For various “controlled substances”, such as refrigerant R22, a ban on production and marketing has been in place since 1 Jan. 2015. Up to now, it was possible to recover these substances from old facilities and re-use the recycled material for maintenance and repairs. Since 1 Jan. 2015, this is no longer possible the case. Existing facilities that contain refrigerant R 22 can continue to be operated. However, refilling of the substance as part of maintenance or repair work is now banned.
As previously, the number of leak tests depends on the nature and quantity of the refrigerant. However, in the new regulation, not only the amount of the refrigerant is used as a basis for the calculation, but also the global warming potential of the substance. This global warming potential (GWP) is expressed in CO2 equivalents. In practice therefore, it is not enough to simply consider the amount of refrigerant added; the GWP of the refrigerant must also be calculated, in order to determine whether and how often leak tests are required.
The new basis of the calculation means that more facilities are subject to audit. In the future, a leak test must be performed by a specialist firm at least every 12 months for a quantity of 5 tonnes of CO2 equivalent or more. Equipment with a refrigerant capacity of less than 3 kg, which previously did not need to be examined, may now fall under this provision. For example, many supermarket refrigerating systems filled with 1.3 kg or more of R 404A are affected. The frequency of testing increases as the quantity increases (every 6 months for 50 tonnes of CO2 equivalent, and every 3 months for 500 tonnes). If a leakage-detection system is installed, the inspection interval is extended to 24, 12 or 6 months. Leakage-detection systems may be mandatory, depending on the type of plant, for example for stationary cooling, air-conditioning, and heat-pump systems.
The requirements regarding record-keeping have also been stated more precisely. The new regulation now stipulates exactly what information is to be contained in the operations journal. In addition to the amount and type of the contained and/or refilled fluorinated greenhouse gases, other specifics are required, including whether it is recycled or reconditioned refrigerant. These records must be retained for a period of five years.
As part of the legal check, Arqum checks whether your equipment falls within the scope of the Regulation, and determines the concomitant inspections required.
Sources: Federal Environment Agency, EPEE
Contact person at Arqum: Dr. Stephanie Bleeck-Schmidt (ed.mu1627732564qra@t1627732564dimhc1627732564s-kce1627732564elb1627732564).