# Environmental Protection A gency

SNAP LISTING

www.adsiarmor.com

230 Duffy Ave., Hicksville, NY 11801

Tel: (516) 390

‐ 5300 Fax: (516) 390

‐ 2970

THE INFORMATION CONTAINED IN THIS DOCUMENT IS PROPRIETARY TO

FIREFREEZE WORLDWIDE/AMERICAN DEFENSE SYSTEM. INC. AND FOR THE USE OF THE 

# Environmental Protection Agency .1 

# 19 July 2011 Mr. John F. Rutledge III Director Military Programs and Special Projects American Defense Systems, Inc. 230 Duffy Ave Hicksville, NY 11801 jrutledge@adsiarmor.com

Ms. Margaret Sheppard

Ms. Melissa Fiffer

Environmental Protection Agency (EPA) SNAP

RE: Environmental Protection Agency (EPA ) SNAP Form 1265-07 (Revised 06/2008) Cold Fire Application for Flooding 1301

Ms. Sheppard & Ms Fiffer

It is with great pleasure that FireFreeze Wo rldwide, Inc. and its agent American Defense Systems, Inc. (ADSI) submits EPA SNAP form 1265-07 application for additional listing of Cold Fire as a flooding agent under 1301.

In the following pages your will find a sign and completed application per your request. This applications in its entirety is contains confiden tial information relative to Cold Fire not to be

shared outside of the Government.

Additionally, in the I will be providing all documentation previously submitted, This will require more than one (1) email I will number the emails as 1 f 3, 2of3, 3of3.

I would like to thank you for all your support during this process of getting Cold Fire listed under the EPA SNAP Flooding 1301.

# Environmental Protection A gency

SNAP LISTING

www.adsiarmor.com

230 Duffy Ave., Hicksville, NY 11801

Tel: (516) 390

‐ 5300 Fax: (516) 390

‐ 2970

THE INFORMATION CONTAINED IN THIS DOCUMENT IS PROPRIETARY TO

FIREFREEZE WORLDWIDE/AMERICAN DEFENSE SYSTEM. INC. AND FOR THE USE OF THE 

# Environmental Protection Agency .2 

# Please contact me should you require a dditional information at 540-842-1678 or jrutledge@adsiarmor.com or Mr. Ray Giessler at 973-766-3816 or info@firefreeze.com

Regards,

John F. Rutledge Director Military Programs and Special Projects American Defense Systems, Inc.

Cc; Ray GiesslerForm 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 1 United States 

## ENVIRONMENTAL PR OTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 06/30/2011



## SNAP INFORMATION NOTICE

For Significant New Alternatives Date of Receipt:

Date 90 Day Review Begins:

Date Review Completed:

CBI Status: When completed send this form to:
Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA
U.S. EPA 1310 L STREET NW
1200 PENNSYLVANIA AVE NW 10 th FLOOR (MC 6205J) WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control Number



## INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit informat ion under the Significant New Alternatives Policy (SNAP) program for the review of

alternatives to class I and class II ozone- depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are required to provide this information on ne w substitutes to assist the Agency in a ssessing the acceptability of chemicals or processes that are considered alternatives for ODSs. A separate notice must be file d for each alternative you are submitting.

All submissions must be provided in three complete copies. If information is to be claimed as confidential, all confidential information must be excised from one of the copies, which will be placed in the public docket; the other two copies must includ e the confidential material. If no claims of confidentiality are made for the subm ission, all copies must be identical.

The attached “Guidance Manual for the SNAP In formation Notice” is designed to assist applicants in completing this form. The manual provides instructions on submitting a SNAP notice, asserting confidentialit y claims, completing the notice form, sectorspecific data requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives , this form must be filled out as complete ly as possible. Please provide all inform ation requested to the extent that it is known or reasonably ascertai nable. Make reasonable estimate s if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternat ive, Substance, or Formulation FireFreeze Worldwide SUBMISSION

Petition: New alternative, Substanc e, or Formulation__________________________________________________________ 

# 

Petition: Revision of the Existing SNAP list__________________________________________________________________ 

# 

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________ 

# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 2 You must provide the identity of the alternative chemical of processes and the identity and percentages of all components in a blend and/or process, even if you claim the identity as confidential. You may authorize another person to submit the identity for you, but your submission will not be complete and review cannot begin until EPA receives this
information.

