Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 1 United States 

### ENVIRONMENTAL PROTECTION 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 Compl eted:

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

SNAP DOCUMENT CONTROL OFFICER SNAP D OCUMENT 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 F LOOR (MC 6205J) WASHINGTON, DC 20460 WASHINGTON, DC 20005

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

### 154 Document Control Number



### INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to su bmit information 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 informati on on new substitutes to assist the Agency in assessing the acceptability of chemicals or processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting

.

All submissions must be provided in th ree 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 incl ude
the confidential material. If no claim s of confidentiality are made for the submission, all copies must be identical.

The attached “Guidance Manual for the SNAP Information Notice” is designed to assist applicants in completing this form. The manual provides instructions on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sector

specific data requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as pos sible. Please provide all information requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailabl e.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________ 

## x

Petition: New alternative, Substance, or Formulation__________________________________________________________ 

# □

Petition: Re vision 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 n ot 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 su bstitute by checking the appropriate
boxes:

• Refrigeration and Air Conditioning 

# □

• Foam Blowing 

# □

• Solvent Cleaning 

# □

• Fire Extinguishing

and Explosion Prevention 

## x

• 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. Please repro duce these sections as
needed.

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

_____________________________ Part III

- RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessa ry.

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 atta chments 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 yo u if
these data are related to the health and environmental effects of the manufacture, processing, distribution 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 da ta to be submitted.) Please indicate test data to be included in your submission notice by checking the appropriate boxes:

 Health Effects Data 

## x Yes 

## □ No

 Flammability Data 

## □ Yes 

## x No

 Environmental Effects Data 

## x Yes 

## □ No

 Environmental Fate Data 

## □ Yes 

## x No

 Risk Assessments 

## □ Yes 

## x No

 Test Data Not in the Possession/

Control of the Submitter 

## □ Yes 

## x No

 Other Data 

## x Yes 

## □ No



### You must pr ovide 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 confidentiality at the time of submission for any data which are to be t reate d as Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information c laimed as CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidential ity 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 information you claim as confidential and mark the confidential box at the bottom of the page . Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, you must provide a “sanitized” version of this notice, including attachments, to EPA with our submission. For additional inf ormati on on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States Environmental Protection Agency (EPA) under an EPA cont ract for the purpose of assisting EPA in the development and implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP progr am. These Authorized Representatives may have access to any informati on received by the Stratospheric Protection Division within EPA Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that these companies can complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential bu si 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.) 

## Bob Langer Vice P resident & General Manager Amerex Defense

_____________________________________________________________________________________________________________ Name of Authorized Official Title 

## Amerex Corporation

, Amerex Defense

____________________________________________________________________________________________________________ Company/Organization 

## 7595 Gadsen Highway, Trussville, AL 35173

- 0081 205

- 655

- 3271 20 5

- 655

- 0976 (fax)

____ _____________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

(b) Agent (if applicable) 

## Thomas Cortina President

_______________________________________________________________________ _____________________________________ Name of Authorized Official Title 

## Cortina Environmental Consulting Inc.

____________________________________ ________________________________________________________________________ Company/Organization 

## 9206 Bexleywood Court, Fairfax Station, VA 22039 703

- 646

- 4808 571

- 384

- 7959 (fax)

___________________________________________________________________ _________________________________________ 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.) 

## Bob Langer Vice President & General Manager Amerex Defense

__________________________________________________________________________________________________________ Name of Authorized Official Title 

## Amerex Corporation , Amerex Defense

_________________________________________________________________________________________________________ Company/Organization 

## 7595 Gadsen Highway, Trussville, AL 35173

- 0081 205

- 655

- 3271 205

- 655

- 0976 (fax)

__________________________________________________________________________________________________________ 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, ph one, etc.) and the EPA staff person’s name: 

## Meeting on April 15, 2011, with Nathani el Jutras and Margaret Sheppard, phone call on October 20, 2011 with Margaret Sheppard and Bella Maranion, emails

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)

Secti on B

- ALTERNATIVE IDENTIFICATION

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


### K

- Ace

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

constituents. (b) Chemical Abs tracts Service (CAS) registry number and molecular formula. (c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information on any chemical constituents. (d) If you hold a pa tent on the substitute, provide the patent name and number and include a copy of the patent as an attachment. If you have submitted a patent application but have not been granted one yet, indicate the date submitted and the expected time fram e for a respo nse.



