New F-Gas Regulation (2014): Guidance for Food and Drink Manufacturers. REI Guide 4a. The 2014 EU F-Gas Regulation

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1 REI Guide 4a The 2014 EU F-Gas Regulation

2 REI Guide 4a: F-Gas Regulation Guidance Chapters 1. Introduction Summary of Key Features of the new F-Gas Regulation Phase Down of HFC Supply The Service Ban Bans on HFCs in new refrigeration equipment Other Important Features of the New F-Gas Regulation Less Relevant Aspects of the New F-Gas Regulation Energy Efficiency Issues The Food & Drink Industry Refrigeration Efficiency Initiative This Guide was originally written in 2007 as part of the Refrigeration Efficiency Initiative, a project led by FDF with participation from Carbon Trust, Dairy UK, British Beer and Pub Association, Cold Storage and Distribution Federation and the Institute of Refrigeration. The project delivery team included refrigeration experts from SKM Enviros, Cool Concerns and Star Technical Solutions. The Guide has been updated in August 2014 on behalf of the FDF by Ray Gluckman, Jacobs (formerly SKM Enviros). The updates take into account technology and regulatory changes that have occurred since FDF Page 2 of 15 August 2014

3 REI Guide 4a: F-Gas Regulation Guidance This guide will help you comply with an important new EU Regulation relating to: Use of HFC refrigerants in refrigeration and air-conditioning systems used by food and drink manufacturers The new Regulation will affect all HFC refrigerants including R404A, R410A, and R134a 1. Introduction A new EU F-Gas Regulation came into force in June It is related to the use and emissions of fluorinated greenhouse gases, including HFCs used as refrigerants. The new Regulation will have a significant impact on the use of refrigerants in food and drink manufacturing plants. The new EU F-Gas Regulation will replace the current Regulation that came into force in 2006 (842/2006). This document provides guidance on the new Regulation. The first impacts of the new Regulation are from 1 st January Current F-Gas Regulation The current F-Gas Regulation only had a small impact of the use of HFC refrigerants in food and drink manufacturing. Key aspects of the existing Regulation are: Mandatory leak checks and leak repairs Use of automatic leak detection on large refrigeration systems Mandatory gas recovery during servicing and at end-of-life Use of trained and certificated technicians for all F-Gas handling operations Keeping records about all refrigeration systems containing F-Gas refrigerants New F-Gas Regulation The new Regulation goes considerably further than the existing one and will lead to massive changes in the way that HFCs are currently used. This document provides details about those features of the new F-Gas Regulation that will affect refrigeration users in food and drink manufacturing. The structure of the Guide is as follows: Section 2 provides a summary of the most important changes Section 3 gives details about the phase down of HFC supplies Section 4 gives details about a new service ban that will affect many existing refrigeration systems Section 5 gives details of new bans that affect selection of refrigerants in new refrigeration systems Section 6 discusses new rules that tighten parts of the existing Regulation, especially in relation to mandatory leak testing and leak prevention. Section 7 briefly summarises other features of the new Regulation Section 8 comments on how energy efficiency affects refrigerant choices FDF Page 3 of 15 August 2014