Part II - ALTERNATIVE-SPECIFIC INFORMATION

Please indicate the sector(s) for which you are submitting information on the substitute by checking the appropriate

boxes:

• Refrigeration and Air Conditioning 

### 

• Foam Blowing 

### 

• Solvent Cleaning 

### 

• Fire Extinguishing
and Explosion Prevention 

### YES

• Sterilization 

### 

• Aerosols 

### 

• Adhesives, Coatings, and Inks 

### 

• Tobacco Expansion 

### 

• Pesticides 

### 

You may need additional copies of Part II if there are several manufacturing, processing, or use operations that you will

describe in this notice. Pleas e reproduce these sections as
needed.

If you substitute is also subj ect to review under FIFRA, provide the FIFRA Registration Number:

_____________________________ Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on the form to fully answer a question. Label each continuation sheet with the corresponding section heading and the question. In part IV, list these attachments and any test data, other data, or any optional information that you include in this notice.

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or control and to provide a description of all other data known to you if
these data are related to the health and environmental effects of the manufacture, processing, dist ribution in commerce, use, or disposal of the alternative. Standard literature citations may be submitted if they do not appear in the open scientific literature. Complete test data (in English), not summaries of data, must be submitted if they do not appear in the open literature. The following are test data and other data that might be submitted (see the Guidance Manual for a more complete list of data to be submitted.) Please indicate test data to be included in your submission notice by checking the appropriate boxes:

 Health Effects Data Yes

 Flammability Data  Yes  No

 Environmental Effects
Data YES

 Environmental Fate
Data YES

 Risk Assessments  Yes  No

1. Test Data Not in the Possession/

Control of the Submitter  Yes  No

 Other Data YES



## You must provide the identity of the alternative chemical of processes and the identity and percentages of all components in a blend and/or process, even if you claim the identity as confidential. You may authorize another person to submit the identity for you, but your submission will not be complete and review cannot begin until EPA

receives this information.

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentia lity at the time of submission for any data which are to be tre ated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information cla imed as CBI will be treated in a manner consistent with 40 CFR Part 2, Su bpart B. Failure to assert a claim of confidentiality at the time of submission may result in disclosure of information by the Agency without further notice.

To assert a claim on this form, circle or bracket the informat ion you claim as confidential and mark the confidential box at th e bottom of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confi dential, you must provide a “sanitized” ve rsion of this notice, including attachments, to EPA with our submission. For additional infor mation on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies des ignated as Authorized Representatives of the United States Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and implementation of national regulat ions for the protection of stratospheric ozone, including the development of the SNAP program

. These Authorized Representatives may have access to any informat ion received by the Stratospheri c Protection Division within EP A Office of the Atmospheric Programs for use in reviewing the need for possible control of any subs tance, practice, process or ac tivity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that these companies can complete the wo rk required by the contract.

Authorized Representatives of the Administ rator are subject to the pr ovisions of 42 U.S.C. 7414(c ) respecting confidential busi ness information as implemented by 40 CFR 2.301(h).Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 3 Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (in U.S.)

RAYMOND GIESSLER COO

_____________________________________________________________________________________________________________ Name of Authorized Official Title

FIREFREEZE WORLDWIDE INC

____________________________________________________________________________________________________________ Company/Organization

272 RT 46 EAST ROCKAWAY NJ 07866 TEL: 973-627-0722 FAX: 973-627-2982

____________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

(b) Agent (if applicable) JOHN RUTTLEDGE Director of Military Programs and Projects

____________________________________________________________________________________________________________ Name of Authorized Official Title AMERICAN DEFENSE SYSTEMS, INC.

