DuPont and 3M on Clean Agents and the Environment

Article written by 3M:

Skipping to Second Generation of Fire Suppression Agents

25 October 2011

Lessons learned in North America and the EU about the next-generation Halon alternatives

Halon has been a popular clean fire suppression agent utilised to protect computer rooms, historical archives and other high-value assets where a water-based system should not be used. Because of Halon’s potent ozone depletion potential, its production was phased out under the Montreal Protocol and it has not been manufactured in the Asia Pacific (APAC) region since 2010.

As the APAC fire suppression industry evaluates alternatives to Halon, it may benefit from the experience gained in the United States (U.S.) and Europe (EU) over the past 20 years, as they were faced with transitioning to alternatives and replacing or significantly modifying their Halon systems. This was not only expensive but also inconvenient. Understanding these experiences provides the APAC region with the unique opportunity to skip over turbulent first-generation Halon alternatives that, although they addressed stratospheric ozone depletion, are now under pressure because they are potent greenhouse gases.

Clean Agent Fire Suppression Options

During the Halon phase out, many in the U.S. and EU began looking into other fire protection agents that did not damage the ozone layer and would not be regulated for environmental reasons now or into the future. One of the most popular alternatives to Halon at the time was hydrofluorocarbons (HFCs). HFCs are man-made compounds used in refrigeration, air conditioning, insulating foam, aerosols, medical devices, solvent cleaning and fire suppression systems. One of the more widely used examples in the fire protection industry is HFC-227ea (FM-200 brand), considered a first-generation Halon alternative. Compared with Halon, HFCs have better environmental characteristics. The ozone depletion potential of HFCs is zero, but their global warming potential (GWP) and atmospheric lifetimes do not rank so well. The GWP of HFC-227ea is 3,220. This means it is 3,220 times more potent than CO2 in its effect on global warming and it has an atmospheric lifetime of 34 years.

HFCs used in fire protection have a higher GWP than those HFCs used in other applications. It has been reported in the Proceedings of the National Academy for Sciences that if nothing changes, HFC emissions are likely to be equivalent to between 9 to19 percent of global greenhouse gas emissions by 2050.

Not all fire suppression agents are created equally. Fortunately, those in the APAC region can learn from these lessons and can skip the first generation Halon alternatives and go directly to a generation of sustainable fire protection. These chemistries, including water mist, inert gas, CO2 and FK-5-1-12, a fluoroketone, branded 3M Novec 1230 Fire Protection Fluid, are not likely to be regulated now or in the future.

Water mist, inert gas and CO2 are suitable for use in some applications but they have limitations. Water mist, for example, damages paperwork and electrical and computer installations, while CO2 can be lethal. Next generation Halon alternatives like the 3M fluoroketone, however, have proven performance and are not likely to be included under regulatory control. FK-5-1-12 fluroketone fluid has an ozone depletion potential of zero with a global warming potential of one and an atmospheric lifetime of just five days. It does not damage sensitive equipment, paper or furnishings and leaves no residue. The fluid is stored as a liquid, making transportation of the fluid much safer and easier than the alternatives. This clean agent fluid has been used successfully in the past seven years in data centres, telecommunication centres and other types of high value, critical applications, as well as archives and museums and in the marine and oil and gas industries. In fact, the fluid can help earn innovation credits toward meeting the U.S. Green Building Council’s Leadership in Energy and Environmental Design Certification (LEED).

With the life span of a building being an average of 30 to 40 years, fire protection systems need to have similar life spans to avoid replacing or reconfiguring the system. As those in the U.S. and EU discovered, doing so is costly and disruptive. Decisions about fire protection need to be for the long term and the type of extinguishing agent used is an important part of that decision. It is tempting to think that lessons would have been learned and that the Halon story could never be repeated. The APAC region has the opportunity to learn from these experiences.

Regulations on HFCs

The future of HFC-based fire protection systems is unclear. There has been a lot of confusion within the fire protection industry about the ultimate impact of global policy, legislative and regulatory initiatives on HFCs. Governments continue to discuss efforts to phase down HFC production under the Montreal Protocol and there are independent efforts to limit their use through regulatory actions already available to the U.S. Environmental Protection Agency (EPA) and in the European Union. Given that there are alternatives to HFCs with substantially lower environmental impact, it seems likely that governments will ultimately limit production of HFCs or specifically limit their use in fire protection systems.

The fate of HFCs in the U.S. and EU fire protection market is unknown and not all HFC markets will be affected the same way. Some applications within air conditioning, refrigeration and foam blowing sectors have no viable alternatives. Fire protection however, has other alternatives. In the years to come, many issues are going to be impacting the fire protection industry and moves to control HFCs have already started.

