Decommissioning: recovery, records and disposal obligations

The obligation

When equipment containing fluorinated greenhouse gases reaches end of life, the refrigerant must be recovered for recycling, reclamation or destruction. It may not be released to atmosphere, and deliberate release is an offence.

The recovery must be carried out by a person holding the appropriate certification, working for a certified company. Records must be kept of the quantity recovered and what happened to it.

As with every other F-Gas duty, the responsibility sits with the operator. Appointing a contractor to remove the plant does not transfer it.

Where it goes wrong

1. Strip-out and demolition contractors removing plant as scrap, with no refrigeration competence and no awareness of the obligation.
2. Refurbishment projects where mechanical services removal is bundled into a general contractor’s scope with no specific requirement for certified recovery.
3. A tenant vacating, removing plant they installed, with no consideration of the obligation.
4. Plant removed by a general builder during an extension or alteration.
5. Scrap value driving the process, where the outdoor unit’s metal is worth something and the refrigerant is an obstacle.
6. Nobody being asked, because the operator did not know the obligation existed.

The pattern is consistent: the people physically removing the equipment are not the people who know about F-Gas, and nobody joined the two up.

How to do it properly

1. Identify the obligation earlyAs soon as plant removal is contemplated, whether as part of a replacement, a refurbishment or a demolition.
2. Appoint a certified contractor for the recoverySpecifically, and separately from any general strip-out contractor if necessary.
3. Recover before anything is cutThe refrigerant comes out first. Nothing is disconnected, cut or removed until it has.
4. Record the quantity recoveredAgainst the system’s recorded charge. A significant discrepancy tells you the system had been leaking.
5. Record the destinationRecycled, reclaimed or destroyed, and by whom.
6. Recover the oil tooRefrigeration oil is also a controlled waste and must be handled appropriately.
7. Update the logbookWith the decommissioning record, and remove the system from the compliance schedule.
8. Dispose of the equipment properlyWaste electrical and electronic equipment obligations also apply to much of this plant.

Writing it into contracts

The practical protection for an operator is to make it explicit in the specification rather than assuming it.

• State in the contract that refrigerant recovery must be carried out by a certified person, with evidence of certification provided.
• Require the recovery record as a deliverable, with quantity and destination.
• Separate the scope where necessary – certified recovery first, general strip-out afterwards.
• Make it a hold point. No mechanical removal until recovery is evidenced.
• Include it in tender documents so it is priced rather than discovered.
• For tenant alterations, make it a condition of any licence to alter.
• At lease end, address it in dilapidations where plant is being removed.

None of this is onerous and all of it is far easier before the work than after somebody has already cut the pipes.

The recovered quantity tells you something

An underrated benefit of proper decommissioning is the information it produces.

Comparing the quantity recovered against the system’s recorded charge tells you how much refrigerant had already been lost over the plant’s life. A system that gives up substantially less than its charge has been leaking, possibly for years, possibly undetected.

That is useful in three ways:

1. It validates or challenges your leak checking regime. A system that was being checked and still lost most of its charge suggests the checks were not effective.
2. It informs replacement decisions for similar plant elsewhere on the site.
3. It is a genuine environmental figure, for organisations reporting on emissions.

Record it, and look at it.

Replacement projects specifically

When plant is being replaced rather than simply removed, the decommissioning is usually in the same contractor’s hands as the installation, which makes it straightforward. Things still worth ensuring:

• Recovery is recorded, even though the same contractor is fitting the replacement.
• The old system’s logbook is closed out with the decommissioning entry, rather than simply abandoned.
• The new system’s register entry is created, with its refrigerant type, charge and CO2e.
• The compliance schedule is updated – the new system may have a different check frequency, or none.
• Pipework is assessed. Reusing existing pipework for a new refrigerant is possible in some circumstances and requires the pipework to be suitable and properly cleaned. Residual oil from the old refrigerant is incompatible with some new ones, and getting this wrong damages the new compressor.

That last point is worth emphasising. Reusing pipework is attractive because it avoids disruption, and it is not automatically acceptable. It depends on the refrigerant pairing, the oil types, the pipe sizing for the new system, and whether the pipework can be properly cleaned.