Fire Protection Sector SNA

Stakeholder Workshop

March 5, 2014

U.S. Environmental Protection Agenc
Introduction

• Why fire protection, why now?

– EPA has been conducting a series of SNAP sector work

• March: Aerosols• April: Foams• November: Household Appliances• December: Stationary A/C, MVAC, Commercial and 

Refrigeration

• Scope of the Meeting

– Significant New Alternatives Policy (SNAP) Program– Climate Action Plan – Vintaging Model

• Discussion
Identifying Safer Alternatives:

SNAP Program• Evaluates substitutes that reduce overall risk t

health & 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/safety
Progress Under SNAP

• In CAA Title VI, Congress directed EPA to create 

clearinghouse to smooth transition to safer alterna

– Process seamless from consumer perspective– regular SNAP list updates promote certainty and stability 

encouraging continued innovation

• SNAP is an expanding menu of options that:

– Are reviewed for health and environmental protection crit– Reduce ODS/GHG emissions– Promote responsible practices to reduce emissions

• Unique review program supporting global transitio• Sector-focused coordination

– Long-standing cooperation with U.S. stakeholders– Work supporting national/international standards and cod

removing barriers to adoption of alternatives
SNAP Listings

• SNAP lists alternatives as acceptable, unacceptab

acceptable 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 subm

– EPA has been getting many more submissions in recent 

particularly for foams, air-conditioning, and refrigeration

President’s Climate Action Plan

and HFCs• Continue International Diplomacy

– Lead negotiations under the Montreal Protocol to phase do

• Global phase down could reduce over 90 gigatons of CO

2eq 

equal to roughly two years' worth of current global GHG emis

– Work with partners in the Climate and Clean Air Coalitio

Short-Lived Climate Pollutants to promote climate-friendto high-GWP HFCs, address standards, & reduce emissiouse 

• Address Through Domestic Actions

– Use existing Clean Air Act authority of Significant New A

Policy (SNAP) Program to approve climate-friendly chemsome uses of most harmful

– Provide federal leadership by purchasing cleaner 

alternatives to HFCs whenever feasible and by transitioning to equipment using safer, more sustainable alternatives
What the Climate Action Plan 

Means for SNAP

• Prioritize review of alternatives that are safer for th

climate

– In the context of SNAP’s broader criteria– Innovative companies have invested in low-GWP alterna– Forward-leaning manufacturers of advanced technologie

equipment can provide near-term reductions in emission

• Support, fit within, broader HFC strategy

– Listing additional low-GWP options positions U.S. indust

better meet potential future phasedown steps proposed Montreal Protocol

– Responds to federal procurement needs to “purchase cle

alternatives to HFCs whenever feasible”
EPA Immediate Next Steps

• Share information to facilitate and focus individual 

stakeholder input

• Currently planning two separate rulemakings

1) New SNAP Listing Rule

• Would propose adding new low GWP refrigerants as 

subject to use conditions

• Expected timing: proposed rule this spring

2) SNAP Status Change Rule

• Would propose changing the status of certain high GW• Expected timing: proposed rule in the summer
Some Key Principles Guiding

Our Thinking

• SNAP rules will continue to consider individual en• No across the board GWP cut offs • No prohibition on HFCs as a whole, or in any one • New HFCs or HFC blends may be listed if risk not 

than other available substitutes 

• Recognition that timing is a critical dimension and 

each end use has unique considerations 

• Status change actions will be issued through notic

comment rulemaking
Other Factors Stakeholders

Have Raised

• SNAP should continue its end use by end use and 

by chemical approach

• SNAP should allow existing equipment be to be se

minimize stranded capital

– EPA should consider the useful lifetimes of equipment

• EPA should consider mechanisms to add certainty 

potential 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 
Change of Status Rule

•

§612 directs EPA to list unacceptable substitute suwhere other substitutes are currently or potentially athat reduce overall risk to human health & environm

– Potentially available: adequate health, safety, & environm

exist to make determination of acceptability, and EPA reasbelieves is technically feasible, even if not all testing has ycompleted and alternative is not yet produced or sold (40 

