ODS and F-Gas: Obligations for Refrigerant, Air-Conditioning and Fire Suppressant Contractors

Transcription

1 ODS and F-Gas: Obligations for Refrigerant, Air-Conditioning and Fire Suppressant Contractors Facilities Management Ireland th March 2018 Eamonn Merriman, Inspector, ODS & F-Gas Team, EPA

2 Presentation Outline Why are ODS and F-Gases Regulated? ODS AND F-Gas legislation Stakeholders EPA Role ODS Bans F-Gas Restrictions EPA Enforcement Contractor Obligations Guidance

3 Why are ODS and F-Gases Regulated? Ozone Depleting Substances (ODS) are chemicals which can damage and deplete ozone within the earth s ozone layer when released. Fluorinated Greenhouse Gases (F-gases) are very potent greenhouse gases which contribute to climate change if released to atmosphere.

4 ODS and F-Gas legislation ODS Montreal Protocol (1987) Phase out production and consumption F-gas Kyoto Protocol (1997) Prevent emissions Kigali Amendment to Montreal Protocol (2016) EU ODS Regulation EC 1005/2009 EU F-gas Regulation EU 517/2014 S.I. No 465 of 2011 S.I. No 658 of 2016

5 Stakeholders Operators (end-users) Department of Communications, Climate Action and the Environment (Policy and Legislation) F-gas Registration Limited (Company Certification) Contractors RAC, Heat Pump, Fire, MAC Competent Authority Trade and industry representative groups Personnel Certification

6 EPA Role Competent authority for ODS and F-gas Regulations Responsible for enforcement activity Prepare annual reports to European Commission Engage with relevant stakeholders Provide guidance and advice Liaise with Department of Communications, Climate Action and the Environment

7 ODS Bans ODS gases (e.g. R22) are no longer allowed for maintenance and servicing of equipment since 1 st January This means that if equipment containing ODS such as R22 now breaks down, it cannot be topped up.

8 F-Gas Restrictions If your equipment runs on F-gas make sure you are aware of, and ready for, F-gas Phase Down (in force since 1st January 2015) the Service and Maintenance Ban (from 1st January 2020) Placing on the Market Bans (from July 2007 to January 2025)

9 HFC Phase Down HFC phase down begins in 2016 and will be completed by 2030 By 2030, only 21% of what was placed on the market for the base year (average of ) will be available Significant set-down in availability looming % of base % of base

10 F-Gas Placing on the Market Bans Products and Equipment that contain HFCs GWP Date of Prohibition Domestic refrigerators/freezers with HFC s January 2015 Hermetically sealed refrigerators/freezers for commercial use Multipack centralised refrigeration systems for commercial use with a rated capacity 40kW (except primary circuit of cascade systems when limit will be GWP 1500) January January 2022 Stationary refrigeration January 2020 Movable, hermetically sealed room Air Conditioning January 2020 Single split AC with less than 3Kg F-gases January 2025

11 F-Gas Service and Maintenance Bans From 1 st January 2020, use of F-gases with a GWP 2500 for systems of charge size 40 tonnes CO 2 equivalent However Reclaimed and Recycled F-gases with a GWP 2500 may be used until 1 st January 2030 on existing equipment Example: R404A = GWP 3922 : 40 t CO 2 eq = 10.2 Kg

12 Implications of F-Gas Restrictions Reduced availability/increased cost of common F-gases may have implications for business critical equipment Retrofitting of equipment may be required to accommodate alternatives gases with lower Global Warming Potential The GWP of gases needs to be considered when purchasing in order to future proof new equipment Lower-GWP Alternatives in Commercial and Transport Refrigeration: An expanded compilation of propane, CO2, ammonia and HFO case studies (UNEP, 2016)

13 EPA Enforcement Activity Desk Surveys Inspections Contractors Operators/end-users Distributors Waste Companies Follow up non-compliances Offences may apply for breach of the regulations Third party enforcement support contracts

14 Summary of Contractor Inspections 2016

15 Contractor Obligations The operator is responsible for making arrangements so that the installation, maintenance, servicing, leak checking, recovery of gases and decommissioning of equipment are carried out by certified personnel. The certified personnel (and company) are responsible for the proper execution of the activities.

16 Training and Certification Service personnel must be certified to install, service and maintain, repair or decommission equipment as well as to perform leak checking and recovery of gas at end of life. Operators engaging a contractor to do these activities must make sure that the contractor is certified. Only contractors that are certified can acquire F- gases for the purpose of installing, servicing, maintaining or repairing.

17 Containment Intentional release of F-Gas (i.e. venting) is prohibited. Operators shall take precautions to prevent unintentional release (leakage) of F-Gases Where leakage detected, repair without undue delay The repair must be verified by a certified person within one month

18 Leak Checking Quantity of gas (t CO 2 eq) No leak detection equipment fitted F- gas Leak Checking Frequency Leak detection equipment fitted 5 None None monthly 24 monthly monthly 12 monthly monthly 6 monthly Hermetically sealed equipment containing less than 10 t CO 2 eq is not subject to leak checking provided the equipment is labeled as being hermetically sealed. Stationary equipment >500 t CO 2 eq must have automatic leak detection

19 GWP Based Leak Testing Charge Limit in t CO 2 eq Gas GWP Charge in Kg R134a 1, R404A 3,

20 Waste Management In order to transport waste ODS & F-Gases, a Waste Collection Permit (LA) or a Prior Annual Notification or PAN (EPA) is required. The storage of these wastes is not permitted on any site other than storage for up to 6 months at the site of generation unless the site is specifically authorised to do so under the Waste Management Act 1996 (as amended).

21 Records The operator of equipment is required to maintain specified records for at least 5 years, including the identity of the contractor Contractors are required to keep copies of records for at least 5 years. These must be made available to the EPA upon request

22 Other Issues All F-Gas equipment placed on the market after 01/01/2017 must have a new label for F- Gases

23 Guidance Documents Other guidance available at and

24 EPA website

25 European Commission webpages (linked from EPA website)

26 Further information Eamonn Merriman (EPA Dublin) EPA website or Lo Call

27 UNEP video: Precious Ozone - the Climate Connection UNEP 2015.mp4