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3M Confidential. 1 6 March 2014 . All Rights Reserved. © 3M


A long road to sustainable fire protection 25 February 2014

Fire protection product development in today’s highly regulated market



Regulatory Risk

New York City Chapter, SFPE Paul E Rivers PE

3M Company St Paul MN

February 25, 2014

Fire protection product development in a highly regulated industry



Agenda § Background and History – origin of clean agent development § Halon replacement – not just in-kind anymore § Regulatory activities increasing risk § SFPE International activity to address regulatory pressures § Case history – example of product development because of regulatory risk § The 3M path to developing a viable long term solution § Q&A



The Montreal Protocol

§ Ratified in 1987 §  In 2014, celebrated its 27th Anniversary § Led to ban on CFCs and halons



Global Ozone Depletion

§ Decreasing ozone linked mainly to CFCs

§ Variable from year to year § Ozone depletion a cooling

influence on climate. § Recovery in 21st century

IPCC TEAP Special Report, 2005

2014



Post Montreal Protocol 1985 – Vienna Convention (Conference of Plenipotentiaries) 1987 – Montreal Protocol on Substances That Deplete Ozone Layer 1988 – NFPRF– Halon 1301 Discharge Testing

– Elimination of Discharge Testing (NFPA 12A) 1989 – Halon Technical Options Committee 1991 – NFPA TC on clean agents organized 1992 – Halon production in non-Article 5 countries ceased 1993 – Initial SNAP Approvals 1994 – 1st Ed NFPA 2001 Standard on Clean Agent Fire Extinguishing Systems (going into 7th edition) 1990s – 1st and 2nd generation alternatives introduced 1996 – Australia – first decommissioning, followed by EU 2000 – ISO-14520, Gaseous Media Fire Extinguishing Systems (going into 3rd edition) 2000s – Development of alternative non-standard and non-clean alternatives 2014 – increasing pressure on GHGs used in fire protection



US EPA SNAP Program

§ Significant New Alternatives Policy § Created as part of the Clean Air Act to review and qualify replacements

developed as alternatives for ozone depleting substances – ODSs § Officially regulated ODS replacement use § Regulates all solutions considered a halon replacement § Morphed into climate change issues § SNAP program continues to this day



Evolution of the halon alternative market…

halon

Not in Kind

Solutions Recycled

Inert Gas

PFCs

HFCs

automatic sprinklers, water-mist,CO2, dry chemical, aerosols, etc... oxyreduct, fire prevention, no fire protection

F-ketone



§  A sustainable ‘drop-in’ has been not been found –  over 2 decades of research

§  new molecules still being developed §  new methods of application

–  numerous working groups, manufacturers –  sustainable technology difficult to achieve

Choosing a halon alternative proving difficult:

Halon Alternative Solutions to Date

§  Need proper balance of three key considerations –  extinguishing performance –  acceptable toxicity profile –  sustainable environmental profile



Montreal Protocol’s effect on Fire Protection § Direct – Eliminated Halon Production §  Indirect – Reduced Halon Use §  Introduction of New Technologies

― HCFCs, PFCs, HFC, IG, FK total flooding gases ― Water Mist (Sprinkler and gas alternatives) ― Aerosol/Gas Generators

§ EPA in Fire Protection Business ― Significant New Alternatives Policy (SNAP) ―  Took place of OSHA – Safety issues ― Regulating ANY halon replacement technology

§ Environmental concerns increasing as significant decision driver



Effect of Ozone Depletion?



Halon 1301 (GWP=6900)

HFCs (GWP=3000 to 12000)

49% reduction

Sustainable technologies (GWP= 0 to 1) FK, IGs, water mist, aerosols, etc.