4 2. Summary of Key Features of the new F-Gas Regulation In this section we provide a summary of the key features of the new Regulation, from the perspective of refrigeration users in the food and drink manufacturing industry. The most important new features are: Phase down of HFC supply See Section 3 There will be a significant phase down in the amount of HFCs that can be sold in the EU. Supply of HFCs will be controlled in the EU from 2015, with a series of supply cuts being introduced. By 2030, only 20% of the current HFC volumes will be available for sale. The supply phase down will create strong pressures for refrigeration users to minimise their use of HFCs. One of the most commonly used HFC refrigerants currently used in food and drink manufacturing is R404A this has an especially high GWP (global warming potential) and will become especially scarce / expensive. Service ban for high GWP refrigerants used in existing systems See Section 4 An important new feature is a ban on servicing refrigeration systems that use HFC refrigerants with a GWP above 2,500. This ban will apply from 2020 and will mainly affect users of R404A and R507 systems. Bans for HFCs in new equipment in certain applications See Section 5 The new Regulation introduces bans on the use of HFCs in new equipment in certain specified applications. Most of these bans affect non-industrial refrigeration (e.g. small retail equipment) or non-refrigeration applications (e.g. insulating foam). However, there will be a ban on the use of high GWP refrigerants (such as R404A) in all new equipment from Because of the service ban (see above), there is a de facto ban on high GWP refrigerants from 2014, as it makes no sense to purchase new equipment using a refrigerant that will be affected by the service ban in Certain changes to the rules on leak checking See Section 6 The existing rules on leak testing and leak repair have been strengthened and are based on new size thresholds that target very high GWP refrigerants like R404A. A particularly important new rule is that the size threshold for mandatory installation of automatic leak detection is now only 137 kg for R404A systems (it was 300 kg in the existing Regulation). This rule takes effect from 1 st January 2015, so many medium sized systems in food and drink manufacturing need to take urgent action. Other changes to the Regulation See Section 7 There are various other changes that have less impact on food and drink manufacturers. These are briefly discussed in Section 7. MOST URGENT ACTIONS REQUIRED: a) Avoid buying any new equipment using refrigerants with a GWP above 2,500 (especially R404A or R507) as these will be affected by the service ban. Try and avoid these refrigerants in new equipment from b) Check whether you have equipment affected by the new threshold for mandatory installation of automatic leak detection if you are affected, you need to fit automatic leak detection systems by January c) Consider how the HFC supply phase down process will affect your strategy for leak prevention and purchase of new equipment. d) Check whether you will be affected by the service ban. If you will be affected, start to consider the best strategy for compliance with the service ban. FDF Page 4 of 15 August 2014

5 % of baseline consumption allowed New F-Gas Regulation (2014): Guidance for Food and Drink Manufacturers 3. Phase Down of HFC Supply There will be a massive cut in the volume of HFCs that can be sold on the EU market. Refrigerants currently account for over 80% of HFC sales, so this will put significant pressure on the availability of HFC refrigerants. The phase down will take place in a series of steps, starting in The amount that can be placed on the market each year will be calculated as a percentage of the baseline EU consumption, which was the average annual consumption in the 4 years between 2009 and The annual amounts available for sale in the EU are shown in Figure 1. By 2030 there will be a cut of nearly 80%. 100% 90% 80% Figure 1: EU HFC Phase Down Steps Big cut in % below baseline 70% 60% 50% 40% Final cut in % below baseline 30% 20% 10% 0% There could be major supply shortage by 2018 It is interesting to note that the allowed amounts in the first 3 years (2015 to 2017) are reasonably close to the baseline, but in 2018 there will be a cut of 37%. It is clear that HFC users are going to need to significantly reduce their demand within this 3 year period to avoid supply shortages. Early action is vital! The phase down is GWP weighted The annual quantities allowed are based on GWP tonnes. This means the physical tonnage of each gas sold multiplied by its GWP (global warming potential). This is very important as it will put most pressure on the refrigerants with the highest GWP. Table 1 illustrates the GWPs of a number of common refrigerants. Two commonly used HFCs in industrial refrigeration systems are HFC 404A and HFC 134a. As shown in Table 1, these have GWPs of 3,922 and 1,430 respectively. HFC 404A has a very high GWP it is 2.7 times higher than the GWP of HFC 134a. This means that selling 1 kg of HFC 404A will use up 2.7 times as much of the allowed HFC allocation as selling 1 kg of HFC 134a. It is reasonable to expect that the prices of HFCs will rise considerably as supplies become constrained. It is also reasonable to expect that this price rise will be GWP weighted there will clearly be greatest phase down pressures on HFC 404A and HFC 507. FDF Page 5 of 15 August 2014

