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  1. #1
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    purging and the law



    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



  2. #2
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    Re: purging and the law

    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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    Last edited by Argus; 07-02-2011 at 09:58 AM.

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    Re: purging and the law

    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

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    Re: purging and the law

    Quote Originally Posted by 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

    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.


    .
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    Last edited by Argus; 07-02-2011 at 09:59 AM.

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    Re: purging and the law

    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?
    It's better to keep your mouth shut and give the impression that you're stupid than to open it and remove all doubt.

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    Re: purging and the law

    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

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    Re: purging and the law

    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.
    What happens when you change systems and its a differant gas? differant set of gauges for each gas?

    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
    So, your an optimist then?!?!?

    Chillin
    IF AT FIRST YOU DON`T SUCCEED.
    DESTROY ALL EVIDENCE THAT YOU TRIED!
    and go get a cuppa

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    Re: purging and the law

    Evening Chillin,

    yes i am an optimist, which is why i comply and do my bit.
    But................ I am also an educated REALIST.
    Nothing we do now will bring back the balance to the sealife ecosystem or bring back the extinct animals and creatures mankind has disposed of.
    Without them the earth is out of balance and heading for breakdown.
    There is nothing more important to life than fresh water. We can survive without oil, gas, even animals. But we NEED water.
    At the current rate of global warming, within 30 years we will see wars starting over fresh water supplies. Sorry to sound pessimistic but the damage is done, nothing we can do now will slow down the current rate of global warming enough to avert the wars that will start in 30ish years time.

    Unless of course, scientific technology finds a way in the meantime.
    But for now.......................

    asses the customer, take your choice...........

    cheers

    eggs

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    Re: purging and the law

    Guys

    I would say matter what part of the world you are it it is prudent to use a recovey unit and a vacumn pump

    In some cases, well with the sort of plant I work at, a long hose to the nearest unit running on the same gas is all you need

    Pull the remaining vapour after pumpdown into the unit beside it

    We use this method and our recovery unit on push-pull for the smaller jobs. Then vac out after service/modifications. I have never had a customer complain about us saving gas yet

    Kind Regards Andy

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    Re: purging and the law

    Andy, that's also the way I'm doing it.

    We have in each van 2 flexible hose lines of 30 ft long so that we can use this for several purposes: pull the gas out of a system with the compressors of another system with the same gas, pressurise a unit mounted high with the OFN bottle on the ground, fill gas with ***** bottles left on the ground, even vacuum the system with 2 hoses (works fine)
    We use those allways when working on the market trucks.

    But as said previously, you easily can retract all the gas out of a system when there's a service connection on the discharge side of the compressor.
    Anyone else using this fasts and cheap method?

    About all that legislation about release of gas to the atmosphere: it's allways the use of common sense that counts and try to avoid escape gas to the environment as much as possible. So, if you have to add gas, try to find the leak, don't just top it off.

    If you have to remove a compressor, try to re-use the gass that is in the system. I even re-use it with a burned compressor where many others say you can't do this.
    But the gas isn't burned at all, it can only be contaminated.
    Recover it in a cilinder, let it rest there while changing the compressor, and re-use it for your new system but add only gass, no liquid (just heat up the botlle a litlle bit with a gun heater while attaching the electrical cables)
    Fill through a Sporan dryer and add some Acid-Away in the system.

    And lik Eggs said, make then that the paperwork is done the right way.

    All those laws are made many times by peoples who never saw a refrigerant compressor.

    One of the first laws in Belgium - the VLAREM I - stated that all pressure vessels had to pressure tested each 5 years with....WATER.
    I once had around 1990 almost a lawsuit for this because i refused to do this. The examiner said I had to remove the reciever out of the system, pressurise it with water, dry it afterwards and then had to re-instal it afterwards. There was +/- 100 kg of liquid in that system.

    Same for the meat cutting factories: all the bones, fat and skin must be cooled to 2°C. All this is then collected by a big truck for mass destruction and this is an open truck. In summer, you can smell it minutes after he passed you.

    All the cold items sold on the market must be sold colder then 2°C and warm products (like roasted chicken) must be sold more then 65°C. But what if that person walks afterwards some hours, let it in his car some hours and then complains afterwards that there's something wrong with the product.

