5852 Baker Road • Minnetonka, MN 55345

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com 

### 8 / 08 /1 3

Ms. Rebecca von dem Hagen

Alternatives and Emissions Reduction Branch
Stratospheric Protection Division
United States Environmental Protection Agency
Washington, DC 20460

Re: Redacted SNAP Submission for Stat

- X/Aero

- K Condensed Aerosol System in Fire Sup p ression

Dear Ms. Von dem Hagen:

Please find attached a redacted version of our SNAP Submission as requested in your letter of
July, 15,2013. We consider all the Attachments to the submittal including the Test Rep o rt s in

their entiret y as Confident ial Business Information of Fireaway Inc.

Sincerely,

Marc V. Gross

PresidentForm 1265-07 (Revised 09/2011) 

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OMB Control No.: 2060-0226

Previous editions are obsolete United States 

### ENVIRONMENTAL PR OTECTION AGENCY

Washington, DC 20460 AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 8/31/2014



### 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 10 th FLOOR (MC 6205J) WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control Number



### INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit informat ion 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 ne w substitutes to assist the Agency in a ssessing the acceptability of chemicals or processes that are considered alternatives for ODSs. A separate notice must be file d for each alternative you are submitting.

PAPER SUBMISSIONS: All paper submissions must be provided in th ree 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; t he other two copies must include the confident ial material. If no claims of confidentia lity are made for the submission, all copi es must be identical.

CD-ROM SUBMISSIONS: The SNAP program also accepts submi ssions via CD-ROM. If inform ation is to be claimed as confidential, all confidential information must be excised from one of the files on the CD-ROM, which will be placed in the pub lic docket; the other file must include the confidential material. T he file with the confidential material must include “contains CBI” in

the file name.

STEP-BY-STEP INSTRUCTIONS: The Instructions for the SNAP Information Notice and TSCA/S NAP Addendum (“Instructions”) are designed to assist applicants in completing this form. The Instructions provide step-by-s tep guidance on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sector-specific data requirements, and submitting test da ta and supplemental information.

To facilitate Agency review of alternatives , this form must be filled out as complete ly as possible. Please provide all inform ation requested to the extent that it is known or reasonably ascertai nable. Make reasonable estimate s 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 _____________________________________________ 

# Form 1265-07 (Revised 09/2011) 

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OMB Control No.: 2060-0226

Previous editions are obsolete Part I - GENERAL INFORMATION

You must provide the identity of the alternative chemical or 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. Pleas e reproduce these sections as

needed.

If your substitute is also s ubject 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, dist ribution 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 Instructions 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 x Yes  No

• Environmental Effects

Data x Yes  No

• Environmental Fate

Data  Yes  No

• Risk Assessments  Yes  No

• Test Data Not in the Possession/
Control of the Submitter  Yes  No

• Other Data x Yes  No

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentia lity at the time of submission for any data which are to be tre ated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information cla imed as CBI will be treated in a manner consistent with 40 CFR Part 2, Su bpart 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 informat ion you claim as confidential and mark the confidential box at th e bottom of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confi dential, you must provide a “sanitized” ve rsion of this notice, including attachments, to EPA with your submission. For additional info rmation on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies des ignated 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 regulat ions for the protection of stratospheric ozone, including the development of the SNAP program

. These Authorized Representatives may have access to any informat ion received by the Stratospheri c Protection Division within th e EPA Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process o r activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure t hat these companies can complete the work required by the contract.

Authorized Representatives of the Administ rator are subject to the pr ovisions of 42 U.S.C. 7414(c ) respecting confidential busi ness information as implemented by 40 CFR 2.301(h).Form 1265-07 (Revised 09/2011) 

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### Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (in U.S.)



