IHRCM/3 Report
19/11/12
|
REPORT OF THE
INTERNATIONAL HALON REPLACEMENT COORDINATION
MEETING
THIRD MEETING (IHRCM/3)
(Long Beach, California, United States, 15 to
16 November 2012)
SUMMARY
|
This report captures the presentations,
discussions and conclusions of the third International Halon Replacement
Coordinating Meeting (IHRCM/3).
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1.
INTRODUCTION
1.1
For over forty-five years
halogenated hydrocarbons (halon) have been the main fire extinguishing agent
used in civil aircraft fire suppression systems. With the signing of the
Montreal Protocol on Substances that Deplete the Ozone Layer, the production of
halon was banned on 1 January 1994 in developed States. This is mainly due to
halon’s ozone depleting and global warming characteristics. However, halon is still
to this day being used in aircraft fire suppression systems.
2.
BACKGROUND
2.1
In December 2009, the first
halon coordinating meeting (IHRCM/1) was held with industry, State regulators
and international organizations to review the current status of halon replacements,
look at the way ahead and discuss alternatives to halon. This meeting focused
its work on the timeframes specified in Assembly Resolution A36-12 and on the
viability of meeting those timeframes. As a result of the meeting, new
timeframes were proposed in the form of an amended draft resolution.
2.2
During the IHRCM/1, it was
concluded that the only effective means to set international requirements with
regard to halon replacement would be to propose that the Council approve
amendments to Standards and Recommended Practices (SARPs). Amending Annex 6 — Operation
of Aircraft and Annex 8 — Airworthiness of Aircraft would be the
recommended course of action in implementing the requirements of the updated
Assembly Resolution A36-12 and Assembly Resolution A37-9 ─ Halon replacement,
adopted on 7 October 2010, calls for the Council to establish a mandate for the
replacement of halon fire extinguishing agents in civil aircraft and sets new
timeframes previously agreed by stakeholders.
2.3
While Assembly Resolution A37-9
mandated the use of an alternative agent to halon, it also established other
tasks to be accomplished:
a) Direct the Council to conduct regular
reviews of the status of potential halon alternatives to support the agreed
upon implementation dates given the evolving situation regarding the
suitability of potential halon alternative agents as they continue to be
identified, tested, certified and implemented;
b) Urge States to inform ICAO regularly of
their halon reserves, and directs the Secretary General to report the results
to the Council. Further, the Council is
directed to report on the status of halon reserves at the next Ordinary Session
of the Assembly; and
c) Resolve that the Council shall report to
the next ordinary session of the Assembly on progress made developing halon
alternatives for cargo compartments and engine/auxiliary power unit fire
extinguishing systems as well as the status of halon alternatives for hand held
fire extinguishers.
2.4
The process to amend Annexes 6
and 8 began in November 2010 and the proposal was adopted by the ICAO Council
on 13 June 2011.
2.5
IHRCM/2 provided an opportunity
for the various stakeholders to update and discuss on the following:
a) the status of lavatory fire extinguishing systems;
b) the status of halon alternatives for hand-held fire extinguishers;
c) the progress made in the development of halon alternatives for
engine/auxiliary power unit and cargo compartment fire extinguishing systems;
and
d) the reporting of halon reserves by States.
2.6
IHRCM/3 further updated and discussed
with the stakeholders on the following:
a)
the status on the development
of potential halon alternatives to support the agreed upon implementation
dates, including halon alternatives for cargo compartment fire suppression
systems;
b)
the issues associated with the
quality of recycled halon;
c)
the progress of the
implementation of the requirements of Annex 6 and Annex 8 for halon
replacement;
d)
the States responses to the
ICAO State questionnaire on halon reserves; and
e)
the proposal of a tentative
timeframe for the replacement of halon in cargo compartments.
3.
AGENDA ITEM 1: OPENING OF THE
MEETING
3.1
Place and duration
3.1.1
The third meeting of the
International Halon Replacement Coordinating Meeting (IHRCM/3) was held at Boeing
Commercial Airplanes, Long Beach, USA on 15 and 16 November 2012. IHRCM/3 was
held in conjunction with the International Aircraft Systems Fire Protection
Working Group (IASFPWG) meeting on 14 and 15 November 2012 to accommodate
participants.
3.2
Opening remarks
3.2.1
The meeting started at 1430 hours
on 15 November 2012. Mr. Alain Coutu,
Technical Officer Airworthiness, Air Navigation Bureau (ANB) welcomed the
participants and provided the opening remarks. Mr. Coutu stated that this
gathering was different from previous meetings as there were more participants present
than when the original group of experts first convened in 2009. He informed the
meeting that this group of experts had been tasked to support the Secretariat
in providing a progress report on halon alternatives and halon reserves, which
is to be submitted at the next Assembly. A brief introduction to the halon
replacement in aircraft was presented and a brief discussion on the earlier
IHRCMs.
3.3
Attendance
3.3.1
The meeting was attended by
experts and observers from four States, EASA, ICCAIA and twenty industry organizations.
Also attending the meeting via teleconference were representatives of ICCAIA
and IATA. The list of participants is attached in Appendix A.
3.4
Meeting Chairperson
3.4.1
Mr. Dick Hill, Program Manager, Fire Safety Branch, International Aircraft Systems Fire Protection Working Group
(IASFPWG), was the Chairperson of the meeting throughout its duration supported
by Mr. Coutu.
3.5
Adoption of the agenda
3.5.1
The meeting adopted the
following agenda:
Agenda Item 1:
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Opening of the meeting
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1.1
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Opening remarks
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1.2
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Administrative remarks
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1.3
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Introduction of participants
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1.4
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Adoption of Agenda
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Agenda Item 2:
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Status report
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2.1
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Status report on the
development of potential halon alternatives to support the agreed upon
timeline.
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2.2
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Updates on the research
and development made on halon alternatives for cargo compartment fire
suppression systems.
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Agenda Item 3:
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Recycled halon
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3.1
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Updates on issues
associated with the quality of recycled halon.
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Agenda Item 4:
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Progress made since IHRCM/2
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4.1
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Presentations and discussions
on alternatives to halon and progress of implementation of the requirements
of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of
Aircraft for halon replacement.
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4.2
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Report on halon reserves
based on States’ responses to the ICAO State questionnaire on halon reserves.
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Agenda Item 5:
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Timeframe for halon replacement in cargo
compartment
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5.1
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Propose a
tentative timeframe for replacement of halon in cargo compartments.
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Agenda Item 6:
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Any other business
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Agenda Item 7:
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Closing
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4.
agenda item 2: STATUS REPORT
4.1
Agenda Item 2.1 - Status report
on the development of potential halon alternatives to support the agreed upon
timeline.
4.1.1
Present status of halon
replacement in aircraft
4.1.1.1
Mr. R. Hill of FAA Technical
Center, provided a presentation to update the meeting on the status of halon
alternatives for lavatory extinguishers and potential alternatives for
hand-held, engine nacelle/APU and cargo compartment extinguishers.
4.1.2
Lavatory extinguishers
4.1.2.1
The meeting was informed that
the approved halon replacement agents FM-200 and FE-36 had passed the FAA
Minimum Performance Standards (MPS) tests and are certified under the US EPA
Significant New Alternatives Programme (SNAP). Currently, all Boeing and Airbus
aircraft use these replacement agents.
4.1.2.2
Bombardier and Embraer informed
the meeting that halon replacement agents in lavatory fire extinguishers will
begin to be implemented as of January 2013.
4.1.3
Hand-held extinguishers
4.1.3.1
The meeting was informed that
the following replacement agents for halon 1211 meet MPS and are SNAP approved:
a)
HCFC Blend
B (Halotron 1);
b)
HFC-227ea
(FM-200); and
c)
HFC-236fa
(FE-36)
4.1.3.2
However, these 3 agents, though
approved for use, have yet to be installed as they are reported to be up to twice the weight,
greater in volume and have up to seven times global warming potential (GWP)
than halon 1211. To mitigate the issue of weight, Mr. Hill informed that the
FAA Technical Center has begun a project for hand-held extinguishers design
optimization to reduce weight. Considerations include nozzle and bottle design
and bottle operating pressures. This project is not aimed at finding a
replacement but at what can be done should 2BTP (2-bromo-3,
3, 3-trifluropropene) fails.
4.1.3.3
The
meeting was updated on new replacement agents being evaluated including 2BTP which is awaiting SNAP
approval and Underwriters Laboratories (UL) rating. This is a promising agent.
4.1.3.4
Mr. Hill informed the meeting that
the industry has agreed to use
approved agents if better alternatives are not approved prior to the
established ICAO date, 31 December 2016.
