GUIDANCE DOCUMENT FOR THE OFFSHORE INDUSTRY ON THE EU F-GASES REGULATION (EC) No. 842 / 2006 REVISED: APRIL 2011 URN 10D / 689 © Crown Copyright Contents Page(s) 1.0 Introduction 3&4 2.0 Regulatory requirements on offshore Operators 3.0 Additional obligations 7 4.0 Other sources for guidance 8 5.0 Future developments 8 6.0 DECC - EDU / OED contact 9 4, 5, 6 & 7 Annexes Annex A - Guidance Sheet for the Offshore Industry 10 & 11 Annex B - Record Maintenance Template 12 Annex C - Reporting Form for Unintentional / Accidental Emissions 13 Annex D - Calculation method and Fluid Properties / Global Warming Potential (GWP) Factors to be used for converting F-gas emissions to `tonnes of CO2 equivalent’ 14 Annex E - Specific regulatory aspects to be assessed by DECC’s offshore Inspectors 15 Page 2 of 16 1.0 Introduction 1.1 The objectives of the EU F-Gases Regulation (EC) No. 842 / 2006 (“the EU F-Gases Regulation”) are to contain, prevent and reduce atmospheric emissions of Fluorinated greenhouse gases (“F-gases”) covered by the Kyoto Protocol (i.e. Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulphur Hexafluoride (SF6)) as listed in Annex 1 to the EU F-Gases Regulation from refrigeration systems, airconditioning units, fire-protection systems, heat pumps and high voltage switchgear. 1.2 In December 2007, the EU formally issued supplementary Regulations to the F-Gases Regulation on: (i) leakage checking standards for refrigeration systems, air-conditioning units and heat pumps; (ii) leakage checking standards for fire-protection systems; and (iii) the labelling requirements for all types of equipment. These requirements are briefly described in Section 2 with web-links to the respective Regulations provided in Annex A. These aspects together with other EU measures for companies / personnel that provide services involving the handling of F-gases (see Section 3) will be enforced by the UK F-Gases Regulations as referred to in paragraph 1.3. 1.3 On 9 March 2009 and 12 May 2009 respectively, the GB Fluorinated Greenhouse Gases Regulations 2009 (covering England, Wales and Scotland) and the F-Gases Regulations (Northern Ireland) 2009 entered into force - details at https://www.og.decc.gov.uk/environment/F-Gas2009.pdf and http://www.legislation.gov.uk/nisr/2009/184/contents/made (both sets of Regulations are hereinafter referred to as “the UK F-Gases Regulations” except where indicated). The UK F-Gases Regulations detail offences, enforcement powers and prescribe penalties for non-compliance with the EU F-Gases Regulation (see paragraph 1.7) - the offshore industry is among the sectors covered. On 1 July 2010, the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010 entered into force. The Order applies the requirements of the GB F-Gases Regulations to offshore Carbon Capture and Storage (CCS) and gas unloading / storage (GUS) activities (the Order is at: https://www.og.decc.gov.uk/environment/eaco_2008.pdf). 1.4 The purpose of this guidance document is to set out the various requirements on Operators under the EU F-Gases Regulation that will be enforced offshore by the Offshore Environment and Decommissioning Branch (OED) of DECC’s Energy Development Unit (EDU) - see Annex E for the core aspects against which DECC’s offshore Inspectors will assess Operator compliance with the relevant regulatory obligations. However, DECC (EDU-OED) would not be the competent authority for enforcing the provisions of the NI F-Gases Regulations 2009 on any offshore installations undertaking CCS and GUS activities that might be positioned in Northern Ireland’s territorial waters (this responsibility would fall to the Department of the Environment in Northern Ireland (DOE NI)), so these particular Regulations are not included in the Consequential Order referred to in paragraph 1.3. 1.5 DECC will regard the licensed Operator (i.e. the licence holder) as being responsible for ensuring that the provisions of the EU F-Gases Regulation are complied with. However, it is acknowledged that in some cases another company may be responsible for undertaking the day-to-day operation / management of an offshore installation on behalf of the licensed Operator. This could be the owner of the installation; the duty holder of the installation; a company contracted to "operate" the installation; or a company contracted to undertake specific works on behalf of the "approved" Operator. Nevertheless, in such circumstances, the licensed Operator will need to make sure that sufficient systems and procedures, or where applicable contractual obligations, are in place to ensure adherence to the requirements of the EU F-Gases Regulation. 