Bart Goeman looks at the potential impact of new European legislation on the oil and gas industry.
Specifiers and managers of fire suppression systems in the oil and gas sector have many issues to consider when choosing the right system to protect their facilities.
Factors include maintenance and refilling in offshore locations, health and safety in potentially hazardous environments, running costs and, of course, just how fast and effective a fire suppression system deals with a fire outbreak.
Another requirement is the need to adhere to industry regulations and compliance. Currently the oil and gas industry is addressing Commission Regulation (EU) No 744/2010, which calls for all new fire suppression systems from 31st December 2010 to be halon-free, with the phase out of all halon systems completed by 2020.
Now there is another factor to consider, recent changes to the F-gas Regulation - which covers the use of hydrofluorocarbons (HFCs), including those commonly used in fire suppression systems that will result in tighter restrictions on the production and import of HFCs.
Before we examine the practical implications for oil and gas engineers responsible for or involved in specifying or managing fire suppression systems, let’s look at this new piece of legislation in a bit more detail.
Legislation in detail
On 12th March 2014, the European Parliament voted to support a European Commission proposal to cut the use of hydrofluorocarbons (HFCs) 79 per cent below average 2009-2012 CO2 levels by 2030. This has since become law, the provisions of which will come into effect in January 2015.
This is part of the ongoing F-gas Regulation (officially known as the Regulation (EU) No 517/2014 of the European Parliament, repealing Regulation (EC) No 842/2006). HFCs are used in a wide variety of applications, such as refrigeration and air conditioning.
However, there are also clear implications for the HFCs used in fire suppression systems, since these have some of the highest global warming potentials (GWPs) when compared to HFCs used in other situations.
GWPs are calculations of how powerful the environmental impact a greenhouse gas is over a specific timescale, when compared to carbon dioxide. The GWP for HFC-227ea which is commonly used in fire suppression systems is 3350, so it is 3350 times more potent than CO2 in its potential climate impact. To provide a comparison with two HFCs used in refrigeration: HFC-134a has a GWP of 1300 and HFC-32 has a GWP of 677.
Until a fire suppression system is discharged, the HFCs used in fire suppression arguably have low emissions. However, the F-gas Regulation covers reduction of emissions across usage, production and importation of HFCs.
Producers or providers of HFCs will be allocated a production or import quota, based on CO2 equivalent in relation to their GWPs. This is where the challenge lies: the relatively high GWPs of HFCs used in fire suppression would mean that, for instance, an HFC producer would consume the same percentage of a quota by making either one tonne of HFC-227ea, three tonnes of HFC-245fa, or five tonnes of HFC-32 (all of which are covered by the new legislation).
Nor is it just new systems that are affected: recharging existing systems are also covered by the phase-down schedule. Since fire suppression systems can be in situ for twenty years or more, then users of or companies supporting systems that have already been installed also have to be consider the F-gas Regulation.
Not just a European issue
The F-gas Regulation is the latest in a series of worldwide initiatives to address the use of HFCs. For instance, in Malaysia, the Green Building Index (GBI) has initiated significant measures to heighten the awareness of the environmental impacts of the options available for clean agent fire suppression and, in particular, the climate impacts of HFC-227ea and HFC-125. In Spain, the Council of Ministries recently approved a tax on fluorinated greenhouse gases (Law 16/2013 from October 2013) for fluorinated gases (F-gases with GWPs above 150.
In the USA, the Environmental Protection Agency (EPA) has previously issued its proposal to change the status of hydrofluorocarbons (HFCs) in certain applications. It is estimated to reduce harmful greenhouse gas emissions by as much as 42 million metric tonnes of carbon dioxide equivalent by 2020.
According to the proposal, this is equal to the carbon dioxide emissions from more than five million homes’ annual electricity use. The Climate Action Plan website claims that without significant action, HFC emissions in the US are expected to double by 2020 and nearly triple by 2030. The US has also made agreements with both China and India to phase down the use of HFCs.
Fortunately for the oil and gas industry, there are some viable and well-established halon alternatives that are not affected by the F-gas Regulation, including water and inert gas based systems and some engineered extinguishing agents.
Water-based systems have the benefit of zero GWP and naturally low toxicity, although there is the issue of safe disposal of contaminated water in the event of a system discharge to consider. These systems are suitable for many situations, but not those where sensitive, delicate or expensive equipment is involved such as computers because of damage that water can cause to electronics. Plus, water-based systems cascade downwards (two-dimensional activity), so it is important to ensure that all equipment is adequately covered from all angles.
Another option is inert gasses, typically combinations of argon and nitrogen, which work by replacing air in the risk area and reducing the oxygen below the level of combustion. Again, they have low GWPs and are not affected by the F-gas Regulation. They may not be the best choice where very rapid fire extinguishing is required, because they can take a couple of minutes to effectively discharge and then 30 seconds to put out a fire. Plus, they are not ideal in occupied areas, because the elimination of oxygen can cause these gasses to be hypoxic at the concentration level required to extinguish a fire. They also need high pressure to operate and since high volumes of gas are required, the size of the overall system can be comparatively large.
A third option is to use systems based on engineered clean extinguishing agents. Systems that use these agents typically require lower pressure and have smaller footprints so they take up less valuable space. This category includes non-sustainable agents such as HFCs, but also environmentally sustainable agents that are not affected by the new EU legislation, nor any other environmental legislation worldwide.
For instance, perfluoroketones (also known as FK 5-1-12) have a GWP of less than one and zero ozone depletion. This agent discharges in 10 seconds and extinguishes a fire within 30 seconds, by removing heat rather than oxygen. As these clean extinguishing agents are electrically non-conductive and do not leave any residue on equipment, they are safe for use without any interruption to service, following discharge.
In the oil and gas market, there are other issues to consider. For instance, engineered clean extinguishing agents which are fluids at room-temperature (such as FK 5-1-12) can be shipped using any form of transportation, including air cargo. Consequentially, these agents can be rapidly delivered to remote locations - such as offshore oil rigs - and lend themselves well to local refilling by trained personnel, eliminating the need to remove cylinders off-site for maintenance.
This brings us to a final and important point: whatever system is chosen, total cost of ownership needs to be understood, because variable factors, such as refilling, maintenance, space and storage, can vary considerably.
Regardless of which type of system is selected, the message to the oil and gas market is that current environmental legislation does not have to inhibit the ability to select and install fire suppression systems that meet a wide range of criteria: looking after health and safety; protecting valuable assets; and of course, effective extinguishing of any fire outbreak.