### September 27, 2011 1 

## Significant New **Alternatives Policy Pr ogram**  **Fire Extinguishing and Explosion Prevention Sector Risk Screen on Substitutes for Halon 1301**  **Total Flooding Systems in Normally Occupied or Unoccupied Spaces**  **Substitute: Firebane**  **® 1179** 

**This risk screen does not**  **contain Clean Air Act (CAA) Confidential Business Information (CBI) and, therefore,**  **may be disclosed to the public.** 

**1. Introduction**  Ozone

- depleting substances (ODS) are being phased out of production in response to a series of diplomatic and legislative e fforts that have taken place over the past two decades, including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAAA). The U.S. Environmental Protection Agency (EPA), as authorized by Section 612 of the CAAA, administers the Significant New Alternatives Policy (SNAP) Program, which identifies acceptable and unacceptable substitutes for ODS in specific end

-uses based on assessment of their health and environmental impacts. EPA’s decision on the acceptability of a substitute is based large ly on the findings of a screening assessment of potential human health and environmental risks posed by the substitute in specific applications. EPA has already screened a large number of substitutes in many end

-use applications within all of the major OD S

-using sectors, including refrigeration and air conditioning, solvent cleaning, foam blowing, aerosols, fire suppression, adhesives, coatings and inks, and sterilization. The results of these risk screens are presented in a series of Background Documents that are available in EPA's docket. The purpose of this risk screen is to supplement EPA’s Background Document on the fire suppression and explosion protection sector (EPA 1994) (hereinafter referred to as the Background Document). This risk screen discus ses the potential human health and environmental risks posed by Firebane® 1179 when used as a flooding agent in normally occupied or unoccupied spaces as a replacement for Halon 1301. The reader is referred to the Background Document for the methodologies and assumptions used to conduct this risk screen. Firebane ® 1179 is designed for use in an Advanced Automatic Fire Extinguishing System (AFES), with primary use for fire protection in military ground vehicles . AFES discharge s into the vehicle in two pha ses , which together extinguish any residual fires and reduce the chance of fires from re

- flash due to hot surfaces or the presence of molten metals (GSL 2011d). Phase 2 of AFES is not under the jurisdiction of SNAP, and is not addressed in this risk screen. However, the potential for Phase 2 discharge to increase total exposure concentrations at end

-use is considered (see Section **Error! Reference source not found.** 5 ). Table 1 presents the composition of the proposed substitute.

### September 27, 2011 2 **Table 1**  **: Composition of**  **Firebane® 1179 Constituent**  **Chemical Formula**  **a CAS No.**  **Weight Percent**

a N/A = not available

. Section 2 of this risk screen summarizes the results of the risk screen for the proposed substitute. The remainder of the risk screen is organized into the following sections:

 Section 3 : Atmospheric Assessment ;  Section 4 : Occupational Exposure Assessment;
 Section 5 : End

-Use Exposure Assessment ;  Section 6 : G eneral Population Exposure Assessment ;  Section 7: Volatile Organic Compound Assessment; and
 Section 8: References

. 

### 2. **Summary**

**of Results** Firebane® 1179 is recommended for SNAP approval as a flooding agent in normally occupied and unoccupied spaces. However , adequate ventilation should be in place , appropriate personal protective equipment ( PPE) should be worn , and proper training administered for the manufacture and disposal of this product. PPE should include safety goggles and protective gloves. Additionally, the risk screen indicates that the use of the proposed substitute will be less ha rmful to the atmosphere than the continued use of Halon 1301 . Risk to the general population is expected to be negligible provided that proper disposal procedures are used , and occupational exposure should not pose a problem if PPE is used. 

### 3. **Atmospheric A** 

**ssessment** This section presents an assessment of the potential risks to atmospheric integrity posed by the use of Firebane® 1179 as a flooding agent. According to the submitter , Firebane® 1179 contains no Class I or Class II ODS , nor any compounds with me asured global warming potential (GWP). Therefore, the use of Firebane® 1179 will be less damaging to the atmosphere than continued use of Halon 1301

. 

