Risk Screen on Substitutes for Halon 1301

Fire Suppression and Explosion Protection Applications

Proposed Substitute: FirePro®

Total Flooding Applications in Normally Unoccupied Spaces

This risk screen does not contain Clean Air Act (CAA) Confidential
Business Information (CBI) and, therefore, may be disclosed to the
public.



Introduction

Ozone-depleting substances (ODS) are being phased out of production in
response to a series of diplomatic and legislative efforts that have
taken place over the past decade, including the Montreal Protocol and
the Clean Air Act Amendments of 1990 (CAAA).  The U.S. Environmental
Protection Agency (EPA), as authorized by Section 612 of the CAAA, is
developing a program to evaluate the human health and environmental
risks posed by alternatives to ODS.  The main purpose of EPA's program,
called the Significant New Alternatives Policy (SNAP) program, is to
identify acceptable and unacceptable substitutes for ODS in specific end
uses.  

EPA’s decision on the acceptability of a substitute is based largely
on the findings of a screening assessment of potential human health and
environmental risks posed by the substitute in specific applications. 
EPA has already screened a large number of substitutes in many end uses
within all of the major ODS-using sectors, including refrigeration and
air conditioning, solvent cleaning, foam blowing, aerosols, fire
suppression, adhesives, coatings and inks, and sterilization.  The
results of these risk screens are presented in a series of Background
Documents that are available in EPA's docket.

The purpose of this report is to supplement EPA’s Background Document
on the fire suppression and explosion protection sector (U.S. EPA 1994).
This risk screen discusses potential human health and environmental
risks posed by FirePro® when used as a replacement for Halon 1301 for
use as a total flooding system in normally unoccupied spaces.

FirePro® is generated in an automated manufacturing process during
which the chemicals, in powder form, are mixed and then supplied to end
users as a solid contained within a fire extinguisher.  In the presence
of heat, the solid converts to an aerosol consisting mainly of potassium
salts.  When the aerosol reacts with the flame, the potassium salts
disassociate, forming potassium free radicals, which then bind to other
flame free radicals to form stable products.  

Table 1a, 1b, and 1c provide the composition of FirePro® prior to and
after activation, respectively.

Table 1a.  Composition of FirePro®, Prior to Activation

Constituent	Chemical Formula	CAS No.	Percent of Total 

(by weight)

Potassium Nitrate	KNO3	7757-79-1

	Potassium Carbonate	K2CO3	584-8-7

	Magnesium	Mg	7439-95-4

	Epoxy Resin Polymer	Polymer	25068-38-6

	Trace elements	See Table 1c	--

	

Table 1b.  Composition of FirePro®, Post Activation

Compound	Chemical Formula	CAS No.	Percent of Total (by weight)

Gas

Carbon Dioxide	CO2	124-38-9

	Nitrogen	N2	7727-37-9

	Water Vapor	H2O	7732-18-5

	Methane	CH4	74-82-8

	Hydrogen	H2	1333-74-0

	Carbon Monoxide	CO	630-08-0

	Particulate 

Potassium Carbonate	K2CO3	584-08-7

	Potassium Nitrate	KNO3	7757-79-1

	Potassium Chloride	KCl	7447-40-7

	Trace elements	See Table 1c	---

	

Table 1c. Composition of Micro and Trace Elements in FirePro

Trace Elements	Concentration (ppm)	Trace Elements	Concentration (ppm)

