In order to reduce emissions of fluorinated greenhouse gases and to meet the mandatory targets set by the Kyoto Protocol to the EU on the climate crisis, Regulation (CE) No 842/2006, in relation to some of these gases, including sulphur hexafluoride (SF6), has been adopted by the European Parliament and its Council.
This text, in force since 4 July 2007, regulates the obligations specific to all stages of the life cycle of fluorinated greenhouse gases, since their production.
This Regulation is therefore addressed to all parties involved in all 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.
The responsibility for compliance with the law in force lies with the operator of the high-voltage switchgear and controlgear.
The legislation, through Regulation 842/2006, repealed by Regulation (EU) No. 517/2014 of 16/04/14 on fluorinated greenhouse gases, defines it as : "the legal or natural person exercising real power over the technical functioning of equipment and systems".
This definition includes the fact that this equipment operator is not necessarily the owner.
In most cases, the operator of high-voltage connecting devices is a legal entity. It must properly train its personnel for the proper technical operation of this equipment for its proper day-to-day use.
This regulation aims, among other things, to prevent any release of SF6 into the air, by strictly regulating the operators of high-voltage switchgear and controlgear, mainly with regard to :
A. SF6 retrieving obligation
The operator must organise the implementation of the recovery of the SF6 in the event of maintenance work, dismantling of the equipment, with certified employees, whether for recycling, regeneration or destruction in an incinerator.
There are two main groups of high voltage equipment :
Sealed pressure vessels, generally referred to as "lifetime seals". The SF6 is kept indoors without the need for intervention at any time during the life of the device.
This situation implies that the operator does not need maintenance.
He will then only have to manage, with certified employees, the removal of the device.
The other case concerns pressure controlled devices, which have a control and alarm system if the pressure of the SF6 varies. This allows the gas charge to be adjusted to maintain the appliance during its operating time.
These cases of maintenance and recovery of SF6 must then be managed by the operator via his qualified employees.
B. Certification obligation for maintenance employees
Employees who have obtained the official certificate are the only ones authorized to implement the recovery procedures of SF6, as well as those of intervention on the load at SF6 of the devices, at all stages of their use, as well as to proceed to their maintenance and removal.
European Commission Regulation CE No 305/2008 stipulates at least how training should be organised and what the conditions for obtaining certificates are. The aim is to ensure uniform certification of persons responsible for managing the recovery of certain fluorinated greenhouse gases from high-voltage switchgear.
This training is organized around three axes : knowing the characteristics of SF6 and its environmental impact, knowing the high-voltage connection electrotechnics 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 carried out by a state-approved body.
Once obtained, this certificate must include the name of the certifying body, the full name of the holder, the number of the certificate, its expiry date if any, the exact activities authorised for the holder, the date of issue and the stamp of the authority issuing the certificate.
These certificates are valid in all EU Member States. However, some may ask the holder for a translation of this document.
EU Regulation 842/2006 was amended and supplemented on 7 November 2012 by the adoption by the European Commission of a proposal for a 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 previously described (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 covered by CE Regulation 842/2006, must now have records relating to a certain amount of information on a daily basis, per device :
- The capacity of the equipment in SF6
- The addition of SF6 and their justification
- The volume recovered during maintenance operations
- Leaks observed and their regularity
- The identification information of the company and employee who installed the device, its maintenance and, if applicable, its repair or decommissioning.
- The measures observed for the recovery and elimination of fluorinated greenhouse gases during the decommissioning of the equipment.