### Marc V. Gross President

Name of Authorized Official Title



### Fireaway Inc.

Company/Organization



### 5852 Baker Road, Minnetonka, MN 55345 P hone: 952.935.9745 • Fax: 952.935.9757

Mailing Address Telephone & Fax Numbers



### mgross@statx.com

E-mail Address

(b) Agent (if applicable)

____________________________________________________________________________________________________________ Name of Authorized Official Title

____________________________________________________________________________________________________________ Company/Organization

____________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

____________________________________________________________________________________________________________ E-mail Address

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________ Name of Authorized Official Title

____________________________________________________________________________________________________________ Company/Organization

____________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

____________________________________________________________________________________________________________ E-mail Address

2. Technical Contact (in U.S.)

__________________________________________________________________________________________________________ Name of Authorized Official Title

_________________________________________________________________________________________________________ Company/Organization

__________________________________________________________________________________________________________ Mailing Address Telephone & Fax Numbers

__________________________________________________________________________________________________________ E-mail Address

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phon e, etc.) and the EPA staff person’s name:



### See “Continuation Sheet Part I-A-3”

Mark (X) if None ________________

Mark (X) this box if this page contains CBI __________Form 1265-07 (Revised 09/2011) 

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### Continuation Sheet

Part I-A-3

EPA Contacts

The following is a listing of the contacts Fireaway has made with the EPA personnel on this matter identifying the form of contact, the date and th e person(s) contacted at EPA. These contacts do not

include those that were made before the current EPA SNAP approval described in EPA-HQ-OAR-2005-

0087-0009.

• On or about May 18, 2010 Fireaway management participated in a conference call with EPA personnel including Bella Maranion and Margaret Sh eppard. The purpose of the call was to discuss what type(s) of testing and data would be appropria te for a submittal requesting expansion of the StatX SNAP listing to include normally occupied spaces.

• In addition, we believe a very limited number of email were also exchanged following the conference call for additional clarification. These were sent, however, by a former employee and copies are not available at Fireaway.

Mark (X) this box if this page contains CBI __________Form 1265-07 (Revised 09/2011) 

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### Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative:



### Stat-X ® 

### Aero-K ® 

### Condensed Aerosol System


### (See “Continuation Sheet Part I-B-1” for explanati on of this submittal and inhalation, dermal and ocular irritation study information).

2. (a) Name of chemical(s) (preferably IUPAC nomenclature) and/ or process name. For blends, provide the percent composition of each constituent. For powdered aerosols used in fire suppression, see page 11 of the Instructions for additional necessary composit ion information. (b) Chemical Abstracts Service (CAS) registry number and molecular formula. (c) For alternative processes and tec hnologies describe the technology and provide a diagram of the system. Also provide t he information on any chemical constituents. (d) If you have applied for or hold a patent on the substitute, provide the patent name, number (if available), and informa tion on the topics covered in the patent.



### a & b. Manufacturing constituents :

a & b. Discharged agent constituents: See “Continuation Sheet Part I-B-2-a & b & c”

c. See “Continuation Sheet Part I-B-2-a & b & c”

d. Fireaway Inc. is a world-wide licensee for the following patents covering the technology: 6089326, 5865257, 6116348,6264772,5831209, 6042664

3. Generic name:

If the name of the substitute is declared Confidential Business Info rmation, provide a generic name.



### Stat-X ® 

### Aero-K ®

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 subs titute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A to the Instructions, beginning on p. 23. If the alternative is a refrigerant, indicate whether it is a candidate for use in re trofits of existing equipment, for use in new equipment only, or both. (b) Identify the ODS and the quantity of substitute needed to repl ace it for each end use in pounds (i.e., the replacement r atio). 

### (a) Particulate aerosol for fire and explosion suppressi on and inertion in total fl ooding applications in normally occupied and normally unoccupied ar eas (shipboard machinery spaces, marine engine compartments, electrical cabinets, engine compartments, turbine enclosures, flammable liquid storage, remote cellular base stations, etc.).

(b) For replacement of halon 1301. Stat-X ® 

### Aero-K ® 

### is 5 times more effective than halon 1301 on a weight basis (i.e., 1 lb of Stat-X ® 

### Aero-K ® 

### per 5 lbs of halon 1301).

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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### Continuation Sheet

Part I-B-1

Purpose of Submittal

The Stat-X ® 

### Aero-K ® 

### system presently has an EPA SNAP approval for use as a total flooding fire extinguishing system alternative to halon 1301. However the approval limits the Stat-X ® 

### Aero-K ® 

### system “For use only in normally unoccupied areas.”

As a point of reference, we have attached two documents provided by ICF to US EPA in support of the current SNAP approval for the Stat-X ® 

### Aero-K ® 

### system. They are:

“ 

### Background Information for Revised Stat-X ® 

### /Aero-K ® 

### Risk Screen ,” ICF to US EPA, January 31,

2007.

