Leak Testing & F-Gas Regulations Explained

Overview of Current and Future Legislation

• 31st October 2014 – The European Commission will allocate each producer or importer of HFC’s or equipment containing HFC’s an annual marketing quota, which will gradually decrease until 2030.
• 1st January 2015 – The introduction of a CO2 equivalent HFC phase-down. The global quantity of HFC’s placed on the market in Europe by 2015 will be the average of quantities placed on the market between 2009 and 2012. By 2030, 21% of this volume could still be placed on the market.
• 1st January 2020 – New systems cannot be charged with a refrigerant having a GWP rating of 2,500 or more.

The use of F-Gases with a global warming potential (GWP) of greater than 2500 (R404A is 3,920), to service or maintain an application with a charge greater than 40 tonnes of CO2e (12.3kgs R404A), shall be prohibited from 1st January 2020 (except for equipment whose temperature is <-50oC ).
There is an exclusion that allows recycled or reclaimed gas to be used until 2030, but the supply volume and price may be volatile dependent upon demand.

• 1st January 2022 – Ban on refrigeration units (2 or more parallel compressors) whose power is >40 kW and containing HFC’s with a GWP >150. This ban will not apply to primary centralised cascade refrigeration systems where the fluid has a GWP < 1,500 (medium temperature systems to which one or more refrigeration systems are connected for cooling their condenser(s).

Leak Detection

One of the requirements of the new regulations relates to leak check requirements, which are based upon the GWP CO2 equivalent tonnes. The new regulations set leak check requirements based upon 5, 50 and 500 CO2 equivalent tonnes.

The implementation of such a method results in the threshold level for leak checking differing depending on the GWP of the refrigerant that is used (refer to table).

The following leak inspection regime will be applied from the previously aforementioned data:

• For an installation whose charge is <5 T equivalent CO2: No leak check requirement under the revised F-Gas regulations, however it is recommended for the longevity and efficiency of the equipment that a routine maintenance regime is in place
• For an installation whose charge is 5-50 T equivalent CO2: Every 12 months or (24 months if there are fixed leak detection devices fitted with an alarm sent to the operator).
• For installations whose charge is 50-500 T equivalent CO2: Every 6 months or (every 12 months if there are fixed leak detection devices fitted with an alarm to the operator).
• For an installation whose charge is >500 T equivalent CO2: Every 6 months with mandatory fixed detection devices fitted with an alarm to the operator.

Annual Leak Check Thresholds

Common Refrigerants

For example; system operating on R134a with a charge of 100kg:

This falls in the category >50 T equivalent CO2 as this category is for R134A refrigerant charges greater than 35kg, but less than 349.7kg.

Therefore, the inspection regime should be every 6 months, or every 12 months, if there is a fixed leak detection system fitted with an alarm to the operator.

Record Keeping

Operators of equipment with more than 5T CO2e of refrigerant are required to maintain records detailing quantity and type of refrigerant in the equipment installed on site, dates of leak checks, as well as dates and quantities of subsequently added or recovered refrigerant.

If the installed refrigerant gas has been recycled or reclaimed, you must be able to show the name and address of the recycling/reclamation facility and their certificate number. There is also a requirement to be able to identify the technician who carried out the work, and keep records of their certificate number, and that of any companies used to install, service or decommission your equipment.

These records must be kept for 5 years, and these documents must be available upon request to the competent authority. In England and Wales this is the Environment Agency and in Scotland, the Scottish Environment Protection Agency.

Reduction of HFC’s on the Market

The supply of HFC’s to the marketplace will be controlled through the issuing of quotas to those companies that place HFC’s on the market. These quota’s will be based on freezing the supply levels at the average of 2009 to 2012 levels from 1st January 2015 and reducing steadily, eventually to 21% of the 2012 level by 2030.

The Montreal and Kigali protocols are having a significant impact of the usage of refrigerants. The impact of this is that refrigeration systems going forwards should be installed using minimised refrigerant charges and should use refrigerants with the lowest possible global warming potential (GWP).

Whilst the next ban is on high global warming potential refrigerants (>2,500 CO2 equivalent). From discussions with the refrigerant manufacturers, it has become apparent that certain refrigerants may fall into an unofficial group in the following years, this group being legal to use but with limited availability from the manufacturers.

The reason behind this unofficial group is the global commitment to reduce CO2, specifically in this case by the manufacturing quotas imposed on the refrigerant producers.

Globally the production of refrigerants from 1st January 2018 have been (and will be) subject to ever tightening restrictions with the total quantity of refrigerant being based on the equivalent amount of CO2 that the total production relates to; i.e. if a manufacturer has a limit of 2,500 kg’s that is can produce this would allow them to either produce 1kg of a refrigerant that has a GWP of 2,500 or 10kg’s of a refrigerant that has a GWP of 250.

Taking this into account the cost for the higher GWP refrigerants going forward are anticipated to increase significantly as the manufacturers would look to make the same profit on a single kilogram of a higher GWP refrigerant that they would on the equivalent multiple kilograms of the lower GWP refrigerants. Thus, the requirement for refrigeration systems to utilise the lowest global warming potential refrigerant that is possible for the application.

Entering into a Service and Maintenance contract with us will provide the necessary documentation to ensure you are meeting the requirements of the F-Gas Regulations as an end user/operator. If you require further information regarding F-Gas Regulations, then please do not hesitate to contact me or log on to the DEFRA website (www.defra.gov.uk).