### Potassium a cetate, 50%, CAS# 127

- 08

- 2

Formula: C 2 

### H 3 

### KO 2 

### Water, 50%, CAS# 7732

- 18

- 5

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information).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 substitute refrigerant for centrifugal chillers). For a list of end use s, 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 each end use in pounds (replacem ent ratio).



### K

- Ace (potassium acetate solution) is being proposed as a replacement for Halon 1301 in water mist type total flooding and local application fire suppression and explosion protection systems in normally occupied and unoccupied areas

. Types of applications include the following:

 Military vehicle crew compartment fire suppre ssion (p roduct developed and performance tested at Aberdeen Testing Center for a specific US Marine Corp program)

 Military vehicle crew comp artment explosion suppression (p roduct in development phase)

 Military and commercia l wheel well fire suppression (lo cal application in a normally un occupied area)

 Military and commercial engine compartment fire suppression (application in a normally un occupied area)

 Military and commercial equipment storage and cargo compartment fire suppression (a pplication in an

occup iable space)

Spaces being protected are enclosed spaces with minimal un

- closable openings. The primary fuels encountered are Class B flammable liquids with smaller amounts of Class A combustibles. Volumes of protected spaces are typically in the range o f 50 cubic feet to 500 cubic feet. Crew compartment volumes (normally occupied spaces) range from 100 to 250 cubic feet.

Airflow through the protected space varies drastically from occupied crew compartments to un

- occupied engine compartments. Airflow t hrough crew compartments can range from 25 CFM to 150 CFM, most of the air being

re

- circulated. Typical air changes in the crew compartment are on the order of one (1) air change every 3 to 20 minutes. Airflow in engine compartments can be on the order o f 50,000 or more CFM with typical air changes of 100 to 500 air changes per minute.

The agent is dispersed in a conical pattern with a cone angle slightly less than 90 degrees. The pattern is considered solid with droplet distribution relatively even thr oughout the cone. Nozzles are aimed to apply agent to the hazard surface being protected developing a fine mist similar to a water mist system. The attached test report entitled ”Nozzle Characterization: Droplet Sizing (Amerex Nozzles 1 and 2)” provides photos, a description of the discharge pattern, and details of droplet size at varying distances both axially and radially. Average droplet size based on data collected from over 300,000 samples was 39.3 microns. Droplet sizes ranged

from 0.042 to 555 mi crons with greater than 99.99% of droplets being 5 microns or larger.

Unlike gaseous agents there is no cup burner or minimum extinguishing concentration determined. The quantity of agent is determined from full

- scale fire tests for the specific hazard/f uel to be protected. Typical design concentration/density is in the range of 0.005 to 0.025 gallons per cubic foot. The typical one

- gallon cylindrical system container is 6 inches in diameter and 14.2 inches tall (not including system valve) for a volume of approximately 400 cubic inches with an internal volume of 330 cubic inches.

Attached is a paper by the Naval Research Laboratories that assesses the fire suppression properties of mists of aqueous potassium acetate. It concludes that the addition of potassium acetate “substantially increases the fire suppression effectiveness of the mist.” Also attached is a paper by the US Army that evaluates the potential of different agents, including a potassium acetate solution, to be used for protection of crew compartments in military ground vehicles.

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

# □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 reasonably be anticipated to be present in the chemical alternative as manufactured fo r commercial purposes. If the re are unidentified impurities, enter “unidentified.” (b) Provide the CAS Registry Number if available. (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weig ht
percentages.