4.1.4
Engine nacelle / APU
extinguishers
4.1.4.1
The meeting was briefed that
the following replacement agents have passed MPS and are SNAP approved:
a)
HCF-125 (17.6% concentration);
b)
FK-5-1-12
(Novec 1230) (6.1% concentration); and
c)
CF3I (7.1% concentration)
4.1.4.2
Mr. Hill
provided further information on some of these agents:
a)
HFC-125
i)
used by
the military;
ii)
major
weight and volume penalty
b)
Novec 1230
i)
Novec 1230
is not functioning as required by the MPS at low ambient temperature;
ii)
more
R&D needed
c)
CF3I
i)
toxicity concerns
d)
Kidde Solid Aerosol (KSA)
i)
new
non-gaseous agent;
ii)
MPS
developed concentrations unable to extinguish live engine fire;
iii)
additional
R&D needed
4.1.5
Cargo compartment
extinguishing systems
4.1.5.1
The meeting was informed that
the following potential replacement agents have failed the cargo compartment
MPS test:
a)
HFC-125/FM-200:
high HF concentrations, ignition of smoke layer;
b)
CF3I:
toxicity concerns;
c)
2BTP/Novec
1230: overpressures at below inerting concentrations during aerosol can scenario
4.1.5.2
However, the following developments
are being considered for cargo compartment fire extinguishing systems:
a) Integrated Fire Protection - Water
Mist/Nitrogen System
i) passed
MPS in early 2010;
ii)
promising
concept but requires significant development and acceptance; and
iii)
requires
the use of the on-board inert gas generation system installed on aircraft to
reduce fuel tank flammability
b)
Airbus has
proposed a halon knock-down nitrogen system for A350 that would reduce the use
of halon by 50%
4.1.5.3
MPS was developed in 2005
(DOT/FAA/AR-TN05/20) and now the FAA is considering adding a lithium battery
scenario. There is nothing at this time indicating that an additional test and/or
amendment to the MPS may be required.
4.1.5.4
Mr. Hill added that there is a
possibility that there may be a recommendation from NTSB to equip freighter
airplanes with fire extinguishing systems.
4.1.6
BTP-
Status
4.1.6.1
Mr. B. Colton from AMPAC
provided a status report on 2BTP (2-Bromo-3,
3, 3-Trifluoropropene). 2BTP was initially developed as a replacement agent for
halon 1301. However, rresults of recent testing
provided confidence that 2BTP could be used as a drop-in replacement for the
halon 1211 fire extinguishers.
4.1.6.2
2BTP still requires further
tests including toxicology and UL leak tests. Regulatory review is expected to
be completed by 2013. Commercialization for aviation is expected to follow
after US and EU approvals, sometime in 2014.
4.1.7
Industry update – Challenges
and solutions to halon replacement
4.1.7.1
Mrs. Robin Bennett of ICCAIA
provided a presentation and information paper on the challenges and solutions
to halon replacement from the perspective of the industry stakeholders. This
update is based on Boeing, Airbus, Bombardier, AIA discussions.
4.1.7.2
The aerospace industry remains
committed to implementing solutions but the new challenges need to be addressed,
and more concerted engagement by all stakeholders is key. ICCAIA recognized the progress made with
lavatory and handheld fire extinguishing agents, yet challenges remain. Two engine
and APU alternatives promising agents did not meet expected performance
requirements under additional FAA testing. The industry is not optimistic that
any current known agent will be certification-ready to meet the 31 December
2014 date. The cargo alternatives research continues for potential replacements.
4.1.7.3
ICAO reiterated that the 2014
date is applicable to aircraft for which an application for type certificate is
submitted on or after 31 December 2014. There are still a few years after that
before the aircraft rolls out of the production line. ICAO is not ready to
change the established date.
4.1.7.4
Industry’s position continues
to be that it is premature to establish halon replacement deadlines for cargo
applications. The successful establishment of a replacement date requires full
cooperation of all stakeholders with broader representation and more frequent
engagement.
4.1.7.5
ICAO Assembly Resolution A37-9
adopted in 2010 should consider the new challenges and an update should be made
to provide flexibility to address potential situation of alternative solutions
not being viable with current A37-9 deadlines similar to the provision in the
halon regulation adopted by the EU.
4.1.7.6
The EASA representative, Mr R
Deletain, was asked what would be the process if an applicant did not have a
halon replacement at the time of type certificate application after 31 December
2014. Mr. Deletain stated that considerations at certification level would be
whether it is a rejection of the application because it doesn’t propose a
replacement agent or an alternative means to show compliance at later date as a
certification plan changes with time. He is uncertain of what the process would
be. Mr Deletain will request the rulemaking department at EASA.
4.1.7.7
The EU regulation provides for
exemption if no alternatives exist but there is an alternative for engine and
APU. HFC 125 is currently used by the military and although it has a weight
penalty, it works.
4.1.7.8
Regarding more engagements by
stakeholders, ICAO offered the meeting as a forum if stakeholders wanted to
start discussions and form a working group. ICCAIA offered to support an
initiative to bring the stakeholders together and draft a roadmap.
4.2
Agenda Item 2.2 - Updates on
the research and development made on halon alternatives for cargo compartment
fire suppression systems
4.2.1
This agenda item was covered by
the presentation in Agenda item 2.1.
4.2.2
Laptop and other thermal
runaways in Lithium battery development
4.2.2.1
Mr. Kent Faith from Sprectrum FX provided information on lithium
battery fire and the available product for extinguishing. The available product
is not a replacement for halon and is a supplemental kit to existing handheld
extinguishers for lithium battery. The agent called Firebane is not rated for
electrical fire as it is conductive.
Conclusion
Status report
Lavatory fire extinguisher:
1)
There are currently two approved halon replacement agents FM-200 and
FE-36
2)
All new Boeing & Airbus aircraft presently use replacement agents
and Bombardier and Embraer will begin using a replacement agent as of January
2013.
Handheld Fire extinguisher:
1)
There are currently three replacement agents that are approved but not
installed:
a.
HCFC Blend B (Halotron 1)
b.
HFC-227ea (FM-200)
c.
HFC-236fa (FE-36)
These agents are up to twice the weight, are larger in volume, and have
up to 7 times the GWP.
2)
The FAA is funding a project for fire extinguisher design optimization
to reduce weight. Its focus is on:
a)
nozzle design;
b)
bottle design; and
c)
operating pressure
3)
Work continues to be done with 2BTP as it is a promising agent.
Commercialization for aviation is planned for 2014. 2BTP does not have the environmental, size, or weight issues of existing
approved halon replacement fire extinguishers agents.
4)
Industry has agreed to use approved agents if better alternatives are
not approved prior to the ICAO date.
Engine/APU fire extinguisher:
1)
Three replacement agents have passed the MPS and are SNAP approved
a)
HCF-125 (17.6% concentration)
b)
CF3I (7.1% concentration)
c)
FK-5-1-12 (Novec 1230) (6.1%
concentration)
2)
Novec 1230
·
not functioning as required by the MPS at low ambient temperature
·
agents use in question – More R&D needed
3)
CF3I
·
concerns with toxicity
4)
HFC-125
·
currently used by military
·
major weight and volume penalty
5)
Kidde Solid Aerosol (KSA) Testing
·
new non-gaseous agent
·
MPS developed concentrations unable to extinguish live engine fire.
·
additional R&D is in process
6)
The research is in progress and ICCAIA is not certain to be able to meet
the target date of 2014 for the engine/APU fire extinguisher.
7)
There is a replacement but it has weight and volume property.
8)
The representative
from EASA will inquire from the rulemaking department at EASA what would be the
course of action at the certification level if the applicant for a type
certificate doesn’t propose a replacement agent or alternative considering that
a certification plan changes with time.
Cargo fire extinguisher:
1)
Replacement agents tested – failed MPS
a)
HFC-125/FM-200: high HF concentrations, ignition of smoke layer
b)
CF3I: toxicity concerns
c)
2-BTP/Novec 1230: overpressures at below inerting concentrations during
aerosol can scenario
2)
Integrated fire protection - water mist/nitrogen system
·
passed MPS in early 2010
·
promising concept but requires significant development and acceptance
·
uses on-board inert gas generation system installed on aircraft to
reduce fuel tank flammability
3)
Airbus has proposed halon knock-down nitrogen system for A350
4)
MPS was developed in
2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering lithium battery
scenario. It may or may not require a
new test and/or amendment to the MPS.
5.
AGENDA ITEM 3: RECYCLED HALON
5.1
Agenda item 3.1 – Updates on
issues associated with the quality of recycled halon
5.1.1
Halon supply and quality of recycled
halon
5.1.1.1
Mr. R. Marcus of RemTec
provided the meeting with an insight to issues associated to the recycling of
and the quality of recycled halon (1211, 1301, and 2402). The presentation
informed the meeting of the supply and quality issues; recovery, reclamation
and destruction processes; quality control and testing of recycled halon; and
storage considerations.
The production of halon 1211 has ceased in industrialized countries
since 1 January 1994 and U.S. excise taxes apply to both new and used Halon
1211 imported into the U.S. Supplies of
Halon 1211 are limited and the quality of used installed inventory is
declining.
