Fluorinated GHGs 

For information on the impact of Brexit on oil and gas environmental legislation, please refer to the pdf document downloadable from the Home Page.

Key Legislation and Guidance:

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

Supporting Legislation:
Guidance:

 

Consent Needed:

No consent is required, although annual reporting where derogations or exemptions are being used is required to be submitted to the Department for Energy Security and Net Zero.

The Department for Energy Security and Net Zero 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.
  • The operator of equipment shall notify the Department for Energy Security and Net Zero on an annual basis (via the Environmental Emissions Monitoring System – EEMS) of the quantities and types of F gas released from, or contained in, their equipment on an installation-by-installation basis.
  • Additionally, significant unintentional/accidental releases of F-gas emissions equal to or greater than 250 tonnes of CO2 equivalent must be reported (along with the corresponding amount in kg) to the Department for Energy Security and Net Zero  using the form on page 18 of the Department for Energy Security and Net Zero F-Gas Guidance(also available as a Word document on the Department for Energy Security and Net Zero website).
  • 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 the Department for Energy Security and Net Zero F-Gas Guidance can be used for recording the above data.

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

The Department for Energy Security and Net Zero (formerly 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 the Department for Energy Security and Net Zero’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.

The Department for Energy Security and Net Zero 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 the Department for Energy Security and Net Zero 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 the Department for Energy Security and Net Zero on request.

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

Non compliances should be reported to the Department for Energy Security and Net Zero Offshore Inspectorate at the following email address: offshore.inspectorate@beis.gov.uk

When to Report:

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

Unintentional/accidental releases of F-Gas 250 tonnes CO2 equivalent – report within 48 hours of the incident occurring.

Other records are to be made available on request to the Department for Energy Security and Net Zero (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

Any potential or actual non-compliance with The Fluorinated Greenhouse Gases Regulations 2015 or other F-gas regulations, as appropriate, must be reported to OPRED through the submission of an F-Gas NCN via the Integrated Reporting Service (IRS) on the UK Energy Portal. If the IRS system is unavailable, the EU F-Gas reporting form should be sent to OPRED.

Renewal of Permit: N/A
Ban on certain F-Gases: OPRED have released a statement that the EU and the UK are reducing the availability of hydrofluorocarbons by 79% between 2015 and 2030 . A ban has been placed on certain F-gases with a global potential of 150 or more in certain circumstances.
Environmental Alert 03/2014 – EU F-Gases Regulations: DECC (now Department for Energy Security and Net Zero) 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.