An Overview of the F-Gas Regulation Proposals


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By now you should have an appreciation of F-Gas regulations and what it means to you. But in case you don’t, here’s a quick overview in relation to leak detection.

Why have the F-Gas regulations come into force?

Fluorinated greenhouse gases (F-Gases) are potent greenhouse gases that contribute to global warming and are sometimes referred to as High Global Warming Potential Gases (High GWP Gases) if released into atmosphere.

The EC F-Gas regulations were brought into action in July 2007, as part of the Kyoto Protocol to reduce emissions of greenhouse gases (GHG) because of their high GWP. Actions to contain, prevent and reduce emissions of F-Gases are being taken by the European Union as part of its obligations under the Kyoto Protocol.

The European Union has a binding target to cut carbon emissions by 20 per cent by 2020 and non-binding targets to cut greenhouse gas emissions by 80-95 per cent by 2050.

What are F-Gases and where are they used?

Fluorinated greenhouse gases (F-Gases) are a group of chemicals containing fluorine. There are three main types of F-gases:

  1. Hydrofluorocarbons (HFCs)
  2. Perfluorocarbons (PFCs)
  3. Sulphur hexafluoride (SF6)

In total, F-gases account for 2% of all greenhouse gases in the EU today but have a much more potent atmospheric warming potential than CO2. They are used in a variety of refrigeration and air-conditioning equipment, in insulation foams and electrical equipment, in aerosol sprays, as solvents or in fire protection systems.

Emissions occur mainly during emissive uses (of aerosol sprays or solvents for example) or due to leakage during the operation and disposal of products and equipment that contain F-gases.

Do we have a responsibility to reduce F-Gas emissions?

When you consider that since 1990, CO2 equivalent emissions within the EU have reduced by 18% overall but F-Gas emissions have increased by 60% in the same time, it is not difficult to see why this particular area has received such intense focus.

The cost of leak detection is partly due to the result of complying with legislation. Legislation that was introduced because of the harm that HFC's and CO2 can pose to our environment, resulting in climate change.

What other benefits does compliance to F-Gas bring?

Reducing F-Gas emissions should not only be thought of as just complying with legislation for the overall objective of achieving government set targets, but will only have a positive effect on operating costs, making cost savings through efficient operation and foremost, it can help enhance market reputation by being appearing to be more environmentally friendly. We’ll discuss this later.

How can we reduce our F-Gas emissions?

There has been much discussion surrounding F-Gas emission reduction and the most practical methods in doing so. Here we discuss the options available.

1. HFC Emission Reduction

One theory is to use low or very low GWP refrigerants. The refrigeration industry is being ‘encouraged’ to move towards a HFC free market and use of low GWP refrigerants. For many people, this is an ideal solution as many of these refrigerants have a GWP score of less than 10, however there are constraints with using these gases, with flammability being one.

2. Leak Detection Programme

Refrigerant gas leakage to the atmosphere can result in product loss, causing systems to operate inefficiently and is detrimental to the environment. Many refrigerant gases can cause depletion of the ozone layer therefore it is imperative that your gas leak detection equipment identifies these possible leaks. The F-Gas regulations have a greater emphasis on leak detection and we’ll discuss this option further.

How does the F-Gas Regulations impact leak detection?

Under the F-Gas regulations, system and equipment operators have a legal obligation to:

Prevent leakage - If you operate stationary refrigeration or air conditioning systems, where it is technically feasible, you must prevent leakage of F-Gas refrigerants, and repair any discovered leaks as soon as possible.

Frequent leak checks – The frequency of leak checks depends on the type of system and the quantity of F-Gas refrigerants used.

The following table illustrates the frequency of leak testing in normal and hermetically sealed systems depending on refrigerant charge.

Systems shall be checked for leakage dependent on refrigerant charge:

  • 3kg charge and above - check at least once every 12 months
  • 30kg charge and above - check at least once every 6 months
  • 300kg charge and above - check at least once every 3 months
  • Hermetically sealed systems, which are labelled as such and contain less than 6kg, are exempt

Under the current F-Gas regulations, it is mandatory for sites with an overall refrigerant charge in excess of 300kg to install a fixed refrigerant leak detection system. This system must be leak checked once per year.

You will need to maintain records of all refrigerants within your equipment with a charge of 3kg or more (if hermetic, 6kg or more). You must keep detailed service records for equipment containing a charge of 30kg or more.

November 2012 saw a review proposal of the F-Gas regulations. So what does this mean for leak detection?

The new F-Gas regulation was published and presented to delegates at the Atmosphere 2012 conference in Brussels on 7th November 2012 includes some significant changes to the existing regulation and has far reaching implications for the European Refrigeration & Air Conditioning Industry.

The new proposal contains a range of measures to reduce emissions of HFCs, including a cap and phase down of 79% by 2030, and bans on use of HFCs in hermetically sealed commercial systems and other applications.

The EU Low Carbon Economy Roadmap shows that, in order to achieve this objective at the lowest cost, all sectors and greenhouse gases must contribute including F-Gases whose global warming potential can be up to 23,000 times more potent than carbon dioxide (CO2).

The much anticipated regulation changes aim to strengthen the existing F-Gas regulation, apply the regulation to new areas (transport refrigeration) and ‘encourage’ the industry to move towards a HFC free market and use of low GWP refrigerants.

In addition to the well publicised phase down schedules for HFCs, quotas for supply of HFCs into the EU market, training & certification requirements for ‘natural’ refrigerants and banning of pre-charged equipment, the proposed regulation has significant implications with regard to obligations for leak checking.

What is the GWP concept under the new regulations?

The intention is to put all GHG onto a common scale and GWP, however imperfect, remains the recommended metric to compare future climate impacts of emissions of long-lived gases.
Under the existing regulation, a site would simply have to calculate what Kg charge they had, to know what leak detection frequencies/requirements applied. Under the new proposal, they now have to factor in the GWP and make a calculation relative to CO2 equivalent emissions.

This will undoubtedly complicate things for many site operators who will be asking ‘how do we calculate how frequently we need to check for leaks’? And ‘we didn’t need to have fixed leak detection under the existing regulations; do we need it under the new F-Gas regulation’?

Let’s take R404a as an example – for companies trying to work out if they require a fixed leak detection system, under the proposed F-Gas regulations, systems using R404a would take the figure 500 (tonnes) then divide by 3920 (GWP CO2 equivalent). To get the total Kg amount, multiply by 1000. If this figure is greater than 130kg, then a fixed system is required. In addition, a leak check is mandatory every 3 months.

How are the F-Gas regulations enforced?

Compliance is policed by the Environment Agency and Local Authorities. The UK Government has issued a draft statutory instrument laying out the proposed penalties associated with non compliance with the F-Gas Regulations. Powers have been proposed for enforcement authorities to serve enforcement and/or prohibition notices and fines on those not adhering to the F-Gas regulations, specifying action that must be taken.

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