### 4. **Occupational Exposure As**  **sessment** The potential for personnel exposure during manufacture, installation , and maintenance are examined in this section. The discharge scenarios discussed are assumed to occur accidentally and not as the result of a fire. In order to evaluate occupational exposure, ICF has evaluated the active compounds contained in Firebane® 11 79

. The common application types, FDA approval status, and associated hazards for these compounds are presented in Table 2

.

### September 27, 2011 3 **Table 2**  **: Common Applications Types and FDA Approval Status of F**  **irebane® 1179 Constituents**  **Constituent Common** 

**Application Types FDA Approval Status**  **a,b,c Associated Hazards** 

a FDA = U.S. Food and Drug Administration b FDA approvals are subject to use restrictions. Please see the cited regulation for further informatio n. c GRAS = G enerally Recognized as S afe **4.1. Occupational Exposure during Manufacture**  Firebane® 1179 is not expected to pose a risk to workers during manufacture

. As indicated by the submitter, oc cupational exposure during manufacture of Firebane® 1179 is expe cted to be limited to filling of extinguishers (GSL 2011d) . As summarized in the table above, all the constituents exhibit low toxicity and are commonly used in food applications. In addition, exposure to Firebane® 1179 is expected to be in the liquid form , with any vapor or gas exposures considered to be negligible (GSL 2010). T he risk of exposure will be further minimized by following safety and precautionary measures. For measures designed to minimize the hazards associated with a specific constituent , a s noted in Table 2, the constituent’s MSDS should be referenced. In order to minimize the risk associated with all of Firebane® 1179 constituents, EPA recommends the following in accordance with general procedures prescribed in the MSDS of the proposed sub stitute and by the submitter:

 Proper Level D or higher PPE be used during handling of the substitute (e.g. , goggles, gloves);
 A dequate ventilation should be in place;
 A ll spills should be cleaned up immediately in accordance with good industrial hygiene practices; and
 T raining for safe handling procedures should be provided to all employees that would be likely to handle the containers of Firebane® 1179 or extinguishing units filled with the material. Because of the minimal chance of worker exposure to the chemicals during the manufacturing process, the use of exposure controls and adherence to the appropriate occupational safety guidelines as mentioned above, are sufficient to ensure that the manufacture of Firebane® 1179 does not pose a risk to human health. In addition , an automated system for charging the extinguishers, as proposed by the submitter, would further reduce the risk of occupational exposure during manufacture to Firebane® 1179 ( 2011 d). **4.2. Occupational Exposure during Installation and Maintenance**  Firebane® 1179 is not expected to pose a significant risk to personnel during installation and maintenance activities , even in the case of an inadvertent discharge of the entire charge

. In such cases, o xygen displacement is negligible and discharge of Firebane® 1179 will not reduce oxygen levels to levels of concern (GSL 2011d). In addition, as noted above, all the constituents of Firebane® 1179 exhibit low

### September 27, 2011 4 toxicity and are commonly used in food. To ensure that the potential for exposure s during install ation and maintenance are further minimized, it is recommended that all personnel involved in the installation and maintenance of Firebane® 1179 a dhere to safety guidelines, as mentioned previously in Section 4.1

. Itis recommended that the proposed safe handling training also focus on prevention of an inadvertent discharge. In case of an inadvertent discharge, workers should immediately follow the instructions listed in the MSDS for Firebane® 1179

. 

### 5. **End -**  **Use Ex posure A** **ssessment** Firebane® 1179 is not expected to pose significant risk to end

-users when used as a flooding agent in normally occupied or unoccupied spaces

. Firebane ® 1179 is designed for use in an AFES , with primary use in military ground vehicles

. Th e primary health concern for Firebane® 1179 at the end

-use is exposure to the post

- activation discharge products

. Inhalation of the Firebane ® 1179 may cause mild irritation to the upper respiratory tract (GSL 2010). In the case of Firebane® 1179 , it is s tored and released as an aqueous solution. T he amount of time it takes for Firebane® 1179 to transverse the crew compartment is approximately a small fraction of a second (GSL 2011a and GSL 2011d). As such, the amount of Firebane® 1179 suspended in air in the crew compartment is expected to be minimal (GSL 2011a)