	FP100	FP8

FP100	FP8

Al	Aluminum

	Mg	Magnesium



As	Arsenica

	Mn	Manganesea



Ba	Bariuma

	Mo	Molybdenuma



Br	Bromine

	Na	Sodium



Ca	Calciuma

	Ni	Nickela



Cd	Cadmiuma

	Rb	Rubidium



Ce	Cerium

	Sb	Antimonya



Cl	Chlorineb

	Sc	Scandiuma



Co	Cobalt

	Se	Selenium



Cr	Chromium

	Sm	Samariuma



Cs	Caesiuma

	Sr	Strontiuma



Cu	Coppera

	Te	Telluriuma



Eu	Europium

	Th	Thoriuma



Fe	Irona

	Ti1	Titaniuma



Hf	Hafniuma

	U	Uraniuma



I	Iodinea

	V	Vanadium



K	Potassium

	W	Wolframa



La	Lanthanum

	Zn	Zinc



aElements were not detected by INAA (Instrumental Neutrons Activation
Analysis) and therefore were present at levels below the listed
detection limits

bindicative 

FirePro® systems are intended for use in normally unoccupied areas of
small, medium, and large volumes (e.g. computers, electrical panels,
switch gear boxes, household equipment, panels, control cabinets, engine
compartments, raised floors, false ceilings, marine engine compartments,
plant rooms, equipment rooms, control rooms, data rooms, and warehouses;
FirePro® SNAP Submission 2004).  The FirePro® system is produced in 13
models, each designed with a different charge size.  Table 2 below shows
the intended end-uses for each model.  Annex A contains further
information on each model.

Table 2: Different models of FirePro® and Corresponding Possible
End-Uses

Modelsa	Possible End-Uses

FP-8 

FP-20 	Computers, electrical panels, switch gear boxes, household
equipment, small enclosures

FP-20B	Same as above with the addition of a power-cut fuse

FP-100 

FP-200	Panels, control cabinets, engine compartments, raised floors,
false ceilings

FP-200M	Marine engine compartments

FP-500	Plant rooms, equipment rooms, raised floors, false ceilings,
medium volume enclosures, etc.

FP-1000Mb	Manually operated for large volumes, mainly engine
compartments, plant rooms

FP-1200H	Buses, trains, trams, metros

FP-1200C	For large volumes total flooding, plant rooms, control rooms,
engine compartments, etc

FP-2000

FP-3000	Total flooding of large volumes, data rooms, control rooms,
plant rooms, engine compartments

FP-6300C	For total flooding of large volumes, warehouses, plant rooms

a The model number indicates the size, in grams, of the charge

b The FP-1000M model is designed to be activated by manually removing a
pin and throwing the device into a fire, similar to a grenade.  This
model does not replace a previous halon use and is therefore not covered
by the SNAP program.  

Occupational exposure (during manufacturing, installation, and
maintenance) and general population analyses were performed to ensure
that use of the proposed blend in the applications listed above does not
pose unacceptable risks to workers or the general public.  Consumer
exposure modeling was not performed because no consumer applications are
proposed for this blend.  

Section 2 of this report summarizes the results of the risk screen for
FirePro®.  Section 3 presents atmospheric modeling and potential
environmental risks; Section 4 discusses occupational exposure during
manufacturing, installation, and maintenance; Section 5 assesses risks
associated with general population exposure; and Section 6 assesses the
emissions of volatile organic compounds.

Summary of Results

FirePro® is recommended for SNAP approval in total flooding in normally
unoccupied spaces.  However, the appropriate protective clothing (e.g.,
goggles, particulate removing respirators, and gloves) should be worn
during the manufacture, clean up, and disposal of this product and
should be worn or on site during the installation and maintenance of the
product. The risk screen indicates that the use of the proposed
substitute in normally unoccupied spaces will be less harmful to the
atmosphere than the continued use of Halon 1301.  Additionally, the risk
to the general population is expected to be negligible.  For
applications of this and all other fire suppression equipment, ICF
recommends that the applicable National Fire Protection Agency (NFPA)
standards be followed (NFPA 2003).

Atmospheric Modeling

This section presents an assessment of the potential risks to
atmospheric integrity posed by the use of FirePro® as a total flooding
system in normally unoccupied areas.   According to the applicant, the
active ingredients for this technology are solids both before and after
use; therefore, the ozone-depleting potential (ODP) and the atmospheric
lifetime (ALT) are both zero (FirePro® SNAP Submission 2004).  The
global warming potentials (GWP) of the gaseous post-activation products
released upon activation of the fire suppressant are listed in Table 3. 


