purging and the law

[rbartlett]

hi guy's

had a conversation with a guy who is one of those Mr millennium ebay'ers. really Nice chap and no idiot for sure.

we got talking about th law and i asked if he sells vac pumps?

"no" he said " we recommend purging"
I mentioned that I thought that was illegal.
he had been told that it was similar to corgi -IE anyone can do it but you cannot charge .

i understood that purging was technically illegal who ever did it not just 'professionals'?

any ideas?

cheers

richard

[Argus]

You are right, Richard.

Deliberate venting and purging refrigerant to atmosphere in any form by anybody is definitely illegal in the UK and has been for 15 years.

In the UK the enforcement is the Environmental Protection Act, 1990.

http://www.opsi.gov.uk/acts/acts1990...00043_en_1.htm

There are two immediate relevant offences in the 1990 Act:

1. Deliberate release. Section 33.
2. Duty of care in respect of controlled waste, section 34

.

The second has now been overtaken since July last year by the Hazardous Waste Regulations; 'controlled waste' is a thing of the past, but the concept of duty of care remains.
Further offences under the Hazardous Waste Regs will be (if you or your company is not registered with the EA)

• Failure to register,
• Failure to produce quarterly returns etc

.

Technically, refrigerant from sub-atmospheric pressure expelled through a vacuum pump exhaust is Hazardous Waste.

I should mention that the laws in Scotland are different; you still need 3 day notification.

At present in the UK, anyone, including your granny, can purchase and use Fluorinated refrigerants, (HFCs, HCFCs etc), but cannot dispose of waste without registration. That will change with changes to the ODS regulations expected in July and the introduction of the F Gas regulations expected later this year.
Sales of refrigerant will be restricted to individuals or companies who possess the relevant handling competence qualifications.

.
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VN1500G

[eggs]

hmmmm, if you purge a system and you know what you are doing, you shouldnt loose anymore gas than what is accepted as " an accepted minimal loss" you know, the ammount you loose when removing lines, purging lines etc.
another grey area.

cheers

eggs

[Argus]

hmmmm, if you purge a system and you know what you are doing, you shouldnt loose anymore gas than what is accepted as " an accepted minimal loss" you know, the ammount you loose when removing lines, purging lines etc.
another grey area.

cheers

eggs

Greyish, Eggs, only greyish!

Nothing is accepted in written form as 'minimal'.

I recently asked the Environment Agency, in the form of a prominent official who deals with this sort of thing, a basic question:

?What would be considered de minimis quantity in terms of line losses during inspection and service??
The answer I received is that there is no level that is considered minimal in terms of the Hazardous Waste rules.

The consideration is
Question: Is it practicable to contain refrigerant in gauge lines?
Answer: Yes. Universal and quick release couplers are readily available to contain refrigerant in the system or gauge lines.
Question: Is it the cost disproportionate?
Answer: No ? they are relatively cheap.

Similarly, this is the reasoning behind the ban on use of non-refillable refrigerant containers in Europe, (except HFCs - that one is coming soon). The heel of gas left in the can is immeasurable.

There is a great chunk of new legislation floating around in this area and I really expect the UK authorities to start tightening up.


.
________
Suzuki GT750

[Peter_1]

What then about leak testing?
We fill the system with the same gass the system is running on and pressurise it then further till 20 or 25 bar.
After finding the leak, we then have to release this mixture to the atmosphere.
Is this hen also not allowed?
And if not, how can we find a leak in a system?

[eggs]

shhhhhhhhhh Peter.
we are not supposed to do this. we are supposed to recover any remaining gas, then refill with OFN, then pressure test using soapy water or an expensive alternative.

Then we charge the customer ££££ for destruction of the reclaimed gas and the extra labour time recovering the gas.

Meanwhile some Latvian or Pole in an old GPO van has installed a new LG, at half your breakeven cost.

Wile in China and India1,000,001 leaking systems have been topped up with R12. The good old US of A are still filling their systems up with old fridge gasses.

In otherwords, do as the rest of europe does (obviously including yourself and other Belgians), fill in the correct forms, tick the correct boxes and get your invoice in.

The environment is now beyond repair, the glaciers will still melt and the rainforest will still turn to desert no matter what we do. 3 or 4 generations from us now the WAR of all WARS for fresh water will wipe out mankind anyway.

Even though i do comply with the law and recover, reclaim vac etc....etc... I really do wonder why?????

The planet is F............................................D

cheers

eggs

[Emma]

Thanks for your suggestions Johnny.

We already have an oxygen level monitor so thats covered.

Of course, you can buy Liquid Nitrogen. But... I work for an organisation which supports research scientists at sea on ships. Potentially the ship could be away from port for 6 weeks and over that period of time the natural evaporation of Liquid Nitrogen would mean you have little left at the end of the trip. Hence the need to make our own!

[fatty]

I am very interested in this do you have any pictures of the unit or specs Emma??

Is the unit a cryochill unit??

[Emma]

Hi Fatty,

The unit was made by Cryomech, who are based in New York. At the time we purchased the unit there were no suitable manaufacturers outside of the US. I don't know what the situation is in that respect now.

Sorry, but I am not able to post the link as I have not made enough posts, but a google search for Cryomech should get you there and then click on "Liquid Nitrogen Plants".

Hope that helps,
Cheers
Emma

[pendlesteve]

Please be careful on this one.
Firstly purging. How can you be sure all the air is out? How can you be sure you have not released refrigerant? Loss of refrigerant is catagorised, avoidable loss & unavoidable loss. Taking off a charging line with as low a vapour pressure left in the line is unavoidable but loss through purging is avoidable. Also how do you purge? If it's by cracking a flare then it's a no no as you should pressure test the joints. An avoidable refrigerant loss is prosecutable and the penalty in the UK is - an unlimited fine and/or up to five years in prison.

[winfred.dela]

Hi Emma,

As i understand, you have a Liquid Nitrogen (LN2) Plant cooled by refrigeration system charged with Helium.
You are then inquiring if the containers with N2 gas that should be vented is OK, before you refill the containers with LN2.

Am also involved in the maintenance of three LN2 plants since 2001. These units are from Japan and the LN2 is used for cow/carabao Breeding and AI program.

The N2 gas venting is not illegal because its a Natural gas and not covered with the Montreal & Kyoto protocols.

As to the refrigeration system with Helium, no cause for concern because very small amount of Helium leaks. We only charged once in 5 years and small quantity at that.

The concern is that you just have to make sure that you have enough fresh air and exhaust in your plant as required by the LN2 plant manufacturer.

Hope to have answered your question.

[Electrocoolman]

Surely both helium and Nitrogen are constituents of the atmosphere and are extracted from the atmosphere in their production....hence no problem in venting these to atmosphere