6 Table 1: Example Refrigerant GWPs (based on IPCC AR year GWP values) Refrigerant GWP HFC 507 3,985 HFC 404A 3,922 HFC 434A 3,245 HFC 407A 2,107 HFC 407F 1,825 HFC 407C 1,774 HFC 134a 1,430 HFC Propane 5 CO2 1 HFO 1234yf <1 Ammonia 0 The first 8 refrigerants in Table 1 are HFCs these are all affected by the phase down. It is important to note that there are various other HFCs used as refrigerants not shown in Table 1 these are also affected. The last 4 refrigerants in Table 1 are not affected by the phase down. How should you respond to the phase down It is important to note that this is a phase down, not a phase out. A residual amount of HFCs, equivalent to around 20% of baseline sales, will be allowed after To achieve the required cuts, users of HFCs will need to combine 4 strategies: a) For existing systems, consider the possibility of replacing high GWP refrigerant with a medium GWP HFC. For example, use HFC 407F in place of HFC 404A. This will create a 50% cut in GWP weighted demand. This is a realistic example as HFC 407F can often be retrofilled into existing HFC 404A equipment (see Section 4 for further details). b) For existing systems, reduce the quantity of HFCs used by reducing leakage. A good leak reduction strategy can often reduce annual leak rates by at least 50% (see Section 5 for further details). c) For new systems, carefully consider which refrigerant to use. Very high GWP refrigerants such as HFC 404A and HFC 507 should be avoided immediately there are virtually no refrigeration applications in food and drink manufacturing that still need these high GWP refrigerants in new systems. If possible use one of the ultra-low GWP refrigerants in Table 1 (e.g. ammonia, CO 2, HFO 1234yf) these fall outside the scope of the phase down. If that is not possible, there are various new medium GWP refrigerants that will come on the market over the next few years. These have GWPs in the 200 to 700 range (see Section 5 for further details). d) For new systems, ensure a low leakage design. Spending a little extra on good quality components and design strategies that avoid problems like vibration of pipework can keep leakage to a minimum this will be a good investment as the prices of HFCs rise in response to the phase down. FDF Page 6 of 15 August 2014

7 4. The Service Ban A very important feature of the new F-Gas Regulation is the service ban. From 2020, this will prohibit the use of refrigerants with a GWP above 2,500 for the servicing and maintenance of refrigeration equipment. There are 3 exemptions from the service ban: a) It does not apply to very small systems. Systems containing less than 40 tonnes CO 2 equivalent are exempt. However, for HFC 404A this size threshold is only 10 kg the majority of such systems in food and drink manufacturing plants will be above this size threshold. b) It does not apply to systems designed to cool products to temperatures below -50 o C. However, very few food / drink processing operations require a product temperature below -50 o C. c) Until 2030 it does not apply to the use of reclaimed refrigerants this is a useful exemption as it can be expected that some reclaimed HFC 404A and HFC 507 will be available for a few years after Three of the refrigerants shown in Table 1 have GWPs above 2,500 and will be affected by the service ban. In relation to food and drink manufacturing plants: HFC 404A is widely used in both frozen and chill applications. Most HFC 404A systems used in the industry are above the 40 tonnes CO 2 threshold (10 kg). HFC 507 is much less common it is used in a few large applications such as blast freezers. Virtually all HFC 507 systems used in the industry are above the 40 tonnes CO 2 threshold (10 kg). HFC 434A is one of a number of drop-in blends introduced to replace HCFC 22. The 40 tonnes CO 2 equivalent threshold is 12 kg of HFC 434A most systems using this refrigerant are above this size. Some other HFC blends not shown in Table 1, such as HFC 422D, are also above the 2,500 GWP threshold and will be affected by the service ban. The service ban creates a de facto ban on high GWP refrigerants in new plant It is vital that you avoid using refrigerants above the 2,500 service ban threshold in all new plant purchased. If you buy new plant in 2014 using HFC 404A, within 6 years you will be affected by the service ban. Every effort should be made only use refrigerants below the 2,500 GWP threshold in new equipment. This is not a problem for new industrial systems a range of lower GWP options are available. What needs to be done to comply with the service ban? If you have a plant affected by the service ban you should adopt one of three strategies: a) You can retrofill the plant with an alternative refrigerant. A lot of supermarket systems using HFC 404A have been retrofilled with either HFC 407A or HFC 407F. These conversions have been successful and generally led to improved energy efficiency. These refrigerants will be suitable for many industrial plants and will minimise the cost impact of the service ban. b) You can replace the existing plant with a new system this is a good strategy if your existing plant is old or unreliable. c) You can delay action for a few years by purchasing reclaimed refrigerant for plant servicing. This is a slightly risky strategy as the availability of reclaimed refrigerant cannot be guaranteed. FDF Page 7 of 15 August 2014

