Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net December 2, 2015

DELIVERED VIA ELECTRONIC MAIL: 

### McCarthy.gina@Epa.gov

Administrator Gina A. McCarthy 

### U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, N. W.

Mail Code: 1101A Washington, DC 20460

SUBJECT: Change of Status of HFCs under Clean Air Act Section 612 (SNAP Program)

Dear Administrator McCarthy:

The Fire Suppression Systems Association (FSSA) is a not-for-pr ofit trade association, drawing members domestic and internationally and is comprised of a blend of designer/install ers, manufacturers, consultants, academics, and suppliers, working together to share ideas and strategies for the benefit of the fire suppression systems industry.

The Fire Suppression Systems Association supports the United St ates Environmental Protection Agency (EPA) and its ongoing evaluation and adjustment of the list of acceptable alt ernatives maintained under the Significant New Alternatives Policy Program (SNAP). The SNAP Program has bee n, and continue s to be, a very effective means to promote the proper use and application of alterna tives to ozone depleting halons i n fire protection.

Recently EPA received petitions from the Natural Resources Defe nse Council (NRDC) and the Environmental Investigation Agency (EIA) to further restrict or remove various products wit h global warming potentials from the SNAP program. It should be noted that the fire protection sector is the source o f only about 3% of the installed quantities of HFC gases. However, because these extinguishing agents are virtually non-e missive in non-fire situati ons, it is estimated that less than .4% of HFC emissions from all U.S. sources is from fire protect ion systems. As a percentage of all U.S. greenhouse gas emissions, HFC fire protection agents represent a miniscule 0.008%. Further, our industry has led the way in this field - introducing global codes of practice for containment an d leak protection well in advance of any regulatory pressures. For example, see the Halon Alte rnatives Research Corporation (H ARC) publications listed below:

 HARC Code of Practice for Use of Recycled Halogenated Clean Agents (www.harc.org)

 HARC Voluntary Code of Practice for the Reduction of Emissions of HFC & PFC Fire Protection Agents

(www.harc.org/vcopdocument.pdf)

 Halon Recycling Corp. Code of Practice for Halon Reclaiming Companies (www.halon.org/pdfs/code/pdf).

FSSA is a member of HARC and was heavily involved in developing and promulgating these cod es of practice. FSSA has always supported effective codes and regulations that take into account the unique concerns of fire protection – the risk posed to life and property from fire events.Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net Protecting People and Property – A Unique Challenge

The fire protection industry fully supports the goal to minimiz e non-fire emissions of all fire protection agents. The overarching concern of our industry, however, remains the reduc tion of risk to people and property from the threat of fire and explosion with products and systems proven to be effective. Every fire protection scenario presents a unique challenge.

Rooms have different shapes, di fferent uses and contents, and e ven different atmospheric conditions and fire hazard threats. These factors all affect, from a scientific perspective, the ch oice of the right fire extinguishing agent. Therefore, it is vi tal that measures to reduce emissions do not prevent fire protectio n scientists and engineers from determining the most appropriate fire extinguishing system to use for each individua l scenario based on a thorough risk assessment.

The vast majority of FSSA members offer a range of fire protect ion solutions, including water systems, foam, water mist, carbon dioxide and inert gases. FSSA fire equipment installers seek to provide the best fire protection solution for each hazard from among their multiple options. Fire protection engin eers and Authorities Having Jurisdiction (e.g., local or state fire marshals, code enforcement officials, insurers) make their recommendations based on which solution is the most appropriate in each given design circumstance.

To restrict this choice through arbitrary regulation – such as these proposals submitted in the N RDC and EIA letters - would be to put health and safety at risk. We strongly recommend agai nst regulatory measures constraining the ability of fire protection professionals to make effective, appropriate fire pr otection choices for the protection of lives and critical prope rty. Specifically, for these reasons FSSA opposes the requests to de list or modify the SNAP approvals now in place for HFC23, HFC-125, HFC-236fa and HFC-227ea.