1.6 In this context, where a Mobile Drilling Unit (MODU) is supplied under contract to assist offshore activities, we would strongly recommend that the licensed Operator liaises closely with the contractor operating the MODU in order to determine how the obligations of the EU F-Gases Regulation are to be complied with i.e. the operator of a MODU providing the licensed Operator with copies of any procedures to be used to ensure compliance ahead of commencing activities and subsequently, any Page 3 of 16 records that have been maintained during the period of operation relating to the functioning of any Fgas containing equipment on the facility plus an inventory of equipment / associated levels of F-gases contained therein (i.e. to enable the reporting of emissions to the Environmental Emissions Monitoring System (EEMS) - see Section 2 (paragraph 2.3 part D)). It is also the case that where a MODU was planning to operate specifically in UK territorial waters or the United Kingdom Continental Shelf (UKCS) it would require a `Consent to Locate (CTL)’ from DECC and application for CTL would be a useful trigger point for addressing the F-Gas compliance requirements - for more information on CTL see guidance at: https://www.og.decc.gov.uk/environment/cpa1949.htm. 1.7 The EU F-Gases Regulation and the UK F-Gases Regulations have many provisions relating to the control and prohibition of F-gas emissions, however, not all are immediately relevant to the offshore industry, and this guidance document only concerns those provisions which it is considered are likely to affect it. Therefore, this guidance is not intended to be exhaustive as regards compliance with the entirety of the EU F-Gases Regulation or the UK F-Gases Regulations, but is only intended to assist Operators in complying with provisions which are relevant to them. Details on the enforcement powers, specific offences and penalties (for non-compliance with the requirements of the EU F-Gases Regulation) are contained in Part 4 (Enforcement, offences and penalties) to the UK F-Gases Regulations. 2.0 Regulatory requirements on offshore Operators 2.1 The Guidance Sheet at Annex A outlines the relevant requirements on Operators to ensure compliance with the EU F-Gases Regulation. 2.2 Under Article 9(1) of the EU F-Gases Regulation, the placing on the market of certain F-gas containing equipment - as listed in Annex II to the Regulation - was prohibited from either 4 July 2007 or on the same date in 2008 or 2009 - note: the prohibition does not apply to appliances such as catering / domestic refrigeration or air-conditioning units. Accordingly, in the unlikely event that any Operators obtained some of the types of equipment listed in Annex II on or after the specified dates, then they may be required to remove the equipment for safe disposal unless it can be proven that it was manufactured before the applicable prohibition date. 2.3 The other obligations of the Regulation (as described below) apply to stationery refrigeration systems, air conditioning units and heat pumps (including their circuits) and fire-protection systems (FPS). With the exception of item (A), the obligations relate to equipment which contain 3kg or more of F-gases (although in the interests of best practice Operators may wish to consider applying the provisions to appliances containing F-gases below the specified threshold that are not hermetically sealed - but this is, of course, not mandatory) and concern the need for Operators to: (A) Under Article 3(1) - prevent and repair as soon as possible detected leakages from all relevant equipment (regardless of F-gas levels contained therein) that are covered by the EU F-Gases Regulation. (B) Under Article 3(2) - undertake periodic leakage inspections, the frequency of which is determined by the level of F-gases contained in equipment - as detailed in Annex A. Equipment should be checked within one month of any repairs to ensure that they have been effective. The EU Commission has introduced Regulations (in accordance with Article 3(7)) on leakage checking standards for equipment - web-links to which are included in Annex A. Leakage tests can invariably involve the use of `direct’ measuring techniques such as: A hand held electronic gas detector. Page 4 of 16 UV sensitive detection fluid or dye in the refrigerant. Soap suds or proprietary bubble solutions. It is best (where possible) to use a combination of techniques i.e. an electronic detector to test a wide area and soap suds to identify the exact location of a leak. In certain situations it will be more appropriate to use `indirect’ leak measurement methods basically involving the observation of factors such as temperatures and pressures in equipment i.e. refrigeration systems, to ascertain whether there has been a reduction in inventory of refrigerant. This can be useful if parts of the equipment are inaccessible (when a hand held leak detector may not be appropriate). If a leak is suspected, then it will often be necessary to use `direct’ measurement methods to identify the exact location of the leak. Indirect measuring methods can be valuable in cases where the leakage develops very slowly and where equipment is placed in a well ventilated environment making it difficult to detect F-gases escaping from the system into the