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Halon Extinguisher Subsector Monitoring and Evaluation Technical Guidelines

This guideline is to assist those involved in the monitoring and evaluation of Ozone Depleting Substances (ODS) phaseout projects better understand the technical requirements of projects which phaseout halon 1211 by converting fire extinguisher filling operations from use of halon to alternative extinguishing agents including ABC powder and carbon dioxide. Each technical evaluation should be based on five criteria: ODS phaseout quantity, compliance with safety and environmental standards, product and process performance, ease of technology transfer, and adherence to implementation schedule. Technical evaluations will complement information compiled through financial evaluations to provide a complete picture of the success of Multilateral Fund the Implementation of the Montreal Protocol (MLF) and Global Environment Facility (GEF) ozone protection activities in supporting developing countries to comply with the Montreal Protocol (MP).

The information obtained through monitoring and evaluation of MLF and GEF ozone protection projects will be used by developing country governments to develop ODS phaseout polices, report on compliance with the MP, and to develop future projects for MLF or GEF financing. The information will also be used by the MLF (or GEF) Secretariat to report to the MLF (or GEF Council) and the Parties of the Protocol on the success of the MLF and GEF. Finally, the technical evaluation information will be used by the implementing agencies to evaluate the success of projects and help in designing future projects.

General Approach to Monitoring and Evaluation of ODS Phaseout Investment Subprojects

The evaluator should apply the five criteria by addressing the set of questions outlined below. Each question is followed by technical guidance specific to the halon extinguisher sub-sector. These questions are designed to help the evaluator assess the extent to which the beneficiary has executed the project for which it received funding support. For each project, the subproject appraisal report should guide the evaluation. The evaluator would confirm that the project was completed as proposed and that the equipment which has been installed is the equipment for which funding was approved and that use of halon 1211 has ceased as a result of the project.

Note:
It is assumed in the preparation of these guidelines that the inspector/evaluator has training or experience in auditing techniques, particularly those with respect to financial accounting, analysis of material balances, shipping/receiving records, inventory control as well as some quality assurance auditing background. The objective of these guidelines has been to provide specific guidance or indicators particular to portable extinguisher conversion projects.

Specific M&E Questions and Technical Guidance

  1. How much ODS was phased out through the project and is there a risk of conversion back to ODS?
  1. Baseline Consumption.

    Accurate baseline assessment is key to establishing a projects overall effectiveness in terms of ozone protection impact. Baseline halon usage for halon extinguishers is established by multiplying the number of extinguishers produced for each extinguisher size by the amount of halon that corresponds to that size. Finally an estimate of leakage (1-3%) should be included in the total consumption estimate. (Baseline estimates for the year prior to project implementation or the previous three years should be included in the project appraisal report.)

    For example, if a company produced 10,000 5kg halon 1211 extinguishers and 3,000 2kg halon 1211 extinguishers during the previous year and average leakage during filling is 1% then the baseline ODS consumption would be: (5*10,000 + 2*3,000)*1.01=56.6. Since the ODP of halon 1211 is 3, the baseline ODP consumption would be 170 tons (rounded up to nearest one's place).
  • One straightforward method for determining these baseline figures is to examine shipping and receiving records, invoices, inventory, etc. to establish consistency between halon used and portable extinguishers shipped. In almost all cases, the Halon 1211 is purchased from a chemical producer; hence, product received is generally an accurate way of estimating gross consumption which will include handling and leakage losses. Another approach would be to check valve purchase records.

  • It is important to examine several years (prior to the phaseout) consumption/production records. If there are substantial differences between years, this may indicate that the 'baseline' year was artificially inflated.

  • Where recovering/recycling equipment has been procured, the leakage fraction or handling losses should be substantially reduced after the equipment was placed in service.

  • If servicing, re-charging, or hydrostatic testing is performed at the site, inventory and portable extinguisher shipping records will not directly correspond to 1211 product consumption, and quantities derived will need to reflect this.
  1. Key Equipment or Process Changes for Achieving Phaseout.

    In all cases, the inspector should confirm that the company no longer has a license to make halon extinguishers and that certification for replacement extinguishers has been obtained.
    • Conversion to ABC or dry chemical powder.

    1. A key change is the filling equipment. Bulk powder is used to fill extinguishers which are then charged with dry air, nitrogen, or fitted with small CO2 cartridges.

    2. Portable ABC powder extinguishers are similar to 1211 portables. There are, however, some modifications. The dimensions of the extinguishers cylinder are often modified, generally increasing the length of the ABC powder extinguisher relative to the Halon 1211 portable. Comparison of DCP extinguishers to design drawings or approval documents will verify the change.

    3. The valve design is usually modified in the conversion. Again, direct comparison of the DCP valve to the previously used 1211 valve will verify that this change is met. If the valves are purchased from outside, the specifications can and purchases may be confirmed with the supplier.

    4. Obviously, the inventory and shipping/receiving records of the quantity of dry chemical powder (which is readily observable) will be a good indicator of the conversion.
      e. There are generally strict labeling and/or name plate identification criteria for portable fire extinguishers. Observe such identification for required approvals, ratings, fire classification, etc. They will be distinct for ABC versus Halon 1211.
  1. Conversion to carbon dioxide extinguishers
  • A key indicator is the CO2 storage and filling system. There should be bulk storage of refrigerant CO2 at low pressure or a large number of high pressure CO2 storage cylinders.

  • The cylinder technology for CO2 extinguishers is quite distinct from 1211/ABC powder. CO2 requires spun high pressure gas storage cylinders as opposed to lightweight steel, seamless or welded pipe with welded ends. No part of the CO2 cylinder will be welded. These extinguishers do not have pressure gauges. Often, the cylinders (and/or valves) will be outsourced, a convenient way to check unit sales of CO2 extinguishers.

