AMEREX CORPORATION

P. O. Box 81

7595 Gadsden Highway

Trussville, AL 35173-0081

Phone: (205) 655-3271

Fax: (205) 655-3279

May 24, 2012

Melissa Fiffer

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

United States Environmental Protection Agency

Washington, D. C. 20460

Re: Incompleteness of SNAP Submission for K-ACE

Dear Melissa:

Thank you for the update in your April 3, 2012 letter and e-mail. Please find the following information 

in response to your questions.

End-Use Applications

1) The expected use of K-ACE is for total flooding in ground vehicles and does not include 

application in aircraft.

Cost and Availability

2) a) The estimated annual production of K-ACE of 150,000 lbs./year in 10 to 15 years is our 

projected estimated production specifically for ground vehicle protection and would not be 

considered at market saturation.

2) b) Assuming the total flooding market for Halon 1301 alternatives includes both commercial and 

military applications the estimated percentage of the market that 150,000 lbs./year represents 

would be less than 1%.

Occupational Exposure and End-Use

3) The discharge time for the specific military vehicle fire suppression system is 3 to 4 minutes, 

which is the time to release the entire contents of the agent tank. The settling rate will be 

based on airflow through the space but since the agent is discharged in small droplets similar to 

a water mist system we would anticipate the settling rate to be similar to that of a water mist 

system. K-ACE will not settle in the same way that an aerosol system would. In the event of an 

unwanted discharge, egress time for the crew inside a military ground vehicle would be 

estimated at less than 30 seconds.

4) The minimum number of people would be one (1), the average would be three (3), and the 

typical maximum number in a personnel carrier is nine (9). We would estimate the number of 

workers involved in clean up would be one (1) or two (2).

5) The contact pathways for occupational exposure at end-use would be inhalation and possible 

dermal.

Fire Suppression Specific Information

6) Hand portable fire extinguishers manufactured by Amerex Corporation that are intended for use 

in commercial kitchens, referenced in NFPA 10 as K-rated, use a proprietary mixture of a liquid 
extinguishing agent that consists of approximately 91% potassium acetate solution (50%/50%). 

K-ACE is 99+% potassium acetate solution (50%/50%) and although the primary ingredient in 

K-rated hand portable fire extinguishers we do not intend this product to be used on fires 

involving combustible cooking media. K-ACE is the primary ingredient in both the Amerex UL 

Listed K-rated hand portables and liquid restaurant fire suppression systems however, at this 

time, there is no intent to obtain UL Listing for the units intended for military application.

7) You are correct the design density would be 24 to 120 grams per cubic foot.

8) Attached is a report from Energy Research Consultants showing the heat of vaporization of KACE to be 42.42 KJ/mole or 1.393 MJ/Kg. The release rate, or application rate for K-ACE 

would typically be in the range of 20 grams/second to 80 grams/second for fire suppression and 

30,000 grams/second to 50,000 grams/second for explosion suppression.

Confidentiality

9. None of the information provided in the submittal package/application for SNAP Listing is 

considered confidential.

Please let us know if you have any additional questions.

Sincerely,

Amerex Defense