air. Under Article 3(3) any equipment (as listed in paragraph 2.3 above) with more than 300kg of Fgases must be fitted with a leakage detection system. In the case of FPS with 300kg + of F-gas that were installed before 4 July 2007, such leakage detection systems had to be fitted by 4 July 2010. Leakage detection systems should be checked at least once a year to ensure proper functioning. In accordance with Article 3(4) where equipment that contains 30kg + and 300kg + of F-gas is fitted with a leakage detection system, the frequency of leak checking can be halved. As indicated in Article 3(5), in the case of FPS where there is an existing inspection regime in place that meets ISO 14520 standard, these inspections may also fulfil the EU F-Gases Regulation’s obligations so long as those inspections are at least as frequent. Two types of leak detection systems can be considered: A direct system, which uses electronic sensors to detect the presence of leakages in areas adjacent to equipment. An indirect system, which interprets measurements within equipment to predict a leak. This might include liquid level in a receiver vessel combined with relevant temperatures and pressures. There are advantages and disadvantages to both types of system as explained below: - A direct system gives a `robust’ indication of a leak if the sensor is located in the right place but it is not effective if a leak is outdoors or a long way from a sensor. A direct system often helps locate the general vicinity of the leak. - An indirect system requires `built-in intelligence’ as it is quite difficult to interpret varying conditions of liquid level and pressures / temperatures within equipment, which can vary widely even if no leak has occurred. However where, for example, a refrigeration system has components in several locations or has components in exposed outdoor locations then an indirect system might be the only practical option for detecting leakages. It will therefore be necessary for Operators to take into account the specific circumstances of equipment when selecting the best approach for detecting leakages. Page 5 of 16 (C) Under Article 3(6) - maintain annual records of: the quantity and type of F-gases installed in equipment; any F-gases that are added to, or recovered (as specified in Article 4) from, equipment on site during maintenance / servicing and final disposal - equipment labels would also have to be updated with the resulting quantity (the EU Commission has introduced a Regulation on the labelling of equipment - a web-link to which is included in Annex A). leakage checking / repairs - including the dates and results of the checks; checks on the proper functioning of any leakage detection systems that are fitted to equipment - including the dates and results of the checks; the identity of the company / technician who performed the servicing / maintenance / leakage checking - including any checks on leakage detection systems; and information on equipment with 30kg+ and 300kg+ of F-gases. For manned installations records should be retained offshore. Where installations are unmanned, records should be kept at the Operator’s onshore premises. For this purpose, Operators may wish to use the template at Annex B for maintaining the required records. Operators must maintain the required records for each calendar year i.e. 1 January to 31 December. (D) Monitor and annually report (by 31 March each year) data to the Environmental Emissions Monitoring System (EEMS) on all emissions of HFCs / PFCs and SF6 from relevant equipment i.e. with 3kg+ of these substances (see also instructions in paragraph 2.4 on additional reporting requirements for unintentional or accidental emissions). This EEMS reporting requirement is linked to the provisions of Article 6(4), as the data provided will enable DECC to monitor over time the extent of emissions of F-gases from relevant equipment. Intentional or inherent emissions under normal operating conditions are classified as gradual leakages that occur during the normal operation of equipment i.e. there are many potential leak locations, especially on large systems that have numerous joints, valves and compressors. Where leakages are slow they can go unnoticed for long periods and result in direct emissions of F gases and poor equipment performance - often leading to wasted energy. Unintentional or accidental emissions are generally considered to be significant / unexpected leakages that occur during the normal operation of equipment (i.e. where a significant amount or all F-gases are lost due to a major system failure i.e. a refrigerant pipe burst, or where substances are lost during the maintenance of equipment i.e. involving the addition / removal of F-gases). Some years ago it was the case that during the maintenance / servicing of equipment any F-gases were simply vented to the atmosphere, however, it should be noted that this practice is now illegal. 