Printable View
.
How would you difine as soon as possible?
According to DEFRA leak testing should be:-
Using all measures which are technically feasible and do not entail disproportionate cost operatorsleakage.
must: (a) prevent leakage of F gas refrigerants and (b) as soon as possible repair any detected
I have also read that regarding HCFC's 14 days is the maximum time before a repair can
be completed. According to DEFRA....
So
How would you difine as soon as possible?
taz
.
ASAP is after I finish the currant job, never leave a job undone.
14 days?? It seems like you will not need the recovery unit.
As soon as possible to me would be when i found the leak. Unless i needed parts like a new evaporator or the like then i would decide either to shut the system down or leave it running based on how big the leak is how much they need the system and how soon a repair can be made.
I thought the wording in the guideline was 'as soon as practicable' but i'm not the best at words!
I posed this question to the FGas support back in May last year :
Quote:
DearRichard,
Thank you for yourquery.
We areassuming the systems contain HFCs, so the EC F gas Regulation applies. If theycontain HCFC such as R22 then please see RAC 8 attached.
Toppingup leaky system:
There is nothingin the EC F gas Regulation that states that it is permissible to top up a RACsystem twice before other action is taken.
TheRegulation does not specifically state that to top up a system with a knownleak is not permitted, this is implied within the key obligations as beingagainst the spirit of the regulation, unless there are technical or economicbarriers hindering the repair:
Informationsheet RAC 3 (attached) contains wording direct from the EC F gas Regulationwhich states one of the key obligations for operators of equipment containingHFCs must: ‘’ Using all measures which are technically feasible and do notentail disproportionate cost operators must:
(a) preventleakage of F gas refrigerants and
(b) as soon aspossible repair any detected leakage.’’
This isdetailed in Article 3.1 of the EC F gas Regulation (copy attached) and isenforceable in GB law, see GB regulations 2009 SI 261 (also attached).
There is noabsolute period of time specified within which a leak must be repaired, itneeds to be as soon as possible within the caveats of technically feasible andnot entailing excessive cost, which is for the operator to decide and can onlybe tested in the courts should a prosecution for non-compliance be broughtabout.
Therefore itis for the operator to decide, drawing also upon expert advice from thecontractor, whether it would be technically or economically unviable to repairthe leak immediately if proving problematic to locate and/or whether the systemcould be topped up with refrigerant whilst this process was taking place. It isour view that if the operator requests top up of a leaking system, that it isonly undertaken if a plan for repair of the leak which suits both the operatorand contractor is scheduled for the first reasonable opportunity.
We havepreviously supplied the following advice on disproportionate cost which may beof interest to you:
If there isa large leak logically it must be dealt with very quickly. Otherwise you mightlose the whole refrigerant charge before you came back to do a repair. Thismight be compared to a large leak from a water main – it must be dealt with asan emergency.
Shutting theplant down would not necessarily help – the leak will probably continue duringa shut down (indeed for a leak on the low pressure side of a refrigerationplant the leak rate might increase if you shut the plant down!). Shutting downand isolating the part of the plant that is leaking might help, but not allplants have isolation valves to make this possible or safe.
Also, with alarge leak, there is no issue of excessive cost. If the leak is allowed tocontinue, the refrigeration plant will lose so much refrigerant that it willnot work – so you have to spend money to repair it whether you like it or not.
At the otherextreme, a very small leak would not need such prompt action and, at some verylow level of leakage may either be un-repairable or very expensive to repair(in relation to the value of the environmental benefit). As an example imaginea plant with 10 kg of HFC refrigerant. With a very sensitive leak detector youfind a leak of 10 grammes per year. It would take 100 years to leak 1 kg. It islikely that repairing such a tiny leak does entail disproportionate cost. Leaksof such a tiny size can be noted and might be dealt with at the next majoroverhaul when the plant is shut down for other reasons.
The problemwith these 2 extreme examples is judging where there is a"cross-over" in terms of disproportionate cost. This is not a clearcut answer as there is no set level of what is excessive costs and would bebased on the individual company looking at their financial position. Defra’sadvice is that it is for the courts to decide what would be excessive costs. Itis for you and the customer need to make a decision based on the guidance abovewith the aim of the EC F gas Regulation in mind.
Leakchecking with UV dye
As long asthe guidelines in supporting Commission Regulation EC 1516/2007 on leakchecking are adhered to, then it is for the qualified personnel undertaking thework to utilise their skill and experience to determine the most suitablemethod and procedure on a case by case basis.
TheRegulation does not go into detail of the procedures, but you will see thatthis method is listed as an acceptable direct testing method in Article 6 ofthe Regulation. Certain articles in the Commission Regulation also refer:
Article 5.1allows both direct and indirect checks.
Article 5.2requires direct checks may always be used.
Please alsonote that this work must be undertaken by personnel holding a qualificationthat covers them for breaking into the refrigeration circuit. i.e. personnelholding a Category IV F gas qualification (leak checking) would not besufficiently qualified to do this work.
EC 1516/2007Article 6
Directmeasuring methods
1. Toidentify leakage, certified personnel shall use one or more of the followingdirect measuring methods:
(b)application of ultraviolet (UV) detection fluid or suitable dye in the circuit;
3. Theapplication of UV detection fluid or suitable dye in the refrigeration circuitshall only be undertaken if the manufacturer of the equipment has approved thatsuch detection methods are technically possible. The method shall only beundertaken by personnel certified to undertake activities which entail breakinginto the refrigeration circuit containing fluorinated greenhouse gases.
Nitrogen orother means such as use of soapy water would be the preferred methods todetermine a leak, but the EC F gas Regulation does not specify which methodsshould be tried first.
This use ofa small amount of refrigerant mixed with other gases for use in leak finding ineither mobile or stationary air conditioning is not specifically banned underthe EC F gas Regulation although knowingly venting F gases to atmosphere wouldnot be in the spirit of the Regulation. This use may be considered to bebeneficial as it results in less F gas being lost to atmosphere overall. It isour opinion that the gases should be recovered as required by Article 4 of theregulation if technically and economically feasible.
Please seesheet RAC 6 and EC 1516/2007 (attached) for further detail on leak checking.
We hope that theinformation provided answers your query. If not, and you require furtherinformation, please do not hesitate to contact us again (details are atthe bottom of this email).
Kind Regards,
Lucinda
.
Thankyou Richard.....
It was those RAC info sheets that I quoted directly from and as your reply
states "As soon as possible" is open to interpritation and each case needs
to be dealt with individualy...
As I say
"It can come down to who has the best Solicitor if it ever gets to court"
Cheers guys.
taz
.
Hi Jon,Quote:
Originally Posted by monkey spanners
sorry about my blonde question, but, why would you need a new evaporator in case of a leak? has it anything to do with the presence of water in it?.
Regards,
Nando.
Quote:
Originally Posted by Fri3Oil System
Because it may be unrepairable or as we have found before you end up chasing leaks after you repaired it once it leaks somewhere else and the customer ends up paying far more for repairs than replacement
Cheers r.bartlett,
I guess every case is different, as the evaporator can be saved in many occasions, even if it's flooded.
Regards,
Nando.
I know this may sound flippant but you need a special tool, its called a roundtoit.
It will be done when you get a "roundtoit"
Quote:
Originally Posted by B G Scott
Now that is a tool that gets used a lot.
:)
Cheers
taz
.