More users given R22 ban exemptions
3rd January 2015
EUROPE: The European Commission has exempted two more petrochemical facilities from the European HCFC refrigerant ban which came into force on January 1.
BP’s Kinneil refrigerated LPG facility in Grangemouth, Scotland, and Denmark’s DONG Energy Nybro gas treatment plant have been allocated an exemption to use up to 18,300kg of reclaimed R22 over the next two years. An exemption has also been granted to the Dutch Navy for the use of R22 in two of its submarines.
In September last year, the Cooling Post reported that the ConocoPhillips gas processing plant at Theddlethorpe, Lincolnshire, had been been granted an exemption to continue using up to 35,100kg of reclaimed R22 refrigerant until July 2016.
BP Kinneil has been given an exemption from the HCFC ban (1005/2009) to use 9,000kg of reclaimed R22 from 1 January 2015 to 1 March 2017.
The purpose-built refrigeration plant was constructed in 1978 and fulfils the natural gas management needs of the Forties pipeline system. It currently supports the transport of around 50% of the UK oil production and approximately 25% of the UK gas production is also dependent on the facility being in operation.
BP is said to have begun the process to assess and identify alternatives to R22 in 2009. Three alternatives were identified as potentially feasible. One of these, using ammonia/carbon dioxide, was selected in 2010 but in 2011 it was concluded that its use was not technically feasible. It then investigated the use R507 and a planned replacement was on track to be finalised before the end of 2014. However, R507, with its high GWP of 3985, then fell under European F-gas revision proposals, first mooted in 2012, to ban the servicing of refrigeration equipment with R507 after 2020.
R410A, previously considered but not pursued since the required technology was at the time unproven, was then seen as the only economically and technically feasible alternative for a new refrigeration plant. This new plant will not be completed until July 2017.
Each use of R22 by BP is subject to specific authorisation by the UK government’s Department for Environment, Food & Rural Affairs (DEFRA). The exemption states that no quantity of R22 can be authorised unless it has been proven that any leak found has been repaired, as required by Regulation 1005/2009, before topping up.
Chiller exemption
Denmark’s government-owned DONG Energy, the country’s largest energy company, has received an exemption to use up to 9,300kg of reclaimed R22 until 31 December 2017 at its Nybro gas treatment plant. The plant receives approximately 95% of the Danish supply of natural gas.
R22 is used as a refrigerant at the terminal to refine natural gas to the required specification for distribution into the transmission system in periods where the received gas does not meet the required standards. The refrigeration system uses twin chiller units – one in operation and the other as stand-by emergency replacement. The replacement unit is currently empty.
While it would have been possible to legally fill the standby chiller with reclaimed R22 last year, DONG Energy maintained that it considered it would be more environmentally friendly to retain only one chiller unit in operation, and to rely on emergency filling of that unit only if a major leak occurs due to an accident.
DONG Energy insists that the only substances that could be used in the existing system are HFCs which are banned under Danish law. A new refrigerant system has been ruled out at this time as the future amount of gas passing through the plant is said to be in doubt, according to the operators.
R22 on Dutch submarines
The Netherlands Ministry of Defense was successful in seeking an exemption of the use of 324kg of reclaimed R22 until the end of 2018 in its submarines HNLMS Bruinvis and HNLMS Walrus.
Research to identify alternatives to R22 started in 2003 but, due to the complexity of the refrigeration system in navy submarines, the Dutch Ministry of Defence insists there is no suitable “drop in” refrigeration system or any other alternative installation.
They also maintain that the particular nature of navy submarines imposes further restrictions when identifying alternative solutions, for example space and weight limitations, as well as military-specific concerns related to noise, vibration, shock impact and electromagnetic compatibility.
The competent national authority stated in the request that the Ministry of Defence has identified a new tailored-made alternative solution, specifically planned for this type of submarines. This involves the design of a system based on R134a, R404A and R407C. However, the implementation of the new system will require significant adjustments to the submarines. These can only be performed during the planned maintenance taking place between 2017-2019 for HNLMS Bruinvis and 2019-2021 for HNLMS Walrus.
The Ministry points out that in cases of R22 leaks from the submarine refrigeration systems, the emitted substance will be used to feed the combustion process of the diesel engine which will eliminate largely its ozone depleting potential.
Related news:
Gas plant given R22 ban exemption – September 5, 2014
UK: A major UK gas processing plant has been granted an exemption to continue using up to 35,100kg of reclaimed R22 refrigerant until July 2016. Read more…
