April 4, 2011

U.S. Environmental Protection Agency ATTN: Nathaniel Jutras, SNAP Division 1200 Pennsylvania Ave. NW Mail Code 6205J Washington DC 20460

Re: Responses to Incomplete SNAP Submission for FirebaneTM 1179

Dear Nathaniel,

Thank you and your team for taking the time to conference with us by phone on Monday, March 20. Below are our answers to your qu estions in the order in which they were listed in your March 15 letter. Your questions to us are reflected below in black, and our

answers follow in red.

Cost and Availability of the Alternative

EPA : Please provide estimated system installation costs, the estimated maximum total production per year at market saturation and th e estimated percentage of market at market

saturation.

GSL: The cost per pound to manufacture FirebaneTM 1179 agent is $2.60. Estimated maximum total production per year at market saturation is ~ 75,000 pounds. Estimated market share is 15% or higher.

Toxicity and Hazard Information

EPA : Please clarify which substances were used to test for eye irritation. Which ionic and non-ionic soaps are included in the formulation?

GSL: Firebane 1179 was tested by RespirTek for toxicity, biodegradability, and eye and

skin irritation. The results of the tests we re provided in our original submission.

Tween 20 (polysorbate 20) is the only surfacta nt used in the formulation. Tween 20 is

non-ionic but is not generally considered a soap. It can be used, however, as the surfactant in detergents. For GSL’s FirebaneTM 1179 agent, Tween 20 is used as an

emulsifier. MITCHAEL C. FREEMAN

VICE PRESIDENT, PRODUCT DEVELOPMENT & TESTIN GFor Use as a Streaming Agent:

Alternative-Specific Information

EPA : The submission indicates that FirebaneTM 1179 will be used in handheld extinguishers to suppress Class A (ordinar y combustibles) and Class D (combustible metals) fires. Please explain how this substa nce could act as a Clas s D fire extinguisher when, as stated in Part III, Section E (c), the substitute is stored as an aqueous solution that becomes a gas upon introduction to fire. Wa ter can create an explosive reaction with

reactive metals. Please clarif y the state (liquid or gas) of the aqueous substitute upon release from the extinguisher. If they ar e intended for suppressing Class D fires, please clarify which types of metal fires FirebaneTM 1179 will extinguish.

Additionally, has FirebaneTM 1179 been submitted for approv al under UL Standard 711: Rating and Fire Testing of Fire Extinguishers?

GSL: FirebaneTM 1179 has shown documente d success extinguishing a wide variety of metals, including magnesium, titanium and lithium. FirebaneTM 1179 has not yet been submitted for approval under UL Standard 711: Rating and Fire Testing of Fire Extinguishers, but we intend to complete this testing with Southwest Research Institute for Class A and Class D fires later this year.

It is true that aqueous CO 2 and halogenated agents are highly discouraged from being used on a Class D fire because they serve as fuel and/or oxidant for the metal fire. Halogenated agents also release highly to xic compounds. Most water-based extinguishers cannot boast the ability to extinguish Class D fires. When water-based extinguishers are used on metal fires, a violent, flaring explosion occurs.

The temperature at which combustible metals, such as lithium, magnesium, and titanium, burn can exceed 2,500°F. Because of these ex cessive temperatures, the water molecules dissociate into hydrogen and hydrogen oxide (H 2 O Æ H + + OH - ). Thus, the hydrogen ignites and increases the combustion and hydrogen explosive hazard. However, even though it is water-based, FirebaneTM 1179 can su ccessfully extinguish a Class D fire with little flaring.

Not only is the 1179 agen t effective in extinguis hing the fire, but it al so cools the fire to ambient temperatures within seconds. This cooling effect results from the high number of hydrogen bonds found in FirebaneTM 1179. These hydrogen bonds cause it to have a very high specific heat (meaning that more thermal energy or a lack of thermal energy is required to change its temperature). Heat cap acity has to do with how well molecules are able to store (or trap) energy. This can incl ude translational energy, molecular vibrations and molecular rotations. Hydroge n bonds provide another way for energy to be stored. As heat is added to the substance, some of th at energy is expended in breaking the bonds,rather than simply raising the temperature. The more places a molecule has to deposit energy (degrees of freedom), the higher the heat capacity.

The state of FirebaneTM 1179 agent when it is release from the extinguisher is as a liquid.

The test for becoming a rated Class D agent includes fighting such fires as magnesium, titanium and lithium. FirebaneTM 1179 has been shown to rapidly extinguish magnesium, titanium, and lithium.

Process Description

EPA : Please describe the manufacturing process for charging the handheld extinguishers. Is it an open or closed process? Is it automated?

GSL: The manufacturing process is open. Because FirebaneTM 1179 is aqueous and non-toxic, there are no exposure issues for the charging of our handheld extinguisher. The approved quality manual currently uses a ma nual filling procedure. We have plans to submit an updated Listing & Labeling process us ing an automated system in the future.