. Further, this is a conservative estimate, as the airflow rate in military ground vehicles that would further decrease the concentrations of suspended Firebane® 1179 is not considered in this asse ssment (GSL 2011d). Phase 2 discharge of Firebane® 1179 , as described in Section 1 , is not expected to increase concentrations of the proposed substitute within the crew compartment; this discharge is similar to a building sprinkler , resulting in larger droplets that will not be suspended within the air (GSL 2011a). Because of the low toxicity exhibited by Firebane® 1179 and the low inhalation concentrations anticipated during discharge, Firebane® 1179 is not considered to present a significant inhalati on risk at end

-use. Dermal and ocular exposure to Firebane® 1179 is not expected to present a significant risk to end

-users. As indicated in the MSDS, Firebane® 1179 is no t irritating to the skin and eyes

. In the event of exposure to Firebane® 1179 , indi viduals should follow the instructions prescribed in the proposed substitute’s MSDS. To minimize risk of exposure and irritation , EPA recommends that individuals follow the precautionary measures described in Section 4.1

. 

### 6. **General Population Exposure**  **As sessment**  This section screens potential risks to the general population from exposure to releases of Firebane® 1179 and its constituents to ambient air, surface water, and solid waste

. Firebane **®** 11 79 is not expecte d to cause a significant threat to human health in the g eneral population when used as flooding agent in normally occupied or unoccupied spaces. The only consumer exposure to Firebane® 1179 will be during discharge of the extinguishers in occupied spaces. Individuals should follow the precautionary measures described in the proposed substitute’s MSDS and Section 4.1 of this risk screen . When the recommended safety precautions are followed, no significant adverse health effects are expected. **6.1. Am**  **bient A ir**  Firebane® 1179 is not expected to pose a significant threat to human health in the general population in ambient air concentrations. A s noted previously, Firebane® 1179 is composed entirely of compounds that are FDA

- approved for use in food , of which so me are also FDA

- classified as GRAS

. Therefore, Firebane® 1179 is not expected to be a safety concern for ambient air contamination. **6.2. Surface Water**  Firebane® 1179 is not expected to pose a significant threat to human health or the environment , provided

### September 27, 2011 5 that proper disposal procedures are followed

. As discussed in the Background Document, the physicochemical properties of the majority of halon substitutes make it unlikely that the substitutes would be released to surface water as a result of use. In th e case of Firebane® 1179 , it is expected that all of the constituents would rapidly aerosolize during expulsion from the container and then settle as a liquid film on surfaces within the military ground vehicle (as opposed to becoming airborne and settling on a nearby stream) . After settling, cleanup would involve washing/rinsing of surfaces. Because of the high biological oxygen demand 1 (BOD) of Firebane® 1179 , it is recommended that discharges of Firebane® 1179 at the end

-use not be released to waterways . Further, it is recommended that during cleanup, discharges of Firebane® 1179 be collected (e.g., mopp ed) and contain ed in sealed containers and then disposed of in accordance with local, state, and federal requirements. T raining for safe disposal procedures should be provided to all employees that would be likely to dispose of Firebane® 1179 at end

-use. Further, activation of the Firebane® 1179 AFES is expected to be infrequent (i.e., in case of a fire emergency), where the greatest risk is exposure to fire and lack of oxygen. EPA believes that when the recommended disposal procedures are followed, Firebane® 1179 does not pose a significant threat to human health or the environment during end

-use. D ischarges of Firebane® 1179 at manufacture to publicly owned treatment works (POTW) are subject to local , state, and federal restrictions. Such restrictions include a limit on the BOD levels of industrial wastewater. 2 EPA believes that regulatory requirements on discharges that result from manufacture are suf ficient to control human health and environmental risks associated with Firebane® 1179 manufacturing operations

. **6.3. Solid Waste**  No constituents of Firebane® 1179 are considered to be hazardous waste under EPA regulations implementing the Resource Conservation and Recovery Act

. During post
- activation clean

-up procedures, clean

-up residues should be disposed of in accordance with requirements appropriate for those materials. 