“ 

### Risk Screen on Substitutes for Halon 1301 Total Flooding System in Unoccupied Space, 

### Substitute:

Stat-X ® 

### /Aero-K ® 

### ,”ICF to US EPA, January 30, 2007.



### The purpose of this submittal is to provide inhalation, dermal and ocular irritation study information to be considered for the purpose of removing the current SNAP limitation, thus approving the use of the StatX

® 

### Aero-K ® 

### system to protect areas that are considered normally occupied.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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## x

1 

### “Effluent Concentrations of Fire Suppressant Units,” : 20 September 1999.

2 

### “Characterization of Particulate and Gas Release Afte r Activation of Stat-X Electrical Units,”

, 4 April 2013

3 

### “Fire-Hygienic Assessment and Evaluation of Fire Extinguishing Generators of Type Stat-X 30 E,"

: 18 November

2010.

4 

### “STAT-x, Fire Suppressant Unit: Preliminary Inhalation T oxicity Study in Rats for 15 Minutes,”

: 11 November 2011.

5 

### While the report identifies the units as 25 gram generant capacity, the units supplied by Stat-X were indeed of 30 grams generant capacity each, thus providing an ap plication density of 8 x 30g = 240g or 99g/m 3



### .Form 1265-07 (Revised 09/2011) 

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### The discharge of any aerosol extinguishing system resu lts in a reduction of visibility in the protected space due primarily to the uniform distribution of the particulate generated. There are several ways to minimize the possibility of a system discharge when personnel are still in the protected space and / or to mitigate the effect of the reduced visibility on safe egress for personnel still in the protected space at the time of system discharge.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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### Prevention

NFPA 2010 6 

### requires that a warning of a pending discharge and a delay in the discharge to allow personnel to exit the protected space. In add ition, cross zone detection systems are often employed where detection by one zone would cause an alarm and the time delay before system discharge would not begin until detection by the sec ond zone. Further the standard allows the use of a system abort switch located near an exit from the protected space that would prevent the discharge of the system until all personnel have been evacuated from th e protected space. All systems must have the pre-discharge alarm and tim e delay with the cross zone detection and abort switch approaches optional but commonly used.

Mitigation

Annex C of NFPA 2010, “Reduced Visibility In formation,” provides information on several approaches one can take to facilitate the safe egre ss of personnel who may not have been able to exit the protected space before the system discharg e. The most useful of the approaches are:

• C.10 Utilizing Light of Specific Wavele ngths and Photo-luminescent Marking Systems

• C.11 Decreasing Distance to Exits

• C.12 Training

We believe the combination of .....

• the favorable inhalation toxicity, dermal and ocular effects reported by the two laboratories, ....

• the prevention techniques available for delayi ng system discharge until all personnel are evacuated from the protected space and ....

• the NFPA 2010 mitigation approaches available to facilitate the safe egress of personnel who remained in the protected space during or after system discharge .....

..... serve as the basis for EPA to change the SNAP approval for Stat-X ® 

### Aero-K ® 

### to allow the use of our systems in normally occupied spaces

Mark (X) this box if this page contains CBI __________ 

## x

6 

### “NFPA 2010 - Standard for Fixed Aerosol Fire-Extinguis hing Systems – 2010 Edition” National Fire Protection Association, Quincy, MA: August 2009.Form 1265-07 (Revised 09/2011) 

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### Continuation Sheet

Part I-B-2-a & b & c Manufacturing Constituents

The Stat-X ® 

### Aero-K ® formulation consists of three main c onstituents as shown in Table 1:

and an of the type:

Table 1 Manufacturing Constituents

The combination of these three constituents are referr ed herein as the “generant.” The functions of the three constituents in the composition are:

Discharged Agent Constituents

Upon ignition the com position reacts exothermically a nd produces a fine aerosol of particulate and gas which has an effective ability to interrupt the combustion process.

Mark (X) this box if this page contains CBI __________ 

## x

7 

### Tests conducted by

.Form 1265-07 (Revised 09/2011) 

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### Table 3 is an illustration of the particulate effluent percentages as submitted with the original SNAP Notice (EPA-HQ-OAR-2005-0087-0009).