Halon 2402 is primarily used on Soviet Union / Russian
military and commercial aviation equipment and worldwide supplies are limited.
The production of halon 1301 ceased in industrialized countries 1 January
1994 and critical users are aviation, petrochemical plus and equipment
distributors servicing used equipment.
In 1993 the installed inventory was primarily in Japan, North America
and Europe. After 20 years the supply of used Halon 1301 is dwindling, quality
is declining especially if sourced from developing countries and many of those
countries restrict the export of halons. Japan does not allow export of halon.
As the quality and supply of halons has decreased, the cost to procure
and reclaim halons has increased, and in the last 5 years, the cost of
procuring recovered halon 1301 has augmented 100%.
Cross-contamination is becoming more prevalent the farther we move away
from virgin production end dates. As used halon and other “in demand”
halocarbons become more expensive, the incentive to intentionally blend-in
cheaper halocarbons such as R-22, forming increases.
5.1.1.2
The
presentation suggests that to successfully manage halocarbons, considerations
should be made to:
a)
provide
incentives to encourage recovery from end-users;
b)
institute
safe handling practices;
c)
document
and track agents and tanks;
d)
perform laboratory
testing for both the incoming material and the out-going finished product;
e)
establish
long-term strategic reserves for critical users; and
f)
continually
conduct leak testing and periodic physical inventories.
Conclusion
Recycled halon
1)
As the
quality and supply of halons has gone down, the cost to procure and reclaim
halons has gone up and in the last 5 years the cost of procuring recovered
halon 1301 has increased 100%.
2)
Halons are more difficult to recycle
due to cross contamination.
3)
Cross-contamination
is becoming more prevalent the farther we move away from virgin production end
dates. As used halon and other “in demand” halocarbons become more expensive
the incentive to intentionally blend in cheaper halocarbons such as R-22
increases.
4)
TCCA, in cooperation with the
FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means
to minimize the probability that non-compliant/contaminated agents will be
installed on aircraft.
6.
AGENDA ITEM 4 – PROGRESS MADE SINCE IHRCM/2
6.1
Agenda item 4.1 -
Presentations and discussions on alternatives to halon and progress of
implementation of the requirements of Annex 6 – Operation of Aircraft
and Annex 8 – Airworthiness of Aircraft for halon replacement.
6.1.1
EASA progress and plans
6.1.1.1
Mr. R. Deletain of EASA briefed
the meeting on EASA’s Rulemaking Tasks (RMT) on halon replacement. The meeting
was updated on the status of several RMTs.
In 2011 EASA
initiated a rulemaking task to amend CS-23, CS-25 and CS-29 in order to be
compliant with EU legislation and with the Amendment 103 to ICAO Annex 8. And
in 2012 CS-23 and CS-25 have already been amended and CS-29 is being amended
accordingly. The CS (Book 1) has
no reference to either halon or any other extinguishing agent and AMC/GM (Book
2) explains the reason for halon being phased out referring to Regulation
744/2010.
The EU
legislation implies compliance with applicable amendments to ICAO Annex 6 (i.e.
newly produced aircraft based on existing Type Certificates) only in 2025 (for
handheld fire extinguishers) and 2020 (for lavatories). EASA has planned RMT.0560 to comply with the
dates set in ICAO Amendments to Annex 6 which will be late for lavatories. It
will comprise of an update of EASA part 26 and propose a forward fit for
lavatory disposal receptacle and portable fire extinguishers in cabins and crew
compartments.
The halon
alternatives are sufficiently safe and suitable for handheld and lavatories
fire extinguishers bringing environmental benefits, with minimum economic
impact on aircraft manufacturers. This proposal complies with current ICAO
standards without a need for amending EU regulation 744/2010. The Notice of
Proposed Amendment (NPA) will be available by mid-2013 and anyone can comment.
EASA has also mandated
SAE (Society of Automotive Engineers) to develop Minimum Performance Standards
for (halon free) portable fire extinguishers to be used in aircraft and an ETSO
(European Technical Standard Order) will be published. There is a rule making
task (RMT.0206) in process and the NPA will be available in 2013.
In order to
align with ICAO Resolution A37-9 ‘halon replacement’ adopted during ICAO 37th
General Assembly, amendments to of Part- 145 and Part-M shall be made.
AMC/GM (Acceptable Means of Compliance /Guidance Material) will be
developed for production and maintenance organizations to verify the quality of
halon in their possession through testing and internal procedures. The notice
of proposed amendment (NPA) is planned for Q3 of 2013.
The following is
a summary of EASA actions:
RMT
|
STATUS
|
|
0273
|
New
applications for TC
|
CS-23
& 25 amended
CS-29
amended before end 2012
|
0560
|
Newly
produced aircraft
|
NPA
planned in 2013
|
0206
|
ETSO
for portable fire extinguishers
|
NPA
planned in 2013
|
0368
|
Contaminated halon
|
ToR
being drafted
NPA
planned in 2013
|
??
|
Engine
nacelles, APU and cargo compartments
|
No
obligation of any agent in CSs
Additional
RMTs could be planned
|
Filing
of Differences
Mr. Alain Coutu presented a summary
of the differences filed by States regarding the standards relating to halon
replacement:
Annex 6, 8
|
A 35 Annex 6
Part I, 6.2.2.1
(L, H)
|
A30 Annex 6
Part II, S II 2.4.2.3
(L, H)
|
A16 Annex 6
Part III, S II 4.2.2.1
(L, H)
|
A 6 Annex 6
Part III, S III 4.1.3.2
(L, H)
|
A103 Annex 8
Part II, 1.2.5
(L, E, A)
|
No Difference
|
13
|
20
|
17
|
16
|
19
|
Currently do not have such requirements
|
3
|
5
|
5
|
3
|
3
|
Will comply at a later Date
|
13
|
12
|
6
|
13
|
0
|
N/A
|
0
|
1
|
2
|
1
|
2
|
Total Replies
|
29
|
38
|
30
|
33
|
24
|
No States filed
differences stating they would not comply with the Standards. Most States
either declared no differences or would comply at a later date. The N/A means
the States do not have the activity in their State at this time.
6.2
Agenda item 4.2 - Report on
halon reserves based on States’ responses to the ICAO State questionnaire on
halon reserves.
6.2.1
Responses to ICAO State
Letter on halon reserves
6.2.1.1
Mr. Coutu also updated the
meeting on the responses received from States regarding halon reserve.
•
In May 2012 ICAO issued State
Letter AN 3/25.1-12/35
requesting information on halon
reserves accessible to the civil aviation industry within States to
follow-up on Assembly Resolution A37-9: Halon replacement, adopted by the 37th
Session of the ICAO Assembly. The resolution urges States to inform ICAO regularly
on their halon reserves of which ICAO is to report at the next Assembly, which
will be held in September 2013.
•
As of
October 2012 ICAO received 53 Replies to the
questionnaire on halon reserve.
•
To question No.1; “With the ban
……..do you anticipate that there will be enough halon to meet the civil
aviation needs of your State? Most States responded they were unsure of the
halon reserve while others responded N/A as they purchase it from an outside
source.
•
To question No. 2; “Do you know
the quantity of halon reserves accessible to the civil aviation industry in
your State in order to support its future operations? Most States replied no,
while several others replied N//A. Only 33 States replied they know their
reserves, 16 for halon 1211 and 17 for halon 1301.
6.2.2
Estimated Global Inventories
of Halons 1301 and 1211
6.2.2.1
Mr. T. Cortina presented, on
behalf of UNEP, their approach to estimate the amount of halon available. The
presentation also discussed the ownership of halon by region, the challenges in
procurement, and the availability of halon for civil aviation use.
No one “Knows” how much halon is left. We
know the global yearly production data, the global yearly estimated emissions
and comparing with atmospheric measurements of emissions we can estimates the
reserves.
Global quantities are irrelevant unless owned
by civil aviation. Some States have
import taxes while others have exporting laws prohibiting export of halon. It
is not only a reserve issue but also a regulatory issue. Halon reserves are
difficult to estimate as there are owners retaining supplies from
decommissioned systems for own uses/stockpile, large users like the US Dept. of
Defense and North Slope in U.S., maintain their own long-term reserves, and
some airlines may have their own reserve.
Reliance on halon “Banks” has implications,
one which is destruction for carbon credits. Ozone depleting substance (ODS)
have high global warming potential (GWP) similar to HFC alternatives.
(i.e.: Halon 1301 = 7,140, HFC-227ea = 3,220)
US Climate Action Reserve provides greenhouse
gas (GHG) offset credits for destruction of ODS (not currently halons) and
Australia will have a carbon tax in July 2013, which will be an incentive for
destruction of waste GHGs. Therefore users of halon could be competing in a market
with companies looking to destroy halons for GHG credits.
6.2.3
UNEP assessment of the responses to ICAO
State letter on halon reserve
There is a notable lack of response from States where we think there could be a lot
of halon and where filling of bottles now occurs. Although some States have
determined their supplies some did not know how much halon they had. While some
States believe that there is enough halon we are not certain how they could
determine that.