____________________________________________________________________________________________________________ Company/Organization 420 McKinney Parkway Lillington, NC 27546 Tel: 540-842-1678 Fax 910-514-97 02

____________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________ Name of Authorized Official Title

____________________________________________________________________________________________________________ Company/Organization

____________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

2. Technical Contact (in U.S.)

RAYMOND GIESSLER COO

__________________________________________________________________________________________________________ Name of Authorized Official Title

FIREFREEZE WORLDWIDE INC

_________________________________________________________________________________________________________ Company/Organization

272 RT 46 EAST ROCKAWAY NJ 07866 TEL:973-627-0722 FAX 973-627-2982

__________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phon e, etc.) and the EPA staff person’s name:



## Margaret Sheppard Melissa Fiffer

Environmental Scientist Stratospheric Protection Division

email: sheppard.margaret@epa.gov Fiffer.Melissa@epamail.epa.gov

Mark (X) if None _____

Mark (X) this box if this page contains CBI ____Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 4 Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative:

COLD FIRE / Cold Fire Tactical

2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/ or process name. For blends, provide the percent composition of each

constituents. (b) Chemical Abstracts Service (CAS) registry number and molecular formula. (c) For alternative processes and tec hnologies describe the technology an d and pr ovide a diagram of the system. Also prov ide the information on any chemical constituents. (d) If you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attac hment. If you have submitted a patent application but have not been granted one yet, indicate the da te submitted and the expected time frame for a response.

PROPRIETARY FORMULA HAVING NO KNOWN HAZ SUBSTANCES

a. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provide d to support EPA SNAP Flooding 1301

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conduc ted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing was conducted by the US Government and is under review. If requested we will provide the Contracting officer informati on if the EPA needs to review testing.

3. Generic chemical name (if chemical name of subs titute is declared Confiden tial Business Information).

b. The formula of COLD FIRE is confidential and sensitive info rmation. Due to the number of companies that have made efforts to copy the formula and make-up of Cold Fire over the years causing legal action at a great expense to Fire Freeze

Worldwide.

c. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Mark (X) this box if this page contains CBI _____XX__________Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 5

4. Specific End-Use

(a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e .g. terpene-based semi-aqueous solvent cleaner for electronic parts, or HFC subs titute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A to the instructions, beginning on p. 19. (b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for ea ch end use in pounds (replace ment ratio).

Cold Fire is an aqueous fire suppressant agent. This has been categorized as a Firefighting Foam Agent (NOTE: NOT TO BE CONFUSED WITH AFFF TYPE FOAMS). Cold Fire product has been UL Classified

 Structure fires

 Structure protection from fires

 Cool-down of embers on firefighters and other protective applications

 Tire fires

 Vehicle fires

 Paint and oil-based fires

 Automotive, aviation and ship board fuel fires

 Fuel storage tanks close to fires (keeping them cool)

 Rapid cool-down of military equipment in combat related events i.e. IEDs, VBIEDs, and EFPs

 Protection of hazardous or explosive material from oncoming fires

 Creation of a heat barrier to help prevent heat damage and hidden fires

 Closed loop systems such as sprinkler systems and on-board extinguishing systems *The above are just a few applications of CF

Cold Fire is listed on EPA SNAP Streaming 1211

Cold Fire is UL Classified: 2N75

Cold Fire is NFPA 18

Cold Fire Is NFPA 13

The Purpose of this application is to have Cold Fire and Appr oved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI _____XX__________Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 6 Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. (a) Identify each impurity that may reasona bly be anticipated to be present in the chemical alternative as manufactured for commercial purposes. If there are unidentifie d impurities, enter “unidentified.” (b) Provide the CAS Registry Number if available. (c) Estimate the maximum weight percentage of each impurit y. If there are unidentified impurities, estimate their total we ight
percentages.

a. Cold Fire has no impurity that may reasonably be an ticipated to be present in the suppressant agent.

a. It should be noted that documented testing was provide to the EPA under different letter.

b. Cold Fire has no CAS registry number

c. Cold Fire has no impurity

d. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, Fire Freeze Worldwide is listed on the EPA SNAP website as an Alternative Approved Manufacture for altern ative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