### Attached is a technical data sheet that lists the impurities in the potassium acetate solution as purchased.

6. Byproducts: (a) Describe any byproducts of degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative or chemicals used in the new alternative. If there are unidentified byproducts/ degradation products enter “unidentified.” (b) Provide the CAS Registry Number if available. (c) Indicate where the byproduct/deg radation product is formed (e.g. during manufacturing, during use, etc.) and the amount or rate at which

it is formed.



### Carbon monoxide (CAS# 630

- 08

- 0) and carbon dioxide (CAS# 124

- 38

- 9) are potential byproducts of combustion of potassium acetate.

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

# □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 98.14 2. Physical state at 20  C Liquid

3. Melting point 4. Boilin g point at 1 atm. Pressure > 93  C

5. Specific gravity 1.27 g/ml 6. Odor threshhold mg/m3

7. Solubility using solvent @ tempera ture  C g/L

8. Solubility in water @ temperature Complete  C

9. Partition coefficient Log K ow 

### Log K 

10. Vapor pressure @ 20  C 0.19 psi 11. Critical temperature

 C 12. Critical Pressure psi

13. Are spectra attached? No 14. Di sassociation constant

15. Particle size distribution 0.042 to 555 microns 16. Volatilization from soil

17. Volatilization from water 18. Viscosity @ 20  C 5.54 cPs

19. pH@concentration 8.0

– 11.0 20. Thermal conductivity

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

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

25. Maximum pressure rise N/A 26. Maximum rate of pressure rise N/A

27. Other (specify)

28. Provide any information on flam mability concerns. For example, if any abatement techniques are being used to minimize the risks associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an assessment of overall risk
in each end

- use may be required. (See Instructions for sector

- specific data requirements for flammable substances).



### Non

- flammable. Used as a fire extinguishing agent.

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

# □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 substitute is a blend, provide the ODPs of individual

constituents. (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromin e loading potentials). Reference the source of this information and attach any supporti ng documentation.



### Potassium acetate does not contain chlorine or bromine and is not considered to be an ozone

- depleting substance.

ODP = 0

2. Global Warming Characteristics: (a) Provide the alternative’s global warming potential ( GWP) relative to carbon dioxide over 100

- and 500

- year time horizons, if known. If the substitute is a blend, provide the 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 (both theoretical and actual testing). (c) Provide source of GWP or any additional data on the GWP of the alternative, including the atmospheric lifetime, infrared ab sorption spectrum, and infrared absorption capacity. If the alternative (e.g. CO 2 captured from a stream of waste gas as a by

- product of fermentation).



### Potassium acetate is not considered to be a greenhouse gas by the IPCC and does not have a published G WP.

GWP = 0

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

# □

Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (Continued)

Section B

- ATMOSPHERIC INFORMATIONForm 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 9 Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section C

- OTHER STATUTES AND STANDARDS

1. Describe whether an d how the alternative is regulated under other environmental regulatory statutes, for example other t itles under the

Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking 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 Comprehen sive

Environmental Response, Compensation and Liability Act (CERCLA), 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.



### Potassium acetate (CAS# 127

- 08

- 2) is listed in the TSCA inventory as acetic acid, potassium salt.

Potassium acetate is registered as an inert ingredient under FIFRA and classified in List 4B

– ingredi ents for which EPA has sufficient data to conclude that their current use patterns in pesticide products will not adversely

affect the environment.

Attached is a substance details report for potassium acetate listing other EPA applications/systems.

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as thos e implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), the Departm ent of Transportation (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

- setting organizations such as the National Fire Prevention Association (NFPA) or the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), by which the substitute is evalua ted.



### Potassium acetate is an FDA approved drug for injection used in the treatment of diabetic ketoacidosis (FDA Application No. NDA 018896).

