Fire Protection Sector SNAPStakeholder WorkshopMarch 5, 2014U.S. Environmental Protection AgencyIntroduction• Why fire protection, why now?– EPA has been conducting a series of SNAP sector workshops• March: Aerosols• April: Foams• November: Household Appliances• December: Stationary A/C, MVAC, Commercial and IndustrialRefrigeration• Scope of the Meeting– Significant New Alternatives Policy (SNAP) Program– Climate Action Plan– Vintaging Model• Discussion2Identifying Safer Alternatives:SNAP Program• Evaluates substitutes that reduce overall risk to humanhealth & environment in industrial sectors– Aerosols, Foams, Refrigeration and A/C, Solvents,Fire Suppression, Adhesives, coatings & inks, etc.• 400+ substitutes reviewed considering:– Ozone-depleting potential– Global warming potential– Flammability– Toxicity– Local air quality– Ecosystem effects– Occupational & consumer health/safety3Progress Under SNAP• In CAA Title VI, Congress directed EPA to create listingclearinghouse to smooth transition to safer alternatives– Process seamless from consumer perspective– regular SNAP list updates promote certainty and stability whileencouraging continued innovation• SNAP is an expanding menu of options that:– Are reviewed for health and environmental protection criteria– Reduce ODS/GHG emissions– Promote responsible practices to reduce emissions• Unique review program supporting global transition• Sector-focused coordination– Long-standing cooperation with U.S. stakeholders– Work supporting national/international standards and codes revisions,removing barriers to adoption of alternatives4SNAP Listings• SNAP lists alternatives as acceptable, unacceptable, oracceptable with conditions for use• Alternatives include:– Alternative chemicals/blends– Alternative technologies (e.g., inert gas generators)• Next generation alternatives– Many climate-friendly options• Currently SNAP has approximately 25 active submissions– EPA has been getting many more submissions in recent years,particularly for foams, air-conditioning, and refrigeration56President’s Climate Action Planand HFCs• Continue International Diplomacy– Lead negotiations under the MontrealProtocol to phase down HFCs• Global phase down could reduce over 90 gigatons of CO2eq by 2050,equal to roughly two years' worth of current global GHG emissions– Work with partners in theClimate and Clean Air Coalition to ReduceShort-Lived Climate Pollutantsto promote climate-friendly alternativesto high-GWP HFCs, address standards, & reduce emissions from HFCuse• Address Through Domestic Actions– Use existing Clean Air Act authority ofSignificant New AlternativesPolicy (SNAP) Programto approve climate-friendly chemicals, prohibitsome uses of most harmful7– Provide federal leadership bypurchasing cleaneralternatives to HFCswhenever feasible and bytransitioning to equipment using safer, moresustainable alternativesWhat the Climate Action PlanMeans for SNAP• Prioritize review of alternatives that are safer for theclimate– In the context of SNAP’s broader criteria– Innovative companies have invested in low-GWP alternatives– Forward-leaning manufacturers of advanced technologies andequipment can provide near-term reductions in emissions• Support, fit within, broader HFC strategy– Listing additional low-GWP options positions U.S. industries tobetter meet potential future phasedown steps proposed under theMontreal Protocol– Responds to federal procurement needs to “purchase cleaneralternatives to HFCs whenever feasible”8EPA Immediate Next Steps9• Share information to facilitate and focus individualstakeholder input• Currently planning two separate rulemakings1) New SNAP Listing Rule• Would propose adding new low GWP refrigerants as acceptablesubject to use conditions• Expected timing: proposed rule this spring2) SNAP Status Change Rule• Would propose changing the status of certain high GWP HFCs• Expected timing: proposed rule in the summerSome Key Principles GuidingOur Thinking10• SNAP rules will continue to consider individual end uses• No across the board GWP cut offs• No prohibition on HFCs as a whole, or in any one sector• New HFCs or HFC blends may be listed if risk not greaterthan other available substitutes• Recognition that timing is acritical dimension and thateach end use has unique considerations• Status change actions will be issued through notice andcomment rulemakingOther Factors StakeholdersHave Raised11• SNAP should continue its end use by end use and chemicalby chemical approach• SNAP should allow existing equipment be to be serviced tominimize stranded capital– EPA should consider the useful lifetimes of equipment• EPA should consider mechanisms to add certainty topotential status change actions– Consider specific time periods for review and action– Consider percent of market already in alternatives– Consider minimum listing periods to enable recoupment of investmentChange of Status Rule12•§612 directs EPA to list unacceptable substitute substanceswhere other substitutes are currently orpotentially availablethat reduce overall