• EPA plans to prioritize proposing to change the stat

GWP HFCs where alternatives are available or poteavailable

– Proposed decisions being developed within existing SNAP 

and rely on established SNAP criteria 

– Considering end uses where low-GWP alternatives are av

potentially available 

– Considering end uses where significant environmental ben

achieved, backsliding to high-GWP HFCs avoided
Current Thinking on Possible 

Status Changes

• Consumer Aerosols (non-medical & non-technica

– 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 h

• Commercial Refrigeration

– Vending Machines and Stand-Alone Reach-In Coolers

• Change the status for HFC-134a and HFC blends wi

GWPs

– Multiplex Supermarket Systems

• Change the status for R-507A, R-404A and other HF

high GWPs

• Retain R-407A , R407F, others

• Motor Vehicle Air Conditioning 

– Change the status for HFC-134a 
SNAP & Fire Protection

• Two fire protection end uses

– Streaming (historical use of halon 1211)– Total flooding (historical use of halon 1301): normally oc

normally unoccupied spaces

• Multiple options available under SNAP for ODS tr

– Streaming agent uses: conventional agents (e.g., water, 

chemical), HFCs, continuing use of recycled halon 1211

– Total flooding uses: 

• Existing and legacy systems maintained w/recycled • New installations: 1) In-kind: HFCs and lower-GWP o

fluoroketones, inert gases; and 2) Not-in-kind: water 

• Significant safety and performance criteria for sys

compliance with standards

• Additional submissions under consideration
Work with Standards

• National Fire Protection Association (NFPA) Stand

• 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 

• International Organization for Standardization (ISO

Standards

• ISO 14520: Gaseous Media Fire Extinguishing Systems

• International Civil Aviation Organization• Others

• ASTM• Building codes
U.S. EPA Vintaging Model

• What? Tool to track U.S. types of equipment (“en

uses”) of ODS and substitutes

• Where? Major Sectors: Aerosols, Foams, Solven

Protection, Refrigeration/AC

• When? Tracks chemical from when first produced 

placed in equipment or product (“consumption”) thservicing and use until finally recycled/released to atmosphere (“emissions”)

• Who? EPA tool developed with input from industr

AHRI AC/HP shipment data)

– Other data sources (some CBI)

• Why? Required reporting and other analyses of 

consumption and emissions of ODS and substitute
Vintaging Model – Uses

• Reporting for international regimes

– Consumption and emissions– Annual Inventory of U.S. Greenhouse Gas Emissions– Biannual National Communications (Climate Action Rep

• Analysis of ODS phaseout• Projections of consumption and emissions for 

alternatives (e.g., HFCs)

– What-if scenarios
Foam Blowing Fire Protection Solvents Aeroso

ODS Substitutes

Flexible

Polyurethane

Extruded Polystyrene

Phenolic

PU/PIR Boardstock

Total Flooding

Streaming

Meter

Inhale

Non-M

Dust

Deod

Metals

Electronics

Precision

Polyolefin

Rigid PU

Commercial Refrigeration

Integral Skin

Slabstock/Moulded

Sheet Foam Boardstock Foam

Spray Foam

One Component

Slabstock Domestic Refrigerator/

Freezer Insulation

Continuous &

Discontinuous

Panels
Discussion Questions
Discussion Questions: Sector 

Transitions

• The SNAP program continues to receive submissi

various sectors. SNAP has received a few fire protagent submissions and has acted on others in the several years. Are new substitutes anticipated for fire 

applications?

• What benefits have you seen from transitions? De

cost? Reduced/avoided emissions? Better perform

• What are barriers to adoption of safer alternatives?

– What transition times are needed to adopt alternativ– What end uses will require continued servicing and 

long?
Discussion Questions: Sector 

Transitions (2)

• Can your company or trade association share add

to inform our understanding of the fire sector? 

– What are current industry equipment leak rates and 

these changed from existing to new equipment and applications?

– What should we assume regarding emissions assoc

fire equipment manufacture or disposal (currently winclude any emissions in our modeling)?

– Can industry share information on the agents in use 

Available industry data on amounts/annual sales by 
Discussion