    They making it all so clean now that we can't withstand anything, the litlle that there's wrong with food we are terrible ill from it.
    We're making it to clean.
    Kids who lives on a farm rarely are sick and rarely have allergies.

    All this because I wanted to say..use your common sense.
    It's better to keep your mouth shut and give the impression that you're stupid than to open it and remove all doubt.

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    Re: purging and the law

    All this because I wanted to say..use your common sense.
    A little common sense goes a long way

    We all know not to vent refrigerant

    We all know to vac out a system after service

    If you use your common sense and do your job properly you are less likely to end up in court, and you have a defence when you do end up in court, good practice

    Kind Regards Andy

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    Re: purging and the law

    Quote Originally Posted by eggs
    Meanwhile some Latvian or Pole in an old GPO van has installed a new LG, at half your breakeven cost.
    I also think that water will become a lot more expensive then oil. If you compare now already the price of 1 liter of quality drinking water and 1 liter of fuel.
    And think what costs there (exploring, refiing, transport, savings for teh oil company, the pump holder,...) has to be made to make 1 liter of fuel.

    I had to visit for the Belgium court 3 weeks ago a rather big wharf where airco's were installed.
    There were plumbers, electricians, ...
    There were also plasterers, Polish men, 11...
    They worked legally for their boss in Poland, 7 days a week, 3 weeks a month. They sleep on the warf on air-mattress in a sleeping back. They earn net 3,5 €/hour which seems to be the double of what they earn in Poland.
    They're doing a very nice job at a very high tempo. (they work +/14 hours/day)
    With these wages, a Belgium plasterer can never win a job any longer.
    It's better to keep your mouth shut and give the impression that you're stupid than to open it and remove all doubt.

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    Re: purging and the law

    Quote Originally Posted by Peter_1

    But as said previously, you easily can retract all the gas out of a system when there's a service connection on the discharge side of the compressor.
    Anyone else using this fasts and cheap method?
    Hello, Peter I did ask about this method. http://www.refrigeration-engineer.co...ead.php?t=3783

    as i never got any response i assumed it was not a common practice.

    cheers

    eggs

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    Re: purging and the law

    Quote Originally Posted by eggs
    Hello, Peter I did ask about this method. http://www.refrigeration-engineer.co...ead.php?t=3783

    as i never got any response i assumed it was not a common practice.

    cheers

    eggs
    If it is a small compressor, a cylinder will have enough capacity to be used as a condenser, better removing refrigerant as liquid where possible

    Anyway discharge gas contains oil, with pumpdowns it wouldn't be hard to end up with all the compressor oil in the cylinder, fatal for a pot

    Kind Regards. Andy

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    Re: purging and the law

    I think I never read the post you were referring to.
    And if I read it with the little English I know, I think I should not have realized that this was your question.

    How we do it: attach HP to the service valve (SV) of the receiver. Close the SV and pump it down and hold the LP switch so that the system goes in vacuum. After pumping down, open valve on the manifold and release liquid of the receiver to the refrigerant cylinder.
    Bypass rest of the HP to the LP which is in vacuum.
    Open SV on the receiver completely.
    disconnect hose from receiver.
    Connect it to the SV of the discharge SV on the compressor.
    Let compressor run and also open the bypass to the cylinder.
    Let compressor run and gradually close SV and monitor HP so that it doesn't goes beyond acceptable limits (20 bar)
    After you closed it complete, let it run till LP reaches 0 bar.
    You then have evacuated the whole system, except the small clearance volume above the pistons.

    If you wants to re-use the gas and are afraid of oil contamination, use the method for re-using the gas with the method described 4 posts higher.
    It's better to keep your mouth shut and give the impression that you're stupid than to open it and remove all doubt.

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    Re: purging and the law

    he had been told that it was similar to corgi -IE anyone can do it but you cannot charge .

    It is illegal for any non competent person to install or modify any pipe that is to be used as a gas pipe, the entire gas side of the installation must be carried out by a CORGI gas fitter.

    Recently CORGI went to Europe and succesfully defended against Europes wish to allow foreign gas fitters to work in the UK under the standards and governing body of their home country.
    Karl

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    Re: purging and the law

    Quote Originally Posted by Karl Hofmann

    Recently CORGI went to Europe and succesfully defended against Europes wish to allow foreign gas fitters to work in the UK under the standards and governing body of their home country.


