Fluorinated GHGs

Key Legislation and Guidance:

For more detail on the Legislation relevant to this page, please use the following links:

Supporting Legislation:
Guidance: BEIS Fluorinated Greenhouse Gases Guidance for the Offshore Hydrocarbon Industry on the Fluorinated Greenhouse Gases Regulation (EU) No. 517 / 2014. the Fluorinated Greenhouse Gases Regulations 2015 (SI 2015 / 310) and the Fluorinated Greenhouse Gases Regulations (Northern Ireland) 2015 (SI 2015 / 425) October 2016 (PDF document)The offshore industry guidance documents on the EU F-Gases Regulations have been updated. BEIS (then DECC) Guidance document for the offshore hydrocarbon industry on the F-Gases Regulation (EU) 517/2014 (July 2015) (PDF document)

Greenhouse gas reporting Conversion factors 2016 - DECC have released the emission conversion factors required when reporting on 2017 greenhouse gas emissions by UK based organisations of all sizes. User guidance is also accessible through the link provided.

 

Consent Needed:

No consent is required, although annual reporting where derogations or exemptions are being used is required to be submitted to BEIS.

BEIS will regard the licensed operator (i.e. the licence holder) as being responsible for ensuring that the provisions of the EU F-Gases are complied with. Where another company is responsible for management of operations, the licensed operator will still need to make sure that sufficient systems and procedures are in place to ensure adherence to the requirements, e.g. where a MODU is in the field on contract.

How to Apply: N/A
Who to Apply to: N/A
When to Apply: N/A

 

Control of the placing on the market and use of controlled substances:

F-Gas Containing Equipment

The placing on the market of certain F-Gas containing equipment is prohibited. This equipment is listed in Annex II to the EU Regulations. If any operators obtained such equipment on or after that date they may be required to remove it for safe disposal/destruction, unless it can be proven that it was manufactured before the applicable prohibition date.

Leakage prevention and Recovery:

Operators of refrigeration and air-conditioning systems, heat pumps (including their circuits) and fire-protection equipment are to:

  • Prevent leaks of F-gases listed in Annex 1 to the EU F-Gas Regulations (i.e. HFCs, PFCs and SF6)
  • Repair detectable leakages ASAP (also see the Reporting Requirements tab) and check within one month that repairs have been effective

Fire protection equipment installed before 4 July 2007 had to have a leakage detection system for F-Gases fitted by 4 July 2010 (obligations would be fulfilled where an existing inspection regime is in place to meet the ISO 14520 standard) (also see the Sampling/Monitoring Requirements tab).

Equipment containing >300kg of F-Gas should have a leakage detection system (LDS) installed (also see the Sampling/Monitoring Requirements tab).

Labelling:

Where F-Gases are added on site to relevant equipment, the quantity added/resulting total quantity should be recorded on the existing label, in line with Commission Regulation (EC) No 1494/2007 (PDF document).

Leakage Inspections: Operators are required to inspect relevant equipment for leakages according to the schedule provided in Annex A of the DECC Guidance on the EU F-Gases Regulations.

  • 3 kg+ F-Gas – once every 12 months (except for appliances labelled as hermetically sealed and where the content of F-Gas is <6kg).
  • 30 kg+ F-Gas – once every 6 months. Where leakage detection systems are installed inspections can be every 12 months.
  • 300 kg+ F-Gas – once every 3 months. Equipment containing these levels of F-Gas should have a leakage detection system installed (to be checked every 12 months) – inspections would then be every 6 months.
  • Fire protection equipment installed before 4 July 2007 had to have a leak detection system fitted by 4 July 2010. This obligation would be met if an inspection regime met ISO 14520 standards.

The equipment or system also 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).

Relevant equipment is to be inspected in line with the following recent EU Regulations on leakage checking standards:

 

What to Report: The following data should be reported:

  • Data on total F-gas emissions to air from intentional/inherent and unintentional/accidental releases should be acquired by operators.
  • Significant unintentional/accidental releases of F-gas emissions equal to or greater than 1,000 tonnes of CO2 equivalent must be reported (along with the corresponding amount in kg) to DECC using the form at Annex C of the DECC F-Gas Guidance (Word document). A record of these types of emissions should also be maintained as indicated in Section 10 of the Annex B form in the DECC F-Gas Guidance (Word document). Where such emission are <1,000 t/CO/e then a record of these should be kept by Operators in accordance with Section 10(a) of the Annex B form.
  • Any potential, or actual instances of, regulatory non-compliance.

For relevant equipment containing 3 kg+ F-Gases, operators are also to maintain records of the:

  • Quantity/type of F-gases installed and any quantities added.
  • Any F-gases that are added to, or recovered from equipment on site during maintenance servicing and final disposal.
  • 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.
  • Identification of the technician (or Company) who performed the servicing/maintenance/leakage checking – including any checks on leakage detection systems.
  • Information identifying separate equipment with 30 kg+ and 300 kg+ of F-Gases.

The template provided in Annex B to the DECC F-Gas Guidance (Word document) can be used for recording the above data.

These records are to be made available on request to DECC (for checking compliance and if needs be for responding to requests for such information from the EU Commission).

DECC put out an Environmental Alert in November 2013 alerting operators that many have not been reporting all F-Gas emissions to the atmosphere through the Environmental Emissions Monitoring System (EEMS). It is DECC’s understanding that this is attributed to a mistaken belief that if an F-Gas is not listed on the relevant EEMS reporting form then this eliminates the requirement to report the emission.

DECC reiterates the point that when operators become aware of the requirement to report an F-Gas to EEMS that is not included within the existing reporting form, they are requested to inform DECC by e-mail, who will then arrange for this product to be added to the return. This will ensure the details of the F-Gas are recorded on the system for future reporting.

Who to Report to:

Use and Service/Maintenance/Leakage Tests – Records to be maintained and made available to DECC on request.

Emissions to atmosphere – report via EEMS Portal (see EEMS website).

Non compliances should be reported to DECC’s Offshore Inspectorate at the following email address: offshore.inspectorate@decc.gsi.gov.uk

When to Report:

An EEMS report is to be submitted by 7 February each year.

Unintentional/accidental releases of F-Gas >1,000 tonnes CO2 equivalent – report within 48 hours of the incident occurring.

Other 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).

Non conformance: Obligations enforced by the F-Gas Regulations 2009 which set out offences/penalties for non-conformance, powers include:

  • Enforcement Notices
  • Prohibition Notices (where serious risk of pollution)
  • Court proceedings and financial penalties
  • Fixed fee penalties for certain activities
Renewal of Permit: N/A
EU Commission review of F-Gas Regulations: The EU Commission undertook an extensive consultation in late 2011, and responses have now been received on this. According to responses, there was widespread support for tougher EU action on F-gases, but the complexity of the issue means that a mix of policies may be needed. The Commission hopes to publish formal legislative proposals in Autumn 2012. Information on the stakeholder event and results of the consultation are available on the EU Climate Page.Any future EU proposals are likely to complement and be influenced by further UN negotiations on the international phase-down of HFCs.
Environmental Alert 03/2014 – EU F-Gases Regulations: DECC (now BEIS) issued an Environmental Alert (PDF document) report after identifying a number of “non-compliances” under The Fluorinated Greenhouse Gases Regulations 2009, alerting operators to the newly-published DECC guidance.