What does the law say?
With a view to reducing emissions of fluorinated greenhouse gases and in order to meet the mandatory targets set by the EU’s Kyoto Protocol on the climate crisis, Regulation (EC) No 842/2006, in relation to some of these gases, including sulphur hexafluoride (SF6), was adopted by the European Parliament and its Council.
The SF6 gas certification and issuance of its certificate is based on: “COMMISSION IMPLEMENTING REGULATION (EU) 2015/2066 of 17 November 2015 establishing, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council, the minimum requirements and conditions applicable to the mutual recognition of the certification of natural persons involved in installation, maintenance, the repair or decommissioning of electrical switching equipment containing fluorinated greenhouse gases or the recovery of fluorinated greenhouse gases from stationary electrical switching equipment”.
This text, in force since 4 July 2007, regulates the obligations specific to all stages of the life cycle of fluorinated greenhouse gases, from their production.
This regulation is therefore addressed to all parties involved in these life cycles: producers of these gases, importers and exporters, manufacturers and importers of products and/or equipment containing them, as well as all those who use them.
Responsibility for compliance with the law in force rests with the operator of high-voltage switchgear.
The legislation, through Regulation no. 842/2006 repealed by Regulation (EU) n° 517/2014 of 16/04/14 on fluorinated greenhouse gases defines it as: “a legal or natural person exercising real power over the technical operation of equipment and systems”.
This definition includes the fact that this operator of the equipment is not necessarily the owner.
In most cases, the operator of high-voltage connection devices is a legal entity. It must properly instruct its personnel for the proper technical operation of this equipment for its proper use on a daily basis.
This regulation aims, among other things, to prevent any release of SF6 into the air by strictly framing operators of high-voltage switchgear, mainly with regard to:
A. Obligation to recover SF6
The operator must arrange for the implementation of SF6 recovery in cases of maintenance intervention, dismantling of equipment, with certified employees, whether for recycling, regeneration or destruction in incinerator.
There are two main groups of high-voltage equipment:
Sealed pressure vessels, commonly referred to as “life time seals”. SF6 is kept inside without the need to intervene at any time during the life of the device.
This situation implies no need for maintenance for the operator.
He will then have to manage, with certified employees, only the removal of the device.
The other case concerns pressure vessels with a control and alarm system if the SF6 pressure varies. This allows to act on the gas charge to maintain the device during its use time.
These SF6 maintenance and recovery cases will then have to be managed by the operator through its qualified employees.
Certification requirement for employees responsible for intervention
Employees who have obtained the official certificate are the only ones authorized to implement the procedures for recovery of SF6, as well as those for intervention on the SF6 load of the devices, at all stages of their use, as well as prior to their maintenance and removal.
The EC Regulation n°305/2008 of the European Commission stipulates at least how training should be organized and what are the conditions for obtaining certificates. The aim is to standardize the certification of those responsible for managing the recovery of certain fluorinated greenhouse gases from high-voltage switchgear.
This training is organized around three axes: to know the characteristics of SF6 and its environmental impact, to know the high-voltage electrical connection techniques that contain this gas and finally, what are the various possible interventions on these devices.
This certificate can only be obtained through a double theoretical and practical test, which must be set up by a state-approved body.
This certificate, once obtained, must mention the name of the certifying body, the full name of the holder, the number of the certificate, its expiry date if any, which exact activities are authorized for the holder, the date of issue and the stamp of the issuing authority.
These certificates are valid in all EU Member States. However, some may request a translation of this document from the holder.
The EC Regulation no. 842/2006 was amended and supplemented on 7 November 2012 by the adoption of a proposal for a European Commission Regulation on greenhouse gases and repealed by Regulation (EU) no. 517/2014 of 16/04/14 on fluorinated greenhouse gases.
In addition to the obligations described above (recovery of SF6 emissions during any intervention on devices containing SF6 and certified training of employees managing the monitoring of these devices), operators of electrical switching devices containing SF6, or high-voltage connection devices affected by EC Regulation No. 842/2006, will now have to have day-to-day registers reporting, per device, a certain number of information:
The SF6 content of the equipment
The additions of SF6 and their justification
The volume recovered during maintenance operation
The leaks found and their regularity
Identification of the company and employee who installed, maintained and, if applicable, repaired or decommissioned the equipment.
The measures observed for the recovery and elimination of fluorinated greenhouse gases when the equipment is taken out of service.
