TO: 

FROM: 

DATE: 

RE: 

 

1. A

EPA: In 

714,000 m

values. 

GSL: GS

verify the

a second 

reported 

upon req

Research

organic m

BOD/CO

zone ratio

around 0

value tha

2. In

a. EPA

g/m3

appli

GSL

densi

 

b. EPA

and m

reque

GSL

envir

Drive

Drive

Passe

Passe

Left h

Left h

                 GS

MELI

GSL, 

6/15/2

RESP

(TOTA

Alternative-S

the 1179 SN

mg/L (respe

SL asked the

eir accuracy

company pe

values of BO

quest). 

hers use the B

matter contai

OD ratio can 

o = 0.1 – 1.0

.65. The rat

at Firebane 1

nstallation, M

: On p. 4 of 

. Please clar

cation densi

: Firebane®

ity of 1.15 g/

: In the May

min air excha

est the avera

: The follow

ronment at th

er’s side left 

er’s side righ

enger’s side 

enger’s side 

hand rear sid

hand rear sid

SL CONFIDEN

ISSA FIFFE

INC. 

2011 

PONSE TO E

AL FLOOD

Specific infor

NAP Submis

ectively), wh

e testing faci

. RespirTek

erform the B

OD = 283,00

BOD/COD r

ining wastew

be classified

0. For fully

tio of Fireban

1179 is “Rea

Maintenance

the May 6 fo

rify if the val

ty. 

1179 is store

/ml (9.57 lbs

y 27 followange rates in

ge air excha

wing airflow

he plant usin

hand vent fr

ht hand vent 

left hand ven

right hand v

de vent w/fil

de vent w/o f

NTIAL & PRO

ER, EPA SNA

EPA QUEST

DING REPLA

rmation

ssion, the BO

hich are very

ility, RespirT

k’s response 

BOD/COD te

00 mg/L and

ratio to descr

water is read

d into zones

 biodegradab

ne

® 1179’s B

adily Biodegr

e, and Use

follow-up inf

lue provided

ed, discharge

s/gal). 

-up info, it w

nside a vehic

ange rate. 

w values were

ng special air

front duct = 5

front duct =

nt front duct

vent front du

lter = 51.92 C

filter = 59.4 

OPRIETARY –

AP DIVISIO

TIONS RE F

ACEMENT)

OD and COD

y high. Please

Tek, to revis

was that the

esting to furt

d COD = 529

ribe the biod

dily broken d

, with a toxi

ble matter (s

BOD/COD i

radable”. 

fo, the applic

d is a design 

ed, and appl

was stated tha

cle from the 

e collected o

rflow adapte

53.24 CFM (

= 66.88 CFM

t = 32.56 CF

uct = 90.64 C

CFM (19 air

CFM (22 ai

– PUBLIC VE

ON 

FIREBANE®

) 

D are stated t

e confirm th

it the reporte

e reported va

ther verify th

9,000 mg/L 

degradability

down in the e

c zone ratio 

such as aceta

is 0.53, whic

cation densit

application 

lied as an ext

at the submi

U.S. military

on the militar

ers, and a cal

(20 air chang

M (25 air cha

FM (12 air ch

CFM (34 air 

r changes pe

ir changes pe

ERSION         

® 1179 

to be 280,00

hat these are 

ed BOD and

alues were co

he values. T

(the test repo

y level of ma

environment

> 0.1 and bi

ate) the BOD

ch validates 

ty was speci

density or ex

tinguishing l

itter would re

y. If possible

ry vehicles i

librated anem

ges per hour

anges per hou

hanges per h

changes per

er hour) 

er hour) 

                     

 

00 mg/L and

the correct 

d COD value

orrect. GSL

This company

ort is availab

aterials by w

t. The 

iodegradable

D/COD ratio

the reported

ified as 1,200

xtinguishing

liquid that h

equest the m

e, please als

in a controlle

mometer. 

r) 

ur) 

hour) 

r hour) 

     2

d

es to 

L had 

y

ble 

which 

e

o is 

d

0

g

has a 

max 

o 

ed 
                               GSL CONFIDENTIAL & PROPRIETARY – PUBLIC VERSION                                   2

Left hand rear front vent w/filter = 50.6 CFM (19 air changes per hour) 

Left hand rear front vent w/o filter = 59.40 CFM (22 air changes per hour) 

Right hand rear side vent w/filter = 57.2 CFM (21 air changes per hour) 

Right hand rear side vent w/o filter = 62.48 CFM (23 air changes per hour) 

Right hand rear front vent w/filter = 42.24 CFM (16 air changes per hour) 

Right hand rear front vent w/o filter = 56.32 CFM (21 air changes per hour) 

c. EPA: Please describe the method(s) of activation for 1179. If there is a manual activation, 

what is the time period from activation to discharge? Is any visual or audible warning 

provided prior to the discharge of 1179?

GSL: Upon detection of a fire Firebane® 1179 is automatically activated. The activation to 

discharge time is less than 20 milliseconds. There is a manual activation lever with a safety 

pin; after removal of safety pin and activation of lever, there is about 20 milliseconds until 

discharge. There are no warnings prior to discharge of 1179, other than the fireball seen 

milliseconds before discharge. 

Current gas systems found in military vehicles are harmful to the vehicle’s occupants, thus 

the reason behind a warning prior to discharge. Harm can be done by pressure, noise level, 

and temperature of the gas being discharged. Firebane® 1179 is charged at a pressure 1⁄2 that

of gas systems, the noise level is not harmful, and comes out as a liquid. 

3. CBI Question

EPA: In order to determine whether Firebane will fall under a single or multiple listings, could 

you clarify whether or not GSL will waive the composition's CBI status? 

GSL: At this time, the composition of Firebane® 1179 is a trade secret and remains proprietary. 

Therefore, GSL elects not to waive the composition’s CBI status.