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DuPont 4-page reprint 16/2/12 7:37 am Page 1 CLEAN AGENTS Dubai Metro. Protected by FM-200 Climate Change and the HFCBased Clean Extinguishing Agents Mark L. Robin DuPont Chemicals & Fluoroproducts No other issue related to the hydrofluorocarbon (HFC) clean fire extinguishing agents is perhaps more misunderstood than the issue of their environmental impact. T his confusion in the clean agent marketplace results from a lack of understanding of three key issues. Each requires reviewing in detail and provides factual information related to the use and environmental impact of HFCs in fire suppression applications. The three issues are: 1 The meaning of global warming potential (GWP) values. 2 The impact of HFCs used in fire suppression on climate change. 3 Regulations related to HFCs in fire suppression applications. Background Since their introduction in the early 1990s, the HFC-based clean agents have been the most INTERNATIONAL FIRE PROTECTION widely employed replacements for Halon 1301 worldwide, and there are currently hundreds of thousands of HFC-based fire suppression systems installed worldwide, protecting billions of dollar’s worth of valuable and sensitive assets. The HFC-based clean agents employed in total flooding applications are FM-200 (CF3CHFCF3, HFC-227ea), FE-25 (CF3CF2H, HFC-125), and FE-13 (CF3H, HFC-23). Table 1 (page 2) shows a small sample of some of the facilities and equipment protected by HFCs. Major corporations employing HFC-based fire protection include Cisco, Westinghouse, Etisalat, Sprint, Lockheed Martin, Exxon/Mobil, AT&T, GTE, Nokia, Saudi Aramco, Intel, IBM, Mitsubishi and Wal-Mart. 1 DuPont 4-page reprint 16/2/12 7:37 am Page 2 CLEAN AGENTS CLIMATE CHANGE AND THE HFC-BASED CLEAN EXTINGUISHING AGENTS Table 1. Examples of HFC Clean Agent System Installations Facility National Museum of Pre-History, Taiwan Eiffel Tower, France Royal Thai Family Silk Museum, Thailand Bangkok International Airport, Thailand Smithsonian Institute, USA US EPA Supercomputing Center, USA Alexandria Library, Egypt Dubai International Airport, UAE Dubai Metro, UAE King Saudi University, Saudi Arabia Bouabieh Palace, Riyadh, Saudi Arabia Aristoteles Museum, Greece Dusseldorf International Airport, Germany The success of HFCs in the clean agent market is due to the fact that the HFCs offer the best overall combination of the properties desired in a Halon 1301 replacement, along with being the most cost effective replacements. All HFCs are characterised by zero ozone depletion potentials (ODPs), and hence they do not contribute to ozone depletion. As can be seen below, the impact of HFCs employed in fire suppression applications on climate change (global warming) is minuscule, rendering the HFCs a viable, sustainable replacement for Halon 1301 in total flooding fire suppression applications. What are GWP Values, and What Do They Mean? A clear explanation of what GWP values are can be found in Section A.1.6 of the recently published (2012) edition of NFPA 2001 Standard on Clean Agent Fire Extinguishing Systems, which demonstrates the fact that the GWP value considered by itself does not provide an indication of the impact of an agent on climate change, stating: “It is important to understand that the impact of a gas on climate change is a function of both the GWP of the gas and the amount of gas emitted. For example, carbon dioxide (CO2) has one of the lowest GWP values of all greenhouse gas emissions (GWP=1), yet emissions of CO2 account for approximately 85% of the impact of all greenhouse gas (GHG) emissions.” The GWP value for a gas simply compares the impact on climate change of the emission of the gas to that of CO2. For example, a GWP value of 100 indicates that the emission of 1 kg of the gas in question has the same impact on climate change as the emission of 100 kg of CO2. Impact of HFCs in Fire Suppression Applications The relative contribution or impact of any GHG to climate change is readily found from an examination of the number of the “CO2 equivalents” associated with the amount of gas emitted. CO2 equivalents are calculated by multiplying the mass of agent emitted by its GWP value, and are 2 typically expressed in terms of “Tg of CO2 equivalents,” which can be calculated by multiplying the mass of emissions (in Tg) by the GWP of the gas in question. Factual information related to the impact on climate change of HFCs in fire suppression applications is available from several independent sources. The US EPA (Environmental Protection Agency) has employed its vintaging model to estimate the emissions of