6. Byproducts: (a) Describe any byproducts of degr adation products resulting from the manufacturer , processing, use or disposal of the che mical alternative

or chemicals used in the new alternative. If there are unidentified byproducts/ de gradation products enter “unidentified.” (b) Provide the CAS Registry Number if available. (c) Indicate where the byproduct/degradation product is form ed (e.g. during manufacturing, during use, etc.) and the amount or rate at which

it is formed.

a. Cold Fire has no byproducts of degradation resulting from the manufacturing process.

b. Cold Fire has no CAS registry number

c. Cold Fire has no byproducts of degradation resulting from the manufacturing process.

d. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, Fire Freeze Worldwide, Inc. Is listed on the EPA SNAP webs ite as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI _____XX______Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 7 Part II - ALTERNATIVE- SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight: 9 LBS PER GALLON 2. Physical state at 20  C N/A

3. Melting point: N/A 4. Boiling point at 1 atm. Pressure

SAME AS WATER  C

5. Specific gravity g/ml 6. Odor threshhold mg/m3

7. Solubility using solvent 100% WITH WATER @ temperature  C g/L

8. Solubility in water @ temperature  C

9. Partition coefficient : N/A Log K ow 

### Log K 

10. Vapor pressure @ 20  C: N/A psi 11. Critical temperature

 C 12. Critical Pressure psi

13. Are spectra attached? N/A 14. Disassociation constant: N/A

15. Particle size distribution : SYSTEM MAKES SIZE 16. Volatilization from soil: NA

17. Volatilization from water: NONE 18. Viscosity @ 20  C: HEAVIER THEN WATER

19. pH@concentration : 7 20. Thermal conductivity: SAME AS WATER

21. Adsorption coefficient N/A 22. Flammability limits (LFL, UFL) N/A %
vol

23. Flash point: N/A 24. Heat of combustion NA

25. Maximum pressu re rise: N/A 26. Maximum rate of pressure rise: None

27. Other (specify)

28. Provide any information on flammability concerns. For example, if any abatement techniques are being us ed to minimize the risks
associated with flammable substances or mi xtures, detail those techniques below. If a substitute is flammable, an assessment o f overall risk in each end-use may be required. (See Instructions for sect or-specific data requirements for flammable substances).

1 . Cold Fire is fire suppressant agent and is 100% Non-Flammable.

Mark (X) this box if this page contains CBI __XX_______Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 8

1. Ozone-depletion potential (ODP): (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the subs titute is a blend, provide the O DPs of individual

constituents. (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bro mine loading potentials). Reference the source of this info rmation and attach any supporting documentation.

a. Cold Fire formula has been approved for EPA SNAP streaming 1211 so there is no Ozone-depletion potential. This application is to use the same agent( Cold Fire) for EPA SNAP Flooding 1301

b. Non- applicable

2. Global Warming Characteristics: (a) Provide the alternative’s global warming potential (G WP) relative to carbon dioxide over 100- and 500-year time horizon s, if known. If the substitute is a blend, provide th e GWPs of the individual constituents. (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g . +/- X%) and results of any testing or modeling done (bot h theoretical and actual testing). (c) Provide source of GWP or any additional data on the GW P of the alternative, including the atmospheric lifetime, infrare d absorption spectrum, and infrared absorption cap acity. If the alternative (e.g. CO 2 captured from a stream of waste ga s as a by-product of fermentation).

1. Cold Fire has no effect or characteristics that affect Global Warming.

a. Official Government testing was conducted at U.S. Army Proving Grounds, Aberdeen Testing Center, during the May/ June 2011 time frame in support of the United States Marine Corps, Automated Fire Suppressant Extinguishing – Replacement (AFER-R) system used to deliver Cold Fire.

b. The Purpose of this application is to have Cold Fi re and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI ____XX______ 

## Part II - ALTERNATIVE-SPECIF IC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATIONForm 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 9

Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether an d how the alternative is regulated under other environmental regulator y statutes, for example other tit les under the Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Dri nking Water Act (SDWA), the Resource Conservation and Recovery Act (RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Comprehensi ve Environmental Response, Compensation and Liability Act (CERCL A), the Emergency Planning and Community Right-to-Know Act (EPCRA, also known as SARA Title III), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the above standards and regulations.