2.4 Reporting of unintentional or accidental emissions: With regard to unintentional or accidental emissions of F-gases, where total losses equate to 1,000 tonnes of CO2 equivalent or more, Operators will also be required to report these (along with the corresponding amount in kgs) to DECC’s Offshore Inspectorate ([email protected]) - via the form at Annex C - within 48 hours of it being established (i.e. during the course of scheduled maintenance) that such an incident had occurred. This requirement is also linked to the provisions of Article 6(4). The calculation method and Fluid Properties / Global Warming Potential (GWP) Factors to be used for converting F-gas emissions to `tonnes of CO2 equivalent’ are provided at Annex D. Operators would not have to submit an Annex C form report where unintentional or accidental emissions were below the abovementioned Page 6 of 16 threshold. Nevertheless, please note that all emissions from equipment with 3kg+ of F-gases regardless of their origin / level - should be reported annually to EEMS (as indicated under paragraph 2.3 part D). It is, of course, the case that emissions of F-gases will be reported to EEMS in kgs. Operators will therefore, need to take care when determining whether any unintentional / accidental emissions of F-gases were likely to meet the Annex C reporting criteria of 1,000 tonnes + of CO2 equivalent (i.e. a 500kg (0.5 tonne) emission of HFC 134A would equate to 650 tonnes of CO2, whereas a 500kg emission of HFC 404A would be equal to 1,630 tonnes of CO2). 2.5 Reporting non-compliance: If any Operators believe that they might be at risk (for whatever reason) of breaching the obligations set out in this guidance document then we would encourage them to report - via a brief e-mail to DECC’s Offshore Inspectorate ([email protected]) any potential, or actual instances of, regulatory non-compliance so that pragmatic solutions can be agreed. Operators should address any queries on the policy aspects described in this document to David Foskett - see contact details in Section 6. 3.0 Additional obligations 3.1 There are additional obligations - implemented under the UK F-Gases Regulations - concerning training and qualification requirements for personnel handling / recovering F-gases from equipment (regardless of the levels contained i.e. < or > 3kg). These obligations (referred to in Article 5 of the EU F-Gases Regulation) are based on supplementary EU Regulations (published in April 2008). More information on the supplemental EU Regulations can be found at: http://ec.europa.eu/clima/documentation/f-gas/index_en.htm. It is also the case that where Operators employ their own in-house technicians to maintain / service F-gas containing equipment, then these Operators will need to obtain company certificates which indicate that they employ personnel who hold appropriate qualifications (the requirements for company certification are included in the UK F-Gases Regulations). Details on the company certification scheme in the UK can be accessed from: http://archive.defra.gov.uk/environment/quality/air/fgas/documents/fgassupport-companycert5.pdf. 3.2 A key obligation is that all companies involved in refrigerant handling activities (during installation, maintenance or servicing) required either an interim or full company certificate by 4 July 2009 (an interim company certificate is valid until 4 July 2011 after which a full certificate should be obtained). Operators who use sub-contractors to maintain their F-gas containing equipment are not affected. Whilst the obligations in question are outside DECC’s regulatory remit and the onus for compliance will predominantly reside with companies in the service / maintenance sector, it is nevertheless recommended that Operators check to ensure that all personnel working with F-gas containing equipment on their installations are qualified in line with the existing requirements and those which will eventually apply in the future (as from July 2011) and that interim or full company certificates are acquired if necessary. 3.3 On 15 December 2009, Defra announced (as part of a consultation on the new GB OzoneDepleting Substances (ODS) Regulations for enforcing the EU ODS Regulation (EC) No. 1005 / 2009) a proposal for amending the `interim personnel qualification’ provisions of the GB F-Gases Regulations 2009 - see proposed modifications at: http://webarchive.nationalarchives.gov.uk/20100505154859/http://www.defra.gov.uk/corporate/consult/o zone/fgas-si-amendment.pdf. 3.4 For information on the other requirements that are outside DECC’s regulatory responsibilities i.e. the recycling / reclamation / destruction of recovered F-gases, please use the web-links provided in Section 4. Page 7 of 16 4.0 Other sources for guidance 4.1 For additional guidance on all aspects pertaining to the EU F-Gases Regulation, Operators should access the Defra / F-Gas Support Information Sheets which are available from: http://ww2.defra.gov.uk/environment/quality/air/fgas/srac/. More generic Government guidance can be found at: http://www.bis.gov.uk/policies/business-sectors/environmental-and-productregulations/environmental-regulations/fluorinated-greenhouse-gases and http://ww2.defra.gov.uk/environment/quality/air/fgas/. 