8 5. Bans on HFCs in new refrigeration equipment The new Regulation includes a number of bans on the use of HFCs in new refrigeration equipment. These are summarised in Table 2. Table 2: New Equipment Bans Ban description Refrigerants affected Ban starts 1 Non-confined direct evaporation systems All HFCs and PFCs 2007 Domestic refrigerators and freezers HFCs with GWP > Refrigerators and freezers for commercial use (hermetically sealed equipment) Stationary refrigeration equipment, except equipment intended for application designed to cool products to temperatures below -50 C Multipack centralised refrigeration systems for commercial use with a rated capacity of 40kW or more HFCs with GWP > 2, HFCs with GWP > HFCs with GWP > 2, HFCs with GWP > Movable room air-conditioning (hermetically sealed) HFCs with GWP > Single split air-conditioning systems containing less than 3kg of refrigerant HFCs with GWP > : All bans start in January of the year specified Are industrial systems affected by bans? The only one of these bans that has an impact on industrial systems is the shaded item in Table 2 i.e. the ban on very high GWP refrigerants, from However, industrial users should treat this date with great care as discussed in Section 4, there is an immediate de facto ban on high GWP refrigerants in new equipment because of the service ban, which also comes into force in The 2020 date is only relevant to very small equipment, below the 40 tonnes CO 2 threshold for the service ban. How does the phase down affect refrigerant choice in new equipment? The bans in Table 2 will influence the choice of refrigerants, but they are not the only factor to take into account. The HFC phase down (as discussed in Section 3) will also be a major influence on the choice of refrigerant. All new equipment purchased in the next few years will still be operating in 2030, when the phase down will limit availability of HFCs to 20% of current consumption. Clearly that will create a significant shortage in HFC supply and will probably lead to very high HFC prices. If you are purchasing new equipment you should make every effort to select a refrigerant with the lowest practical GWP, irrespective of whether there is a ban in place. If you can use an ultra-low GWP refrigerant such as ammonia then you are future proofing your new plant against supply shortages that will occur during the next few years. Table 3 illustrates a range of different refrigerants that can be considered for food and drink refrigeration installations. These have been put into 5 GWP groups. The general rules for refrigerant selection in new systems are: a) Immediately avoid any of the refrigerants in the very high GWP group b) If possible, use a refrigerant from the ultra-low GWP group c) Where this is difficult, consider one of the new moderate GWP options as these become commercially available FDF Page 8 of 15 August 2014

9 Table 3: Refrigerants for use in new systems GWP Group GWP Range Refrigerant GWP Flammability Comments / Applicability Ultra-low 0 to 10 R 717 (ammonia) 0 Mildly flammable R 744 (CO2) 1 Non-flammable HC 290 (propane) 5 Highly flammable HFO 1234yf 4 Mildly flammable HFO 1234ze 7 Mildly flammable Other HFOs <10 Mildly flammable Excellent refrigerant for large systems. Already widely used in food and drink manufacturing. Toxic and mildly flammable, so requires safety precautions. Safety issues make ammonia expensive for small systems. Recently introduced for supermarkets and some industrial applications. Much higher pressure than most refrigerants which creates some practical difficulties. Beginning to be widely used in very small systems. May have some applicability for larger industrial systems with appropriate safety precautions. Newly introduced refrigerant being used for car air-conditioning systems. Has thermodynamic properties similar to HFC 134a, so may become applicable in chill temperature industrial systems. Mildly flammable, so requires safety precautions. Newly introduced refrigerant being trialled in water chillers. Mildly flammable, so requires safety precautions. Various other HFOs have been announced (e.g. 1336mzz and 1233zd) but not yet commercially available. All expected to be mildly flammable. Low 10 to 200 None currently available or known to be under development HFC Mildly flammable Very efficient refrigerant. Prior to 2014 only used as a blend component. Now being introduced for small air-conditioning systems and being considered for some industrial applications. Mildly flammable, so requires safety precautions. Blend A ~300 Mildly flammable New blends being introduced. Similar properties to HFC 404A. Moderate 200 to 1,400 Blend B ~1,300 Non-flammable New blends being introduced. Similar properties to HFC 404A. Blend C ~600 Mildly flammable New blends being introduced. Similar properties to HFC 410A. Blend D ~600 Non-flammable New blends being introduced. Similar properties to HFC 134a. Other blends?? Various other new blends likely to be introduced over next 5 years. FDF Page 9 of 15 August 2014