Cold Fire is listed on EPA SNAP Streaming 1211

Cold Fire is UL Classified: 2N75

Cold Fire is NFPA 18

Cold Fire Is NFPA 13

a. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. With out any changes to the formula Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing. Mark (X) this box if this page contains CBI ___XX_______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 10

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the O ccupational Safety and Health Administratio n (OSHA), the Department of Transportat ion (DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-s etting organizations such as the National Fire Prevention Associ ation (NFPA) or the American Society of Heating, Refrigerating, and Air C onditioning Engineers (ASH RAE), by which the substitute is evaluate d.

Cold Fire is listed on EPA SNAP Streaming 1211

Cold Fire is UL Classified: 2N75

Cold Fire is NFPA 18

Cold Fire Is NFPA 13

a.The Purpose of this application is to have Cold Fire and A pproved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without an y changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI ___XX_______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 11 Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

2. Estimate the cost per pound for the substitute chemical. For a lternative processes and technologi es, describe installation cos ts associated

with the alternative

1.The estimates cost for Cold Fire is $18.00 per gallon there is no cost associated with using Cold Fire as a wetting agent.

2.The Purpose of this application is to have Cold Fire and A pproved EPA SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

2. Provide information on production of the substitute. Include estimates on:

(a) Year substitute will be available if not currently produced. Cold Fire is currently produced

(b) Total pounds production per year (current figure). Cold Fire is a suppressant agent ( N/A)

(c) Years to maximum market penetration. N/A

(d) Maximum total production per year at market saturation. N/A

(e) Estimated percentage of market at market saturation . N/A

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# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 12

3. Describe any new equipment and use profiles. If retrofitti ng of existing equipment is required, detail changes in technolo gies needed to use the alternative and address any materials compatibility issues. Provide informati on on each end-use and capital costs associat ed with the
substitute or alternative process. Include cost of equipment and/or any new material s, equipment lifetime, changes in labor an d energy costs



## .

1. The Automated Fire Extinguishing System- Replace (AFES-R) was designed to perform a very specific function. The AFES-R system was designed for USMC to protect military personnel in mili tary vehicles (only) this is not a commercial application.

 The number of personnel in a HMMWV could be one (1) to five (5).

o 1-Driver, 1-Vehical commander, 2- Passengers and 1- Gunner (manning the 50 Cal. Machine Gun.

o Note: The Gunner sits in a position where the upper half of his body is outside the crew cab in an open

turret.

2. The AFES-R system was designed for use in the present fielded HMMWV’s. The requirements of the AFES-R system were developed by the USMC. This being the first AFES-R system using a wetting agent suppressant system to be tested and field by t he USMC information on the requirement development is unknown. To meet the AFES-R equipment’s requirements of space and weight we are designed a two (2) gal hydro-nomadic tank for maxi mum agent dispersion. Additionally, and most important is to extinguish fires and provide maximum protection from burns to the Marine allowing increase time to egress a burning HMMWV.

NOTE: The Cost information for the equipment, material, equipment life is pr esently under a US Marine Corps solicitation for competitive bid. Presently the AFES-R system has been tested at China Lake Naval testing facility, has be under review by USM C Source teams, has complete a round of Live Burn test, as well as dur ability testing at Aberdeen provin g Grounds, Aberdeen Testing Cent er. So at this time I am restricted from prov ided the requested information’s.

Mark (X) this box if this page contains CBI ___XX______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 13 Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and fo r chemicals used with alterna tive processes, summarize below (and attached supporting informati on) the acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, and plants), if available. Include any data on impurities and degradation pr oducts if known. Also include information on any “All owable Exposure Limits” (AELs) that have been set for the substitute for use in the workplace. In addition, please attach a copy or f acsimile of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is r easonably likely to be exposed. (See Guidance Manual fo r sector-specific data requirements).

1. In response to this section the U.S. Department of Agriculture testing conducted for the U.S. Forestry Service address’s all information requested above. The DoA test ing is provided with this submission.

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.



## Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

(a) Identify all site locations (i.e. name and address) for each chemi cal manufacturing process. (b) Identify all site locations for manufacturing of pr oducts using substitutes (e.g. refrigerators containing the substit utes). (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products cont aining the substitutes. (d) Provide information on the magnitude of release if av ailable, along with the media to which the substitute is released (e.g. indoor air, outdoor air, water, land).

a. Cold Fire is agent mixing is accomplished at the Firefreeze facility located at :

a. 429 ROCKAWAY VALLEY ROAD BLDG 8 AND 9 BOONTON TWP NJ 07005

b. None applicable

c. Cold Fire is liquid agent that if spill ov er accrues during mixing or filling it has been tested to be 100% Bio- Degradable and is washed away with water.

d. Not available

e. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA SNAP Flooding 1301. Without any changes to the formula

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, Fire Freeze Worldwide, Inc. is listed on the EPA SNAP Webs ite as an Alternative Approved Manufacture fo r alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center, All testi ng was conducted by the US Government and is under review. If requ ested we will provide the Contrac ting officer information if t he EPA needs to review testing.

Mark (X) this box if this page contains CBI __________ 

# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 14 Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of su bstitutes and/or products containing substitutes):

(a) Describe the activities in whic h workers may be exposed to chemicals. (b) Describe any protective equipment and engineering c ontrols used to protect workers (e.g. goggles, gloves, chemical hoo ds). (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas (d) Estimate average and maximum numbers of workers involved in each activity. (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hour/day and (2) days/year. (f) Enter the contact pathway (e.g. inge stion, inhalation, derm al). FORESTRY REPORT (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure.

a. Blended in Agent ( chemical) containment Tanks

b. N/A Basis eye protection (safety gla ss) and OSHA eye washing station

c. Cold Fire has a combinations of Liquids /Solids/Powders all of which are not ha rmful during mixing of the Cold Fire

Formula

d. Two(2) to Four (4) employees

e. N/A

f. None



## Section D - ENVIRONMENTAL RELEA SE AND DISPOSAL IN END-USE

For each end-use of a substitute:

(a) Provide the estimated amount (in kg/day) of each chemi cal released directly to the e nvironment (e.g. as a hazardous wa ste or wastewater effluent) at a site using the substitute (e.g. in products containing the substitute and processes using the substit ute). (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release poi nt. (c) Describe the control technology used to limit release; estimate the amount released to the environment with the contro l technology in place to limit release. If the subs titute is to be disposed of, indicat e the method and location of disposal. (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. (e) Identify the appropriate number of sites expected to use the substitute. (f) Provide information on recycling of the subs titute. Describe any associated costs and equipment.

1.In response to this section pl ease review the testing package provided. Please pay particular attention to the Department of Agriculture testing conducted for the U.S. Forestry Service.

2.Cold Fire Is 100% Bio- Degradable with no adverse effects on the environment

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, Fire Freeze Worldwide, Inc. is listed on the EPA SNAP Webs ite as an Alternative Approved Manufacture fo r alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center, All testi ng was conducted by the US Government and is under review. If requ ested we will provide the Contrac ting officer information if t he EPA needs to review testing.

Mark (X) this box if this page contains CBI __________ 

# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 15 Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in pr oducts and/or processes):

(a) Describe the activities in whic h workers may be exposed to chemicals. (b) Describe any protective equipment or engineering c ontrols used to protect workers (e.g. goggles, gloves, chemical hood s). (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). (d) Estimate average and maximum numbers of workers involved in each activity. (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year. (f) Enter the contact pathway (e.g. ingestion, i nhalation, dermal). (g) Estimate the average and high-end exposure concen trations (separated by a /), being sure to provide units.

a. Blended in Agent (chemical) containment tank (all chemic als are non- hazardous in mixed and un-mixed state.

b. N/A Basis eye protection (safety gla ss) and OSHA eye washing station

c. Cold Fire has a combinations of Liquids/S olids/Powders all of which are harmful du ring mixing of the Cold Fire Formula

d. Two(2) to Four (4) employees

e. N/A

f. None

g. None



## Section F - CONSUMER EXPOSURE

For each end-use of a substitute:

(a) Identify the potentially exposed population (e.g. indoor residents). (b) Identify the exposure medium (e.g. air). (c) Enter the contact pathway (e.g. ingestion, i nhalation, dermal). (d) Enter the exposure point of concentrati on. Provide (1) average and (2) high-end estimates.

