Art. 3-6 : Leakage prevention during use, incl. record keeping

Article 3-6 of the F‑Gas Regulation sets out the requirements on the operator of equipment containing certain fluorinated greenhouse gases during use.

General Overview of requirements

The end users of refrigeration or air conditioning equipment are responsible for complying with the F‑Gas Regulation because they are the “operator” of the system. The aim is to reduce leakage of HFC refrigerants. The F Gas regulation also provides a minimum standard for leak testing and training of personnel handling refrigerants. It states that the operator shall take all precautions that are technically and economically feasible to minimise unintentional release (leakage) of fluorinated greenhouse gases.

Why minimise leakage?

Minimising leakage through refrigerant containment is a priority for everyone who designs, builds, uses or maintains refrigeration or air-conditioning equipment. If we want to continue to have the best choice of refrigerants from which to select in the future we must ensure that refrigerant is contained within the equipment. If the refrigerant is contained within the equipment its environmental impact is negligible. But if allowed to leak to atmosphere it is a significant contributor to global warming. Refrigeration equipment which are allowed to continue to leak are also likely to be less energy efficient, resulting in additional indirect CO2 emissions at the level of the electricity generating plant, along with higher running costs.

Article 3 of the F‑Gas Regulation sets out the general principles:

  • It is prohibited to release the fluorinated greenhouse gas unless it is technically necessary for the intended use.
  • The operator of equipment containing fluorinated greenhouse gases shall take all precautions that are technically and economically feasible to minimise unintentional release (leakage).
  • When leakage is detected the operator shall ensure the equipment is repaired and the leak stopped without undue delay. For certain equipment requiring routine leak checks the repair shall be tested one month after repair.
  • Persons undertaking work on equipment containing fluorinated greenhouse gases shall be certified in accordance with Article 10.

Article 4 of the F‑Gas Regulation dictates to when and how often leak checks are required on equipment contained fluorinated greenhouse gases. The types of equipment included are:

  • stationary refrigeration equipment;
  • stationary air-conditioning equipment;
  • stationary heat pumps;
  • stationary fire protection equipment;
  • refrigeration units of refrigerated trucks and trailers;
  • electrical switchgear;
  • organic Rankine cycles.

A cut off below which leak checks are not required includes:

  • Equipment containing less than 5 tonnes of CO2 equivalent of fluorinated greenhouse gases (10 tonnes of CO2 equivalent for hermetically sealed equipment).
  • Electrical switchgear that
    • has a tested leakage rate of less than 0,1 % per year;
    • is equipped with a pressure or density monitoring device; or
    • contains less than 6 kg of fluorinated greenhouse gases.

The new F‑Gas Regulation sets leak checking requirements based upon 5, 50 and 500 tonnes of CO2 equivalent. With the most significant changes affecting high GWP refrigerants for the 500 tonnes of
CO2 equivalent as fixed leak detection is required for this threshold. The new requirements took
effect from 1st January 2015, except for systems with a charge below 3kg (6kg for hermetic
systems) where it will apply from 1st January 2017.

Table 1 Leak detection Requirements

RAC System size With leak detection system installed Without leak detection system installed
5 tonnes ≤ CO2 equivalent < 50 tonnes At least every 24 months At least every 12 months
50 tonnes ≤ CO2 equivalent < 500 tonnes At least every 12 months At least every 6 months
≥ 500 tonnes of CO2 equivalent At least every 6 months At least every 3 months

Table 2 Translation of the new tonnes of CO2 equivalent limits to kg of common refrigerants

Fluorinated Greenhouse Gas GWP under the F Gas Regulation Mass of fluorinated greenhouse gas (kg)
5 tonnes of CO2 equivalent 50 tonnes of CO2 equivalent 500 tonnes of CO2 equivalent
R23 14800 0.34 3.4 34
R32 675 7.41 74.1 741
R404A 3922 1.27 12.7 127
R407A 2107 2.37 23.7 237
R407D 1627 3.07 30.7 307
R407F 1825 2.74 27.4 274
R410A 2088 2.39 23.9 239
R507 3985 1.25 12.5 125
R508A 13214 0.38 3.8 38
R508B 13396 0.37 3.7 37

Article 5 of the F Gas Regulation

Article 5 of the F Gas Regulation requires equipment containing more than 500 tonnes of CO2 equivalent of fluorinated greenhouse gases to provide a leakage detection system which alerts the operator or a service company to the leakage. The leakage detection systems should be checked at least once every 6 or 12 months depending on the type of system.

Article 6 of the F Gas Regulation requires that operators of equipment requiring leak checks under Article 4 must keep adequate records. These records include:

  • The quantity and type of fluorinated greenhouse gases installed;
  • The quantities of fluorinated greenhouse gases added during installation, maintenance or servicing or due to leakage;
  • Whether the quantities of installed fluorinated greenhouse gases have been recycled or reclaimed, including the name and address of the recycling or reclamation facility and, where applicable, the certificate number;
  • The quantity of fluorinated greenhouse gases recovered;
  • The identity of the undertaking which installed, serviced, maintained and where applicable repaired or decommissioned the equipment, including, where applicable, the number of its certificate;
  • The dates and results of the checks carried out under Article 4(1) to (3);
  • If the equipment was decommissioned, the measures taken to recover and dispose of the fluorinated greenhouse gases.

These records must be kept by the operator and undertaking which installed, serviced, maintained and where applicable repaired or decommissioned the equipment for at least 5 years. The records shall be made available, on request, to the competent authority of the Member State concerned or to the Commission

Logbooks

The F Gas Regulation requires each operator of a system containing 5 tonnes of CO2 equivalent of fluorinated greenhouse gases or more to keep accurate records of all activities performed on the system. This will enable the authorities to check if all requirements of the F Gas Regulation are met. For example, they can check if the regular leak checks have been carried out. Based on the data recorded, it will be possible to estimate the emissions of fluorinated greenhouse gases, and therefore have an impression of the effectiveness of the Regulation, and where the opportunities for improvement lay.

The most common way to keep records is a logbook. A logbook can be as simple as a notepad, where all data are entered manually in writing and as complex as dedicated software packages that are available commercially. It is possibly a good idea to have an electronic logbook and to print out hard-copies when needed. If you decide to have an electronic logbook, please make sure you make back-ups at regular intervals. In some countries, you may need approval by the authorities for the type of logbook you want to use.
Most contractors will offer to keep the logbook for their customers. Please keep in mind that you as the operator (or owner) of the equipment will still be responsible for compliance, so if the logbook is found inaccurate, you will be the one to get the fine. It may also complicate matters if you use more than one contractor, or if you change contractors.

The EFCTC Logbook

EFCTC has developed an easy to use standard format for a Logbook, which can be a valuable tool for monitoring the performance of your systems. You can download it here

Additional references

F-Gas Regulation Implementing acts

http://ec.europa.eu/clima/policies/f-gas/legislation/documentation_en.htm

  • Regulations (EC) (1) No 1497/2007 and (2) on standard leakage checking requirements for:
    • stationary fire protection systems containing certain F Gases.
    • stationary refrigeration, air conditioning and heat pump equipment containing certain fluorinated greenhouse gases

DG CLIMA Guidance documents for F-Gas Regulation

http://ec.europa.eu/clima/policies/f-gas/documentation_en.htm

  • Guidance document: Information for technicians and users of refrigeration, air conditioning and heat pump equipment containing fluorinated greenhouse gases
  • Brochure: Information for technical personnel and companies working with equipment containing fluorinated greenhouse gases