The following is a fairly typical answer of
the survey responses. Brazilian aircraft manufacturers, Embraer and Helibras
declared:
—
The halon used to fill the fire extinguishers of their aircraft is
provided by foreign suppliers.
Moreover, the two Brazilian airlines, TAM and
Gol, that retain approximately 75% of the civil aviation domestic market in
Brazil and are the only Brazilian airlines that operate international flights
declared:
—
The halon used to fill the aircraft fire extinguishers of their fleet is
also provided by foreign suppliers.
ANAC is unaware of any Brazilian company that
recycles halon to be used in aircraft fire extinguishers.
Therefore, the civil aviation halon needs in
Brazil depend on the availability of halon in the countries that supply the
Brazilian aircraft manufacturers and airlines.
On the subject of cargo compartment fire
extinguishing agent replacement, this is the largest use of halon on aircraft
and drives the quantities of halon needed for the long-term. With no end in
sight, it makes estimates of needs impossible to determine.
European Union has end and cut-off dates. We need
to consider now establishing a date for the replacement of halons in new
designs aircraft and the ICAO end dates help to support commercial research and
development of halon alternatives.
The presentation concluded with
UNEP suggesting the following:
a)
the need
to consider establishing a date to mandate implementation of halon alternatives
for aircraft cargo compartment;
a)
civil aviation still needs to
determine the long term needs for halon, where the requirements will come from,
and to report to Parties to the Montreal Protocol;
b)
resend ICAO State Letter AN
3/25.1-12/35 to States’ ozone focal point to canvass a broader response from
States to the State Letter; and
c)
consider developing guidance on
the collection and provision of
information on halon for aviation needs and halon reserves.
Conclusion
Progress made since IHRCM/2
1)
EASA has begun rulemaking and the following
is a summary of EASA actions:
RMT
|
STATUS
|
|
0273
|
New
applications for TC
|
CS-23
& 25 amended
CS-29
amended before end 2012
|
0560
|
Newly
produced aircraft
|
NPA
planned in 2013
|
0206
|
ETSO
for portable fire extinguishers
|
NPA
planned in 2013
|
0368
|
Contaminated halon
|
ToR
being drafted
NPA
planned in 2013
|
??
|
Engine
nacelles, APU and cargo compartments
|
No
obligation of any agent in CSs
Additional
RMTs could be planned
|
2)
Of the States who have filed differences, none have stated they will not
comply, and although some States stated no differences, others stated they
would comply at a later date.
Halon reserves:
1)
The HTOC model of global
inventories of halon is based on:
a)
production data known prior to
1996;
b)
estimate of yearly emissions by
region;
c)
estimate of yearly recovery
rates; and
d)
similar results from
atmospheric samplings validate the HTOC model
2)
The HTOC charts on the global
inventories of halon 1301 and halon 1211 is given in Appendix 2.
3)
No one “knows” how much halon is left. We know the global yearly
production data, the global yearly estimated emissions, and comparing with
atmospheric measurements of emissions, it is possible to estimate the reserves.
4)
Global quantities are irrelevant unless owned by civil aviation. Some States have import taxes while others
have exporting laws prohibiting export of halon. Therefore it is not only a
reserve issue but also a regulatory issue.
5)
Reliance on banks has the
implications that States may destroy halon for Carbon Credits:
a)
ODS have
high GWPs similar to HFC alternatives
i.
Halon 1301
= 7,140, HFC-227ea = 3,220
b)
US Climate
Action Reserve provides GHG offset credits for destruction of ODS (not
currently halons)
c)
Australia
carbon tax, incentives for destruction of waste GHGs including ODS in July 2013
d)
users of
halon could be competing in market with companies looking to destroy halons for
GHG credits
i.
Current
cost of Halon 1301 in US ≈ $33,000/tonne
ii.
At $20/tonne of CO2
equivalent = $142,800/tonne
6)
Responses from States to ICAO
State letter on halon reserve for civil aviation:
a)
little
evidence that States civil aviation and ozone offices worked together;
b)
notable
lack of response from States where possibly there could be a lot of halon and
where filling of bottles now occurs;
c)
little
evidence that States know how much halon is available to civil aviation
although some States believe there is enough halon, it must be difficult to
determine; and
d)
resend ICAO State Letter AN
3/25.1-12/35 to States’ ozone focal point to canvass a broader response from
States to the State Letter.
7)
European Union has end and cut-off dates. ICAO needs to consider now
establishing a date for the replacement of halons in new designs aircraft and
the ICAO end dates help to support commercial research and development of halon
alternatives.
7.
AGENDA ITEM 5: TIMEFRAME FOR
HALON REPLACEMENT IN CARGO COMPARTMENTS
7.1
Agenda item 5.1 – Propose a
tentative timeframe for the replacement of halon in aircraft cargo
compartments.
7.1.1
Establishment of Timeframe
7.1.1.1
Mr. Coutu briefed the meeting
on the ICAO Standard making process. It was explained that should a decision be
made on the timeframe for halon replacement in November 2012; the earliest
applicable date for a Standard in Annex 8 would be March 2018 and therefore
would be adjusted to the 31 December 2018 to correspond with EASA cut-off date.
ICCAIA
reiterated that it is too early to commit to a replacement date and committing
to a replacement date that the industry is uncertain of meeting. Aircraft designers
may be hesitant to apply for a new type certificate.
A representative
from Boeing stated that the process is difficult and flexibility is required.
ICAO reiterated that the process of standard making will lead to a date for the
replacement of halon in cargo compartment fire extinguishing system for new
design aircraft. In the Standard making process a date cannot be left open, an
implementation date is required.
UNEP stated that
with a replacement date of 2019, it will have been 20 years since the
production of halon ceased and States do not know how much halon is available for use by aviation. Will a
few more years help? If a date is not established now, it is likely that a replacement
will be available in the near future.
UNEP asked the
question: EASA has a dateline; what are the manufacturers going to do?
Airbus stated
that it is a big discussion right now within the organization and that although
very political and controversial they may have to request an exemption. At
least, this flexibility is available.
The meeting
asked how the new lithium battery test would impact the research. The
representative of the FAATC stated that it will not affect the progression of
the research.
FAATC also
stated that it is expected that the National Transportation Safety Board may
issue a recommendation for the installation of fire suppression system in cargo
airplane.
The concept of a
working group of the stakeholders was discussed again and could be used as a
collaborative decision making process to achieve the establishment of an
implementation date for the replacement of halon in cargo compartment.
ICCAIA committed
to lead the initiative and several stakeholders present offered their support.
The group should have a plan by early January 2013 that will provide a target
date, by which the group should have reached consensus, on a replacement date
for cargo compartment.
Conclusion
Timeframe for halon replacement in cargo compartment
1)
Research has not progressed
rapidly enough.
2)
ICCAIA has proposed to lead an
initiative to create a working group of stakeholders that will work together at
creating a roadmap that would define the processes required, as well as the role
of the stakeholders, and by January 2013 would propose a plan that would lead
to the establishment of a target date for the replacement of halon.
8.
AGENDA ITEM 6: ANY OTHER
BUSINESS
8.1
Study Regarding Fire Extinguishing/Suppression Agents’ Quality Processes
Mr. Claude Lewis
of Transport Canada briefed the meeting on their study. The quality of agents
in fire extinguishing and suppression systems has been brought into question as
a result of cases of contaminated halons found installed (or destined for
installation) on aircraft. TCCA, in
cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a
study to identify means to minimize the probability that
non-compliant/contaminated agents will be installed on aircraft. The study, which is being conducted (under contract) by R.G.W. Cherry &
Associates (UK ) is considering contamination potential for both new and
recycled agents, from agent production to filled vessels installed on aircraft, and accidental, as well as
intentional ‘opportunities’. The project
comprises two phases: 1) documenting the processes currently in use in North
America and in Europe, and 2) analysis to identify best practices as well as
deficiencies/gaps, and development of proposed standardized quality protocols.
The first phase, which involved the polling of stakeholders (manufacturers,
suppliers, recyclers, operators, test laboratories, etc.) is essentially
completed. Preliminary review indicates
that there are differences between the processes used in North America and in
Europe for the different ‘applications’, that there are no equivalent to UL/ULC
in Europe, and that third party
testing/sampling, when done, is an industry practice or is being conducted as a
contractual obligation. The second phase
has just been initiated and is expected to be completed in early 2013.
9.
AGENDA ITEM 7: CLOSING OF THE
MEETING
9.1
The meeting was concluded and
ICAO thanks all participants for sharing information and discussing these
issues. The meeting objectives were met and positive results can be reported at
the next assembly on the progress made with halon replacement.
The meeting ended at 1400 hours on 16 November 2012
— END —.