10 Table 3 continued: Refrigerants for use in new systems GWP Group GWP Range Refrigerant GWP 1 Flammability Comments / Applicability HFC 134a 1430 Non-flammable Widely used in chill temperature systems and water chillers HFC 407C 1774 Non-flammable Used in air-conditioning systems and some small industrial plants High 1,400 to 2,500 HFC 407F 1825 Non-flammable HFC 410A 2088 Non-flammable HFC 407A 2107 Non-flammable HFC 417A 2346 Non-flammable Being introduced as an alternative to HFC 404A. Can be retrofilled into existing HFC 404A systems as well as being used in new plants. Widely used in small air-conditioning and small water chillers. Can be used in small industrial applications. Being introduced as an alternative to HFC 404A. Can be retrofilled into existing HFC 404A systems as well as being used in new plants. Used as a drop-in replacement for HCFC 22 to keep existing plants operating after the ban on use of HCFC 22 under the EU Ozone Regulation. With a GWP below the 2,500 threshold it is not affected by the HFC Service Ban in HFC 422D 2725 Non-flammable Both are used as drop-in replacements for HCFC 22 to keep existing plants operating after the ban on use of HCFC 22 under the EU Ozone Regulation. With a GWP above the 2,500 threshold these refrigerants are both affected by the HFC HFC 434A 3245 Non-flammable Service Ban in 2020 Very high >2,500 HFC 404A 3922 Non-flammable HFC Non-flammable Widely used in both industrial and commercial refrigeration. Originally intended for low temperature applications (frozen food) although also widely used in chill temperature systems. There are much lower GWP alternatives available for ALL new food and drink industry refrigeration systems. Similar refrigerant to HFC 404A. Not widely used in the UK, although more common in USA. There are much lower GWP alternatives available for ALL new food and drink industry refrigeration systems. 1 GWPs used in this paper are from 2007 IPCC 4 th Assessment Report, 100 year values FDF Page 10 of 15 August 2014

11 Understanding refrigerant flammability As discussed above, the phase down of HFC supply will encourage refrigeration users to avoid buying new plants with refrigerants in the high and very high GWP groups. As shown in Table 3, all the HFC refrigerants in these 2 GWP groups are non-flammable. That made it relatively easy to safely use these refrigerants in a wide range of small and medium sized industrial applications. Many of the refrigerants in the ultra-low and moderate GWP groups have some flammability. This means that extra safety precautions are required to use them. However, it is important to recognise that the flammable refrigerants fall into 2 very different sub-groups: a) Highly flammable refrigerants. Hydrocarbon refrigerants such as propane are defined as highly flammable. They are very easy to ignite (e.g. a small spark) and burn with very high flame velocity burning can take place with explosive characteristics. This makes them very dangerous in the event of refrigerant leakage significant safety precautions are required. b) Mildly flammable refrigerants. Many of the other ultra-low and moderate GWP refrigerants are defined as mildly flammable. These refrigerants are much harder to ignite (they need a very high energy ignition source) and they burn with very low flame velocity (to be mildly flammable the flame velocity must be less than 10 cm per second). This makes risk of ignition much lower and the consequences of ignition are much less severe as the burning is gentle. However, the fact that the refrigerant can ignite must be taken into account during plant design and operation. Historically the refrigeration industry has made little use of mildly flammable refrigerants the only exception is ammonia. As ammonia is also highly toxic, so significant safety precautions are always required for ammonia systems. It is likely that in the future the refrigeration industry will make much more use of nontoxic mildly flammable refrigerants such as HFOs and HFO / HFC blends. Codes of safe practice for using these refrigerants are still being developed. Commercial availability of refrigerants In the ultra-low GWP group ammonia, CO 2 and propane have all been commercially available for many years. However, the new HFO refrigerants have only been in commercial scale production since 2013 and have not yet been used in many refrigeration installations. It is unlikely that HFOs will be in widespread use in new systems until around In the moderate GWP group, HFC 32 has been in commercial scale production for many years, but has only been used as a component in certain high GWP refrigerant blends (including HFC 410A and HFC 407F) because of its mild flammability. It has been used in small air-conditioning systems since 2013 and is expected to be widely used in new air-conditioning units by Use of HFC 32 in industrial systems may become common by The various moderate GWP blends referred to in Table 3 are all under development. Early field trials are currently taking place. Full commercial availability of these blends cannot be expected until around 2016 to Some of the high GWP refrigerants, especially HFC 134a, HFC 407A and HFC 407F should be considered as interim alternatives for very high GWP refrigerants such as HFC 404A. They are a logical choice for new equipment in 2014 / 2015, but will probably be superseded by lower GWP alternatives by around FDF Page 11 of 15 August 2014

