Which of these may be released without violating the venting prohibition?

Pure nitrogen is one example. Carbon dioxide, nitrogen and water are exempt from the venting prohibition in any application. A few other substitutes are exempt only in the equipment the rule lists.

  • R-410A drained from a system before a coil change
  • R-134a from a disposable cylinder heel
  • Pure nitrogen used to pressure-test a line setCorrect answer
  • R-22 removed during an oil change

Why “Pure nitrogen used to pressure-test a line set” is correct

40 CFR 82.154(a)(1) lists substances exempt from the venting prohibition, including nitrogen in any application, carbon dioxide and water. Pure nitrogen used for a pressure test can be released. HFCs and HCFCs must be recovered.

Source: 40 CFR 82.154(a)(1)

Why the other answers are wrong

  • R-410A drained from a system before a coil change — R-410A is a non-exempt substitute; removing it before opening the system means recovering it, not venting it.
  • R-134a from a disposable cylinder heel — The heel of a disposable cylinder must be recovered, not vented.
  • R-22 removed during an oil change — Refrigerant in oil must be recovered; oil changes have their own pressure limit.

The source, word for word

Carbon dioxide in any application;
40 CFR 82.154(a)(1)(i)
Nitrogen in any application;
40 CFR 82.154(a)(1)(ii)
De minimis releases associated with good faith attempts to recycle or recover refrigerants are not subject to this prohibition.
40 CFR 82.154(a)(2)

The exemptions

Most of the list is tied to an end-use, so the same substance may be exempt in one appliance and not in another.

Exempt substitutes, 40 CFR 82.154(a)(1)
SubstanceExempt in
Carbon dioxide, nitrogen, waterAny application
AmmoniaCommercial or industrial process refrigeration, or absorption units
HydrocarbonsIndustrial process refrigeration that processes hydrocarbons
Propane (R-290), isobutane (R-600a), R-441AListed equipment such as household refrigerators and freezers
Ethane (R-170)Very low temperature refrigeration and non-mechanical heat transfer

De minimis is different

A de minimis release is not an exempt substance. It is a small loss of a regulated refrigerant during a good-faith recovery, while following the required practices with certified equipment and certification. The small loss when connecting hoses during proper recovery is an example.

Keep practicing

Answer checked against 40 CFR 82.154(a)(1)(i); 40 CFR 82.154(a)(1)(ii); 40 CFR 82.154(a)(2) 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.