APPENDIX B
IHRCM/3 Report
19/11/12
|
REPORT OF THE
INTERNATIONAL HALON REPLACEMENT COORDINATION
MEETING
THIRD MEETING (IHRCM/3)
(Long Beach, California, United States, 15 to
16 November 2012)
SUMMARY
|
This report captures the presentations,
discussions and conclusions of the third International Halon Replacement
Coordinating Meeting (IHRCM/3).
|
1.
INTRODUCTION
1.1
For over forty-five years
halogenated hydrocarbons (halon) have been the main fire extinguishing agent
used in civil aircraft fire suppression systems. With the signing of the
Montreal Protocol on Substances that Deplete the Ozone Layer, the production of
halon was banned on 1 January 1994 in developed States. This is mainly due to
halon’s ozone depleting and global warming characteristics. However, halon is still
to this day being used in aircraft fire suppression systems.
2.
BACKGROUND
2.1
In December 2009, the first
halon coordinating meeting (IHRCM/1) was held with industry, State regulators
and international organizations to review the current status of halon replacements,
look at the way ahead and discuss alternatives to halon. This meeting focused
its work on the timeframes specified in Assembly Resolution A36-12 and on the
viability of meeting those timeframes. As a result of the meeting, new
timeframes were proposed in the form of an amended draft resolution.
2.2
During the IHRCM/1, it was
concluded that the only effective means to set international requirements with
regard to halon replacement would be to propose that the Council approve
amendments to Standards and Recommended Practices (SARPs). Amending Annex 6 — Operation
of Aircraft and Annex 8 — Airworthiness of Aircraft would be the
recommended course of action in implementing the requirements of the updated
Assembly Resolution A36-12 and Assembly Resolution A37-9 ─ Halon replacement,
adopted on 7 October 2010, calls for the Council to establish a mandate for the
replacement of halon fire extinguishing agents in civil aircraft and sets new
timeframes previously agreed by stakeholders.
2.3
While Assembly Resolution A37-9
mandated the use of an alternative agent to halon, it also established other
tasks to be accomplished:
a) Direct the Council to conduct regular
reviews of the status of potential halon alternatives to support the agreed
upon implementation dates given the evolving situation regarding the
suitability of potential halon alternative agents as they continue to be
identified, tested, certified and implemented;
b) Urge States to inform ICAO regularly of
their halon reserves, and directs the Secretary General to report the results
to the Council. Further, the Council is
directed to report on the status of halon reserves at the next Ordinary Session
of the Assembly; and
c) Resolve that the Council shall report to
the next ordinary session of the Assembly on progress made developing halon
alternatives for cargo compartments and engine/auxiliary power unit fire
extinguishing systems as well as the status of halon alternatives for hand held
fire extinguishers.
2.4
The process to amend Annexes 6
and 8 began in November 2010 and the proposal was adopted by the ICAO Council
on 13 June 2011.
2.5
IHRCM/2 provided an opportunity
for the various stakeholders to update and discuss on the following:
a) the status of lavatory fire extinguishing systems;
b) the status of halon alternatives for hand-held fire extinguishers;
c) the progress made in the development of halon alternatives for
engine/auxiliary power unit and cargo compartment fire extinguishing systems;
and
d) the reporting of halon reserves by States.
2.6
IHRCM/3 further updated and discussed
with the stakeholders on the following:
a)
the status on the development
of potential halon alternatives to support the agreed upon implementation
dates, including halon alternatives for cargo compartment fire suppression
systems;
b)
the issues associated with the
quality of recycled halon;
c)
the progress of the
implementation of the requirements of Annex 6 and Annex 8 for halon
replacement;
d)
the States responses to the
ICAO State questionnaire on halon reserves; and
e)
the proposal of a tentative
timeframe for the replacement of halon in cargo compartments.
3.
AGENDA ITEM 1: OPENING OF THE
MEETING
3.1
Place and duration
3.1.1
The third meeting of the
International Halon Replacement Coordinating Meeting (IHRCM/3) was held at Boeing
Commercial Airplanes, Long Beach, USA on 15 and 16 November 2012. IHRCM/3 was
held in conjunction with the International Aircraft Systems Fire Protection
Working Group (IASFPWG) meeting on 14 and 15 November 2012 to accommodate
participants.
3.2
Opening remarks
3.2.1
The meeting started at 1430 hours
on 15 November 2012. Mr. Alain Coutu,
Technical Officer Airworthiness, Air Navigation Bureau (ANB) welcomed the
participants and provided the opening remarks. Mr. Coutu stated that this
gathering was different from previous meetings as there were more participants present
than when the original group of experts first convened in 2009. He informed the
meeting that this group of experts had been tasked to support the Secretariat
in providing a progress report on halon alternatives and halon reserves, which
is to be submitted at the next Assembly. A brief introduction to the halon
replacement in aircraft was presented and a brief discussion on the earlier
IHRCMs.
3.3
Attendance
3.3.1
The meeting was attended by
experts and observers from four States, EASA, ICCAIA and twenty industry organizations.
Also attending the meeting via teleconference were representatives of ICCAIA
and IATA. The list of participants is attached in Appendix A.
3.4
Meeting Chairperson
3.4.1
Mr. Dick Hill, Program Manager, Fire Safety Branch, International Aircraft Systems Fire Protection Working Group
(IASFPWG), was the Chairperson of the meeting throughout its duration supported
by Mr. Coutu.
3.5
Adoption of the agenda
3.5.1
The meeting adopted the
following agenda:
Agenda Item 1:
|
Opening of the meeting
|
||
1.1
|
Opening remarks
|
||
1.2
|
Administrative remarks
|
||
1.3
|
Introduction of participants
|
||
1.4
|
Adoption of Agenda
|
||
Agenda Item 2:
|
Status report
|
||
2.1
|
Status report on the
development of potential halon alternatives to support the agreed upon
timeline.
|
||
2.2
|
Updates on the research
and development made on halon alternatives for cargo compartment fire
suppression systems.
|
||
Agenda Item 3:
|
Recycled halon
|
||
3.1
|
Updates on issues
associated with the quality of recycled halon.
|
||
Agenda Item 4:
|
Progress made since IHRCM/2
|
||
4.1
|
Presentations and discussions
on alternatives to halon and progress of implementation of the requirements
of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of
Aircraft for halon replacement.
|
||
4.2
|
Report on halon reserves
based on States’ responses to the ICAO State questionnaire on halon reserves.
|
||
Agenda Item 5:
|
Timeframe for halon replacement in cargo
compartment
|
||
5.1
|
Propose a
tentative timeframe for replacement of halon in cargo compartments.
|
||
Agenda Item 6:
|
Any other business
|
||
Agenda Item 7:
|
Closing
|
||
4.
agenda item 2: STATUS REPORT
4.1
Agenda Item 2.1 - Status report
on the development of potential halon alternatives to support the agreed upon
timeline.
4.1.1
Present status of halon
replacement in aircraft
4.1.1.1
Mr. R. Hill of FAA Technical
Center, provided a presentation to update the meeting on the status of halon
alternatives for lavatory extinguishers and potential alternatives for
hand-held, engine nacelle/APU and cargo compartment extinguishers.
4.1.2
Lavatory extinguishers
4.1.2.1
The meeting was informed that
the approved halon replacement agents FM-200 and FE-36 had passed the FAA
Minimum Performance Standards (MPS) tests and are certified under the US EPA
Significant New Alternatives Programme (SNAP). Currently, all Boeing and Airbus
aircraft use these replacement agents.
4.1.2.2
Bombardier and Embraer informed
the meeting that halon replacement agents in lavatory fire extinguishers will
begin to be implemented as of January 2013.
4.1.3
Hand-held extinguishers
4.1.3.1
The meeting was informed that
the following replacement agents for halon 1211 meet MPS and are SNAP approved:
a)
HCFC Blend
B (Halotron 1);
b)
HFC-227ea
(FM-200); and
c)
HFC-236fa
(FE-36)
4.1.3.2
However, these 3 agents, though
approved for use, have yet to be installed as they are reported to be up to twice the weight,
greater in volume and have up to seven times global warming potential (GWP)
than halon 1211. To mitigate the issue of weight, Mr. Hill informed that the
FAA Technical Center has begun a project for hand-held extinguishers design
optimization to reduce weight. Considerations include nozzle and bottle design
and bottle operating pressures. This project is not aimed at finding a
replacement but at what can be done should 2BTP (2-bromo-3,
3, 3-trifluropropene) fails.
4.1.3.3
The
meeting was updated on new replacement agents being evaluated including 2BTP which is awaiting SNAP
approval and Underwriters Laboratories (UL) rating. This is a promising agent.
4.1.3.4
Mr. Hill informed the meeting that
the industry has agreed to use
approved agents if better alternatives are not approved prior to the
established ICAO date, 31 December 2016.