Phase Down of HFCs

The alarming growth in the use of HFCs as replacements for ozone depleting substances has increased attention on this class of materials as a significant future contributor to global warming and climate change. A production phase-down would lead to higher costs for HFCs over time. HFC producers may turn their commodity HFC markets back into specialty markets by introducing new chemistry in refrigeration and air conditioning but the increased cost of replacement chemistry may not be favourable for HFCs sold into fire protection. If an HFC production phase-down takes hold, applications where low cost alternatives already exist will be the first to transition to alternatives. Fire suppression would likely be one of the first sectors to move away from HFCs.

In May of 2010, the U.S. 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 where next generation alternatives are readily available.

While the future of HFCs is unclear, what is clear is that those in the APAC region will need to convert their traditional Halon business to more sustainable fire suppression. First-generation HFCs may not be the right choice however, because of their high GWP and atmospheric lifetimes, and because they will likely become more difficult and expensive to maintain. In addition to looming environmental regulations, HFCs are also undergoing supply chain difficulties, making fire suppression system planning more challenging than ever. Uncertainty about the availability of raw materials and feed stocks, the status of environmental regulation and now supply disruptions, have turned the marketplace on its head. With all of this uncertainty, switching from Halon to first generation HFCs is no longer a good idea. The countries in the APAC region have the good fortune to have access to a proven clean agent fire protection technology that is truly environmentally sustainable.

Contact: For further information, go to www.3M.com/Novec

Kurt Werner is Environmental Affairs Manager at 3M.

George Ip is a senior application development specialist for 3M.

Here is the response from Mark Robin to that article:

Comments Related to the AFP Article “Skipping to Second Generation of Fire Suppression Agents,” Kurt Werner and George Ip (3M), Asia Pacific Fire Magazine, 25 October 2011

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With regard to the recent article in Asia Pacific Fire Magazine (October 25, 2011),  entitled “Skipping to Second Generation Fire Suppression Agents,” by Kurt Werner (3M),  I would like to offer the following comments.

No other issue related to clean agents is perhaps more misunderstood and misrepresented in the marketplace than the issue of environmental impact. This confusion and misinformation includes a lack of understanding of (1) the meaning of GWP values, (2) the impact of HFCs used in fire suppression on climate change, and (3) regulations related to HFCs in fire suppression applications. Unfortunately, the above-referenced article adds to the misinformation already prevalent in the marketplace.

GWP Values. 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: “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 GHGs (GWP=1), yet emissions of CO2 account for approximately 85% of the impact of all 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, e.g., 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 on Climate Change. The relative contribution or impact of any GHG gas to climate change is readily found from an examination of the number of “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 typically expressed in terms of “Tg of CO2 equivalents,” 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. Appendix A.1.6 of NFPA 2001 (2012 edition), for example, indicates that, based on US EPA data (US EPA, Inventory of U.S. GHG Emissions and Sinks: 1990-2007), “…the impact (in Tg of CO2 equivalents) of HFC emissions from fire suppression applications represents 100 x (0.7/7150.1) = 0.0098 percent of the total impact of all GHGs; that is, the impact of HFC emissions from fire protection applications represents less than 0.01 percent of the impact of all GHG emissions.” Emissions data are also available for EU-15 countries, and as is the case for the US, indicate that the relative contribution of HFCs in fire suppression applications to climate change is miniscule (Annual European Union GHG Inventory 1990-2009 and Inventory Report 2011, 27 May 2011).

Regulation of HFCs in Fire Suppression Applications. 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 characterized by high chemical reactivity (e.g., hydrolysis when crossing the lung-air interface, cf. NovecTM 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.

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 and (2) the location of the text which 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 the Article in question exemplify these risks. The devil, as always, is in the detail.

The AFP article indicates 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 article, “The Large Contribution of Projected HFC Emissions to Future Climate Forcing,” Velders, et. al., Proc. Nat. Acad. Sciences, (106), 27, page 10949, co-authored by DuPont (copy available at http://www.harc.org/images/PNAS-2009-Velders-0902817106.pdf). The article specifically relates to HFCs used in refrigeration, air conditioning and insulating foam production whose emissions dwarf those of HFCs from fire suppression applications. The report further indicates on page 10950 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 AFP article also references 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 Defense 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 end-use category (e.g., aerosols, 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 fire suppression industry.

As a footnote, the LEED program specifies that fire suppression systems not contain ozone depleting substances (ODSs), specifically CFCs, HCFCs or Halons. HFCs, inert gases and FK-5-1-12 are NOT ozone depleting substances and hence LEED credits can be obtained for the use of any of these clean agent systems.

Any readers interested in copies of any of the cited documents, or of the NRDC petition, please let me know and I would be happy to either supply copies or direct the reader to a copy.

Mark L. Robin, PhD
DuPont Chemicals & Fluoroproducts

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