12 6. Other Important Features of the New F-Gas Regulation The new Regulation continues or strengthens a number of requirements that are already in the 2006 Regulation. The most significant change is the introduction of tonnes CO 2 equivalent size thresholds in place of kg of refrigerant thresholds. Mandatory leak checks and repairs All systems above certain size thresholds must be regularly checked for leakage by trained technicians and any leaks identified must be promptly repaired. This requirement is broadly similar to the existing rules for leak checks, except that the size thresholds are based on tonnes CO 2 equivalent. This means that the physical size threshold (in kg of refrigerant) is different for each refrigerant as the GWP must be taken into account. Table 4 shows the old and new size thresholds and Table 5 gives illustrations of the new thresholds for different refrigerants. Table 4: Leak Checking Frequency Frequency Old Threshold New Threshold Annual 3 kg to 30 kg 5 to 50 tonnes CO 2 Every 6 months 30 kg to 300 kg 50 to 500 tonnes CO 2 Every 3 months >300 kg > 500 tonnes CO 2 In relation to Table 4, also note that: a) The frequency is halved if automatic leak detection equipment is fitted b) There is a 2 year derogation on the 5 tonnes CO 2 threshold for plants with less than 3 kg of refrigerant. The requirement to leak test plants with <3kg but more than 5 tonnes CO 2 begins in January All other new thresholds apply from January c) The lower threshold for annual checks of hermetically sealed refrigeration equipment is 10 tonnes CO 2 (or 6 kg before 2017). Table 5: Example Thresholds Refrigerant 5 tonnes CO 2 50 tonnes CO tonnes CO 2 HFC 404A 1.3 kg 13 kg 127 kg HFC 410A 2.4 kg 24 kg 240 kg HFC 407C 2.8 kg 28 kg 282 kg HFC 134a 3.5 kg 35 kg 350 kg As illustrated in Table 5, for the majority of commonly used refrigerants, the new tonnes CO 2 thresholds are for lower kg amounts than the old thresholds of 3, 30 and 300 kg. The thresholds are considerably lower for HFC 404A because of its very high GWP. For HFC 134a, the new thresholds give a slightly high kg amount than the old thresholds. FDF Page 12 of 15 August 2014

13 Automatic leak detection systems All refrigeration systems containing above 500 tonnes CO 2 of refrigerant must be fitted with a leakage detection system which alerts the operator or a service company of any leakage. This is similar to a requirement in the 2006 Regulation, but the size threshold is 500 tonnes CO 2 instead of 300 kg. The rule applies from January This creates an urgent action for operators of systems with less than 300 kg but more than 500 tonnes CO 2. The new thresholds are illustrated in Table 5 for HFC 404A the new threshold is only 127 kg (compared to 300 kg in current Regulation). It is important that factories with HFC 404A (or other very high GWP refrigerants) check whether they are affected by this change. Refrigerant recovery It is illegal to vent any HFC refrigerants to atmosphere during plant servicing or endof-life decommissioning. Refrigeration plant owners must ensure that HFC refrigerants are properly recovered using specialized recovery equipment operated by trained technicians. This is similar to the recovery requirement in the 2006 Regulation. Use of trained technicians All HFC refrigerant handling operations must be carried out by technicians with an appropriate F-Gas handling certificate. This includes refrigerant handling during new plant installation, servicing and maintenance and end-of-life decommissioning. It also includes mandatory leak testing and refrigerant recovery as discussed above. This is similar to the training requirement in the 2006 Regulation. The relevant UK qualifications include City & Guilds 2079 and CITB J11. All companies employing trained technicians that work as contractors for 3 rd parties require a Company Certificate. In the UK these certificates can be obtained from Refcom, Quidos or Bureau Veritas. Record keeping Operators of refrigeration systems with HFC refrigerant charge above the leak testing thresholds must keep records for each piece of equipment for at least 5 years and must make these available to the Government if requested. The records must show: the quantity and type of HFC refrigerant in the system when purchased the quantities of HFC refrigerant added during installation, maintenance or servicing details of any reclaimed or recycled HFC refrigerant added to the plant the quantity of any HFC refrigerant recovered the identity of the undertaking which installed, serviced, maintained and where applicable repaired or decommissioned the equipment, including, where applicable, the number of its certificate; the dates and results of the mandatory leak checks carried out if the equipment was decommissioned, the measures taken to recover and dispose of the fluorinated greenhouse gases This is similar to the record keeping requirement in the 2006 Regulation. There is a new requirement for contractors to keep data they collect on behalf of their customers for at least 5 years. FDF Page 13 of 15 August 2014