Table 3: Global Warming Potentials of 

Gaseous Post-Activation Products

Gaseous Post-Activation Product	GWP

CH4	23

CO2	1

N2	0

H2O	0

CO	0

H2	0



The GWPs of post-activation compounds in FirePro® are well below the
GWPs of previously SNAP-approved fire-suppression agents (e.g. HFCs and
other high-GWP fluids).  Accordingly, use of FirePro® is not expected
to pose any significant adverse atmospheric impacts.

Occupational Exposure

Exposure During Manufacture

Worker exposure during the manufacturing process is precluded by the use
of appropriate protection equipment.  The main constituents of FirePro®
do not have published occupational exposure limits; however some of the
constituent are known eye, skin, respiratory tract, and gastrointestinal
irritants.  Additionally, bromine and chlorine could be present at
levels above the occupational exposure limits, as shown by Table 4.

  

Table 4: Tested Levels of Trace Elements Present in the FirePro® 100
System 

Compared to OSHA Permitted Exposure Levels (PEL) (HSDB 2004)

Trace Element	Levels Present (ppm)	OSHA PEL TWA (ppm)

Bromine

0.1

Chlorine

1



As described by the submitter, the manufacturing of FirePro® involves
an automated process which requires minimal handling of chemicals by
personnel.  Workers may be exposed to the constituents (in powder form)
while loading them into the mixer, a process which accounts for 15% of
the entire production time.  Therefore, the mixing room should be
equipped with a ventilation system and employees should be required to
wear gloves, chemical suits, particulate respirators with fine dust
rating/capability, and goggles.  Also an eye wash fountain and quick
drench facilities must be close by the production area.  Finally, in the
case of an accidental spill, workers should wear their protective
equipment while wet vacuuming the particulate matter. 

Exposure During Installation, Maintenance, and Cleanup

Installation and Maintenance

μm, the size of respirable dust as designated by OSHA (1997), so the
levels of respirable dust will range from 13.7 to 32.9 g/m3. Therefore,
if accidentally activated in the presence of workers, the level of
respirable particles in the air will exceed OSHA’s limit of 5 mg/m3 of
respirable particles and will therefore be considered a nuisance dust. 
Additionally, bromine and chlorine could be present at levels above the
American Conference of Governmental Industrial Hygienists (ACGIH)
designated Short Term Exposure Limits (STEL), as shown by Table 5 below.
   

Table 5: Levels of Trace Elements Present when 72 g/m3 are Released from
a 

FirePro® System as Compared to their ACGIH STEL (HSDB 2004)

	Levels Present (ppm)	Amount (mg/m3) emitted when 72g/m3 releaseda	TLV,
STEL mg/m3

Bromine

1.9	1.3

Chlorine

30.0	2.9

a To account for the worst case scenario, the largest design
concentration of all the models, 72 g/m3, was used

FirePro® is automatically activated by either a thermo-sensitive cord
or an electrical signal from a conventional detection and activation
system in normally unoccupied spaces.  Some FirePro® systems can also
be manually activated by an electrical switch or pulley system (marine
use) outside of the room in which the system is located.  A pre-alarm
and alarm are both set to occur when a fire is detected and before the
FirePro® system is triggered.  A time delay, set in accordance with
federal, state, and/or local standards, allows for the evacuation of any
maintenance personnel potentially located in the area.  In addition to
the time delay, each FirePro® system includes a lock-off device outside
the room which permits the system to be locked to manual activation mode
(only able to be activated by following procedure stated by the relevant
reference standards or federal, state, or local regulations) whenever
maintenance personnel are present in the area.  Assuming the lock-off
device is always activated during installation and maintenance, the risk
of accidental activation in the presence of personnel should be minimal.
 