While the and data do not perfectly track , both sets of data are well within limits set by

NIOSH which are illustrated in Table 5.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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### Table 5 NIOSH Time Weighted Average Concentrations (ppm)

Component IDLH (Immediately

dangerous) Automobile Airbag

Standard (TWA at 20 minutes exposure)

Carbon dioxide 40,000 40,000

Carbon monoxide 1,200 445

Ammonia 300 151.5

Methane NE NE
Nitrogen IV oxide 20 2 

### 9.9
Nitrogen II oxide 100 50.1



### Table 6 is a comparison of the Table 3 particulate da ta with the particulate data. Only a broad comparison is possible since the testing limited the identification of the particulate to broad categories of potassium, potassium nitrogen and ot her compounds. However, the study broadly

confirms the values found in the work.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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### Continuation Sheet

Part I-B-2-c System Description

The Stat-X ® 

### Aero-K ® 

### system pyrotechnically generates a homo geneous mixture of gas and particulates that is discharged into a space containing a fire hazard or directly on the hazard itself, thereby extinguishing the fire.

Figure 7 Generator Discharging Agent

The effluent is sufficiently non toxic that the generato r can be discharged into normally occupied spaces for fire suppression. There are several applications for this technology ranging fr om industrial and marine fire hazards historically protected by halon 1301 or carbon dioxide systems. These applications would include the protection of selected spaces in aircraft , ships and vehicles – any of which might include military versions.

The generator is intended to be installed to direct th e discharge of the agent in a manner and at a distance that neither occupants nor combustible materials are subjected to temperature levels above those permitted in NFPA 2010 (75°C for o ccupants and 200°C for combustible materials). The discharge temperature of the gaseous effluents is controlled by the design of the heat management system.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011) 

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### Stat-X ® 

### Aero-K ® 

### generators are intended to be used either singly or several grouped together depending on the size of the hazard and the extinguishing concentration necessary

Agent Effectiveness

A single 500 gram (1.1 pounds) generator is capable of extinguishing a heptane fire in a volume of 265 cubic feet with a safety factor of 1.3 on the agent qu antity. This is comparable to 5.5 pounds of halon 1301 at a 5% concentration to protect that same volume with a heptane fuel source.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
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### 15 Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. Impurities (a) Identify each impurity that may r easonably be anticipated to be present in th e chemical alternative as manufactured for commercial purposes. If there are unidentifie d impurities, enter “unidentified.” (b) Provide the CAS Registry Number for each impurity if available. (c) Estimate the maximum weight percentage of each impurit y. If there are unidentified impurities, estimate their total we ight

percentages.



### There are no known impurities. The formulation uses reagent grade chemicals.

6. Byproducts: (a) Describe any byproducts or degradation products resulting from the manufacturer , processing, use or disposal of the che mical alternative

or chemicals used in the new alternative. If there are unidentified byproducts/ de gradation products enter “unidentified.” (b) Provide the CAS Registry Number for ea ch byproduct or degradation product if available. (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, in case of fire, etc .) and the amount

or rate at which it is formed.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
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### 16 Part II - ALTERNATIVE- SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES

– See Appendix B to the Instructions to see which properties apply

to which uses.

1.

21.

27.

28. Flammability: Provide any information on flammability concerns . For example, if any abatement techniques are being used to

minimize the risks associated with flammable substances or mixt ures, detail those techniques below. If a substitute is flammab le, an assessment of overall risk in each end-use may be required. For flammable refrigerants, provide a fault tree analysis for each end use. For flammable foam blowing agents used in spray foam, provide a training program that addresses flammability concerns specific to this substitute. (See Appendix B to Instruc tions for sector-specific data requi rements for flammable substances).



### The agent in its pressed form is fl ammable with an auto-ignition temperature of 300°C. However, it is contained within a double-walled, insu lated, and hermetically sealed canis ter so exposure to flame is not a likely scenario. Ignition of the ag ent produces a fire suppressant aeroso l that is extremely effective.

Mark (X) this box if this page contains CBI __________ 

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### 17

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 O DPs of the

individual constituents. Reference the source for each ODP. (b) Provide any additional data on the ODP of the alterna tive (e.g. atmospheric lifetime, chlorine or bromine loading pote ntials). Reference the source of this information and attach any supporting documentation.