1. In response to the above (a thru e). A complete testing pa ckage has been provided under different letter. As part of the s ubmission

we have reattached to the submission email. Additionally, We will attach a copy of the final test report from Department of Agriculture Cold Fire Test conducte d for the US Forestry Service.

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI ___XX______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 16 Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULA TION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

(a) Identify and number potential exposure points. (b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline ). (c) Identify the c ontact pathway (e.g. ingesti on, inhalation, dermal). (d) Identify the exposure medium (e.g. air, water). (e) Enter the exposure point concentration (mg/m 3 ). Provide (1) average and (2) high-end estimates.

1. In response to the above (a thru e). A complete testing pa ckage has been provided under different letter. As part of the submission

we have reattached to the submission email. Additionally, We will attach a copy of the final test report from Department of Agriculture Cold Fire Test conducte d for the US Forestry Service.

Note1: Cold Fire agent test provid ed to support EPA SNAP Flooding 1301 Note2: It should note that Cold Fire is presently listed on th e EPA SNAP listing for Streaming 1211. There is no change to pro duct (Cold Fire) formula. Note3: Additionally, FireFreeze Wo rldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for alternative replacement of Ozone depletion products. Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aber deen Testing Center; All testin g was conducted by the US Government and is under review. If re quested we will provide the Contra cting officer information if th e EPA needs to review testing.

Mark (X) this box if this page contains CBI ___XX_______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 17 Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the que stions on this form or that provide additional information tha t may assist

EPA’s review of the alternative under Section 612 of the Clean Ai r Act. Also, provide citation for information already submitt ed to EPA as part of past regulatory and information activities, as well as fo r other information that could not be included with this submi ssion. If you have attached continuation pages, describe the Part, Section and question numb er being continued. Attach additional pages if necess ary.

Attachment Name Question # Number of Pages CBI



# Initial letter to EPA SNAP dt d 31 March 2011w/ testing

Response to EPA SNAP questions dtd 14 June 2011

Department of Agriculture ( US Forestry Service ) official test reports Cold Fire

Cold Fire MSDS

Initial Cold Fire Power Point Presentation

Mark (X) this box if this page contains CBI __XX______



# Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

## 18 Part V - CERTIFICATION

I certify to the best of my knowledge and belief that:

1. All information provided in this notice is complete and truthful as of the date of the submission.

2. I am submitting with this notice all test data in my possession or contro l and a description of all other data known to or reasonably ascertainable by me.

3. If this is a submission of a new alternative, the company name in Part I, Qu estion 1a of this notice: (a) Intends to manufacture, formulat e, import, market, or use a new alternative to a Class I or Class II ozone-depleting substance which is identified in Part Me, Section B, Question 2. (b) seeks an acceptability determination on a new alternative(s) to a Class I or Class II ozone-depleting substance, which is identified in Part I, Section B, Question 2.

4. The accuracy of the statements made in this notice reflects my best prediction of the anticipated facts regarding the alternative described herein. Any knowing and willful misinterpr etation is subject to criminal penalty pursuant to section 113 (c) of the Clean Air Act and 18 U.S.C.§1001.



## Signature and Title of Authorized Official (Original Signature Required) : Date

“signed “ Raymond Giessler COO 19 July 2011

Signature of Agent (Where Applicable): Date

19 July 2011

For persons filing a SNAP Information Notice, the reporti ng burden is estimated to average 150 hours per year. For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 46 hours her year. Burden means that total time, or financial resources expende d by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instruction; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a co llection of information unless it displays a currently valid

OMB control number.

Send comments on the Agency’s need for this informati on, the accuracy of the provide d burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency,1200 Pennsylvania Ave NW, Washington, DC 20460. Include the OMB c ontrol number in any correspondence. Do not send the completed form to this address.
Mark (X) this box if this page contains CBI __XX______



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