Potassium acetate is currently used in restaurant fire protection systems that are installed based on NFPA Technical Standard 17A and listed under UL specification 300. Potassium acetate is also use d in Class K fire extinguishers that are installed based on NFPA Technical Standard 10.

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

# □Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 10

Part II

- ALTERNATIVE

- SPECIFIC INFORMATION (continued)

Section D

- COST AND AVAILABILI TY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installati on costs associated

with the alternative. 

### Agent cost based on protected space volume would be in the range o f $0.25 to $1.00 per cubic foot with a total system cost not including detection and release of $10.00 to $25.00 per cubic foot.

K

- Ace sold as recharge agent would have a list price in the range of $30.00 to $35.00 per gallon.

2. Provide informatio n on production of the substitute. Include estimates on:

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

(b) Total pounds production per year (current figure).

(c) Years to maximum market penetration.

(d) Maximum total pro duction per year at market saturation.

(e) Estimated percentage of market at market saturation.



### K

- Ace (potassium acetate solution) is purchased commercially from Nachurs Alpine Solutions (NASI) in Marion,

Ohio.

Estimated current production for fire p rotection uses is 30,000 pounds per year

, with anticipated increase to 150,000 pounds per year over a 10 to 15 year period

.

3. Describe any new equipment and use profiles. If retrofitting of existing equipment is required, detail changes in technologi es needed to use the alternative and address any materials compatibility issues. Provide information on each end

- use and capital costs associated with the
substitute or alternative process. Include cost of equipment and/or any new materials, equipment li fetime, changes in labor and energy costs



### .

The use of K

- Ace does not require any modifications to traditional water mist system equipment such as piping and nozzles. Material compatibility issues would have to be evaluated based on the hazard being pr otected.

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

# □Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 11 Part III

- RELEASE AND EXPOSURE DATA

Section A

- TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attached supporting informa tion) 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 products if known. Also include information on any “A llowable Exposure Limits” (AELs) that have been set for the substitute for use in the workplace. In addition, please attach a copy or facsimile of any hazard warning statement, label, material safety data sheet, or other information which will be provided to any person wh o is reasonably likely to be exposed. (See Guidance Manual for sector

- specific data requirements).



### Potassium acetate has an oral LD 50 

### of 3.25 g/kg and is generally considered to be a mildly toxic compound. According to the attached MSDS it has an NFPA h azard ranking of 1 for health and 0 for fire and reactivity. Potassium acetate is not listed as a potential carcinogen by EPA, NTP or IARC and allowable exposure limits have not been developed for potassium acetate by OSHA or ACGIH.

Attached is a toxicit y profile of water mist spray with additives produced by the US Army. It concludes that potassium acetate “should pose a minimum health hazard in this application.”

Attached is information on aquatic toxicity and biodegradation of two commercial deicers

– Alpine Ice

- Melt and Cryotech E36

– that have a composition almost identical to K

- Ace (50% potassium acetate, 50% water with less than 1% of corrosion inhibitors added). It includes the following data:

Fathead minnow 7

- day chronic LC 50 

### > 1500 mg/L Chemical oxygen demand (COD) = 0.32 g O 2 

### /g deicer

Rainbow trout 96

- hour acute LC 50 

### >2100 mg/L Biological oxygen demand (BOD) = 0.25 g O 2 

### /g deicer Daphnia magna 48

- hour acute LC 50 

### >3000 mg/L Sheepshead minnow 48

- hour LC 50 

### = 6300 mg/L CO D = 430,000 mg/L Mysid 48

- hour LC 50 

### = 1400 mg/L BOD = 182,000 mg/L

Section B

- ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

(a) Identify all site locations (i.e. name and address) fo r each chemical manufacturing process. (b) Identify all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitute s). (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing the substitutes. (d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e .g. indoor air, outdoor air, water, land).