### Stat-X ® Aero-K ® contains no halogens and, therefore, has a zero ODP.

2. Global Warming Characteristics: (a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) rela tive to carbon dioxide over 100-y ear time horizon, and 20-year or 500-year time horizon, if known. Referen ce the most recent assessment report of the Intergovernmental Panel on Climate Change (IPCC AR4). Alternate sources may include the 2010 World Meteorological Organizati on (WMO) Scientific Assessmen t of Ozone Depletion or the peer-reviewed literatu re. If the substitute is a blend, provide the GWPs of the i ndividual constituents and an estimate of the blend at its nominal composition. (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 theore tical and actual testing). Energy efficien cy information is particularly useful f or refrigerants and

foams. (c) For GWP values that do not come from AR4 or WMO 2010, provide any available additional data on the atmospheric lifetime and GWP of the alternative, including infrared ab sorption spectrum and infrared absorption cap acity. Reference the source of this info rmation.

Mark (X) this box if this page contains CBI __________ 

## x Part II - ALTERNATIVE-SPECIF IC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATIONForm 1265-07 (Revised 09/2011)
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### 18

Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulat ed under other environmental regul atory statutes such as those listed below. List any concentration-ba sed or other numerical standards to which the alternative is sub ject under the standards and regulations.

Titles of the Clean Air Act (CAA) other than Title VI : contains no hazardous air pollutants, no Class 1 ozone depleters and no Class 2 ozone depleters.

the Clean Water Act (CWA): is not listed as a Hazardous Substance unde r the CWA, not listed as a priority pollutant and is not listed as a toxic pollutant under the CWA.

the Safe Drinking Water Act (SDWA ): None known

.

the Resource Conservation and Recovery Act (RCRA): has none listed for RCRA D- Series Maximum C oncentration of Contaminants; RCRA D-Series Chronic Toxicity Reference Levels; RCRA F-Series; RCRA P-Series; nor RCRA U-Series.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA

the Toxic Substances Control Act (TSCA): is liste d on the TSCA inventory; is not on the Health & Safety Reporting List; is not under a Chemical Test Rule; is not listed under TSCA Section 12b;

does not have a SNUR under TSCA.

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): does not have an RQ under

CERCLA

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 302); does not have a TPQ (Section 302).

State and local laws: can be found on the following state right to know lists: New Jersey, Florida, Pennsylvania,

Massachusetts.

Other applicable environmental federal, state, and local laws not mentioned above : SARA Codes: flammable; is not reportable under Section 313.

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under healt h 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 Tr ansportation (DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the above st atutes and regulations. Also list any other standard-setting organizations such

as the National Fire Protection Association (NFPA), the American Society of Hea ting, Refrigerating, and Air Conditioni ng Engineers (ASHRAE), or Underwriters Laboratories (UL) that will evalua te the substitute from a health and safety perspective.

Food and Drug Administration (FDA) for Not applicable

Occupational Safety and Health Administration (O SHA) and other Exposure Limits for NIOSH Exposure Limit: None Listed ACGIH Exposure Limit: None Listed

OSHA Vacated PELs: None Listed

Department of Transportation (DOT): is Hazard Cl ass , Packing Group III

State and Local Laws: California No Signifi cant Risk Level: is not listed

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
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### 19

Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDA RDS

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulat ed under other environmental regul atory statutes such as those listed below. List any concentration-ba sed or other numerical standards to which the alternative is sub ject under the standards and regulations.

Titles of the Clean Air Act (CAA) other than Title VI : contains no hazardous air po llutants, no Class 1 ozone depleters and no Class 2 ozone depleters.

the Clean Water Act (CWA): is not listed as a Hazardous Substance under the CWA, not listed as a priority pollutant and is not listed as a toxic pollutant under the CWA.

the Safe Drinking Water Act (SDWA) ): None known.

the Resource Conservation and Recovery Act (RCRA): has none listed for RCRA P-Series and none listed for RCRA USeries.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA

the Toxic Substances Control Act (TSCA): is listed on the TSCA inventory; is not on the Health & Safety Reporting List; is not under a Chemical Test Rule ; is not listed under TSCA Section 12b;

does not have a SNUR under TSCA.

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA ): None of the chemicals in this material have an RQ.

