A crew is tearing out an old R-22 rooftop unit for scrap. What does the venting prohibition require of them?

Yes. The venting prohibition names disposal along with maintenance, service and repair, so a crew scrapping a rooftop unit has to recover the refrigerant rather than release it.

  • Nothing, because disposal is not servicing
  • Release the refrigerant slowly outdoors
  • Recover the refrigerant instead of releasing itCorrect answer
  • Ask the owner to sign a venting waiver

Why “Recover the refrigerant instead of releasing it” is correct

The venting prohibition covers disposal as well as service. Anyone disposing of an appliance may not knowingly release its refrigerant, and equipment dismantled on site must have its refrigerant recovered before disposal.

Source: 40 CFR 82.154(a); EPA: Safe Disposal Requirements

Why the other answers are wrong

  • Nothing, because disposal is not servicing — The rule names disposal along with maintenance, service and repair.
  • Release the refrigerant slowly outdoors — Releasing slowly is still knowingly venting.
  • Ask the owner to sign a venting waiver — No owner waiver allows refrigerant to be vented.

The source, word for word

must have refrigerant recovered in accordance with EPA's requirements for servicing prior to their disposal.
EPA: Safe Disposal Requirements
Before opening appliances (except small appliances, MVACs, and MVAC-like appliances) or disposing of such appliances, technicians must evacuate the refrigerant, including all the liquid refrigerant, to the levels in Table 1
40 CFR 82.156(a)

Two paths at disposal

EPA splits equipment by how it reaches the end of its life, and the duty falls in a different place for each.

From EPA: Safe Disposal Requirements, 40 CFR 82.155 and 82.156
EquipmentWho actsWhat is required
Dismantled on site, such as chillers, central air and retail food refrigerationThe technicianEvacuate to Table 1 with certified equipment before disposal
Reaches the waste stream with its charge intact, such as household refrigerators and window unitsThe final processorRecover what remains, or verify it was recovered

After recovery

Between 5 and 50 pounds of full charge, the technician keeps disposal records for three years. Scrapping the unit does not change what can happen to the refrigerant, and emptying the cylinder later is still venting.

Keep practicing

Answer checked against EPA: Safe Disposal Requirements; 40 CFR 82.156(a) on .

Unofficial, not affiliated with the EPA or any EPA-approved certifying organization. Questions are original practice written from public EPA material, not real exam questions.