>99.9% reduction

PFCs (GWP=9000)

61% reduction

Reduction in Greenhouse Gas Emissions



17 April 09 – EPA Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act §  Current and projected concentrations of the mix of six key greenhouse [gases] in the

atmosphere [that] threaten the public health and welfare of current and future generations. This is referred to as the endangerment finding. ―  carbon dioxide (CO2) ―  methane (CH4) ―  nitrous oxide (N2O) ―  hydrofluorocarbons (HFCs) ―  perfluorocarbons (PFCs) ―  sulfur hexafluoride (SF6)

§  Combined emissions of CO2, CH4, N2O, and HFCs from new motor vehicles/engines [that] contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.

http://epa.gov/climatechange/endangerment.html

[emphasis added]



Published by Guus J. M. Velders, David W. Fahey, John S. Daniel, Mack McFarland, Stephen O. Andersen in the Proceedings of the National Academy of Sciences, 106, June 2009

HFC growth projected to = climate forcing of ODSs and 9-19% of the Kyoto basket by 2050

HFC-227ea Atm. Concentrations

Laube et. al. 2010

Continued Growth in Emissions is the Concern



0

2000

4000

6000

8000

10000

12000

14000

HFC-23

HFC-227ea

HFC-236fa

HFC-125

HFC-32

HFC-134a

HFC-152a

HFC-245fa

HFC-365mfc

HFC-43-10mee

GWP

Fire Protection

Refrgerant

Foam Blowing

Solvent

HFCs by Industry Sector

Fire suppression has readily available substitutes



Countries Signing the 2010 Declaration Afghanistan, Antigua and Barbuda, Armenia, Austria, Australia, Bahamas, Bangladesh, Belgium,

Belize, Benin, Bosnia and Herzegovinia, Bulgaria, Burkina Faso, Cambodia, Cameroon, Canada, Columbia, Comoros, Congo, Cook Islands, Costa Rica, Cyprus, Czech Republic, Democratic Republic of the Congo, Denmark, Dominican Republic, Egypt, Estonia, European Union, Federated States of Micronesia, Finland, France, Gabon, Gambia, Georgia, Germany, Ghana, Greece, Haiti, Hungary, Indonesia, Iraq, Ireland, Italy, Japan, Kazakhstan, Kyrgyzstan, Latvia, Liechtenstein, Lithuania, Luxembourg, Madagascar, Mali, Mauritius, Macedonia, Malta, Mexico, Micronesia, Montenegro, Mozambique, Myanmar, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Palau, Philippines, Poland, Portugal, Republic of Moldova, Romania, Saint Lucia, Sao Tome and Principe, Senegal, Serbia, Slovakia, Slovenia, Spain, Somalia, Sri Lanka, Sweden, Switzerland, Timor-Leste, Togo, Tuvalu, Uganda, United Kingdom, United States of America, Vietnam

22nd Meeting of the Parties-Montreal Protocol – November 2010 “Declare our intent to pursue further action under the Montreal Protocol aimed at transitioning the world to environmentally sound alternatives to HCFCs and CFCs.”



Proposals to Amend the Montreal Protocol to include a Phase-down in HFC Production

§  Proposals advanced in 2009, 2010, 2011, and 2012. ―  Takes HFCs out of the Kyoto Protocol ― Montreal Protocol has proven record of success ―  Technical Committees already exist for ODS and HFC market sectors ―  http://conf.montreal-protocol.org/meeting/31st/pre-session-documents/PreSession

%20Documents/OEWG-31-5E.pdf §  To date, China, India, and Brazil are blocking advancement of the proposal. §  June, 2013 - China agrees to take action



North American Submission to the Montreal Protocol to Phase Down Production of HFCs



DuPont Advocates for HFC Phase down “Given the success of the Montreal Protocol, DuPont is now engaged in advocacy work to add

hydrofluorocarbons (HFCs) to the Montreal Protocol. HFCs are non-ozone-depleting products that have served a critical role in replacing CFCs, but also are global warming gases. We believe that by developing a cap and reduction plan for HFCs, similar to what was done under the Montreal Protocol for CFCs and other ozone depleting materials, significant progress can be made in reducing the climate change impacts of HFCs and transitioning society to even better alternatives.”