Although FirePro is only approved for use in unoccupied areas, the
possibility remains that installation and maintenance personnel could be
present when a system is activated.  ICF recommends that all personnel
wear goggles, gloves, and a self-contained breathing apparatus (SCBA)
while performing installations and/or maintenance activities.  Because
the respirable dust level is exceeded and the STEL of chlorine and
bromine could be exceeded, FirePro should not be used in occupied
spaces.  

Clean-Up

When the FirePro® system is activated, the aerosol particles that are
produced reach a homogeneous distribution within 5 to 30 seconds,
depending on the model of the FirePro® system.  After approximately 250
seconds, the particles have coagulated and their average size is 1.2
μm.  The aerosol particles that are produced when the proposed
substitute is discharged tend to settle at different rates, depending on
their size, as shown in Table 6.

Table 6: Particle Settling Rate (m/s) Depending On Particle Size (μ) 

Particle Size (μm)	Particle Settling Rate (m/s)

0.1	4.5 x 10-6

1.0	2.5 x 10-4

5.0	5.9 x 10-3



Table 7 presents the settling time for three average room heights.  

Table 7: Setting Time Depending on Room Height

Room Height	Settling Time (hours)

8 ft (2.4 m)	2.7

10 ft (3.0 m)	3.4

12 ft (3.7 m)	4.1

Note: These calculations assume all particles start at the ceiling,
settle at the same rate, and that no air currents present in the area.  
 

Workers should not enter the space following discharge until all
particles have settled and the gases released by the system have
dissipated.  The submitter should provide guidance upon installation
regarding the appropriate time frame after which workers may enter the
activation site for disposal to allow the maximum settling of all the
particulates. Clean-up operations are likely to result in the
re-circulation of potentially toxic nuisance dust particles.  Therefore,
workers entering the protected volume to clean-up after activation are
required to wear chemical suits, gloves, goggles, and a particulate
removing respirator with a fine dust rating capability.  The contents
removed from the protective volume should be disposed of according to
approved safety procedures.  Equipment should be thoroughly
decontaminated after use.  When recommended safety precautions are
followed, no significant adverse health effects should result. 

General Population Exposure 

This section screens potential risks to the general population from
exposure to ambient air releases of FirePro® blend constituents or the
post-activation products.  Factory releases (occurring during
manufacture) and on-site releases (those occurring at the end-use) are
examined in this section. By following existing regulations, ICF
believes that factory or on-site releases are not likely to pose a
significant threat to ambient air, surface water, or solid waste. 
Consequently, use of FirePro® is not expected to pose significant risk
to the general population.   

Ambient Air

All manufacturing occurs in a hermetic facility with a filtered
ventilation system so minimal release to the ambient air is expected. 
All facility emissions are controlled through air sampling and
chromatograph analysis.  On-site releases result in the discharge of
gases that do not pose a threat to the general public.  The
concentration of CO2 and CH4 released into the atmosphere through the
accidental release of a fire extinguishing system is insignificant
compared to the concentration of CO2 and CH4 emitted into the ambient
air by fossil fuel combustion, iron and steel production, and various
other types of anthropogenic activity.  Therefore, air emissions
associated with the manufacture and use of FirePro® are not of concern
to the health of the general population.   

 Surface Water

If all the solid waste settles onto the floor of the unoccupied space
and is removed from the site according to federal, state, and local
requirements, the FirePro® components are not likely to settle into
nearby streams or ponds. 

Solid Waste

At the end of their lifetime, all units are returned to the manufacturer
and the chemical compound is recycled.  If all spilled and settled
material in the manufacturing facility and all on-site releases are
cleaned up and disposed of according to federal, state, and local
requirements, no release to the environment is expected.  

 ADVANCE \d4 

Volatile Organic Compound Analysis\

The FirePro® blend constituents and the reaction products generated
from activation are not considered VOCs for purposes of local air
quality.    

References

CDC. 1997.  Respiratory Protection Program Manual.  Office of Health and
Safety, Centers for Disease Control and Prevention.  January 1997. 