5.0 Future developments 5.1 Further action needs to be taken on HFCs and this action needs to be agreed at international level and followed through with comprehensive EU legislation, so that there is a global solution to the prospect of rising HFC use. 5.2 At the Copenhagen Climate Change Summit (December 2009) an Accord was produced for the first time that lists commitments to cut emissions by both developed and developing countries and which introduces real scrutiny to ensure emission targets are met by both developed and developing countries, with mandatory reporting every two years. An EU clause regarding measures to progressively reduce the production and consumption of HFCs was kept on the table until the very last stage and this will prove extremely useful for future international work on HFC mitigation. The UK, along with the rest of the EU, will now work hard to ensure that this HFC text is taken forward for action at the next Conference in Mexico (December 2010) and will be playing an active role in building support for the EU position along the way. 5.3 In the meantime, the EU Commission has engaged contractors (OKO Recherche - Germany) as the first step in a review of all existing F-gas obligations (including those relating to HFCs) in order to see how they need to be modified / strengthened. The review will include work on options for an emissions reduction arrangement for HFCs and other F-gases. This work will identify the technically and economically feasible, effective, efficient and consistent options for further EU action. An advisory group is to be set up to inform this process. Based on the outcome of the review, the Commission is expected to make proposals for further action by July 2011 (as indicated in Articles 10(2) and 10(3) of the EU F-Gases Regulation). 5.4 Defra has issued a paper on the abovementioned review of the F-Gases Regulation. The paper (enclosed below) was circulated to offshore-sector stakeholders on 15 March 2010, with a request that any comments submitted to the contractors undertaking the review be copied to DECC (David Foskett see contact details in paragraph 6.1). 5.5 In a related development, the Air Conditioning and Refrigeration Industry Board (ACRIB) recently completed an assessment on the effectiveness of the EU F-Gases Regulation in the UK (based on experience of the application by the stationary refrigeration, air conditioning and heat pump industry in the UK). Details on the assessment are available at: http://www.acrib.org.uk/web_images/documents/ACRIB%20Statement%20on%20F%20Gas%20Revie w%20release%2012th%20July%202010.pdf. 5.6 This guidance document will be updated to reflect: (i) any amendments to the GB F-Gases Regulations 2009 proposed by Defra; and (ii) developments arising out of the EU review process. Page 8 of 16 6.0 DECC - EDU / OED contact 6.1 For enquires on this guidance document please contact: David Foskett ([email protected]). Department of Energy and Climate Change (DECC) Energy Development Unit (EDU) Offshore Environment and Decommissioning Branch (OED) Date: April 2011 Page 9 of 16 ANNEX A EU F-GASES REGULATION (EC) No. 842 / 2006 GUIDANCE SHEET FOR THE OFFSHORE INDUSTRY Provisions Reporting actions EU F-Gases Regulation requirements and Operators’ obligations Requirements / Operators’ obligations (i) Data on total F-gas emissions to air from refrigeration systems, air-conditioning units, heat pumps and fire-protection systems (FPS) - as a result of intentional / inherent and unintentional / accidental releases - should be acquired by Operators and reported annually to EEMS. (ii) Significant unintentional / accidental F-gas emissions equal to or greater than 1,000 tonnes of CO2 equivalent must be reported (along with the corresponding amount in kgs) to DECC - using the form at Annex C - within 48 hours of it being established that such an incident had occurred. Leakage prevention – all equipment Leakage checking – equipment with 3kg or more of Fgases (iii) Any potential, or actual instances of, regulatory non-compliance should be reported to DECC’s Offshore Inspectorate ([email protected]). Operators of refrigeration systems, air-conditioning units and heat pumps - including their circuits, and FPS are to: (a) prevent leaks of F-gases listed in Annex 1 to the EU F-Gases Regulations (i.e. Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulphur Hexafluoride (SF6)); and (b) repair detectable leakages ASAP (note point under item (ii) of `Reporting actions’ on significant emissions). Operators to ensure relevant equipment is checked for leakages according to the following schedule (Operators should ensure that leakage checks are undertaken by certified personnel): F-gas Frequency of checks / inspections levels Once every 12 months (except for appliances labelled as hermetically sealed and 3kg+ where the content of F-gases is <6kg). Once every 6 months 30kg+ If leakage detection system is installed - inspections can be every 12 months. Once every 3 months 300kg+ Equipment containing these levels of F-gases should have a leakage detection system (LDS) installed (to be checked annually) - inspections would then be every 6 months. Fire protection equipment installed before 4 July 2007 had to have a LDS fitted by 4 July 2010 (obligations would be fulfilled if an inspection regime met ISO 14520 standard). The equipment or system needs to be checked for leakage within one month after a leak has been detected to make sure the repair has been effective (it is recommended that Operators ensure leakage checks are undertaken by certified personnel). Equipment is to be inspected in-line with EU Regulations on leakage checking standards - details at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:335:0010:01:EN:HTML); and http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:333:0004:01:EN:HTML). Maintaining records and reporting These obligations will be enforced via the UK F-Gases Regulations 2009 which set out offences / penalties for non-compliance. For equipment containing 3kg or more of F-gases - Operators are to maintain records of the: (i) quantity and type of F-gases installed in equipment; Page 10 of 16 (ii) any F-gases that are added to, or recovered from, equipment on site during maintenance / servicing and final disposal; (iii) leakage checking / repairs - including the dates and results of the checks; (iv) checks on the proper functioning of any leakage detection systems that are fitted to equipment - including the dates and results of the checks; (v) the identity of the company / technician who performed the servicing / maintenance / leakage checking - including any checks on leakage detection systems; and (vi) information on equipment with 30kg+ and 300kg+ of F-gases. The template at Annex B can be used by Operators (if they wish) for record maintenance purposes. Labelling Recovery of F-gases Placing on the market These records are to be made available on request to DECC (i.e. for checking compliance and, if needs be, for responding to any requests for such information from the EU Commission). Where F-gases are added / recovered on site the resulting total quantity should be recorded on the equipment’s existing label - in-line with the EU Regulation on labelling - details at: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:332:0025:01:EN:HTML (the requirements of which will also be enforced by the UK F-Gases Regulations). Operators of relevant equipment are to put in place arrangements for the proper recovery of Fgases to ensure their recycling, reclamation or destruction (Operators to ensure recovery is undertaken by certified personnel). Placing on the market of certain F-gas containing equipment - as listed in Annex II to the EU Regulation - was prohibited from either 4 July 2007 or on the same date in 2008 or 2009 - note: the prohibition does not apply to appliances such as catering / domestic refrigeration or airconditioning units. In the unlikely event that any Operators obtained some of the types of equipment listed in Annex II on or after the specified dates, then they may be required to remove the equipment for safe disposal (in accordance with the UK F-Gases Regulations) unless it can be proven that it was manufactured before the applicable prohibition date. Page 11 of 16 ANNEX B EU F-GASES REGULATION (EC) No. 842 / 2006 RECORD MAINTENANCE TEMPLATE [A record for each calendar year must be maintained by Operators for equipment containing 3kg or more of F-gases (Operators may wish to keep records on equipment with <3kg of F-gases although this is not mandatory). If there have been any unintentional / accidental releases of Fgases equal to or more than 1,000 tonnes of CO2 equivalent these (plus the corresponding amount in kgs) must be reported to DECC’s Offshore Inspectorate - using the Annex C form within 48 hours of it being established that such an incident had occurred.] RECORD MAINTENANCE TEMPLATE FOR EU F-GASES REGULATION [Add / expand rows under headings as necessary] Year 1. Installation Name and Operator: 2. Equipment (make / model) i.e. refrigeration system, 3. Quantity (kg) of F-Gas in equipment - at start of air-conditioning unit, fire-protection system, heat pump or year i.e. Hydrofluorocarbons (HFCs), Perfluorocarbons high-voltage switchgear (PFCs) or Sulphur Hexafluoride (SF6) 4. Equipment manufacturer: 6. F-Gas Additions Date Name of Company / technician who performed maintenance / servicing 5. Year equipment supplied: HFCs (kg) PFCs (kg) Amount added (kg) Reasons for addition Annual total of F-Gases added 7. F-Gas Removals Date Name of Company / technician who performed maintenance / servicing Annual total of F-Gases removed 8. Leak Tests Date Name of Company / technician who performed leakage