R22 system legality

[johno12345]

Hi,

I am not an engineer, just work in facilities. We have 26 air conditioners on site, most are R410A, a couple of R407C systems, some R69L / R23 two stage chillers and some R404A /
R23 two stage chillers.

We also have the ISO 14001 thing and I am getting confused comments from auditors regarding these systems. Some say that the R22 is illegal in new systems, some say it must be removed before 2010 and I am just getting more confused! :)

The R22 is used in a carrier 50YQ048 system, a Lennox 12Kw unit and a IMI Hi/Lo 80. I have been led to believe that the R22 systems can be retrofitted with an alternative refrigerant but is it worthwhile? Or, are they fine to leave indefinately as they are existing systems?

any advice would be appriciated :)

Thanks!

[nevgee]

Try starting at these two links and follow the trail
http://www.acrib.org.uk/web_images/documents/legislation_updates/REFRIGERANT%20DATES.pdf

http://www.defra.gov.uk/environment/air-atmos/fgas/pdf/fgas-support-leaflet.pdf

good luck :D

[Argus]

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You have a mix of gases there and no mistake.

The laws concerning the legality of refrigerants and the laws concerning your obligations as an operator are complex and some very new.

Next, you are getting conflicting advice. What is legal you have to do – no choice; what is desirable to comply with ISO 14000 is another – that is voluntary, unless of course you have a contractual obligation. Nonetheless, a standard is not a law.

R69L is a trade name for R403B - a refrigerant mixture containing R22, so you must consider it with all the other plant containing R22. R23 is an Hydrofluorocarbon (HFC) and is covered by other legislation that you must consider, as are the other refrigerants that you mention.

Your auditor is both right and wrong. He is right when he says that new systems containing or using R22 cannot be sold. That has been the case since at least 2002. He is wrong when he says that it must be removed before 2010, (unless that is a clause written into your ISO 14000).

R22 is part of a group of gases known, for legal terms, as Ozone Depleting Substances (ODS). They are governed under the Montreal Protocol, and in the EU they are regulated by the ODS Regulations, 2037/2000 – that’s a European law, enforced in the UK by our own statute.

In it, the regulations states a time scale for the phase-out of ODS. In the case of refrigerants (R22 in your case) the ‘use’ of new refrigerant is banned from the first day of 2010. The term ‘use’ is curious because it has a particular legal meaning in this regulation. It means that you cannot add or remove, or carry out invasive repairs involving ODS. It does NOT means that you have to switch the unit off.
After the start of 2010 you can still continue the plant in operation, but any additions of refrigerant during service must be reclaimed refrigerant – not virgin stock. You may continue to use reclaimed stock for service until the end of 2014. After that no ODS may be added for any reason and any removed must be destroyed legally. You may not legally stockpile new R22 after 2010.

Finally if you are responsible for a series of plant containing refrigerants, you have a number of other legal obligations that are in place now. I would strongly urge you to do a full and detailed audit of the plant and the legal obligations of all your plant as soon as possible and seek professional advice.

Your company is risking serious legal penalties for non-compliance.


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[nevgee]

Here are some other useful links http://www.ior.org.uk/ior_newsdetail.php?r=ELE7TLXM

http://facilities-manager.co.uk/environment/countdown-to-f-gas.html

[nevgee]

http://www.ior.org.uk/ior_/images/pdf/Good%20practice%2025%20f%20gas%20system%20record.pdf

[johno12345]

Hi,

Thanks for the info and detailed reply. I am already halfway there. I have a Plant List with refrigerant qtys and types. We have a service sheet for each unit that is completed each time an engineer visits and all refrigerant alterations are recorded.

I am tempted to recommend the replacement of the R22 systems as they are old anyway.

Sadly, I have just realised that many of our machinery cabinets are cooled by very old chiller units, 1950 vintage. Thats my task for today!