4.1.4
Engine nacelle / APU
extinguishers
4.1.4.1
The meeting was briefed that
the following replacement agents have passed MPS and are SNAP approved:
a)
HCF-125 (17.6% concentration);
b)
FK-5-1-12
(Novec 1230) (6.1% concentration); and
c)
CF3I (7.1% concentration)
4.1.4.2
Mr. Hill
provided further information on some of these agents:
a)
HFC-125
i)
used by
the military;
ii)
major
weight and volume penalty
b)
Novec 1230
i)
Novec 1230
is not functioning as required by the MPS at low ambient temperature;
ii)
more
R&D needed
c)
CF3I
i)
toxicity concerns
d)
Kidde Solid Aerosol (KSA)
i)
new
non-gaseous agent;
ii)
MPS
developed concentrations unable to extinguish live engine fire;
iii)
additional
R&D needed
4.1.5
Cargo compartment
extinguishing systems
4.1.5.1
The meeting was informed that
the following potential replacement agents have failed the cargo compartment
MPS test:
a)
HFC-125/FM-200:
high HF concentrations, ignition of smoke layer;
b)
CF3I:
toxicity concerns;
c)
2BTP/Novec
1230: overpressures at below inerting concentrations during aerosol can scenario
4.1.5.2
However, the following developments
are being considered for cargo compartment fire extinguishing systems:
a) Integrated Fire Protection - Water
Mist/Nitrogen System
i) passed
MPS in early 2010;
ii)
promising
concept but requires significant development and acceptance; and
iii)
requires
the use of the on-board inert gas generation system installed on aircraft to
reduce fuel tank flammability
b)
Airbus has
proposed a halon knock-down nitrogen system for A350 that would reduce the use
of halon by 50%
4.1.5.3
MPS was developed in 2005
(DOT/FAA/AR-TN05/20) and now the FAA is considering adding a lithium battery
scenario. There is nothing at this time indicating that an additional test and/or
amendment to the MPS may be required.
4.1.5.4
Mr. Hill added that there is a
possibility that there may be a recommendation from NTSB to equip freighter
airplanes with fire extinguishing systems.
4.1.6
BTP-
Status
4.1.6.1
Mr. B. Colton from AMPAC
provided a status report on 2BTP (2-Bromo-3,
3, 3-Trifluoropropene). 2BTP was initially developed as a replacement agent for
halon 1301. However, rresults of recent testing
provided confidence that 2BTP could be used as a drop-in replacement for the
halon 1211 fire extinguishers.
4.1.6.2
2BTP still requires further
tests including toxicology and UL leak tests. Regulatory review is expected to
be completed by 2013. Commercialization for aviation is expected to follow
after US and EU approvals, sometime in 2014.
4.1.7
Industry update – Challenges
and solutions to halon replacement
4.1.7.1
Mrs. Robin Bennett of ICCAIA
provided a presentation and information paper on the challenges and solutions
to halon replacement from the perspective of the industry stakeholders. This
update is based on Boeing, Airbus, Bombardier, AIA discussions.
4.1.7.2
The aerospace industry remains
committed to implementing solutions but the new challenges need to be addressed,
and more concerted engagement by all stakeholders is key. ICCAIA recognized the progress made with
lavatory and handheld fire extinguishing agents, yet challenges remain. Two engine
and APU alternatives promising agents did not meet expected performance
requirements under additional FAA testing. The industry is not optimistic that
any current known agent will be certification-ready to meet the 31 December
2014 date. The cargo alternatives research continues for potential replacements.
4.1.7.3
ICAO reiterated that the 2014
date is applicable to aircraft for which an application for type certificate is
submitted on or after 31 December 2014. There are still a few years after that
before the aircraft rolls out of the production line. ICAO is not ready to
change the established date.
4.1.7.4
Industry’s position continues
to be that it is premature to establish halon replacement deadlines for cargo
applications. The successful establishment of a replacement date requires full
cooperation of all stakeholders with broader representation and more frequent
engagement.
4.1.7.5
ICAO Assembly Resolution A37-9
adopted in 2010 should consider the new challenges and an update should be made
to provide flexibility to address potential situation of alternative solutions
not being viable with current A37-9 deadlines similar to the provision in the
halon regulation adopted by the EU.
4.1.7.6
The EASA representative, Mr R
Deletain, was asked what would be the process if an applicant did not have a
halon replacement at the time of type certificate application after 31 December
2014. Mr. Deletain stated that considerations at certification level would be
whether it is a rejection of the application because it doesn’t propose a
replacement agent or an alternative means to show compliance at later date as a
certification plan changes with time. He is uncertain of what the process would
be. Mr Deletain will request the rulemaking department at EASA.
4.1.7.7
The EU regulation provides for
exemption if no alternatives exist but there is an alternative for engine and
APU. HFC 125 is currently used by the military and although it has a weight
penalty, it works.
4.1.7.8
Regarding more engagements by
stakeholders, ICAO offered the meeting as a forum if stakeholders wanted to
start discussions and form a working group. ICCAIA offered to support an
initiative to bring the stakeholders together and draft a roadmap.
4.2
Agenda Item 2.2 - Updates on
the research and development made on halon alternatives for cargo compartment
fire suppression systems
4.2.1
This agenda item was covered by
the presentation in Agenda item 2.1.
4.2.2
Laptop and other thermal
runaways in Lithium battery development
4.2.2.1
Mr. Kent Faith from Sprectrum FX provided information on lithium
battery fire and the available product for extinguishing. The available product
is not a replacement for halon and is a supplemental kit to existing handheld
extinguishers for lithium battery. The agent called Firebane is not rated for
electrical fire as it is conductive.
Conclusion
Status report
Lavatory fire extinguisher:
1)
There are currently two approved halon replacement agents FM-200 and
FE-36
2)
All new Boeing & Airbus aircraft presently use replacement agents
and Bombardier and Embraer will begin using a replacement agent as of January
2013.
Handheld Fire extinguisher:
1)
There are currently three replacement agents that are approved but not
installed:
a.
HCFC Blend B (Halotron 1)
b.
HFC-227ea (FM-200)
c.
HFC-236fa (FE-36)
These agents are up to twice the weight, are larger in volume, and have
up to 7 times the GWP.
2)
The FAA is funding a project for fire extinguisher design optimization
to reduce weight. Its focus is on:
a)
nozzle design;
b)
bottle design; and
c)
operating pressure
3)
Work continues to be done with 2BTP as it is a promising agent.
Commercialization for aviation is planned for 2014. 2BTP does not have the environmental, size, or weight issues of existing
approved halon replacement fire extinguishers agents.
4)
Industry has agreed to use approved agents if better alternatives are
not approved prior to the ICAO date.
Engine/APU fire extinguisher:
1)
Three replacement agents have passed the MPS and are SNAP approved
a)
HCF-125 (17.6% concentration)
b)
CF3I (7.1% concentration)
c)
FK-5-1-12 (Novec 1230) (6.1%
concentration)
2)
Novec 1230
·
not functioning as required by the MPS at low ambient temperature
·
agents use in question – More R&D needed
3)
CF3I
·
concerns with toxicity
4)
HFC-125
·
currently used by military
·
major weight and volume penalty
5)
Kidde Solid Aerosol (KSA) Testing
·
new non-gaseous agent
·
MPS developed concentrations unable to extinguish live engine fire.
·
additional R&D is in process
6)
The research is in progress and ICCAIA is not certain to be able to meet
the target date of 2014 for the engine/APU fire extinguisher.
7)
There is a replacement but it has weight and volume property.
8)
The representative
from EASA will inquire from the rulemaking department at EASA what would be the
course of action at the certification level if the applicant for a type
certificate doesn’t propose a replacement agent or alternative considering that
a certification plan changes with time.
Cargo fire extinguisher:
1)
Replacement agents tested – failed MPS
a)
HFC-125/FM-200: high HF concentrations, ignition of smoke layer
b)
CF3I: toxicity concerns
c)
2-BTP/Novec 1230: overpressures at below inerting concentrations during
aerosol can scenario
2)
Integrated fire protection - water mist/nitrogen system
·
passed MPS in early 2010
·
promising concept but requires significant development and acceptance
·
uses on-board inert gas generation system installed on aircraft to
reduce fuel tank flammability
3)
Airbus has proposed halon knock-down nitrogen system for A350
4)
MPS was developed in
2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering lithium battery
scenario. It may or may not require a
new test and/or amendment to the MPS.
5.
AGENDA ITEM 3: RECYCLED HALON
5.1
Agenda item 3.1 – Updates on
issues associated with the quality of recycled halon
5.1.1
Halon supply and quality of recycled
halon
5.1.1.1
Mr. R. Marcus of RemTec
provided the meeting with an insight to issues associated to the recycling of
and the quality of recycled halon (1211, 1301, and 2402). The presentation
informed the meeting of the supply and quality issues; recovery, reclamation
and destruction processes; quality control and testing of recycled halon; and
storage considerations.
The production of halon 1211 has ceased in industrialized countries
since 1 January 1994 and U.S. excise taxes apply to both new and used Halon
1211 imported into the U.S. Supplies of
Halon 1211 are limited and the quality of used installed inventory is
declining.
