David Dodd, EPA

Ozone Depleting Substances Regulations and
F-Gas RegulationsSI 543 of 2002
Sustainable Energy Ireland
Large Industry Energy Forum
Pfizer
Cork
30th January 2006
David Dodd
Scientific Officer
Environmental Planning and Guidance
Office of Licensing & Guidance
EPA
Presentation
ƒ EPA Context and National Waste Prevention
programme
ƒODS Regulation and F-Gas Regulation Overview
ƒODS Regulation – Scope and purpose
ƒEPA Role as Competent Authority
ƒCurrent and Future work items
EPA Context
Office of Licensing & Guidance, Prevention Unit:
ƒStrategic Environmental Assessment (SEA)
ƒNational Waste Database
ƒNational Hazardous Waste Management Plan
ƒNational Waste Prevention Programme
ƒWEEE Regulations
ƒODS Regulations……..
National Waste Prevention Programme
National Waste
Prevention
Programme
Committee
Why Prevention?
ƒ European Waste Management Hierarchy
ƒ 3 Rs – Reduce , Reuse, Recycle
ƒ Focus on Waste Prevention to try to decouple our buoyant
economy from rising waste generation
www.epa.ie/OurEnvironment/Waste/NationalWastePreventionProgram
me/
What is and isn’t prevention ?
Emissions
factory
Raw materials
Fuel
Electricity
Water
Product
process
Use
End-of-life
Waste
I
What is and isn’t prevention ?
evention?
factory
Raw materials
Fuel
Electricity
reduced
Water material and
Emi
ssio Emissions
ns a
bate
m en
t
not prevention
cleaner
process
production
Product
Internal recycling
Use
resource
use
Prevention is this
side of the line
g
n
i
cl
y
c
Re
End-of-life
Waste
not prevention
Legislation
ƒ
European Legislation
ODS - Regulation (EC) No 2037/2000 of the European Parliament and of
the Council of 29 June 2000 on substances that deplete the ozone layer
F-Gas – Common Poistion (EC) No 25/2005 adpoted by the Council on 21
June 2005 with a view to adopting Regulation (EC) No…../2005 of the
European Parliament and of the Council of…on certain Fluorinated
greenhouse gases
http://europa.eu.int/eur-lex/lex/en/index.htm
Legislation
Irish Legislation
ƒ
Statutory Instrument (S.I.) for ODS Regulation is currently being
prepared by the Department of the Environment Hertitage and Local
Government (DOEHLG) – Q1/Q2 of 2006 ??
ƒ
F-Gas still at Common Position (CP) stage. Statutory Instrument for
F-Gas Regulation – Q 4 2006 ??
Commonly used names
ƒ
ODS Regulation / F-Gas Regulation
Background
Montreal Protocol
ƒ Over 170 countries have ratified protocol for the
protection of the stratospheric Ozone Layer
ƒ Protocol was previously enforced by
EC Regulation 3093/94
ƒ Changes to Protocol made it necessary to introduce tighter
restrictions resulting in EC Regulation 2037/2000
Competent Authority
ƒ ODS Regulation
EPA designated as Competent Authority June 2005 by
DOEHLG. Proposed S.I. may state other responsible bodies
e.g. Customs, Department of Agriculture ?
ƒ F-Gas Regulation
No Competent Authority as Regulation is not finalised at Council
level.
Due to the overlap of ODS/F-Gas, it is likely that the EPA will be
made Competent Authority for this Regulation also.
Scope of ODS Regulation
ƒ ODS – This Regulation shall apply to the production,
importation, exportation, placing on the market, use,
recovery, recycling and reclamation and destruction of the
following ;
chlorofluorocarbons, other fully halogenated
chlorofluorocarbons, halons, carbon tetrachloride, 1,1,1trichloroethane, methyl bromide, hydrobromofluorocarbons,
hydrochlorofluorocarbons and bromochloromethane, to the
reporting of information on these substances and to the
importation, exportation, placing on the market and use of
products containing those substances – Article 1
Scope of F – Gas Regulation
ƒ F-Gas – This Regulation addresses the containment, use
recovery and destruction of the fluorinated greenhouse gases
listed in Annex I; the labelling and disposal of products and
equipment containing those gases; the reporting of
information on those gases; the uses referred to in Article 8
and the placing on the market of the products and equipment
referred to in Article 9; and the training and certification of
personnel involved in activities provided for by this Regulation –
Article 1
ƒ Examples of Annex I substances – Sulphur Hexafluoride (SF6),
HFC-23, HFC-32, HFC 41, HFC 134a…….
ODS Regulations –
Controlled Substances
Controlled substance *
(Examples of Trade Names)
Industry Area
CFCs
and HCFCs
(E.g. Arcton, Care, Freon, Forane, Genetron, Greencool,
Isceon, Klea,)
Air conditioning and refrigeration
Halons
Fire suppression systems and fire fighting
Carbon tetrachloride
Solvent users such as laboratories, chemical and
pharmaceutical industry
(Tetrachloromethane)
1,1,1-trichloroethane
(e.g.chloroethene NU® and Aerothene TT®.)
Methyl bromide
Solvent users such as laboratories, chemical and
pharmaceutical industry
(E.g. Brom-o-gas, Dowfume, Mebrom etc.)
Soil treatment, pest control, quarantine, fumigation,
market gardening
Hydrobromofluorocarbons
Fire suppression systems and fire fighting
Bromochloromethane
Manufacture of biocides.
