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Dave Finlay
02-04-2004, 07:31 AM
I have recently come across this problem and cannot find a difinative answer. Annual leak test on R22 units over 3kg charge is mandatory under law now, but what is acceptable as a leak test??.......is a visiual check of the system adequate or do we need to remove the charge and weigh it!. I have a company with 300 split units asking the question.........help

Bones
02-04-2004, 09:00 AM
what does the law say? do you have a copy of the applicable part you can post here? as everyone knows, all laws are open to interpretation...

i guess if you not sure exactly what to do, just go over each system with electronic leak detetors and soapy water etc... checking parts you know to he problematic like flares, nutorious spots for pipe rub throughs etc...

Latte
02-04-2004, 05:12 PM
I dont know what exactly the law states but personally i would just go over with a leak detector. At the end of the day if the system has a full charge you shouldn't find a leak, if the sytstem is low of gas then you have a leak and will have to spend more time looking into it

Regards

Raymond

Peter_1
02-04-2004, 05:36 PM
I have recently come across this problem and cannot find a difinative answer. Annual leak test on R22 units over 3kg charge is mandatory under law now, but what is acceptable as a leak test??.......is a visiual check of the system adequate or do we need to remove the charge and weigh it!. I have a company with 300 split units asking the question.........help

The law only says that a qualified tech should inspect the system. The way he do this is not prescribed.
In fact is it only the paper written afterwards by the tech that counts.
Best way is with a leaktester.

Argus
02-04-2004, 11:08 PM
Gentlemen, a little bit of background first

The law in question is an EC Regulation, 2037 /2000 on Substances that Deplete the Ozone Layer.
Explanatory Notes here:
http://www.dti.gov.uk/access/general_booklet3.htm

The full text is here:
http://www.dti.gov.uk/access/ozone.htm

This regulation enacts the Montreal Protocol in the EC. You will find the requirement to leak test fixed equipment over 3 kg containment in Article 17 ? 1. The legal treaty requirements of the MP on trading and eradication of ODPs as well as the ODP Regulation is enforced in the UK by SI 528 ? 2002.

The text of the SI is Here:
http://www.legislation.hmso.gov.uk/si/si2002/20020528.htm

Article 6 of the UK SI that enforces this is equally vague:

Quote from the SI:
Duty with respect to Articles 16 and 17
6. It shall be the duty of any person having control of the controlled substances mentioned in Articles 16 (recovery of used controlled substances) and 17 (leakages of controlled substances) to comply with those provisions.
End quote:

There is a new regulation going through the European Parliament now that covers Fluorinated gases and is designed to enforce the EC?s commitments to Climate change at Kyoto. It also contains similar measures for emission controls.

The Regulation simply says that you have to do it. It does not define the methodology of leak testing ? that is down to us, the engineers. Two legal instruments with real teeth are cited in this SI, The Environmental Protection Act and the Health and Safety Act.

What it needs is a serious outbreak of common sense.

The Regulation uses the words "checked for leakages". Obviously your cliemnt wants to comply with what the law demands. I think that you write a realistic and achievable method statement describing how you would test each system under normal standing pressure, running checks, visually with a suitable leak detector or even with an ultra violet lamp if you have that many systems. Then work out how much it will cost. Get your client to approve the method, do the job and give him a report, get paid. Everybody happy.

What he will want is to be able to prove that he took all practicable steps to avoid emissions from his systems. After all, it is his kit and his responsibility to comply with the law. He is employng an engineer to do the technical stuff and you are providing a service.

Hope this helps
________
Honda VFR800 specifications (http://www.honda-wiki.org/wiki/Honda_VFR800)

Peter_1
03-04-2004, 07:26 AM
As I stated previously, it's only the paper that's matter. It's not important how you do it.

According to the PED for the pressure test is another story. There you have to pressure test 1.3 MOP and an independant controlling agency has to supervise your test.

We do it now already more then 5 years and never had any problems with the controlling authority.

If somebody is interested, I always can translate these papers. They'r only 5 lines of text.

We use for a new installation always 3 forms "Pressure Test", "Leak Test" and "CE Conformity"

Dave Finlay
03-04-2004, 08:21 AM
Thanks Argus
It is as i though, I assumed a visiual check and regular maintenance of the equipment would be ok, but this company is being audited by the ISO14000 people and want to be seen to be doing it right. I dont think a leak detector is a suitable way to check each of the 300 systems as most of the pipework is buried inside of wallsbut it should be ok for the valve connections. I think this is a case of the law changing after the equipment was installed, but your input has been very helpful.
thanks
Dave

chemi-cool
03-04-2004, 10:40 AM
hi dave,

as someone suggested before, check first for units with lack of charge.
only those units should be leak tested.

if you check a unit and the charge is ok, it seems to be kind of stupid to go and look for leaks, dont you think?

chemi

Argus
03-04-2004, 11:14 AM
Dave,

This is a slightly different thing to the EC Regulation. Compliance methods for one can usually be used as compliance with the other. It?s just a matter of getting your documentation and reports together.

ISO 14000 is a formal environmental quality assessment and can be taken away as well as awarded. Your client will be mightily cheesed off if they lose it. The whole environmental impact of their processes is assessed under ISO 14000, not just refrigerants in a bit of A/C. It's quite involved and is an on-going series of audits.

This is different again from the EC Regulation checks that most people ignore anyway.

You may consider doing something like this:

Because it is ISO 14000 auditors, do EVERYTHING in writing and file it!

Find out from your client exactly what will satisfy their auditors in terms of leakage testing. If they know what they are about they will give you a method statement. If not write your own.

Establish and declare, if you can, that any inaccessible pipework is installed in one piece without joints. Good practiice says that it should be and you may suggest that if it cannot be established because nobody knows, then that section be reinstalled. Your client may not want to go that far, but you will have asked him and his refusal will serve to protect you against having to guarantee inaccessible joints installed by others that you cannot test. If he accepts, do the job and get paid for it.

Finally, proportionality. If there 300 odd tin-and-wind splits installed, do a test that is appropriate for the complexity of this type of equipment, not something designed for a giant megawatt chiller with pressure vessels that an inspector will force on you. In other words, a periodic leak check is not a full blown strength test that you would do for more onerous legislation. The manufacturer of the kit should be able to suggest a test regime that is appropriate. If not, again write your own based on common sense.

But do EVERYTHING in writing!

Hope this helps.
________
Rambler Six (http://www.dodge-wiki.com/wiki/Rambler_Six)

Peter_1
04-04-2004, 12:35 PM
We did the HVAC for the small testing rooms of Calimet www.calimet.be , a Belgium company here nearby (in the beautifull Bruges) who calibrates measuring devices.
The working limits for temperature are very narrow. (+/- 0,25 K)
They work under ISO14001.
The only thing we have to do is provide a paper whereby we state that systems were leak tested and that they are pressure tested each 5 years.
Like argus said, it's only the paper that counts for the controllers.
If you realy did it,... that's another story.
Nobody can guarantee that a system will stay leak free after a leak test.