Halon 2402 is primarily used on Soviet Union / Russian
military and commercial aviation equipment and worldwide supplies are limited.
The production of halon 1301 ceased in industrialized countries 1 January
1994 and critical users are aviation, petrochemical plus and equipment
distributors servicing used equipment.
In 1993 the installed inventory was primarily in Japan, North America
and Europe. After 20 years the supply of used Halon 1301 is dwindling, quality
is declining especially if sourced from developing countries and many of those
countries restrict the export of halons. Japan does not allow export of halon.
As the quality and supply of halons has decreased, the cost to procure
and reclaim halons has increased, and in the last 5 years, the cost of
procuring recovered halon 1301 has augmented 100%.
Cross-contamination is becoming more prevalent the farther we move away
from virgin production end dates. As used halon and other “in demand”
halocarbons become more expensive, the incentive to intentionally blend-in
cheaper halocarbons such as R-22, forming increases.
5.1.1.2
The
presentation suggests that to successfully manage halocarbons, considerations
should be made to:
a)
provide
incentives to encourage recovery from end-users;
b)
institute
safe handling practices;
c)
document
and track agents and tanks;
d)
perform laboratory
testing for both the incoming material and the out-going finished product;
e)
establish
long-term strategic reserves for critical users; and
f)
continually
conduct leak testing and periodic physical inventories.
Conclusion
Recycled halon
1)
As the
quality and supply of halons has gone down, the cost to procure and reclaim
halons has gone up and in the last 5 years the cost of procuring recovered
halon 1301 has increased 100%.
2)
Halons are more difficult to recycle
due to cross contamination.
3)
Cross-contamination
is becoming more prevalent the farther we move away from virgin production end
dates. As used halon and other “in demand” halocarbons become more expensive
the incentive to intentionally blend in cheaper halocarbons such as R-22
increases.
4)
TCCA, in cooperation with the
FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means
to minimize the probability that non-compliant/contaminated agents will be
installed on aircraft.
6.
AGENDA ITEM 4 – PROGRESS MADE SINCE IHRCM/2
6.1
Agenda item 4.1 -
Presentations and discussions on alternatives to halon and progress of
implementation of the requirements of Annex 6 – Operation of Aircraft
and Annex 8 – Airworthiness of Aircraft for halon replacement.
6.1.1
EASA progress and plans
6.1.1.1
Mr. R. Deletain of EASA briefed
the meeting on EASA’s Rulemaking Tasks (RMT) on halon replacement. The meeting
was updated on the status of several RMTs.
In 2011 EASA
initiated a rulemaking task to amend CS-23, CS-25 and CS-29 in order to be
compliant with EU legislation and with the Amendment 103 to ICAO Annex 8. And
in 2012 CS-23 and CS-25 have already been amended and CS-29 is being amended
accordingly. The CS (Book 1) has
no reference to either halon or any other extinguishing agent and AMC/GM (Book
2) explains the reason for halon being phased out referring to Regulation
744/2010.
The EU
legislation implies compliance with applicable amendments to ICAO Annex 6 (i.e.
newly produced aircraft based on existing Type Certificates) only in 2025 (for
handheld fire extinguishers) and 2020 (for lavatories). EASA has planned RMT.0560 to comply with the
dates set in ICAO Amendments to Annex 6 which will be late for lavatories. It
will comprise of an update of EASA part 26 and propose a forward fit for
lavatory disposal receptacle and portable fire extinguishers in cabins and crew
compartments.
The halon
alternatives are sufficiently safe and suitable for handheld and lavatories
fire extinguishers bringing environmental benefits, with minimum economic
impact on aircraft manufacturers. This proposal complies with current ICAO
standards without a need for amending EU regulation 744/2010. The Notice of
Proposed Amendment (NPA) will be available by mid-2013 and anyone can comment.
EASA has also mandated
SAE (Society of Automotive Engineers) to develop Minimum Performance Standards
for (halon free) portable fire extinguishers to be used in aircraft and an ETSO
(European Technical Standard Order) will be published. There is a rule making
task (RMT.0206) in process and the NPA will be available in 2013.
In order to
align with ICAO Resolution A37-9 ‘halon replacement’ adopted during ICAO 37th
General Assembly, amendments to of Part- 145 and Part-M shall be made.
AMC/GM (Acceptable Means of Compliance /Guidance Material) will be
developed for production and maintenance organizations to verify the quality of
halon in their possession through testing and internal procedures. The notice
of proposed amendment (NPA) is planned for Q3 of 2013.
The following is
a summary of EASA actions:
RMT
|
STATUS
|
|
0273
|
New
applications for TC
|
CS-23
& 25 amended
CS-29
amended before end 2012
|
0560
|
Newly
produced aircraft
|
NPA
planned in 2013
|
0206
|
ETSO
for portable fire extinguishers
|
NPA
planned in 2013
|
0368
|
Contaminated halon
|
ToR
being drafted
NPA
planned in 2013
|
??
|
Engine
nacelles, APU and cargo compartments
|
No
obligation of any agent in CSs
Additional
RMTs could be planned
|
Filing
of Differences
Mr. Alain Coutu presented a summary
of the differences filed by States regarding the standards relating to halon
replacement:
Annex 6, 8
|
A 35 Annex 6
Part I, 6.2.2.1
(L, H)
|
A30 Annex 6
Part II, S II 2.4.2.3
(L, H)
|
A16 Annex 6
Part III, S II 4.2.2.1
(L, H)
|
A 6 Annex 6
Part III, S III 4.1.3.2
(L, H)
|
A103 Annex 8
Part II, 1.2.5
(L, E, A)
|
No Difference
|
13
|
20
|
17
|
16
|
19
|
Currently do not have such requirements
|
3
|
5
|
5
|
3
|
3
|
Will comply at a later Date
|
13
|
12
|
6
|
13
|
0
|
N/A
|
0
|
1
|
2
|
1
|
2
|
Total Replies
|
29
|
38
|
30
|
33
|
24
|
No States filed
differences stating they would not comply with the Standards. Most States
either declared no differences or would comply at a later date. The N/A means
the States do not have the activity in their State at this time.
6.2
Agenda item 4.2 - Report on
halon reserves based on States’ responses to the ICAO State questionnaire on
halon reserves.
6.2.1
Responses to ICAO State
Letter on halon reserves
6.2.1.1
Mr. Coutu also updated the
meeting on the responses received from States regarding halon reserve.
•
In May 2012 ICAO issued State
Letter AN 3/25.1-12/35
requesting information on halon
reserves accessible to the civil aviation industry within States to
follow-up on Assembly Resolution A37-9: Halon replacement, adopted by the 37th
Session of the ICAO Assembly. The resolution urges States to inform ICAO regularly
on their halon reserves of which ICAO is to report at the next Assembly, which
will be held in September 2013.
•
As of
October 2012 ICAO received 53 Replies to the
questionnaire on halon reserve.
•
To question No.1; “With the ban
……..do you anticipate that there will be enough halon to meet the civil
aviation needs of your State? Most States responded they were unsure of the
halon reserve while others responded N/A as they purchase it from an outside
source.
•
To question No. 2; “Do you know
the quantity of halon reserves accessible to the civil aviation industry in
your State in order to support its future operations? Most States replied no,
while several others replied N//A. Only 33 States replied they know their
reserves, 16 for halon 1211 and 17 for halon 1301.
6.2.2
Estimated Global Inventories
of Halons 1301 and 1211
6.2.2.1
Mr. T. Cortina presented, on
behalf of UNEP, their approach to estimate the amount of halon available. The
presentation also discussed the ownership of halon by region, the challenges in
procurement, and the availability of halon for civil aviation use.
No one “Knows” how much halon is left. We
know the global yearly production data, the global yearly estimated emissions
and comparing with atmospheric measurements of emissions we can estimates the
reserves.
Global quantities are irrelevant unless owned
by civil aviation. Some States have
import taxes while others have exporting laws prohibiting export of halon. It
is not only a reserve issue but also a regulatory issue. Halon reserves are
difficult to estimate as there are owners retaining supplies from
decommissioned systems for own uses/stockpile, large users like the US Dept. of
Defense and North Slope in U.S., maintain their own long-term reserves, and
some airlines may have their own reserve.
Reliance on halon “Banks” has implications,
one which is destruction for carbon credits. Ozone depleting substance (ODS)
have high global warming potential (GWP) similar to HFC alternatives.
(i.e.: Halon 1301 = 7,140, HFC-227ea = 3,220)
US Climate Action Reserve provides greenhouse
gas (GHG) offset credits for destruction of ODS (not currently halons) and
Australia will have a carbon tax in July 2013, which will be an incentive for
destruction of waste GHGs. Therefore users of halon could be competing in a market
with companies looking to destroy halons for GHG credits.