.

http://www2.dupont.com/Media_Center/en_US/position_ statements/montreal_protocol.html?src=position_statements_index



EU Action on Climate Change - 2012 § EU 2050 Climate Target - reduce GHG emissions by 80-95 % - “2006 F-Gas Reg is

inadequate” § EU Parliament urges F-gas revision and requests Commission to propose rapid

HFC phase-down ―  “Stimulate innovation/improve market opportunities for low GWP alternatives”

§ Currently formulating new F-gas reg.- 2013 ― HFC phase down starting in 2015 includes FM-200 and FE-25

•  Prohibition on the use of FE-13

―  Targeting finalization of regulation in 2014

.

2014 Cal Poly



Phase-down is based on CO2 Equivalents §  Producer allocation based on historical production §  Phase-down is based on CO2e so it does not favor HFCs sold into fire suppression. §  Choices include:

―  1 ton of HFC-227ea ―  3 tons of HFC-245fa ―  5 tons of HFC-32 ―  20 tons of HFC-152a

§  HFC producers hope to create room under the cap by introducing HFOs. §  If HFC demand remains high, market allocations are likely

―  HFO pricing will be at a premium compared to HFCs ―  Likely need to increase price on HFC to drive share to HFOs



2012 Policy and Regulatory Impacts on HFCs § Australian HFC Tax – July 2012 - ~$30/lb § Spanish HFC Tax passed in 2013 § U.S. – SNAP Submissions to delist HFCs in all sectors where viable alternatives

exist § Global Climate and Clean Air Coalition – U.S. Dept. of State

―  Fast action to reduce short lived climate pollutants, including hydrofluorocarbons (HFCs) ― Accelerating alternatives to HFCs



U.S. Governmental Initiatives US Presidential Executive Order 13514 December 2009

§ Department of Defense Strategic Sustainability Performance Plan -2010 “DoD will initiate an assessment of mission risks associated with the continued use of hydrofluorocarbons (HFC)—a class of potent GHGs used by the Department for air conditioning, refrigeration, fire suppression and explosion protection—and propose proactive risk management measures.”

Required federal agencies to establish GHG emissions reduction targets



President’s Climate Action Plan – June 25, 2013 § US government will “purchase cleaner alternatives to HFCs whenever feasible

and transition over time to equipment that uses safer and more sustainable alternatives.”

§ EPA will use its authority under the SNAP program to “encourage private sector investment in low-emissions technology by identifying and approving climate-friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives.” ― EPA has initiated delisting of HFCs in some sectors

§ Leading Efforts to Address Climate Change through International Negotiations

HFCs in new construction are a liability



So, what does an FPE do…



What do we need to do…

…to minimize risk in this highly regulated environment? …protect the environment? …assure the FPE can perform unencumbered the job of protecting people and

property?



SFPE Position Statement: “Fire Protection and the Environment”



1.0 Executive Summary To assure the fire protection engineer can perform unencumbered the job of

protecting people and property, Society of Fire Protection Engineers (SFPE) recommends fire protection engineers:

§ Be mindful of existing regulatory limitations that can affect the implementation of specified solutions.

§  Consider the fire safety effect of a solution specified addressing environmental or regulatory requirements.

§  Take into account any environmental and regulatory impact that a solution may have on the end user

§ Understand the importance of and advocate for the testing of fire systems.