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 302); does not have a TPQ (Section 302); is not reportable under Section 313.

State and local laws: is not present on state lists from California, Pennsylvania, Minnesota, Ma ssachusetts, Florida or New Jersey.

Other applicable environmental federal, state, and local laws not mentioned above : None known

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under healt h 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 Tr ansportation (DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the above st atutes and regulations. Also list any other standard-setting organizations such

as the National Fire Protection Association (NFPA), the American Society of Hea ting, Refrigerating, and Air Conditioni ng Engineers (ASHRAE), or Underwriters Laboratories (UL) that will evalua te the substitute from a health and safety perspective.

Food and Drug Administration (FDA) for Not applicable

State and Local Laws: California No Signifi cant Risk Level: is not listed

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 20

Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulat ed under other environmental regul atory statutes such as those listed below. List any concentration-ba sed or other numerical standards to which the alternative is sub ject under the standards and regulations.

Titles of the Clean Air Act (CAA) other than Title VI : contains no hazardous air pollutants, no Class 1 ozone depleters and no Class 2 ozone depleters.

the Clean Water Act (CWA): is not listed as a Hazardous Substance unde r the CWA, not listed as a priority pollutant and is not listed as a toxic pollutant under the CWA.

the Safe Drinking Water Act (SDWA ): None known.

the Resource Conservation and Recovery Act (RCRA): is not a RCRA hazardous waste.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA

the Toxic Substances Control Act (TSCA): is not required to be on the TSCA list.

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): is not a CERCLA chemical.

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 302); does not have a TPQ (Section 302); is not reportable under Section 313.

State and local laws : None known

Other applicable environmental federal, state, and local laws not mentioned above : None known

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under healt h 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 Tr ansportation (DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the above st atutes and regulations. Also list any other standard-setting organizations such

as the National Fire Protection Association (NFPA), the American Society of Hea ting, Refrigerating, and Air Conditioni ng Engineers (ASHRAE), or Underwriters Laboratories (UL) that will evalua te the substitute from a health and safety perspective.

Food and Drug Administration (FDA) for Not applicable

Occupational Safety and Health Administration (O SHA) and other Exposure Limits for OSHA TLV TWA: 5mg/m 3

Department of Transportation (DOT): is not regulated under DOT.

National Fire Protection Associati on: has no NFPA rating.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 21 Part II - ALTERNATIVE-SPECIF IC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. Fo r alternative processes and tec hnologies, describe installation costs associated

with the alternative. Please describe the information used as the basis for this cost estimate.

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. 

### (a) Currently produced

3. Describe any new equipment and use pr ofiles that will be necessary in order to use the substitute. If retrofitting of exis ting equipment is required, detail changes in technologies needed to use the alte rnative 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

.



### Systems do not require pressure vessels or piping networks and are easily mounted in a distributed layout throughout the protected volume. Can be easily retrofitted into any area. Integrates with existing releasing panels and detection. Labor cost s for installation are a fr action of that associated with other alternatives. Maintenance costs are also significantly reduced (minimal).

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 22 Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and fo r chemicals used with alterna tive processes, summarize below (and attach supporting information on) the acute and chronic toxicity of the substitute and of its constituent chemicals on any or ganism (e.g. human and/or other mammals, fish, wildlife, and plants), if available. In clude any data on impurities a nd degradation products if known. Also include informati on on any permissible exposure limits (PELs), occupational exposure limits (OELs), or Acceptable Exposure Limits (AELs) that have been se t for the substitute for use in the workplace. In addition, please attach a copy 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 Pgs. 16-17 of the Instruct ions for sector-specific requirements for toxicity testing).



### Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site (for manufacturing of substitutes and/or product s containing substitutes):

(a) Identify all site locations (i.e., name and address) for each chemi cal manufacturing process. (b) Identify all site locations for manufacturing of products using substitutes (e.g., refrigerators containing the substi tutes). (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products cont aining 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).



### (a) Fireaway Inc., 1006 2 nd 

### Street – Area J, Camp Minden, LA 71005

Chemicals are received in solid form at location (above). Potassium nitrate and DCDA are used as

delivered. Resin is dissolved in acetone and mi xed with other ingredients into granulated formulation, which is pressed into finished charge. Finished aerosol forming pellets are shipped to Fireaway in Minnesota for assembly into finished units.

