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 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 10th FLOOR (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 submit 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 information 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 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 include 

the confidential material. If no claims 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, sectorspecific data requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates 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 alternative, Substance, or Formulation___________________________________________x

Petition: New alternative, Substance, or Formulation__________________________________________________________□

Petition: Revision of the Existing SNAP list__________________________________________________________________□

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________□
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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 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 reproduce 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 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, 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 data 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 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 confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart 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 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 information 

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 contract 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 program. 

These Authorized Representatives may have access to any information 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 business 

information as implemented by 40 CFR 2.301(h).
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Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (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 

(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, phone, 

etc.) and the EPA staff person’s name: 

Meeting on April 15, 2011, with Nathaniel Jutras and Margaret Sheppard, phone call on October 20, 

2011 with Margaret Sheppard and Bella Maranion, emails

Mark (X) if None ________________□

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Part I - GENERAL INFORMATION (continued)

Section 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 of each 

constituents.

 (b) Chemical Abstracts 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 patent 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 frame for a response.

Potassium acetate, 50%, CAS# 127-08-2

Formula: C2H3KO2

Water, 50%, CAS# 7732-18-5

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information).
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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 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 each end use in pounds (replacement 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 suppression (product developed and performance tested at 

Aberdeen Testing Center for a specific US Marine Corp program)

 Military vehicle crew compartment explosion suppression (product in development phase)

 Military and commercial wheel well fire suppression (local application in a normally unoccupied area)

 Military and commercial engine compartment fire suppression (application in a normally unoccupied 

area)

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

occupiable 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 of 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 through 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 of 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 throughout 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 microns 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/fuel 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.

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Form 1265-07 (Revised 06/2008)

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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 for commercial 

purposes. If there 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 weight 

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/degradation 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.

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Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

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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. Boiling point at 1 atm. Pressure >93 C

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

7. Solubility using solvent @ temperature C g/L

8. Solubility in water @ temperature Complete C

9. Partition coefficient Log Kow Log K

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

C

12. Critical Pressure 

psi

13. Are spectra attached? No 14. Disassociation 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 coefficient 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 flammability 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.

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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 bromine loading 

potentials). Reference the source of this information and attach any supporting 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 absorption 

spectrum, and infrared absorption capacity. If the alternative (e.g. CO2 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 GWP. 

GWP = 0

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
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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 titles 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 Comprehensive 

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 – ingredients 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 those implemented by 

the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), the Department 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 evaluated.

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 used in Class K fire 

extinguishers that are installed based on NFPA Technical Standard 10.

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

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

with the alternative.

Agent cost based on protected space volume would be in the range of $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 information 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 production 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 protection 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 technologies 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 lifetime, 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 protected.

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Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

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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 information) 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 “Allowable 

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 who is reasonably likely 

to be exposed. (See Guidance Manual for sector-specific data requirements).

Potassium acetate has an oral LD50 of 3.25 g/kg and is generally considered to be a mildly toxic compound. 

According to the attached MSDS it has an NFPA hazard 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 toxicity 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 LC50 > 1500 mg/L Chemical oxygen demand (COD) = 0.32 g O2/g deicer

Rainbow trout 96-hour acute LC50 >2100 mg/L Biological oxygen demand (BOD) = 0.25 g O2/g deicer

Daphnia magna 48-hour acute LC50 >3000 mg/L

Sheepshead minnow 48-hour LC50 = 6300 mg/L COD = 430,000 mg/L

Mysid 48-hour LC50 = 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) for each chemical manufacturing process.

 (b) Identify all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitutes).

 (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 purchases 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 water 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 appropriately 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 along 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 non-hazardous aqueous salt solution. The finished 

product is pumped from the mixers to storage tanks, tested by QA/QC and released for shipment.

Fire suppression and explosion protection systems using K-Ace would be manufactured by Amerex at its 

headquarters 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 systems 

using K-Ace.

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Form 1265-07 (Revised 06/2008)

Previous editions are obsolete

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Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

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

 (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/day 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 liquid 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 cylinder 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 the 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 Procedure.

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 effluent) 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 technology in 

place to limit release. If the substitute is to be disposed of, indicate 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 substitute. Describe any associated costs and 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 extremely 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.

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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 workers 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. 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, 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 explosion 

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 amount 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 exposed 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), identify 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/m3). 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) this 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 that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide 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 submission. If you have 

attached continuation pages, describe the Part, Section 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 Classification 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 Vapor 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 all 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 submission of a new alternative, the company name in Part I, Question la of this notice:

(a) intends to manufacture, formulate, import, market, or use a new alternative to a Class I or Class II ozone-depleting

substance which is identified in Part I, Section B, Question 2.

(b) seeks an acceptability determination on a new a1ternative(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 misinterpretation is subject to criminal penalty pursuant to section 113(c)

of the Clean Air Act and 18 U.S.C.§lOOI.

SignZ AOf Authorized Official (Original Signature Required): Date

-(3; ~./lr-,)a fres)~e'1 fr-&-eS1erCl/ HtlYI'lcr

lib. 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 TSCAISNAP Addendum, the reporting burden is estimated to average 46 hours her year.

Burden means that total time, or 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 accuracy ofthe provided 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 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