Keeping cool

“On a scale of one to ten, where ten is knowledgeable, I would say zero.” That was the response of one air conditioning engineer when he was interviewed last month and asked how knowledgeable his customers were on their key obligations for maintaining refrigeration and air-conditioning (RAC) systems.

F gases
The EC “F gas” Regulation 842/2006 has applied since July 2007. This regulation concerns the use of fluorinated gases (F gases), which are powerful greenhouse gases. Most parts of the healthcare sector will be affected as the regulation covers much equipment used for chilling, freezing and air conditioning amongst other activities.
F gases are hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6). Typically HFCs are used in the Health sector as refrigerants in RAC systems; some examples of HFC refrigerants in common use and covered by the EC F gas Regulation are R134a, R404A and R410A.
The point of this European regulation is to reduce emissions of F gases by getting operators to gain better control over their use and, in particular, to try and reduce rates of refrigerant leakage. Today F gases have many diverse uses crossing almost all sectors of the UK economy, from Magnesium smelting through to use as a propellant in medical inhalers (MDIs) for asthma sufferers. Research undertaken on behalf of Defra  in 2007 found that stationary refrigeration and air-conditioning systems (as opposed to car air conditioning) is responsible for more than 25 per cent of the UK emissions of F gases and this makes it the largest single emitter of these gases.

Ozone-depleting substance
You may not have HFCs in many of your systems as older RAC systems often use R22, a hydrochlorofluorocarbon (HCFC), which is an ozone-depleting substance (ODS). This is due for phase out under the EC Ozone Regulation 2037/2000. Dates to note are: end of 2009 when virgin HCFCs can no longer be used for plant servicing and maintenance; and the end of 2014 from which recycled HCFCs can no longer be used for plant servicing and maintenance. For both these bans, the rule is it is a “use” ban so you cannot purchase material before the ban and stockpile it.
As the obligations in the EC Ozone Regulation for HCFC use in equipment are similar (but simpler) to those for the EC F gas Regulation and similar equipment is affected, expect more attention to be paid to checking compliance in the future.

Does size matter?
The simple answer is yes. In order to reduce leakage from systems containing F gases, the European Commission has prescribed a programme of maintenance activities requiring leak checking and record keeping for owners and operators of RAC systems. The frequency of leak checking activities depends on the refrigerant charge.
Table 1 shows the minimum activities required for different sized RAC systems containing F gases. Under the EC Ozone Regulation, systems containing 3 kg or more of ODS also require annual leak checking.
These activities must all be carried out by appropriately qualified technicians, be these in-house staff or contractors. Currently the set of qualifications introduced to satisfy the training requirements of the EC Ozone Regulation are the acceptable qualification under interim arrangements for those working on equipment containing 3 kg or more of F gases in Great Britain. However, new qualifications are currently under development by City & Guilds and the Construction Industry Training Board (CITB). All those working on RAC systems containing F gases will need to have the new qualifications by July 2011.
In addition to leak testing there are further requirements, again dependent on your system size, for ensuring containment of the refrigerant. These are summarised in table 2.
Finding out how much refrigerant a system holds may be no easy matter. If you’ve checked any attached labels, the instruction manual and commissioning records and you are still no wiser you may need some more help. Defra has published an advisory document about refrigerant charge calculation which suggests a number of ways of assessing the refrigerant charge in a system. The guidance comes with a spreadsheet to assist you to calculate the system charge .

Good News
Recent studies have suggested that this increased programme of maintenance will actually save companies money. The increased maintenance activity will ensure that RAC systems are actually operating with their correct refrigerant charge and this directly affects their energy efficiency. In addition, the increased maintenance regime should also mean that other aspects of the system are checked. For instance if the condenser has become blocked by dust, old bags or other items, this will also reduce efficiency.
We are working closely with the training suppliers to ensure that these areas are included in the regular checks. Overall we expect to see system efficiencies rise by between one and five per cent; and even at the one per cent level, this energy saving will more than cover the extra costs for increased maintenance for most large installations.

Like all good regulations the EC F gas Regulation comes with both benefits, reduced environmental damage and in many cases reduced energy costs, and with penalties for non-compliance. The related offences and penalties for failure to comply came into force in Great Britain on 15 February 2008 (discussions are ongoing as to the timing of the Northern Ireland regulations). Local Authorities will normally be the regulators at sites run by the Health sector and they will have full powers to demand to see evidence that the proper regime of check for leaks, recovered gas, record keeping and use of properly qualified engineers has been followed. Sanctions for non-compliance will ultimately be a matter for the courts although the regulators will look to help the operator comply in the first instance.

Defra recognises the significant culture change required in the UK to properly implement both the F gas and Ozone Regulations, despite the Ozone Regulation having applied since 2000. It has therefore established F-Gas Support which is a Government-funded team set up to help organisations understand their obligations under the EC Fluorinated Greenhouse Gases and Ozone Regulations. To achieve these aims, F-Gas Support has set up a Help Line, has compiled a number of information sheets to help users understand their obligations and is in the process of developing a website.
In addition, the F-Gas Support team will be working proactively with the largest emitters. The 2007 report on F gas usage in the UK highlighted that less than 200 organisations are responsible for 80 per cent of F gas emissions. F-Gas Support will be contacting these large F gas emitters to assist them provide a demonstration of commitment and engagement with these important environmental regulations.
Finally, F-Gas Support will also be working with local authorities and national regulators to promote compliance.

Table 1. Leak Testing Frequencies under EC F gas Regulation

Frequency  Normal systems  Hermetically sealed systems 
None  3 kg or more  6 kg or more 
Annual 3 kg to 30 kg  6 kg to 30 kg 
6-monthly*  30 kg to 300 kg  30 kg to 300 kg 
Quarterly*  More than 300 kg  More than 300 kg 

* Half this frequency if fitted with automatic leak detection

Table 2. Containment Obligations for Systems using F gas

Obligation for Stationary
RAC and Fire Protection Applications
Take steps to prevent F gas leakage
and repair detected leakage as soon
as possible
All stationary systems 
Regularly check for leakage   
Repair any leaks found and recheck for leaks within 1 month  Stationary systems 3kg
or more. For hermetic
systems 6kg* or more
Keep certain records about refrigeration plant that uses F gases  Stationary systems 3kg
or more. For hermetic
systems 6kg* or more 
Fit automatic leak detection system  Stationary systems above 300 kg 

* The threshold is 3 kg for most systems, but is increased to 6 kg for a “hermetically sealed system”.
This is defined as:“a system in which all refrigerant containing parts are made tight by welding, brazing
or a similar permanent connection which may include capped valves and capped service ports that allow proper repair or disposal and which have tested leakage rate of less than 3 grams per year under a pressure of at least a quarter of the maximum allowable pressure.”

The Next Steps

So in summary, you need to identify all the equipment you have on site containing F gases. Identify the proper maintenance regime and implement this regime using adequately qualified engineers. But don’t despair, the F-Gas Support helpline can help you identify the steps to take and a properly implemented regime should save you money through reduced energy bills in the long term.
F-Gas Support is being run on behalf of Defra and the devolved administrations by LACORS and the environmental consultancy Enviros. Further information about the regulations and the F-Gas Support team's role can be can be found at: . The F-Gas Support team are working with ACRIB (Air Conditioning and Refrigeration Industry Board) to provide support to its members are others that are affected by F-gas regulations.