checking HFCs (kg) Amount removed (kg) SF6 (kg) Has the equipment label been updated? PFCs (kg) SF6 (kg) Reasons for removal - what was done with the recovered F-gases (i.e. sent to onshore facility for disposal)? Test result (including location / cause of any leaks identified) 8(a). Quantity of intentional / inherent Date HFCs (kg) F-Gas emissions detected during testing Annual total of intentional / inherent F-Gas emissions 8(b). Annual total of unintentional / accidental F-Gas HFCs (kg) emissions (including those reported to DECC on the Annex C form) 9. Annual total of intentional / inherent plus HFCs (kg) unintentional / accidental emissions of F-Gases 10. Date(s) when data in Section 9 was reported to EEMS 11. Testing of Automatic Leak Detection Systems (if fitted) Date Name of Personnel / Test results Company (contractor) Page 12 of 16 Follow-up actions required PFCs (kg) SF6 (kg) PFCs (kg) SF6 (kg) PFCs (kg) SF6 (kg) Comments ANNEX C EU F-GASES REGULATION (EC) No. 842 / 2006 REPORTING FORM FOR UNINTENTIONAL / ACCIDENTAL F-GAS EMISSIONS [This form must be used by Operators for reporting any unintentional / accidental emissions of F-gases (equal to or greater than 1,000 tonnes of CO2 equivalent) from individual items of equipment to DECC’s Offshore Inspectorate via: [email protected]) within 48 hours of it being established that such an incident had occurred - refer to Annex D for CO2 Calculation Method and Fluid Properties / Global Warming Potential (GWP) Factors to be used.] REPORTING FORM FOR EU F-GASES REGULATION [Add / expand rows under headings as necessary] Reporting year: Report number: Date submitted: 1. Installation Name and Operator: Company Postal Address (Head Office): Telephone number: E-mail: 2. Equipment (make / model) i.e. refrigeration system, air-conditioning unit, heat pump, fire-protection system or high-voltage switchgear (provide details on one category only) 3. Equipment manufacturer: 5. Date when it was established that incident had occurred: 6. Details / likely cause of incident: 4. Year equipment supplied: 7. Quantity in tonnes of Hydrofluorocarbons Perfluorocarbons CO2 equivalent (plus (HFCs) (PFCs) corresponding amount in kgs) of F-gases emitted t/CO2e kgs t/CO2e kgs during incident (estimated if necessary) 8. Steps taken to resolve / prevent re-occurrence of the incident: Sulphur Hexafluoride (SF6) t/CO2e kgs For DECC Purposes Only Environmental Inspector: Inspector’s Assessment: No Further Action Further Action Taken Further Information Requested Additional Details: Date Completed: Page 13 of 16 ANNEX D EU F-GASES REGULATION (EC) No. 842 / 2006 CALCULATION METHOD AND FLUID PROPERTIES / GLOBAL WARMING POTENTIAL (GWP) FACTORS TO BE USED FOR CONVERTING F-GAS EMISSIONS TO CO2 EQUIVALENT Calculation method: Quantity of F-gases emitted multiplied by the Global Warming Potential (GWP) = CO2 equivalent Example: If 2 tonnes (2,000 kg) of HFC 404A (which has a GWP of 3,260) was emitted then this would be the equivalent of 6,520 tonnes of CO2. FLUID PROPERTIES / GLOBAL WARMING POTENTIAL (GWP) FACTORS (See embedded table) Page 14 of 16 ANNEX E EU F-GASES REGULATION (EC) No. 842 / 2006 Specific regulatory aspects to be assessed by DECC’s offshore Inspectors (i) The maintenance of proper records which contain: - quantities / types of F-gases installed; - quantities added or recovered during maintenance, servicing and disposal; - dates / results of leakage checks (including checks on any leakage detection systems fitted see item (v) below); - identity of relevant personnel (servicing technicians); and - information specifically identifying equipment with inventories of 30kg + and 300kg + of Fgases. (ii) The separate reporting of any unintentional / accidental emissions of F-gases equal to or greater than 1,000 tonnes of CO2 equivalent (plus the inclusion of related data in the records to be maintained). (iii) The annual reporting of all F-gas emissions to EEMS. (iv) Leak testing regimes in place to meet `periodic leakage checking frequencies’ (i.e. annual for 3kg+ equipment inventory; 6 monthly for 30kg +; and 3 monthly for 300kg+) plus the repairing of any detected leaks ASAP and the checking of equipment within one month to ensure repairs have been effective. (v) The installation of leakage detection systems for equipment containing 300kg + of F-Gases. (vi) The availability and use of suitable F-gas recovery equipment. (vii) The updating of equipment labels with inventory of F-gases i.e. as a result of substances being added or recovered on-site. (viii) The appropriate labelling of exempted equipment (i.e. hermetically sealed with <6kg of F-gases). (ix) The carrying out of maintenance / servicing work by suitably qualified personnel. (x) The application for, or obtaining of, an interim or full Company Certificate by Operators using `inhouse personnel’ to carry out maintenance / servicing. (xi) General improvements planned in the future. 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