FirePro® SNAP Submission. 2004. Significant New Alternatives Policy
Program Submission to the United States Environmental Protection Agency,
April 2004. 

HSDB.  2004.  Hazardous Substances Data Bank, TOXNET.  National Library
of Medicine.  Specialized Information Services.   <  HYPERLINK
"http://toxnet.nlm.nih.gov"  http://toxnet.nlm.nih.gov  TOXNET> 

NFPA 2003.  Draft NFPA 2010 Standard.  Standard for Fixed Aerosol Fire
Extinguishing Systems.  National Fire Protetion Agency.  July 21, 2003. 
<  HYPERLINK "http://www.nfpa.org/Codes/Drafts.asp" 
http://www.nfpa.org/Codes/ Drafts.asp >.  

OSHA. 1997.  Regulations (Standards - 29 CFR).  TABLE Z-3 Mineral Dusts
- 1910.1000.  Occupational Safety and Health Standards.  Toxic and
Hazardous Substances. 
<http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=
STANDARDS&p_id=9994>

U.S. EPA.  1994. Risk Screen on the Use of Substitutes for Class I
Ozone-Depleting Substances: Fire Suppression and Explosion Protection
(Halon Substitutes).  Stratospheric Protection Division.  March 1994. 

Annex A: Complete Description of FirePro® Models

Model	Contents (grams)	Ignition Mechanism	Outflow Time (sec)	# of
Outflow Openings	Outflow Length (m)	Dimension  (length x diameter unless
noted)	Design Conc. (g/m3)

FP-8	8	thermocord	3-6	1	0.5	14mm x 52 mm	30

FP-20,  FP-20B	20	thermocord	3-6	2	0.3	128mm x 28mm	60

FP-100	100	thermocord & electric	5-10	1	1.0	125mm x 88mm	40

FP-200	200	thermocord & electric	10-15	1	2.0	145 mm x 88mm	40

FP-200M	200	pully system	10-15	1	2.0	139 mm x 88mm	40

FP-500	500	thermocord & electric	10-15	1	2.5	220mm x 88mm	40

FP-1000M	1000	removal of security pin	20-25	2	3.0	200mm x 98 mm	30

FP-1200H, FP-1200C	1200	thermocord & electric	8-10	1	4.0	670mm x 85mm	40

FP-3000	3000	thermocord & electric	20-25	1	3.0	300mm x 340mm x 150mm
(box)	60

FP-6300C	6300	thermocord & electric	20-25	1	8.0	255mm x 310mm x 198mm
(box)	60



Annex B:  Equation Used to Determine Model of FirePro® Needed

The following equation, provided by the submitter, is used to determine
the correct model of FirePro® needed to protect a space.  

M = V x K0 x K1 x K2 x K3 x K4 x q

    M = Net weight of extinguishing material

    V = Gross volume protected (m3)

   K0 = Class of fire: A = 1, B = 0.5, C = 0.75, E = 1.3

   K1 = Uniformity of dispersion coefficient

   K2 = Loss of aerosol coefficient

   K3 = Plant safety coefficient

   K4 = Time of volume inert-condition

    q  = Extinguishing unit’s efficiency coefficient



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ving respirator filters out dust, fibers, fumes and mists by filtering,
absorbing, adsorbing, or causing a chemical reaction with the
contaminants as they pass through the respirator canister or cartridge. 


 NFPA sets a safety factor of 1.3 for a Class A surface fire hazard and
Class B fuel hazard (2003).  In addition, the CEN (European Committee
for Standardization) is developing new standards with varying safety
factors by class of fire.

 Assuming the majority of the particles will settle at an approximate
rate of 2.5 x 10-4 m/s, the time it will take for the particulate
post-activation products to settle can be calculated by dividing the
room height in meters by the particle settling rate in meters per
second.  

 If workers must enter the space before the discharged particles have
settled and the gases released have dissipated, then workers are
required to wear chemical suits, gloves, goggles, and SCBA.  

September 6, 2006

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