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Managing the F Gas Regulations in your data centre

On 15th October 2016, the 28th Meeting of Parties to the Montreal Protocol on substances that deplete the Ozone layer adopted the Kigali Amendment to add HFCs to the list of controlled substances.

The EU ratified the Kigali Amendment on 27 September 2018. EU Member States are in the process of ratifying the Kigali Amendment individually.

The first reduction step to be taken by the EU and other developed countries is required in 2019, while most developing countries will start their phasedown in 2024.

For data centres this affects air conditioning plant and gas-based fire suppression systems.

The Regulations are commonly referred to as the ‘F-Gas Regulations’ or more completely, Regulations (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006.

 If the UK leaves the EU without a deal then the EU F gas and ODS (Ozone Depleting Substances) regulations will no longer apply in the UK. However new UK ODS and F gas regulations* transfer most of the requirements of the EU regulations into UK law.

The UK will continue to:

  • Restrict Ozone Depleting Substances
  • Use the same schedule as the EU to phase down HFCs (hydrofluorocarbons, the most common type of F gas) by 79% by 2030 relative to a 2009 to 2012 baseline

That means UK F gas quotas will follow the same phase down steps as the EU.

Most of the rules for F gas and ODS will not change. However, the UK will have separate quota systems, and the IT systems UK businesses use to manage quotas and report on use will change.

Managing the F Gas Directive

  • Check if your system contains Fluorinated (F) gas
  • Look at the list of F gases regulated by the EU. This is available from the EU website or Capitoline’s Data Centre Fire management course and associated ebook
  • To find out if your equipment contains one of these F gases you can:
    • check your manual or the labels on your equipment
    • speak to the company that installed your equipment
  • Note that HFC 23 and HFC 227ea are common in fire protection systems
  • Note that HFC 404A and HFC 410A are common in air conditioning and heat pump systems

Only trained technicians can carry out work on equipment containing F gases, including:

  • Installation
  • Testing for leaks
  • General maintenance
  • Disposal or decommissioning when you no longer need the product

Check that anyone working on your equipment is qualified.

You must add a label if you add F gas to refrigeration, fire protection or air conditioning equipment when you’re installing it. The label must state;

  • That the equipment contains an F gas
  • The industry name for the F gas, or the chemical name if there isn’t an accepted industry name

From 2017 the label must also state the;

  • Mass of F gas in the equipment (in kg)
  • Carbon dioxide (CO2) equivalent mass of F gas in the equipment (in tonnes)
  • The global warming potential of the F gas

Note that as the data centre operator or manager you are responsible for stopping leaks from your equipment and contractors that install, maintain or dispose of equipment share responsibility for trying to stop leaks with the operators of equipment.

The data centre operator or manager must check all equipment for leaks and even if that means devolving the activity to a third party company you are still responsible.

For equipment that contains F gas above certain thresholds, you must check for leaks at specific intervals.

The operator of equipment, and the company that services it, must keep the following records about any equipment that has to be checked for leaks (i.e. any equipment that contains F gas equivalent to more than 5 tonnes of CO2);

  • Quantity and type of gas in the equipment when it’s installed
  • Quantity and type of gas added during any maintenance (e.g. leak repairs)
  • Details (name, address and certificate number if relevant) of any companies that install, service or decommission the equipment
  • Dates and results of all mandatory leak checks
  • Measures taken to recover and dispose of gases when you dispose of the equipment (e.g. disposing of it through a registered waste carrier)

You must keep records for 5 years and make them available to government officials if they ask for them.

The thresholds at which leak check intervals are specified are expressed in terms of CO2 equivalent and are summarised in the table below.

They take into account both the quantity of F gas in the equipment and the ‘global warming potential’ of the F gas (how much the F gas contributes to global warming).

If a leak is found during a check, you must repair it and repeat the test within a month to check the repair worked.

You must fit a leak detection system if your equipment contains F gas equivalent to more than 500 tonnes of CO2 i.e. 155 kg of HFC 227ea (FM200).

500 tonnes of CO2 equivalent may sound a lot but remember this is less than the equivalent of two standard 98 kg cylinders of FM 200 so the regulations with apply to the majority of data centres using fluorinated gasses in their fire suppression system.

Maximum interval between leak checks CO2 (tonnes)

HFC 23 

(kg)

HFC 227ea (kg) HFC 404A (kg) HFC 410a (kg) HFC 134a (kg)
1 year 5 0.3 1.6 1.3 2.4 3.5
6 months 50 3.4 15.5 13 24 35
3 months 500 34 155 127 240 350

Fire management in the data centre is discussed in much greater detail in Capitoline’s online courses Data Centre Operational Management (DCOM) and Data Centre Fire Specialist (DCFS) and associated How to Manage Fire Safety in your Data Centre eBook.

* The Ozone-Depleting Substances and Fluorinated Greenhouse Gases (Amendment etc.) (EU Exit) Regulations 2019

 

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