greenhouse gases from various sources, and the most recent results are shown in Table Two and Table Three, which indicate the relative impact of GHG emissions (Tg of CO2 equivalents) for the various GHGs and for HFCs as a function of industry, respectively. As can be seen from Tables Two and Three, the impact (in Tg of CO2 equivalents) of HFC emissions from fire suppression applications represents 100 x (0.8/6633.2) = 0.012% of the total impact of all GHGs. That is, the impact of HFC emissions from fire protection applications represents approximately 0.01% of the impact of all GHG emissions. Table 2. Relative Impact of GHG Emissions on Climate Change Gas USA Tg CO2 equivalents % of Total CO2 5505.2 83.0 CH4 686.3 10.3 N2O 295.6 4.5 HFC 125.7 1.9 PFC 5.6 0.1 SF6 14.8 0.2 Total 6633.2 100% Source: US EPA 430-R-11-005 (2011) Table 3. Relative Impact of HFC Emissions on Climate Change Gas USA Tg CO2 equivalents % of Total Refrigeration 104.9 83.5 Aerosols 9.1 7.2 Fire Protection 0.8 0.6 Foam 3.9 3.1 R-22 Manufacture 5.4 4.3 Solvents 1.3 1.0 Semiconductor Manufacture 0.3 0.2 Total HFC 125.7 100% Source: US EPA 430-R-11-005 (2011) Recent results from the HFC Emissions Estimating Program (HEEP), which estimates the emissions of HFCs from fire suppression, are in agreement INTERNATIONAL FIRE PROTECTION DuPont 4-page reprint 16/2/12 7:37 am Page 3 CLIMATE CHANGE AND THE HFC-BASED CLEAN EXTINGUISHING AGENTS CLEAN AGENTS with the results of EPA’s vintaging model results for the emission of HFCs from fire suppression applications. The HEEP analysis also indicates that the emissions of HFCs from fire suppression applications have been steadily decreasing since 2007. The clean agent industry has done an excellent job of policing itself and reducing unnecessary discharges through its adherence to the Voluntary Code of Practice (VCOP) for the Reduction of Emissions of HFC & PFC Fire Protection Agents, a partnership of the U.S. EPA, Fire Equipment Manufacturers Association (FEMA), Fire Suppression Systems Association (FSSA), Halon Alternatives Research Corporation (HARC) and National Association of Fire Equipment Distributors (NAFED). Emissions data is also available for EU-15 countries, and are summarized in Table Four and Table Five [Annual European Union GHG Inventory 1990-2009 and Inventory Report 2011, 27th May 2011]. As is the case for US emissions, the EU-15 data indicates that the relative contribution of HFCs in fire suppression applications to climate change is minuscule; 100 x (2.6/3729) = 0.07% of the impact of all GHG emissions. Eiffel Tower. Protected by FM-200 Table 4. Relative Impact of GHG Emissions on Climate Change EU-15 Gas Tg CO2 equivalents % of Total CO2 3063 81.5 CH4 311 9.0 N2O 280 7.7 HFC 66 1.6 PFC 2 0.1 SF6 6 0.1 Total 3729 100% Table 5. Relative Impact of HFC Emissions on Climate Change EU-N15 Gas Tg CO2 equivalents % of Total Refrigeration 50.1 75.9 Aerosols 7.6 11.5 Fire Protection 2.6 3.9 5.7 8.6 66.0 100% Foam R-22 Manufacture Solvents Semiconductor Manufacture Total HFC Regulation of HFCs in Fire Suppression Applications The Montreal Protocol relates to ozone depleting substances (ODSs), and not to zero ODP agents such INTERNATIONAL FIRE PROTECTION as the HFCs, hence, HFCs are not subject to the provisions of the Montreal Protocol. The Kyoto Protocol and F-Gas Regulations are related to the reduction of GHG emissions, but are solely concerned with emissions reductions and do not limit or prohibit the use of HFCs in fire suppression applications. Regulators understand the science as illustrated above; they understand the minuscule impact of HFC emissions associated with fire suppression. With regard to the regulation of any chemical, no one can guarantee a lack of future regulations, and speculation on this point serves only to confuse the industry and drive end users to non-clean alternatives such as sprinklers. No one can guarantee that HFCs in fire suppression applications will never be phased out — not without being able to divine the future. Can anyone guarantee that perfluoroketones will not be phased out in the future? Unlike other clean agents, perfluoroketones are characterised by high chemical reactivity (for example, hydrolysis when crossing the lung-air interface, cf. Novec 1230 Fire Protection Fluid Safety Assessment, 3M). Even the inert gases have been challenged by acoustic damage, high cylinder pressures, and room over-pressurization. Regulations continuously evolve as new science, information, and issues develop in the marketplace, and no product is immune to a changing regulatory future. It is a fact, however, that with regard to regulations, HFCs in fire suppression applications are being treated differently than HFCs employed in other applications. Emissions of HFCs from fire suppression applications are dwarfed by HFC emissions from other applications such as refrigeration. Regulatory bodies understand this, and to date HFCs in fire suppression applications have been subject to different sets of regulations. A good example is the F-Gas regulation in Europe, which has adopted, supported and regulated good industry practices around system filling, handling, and servicing of fire systems. 