(b) Fireaway Inc., 5852 Baker Road, Minnetonka, MN 55345

(c) All the three chemical constituents of Stat-X ® 

### Aero-K ® are solids as is the final product. No releases are expected during manufacture or shipment.

(d) N/A

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 23 Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

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

(a) Describe the activities in which workers may be expos ed to chemicals at the manufactur ing facility. Answer items (b) through (g) for each activity. (b) Describe any protective equipment and engineering controls used to protect workers (e.g., goggles, gloves, chemical ho ods). (c) Indicate the physical form of chemicals at th e 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 of measure.



### (a) The two activities during which exposure is possible are processing chemicals into pressed charges and assembly of the generator containing the charge.

(b) The production facility is ISO 9002 certified and qualified to MIL procedures. Employees utilize goggles, gloves, masks, chemical suits as appropriate to the operation.

Section D - ENVIRONMENTAL RELEA SE AND DISPOSAL IN END-USE

For each end-use of a substitute (end-uses using the substitute in products and/or processes):

(a) Provide the estimated amount (in kg/day) of each chemical released to the environment (e .g., as a solid waste or waste water effluent) at the point of, or subsequent to, the end-use at a site using th e 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 poi nt. (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 subs titute is to be disposed of, indicat e the method and location of disposal. (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. (e) Identify the approximate number of sites expected to use the substitute. (f) Provide information on recycling of the subs titute. Describe any associated costs and equipment.



### (a) Releases will occur only when the device is used to extinguish or suppress a fire or explosion. The amount of release depends on the magnitude of the event.

(b) The aerosol with gases will be released to the air.

(c) Release is necessary to address the fire/explosion threat.

(d) The particulate released to protect against fi res and explosions are not covered under RCRA. Trace amounts of some gaseous byproducts covered under RCRA are negligible.

(e) Number of sites: Depends on market penetration, average size of protected volume, etc. Estimate <7,000.

(f) Recycling of an agent used to extinguish fires and explosions is neither possible nor practical.

Mark (X) this box if this page contains CBI __________ 

## xForm 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 24 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 pr oducts and/or processes):

(a) Describe the activities in which workers may be expos ed to chemicals at the end-use (i.e., during installation, mainte nance, inspection, servicing, or use). Answer ite ms (b) through (g) for each activity. (b) Describe any protective equipment or engineering c ontrols used to protect workers (e.g., goggles, gloves, chemical hoo ds). (c) Indicate the physical form of chemicals at th e 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, i nhalation, dermal). (g) Estimate the average and high-end exposure concentrati ons (separated by a /), being sure to provide units. Personal m onitoring data may be required for some end uses (see pgs. 17-18 of Instructions).



### (a) No exposure possible during transportation, installa tion or maintenance. Chemical in solid form is contained within a double-walled, hermetic ally sealed metal cylinder. Exposure due to discharge unlikely. Systems are installed in unoccupied or normally unoccupied areas. Predischarge alarm and 60second time delay, system “l ockout” mandatory if personnel may be in the

area. (b) Exposure due to discharge unlikely. Systems are installed with pre-discharge alarm and 60second time delay, system “lockout” mandatory if personne l may be in the area. In event of discharge protective breathing apparatus and gloves required if entering area after the event.

(c) No exposure during handling. In case of discharge aerosol consists of gas (30%) and solid particulate (70%).

(d) Impossible to estimate – minimal.

(e) N/A

(f) N/A


## (g) N/A – maximum standard design concentration is 100g/m 3 

### . Average is 75g/m 3 

### . Actual exposure in event of accidental discharge w ould be much lower than these figures.

Section F - CONSUMER EXPOSURE

For each end-use of a substitute (end-uses where a consumer might be exposed):

(a) Identify the potentially exposed consumer population (e.g ,. indoor residents). (b) Identify the exposure medium (e.g., air). (c) Enter the contact pathway (e .g,. ingestion, i nhalation, dermal). (d) Describe the exposure point of concentration. Provi de (1) average and (2) high-end concentration estimates, including units of measure.



### (a) N/A

(b) Air

(c) Inhalation

(d) N/A due to engineering and application restrictions.

