PDA

View Full Version : Reuse of R22 in larger system







ICEMAN5111
12-05-2006, 11:46 AM
Bit of advise please guys and girls. I'm working on a job at the moment where i have had to completely remove a number of 20 year old nominal 10hp R22 fridge systems operating on a coldstore and deep freeze application. the client wants them reinstalled! i don't think i can do this under current regulations as it would amount to 'new installation' of R22 equipment. even if i could retrofit most of it, do i really want to be re installing 20 year old plant? i think not. anybody had experience of this situation?

Great site by the way, this is also my first post. lost my cherry!:)

Argus
12-05-2006, 01:15 PM
I am not a lawyer, but you can read the same source as me and draw your own conclusions.

There are 3 bits of legislation that come to mind:


ODS Regulations.
Safe Handling.
Hazardous Waste.


I suggest you read the ODS regulation which are the EU rules that govern this issue.
It is Regulation 2037/2000 EC.
http://europa.eu.int/eur-lex/lex/JOHtml.do?uri=OJ:L:2000:244:SOM:EN:HTML
This is the official journal version. Click on page 1 hyperlink and it will open the text as a PDF.

For HCFCs, read article 5. The prohibition is on new equipment, listed according to the use, in the schedule. If your equipment was manufactured before that date, then you may carry out repairs and refurbishment.
The ACRIB Guidelines suggest that the refurbishments must not increase the containment of refrigerant. So, for example, you could replace the evaporator with a new one, provided that the quantity of refrigerant after the modification is equal to or less than the original charge.

There may be another, more serious complication. All refrigerants are now Hazardous Waste. In theory, if the reinstallation is on the same site, you may not have a problem because you intend to re-use the equipment; as soon as you take the refrigerant off site it may be classified as waste, even iff you want to use it elsewhere. The waste laws are site specific ? because it is refrigerant, it will immediately be Hazardous Waste. Be careful with this one ? don?t get caught! It's a serous criminal offence.
You or your company must be registered as a mobile carrier by law now anyway, and the site must also be registered, unless it has an exemption. I'd look into that as a matter of urgency, if I were you.
If you are taking it away from site, I suggest that you have a clear written intent in your contract that the gas will be reused and is not therefore waste.

Finally, there is a new UK SI in preparation that will require you to have the usual refrigerant handling certificate, either CITB or C&G 2078 from about July this year if you are handling CFCs or HCFCs for any reason ? including recycling or reclamation. This won?t apply to HFCs just yet. If you have either of them you are OK.
Read about it here.
http://www.defra.gov.uk/corporate/consult/ozone-depleting/index.htm


This is surrounded by problems. Unless this is a huge earner, you may want to walk away from it.


.
________
medical marijuana dispensaries (http://dispensaries.org/)

Renato RR
12-05-2006, 01:59 PM
Once about 2 years we change piplines of 2 x 10Hp compressors.So I can say that a lot of oil can be found in oil sifons.Regarding R22 we pump down all to liquid receiwer.After demontage of heat exchangers put them in vertical position so that oil flow by gravitation thru pipes.
Open compressor and remove all oil inside.
Big procedure but expensive.All togeder demontage and retrofiting for your system worth betwen 4000 and 6000Euro depends on amount of equipment.

Best regards,
Renato;)

ICEMAN5111
12-05-2006, 02:42 PM
Thanks for this guys, most helpful.

Johnny Rod
12-05-2006, 03:15 PM
With respect to ACRIB guidelines, I presume that this means it's not law? Sounds like, if you really wanted to, you could refit it and use R22 as it is sort of a maintenance job rather than a new installation? In any case, you ought to know that, especially given its age, the old refrigerant could be contaminated so using it again in the same equipment might not be such a good idea.

Argus
12-05-2006, 03:41 PM
With respect to ACRIB guidelines, I presume that this means it's not law?

The ACRIB guideline is precisely that, but is an interpretation of some EU guides.
http://www.acrib.org.uk/ec_reg_2037.htm

I remember this being a serious issue at the time that the regulation was new because there was an imprecise interpretation of the regulation regarding repair and replacement of components. For example, supermarket cases may be replaced during a front-of-house refurbishment, leaving the pack or unit undisturbed. However the new component may increase the total volume of the system. The guides reflected official interpretation at the time to prevent this.

The old memory banks are a bit depleted after this time, but I should be able to find the source?..

.




In any case, you ought to know that, especially given its age, the old refrigerant could be contaminated so using it again in the same equipment might not be such a good idea.

Agreed, but it could be quite legally cleaned up ....

.
________
halfbaked (http://half-baked.com)

Argus
12-05-2006, 03:47 PM
With respect to ACRIB guidelines, I presume that this means it's not law?

The ACRIB guideline is precisely that, but is an interpretation of some EU guides.
http://www.acrib.org.uk/ec_reg_2037.htm

I remember this being a serious issue at the time that the regulation was new because there was an imprecise interpretation of the regulation regarding repair and replacement of components. For example, supermarket cases may be replaced during a front-of-house refurbishment, leaving the pack or unit undisturbed. However the new component may increase the total volume of the system. The guides reflected official interpretation at the time to prevent this.

The old memory banks are a bit depleted after this time, but I should be able to find the source?..

.




In any case, you ought to know that, especially given its age, the old refrigerant could be contaminated so using it again in the same equipment might not be such a good idea.

Agreed, but it could be quite legally cleaned up at site; the regulation recognises this.....

.
________
Browns Lane plant (http://www.ford-wiki.com/wiki/Browns_Lane_plant)