Use Bans Have Proven to be Damaging to the Environment

It is very clear that use bans are not justified or productive in the Fire Protection Sector. Use bans may also have the unintended effect of increasing emissions, as particular firefi ghting agents may become instantly worthless with no marketbased incentive to recycle or dis pose of the agents properly. T his was a noticeable consequence of the halon use bans in some countries and regions (not in the US) following the applic ation of the Montreal Protocol. In the US and elsewhere around the globe, recycling of firefighting agents is a robust and active market, allowing material to hold market value and thus flow to the most critical required applications. Use b ans, as proposed by the petitioners, would likely remove the

intrinsic value of installed ex tinguishing agents and accelerat e the decommissioning and the potential for unwanted release of these materials to the atmosphere.

Emissions are Rare, Measured and Reported

Use of agents in fire protection is unique as emissions general ly only occur in the event of a fire. Thus, as noted earlier, the sector is almost statistically non-emissive. This means tha t the incidence of fires (rather than production levels) is a better measure by which to determine emissions in our sector. This is clearly demonstrated in data gathered by the US HFC Emissions Estimating Program (HEEP) conducted by the Halon Alte rnatives Research Corporation. (See: www.harc.org/images/heepfinalrepor t10.pdf). HEEP data verifies that emissions remain at an extremely low, stable rate, even though the number of installed systems year over year incr eases. Again, instituting a ban on certain fire extinguishing agents would likely result in an increase in inadvertent atmosp heric emissions due to loss of value and increased decommissioning and handling of installed systems, producing th e exact opposite to the goals sought by the petitions.Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net HFC-23 Considerations

Both petitions call for limiting the use of HFC-23 in fire supp ression and explosion protection applications. Already in the USA, HFC-23 is generally used in limited, highly specialized fi re protection applications where typically no other technology is as effective. The key elements of HFC-23 driving these design applications are low temperature requirements and/or high design concentration requirements in occupied space s.

HFC-23, with a boiling point of -82 °C, lower that other gaseou s technologies, provides system flow characteristics and low temperature distribution and extinguishing performance that is not feasible with other technologies. FSSA members typically apply these features to applications involving cold t emperature archiving and stor age and on mining equipment. Occupied areas requiring high concentrations of extinguishing a gent for protection are also candidates for use of HFC-23 due to its low toxicity thresholds.

HFC-227ea, HFC-236fa and HFC-125 Considerations

HFC-227ea, HFC-236fa and HFC-125 have been widely used in the U SA in fire extinguishing systems and portable extinguishers for over 20 years as replacements for ozone deple ting halons. The ba nk of installed system s is considerable. Banning or unnecessarily restricting the use of these agents fo r fire extinguishing purposes, would have a serious economic impact on users of these systems. Recharge of systems would no longer be feasible; the cylinders, pipe and associated system equipment would become scrap. Currently when a system o wner no longer needs a system to protect his facility, the agent is reclaimed, recycled, and used for future fire prot ection. If use bans were implemented, such agent would become a liability with no mark et value and the chance of relea se of the agent to the atm osphere would be increased.

Conclusion

FSSA is proud of its long history of working in cooperation wit h the EPA and other interested parties in answering the challenges to fire protection and environmental concerns. The fire protection sector continues to need all fire suppression agents that are currently available for use in order to safely and effectively protect people and critical assets from fire. Unnecessary restrictions on the available options for use in fi re suppression applications will increase the risk to people without providing a significant benefit to the environment, glo bal warming or climate change.

Respectfully submitted,

FIRE SUPPRESSION SYSTEMS ASSOCIATION

Crista LeGrand

Executive Director

cc: Cynthia Newberg, USEPA Chief, Alternatives and Emissions Re duction Branch, Office of Atmospheric Programs Bella Maranion, USEPA Program Analyst Margaret Sheppard, USEPA Environmental Scientist