### Amerex purchas es K

- Ace (potassium acetate solution) from Nachurs Alpine Solutions (NASI) in Marion, Ohio, but it is also commercially available from a number of other chemical manufacturers. Raw materials are glacial acetic acid, 45% potassium hydroxide and potable wat er combined stoichiometrically to form aqueous 50% potassium acetate. The only by

- product from this process is heat that is removed by a heat exchanger prior to transfer to storage. Raw materials are received by tanker truck or tanker car and stored in a ppropriately designed storage tanks within a secondary containment structure. Raw materials are delivered to the mixer with centrifugal pumps and metered through mass flow meters. All operations personnel are trained to the HAZWOPER

technician level alon g with hazard communication, confined space entry, LOTO, respirator use, PPE, etc.

PPE includes gloves, face shield, emergency escape air pack, steel

- toed boots, safety glasses while handling the

raw materials. The resulting 50% potassium acetate is a no n

- hazardous aqueous salt solution. The finished product is pumped from the mixers to storage tanks, tested by QA/QC and releas ed for shipment.

Fire suppression and explosion protection systems using K

- Ace would be manufactured by Amerex at its headquarte rs and factory in Trussville, Alabama.

K

- Ace is handled in a closed system from the time it is received by Amerex until it is shipped out in filled cylinders , so there should be no environmental release or disposal during manufacture of fire suppression s ystems using K

- Ace.

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

# □Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 12 Part III

- RELEASE AND EXPOSURE DATA

Section C

- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products containing subst itutes):

(a) Describe the activities in which workers may be exposed to chemicals. (b) Describe any protective equipment and engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods)

. (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/da y and (2) days/year. (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). (g) Estimate the average and high

- end exposure concentrations (separated by a /), being sure to provide units of measure.



### K

- Ace is received by Amerex as a l iquid in totes containing 3,200 pounds or approximately 300 gallons. The tote is elevated on a rack and system cylinders are gravity filled through a solenoid valve controlled by a flow meter.

Once filled the valve assembly would be installed, the cylind er pressurized, cylinder assembly leak checked, and then the cylinders packed out and stored in a carton on a pallet. Since the process is a closed system with no direct handling of agent, workers do not use any personal protective equipment.

Including t he manufacture of liquid restaurant fire suppression systems with potassium acetate, Amerex has four

full

- time employees with potential exposure of 40 hours per week.

Spills in the plant are handled in accordance with the attached Amerex Spill Response Pr ocedure.

Section D

- ENVIRONMENTAL RELEASE AND DISPOSAL IN END

- USE

For each end

- use of a substitute:

(a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous waste or wastewater efflu ent) at a site using the substitute (e.g. in products containing the substitute and processes using the substitute). (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point. (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control techn ology in place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal. (d) A re 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 substitute. Describe any associated costs a nd equipment.



### Release of K

- Ace (potassium acetate solution) from an installed fire protection system would only occur during a fire or accidental discharge, both of which are rare. The amount of agent released to the environment would be expected to be e xtremely small.

The MSDS for K

- Ace recommends confining the release and recovering as much of the potassium acetate solution as possible, then disposing of whatever cannot be reused in accordance with federal, state, and local regulations.

For discharge in a vehicle, Amerex recommends flushing the 1 to 2 gallons of potassium acetate solution in the vehicle interior with copious amounts of water, then disposal in accordance with federal, state, and local regulation.

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

# □Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 13 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 products and/or processes):

(a) Describe the activities in which wo rkers may be exposed to chemicals. (b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. so lid, 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 pathwa y (e.g. ingestion, inhalation, dermal). (g) Estimate the average and high

- end exposure concentrations (separated by a /), being sure to provide units.



### Worker exposure to K

- Ace would occur from the release of the agent from a fire suppression or explo sion protection system in an occupied space during a fire or accidental discharge. In this situation workers could be exposed for 3

- 4 minutes to a mist of the potassium acetate solution containing droplets with an average size of 39

microns. The total am ount of agent released as a mist could vary from 1

- 2 gallons for a vehicle system to 30

- 70 gallons for a typical 260 cubic meter room system.

