Coordinator: Lawrence Falkin, CHMM

Business Title: Assistant Director for Environmental Compliance

Contact Information:
City of Kansas City
324 E. 11th St.
18th floor
Kansas City, MO 64106
Phone: 816 513 3456
Fax: 816 513 3471
E-mail: larry_falkin@kcmo.org

Biography: For the past five years, Lawrence Falkin has been the manager of the Environmental Compliance Program for the City of Kansas City, MO. In this capacity, he functions as an in-house consultant to assure that all of the City's Departments are practicing good environmental stewardship. Mr. Falkin has spearheaded the development and implementation of an Environmental Management System for the City of Kansas City, and oversees the performance of more than 150 environmental audits of city facilities each year.

Prior to working for Kansas City, Mr. Falkin served for 3 years as President of ECOCorp, a non-profit group specializing in citizen suit enforcement of RCRA. From 1986 to 1992, Mr. Falkin worked for the U.S.EPA, including 2 years as Chief of RCRA Enforcement for EPA Region 3.

Mr. Falkin holds a BA from the State University of New York at Binghamton and a JD from Pace University.
Title of Presentation: Scrap Appliances Containing Refrigerants: A Municipal Challenge

Author: Lawrence Falkin, CHMM

Key Words: refrigerants, appliances, municipalities

Abstract:
Objective and Scope - Every year, millions of households across the country replace refrigerators, air conditioners, and other appliances containing refrigerants. Typically, the job of collecting and properly managing these scrap appliances falls on the municipal government. This presentation will identify environmental concerns and regulatory requirements applicable to the management of scrap appliances, and discuss some of the procedures being used in Kansas City to manage these items appropriately.

Issues
· Appliance handling prior to CFC recovery - How can CFC releases be minimized?
· CFC Recovery - What does the Clean Air Act require? Should this activity be in-house or out-sourced?
· Compressor Oil - How do you get it out? What do you do with it?
· Scrap Metal Recycling - Are the returns worth the effort?

Developments
1) EPA has taken an active interest in municipal handling of appliances with refrigerants. Inspections, information requests, and enforcement actions have all focused on this issue. Incidental releases during transport have been a major focus.
2) Municipalities have taken a variety of approaches, from curbside CFC recovery, to CFC recovery at a dedicated site, to contracting with a landfill operator to have the landfill recover the CFCs prior to disposal. Kansas City has tried all of these approaches, and has tried overhead booms, appliance dollies, and muscle power to load and unload appliances.
3) Most scrap metal recyclers will only accept appliances if the compressors and compressor oils have been removed. While no law requires the removal of compressors or compressor oil from the appliance, Kansas City has found it desirable to do so because it enables sale of the scrap metal and avoids landfilling costs. The compressor oil, once drained from the compressor, is regulated as an off-specification used oil (due to high chlorine content).

Conclusions
1) Scrap appliances with refrigerant require more attention than most municipalities have devoted to them.
2) The CFCs and compressor oils found in scrap appliances raise important environmental and legal concerns.
3) The approach that works best in Kansas City is labor intensive, but maximizes material recovery, minimizes costs, and assures compliance.