6.2.3
UNEP assessment of the responses to ICAO
State letter on halon reserve
There is a notable lack of response from States where we think there could be a lot
of halon and where filling of bottles now occurs. Although some States have
determined their supplies some did not know how much halon they had. While some
States believe that there is enough halon we are not certain how they could
determine that.
The following is a fairly typical answer of
the survey responses. Brazilian aircraft manufacturers, Embraer and Helibras
declared:
—
The halon used to fill the fire extinguishers of their aircraft is
provided by foreign suppliers.
Moreover, the two Brazilian airlines, TAM and
Gol, that retain approximately 75% of the civil aviation domestic market in
Brazil and are the only Brazilian airlines that operate international flights
declared:
—
The halon used to fill the aircraft fire extinguishers of their fleet is
also provided by foreign suppliers.
ANAC is unaware of any Brazilian company that
recycles halon to be used in aircraft fire extinguishers.
Therefore, the civil aviation halon needs in
Brazil depend on the availability of halon in the countries that supply the
Brazilian aircraft manufacturers and airlines.
On the subject of cargo compartment fire
extinguishing agent replacement, this is the largest use of halon on aircraft
and drives the quantities of halon needed for the long-term. With no end in
sight, it makes estimates of needs impossible to determine.
European Union has end and cut-off dates. We need
to consider now establishing a date for the replacement of halons in new
designs aircraft and the ICAO end dates help to support commercial research and
development of halon alternatives.
The presentation concluded with
UNEP suggesting the following:
a)
the need
to consider establishing a date to mandate implementation of halon alternatives
for aircraft cargo compartment;
a)
civil aviation still needs to
determine the long term needs for halon, where the requirements will come from,
and to report to Parties to the Montreal Protocol;
b)
resend ICAO State Letter AN
3/25.1-12/35 to States’ ozone focal point to canvass a broader response from
States to the State Letter; and
c)
consider developing guidance on
the collection and provision of
information on halon for aviation needs and halon reserves.
Conclusion
Progress made since IHRCM/2
1)
EASA has begun rulemaking and the following
is a summary of EASA actions:
RMT
|
STATUS
|
|
0273
|
New
applications for TC
|
CS-23
& 25 amended
CS-29
amended before end 2012
|
0560
|
Newly
produced aircraft
|
NPA
planned in 2013
|
0206
|
ETSO
for portable fire extinguishers
|
NPA
planned in 2013
|
0368
|
Contaminated halon
|
ToR
being drafted
NPA
planned in 2013
|
??
|
Engine
nacelles, APU and cargo compartments
|
No
obligation of any agent in CSs
Additional
RMTs could be planned
|
2)
Of the States who have filed differences, none have stated they will not
comply, and although some States stated no differences, others stated they
would comply at a later date.
Halon reserves:
1)
The HTOC model of global
inventories of halon is based on:
a)
production data known prior to
1996;
b)
estimate of yearly emissions by
region;
c)
estimate of yearly recovery
rates; and
d)
similar results from
atmospheric samplings validate the HTOC model
2)
The HTOC charts on the global
inventories of halon 1301 and halon 1211 is given in Appendix 2.
3)
No one “knows” how much halon is left. We know the global yearly
production data, the global yearly estimated emissions, and comparing with
atmospheric measurements of emissions, it is possible to estimate the reserves.
4)
Global quantities are irrelevant unless owned by civil aviation. Some States have import taxes while others
have exporting laws prohibiting export of halon. Therefore it is not only a
reserve issue but also a regulatory issue.
5)
Reliance on banks has the
implications that States may destroy halon for Carbon Credits:
a)
ODS have
high GWPs similar to HFC alternatives
i.
Halon 1301
= 7,140, HFC-227ea = 3,220
b)
US Climate
Action Reserve provides GHG offset credits for destruction of ODS (not
currently halons)
c)
Australia
carbon tax, incentives for destruction of waste GHGs including ODS in July 2013
d)
users of
halon could be competing in market with companies looking to destroy halons for
GHG credits
i.
Current
cost of Halon 1301 in US ≈ $33,000/tonne
ii.
At $20/tonne of CO2
equivalent = $142,800/tonne
6)
Responses from States to ICAO
State letter on halon reserve for civil aviation:
a)
little
evidence that States civil aviation and ozone offices worked together;
b)
notable
lack of response from States where possibly there could be a lot of halon and
where filling of bottles now occurs;
c)
little
evidence that States know how much halon is available to civil aviation
although some States believe there is enough halon, it must be difficult to
determine; and
d)
resend ICAO State Letter AN
3/25.1-12/35 to States’ ozone focal point to canvass a broader response from
States to the State Letter.
7)
European Union has end and cut-off dates. ICAO needs to consider now
establishing a date for the replacement of halons in new designs aircraft and
the ICAO end dates help to support commercial research and development of halon
alternatives.
7.
AGENDA ITEM 5: TIMEFRAME FOR
HALON REPLACEMENT IN CARGO COMPARTMENTS
7.1
Agenda item 5.1 – Propose a
tentative timeframe for the replacement of halon in aircraft cargo
compartments.
7.1.1
Establishment of Timeframe
7.1.1.1
Mr. Coutu briefed the meeting
on the ICAO Standard making process. It was explained that should a decision be
made on the timeframe for halon replacement in November 2012; the earliest
applicable date for a Standard in Annex 8 would be March 2018 and therefore
would be adjusted to the 31 December 2018 to correspond with EASA cut-off date.
ICCAIA
reiterated that it is too early to commit to a replacement date and committing
to a replacement date that the industry is uncertain of meeting. Aircraft designers
may be hesitant to apply for a new type certificate.
A representative
from Boeing stated that the process is difficult and flexibility is required.
ICAO reiterated that the process of standard making will lead to a date for the
replacement of halon in cargo compartment fire extinguishing system for new
design aircraft. In the Standard making process a date cannot be left open, an
implementation date is required.
UNEP stated that
with a replacement date of 2019, it will have been 20 years since the
production of halon ceased and States do not know how much halon is available for use by aviation. Will a
few more years help? If a date is not established now, it is likely that a replacement
will be available in the near future.
UNEP asked the
question: EASA has a dateline; what are the manufacturers going to do?
Airbus stated
that it is a big discussion right now within the organization and that although
very political and controversial they may have to request an exemption. At
least, this flexibility is available.
The meeting
asked how the new lithium battery test would impact the research. The
representative of the FAATC stated that it will not affect the progression of
the research.
FAATC also
stated that it is expected that the National Transportation Safety Board may
issue a recommendation for the installation of fire suppression system in cargo
airplane.
The concept of a
working group of the stakeholders was discussed again and could be used as a
collaborative decision making process to achieve the establishment of an
implementation date for the replacement of halon in cargo compartment.
ICCAIA committed
to lead the initiative and several stakeholders present offered their support.
The group should have a plan by early January 2013 that will provide a target
date, by which the group should have reached consensus, on a replacement date
for cargo compartment.
Conclusion
Timeframe for halon replacement in cargo compartment
1)
Research has not progressed
rapidly enough.
2)
ICCAIA has proposed to lead an
initiative to create a working group of stakeholders that will work together at
creating a roadmap that would define the processes required, as well as the role
of the stakeholders, and by January 2013 would propose a plan that would lead
to the establishment of a target date for the replacement of halon.
8.
AGENDA ITEM 6: ANY OTHER
BUSINESS
8.1
Study Regarding Fire Extinguishing/Suppression Agents’ Quality Processes
Mr. Claude Lewis
of Transport Canada briefed the meeting on their study. The quality of agents
in fire extinguishing and suppression systems has been brought into question as
a result of cases of contaminated halons found installed (or destined for
installation) on aircraft. TCCA, in
cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a
study to identify means to minimize the probability that
non-compliant/contaminated agents will be installed on aircraft. The study, which is being conducted (under contract) by R.G.W. Cherry &
Associates (UK ) is considering contamination potential for both new and
recycled agents, from agent production to filled vessels installed on aircraft, and accidental, as well as
intentional ‘opportunities’. The project
comprises two phases: 1) documenting the processes currently in use in North
America and in Europe, and 2) analysis to identify best practices as well as
deficiencies/gaps, and development of proposed standardized quality protocols.
The first phase, which involved the polling of stakeholders (manufacturers,
suppliers, recyclers, operators, test laboratories, etc.) is essentially
completed. Preliminary review indicates
that there are differences between the processes used in North America and in
Europe for the different ‘applications’, that there are no equivalent to UL/ULC
in Europe, and that third party
testing/sampling, when done, is an industry practice or is being conducted as a
contractual obligation. The second phase
has just been initiated and is expected to be completed in early 2013.
9.
AGENDA ITEM 7: CLOSING OF THE
MEETING
9.1
The meeting was concluded and
ICAO thanks all participants for sharing information and discussing these
issues. The meeting objectives were met and positive results can be reported at
the next assembly on the progress made with halon replacement.
The meeting ended at 1400 hours on 16 November 2012
— END —.
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