Section F

- CONSUMER EXPOSURE

For each end

- use of a substitute:

(a) Identify the potentially e xposed population (e.g. indoor residents). (b) Identify the exposure medium (e.g. air). (c) Enter the contact pathway (e.g. ingestion, inhalation, dermal). (d) Enter the exposure point of concentration. Provide (1) average and (2) high

- end estimates.



### Consumers would not be expected to be exposed to K

- Ace from its use in special hazard fire suppression or explosion protection systems.

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 (continued)

Section G

- GENERAL POPULATION 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), identif y the potentially exposed population (e.g. residents at the fenceline). (c) Identify the contact pathway (e.g. ingestion, 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.



### There should be no exposure to K

- Ace in the general population from its use in special hazard fire suppression and explosion protection systems.

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

# □Form 1265

- 07 (Revised 06/2008)

Previous editions are obsolete 

### 15 Part IV

- LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information t hat may assist EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, pr ovide citation for information already submitted to EPA as part of past regulatory and information activities, as well as for other information that could not be included with this sub mission. If you have attached continuation pages, describe the Part, Se ction and question number being continued. Attach additional pages if necessary.

Attachment Name Question # Number of Pages CBI



### Nozzle Characterization, Droplet Sizing for Amerex Nozzles B4 64

Nozzle Characterization: Amerex Droplet Size Classificatio n B4 11

NRL Paper on Mists of Aqueous Potassium Acetate B4 6

US Army Paper on Extinguishing Agents for Ground Vehicles B4 17

Potassium Acetate Solution Technical Data Sheet B5 1

EPA Substance Details Report for Potassium Acetate C1 4

Intertek Vap or Pressure Report for K

- Ace IIA 1

NASI Material Safety Data Sheet for Potassium Acetate Solution III A 2

US Army Toxicity Profile of Water Mist Agents III A 11

Cryotech E36 MSDS III A 2

Cryotech E36 Fact Sheet III A 2

Cryotech E36 Environmental Impact III A 1

Alpine Ice Melt Technical Data Sheet III A 1

Alpine Ice

- Melt Laboratory Analysis III A 4

Alpine Ice

- Melt Biotoxicty Report III A 20

Amerex Spill Response Procedure III C 3

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

# □

### 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 al l test data in my possession or control and a description of all other data known to or reasonably ascertainable by me

.

3. If this is a submis s ion of a new alternative

, the company name in Par t I

, Question la of this notice : (a) int e nds to manufacture, formulate

, import

, market

, or use a new alternati v e to a Class I or Class II ozone-depleting

substance which is identified in Part I

, Section B

, Question 2.
( b ) seeks an acceptabilit y determination on a new a 1ternative(s) to a Class I or Class II ozone-depleting subst a nce
, which i s
ident i fied in Part I

, Section B, Ques t ion 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 misinterpretation is subject to criminal penalty pursuant to section 1 13 (c)

of the Clean Air Act and 18 U

. S.C

. §lOOI

.



### Sign Z 

# A Of

Authorized Official (Original Signature Required): Date



# - (3;

~

. /l r

- , )a fr e s ) ~e ' 1 

# fr

- & -e S1 e r Cl / H t l Y I ' l c r l i b

. 

# g)

. J

- O/ L

/ 

### Signature of Agent (Where Applicable); Date

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 150 hours per year

. For persons filing a TSCA I SNAP Addendum

, the reporting burden is estimated to average 46 hours her year

. Burden means that total time, o r financial resources expended 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 collection of information unless it displays a currently valid

OMB control number.

Send comments on the Agency 's need for this information, the accu r acy ofthe provided burden estimates, and any suggested methods for minimiz i ng 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 OMS control number in any correspondence.

Do not send the completed form to this address.

Form 1265-07 (Revised 06/2008)

Previous editions are obsolete 

### 16