Mark (X) this box if this page contains CBI __________ 

## Form 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 25 Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULA TION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

(a) Identify and number poten tial general population exposure points. (b) For each exposure point described in (a), identify the potentially exposed population (e.g., residents at the fencelin e to the manufacturing facility). (c) Identify the c ontact pathway (e.g., ingesti on, inhalation, dermal). (d) Identify the exposure medium (e.g., air, water). (e) Enter the exposure point concentration (mg/m 3 or ppb). Provide (1) average and (2) high-end estimates.



### (a) None at manufacturing. Product is manufactured in the center of a square mile rural site.

(b) N/A

(c) N/A

(d) N/A

(e) N/A

Mark (X) this box if this page contains CBI __________ 

## Form 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 26 Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the que stions on this form or that provide additional information tha t may assist

EPA’s review of the alternative under Section 612 of the Clean Ai r Act. Also, provide citations for information already submit ted to EPA as part of past regulatory and information activities, as well as fo r other information that could not be included with this submi ssion. If you have attached continuation pages, describe the Part, Section and question numb er being continued. Attach additional pages if necess ary. Mark (X) in the CBI box next to any att achment that contains informa tion you claim as confidential.

Attachment Name Question # Number of Pages CBI



### The following 5 documents are attached

“ 

### Background Information for Revised Stat-X ® 

### /Aero-K ® 

### Risk

Screen ,” ICF to US EPA, January 31, 2007 Part I, Section B, 1 

### 4 X

“ 

### Risk Screen on Substitutes for Halon 1301

..... 

### Substitute:

Stat-X ® 

### /Aero-K ® 

### ,”ICF to US EPA, January 30, 2007 Part I, Section B, 1 

### 7 X

Hygiene-Institut-des-Ruhrgebiets Animal Exposure Study Part I, Section B, 1 

### 12 X

Charles River Animal Exposure Study Part I, Section B, 1 

### 42 X

MVA Particulate and Gas Effluent Report Part I, Section B, 2 

### 81 X

Documents not attached but supplied with initial submittal EPA-HQ-OAR-2005-0087-0009

US Patent # 6089326 Part I, Section B, 2



### US Patent # 5865257 Part I, Section B, 2



### US Patent # 6116348 Part I, Section B, 2



### US Patent # 6264772 Part I, Section B, 2



### US Patent # 5831209 Part I, Section B, 2



### US Patent # 6042664 Part I, Section B, 2



### Gas Effluent Test Report (Talley Defense Systems) Part I, Section B, 6



### Physical Properties Document Part I, Section B, 6



### Ozone Depletion Report Part II, Section B, 2



### MSDS Aero-K ® Part III, Section A



### MSDS Potassium Nitrate Part III, Section A



### MSDS DCDA Part III, Section A



### MSDS Organic Resin Part III, Section A



### Label (Current. Being revised w ith Underwriters Laboratories Canada) Part III, Section A

Mark (X) this box if this page contains CBI __________ 

## Form 1265-07 (Revised 09/2011)
OMB Control No.: 2060-0226

Previous editions are obsolete 

### 27 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 contro l 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 named in Part I, Qu estion 1a of this notice: (a) intends to manufacture, formulat e, 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 alternative(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 misinterpr etation is subject to criminal penalty pursuant to section 113 (c) of the Clean Air Act and 18 U.S.C.§1001.



### Signature and Title of Authorized Official (Original Signature Required) : Date

May 21, 2013

Signature of Agent (Where Applicable): Date

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 171 hours per year. For persons filing a TSCA/SNAP Addendum, the reporting bur den is estimated to average 36 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 techno logy and systems for the purposes of collecting, validating, and verifying information; adjust the existing ways to comply with any previously applicable instru ctions and requirements; train personnel to be able to respond to a collection of informa tion; search data sources; complete and review the collection of information; and transmit or otherwise disc lose 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, t he accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, incl uding through the use of automated collection techniques to the Director, Collection Strategies Division (2822T), U.S. Environmental Protec tion Agency,1200 Pennsylvania Ave NW, Washington, DC 20460. Include the OMB cont rol number in any correspondence. Do not send the completed form to this address.

# ATTACHMENTS 1, 2, 3, 4, and 5 OF SUBMITTAL ARE

CONFIDENTIAL BUSINESS INFORMATION IN THEIR ENTIRETY