Release and Exposure Data

EPA : According to Part III, Section C (c), the substitute is a liquid except when in use. Please clarify how the substitute becomes a gas. Does this occur when the substitute is dispersed? What is the mechanism for dispersion?

According to Part III, Section D (e), only the GSL, Inc. facility in Tulsa, Oklahoma is expected to use the substitute. “End use” refers to use as a fire suppressant. Please clarify

if FirebaneTM 1179 is intended to be sold for us e as a fire suppressant at other sites, and how and where the substitute will be used including:

• The handheld extinguisher charge size (i .e., the mass or weight of FirebaneTM 1179 in an extinguisher)

• The range of room sizes where the handheld extinguishers containing FirebaneTM 1179 will be installed and approximate room size dimensions for where the

substitute will be manufactured. For stream ing agents, it is necessary to determine an instantaneous exposure level (i.e. the co ncentration of the substitute of minute after release)? For us to estimate this, we need the charge size and the approximate dimensions of the space in which the system will be used.

• How many extinguishers will be installed pe r room? What is the rate of airflow in the area in which the fire extinguisher will be used (if this information is available) or a recommendation of airf low rate that w ould provide proper

ventilation in areas where the fi re extinguisher would be used?GSL: The FirebaneTM 1179 agent is in a liquid st ate when dispersed. The term “gas”, in our original submission, was actually meant to refer to the steam when the liquid is introduced to high heat. The FirebaneTM 1179 ag ent is dispersed through various nozzles for various extinguishers used, dependi ng on dispersement requirements. The extinguishers are internally pressurized w ith nitrogen. When activated, the FirebaneTM 1179 agent will then travel through a hose and out of a nozzle.

FirebaneTM 1179 is intended to be sold for use as a fire suppressant to various end users, primarily the U.S. military. To date, the largest intended use is in a military issued High Mobility Multipurpose Wheeled Vehicle (HMMWV). Inside of the HMMWV will be two extinguishers, both charged with 3⁄4 gallons of FirebaneTM 1179. The bottles will be

bolted to the sidewalls of the HMMWV.

The typical compartment size of the protected vehicle into which FirebaneTM 1179 will be discharged is approximately 4,551 liters. A very successful application ratio has been 1 liter of agent to 1000 liters of compartment space.

Because the term “airflow” is geared towards a gas, there is no true value available for

the airflow of FirebaneTM 1179 out of the nozzl e as a liquid. But, assumptions can be made about how the liquid will flow out of th e nozzle, and to what extent it will displace the surrounding oxygen. One of those assumptions is that the pressure used to drive the FirebaneTM 1179 through the nozzle for discharge is low; therefore, we expect to see a laminar flow of liquid, or a streamline flow. Because the flow of liquid is streamlined, the oxygen displacement by the liquid is quite sm all. Therefore, FirebaneTM 1179 is not extinguishing fire by depriving the compartm ent of oxygen, as some fire extinguishing systems do.

The liquid flow of FirebaneTM 1179 when it is discharged is approximately 2 liters/minute, which is 0.044% of the total compartment volume. When comparing this side by side with gas systems which are us ed up to 10%, or in this case 455 liters , the effect of FirebaneTM 1179 is almost negligible.

For Use as a Total Flooding Agent:

Alternative-Specific Information

• Indicate the class of fires that the alternative would be expected to suppress.

Installation, Maintenance, and Use• Describe the installation and maintenan ce activities during which workers may be exposed to flooding agent chemicals.

• Describe the type of space in which the extinguisher will be used (i.e., occupied or unoccupied)

• For gaseous fire extinguishants, identif y the design concentration expressed volumetrically on a percent basis (for example, 5 percent v/v).

• For aerosol extinguishants, state the ex tinguishing applicati on density and the design application density expressed in g/m 3

.

• What is the charge size of the proposed blend; and the purpose and size of the space in which the extinguishing device will be used? Also, include the approximate dimensions of the space in wh ich the fire extinguisher will be used.

• What is the release rate of th e fire extinguisher in g/sec?

• How does the fire extinguisher material di sperse (e.g., is the charge distributed evenly throughout the room?)? Please provi de information describing dispersal system (e.g., is the fire suppression agen t a liquid which is vaporized upon release through the high pressure nozzle? Where ar e the nozzles located?) Describe the behavior of the agent upon release (e.g., agglomeration and settling).

• What is the rate of airflow in the area in which the fire extingui sher will be used (if this information is available) or a recommendation of airflow rate that would provide proper ventilation in areas wher e the fire extinguisher would be used?

GSL: At this time, we are requesting that FirebaneTM 1179 be considered as an enduse streaming agent and not as a total flooding agent. Therefore, we have withheld our responses to these specific questions.

Please let me know if you require any additional information.

Kind regards,

Mitchael C. Freeman

MCF:es