  • CO2 extinguisher valves and nozzles will be quite different than those used for Halon 1211 or DCP.

  • Nameplate and labeling information will be quite different as well as local fire authority approval.
  1. Verifying ODS Phaseout

All 1211 extinguisher conversions and subsequent 1211 phaseout assumes certain production and sale of DCP and CO2 portables. They generally require higher unit sales levels than 1211 since the cost of DCP portables is less than 1211. These can be readily verified by examining records as well as by physical examination of the filling operation, raw materials, and finished product. All of these can be readily differentiated from 1211 by examining items listed in (c) above.

Any servicing of existing 1211 extinguishers will occur independently of plant filling operations. The stock of 1211 including required material should be relatively small and will in general be insufficient for any sustained production. Recharging of halon cylinders from recycled stock will not in general be performed by a mass production filling line operation. Servicing (versus new cylinder filling) can also be differentiated by obviously used portable shells of different manufacturer and dates of manufacturer.

There will, in general, be several large customers or local distributors for an extinguisher manufacturer. A simple visit to one or more of these will verify the product actually shipped and/or installed.

  1. ODS equipment destruction.

The purpose of ODS phaseout projects is to convert the operations of ODS consuming enterprises to production with non-ODS. To realize the environmental benefit of these projects, ODS usage must be permanently discontinued. If, for example, the firm which carried out the conversion project transferred its old ODS based equipment to another firm which used the equipment to go into production with ODS, the environmental benefit of the original conversion project would be lost. Thus, any equipment which is replaced as part of a conversion to non-ODS technology should be destroyed or rendered unusable. Halon filling equipment is particular to halon usage and should be destroyed or rendered unusable following conversion to non-ODS. Halon filling equipment should not be used to create new servicing activities

  1. Was the non-ODS technology implemented in a safe and environmentally sound manner?
  1. Safety

    The conversion to ABC powder and CO2 creates no new manufacturing safety issues. Often, in conversion to ABC powder, enhanced ventilation is provided, particularly if bulk handling of powder or powder mixing/grinding operations are substandard. Verify during the plant visit that powder handling and filling operations areas do not indicate excessive airborne powder as evidenced by powder deposits over a wide area or visible solid aerosol.

  2. Environmental Issues

    The manufacturing processes for ABC powder and CO2 results in no new environmental issues.
  1. How does the performance of the non-ODS technology compare to the ODS technology?
  1. Processing Performance Indicators.

    To the greatest extent possible, processing efficiency should be maintained through the conversion from ODS to non-ODS. Processing efficiency is the rate at which quality products can be manufactured. The primary indicator of processing efficiency for halon extinguisher production is the baseline average daily production rate. This will almost always be higher for ABC powder than for 1211 portables due to economic requirements.

  2. Product Performance Indicators.

    To the greatest extent possible, product performance should be maintained through the conversion from ODS to non-ODS. Additional modifications to the production process may be required to achieve comparable product quality. In addition, a deterioration in product quality may be an indication of potential safety hazards or other liability. For fire extinguishers, performance relates to the quality of the extinguishing agent and the effectiveness of its release.
  • In most cases, the extinguisher will require an independent approval by a national, regional, or government body or a third party authority such as an insurance organization. Such approval will often require 'follow up' inspection services for quality assurance. The existence of such approvals should be checked as a first order indicator of performance of the extinguisher. These approvals can then be used to verify that currently manufactured extinguishers meet the original design. The lack of any such testing or approval indicates that the portable may not meet any minimum performance requirement.

  • In general, newly manufactured cylinders require hydrostatic testing. Evaluation of testing records will indicate the quality of cylinder manufacture. CO2 cylinders will be tested at much higher pressures than ABC powder extinguishers.

  • A good indication of filling operation quality is the net agent weight in each cylinder. The nameplate will record the tare weight. Spot checking gross weight will give a good indication of filling consistency.

  • Loss of agent or pressurant generally occurs through the valve over time. It is difficult to assess this for relatively recently manufactured stock. Examination of pressure gauges on ABC powder extinguishers or by agent weight in CO2 extinguishers on cylinders in stock is one approach. Evaluation of these parameters at either the distributors location or a large customer site is more reliable.

  • One significant quality problem can occur with ABC powders that are not treated properly, stored in high humidity environments, and/or filled with moist air. Caking in the powder which must be quite fluid can occur.
Dry chemical fire extinguishing powders are either purchased already ground to proper size particles or ground and treated on site. Ensure that the powder used for filling is the proper composition (as per specifications or approvals). Evaluate procedures for ensuring proper powder sizing and ensure that any powder sizing and ensure that any powder treatment is being performed.

Two approaches to evaluate this are to depressurize the portable (or remove the CO2 cartridge) and check the top surface of the powder. A more direct approach is to discharge the extinguisher (at a suitable location into a suitable device), note the discharge time, and check against the specifications to ensure that all of the agent is discharged.

  1. What difficulties, if any, were encountered in obtaining the CFC-free technology?

    The inspector should ascertain if the company had difficulty obtaining appropriate technology and note the cause of any problems and how they were addressed.

  2. What technology-related difficulties were encountered in carrying out the conversion?

    Implementation of the project involves many steps that can affect the implementation schedule as well as the projects ultimate success. This section should discuss problems encountered during implementation which affected the project implementation schedule. For example, the evaluator should note any difficulties that were encountered during procurement, including preparation of the bidding documents, evaluation of the bids, etc., which slowed project implementation. Another example could be installation issues that were not fully addressed in the proposal and subsequently delayed project completion.

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