Have you developed contingency plans for the upcoming phaseout of certain gaseous fire suppression agents?
As part of the 2020 American Innovation and Manufacturing (AIM) Act, the EPA mandated a gradual drawdown of certain hydrofluorocarbons (HFCs). This phasedown, which began January 1, 2022, will reduce HFC production by 85 percent by the year 2036.
The phasedown has already affected two common clean agent fire suppressants, HFC-227ea (FM-200) and HFC-125 (ECARO-25), and the production of new FM-200 and ECARO-25 systems has declined sharply since January. While there is no immediate need to rush to replace systems, going forward, installation of new FM-200 and ECARO-25 systems will likely not be cost competitive with other available clean agent fire suppressants, and AEGIS discourages choosing those systems. Pricing for these agents has already increased dramatically, and over time, the availability of FM-200 and ECARO-25 inventory will be reduced substantially, making them even more costly and difficult to obtain.
AEGIS members that use FM-200 and ECARO-25 systems should develop contingency plans for post-discharge replenishment or system replacement, especially if the protection is provided for mission critical facilities or systems. Those could include but are not limited to billing systems, security centers, system operation centers, communications facilities, DCS rooms for power plants, critical electronic and electrical rooms, black start units and combustion turbine enclosures. Facility maintenance and management personnel should be notified that these systems are being phased out and should know who to contact if an FM-200 or ECARO-25 system discharge occurs. Mission critical facilities and systems should not be unprotected because there is no plan in place when a system is discharged or because of agent unavailability, retrofit design and construction requirements, procurement, and installation activity timing.
To develop effective contingency plans, a company should compile a complete list of its FM-200 and ECARO-25 systems. The list should, at a minimum, include:
Where available, design drawings, flow calculations, manuals or other information should be collected and retained, and then used to develop a strategy and a long-term contingency and replacement plan.
In the short term, if a discharge occurs, quickly replenishing the agent for a mission critical facility or system could be accomplished using the agent from a non-mission critical system or a stockpile, or with recycled gas from a reputable fire protection contractor. If there’s no existing contingency plan, one should be developed that includes establishing these relationships or purchasing a stockpile, so that prompt replenishment is possible.
As a system replacement plan is developed, its scope should be assessed by a trusted and qualified special hazard fire protection contractor to determine the level of effort required and the budgetary estimates for replacing each FM-200 and ECARO-25 system. Systems with available design information will be the easiest to assess. In some cases, replacement could be as simple as installing a new and different agent, along with associated storage cylinder(s) (e.g., Novec 1230®), a releasing solenoid listed for that agent, and new discharge nozzles on the existing piping. In other cases, it could require completely replacing the system’s mechanical and electrical portions. A third option could be something in between. Alternatives to clean agent systems should also be considered. In a few cases, the continued use of a clean agent fire suppression system may not be the appropriate option for the hazard, e.g., combustion turbine enclosures.
System replacements that require minimal effort and cost should be completed early, and the FM-200 or ECARO-25 agent and associated components from those systems should be stockpiled for future use. Facility retirements or decommissioning activities for FM-200 or ECARO-25 systems offer the opportunity for stockpiling the agent and associated components. Other more challenging and capital-intensive FM-200 or ECARO-25 systems that need to be replaced (e.g., full system replacement) should be factored into longer-term budgeting plans.
AEGIS members using FM-200 and ECARO-25 systems, or those unclear about whether the HFC phasedown affects their organization, can contact Mark Boone, National Property Manager, by e-mail or phone at 201.508.2881 to ensure appropriate system replacements, designs and acceptance testing.
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