BSRIA's director of engineering, Mike Smith, is concerned that many building owners and operators may be unaware of the changes in refrigerant legislation that could have a major impact on their businesses
24 February 2015
From 1 January 2015, the latest element of legislation in the phasing out of R22 for air conditioning and refrigeration systems came into effect.
The legislation provides a total ban on handling R22 refrigerant regardless of whether it is (stockpiled) new material, recycled or even reclaimed.
If you have a breakdown that requires the refrigerant circuit to be broken into, you are permitted to recover the refrigerant from the system (assuming it hasn't leaked out) but you cannot put any form of R22 refrigerant back into the system. The fault may be something as simple as a pressure sensor needing replacement.
The legislation does not stop you running an R22 refrigerant-based AC unit, but when it breaks down you may no longer repair it using R22. You can use a drop-in replacement, but many of these contain HFCs which are also due to be phased out soon. And it is not quite as simple as just "dropping" it in. All such replacements are mixtures of several different refrigerants that, when blended together, emulate the behaviour of R22 as near as possible. In reality, they are blends; each substance has its own pressure/enthalpy/temperature relationships, which may result in significant "glide" in the heat exchangers. This is where the temperature during the change of phase is not constant in both the evaporator and condensers as it is with a single substance refrigerant like R22. It can vary by several degrees Kelvin across a heat exchanger - this can have implications for effective cooling, capacity and efficiency.
And drop-ins may have other issues to consider that might include safety (both toxicity or flammability) , compatibility with oils and seals, whether any of the constituents will be the subject of further phase-outs, what happens under all leakage scenarios, availability and cost as well as service staff who are trained and knowledgeable on all these issues.
The government website (www.gov.uk/hcfcs-in-refrigeration-and-air-conditioning-equipment) simply states: "You can still use your old equipment, but your technician can't do any work that involves breaking into the refrigerant circuits."
The outcome of this legislation is that if an air conditioning system is currently operating using R22, it is on borrowed time. To ensure that any disruption to the working environment has minimal impact, it is important that a strategy is developed to deal with a failure.
BSRIA believes that the impact of this change on a business is potentially so great that a strategy that fits each application needs to be developed. But what are the options?
1. Replace plant
This leads to a number of advantages, including installing a much improved energy-efficient option and being able to review the necessary capacity to suit the actual load and how well a new piece of plant can cope with variable loads. Allowance can also be made for any changes in building use, ensuring that the plant delivers the required cooling load. New plant will have a longer life than modified equipment. There are disadvantages, the largest of which is the cost involved in replacing systems. The other associated considerations are the installation disruption and longer implementation time for the replacement project.
2. Modify plant to use a new refrigerant
The advantages here may be a quicker implementation compared with replacement, and costs would also be lower.
The disadvantages of choosing this option is that the plant life would not be extended, so the major capital expense of replacement will still need to be incurred at some point, the cooling capacity of the system could fall, and the energy efficiency of the system may get worse (and may not be comparable with modern equipment in the first place).
For those who have yet to decide on their strategy, now is the time to develop an action plan. BSRIA recommends that you follow these three steps:
Identify all equipment using R22 - including air conditioning and refrigeration equipment.
Develop a database of information about each piece of plant, including facts such as:
Quantity of refrigerant in the system;
System age and likely life span;
Current cooling load and any expected future cooling load;
Plant design details (including component details);
Plant efficiency performance;
What business function each AC plant serves and how critical it is to business continuity.
Evaluate your business continuity priorities and decide on the most appropriate option - replace or modify? Carrying out steps one and two will help you to make the best decision.
And just to complicate matters, the F-gas regulations put in place in 2006 have been revised. This brings more duties for system operators and also sets out how HFCs such as R410a and R134 will be phased out - so any replacement strategy must also take this into account.
Useful advice on this is available here.
Mike Smith, director of engineering, BSRIA