~~b:~~ ------------------------------

September 25, 2014 

Ms. Bella Maranion 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division 

Office of Air and Radiation 6205J 

US EPA 

1200 Pennsylvania Ave NW 

Washington DC 20460 

Re: Your Letter of September 9, 2014, re SNAP Submission for 2-Bromo-3,3,3-

Tritluoropropene (BTP) in Fire Suppression, Our Application December 3, 2013 

and March, 2014 

Dear Ms. Maranion: 

We are in receipt of your letter dated September 9, 2014_ The responses are found below. With respect to the 

applications listed, for purposes of our response, Group A pertains to flooding applications of engine nacelles, 

APUs, baggage/compa11ment areas and niche systems_ Group B pertains to streaming applications with handheld 

and wheeled fire extinguishers in all of the noted applications/categories in your letter. Please note that within each 

application, BTP would be expected to be effective in a sub set of the ratings and sizes depending on criteria 

acceptable to the sub set of end users_ Responses: 

1. a) 1) Extinguisher Systems 

I. Design concentration expressed volumetrically on a percent basis. 

a. Group A - The heptane cup burner extinguishing concentration is 4.8% v/v (full scale Kidde 

Research). Design concentrations will typically be 20-30% above this according to NFPA 2001 

and/or other applicable standards and depending on final UL test results under application standards 

(will not be complete pre SNAP approval). On that basis, design concentrations will be in the range 

of 5.8% - 8.0% v/v for most applications. The Federal Aviation Administration (FAA) has 

developed minimum perfonnance standards for each onboard system and the concentrations for 

these will be unique. BTP has not been fully tested for any of these systems. Some work was 

conducted for cargo compartments and engine and auxiliary power unit (APU) protection. For 

cargo compartments, BTP did not pass the exploding aerosol can test. Therefore, for cargo 

compartments, BTP is not currently acceptable, but it may be able to be used in a hybrid system, 

such as with nitrogen, which may make it acceptable. Not all testing was completed on engine/ APU 

protection, but it appears the design concentration would be approximately 8%vol. Additional 

testing is required. 

Halotron Division 

3883 Howard Hughes Parkway, Suite 700 • Las Vegas, Nevada 89169 

Tel: +1 (702) 735-2200 • Fax: +1 (702) 735-4876 

www.halotron.com 
Ms. Bella Maranion 

US EPA 

September25, 2014 

b. Group B-Not applicable. Streaming agents do not require a specific design concentration for the 

protected space. 

II Charge size of a BTP fire extinguisher (grams) 

a. GroupA -

1. For aviation use, the system sizes vary greatly and are based on the size of the aircraft. The 

ranges for system sizes arc: 

1. Lavatory trash receptacle extinguishing systems average 454-1,814 g of Halon 

1301 per aircraft 

2. Engine nacelle/auxiliary power unit (APU) protection systems average 272-84,822 

g of Halon 1301 per aircraft 

3. Cargo compartment extinguishing systems average 10,433-207,294 g of Halon 

1301 per aircraft 

u. Niche systems might range from 1,000-J 00,000 g. 

b. Group B 

i. Fire testing perfonned at UL in 2009 {Preliminary Investigation for later use) according 

to FAA on Board commercial aircraft use resulted in a 1,703 gram (3.751b) extinguisher 

configuration that would be, subject to final hardware testing, UL listed with a 5-B:C 

rating and an FAA approval (in accordance with DOT/FAA/AR-01/37). For accessible 

cargo decks, a 1 A rated handheld is expected to be developed and it is estimated that the 

charge weight of this extinguisher would be 4,536 g. 

ii. Other Handhelds and wheeled extinguishers: Testing not completed and will not be 

completed pre SNAP approval. Ratings from UL 213:C to 30A-240B:C possible. Charge 

size fi:om 900- 91,000 g charge weights. As indicated in the SNAP application, as 

compared to Halon 12l.l, generally BTP will require 1.5 times the weight required for 

Halon 1211 per rating, but testing will be required to determine actual charges and whether 

these similarratings are achievable. Typical Halon 121 1 ratings and charge weights, along 

with estimated BTP charges: 

UL Rating Halon 1211 Charge Estimated BTP Charge 

2B:C 567 g_ 851 g 

SB:C 1,134 g 1,703 g 

1A:1013:C 4,082 g 4,536 g 

2A:40B:C 5,897 g 8,846 g 

4A:80B:C 7,7ll _g 11,567 _g_ 

IOA:120B:C 22,680 g 34,020 g 

30A:240B:C 68,039 g 102,058 g 

Ill. Release rates of a BTP.fire extinguisher (glsec) 

a. Group A- Highly dependent upon the system and end use. Aviation systems, such as engine/APU 

protection will have a discharge time of 1 second, where cargo systems will have an initial 

discharge followed by an extended discharge to maintain concentrations until the plane can safely 

reach the ground. Niche systems would typically have a 10 second discharge. Discharge rates 

might be in the range 90-28,274 g/sec . 

