28/01/2019
If you have systems that contain with a GWP above 2500 & charge size above 40 Tonnes CO2 Equivalent (t CO2-equiv) within your portfolio, and have not defined a refrigerant management strategy for your businesses you have less than 12 months.
**I'm Not Sure If My Site Is Impacted**
If you are unsure check your FGas Refrigerant Log Book asset register.
Every site that contains , & systems that contain FGas Refrigerants above 5t CO2-equiv require an FGas Log Book.
The FGas Log Book should contain many sections such as Legal Operator, Service Provider, FGas Registration Certificates, Waste Transfer Certificates, FGas Systems Asset Register, FGas System Leak Test Frequencies and FGas System Report Sheets.
Within the FGas System Asset Register section it should show each systems Refrigerant Classification, GWP and full system charge in KG so the t CO2-equiv can be documented e.g. R404a, GWP 3922, 10.2kg = 40t CO2-equiv.
Q1 - Where can I find my FGas Refrigerant Log Book
FGas Log Book Records need to be kept for 5 Years following the commissioning of any system by both the legal operator and internal/external service provider. In the absence of historic records contact your current/previous service providers and they should be able to provide you with supporting documentation. This information can then be used to develop a new FGas Log Book and reduce the risk of potential Civil Penalties up to £200,000.
Q2 - What happens if I cannot find any FGas records
Make arrangements for the systems to have an FGas Compliant Refrigerant Leak Test as soon as possible. Systems that contain FGas Refrigerants above 5t CO2-equiv are required to have regular FGas Refrigerant Leak Tests to reduce the impact they have on our environment. The minimum frequency is dependant on each systems refrigerant charge measured in t CO2-equiv as follows:
5t CO2-equiv = 1 Visit every 12 Month
50t CO2-equiv = 1 Visit every 6 Months
500t CO2-equiv = 1 Visit every 6 Month and Fixed Leak Detection System Fitted
Exceptions to this are Hermetically Sealed Equipment:
Hermetically sealed equipment containing less than 10 tonnes of CO2-eq of fluorinated greenhouse gases are exempted from regular leak check provided the equipment is labelled as being hermetically sealed.
Typical examples are self contained factory made systems such as 'Portable, Window mounted, Through the Wall and Packaged Terminal Unit Air Conditioning', and 'Refrigerated Ice Cream Freezers, Bottle Coolers, Stand Alone Retail Displays'.
Q3 - What should I do if I have systems inmpated by the 2020 FGas refrigerant service ban
For systems containing FGas Refrigerants with a GWP above 2500 & Refrigerant charge size above 40 Tonnes t CO2-equiv the industry will only be able to purchase refrigerant through distributors that has been Reclaimed, following being sent away for Reprocessing back to a Virgin Refrigerant equivalent standard such as AHRI 700 until 2030.
Alternatively, the same Reclaimed FGas Refrigerant can be used by the same client only on different refrigeration systems they own.
Relying on either Reclaimed or Recycled FGas Refrigerants are both high risk approaches. Reclaimed Refrigerant availability cannot be guaranteed as shown by comparing how the current FGas Refrigerant price increases and availability have impacted by the reduction of FGas Refrigerant market quotas. Recycled FGas Refrigerants are not converted back to equivalent AHRI 700 standard which may effect system performance efficiency, and there is an increased risk of cross systems contamination.
Some alternative options to consider are:
-Refrigerant Banking
-Replacement of the Systems with more Environmentally Energy Efficient Equivalents
-Contingency Planning
These are just some of the things sites need to consider within their OPEX and CAPEX budget forecasts as January 2020 approaches.
Contact us to learn more about our services throughout Surrey and the South East.