Refrigerants
Commonly Used CFCs and
HCFCs
Legend
ODP – Ozone Depleting Potential
ASHRAE – American Society for Heating, Refrigeration and Air-Conditioning Engineers
(Table taken from EPA Guidance Note on CFCs and HCFCs)
Commonly Used CFCs and
HCFCs
(Taken from EPA Guidance Note on CFCs and HCFCs)
CFC and HCFC Phase Out Dates
(Taken from EPA Guidance Note on CFCs and HCFCs)
Main Requirements
Supply and Use
ƒODS cannot be supplied in disposable containers
ƒUse of existing CFC containing equipment is allowed, however topping up
of such systems (including with non-ODS refrigerants) is not allowed
ƒIn general HCFCs in new equipment are banned since 01/01/2001.
Topping up of existing equipment with virgin and recycled HCFCs is
allowed until 31/12/2009 and topping up with recycled HCFCs only is
allowed until 31/12/2014.
Import and Export
ƒImport, export and recycling of CFCs is banned since 01/10/2000 and
topping up with CFCs is banned since 01/01/2001
Main Requirements (contd)
Import and Export (contd)
ƒ Import and export in the context of Regulation 2037/2000 refers only to
trade with non-EU countries and does not refer to movement of ODS within
the European Community.
ƒImport of CFC-containing equipment and CFC gases is banned, unless the
equipment was manufactured before 30/09/2000. Export of CFC equipment
is banned.
ƒIn general, import of HCFC equipment is banned, unless the equipment
was manufactured before 01/01/2001. Limited quantities of HCFC gases
can be imported with authorisation from the Commission
ƒExports of products and equipment containing HCFCs is prohibited to any
state not party to the Montreal Protocol. Exports to states party to the
protocol where the use of HCFCs is allowed until 31/12/2009
Main Requirements (contd)
ƒ
Maintenance and Leak Detection
- Fixed equipment with a refrigerating fluid charge of more than 3kg of
shall be checked for leakages annually - Art 17 (1)
ƒ
Training Requirements
Personnel servicing and maintaining equipment containing ODS must
be appropriately trained and qualified
ƒ
Waste Management
CFCs must be destroyed and HCFCs must be either recycled or
destroyed. Transport and disposal of ODS must be carried out in line
with Irish and European waste and transport legislation
Main Requirements (contd)
Reporting Requirements
Examples of reporting requirements
ƒ
Essential users to report to commission (and copy to CA) regarding
nature of use, quantities used etc. - Article 19 (1)
ƒ
CA to report to commission on qualification requirements related to
recovery of ODS regarding exemptions for use, production
authorisations - Article 16(5)
ƒ
Producer, Importer, exporter to report to Commission (and copy to
Competent Authority - Article 19(1)….
Alternatives to HCFCs and CFCs
ƒ HCFC blends – introduced as alternatives to CFC 12
and CFC 502 predominantly
ƒ HFCs and HFC blends – can be used as alternatives for
both CFCs and HCFCs (*N.B* F-Gas Regulation will
restrict future use of HFCs)
ƒ Ammonia and Hydrocarbons – Ammonia can only be
used in equipment specifically designed for ammonia. In
general, HCs are viable alterntaives in small and larger
systems remote from public access. Health and Safety
issues with both materials.
Role of the EPA
ƒ Information gathering from Industry regarding level of use
ƒ Enforcement of Regulation in industry sectors (possible local
authority role)
ƒ Enforcement of regulation in IPPC licensed activities (OEE)
ƒ Develop Guidance for sectors covered by the Regulation
ƒ Liaise with other relevant public bodies – e.g. DOEHLG,
Customs, Department of Agriculture,Customs
ƒ Alert Industry to their obligations – national newspaper
adverts Nov 05, meetings with Industry Bodies, Industry
Journals, BS News Dec 05, EPA Website, Proposed workshops
ƒ Review and report implementation to EC
Role of local authorities
ƒPossible use of Accredited Inspection Contractor Scheme
(AIC) similar to Solvents Directive for compliance and annual
leakage testing ??
ƒRegistration of Companies covered under the Regulations ??
ƒEnforce regulations for all non-IPPC licensed activities ??
ƒCompile local returns for National Questionnaire and
submit to EPA ??
Where are we now?
ƒ
Statutory Instrument for 2037/2000 in preparation by DOEHLG
ƒ
Draft Guidance notes completed (See EPA website)
- CFCs and HCFCs - Air Conditioning and Refrigeration
- Halon Phase-Out - Fire fighting Systems
- Methyl Bromide - Pest Control
- Ozone Depleting Solvents - Chemical/Pharmaceutical Sector
ƒ
Preparation of Outstanding Reports for Regulation 2037/2000
ƒ
EPA ODS webpage in place
http://www.epa.ie/TechnicalGuidanceandAdvice/ODS/
EPA Webpage
What next?
ƒIncrease Industry Awareness – workshops, journals, meetings
with representative bodies, seminars
ƒPreparation of Regulations by DOEHLG – nomination of other
responsible authorities
ƒDevelopment of training and competency requirements with
relevant industry and training bodies
ƒEnforcement of Regulations – e.g. use of banned substances,
illegal supply of banned substances, site visits.
Conclusion
ƒThank you for your attention
ƒFor any queries please contact:
Caitríona Collins or David Dodd
Environmental Planning and Guidance
Office of Licensing & Guidance
EPA
ƒE-mail: [email protected]
ƒPhone no.:053 9160600
ƒwww.epa.ie/technicalguidanceandadvice/
ODS/