.8\\AMPACTH rcy HALOTRON 
Ms. BeiJa Maranion 

US EPA 

September 25, 2014 

b. Group B - The 1,703 g unit for on board use: 190 gjs (avg). All others- Prelirnjnary estimate: 

100 - 2,600 g/sec based on a size with the range of 900 g to 9 l ,000 gram net charge weight 

depending on user criterion being performance (lower weight and volume) as predominant. 

1. a) 2) End-Use Exposure 

1. Minimum and typical dimensions (meters) and effective volume (i.e., excluding cargo, passengers, etc.) 

(m3) of the :.pace that BTP isproposedfor use within 

a. Group A. Varies. Possible applications may be 0.5 m3 to 100m3

. For aviation systems, these 

would not be expected to result in exposure to personnel when activated inflight. Exposure due to 

ground discharge of cargo or propulsion tire suppression agents is rare and typically results in only 

briefhuman exposures (less than a minute) due to rapid dissipation and/or the ability to get out of 

the exposure area. 

b. Group B. From approx. 1.0 m3 to unlimited (outside). 

1 . For handheld extinguisher usc, typical use is not in confined spaces, and it is anticipated 

that the user will move away from the fire location immediately until smoke and agent 

vapors cJear. UL2129,Halocarbon CLean Agent Fire Extinguishers, requires a minimum 

room volwne warning be placed on the label of an extinguisher when the extinguisher is 

dischru·ged into a confined space. Minimum room volumes for "confined spaces" 

applicable to UL listed BTP extinguishers would follow established protocol since 1995 

that apply to all UL listed tire extinguishers (no exceedance of cardiotox LOA EL , 1.0% 

v/v for BTP, calculated based on agent density at the upper end of the extinguisher 

operating temperature range, typically 120°F, using assumptions of perfect stirring and 

complete discharge of the extinguisher). 

2. Safe Use Guidelines tor handheld use onboard aircraft is contained in FAA Advisory 

Circular 20-42D, Hand Fire Extinguishers for use in Aircraft. This circular utilizes the 

PBPK model to determine acceptable agent weights discharged. A PBPK report was 

developed for BTP and submitted with our original SNAP application and this describes 

the allowable agent concentrations for aircraft. The original SNAP submission also 

included a Boeing paper which provided the known frequency of handheld fire 

extinguisher discharges onboard Boeing commercial airplanes. The paper showed a 

probability of discharge of only lxl0-6 per tlight. 53% of those reported discharges 

were on actual fires, in which case the agent would react with the fire to form byproducts 

different from neat agent. On those discharges not involving a fire, the airplane volume 

and ventilation preclude hazardous exposures to the agent. 

IT. Minimum and typical rate of airflow in the space that BTP is proposed for use within (air changes per 

hour) 

a. Group A. Varies. Airflow can be zero to high (engine protection during flight). 1n typical server 

room systems, airflow is shut off prior to discharge to maintain design concentrations. However, 

BTP is not envisioned specificaUy for tbis use. It is envisioned that some niche applications will 

be similar in shutdown of ventilation, where other possible niches, such as engine/APU protection 

and vehicle engine protection systems, will have high air exchange ralcs . 

.8\\ AMPAC"' 

(V HALOTRON 
Ms. Bella Maranion 

US EPA 

September 25, 2014 

b. Group B. Varies. Can be zero in confined spaces to high (20+ miles per hour) in outdoor use. 

f<'AA Advisory Circular 20-42D provides air exchange rates for various models of aircraft. For 

Airbus and Boeing narrow and wide body aircraft, cabin air exchange times range 10.3 to 37.5 air 

exchanges per hour. 

1. b) On the other specified uses in your submission forms, we request .further clariflctttion on whether or not 

use by consumers is anticipated 

I. Group A- No use anticipated by consumers 

11. Group B - Yes, for automotive and marine use in niche applications there would be "consumer use" in 

the same manner as other halocarbon halon 1211 substitutes in this case where performance (including 

minimal weight) is the dominant criterion. Non-residential use only. 

2. Di~posal. Please provide the procedures and/or guidelines for proper clean-up and disposal of discharged BTP. 

I. BTP docs contain non-volatile residues at a higher level than existing clean agents, up to 0.4%wt. These 

non-volatiles arc related to the formation of partial polymer chains that may contain oligomcrs up to 5 BTP 

molecules in length. A smaller portion of the non-volatile residue relates to the stabilizer composition. 

These residues are not considered to be corrosive in nature and it is not envisioned in the typical case that 

cleaning of sprayed surfaces would be required. 

ll. Group A- None, volatile liquid, typically no residue and in worst case (low temp sustained, no fire), 

trace residue 

Til. Group B -·None, volatile liquid, typically no residue. Tf enough liquid is allowed to accumulate in 

areas of very low temperature, there could be a slight residue. This non-hazardous residue would be 

wiped off or washed down in accordance with good practice for the type of surface affected. 

3. CBI Claims for Additional Information. 

The data provided herein docs not contain CBI. 

This infonnation represents the best available. If you have any questions regarding the above responses, please let 

us know. 1 can be reached at (702) 699-4131 or bcolton@apfc.com. 

cc: Jeff Gibson, AMPAC 

Holly Stevens, AMPAC 

.0\\ AMPAC"' rcy HALOTRON 

Technical Contact on the SNAP Application