Last reviewed 13 January 2015
This month — January 2015 — marks the next stage in the phase-out of ozone-depleting substances from stationary refrigeration and air-conditioning systems (RACS), when the use of recycled or reclaimed hydrochlorofluorocarbon gases to service RAC equipment will no longer be permissible. Mike Sopp explains the position.
This latest milestone in EU legislation aims to prevent damage to the environment from ozone-depleting substances and fluorinated gases that are commonly used in RAC systems.
For the user of such systems, compliance with legislative requirements calls for good management and the consideration of cost-effective phase-out solutions for older RAC systems that still utilise hydrochlorofluorocarbons (HCFCs).
Refrigeration and air-conditioning systems are widely used in all parts of the economy including food retail, office buildings and manufacturing.
The refrigerants used in such systems are often hydrofluorocarbons (HFCs), which are powerful greenhouse gases (F-gases) or hydrochlorofluorocarbons (HCFCs), which are ozone-depleting substances (ODS).
Both therefore have the potential to cause damage to the environment and historic data suggests that RAC systems have given rise to significant emissions through leakage during normal use and venting during maintenance or at end of life. As a result, various EU directives and regulations have been introduced including:
Regulation (EC) No. 842/2006,which aims to reduce emissions of HFCs
Regulation (EC) No. 1005/2009, which aims to phase out the use of ozone-depleting chemicals.
Compliance with the regulations normally falls upon the person having control of the relevant equipment (the operator), who is defined as “the natural or legal person exercising actual power over the technical functioning of the equipment and systems covered”.
In effect, this includes having free access to the system, control over the day-to-day functioning/running of the system and powers to decide on technical modifications.
The respective pieces of legislation contain numerous obligations, which can be summarised as follows.
Taking steps to prevent leakages and to repair detected leaks as soon as possible.
Undertaking regular checks for leakage based upon certain threshold limits.
Recovery of substances during plant servicing, maintenance and at end of life.
Using appropriately trained personnel to undertake servicing, maintenance and leakage checks.
Labelling and keeping of appropriate records.
In addition to the above, F-gas requirements include the fitting of automatic leak detection to systems and the holding of appropriate certification.
Additional ODS requirements include the stopping of the use of virgin HCFCs (from 31 December 2009) and recycled/reclaimed HCFCs (from 1 January 2015).
It should be noted that the bans refer to the “use” for servicing and maintenance. As such, it will “remain legal to continue using RAC equipment containing HCFCs beyond the phase-out dates providing they do not require maintenance that involves putting any HCFCs back into a system”.
With such numerous obligations, those deemed to be operators of systems need to take a number of steps to ensure such obligations are being met.
The first stage is to determine if the regulations apply and to what extent, by identifying whether HCFC/HFC refrigerants are used and if there are any operator compliance responsibilities. A key aspect of this is the estimate of refrigerant charge as this affects how the regulations will be applied.
It is worth noting that even where a contract exists with a third party, unless all the powers detailed above are transferred, the owner will usually be deemed to have responsibilities — but this should be determined by making reference to contracts as well as lease agreements.
Government guidance recommends the development of an inventory of relevant equipment, stating that “it is sensible to give each piece of equipment a unique identification” recording its location, type/quantity of refrigerant and whether the system is hermetically sealed.
Government guidance makes particular mention of “rogue” plants because data suggests that 80% of all leaks come from 20% of systems, with the guidance suggesting that “it is worth investing effort to improve these plants”.
Practical guidance on the prevention/reduction of leaks is available from the Institute of Refrigeration, the aim being to assist in the reduction of carbon emissions, for example by purchasing leak-tight equipment.
Once it is determined that obligations exist, the operator should allocate roles and responsibilities, including nomination of a Director to have overall responsibility. Operational matters can then be addressed in terms of:
setting up a record-keeping system that enables legally required data to be kept and regularly updated
ensuring that relevant personnel are appropriate qualified; both in-house and contractors and, where applicable, “company Certification” is held
ensuring that a programme of leak tests are completed (six-monthly or annually as required) and that an appropriate system exists for undertaking repairs on leaking systems within the timescales detailed in legislation
ensuring that plant with more than 300kg of F-gas is fitted with automatic leak detectors.
Although record keeping only applies to systems above threshold levels, it is “prudent to include all systems in your records”.
In respect of qualifications, the level and type of qualification is influenced by the system type and activity being undertaken (eg leakage check, recovery and installation maintenance).
Government guidance states that most RAC systems, to a certain degree, will leak, which in practical terms “implies that any equipment that is of strategic importance to a business should not be using HCFCs by 2015”.
Users of systems are advised to develop strategic plans that look at the phase-out of HCFCs as “doing nothing is not a sustainable option”. The phase-out strategy includes:
identifying systems containing HCFCs and assessing the business risk
prioritising the most business-critical systems for action
determining the phase-out solution, assessed against various decision criteria
planning, budgeting and implementation
managing the use of recycled/reclaimed HCFCs.
When determining the most appropriate phase-out option, government guidance suggests a number of criteria. This will include the system type, age, condition and operational performance. Other factors are the energy efficiency of new systems and the logistics of replacing older systems that may be “embedded” into the building fabric.
In terms of phase-out options, solutions are based upon the following options.
To replace the whole plant with new system, which may incur expensive initial costs but give longer-term cost effectiveness in terms of energy efficiency and reduced leakage.
To convert the refrigerant to a suitable alternative, which may be cheaper but may result in reduced operational performance.
To delay or do nothing until the system has reached its end of life, which may be a cheaper short-term option but still retains leakage risks.
If selecting alternative refrigerants, the operator must give consideration to the various advantages and disadvantages. HFCs, eg, are widely used and are non-toxic but have what is known as a high “Global Warming Potential (GWP)”. Conversely, refrigerants such as ammonia, CO2 and hydrocarbons have a low GWP but can be toxic, flammable and offer poor energy efficiency.
With RAC systems accounting for a large percentage of an organisation’s overall carbon footprint, energy efficiency is a key factor to be considered when looking to phase out options.
The Energy Performance in Buildings Directive applies to all buildings with a footprint of 500m2 and requires an assessment to be made of the efficiency of air-conditioning systems. As such, phase-out provides a good opportunity to address this issue and improve RAC energy efficiency.
Government guidance on managing fluorinated gases and ozone-depleting substances can be found at www.gov.uk