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 Env ironmental 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 percentag e 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 aver age 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 inhala tion 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 liquidextinguishing 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 t o 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 t he 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 K

ACE to be 42.42 KJ/mole or 1.393 MJ/Kg. T he 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 pro vided in the submittal package/application for SNAP Listing is

considered confidential.

Please let us know if you have any additional questions.

Sincerely,

Amerex Defense