & http://www.intertek.com/ respectively. <br />o We utilize many certified reclamation facilities throughout the country. A full list of certified <br />reclamation facilities can be found at the following web address: <br />http://www.ei)a.gov/Ozone/titic6/608/reclamation/reclist.html <br />• Refrigerants that we recover are recovered into DOT approved and certified recovery cylinders for <br />transport. A full list of DOT authorized hydrostatic testers is available on-line at <br />http://hazmat.dot.gov/sp app/approvals/hydro/hydro retesters.htm. <br />Refrigerants that we remove, along with the refrigerant oils that make up a small percentage of the materials we <br />remove, are not hazardous waste. Below, please find an excerpt from the Clean Air Act Summary and the web <br />site from which it was taken stating that refrigerants and refrigerant oils are not hazardous waste. <br />From the Clean Air Act Summary hfp://www.epa.gov/ozone/title6/608/608fact.html#hazwaste: <br />"Hazardous Waste Disposal <br />If refrigerants are recycled or reclaimed, they are not considered hazardous under federal law. In <br />addition, used oils contaminated with CFCs are not hazardous on the condition that: <br />They are not mixed with other waste. They are subjected to CFC recycling or reclamation. They are not <br />mixed with used oils from other sources. <br />Used oils that contain CFCs after the CFC reclamation procedure, however, are subject to specification <br />limits for used oil fuels if these oils are destined for burning." <br />Individuals with questions regarding the proper handling of these materials should contact EPA's RCRA <br />Hotline at 800-424-9346 or 703-920-9810. <br />An Independently Owned and Operated Franchise Company <br />REFRIGERANT ABATEMENT EXPERTSO <br />