The ISO seems to be a check and confirmation that we are complying with the relevant legislation, they dont seem to make any further requirements.

I may post back with my complete list of refrigerants :)

Thanks!

[Argus]

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Thanks for the info and detailed reply. I am already halfway there. I have a Plant List with refrigerant qtys and types. We have a service sheet for each unit that is completed each time an engineer visits and all refrigerant alterations are recorded.




Good idea. You are required by law to carry out leakage checks on all equipment containing more than 3 kg F Gases.

There is a log report template available from DEFRA's F Gas site that shows the minimum information needed.

You can use it as a base for extra information if you wish In fact, it’s a good idea to extend the checks to non- F Gas equipment as long as they are in service.




I am tempted to recommend the replacement of the R22 systems as they are old anyway.



If the plant is taken out of service and scrapped, the refrigerant and oils automatically become Hazardous Waste. You will need proof of legal disposal that will key in with your ISO 14000 reporting. It’s illegal to vent any refrigerant direct to the atmosphere.

Your service company doing the rip-out will need details of your company's waste disposal registration and you will need theirs.

The same goes for 1950s vintage plant. That stuff may already contain CFCs (R12 in particular, which is now banned).


Some of us old timers would be interested to know what it is if it really that old. Why not post some pictures?



.

[johno12345]

Hi,

We will be having all refrigerant plant serviced and checked for leaks every 6 months and it will be logged. We never allow venting to atmosphere and I know that the decommissioned units are evacuated and the cylinders are returned to the refrigerant supplier, just need to get a waste consignment note now.

The oldest cooler that I could find states that it uses DF22 which I assume is the same as R22, Not sure of the age but it is totally caked in grease so wont be much of a picture. There is some older stuff but I cant access it today as it is inside running machinery. They are used for cooling, coolant oil.

The Fgas regs are fast aproaching the strictness of the evaporative chiller plant we have which is checked weekly. Not sure of the cooling capacity of these but they are huge like the size of a house each!

List so far of refrigerants found:
R134a
R125
R32
R143a
R134a
R290
R22
R14
R600
R23
Heptafluoropropane

Not listed preparations, just the components....

Thanks

[nevgee]

It would seem that you're getting on top of your problem and also it's reassuring to see there are responsible people out there doing the right thing. I often come across FM's who are only too keen to be seen to do the right thing but underneath are looking to save a buck or two and maintain their kudos.

You deserve the recognition of being aware of your ressponsibilities and making the effort to get it right ...good for you.

Keep asking the questions because on this site there are people who do know what they're talking about and can give you good advise.

[johno12345]

Bad news :( Our fitter has found a unit using R12. It is hermetically sealed and has a charge of 300g.

Is it legal to have a R12 unit in service?

[Argus]

.

There are numerous hermetic systems still running with R 12 (a CFC) in the circuit that are still in service.

The ODS Regulation - 2037 / 2000 EC – does not ban them being in service. What you cannot do under the terms of the regulation is to carry out invasive repairs to the circuit that involves the refrigerant. As soon as the CFCs are removed for any reason, it (the CFCs) must be consigned for destruction as a Hazardous Waste.
You then have a choice to either scrap the kit or clean it out and convert it to use on a legal refrigerant.
If it is a small domestic-type fridge, the chances are high that the insulation foam will be blown with CFCs, so that becomes Hazardous waste as well.

You may find that continued service of a banned substance, although legal in its current form, conflicts with your company’s environmental policies.

Disposal of these fridges and the like in the UK is tightly controlled.


Hope this helps


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[johno12345]

Thats a great help, thanks.

Our environmental policy basically states that we wont break the law.

The unit is a coolant oil cooler, runs at 4.4A per phase at 200V p-p, dont know the cooling output but I guess that it is reasonable, about 2-3kw?

It would cost many thousands to replace it as it is an integrated part of a larger machine. It will be marked for replacement during the next refurbishment but that may be in a few years.

Thanks for the advice