risk to human health & environment–Potentially available:adequate health, safety, & environmental dataexist to make determination ofacceptability, and EPA reasonablybelieves is technically feasible, even if not all testing has yet beencompleted and alternative is not yet produced or sold(40 CFR 82.172)• EPA plans to prioritize proposing to change the status of highGWP HFCs where alternatives are available or potentiallyavailable– Proposed decisions being developed within existing SNAP frameworkand rely on established SNAP criteria– Considering end uses where low-GWP alternatives are available orpotentially available– Considering end uses where significant environmental benefits can beachieved, backsliding to high-GWP HFCs avoidedCurrent Thinking on PossibleStatus Changes13• Consumer Aerosols (non-medical & non-technical aerosols)– Change status for HFC-134a, HFC-227ea and HFC-125– Retain HFC-152a• Various foam blowing end uses– Change status by foam type,generally HFC-134a and higher GWPs• Commercial Refrigeration– Vending Machines and Stand-Alone Reach-In Coolers• Change the status for HFC-134a and HFC blends with higherGWPs– Multiplex Supermarket Systems• Change the status for R-507A, R-404A and other HFC blends withhigh GWPs• Retain R-407A , R407F, others• Motor Vehicle Air Conditioning– Change the status for HFC-134aSNAP & Fire Protection• Two fire protection end uses– Streaming (historical use of halon 1211)– Total flooding (historical use of halon 1301): normally occupied andnormally unoccupied spaces• Multiple options available under SNAP for ODS transition– Streaming agent uses: conventional agents (e.g., water, CO2, drychemical), HFCs, continuing use of recycled halon 1211– Total flooding uses:• Existing and legacy systems maintained w/recycled halon 1301• New installations: 1) In-kind: HFCs and lower-GWP options CO2,fluoroketones, inert gases; and 2) Not-in-kind: water mist, aerosols• Significant safety and performance criteria for systems;compliance with standards• Additional submissions under consideration14Work with Standards• National Fire Protection Association (NFPA) Standards• NFPA 10: Portable Extinguishers• NFPA 2001: Clean Agent Fire Extinguishing Systems• NFPA 2010: Fixed Aerosol Fire Extinguishing Systems• International Maritime Organization• Safety of Life at Sea regulations on marine fire protection systems• International Organization for Standardization (ISO)Standards• ISO 14520: Gaseous Media Fire Extinguishing Systems• International Civil Aviation Organization• Others• ASTM• Building codes15U.S. EPA Vintaging Model•What?Tool to track U.S. types of equipment (“enduses”) of ODS and substitutes•Where?Major Sectors: Aerosols, Foams, Solvents, FireProtection, Refrigeration/AC•When?Tracks chemical from when first produced andplaced in equipment or product (“consumption”) throughservicing and use until finally recycled/released toatmosphere (“emissions”)•Who?EPA tool developed with input from industry (e.g.,AHRI AC/HP shipment data)– Other data sources (some CBI)•Why?Required reporting and other analyses ofconsumption and emissions of ODS and substitutes16Vintaging Model – Uses• Reporting for international regimes– Consumption and emissions– Annual Inventory of U.S. Greenhouse Gas Emissions– Biannual National Communications (Climate Action Report)• Analysis of ODS phaseout• Projections of consumption and emissions foralternatives (e.g., HFCs)– What-if scenarios17Foam BlowingFire ProtectionSolventsAerosolsRef/ACODS SubstitutesFlexiblePolyurethaneExtruded PolystyrenePhenolicPU/PIR BoardstockTotal FloodingStreamingMetered DoseInhalers (MDIs)Non-MedicalDustersDeodorantsMetalsElectronicsPrecisionPolyolefinRigid PUCommercial RefrigerationIntegral SkinSlabstock/MouldedBoardstock FoamSheet FoamDomesticRefrigerationSpray FoamOne ComponentSlabstockDomestic Refrigerator/Freezer InsulationContinuous &DiscontinuousPanels18Discussion QuestionsDiscussion Questions: SectorTransitions• The SNAP program continues to receive submissions acrossvarious sectors. SNAP has received a few fire protectionagent submissions and has acted on others in the pastseveral years.Are new substitutes anticipated for fire protectionapplications?• What benefits have you seen from transitions? Decreasedcost? Reduced/avoided emissions? Better performance?• What are barriers to adoption of safer alternatives?– What transition times are needed to adopt alternatives?– What end uses will require continued servicing and for howlong?20Discussion Questions: SectorTransitions (2)• Can your company or trade association share additional datato inform our understanding of the fire sector?– What are current industry equipment leak rates and how havethese changed from existing to new equipment andapplications?– What should we assume regarding emissions associated withfire equipment manufacture or disposal (currently we don’tinclude any emissions in our modeling)?– Can industry share information on the agents in use today?Available industry data on amounts/annual sales by agent?21Discussion