SFPE International Draft Position Statement



Key areas of risk to fire protection in the USA

§ High GWP greenhouse gas emissions reduction/restriction ― US Congress ― US EPA action via Executive Order ― California ARB adoption of GHG legislation ― RGGIs



Key areas of risk to fire protection

§ Power/energy intensive system management ― Room, stairway pressurizaton ― Air handling, smoke control ― Oxygen reduction suppression technology ― Other



Water-based system issues § Adequacy for fire protection § Testing

― Recycling for AS water flow switches ― Pumps, both electric and diesel(emissions) ― Back-up power supply ― Reduced testing frequency

§ Discharge ― Storm water ― Ground discharge ― PFOA/PFOS based AFFF




§ Design phase consideration of environmental effects ―  LEED requirements ― Materials used

§  Increased greenhouse gas regulation ― State/Federal ― European F-Gas/EN2037 revisit ― Australian GHG tax

§ Other??




Examples of regulatory risk and product development efforts to reduce that risk



Example of regulatory risk



Example of dealing with regulatory risk



Example of dealing with regulatory risk

“An Air Force R&D Success Story”



3M product development §  1950s to today, PFCs for industrial applications

―  Fluorochemicals used in many high-performance applications •  Heat transfer – Cray Supercomputer •  Precision cleaning

•  Vapor deposition of coatings on disc drives •  Chamber cleaning, etching for computer chip manufacturing

―  Related technology – 3M™ Light Water™ AFFF developed in the 1960s ―  1990-98 – PFCs for use in fire protection

•  Development of PFCs as clean agents •  CEA-308, CEA-410, CEA-614

•  Total flooding and streaming

§  All the right things for effective application ―  Safe in use ―  Performance ―  non-ozone depleting ―  but...



§  Targeted due to global warming potential, atmospheric lifetime ―  USEPA SNAP narrowed use restriction “…where no other alternative is technically feasible from a

performance or safety standpoint” ―  Pressure for phase-out, both within 3M and outside

§  Invented two new classes of compounds to address future regulatory action ―  Hydrofluoroethers HFEs (1996) ―  Fluoroketones FKs (1999) ―  Why? To reduce risk.

§  Light Water and Scotchgard – PFOS ―  Exited $300MM business 16 May 2000. ―  Why? Business risk ―  Invented/developed new products to replace

§  Positive SNAP rulings for HFEs and FKs

3M product development



Key physical properties comparison

Property@ 77°F (25°C) Unit Halon

1211 C6F14Novec1230

Molecular Weight 150.7 338.0 316.04Molecular Formula CF2BrCl C6F14 C6F12O

Boiling Point °F(°C)

26(-4)

132.8(56)

120.2(49)

Liquid Density lbs/ft3(kg/m3)

112.3(1799)

104.9(1680)

99.9(1600)

Specific Heat, vapor Btu/lb°F (kJ/kg°C)

0.185(0.774)

0.267(1.12)

0.213(0.891)

Vapor Pressure psi(kPa)

37.5(258.6)

4.5(30.9)

4.73(32.6)

Heat of Vaporization Btu/lb(kJ/kg)

57(133)

39.1(90.8)

40.8(94.9)



Regulatory/Environmental considerations – reduce risk

EPA SNAP Final Ruling* EPA has reviewed the potential environmental impacts of this substitute and has concluded that, by comparison to halon 1301 and other acceptable substitutes, C6-perfluoroketone significantly reduces overall risk to the environment. With no ozone-depletion potential, a global warming potential value of less than 1, and an atmospheric lifetime of less than three days, C6-perfluoroketone provides an improvement over use of halon 1301, hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) in fire protection. We find that C6-perfluoroketone is acceptable because it reduces overall risk to public health and the environment in the end use listed.

*Federal Register / Vol. 67, No. 245 / Friday, December 20, 2002 / Rules and Regulations, pp77931-32 [emphasis added]



§  Addresses regulatory as well as fire protection concerns §  Safe for people and that protected §  Economical, yet applied properly §  Fast, effective extinguishment §  Allows the fire protection engineer to do his job

Specifying technology that reduces risk



Regulatory Risk

New Jersey Chapter, SFPE Green Conference Paul E Rivers PE

3M Company [email protected]

+1-651-733-0029

Fire protection product development in a highly regulated industry

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