3 DuPont 4-page reprint 16/2/12 7:37 am CLEAN AGENTS Page 4 CLIMATE CHANGE AND THE HFC-BASED CLEAN EXTINGUISHING AGENTS F-22 Raptor. Protected by FE-25 It is important when encountered with an assertion of impending legislative or regulatory action related to HFCs in fire suppression applications to always request two items: 1 A copy of the legislation 2 The location of the text that is specifically related to HFCs in fire suppression applications. This will avoid confusing specific targeted information with broader market relevance, or extrapolating an action in one target sector to another entirely different sector, such as fire suppression. The two following examples from a recent article (Asia Pacific Fire Magazine, October 25, 2011) exemplify these risks. In the article it stated that: “It has been reported in the National Academy of Sciences that if nothing changes, HFC emissions are likely to be equivalent to between 9 to 19 percent of global greenhouse gas emissions by 2050.” This statement refers to the report, “The Large Contribution of Projected HFC Emissions to Future Climate Forcing,” Velders, et. al., Proc. Nat. Acad. Sciences, (106), 27, page 10949. The article Based on US EPA data, the impact of HFC emissions from fire protection applications represents approximately 0.01% of the impact of all GHG emissions. Mark L. Robin is Senior Technical Services Consultant at DuPont For further information, go to www.dupont.com 4 specifically relates to HFCs used in refrigeration, air conditioning and insulating foam production where emissions dwarf those of HFCs from fire suppression applications. The report further indicates that HFC-227ea was not even included in the analysis due to its small use and emissions. The article supports the case for the use of alternative technologies and emission reduction schemes for highly emissive HFC uses, but offers no analysis or comment on the use of HFCs with respect to fire suppression. The same article also refers to a petition to the US EPA to delist acceptable SNAP substitutes: “In May 2010, the US EPA received a petition to selectively remove HFCs from the list of acceptable substitutes under the EPA’s Significant New Alternatives Policy Program (SNAP). This move could have a large impact on the fire protection sector…” The US EPA received the petition from the National Resources Defence Council (NRDC) in May of 2010. The petition is a request to remove a single HFC, HFC-134a, from the list of acceptable substitutes for CFC-12 in motor vehicle air conditioning systems maintained under EPA’s Significant New Alternatives Policy (SNAP) program, and to remove HFC-134a from such list in any other enduse category (for example, aerosols and stationary refrigeration) where more benign alternatives are available. Specifically, this was not a petition to “selectively remove HFCs” from the SNAP list, but a petition to remove one, highly emissive compound from specific refrigeration applications, for which the user industry was already moving to adopt a viable alternative. Before addressing the original petition, the EPA required the petition to limit the scope to new mobile air conditioning applications in new passenger cars and light duty vehicles only, and is now just beginning a process to determine whether such a transition can occur. Stakeholder input is currently being assessed, and there has, to date, been no decision as to whether or not such a transition will occur in this specific market sector and application. As such it is puzzling to see it asserted that this petition could in some fashion affect the clean agent fire suppression industry. Conclusion Factual information related to the impact on climate change of HFCs in fire suppression applications is available from several sources, and this data demonstrates that the impact of HFC clean agents on climate change is minuscule. As a result, HFCs are expected to remain viable, sustainable, and environmentally acceptable replacements for Halon 1301 well into the IFP foreseeable future. INTERNATIONAL FIRE PROTECTION