### 7. **Volatile Organic Compound As**  **sessment** Of the constituents of Firebane® 1179 , only propylene glycol has not been exempted as a volatile organic compound (VOC) under the CAA (40 CFR 51.000 

### ). However, some states also have regulations concerning exempted VOCs and the definition of a VOC, which could exclude propylene glycol from consideration as a VOC



### . In general, VOC emissions should be sufficiently controlled through regulations and standard industry practices. VOC emissions from the production of total flooding systems charged with Firebane **®** 1179 are controlled through standard industry practices, and as such, emissions from manufacture of units are likely to be minimal

. Using release estimates from the Vintaging Model, the annual release rate (including discharge, leak, and testing release rates) for total flooding systems was calculated to be approximately 2.5% of fire suppressant charge size, annually. 3 Assuming this release rate, an assessment was performed to compare the annual VOC emissions from use of Firebane **®** 1179 in total flooding systems produced in one year to other anthrop ogenic sources of VOC emissions. Assuming the submitter’s current production plans, the amount of VOCs that would be emitted would be approximately equal to 7.2x10 - 6 percent of the annual VOC emissions caused by fires, 4 or only about

1 BOD is the amount of oxygen consumed by microorganisms as they decompose organic materials in water. 2 POTWs establish BOD limit s in order to prevent overloading of the water treatment system, which could potentially cause the organism

-based treatment system to fail if oxygen levels become too low for aerobic respiration. 3 The total annual release rate of 2 .5% for total flooding s ystems wa s determined using the average annual leak rate ( 0.5 %) , annual discharge rate (2 %) , and annual release during testing (0%) from the Vintaging Model (v4.4_3.23.11). 4 Based on 2010 projections calculated using 2008 EPA annual VOC emissions data f or residential wood burning and agricultural field burning (E PA 2008 and EPA 2011 ) and ICF assumptions.

### September 27, 2011 6 2.6x10 - 7 percent of all annual anthropogenic sources. 5 Moreover, even if all Firebane® 1179 produced by Global Safety Labs in one year were to be released to the atmosphere over the course of the year (extremely unlikely), the resulting annual VOC emissions would be approximately 2.9x10 - 4 percent of annual VOC emissions caused by fires, or only about 1.0 x10 - 5 percent of all annual anthropogenic VOC emissions. As these emissions of Firebane® 1179 are se veral orders of magnitude less than other anthropogenic emissions, the environmental impacts of these VOCs are not considered a threat. 

### 8. **R eferences**  EPA 1994. "Risk Screen on the Use of Substitutes for Class I Ozone

- depleting Substances: Fire Extinguishing and Protection (Halon Substitutes)," U.S. Environmental Protection Agency, March 1994. EPA 2008. 2005 National Emissions Inventory Data & Documentation. Inventory Data: 42 Category Summaries. Last updated 6 July 2010. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/net/2005inventory.html#inventorydata>. EPA 2009. National Emissions Inventory (NEI) Air Pollutant Emissions Trends Data and Estimation Procedures. 1970

– 2008 Average Annual Emissions, All Criteria Pollutants

. Last updated 09 Ju ne 2009. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/trends/index.html#tables>. EPA 2011. The National Emissions Inventory. 2008 National Inventory Data. Last updated 19 July 11. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/net/2008inventory.html >. Global Safety Labs, Inc. 2011 a . “Response to Incomplete SNAP Submission for Firebane® 1179 .” July 22, 2011. Global Safety Labs, Inc. 2011 b . “Response to Incomplete SNAP Submission for Firebane® 1179 .” June 15, 2011. Global Safety Labs, Inc. 2011 c . “Resp onse to Incomplete SNAP Submission for Firebane® 1179 .” May 20, 2011. Global Safety Labs, Inc. 2011d. “Response to Incomplete SNAP Submission for Firebane® 1179 .” May 6, 2011. Global Safety Labs, Inc. 2011 e . “Response to Incomplete SNAP Submission for Firebane® 1179 .” April 4, 2011. Global Safety Labs, Inc. 2010. SNAP Submission to EPA for Firebane® 1179 . December 23, 2010.

5 Based on 2010 projections calculated using 2008 EPA annual VOC emissions data (EPA 2009) and ICF assumptions.