    That?s very interesting, Karl. I wasn?t aware that CORGI had avoided the EU transfer of skills rules.

    Although CORGI held up as an example with refrigeration installations, there is absolutely no comparison and it does muddy the waters even more that they are now.

    Article 5 in the draft of the new F Gas regulation allows a framework for the recognition of other countries skills as far as handling refrigerants is concerned. Ironically the boot is on the other foot here because it means that holders of the CITB or C&G 2078 may be able to practice in other EU countries where the rules are more complex and stringent than ours.

    .
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    Last edited by Argus; 07-02-2011 at 10:00 AM.

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    Re: purging and the law

    In which case, perhaps we should look to improve our own standards so that there is no issue in Europe. It is rare that I agree with much of what CORGI does, but to be fair, they have raised the standards of gas fitting and hense gas safety but I still se an alarming number of gas leaks which have been caused by DIYers. One guy had managed to fill his entire wall cavity with gas, and from what I could tell, it had been like that for some years.

    Fitters from Europe would be just as safe as a British fitter, provided that they were as conciensious, though they may work to the standards of their own country, and so may not comply to all of our regulations, some of which have no obvious purpose. It is the get rich quick merchants that I fear, they get the minimum requirements and then move to undercut, knowing that if there is a problem, then they are impossible to track down, as with part P, we must notify and a gas safety certificate will be issued for any new installation.
    Karl

  19. #19
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    Re: purging and the law

    Hello,
    I have a refrigeration system that uses (very pure) Helium as the refrigerant gas for cooling a dewar. This dewar has Nitrogen Gas pumped into it which condenses within the dewar to make Liquid Nitrogen.

    From what I can see by looking round the site (great stuff btw) it look to me that using Helium as the refrigerant isn't too common. It is an inert gas and due to it's purity couldn't possibly be classed as Fluorinated. I can't find any regs that suggest it can't be vented? Does anyone know differently?
    Many Thanks

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    Re: purging and the law

    .

    The fluorinated refrigerants are man-made industrial gases.
    There are environmental issues surrounding their use and discharge to atmosphere is prohibited by law in the UK and most other countries.
    Waste refrigerants are covered by the Hazardous Waste regulations.

    Nitrogen is used as purge in refrigeration systems and Helium is sometimes introduced as a trace to locate leaks. Small quantities can usually be released without harm, if they are contaminated in any way seek advice.

    Although they are not harmful in the same way as the conventional refrigerant gases, they still have high pressure hazards and are asphyxiants.

    They are not fluorinated and are not covered by the UK laws on chlorinated or fluorinated refrigerants; however you will still be governed by the Health and Safety at Work Act, and need to dispose of them responsibly in line with your company's H&S guidelines.

    You should have an operating manual that tells you what to do.

    .
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    Last edited by Argus; 07-02-2011 at 10:10 AM.

  21. #21
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    Re: purging and the law

    Argus,
    Unfortunately the manual just says to vent it, following your own company guidelines and meeting local regulations!

    I was aware of the asphyxiant issues as well as the high pressure side of things. This has really helped me to make sure I wasn't barking up completely the wrong tree. It shouldn't be too hard for me to write the work procedure now.
    Thanks for your help.

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    Re: purging and the law

    Emma,

    As you are in the UK, you will need to be aware of the H&S at Work Act, COSHH, and most basically the H&S data sheets as given by your supplier.

    There should be no problem with venting Helium and Nitrogen at normal pressures, but make syre that all the PPE is in good order, not only during venting, but during use.

    I would instigate a formal method statement and stipulate that only assessed operators are allowed to use it.

    ..... and don't foget to run it all past your insurance!

    Let me know if you need any more

    .
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    Last edited by Argus; 07-02-2011 at 10:10 AM.

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    Re: purging and the law

    Probably good if you have an oxygen level monitor, you can get fixed or portable ones. Seems a bit of an odd use for helium, why not just buy liquid nitrogen? or are you making very cold liquid nitrogen?
    It's a lovely day to pump some gas

  24. #24
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    Re: purging and the law

    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!

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    Re: purging and the law

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

    Is the unit a cryochill unit??

  26. #26
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    Re: purging and the law

    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

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    Re: purging and the law

    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.

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    Re: purging and the law

    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.

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    Re: purging and the law

    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

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