14 7. Less Relevant Aspects of the New F-Gas Regulation The new F-Gas Regulation includes many other requirements that apply to nonindustrial refrigeration or air-conditioning systems or that apply to completely different F-Gas applications such as aerosols, insulation foam and high voltage switchgear. The other main requirements are summarised in Table 6. Table 6: Other Features of the New F-Gas Regulation Item Leak checking, refrigerant recovery, record keeping Purchase of refrigerants and other F-Gases Sale of pre-charged non-hermetically sealed systems Equipment labelling and instruction manuals Other bans of HFCs in new equipment Import of pre-charged equipment HFC Quota System F-Gas Reporting Summary of Requirement Requirements for mandatory leak checks, F-Gas recovery and record keeping also apply to other F-Gas applications including: refrigerated trucks and trailers, fire protection equipment and high voltage switchgear. Only technicians / companies that hold suitable F-Gas handling certificates are allowed to purchase bulk supplies of refrigerant or other F-Gases. Companies selling these gases are responsible for checking compliance with this requirement and must keep records of who they sell F-Gases to. Equipment of this type (e.g. small split system air-conditioning) can only be sold to an end user where evidence is provided that the installation is to be carried out by an undertaking with a suitable F- Gas handling certificate Products and equipment that contain, or whose functioning relies upon, F-Gases shall not be placed on the market unless they are labelled. The label must show type of F-Gas used and quantity installed. This information must also be included in the instruction manuals for the equipment being sold. In addition to the bans shown in Table 2, the new Regulation includes new bans on HFCs in: Fire protections systems using HFC 23 (from 2016) Technical aerosols (from 2018) XPS insulating foam (from 2020) Other insulating foam (from 2023) Any pre-charged refrigeration, air-conditioning or heat pump equipment using HFC refrigerant that is imported into the EU must contain refrigerant purchase from the EU Quota System The phase down will be controlled via a quota system. Re frigerant producers and importers will be issued with quotas, based on their historic sales. There will be an 11% new entrant reserve to enable new players to enter the market. Producers, importers and exporters of F-Gases must annually report quantities placed on the market in the EU FDF Page 14 of 15 August 2014

15 8. Energy Efficiency Issues It is important to note that the greenhouse gas emissions from all refrigeration systems consist of two distinct parts: a) The direct global warming impact related to emission of high global warming potential (GWP) HFCs, such as HFC 134a and HFC 404A. Direct CO 2 emissions mostly occur via leakage of refrigerant during the operating life of equipment or through venting of refrigerant during plant decommissioning at end-of-life. b) The indirect global warming impact related to the emission of CO 2 from power stations that supply the electricity required by the refrigeration systems. The indirect energy related emissions are usually the dominant part of the total, even in systems using high GWP refrigerants. In a typical industrial plant using HFC 404A the energy related emissions form 80% to 90% of the total. When selecting a new refrigerant it is important to consider the energy efficiency impact of (a) the new refrigerant itself and (b) the overall design of refrigeration system being considered. It makes no sense to reduce the direct emissions but to increase the total emissions because of poor efficiency. It is beyond the scope of this document to discuss energy efficiency issues in detail, but the following points are worth noting: If you are buying new refrigeration equipment there are usually numerous opportunities to improve efficiency. Ensure that you minimise the cooling demand (e.g. can a hot product be pre-cooled using ambient air or cooling tower water). Then ensure that the plant design can deliver efficient cooling at all common operating conditions. It is very common that plants are optimised for efficient operation at the design point i.e. at peak cooling load in hot weather. This is not ideal the plant rarely runs under design point conditions. The plant needs to have maximum efficiency under common part load conditions and in milder weather. An important decision is whether to use a secondary refrigerant such as propylene glycol to transfer cooling from the main refrigeration plant to the process. This can be convenient as (a) any safety issues related to a flammable or toxic refrigerant are restricted to the engine room and (b) a single refrigeration plant can serve several different cooling loads. However, you should look carefully at the energy efficiency of such secondary systems they are often much less efficient than using the primary refrigerant directly. For existing HFC 404A plants it is possible that a retrofill to HFC 407A or HFC 407F will improve efficiency. FDF Page 15 of 15 August 2014