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September 

### 25, 2014

Ms. Bella Maranion Alternatives and Emissions Reduction Branch Stratospheric Protection Division Office ofAir 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 ofthe 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.comMs. B ella Maranion US EPA September25, 2014 b. Group 

### B- Not app li cable . S treaming agents do not require a s pecific design concentration for the protected space. II Charge size of a BTP fire extinguish er (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 s izes arc: 1. Lavatory trash receptacle extinguishing systems average 454-1,814 g of Halon 1 30 1 per aircraft 2. Engine nacelle /auxiliary power unit (APU) protection systems average 272-84,822 g of Halon 130 1 per aircraft 3. Cargo compartment extinguishing systems average 10,433-2 07,294 g of Halon 1 30 1 per aircraft u . Niche systems might range from 1 ,000- J00,000 g. b. Group B i. Fire testing perfonned at UL in 2009 {Preliminary Investigation for later use) according to FAA on Boa rd commercial aircraft use resulted in a 1,703 gr am (3.751b) extinguisher configura ti on th a t wo uld be, subject to final hardware testing, UL listed w ith 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 estimat ed that the charge weigh t ofthis extinguisher would be 4,536 g. 

### ii

. Other Handhelds and wheeled extinguishers: Testing not completed and will not be completed pre SNAP approval. R ati ngs from UL 213:C to 30A-240B:C possible. Charge size fi:om 90 0- 91,000 g charge wei ghts. As indicated in the SNAP appli cation, 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 char ges and whether these s imil a rratings are achievable. Typical Halon 121 1 ratings and charge weights, along with estim ated BTP charges: UL Rating Halon 1211 Charge Estimated BTP Charge 2B: C 567 g_ 851 g SB:C 1 ,13 4 g 1 ,703 g 1A:10 13:C 4,08 2 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, w here cargo systems w ill have an ini ti al discharge followed by an extended discharge to mai ntain concentrations until the plane can saf ely reach the ground. Niche systems would typic ally have a 10 second dischar ge. Discharge rates might be in the range 90-28,274 g/sec

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## .8\\AMPAC TH 

# r cy HALOTRONMs. 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 expo sure area. b. Group B. From approx. 1.0 m 3 to unlimited (outside). 1 . For handheld extinguisher usc, typical use is not in confined spaces, and it is anticipated that th e user will move away from the fire location immediately until smoke and agent vapors cJear. UL21 29,Halocarbon CLean Agent Fire Extinguishers, require s a minimum room volwne warning be placed on the label of an extinguisher when the extingui sher is dischru·ged into a confined space. Minimum room volumes for "confined spaces" applicable to UL listed BTP extinguishers would follow es tablished protocol since 1995 that ap ply to all UL listed tire ext inguishers (no exceedance of cardiotox LOA EL , 1.0% v/v for BTP, calculated based on agent density at the upper end of the extingu isher operating temperature range, typically 120°F, using assumptions ofperfect stirring and compl ete discharge ofthe ext inguisher). 2. Safe Use Guidelines tor handheld use onboard aircraft is contained in FAA Advisory Circular 20-42D, H and Fire Extinguishers for use in Aircraft. T his circular utilizes the PBPK model to determi ne acceptab le agent weights discharged. A PBPK report was developed for BTP and submitted with our original SNAP appli cation and this describ es 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 whi ch case the agent would react wit h the fire to form byproducts different from neat agent. On those discharges not involving a fi re , the airplane volume and ventilation preclude hazardous exposures to the agent. IT. Minimum and typical rate of airflow in the space that BTP isproposed for use within (air changesper hour) a. Group A

. Varies. Airflow can be zero to high (engine protection during flight). 1n typical server room systems, airflow is shut offprior to discharge to maintain design concentrat ions. However, BTP is not envisioned specificaUy for tbis use. It is envisioned that some niche applications will b e s imi lar i n 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 HALOTRONMs. Bella Maranion US EPA September 25, 2014 b. Group B. Varies. Can be zero in confined space s to high (20+ mile s per hour) in outdoor use. f <'AA Advisor y Circula r 20-42D provides air exchange rates for various models of aircraft. For A irbus and Boeing n a rrow 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 submissionforms, 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 th ere would be "consumer use" 

### in the same manner as other halocarbon halon 1211 substitutes in this case where performance (including minim al weight) is the dominant criterion. Non-residential use only. 2.**Di~posal.** 

### Pleaseprovide theprocedu res and/or guidelines forproper clean-up and disposal of dischar gedBTP. I. BTP docs contain non-volatile re sidues 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 smalle r portion of the non-volatile residue relates to the stabili zer composition. Thes e residues are not considered to be corrosive in nature and it is not envisioned in the typical case that cleaning of sprayed surf aces 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 temp erature , there could be a slight residu e. 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 infonnati on 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

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cc: Jeff Gibson, AMPAC Holly Stevens, AMPAC



# .0\\ AMPAC "' 

# r cy HALOTRON Technical Contact on the SNAP Application