April 4, 2011

U.S. Environmental Protection Agency

ATTN: Nathaniel Jutras, SNAP Division

1 200 Pennsylvania Ave. NW Mail Code 6205J Washington DC 20460

Re: Response s to Incomplete S NAP Submission for Firebane TM 1170

Dear Nathaniel,

Thank you and your team for taking the time to conference with us by phone on Monday,

March 20

. Below are our answer s to your questions 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 the estimated percentage of market at market

saturation.

GSL : The cost per pound to manufacture FirebaneTM 1170 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 irritati on. Which ionic

and non

- ionic soaps are included in the formulation?

GSL : Firebane 1170 was tested by RespirTek for toxicity, biodegradability, and eye and

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

.

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

non

- ionic but is not generally considered a soap . I t can be used , however, as the surfactant in detergents. For GSL’s Firebane TM 1170 agent, Tween 20 is used as an

emulsifier. MITCHAEL C. FREEMAN
VICE PRESIDENT, PRODUCT DEVELOPMENT & TESTINGFor Use as a Streaming Agent:

Alternative

- Specific Information

EPA : The submission indicates that FirebaneTM 1170 will be used in handheld extinguishers to suppress Class A (ordinary combustibles) and Class D (combustible metals) fires. Please explain how this substance could act as a Class D fire extinguisher when, as stated in Part III, Section E (c), the substitut e is stored as an aqueous solution that becomes a gas upon introduction to fire. Water can create an explosive reaction with

reactive metals. Please clarify the state (liquid or gas) of the aqueous substitute upon release from the extinguisher. If they are intended for suppressing Class D fires, please clarify which types of metal fires FirebaneTM 1170 will extinguish.

Additionally, has FirebaneTM 1170 been submitted for approval under UL Standard 711: Rating and Fire Testing of Fire Extinguishers?

GSL : Firebane TM 1170 ha s shown documented success extinguishing a wide variety of metals, including magnesium, titanium and lithium. Firebane TM 1170 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

. H alogenated agents also release highly toxic 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 exp losion occurs.

The temperature at which combustible metals, such as lithium, magnesium, and titanium,

burn can exceed 2,500°F. Because of the se excessive temperature s , the water molecules

dissociate into hydrogen and hydrogen oxide ( H 2 O  H + + OH - )

. T hus, the hydrogen ignites and increases the combustion and hydrogen explosive hazard. However, even though it is water

- based, FirebaneTM 1170 can successfully extinguish a Class D fire with little flaring.

Not only is the 1170 agent effective in extinguishing the fire , but it also cools the fire to ambient temperatures within seconds. This cooling effect results from the high number

of hydrogen bonds found in FirebaneTM 1170 . These hydrogen bonds cause it to have a very high specific heat (meanin g that more thermal energy or a lack of thermal energy is required to change its temperature). Heat capacity has to do with how well molecules are able to store (or trap) energy. This can include translational energy, molecular vibrations

and molecular rot ations. Hydrogen bonds provide another way for energy to be stored. As heat is added to the substance, some of that energy is expended in breaking the bonds,rather than simply raising the temperature. The more places a molecule has to deposit energy (degr ees of freedom), the higher the heat capacity.

The state of FirebaneTM 1170 agent when it is release from the extinguisher is a s a liquid.

The test for becoming a rated Class D agent includes fighting such fires as magnesium,

titanium and lithium

. Firebane TM 1170 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 Firebane TM 1170 is aqueous and

non

- toxic, there are no exposure issues for the charging of our handheld extinguisher. The approved quality manual currently uses a manual filling procedure. We have plans to submit an updated Listing & Labeling process using an automated system in the future.

Rele ase 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?

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

if FirebaneTM 1170 is intended to be sold for use as a fire suppressant at o ther sites, and how and where the substitute will be used including:

 The handheld extinguisher charg e size (i.e., the mass or weight of FirebaneTM

1170 in an extinguisher)

 The range of room sizes where the handheld extinguishers containing FirebaneTM

1170 will be installed and approximate room size dimensions for where the substitute will be manufactured. For streaming agents, it is necessary to determine an instantaneous exposure level (i.e. the concentration of the substitute of minute after release)? F or 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 per 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 airflow rate that would provide proper ventilation in areas where the fire extinguisher would be used?GSL : The FirebaneTM 1170 agent is in a liquid state 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 1170 agent is dispersed through various nozzles for various extinguishers used, depending on dispersement requirements. The

extin guishers are internally pressurized with nitrogen. When activated, the FirebaneTM

1170 agent will then travel through a hose and out of a nozzle.

Firebane TM 1170 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 o f Firebane TM 1170 . The bottles will be

bolted to the sidewalls of the HMMWV.

The typical compartment size of the protected vehicle into which Firebane TM 1170 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.

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

the airflow of Firebane TM 1170 out of the nozzle as a liquid. But, assumptions can be made about how the liquid will flow out of the nozzle, and to what extent it will displace the surrounding oxygen. One of those assumptions is that the pressure used to drive the

Firebane TM 1170 through the nozzle for discharge is low; there fore, 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 small . T herefore, Firebane TM 1170 is not extinguishing fire by depriving the compartment of oxygen, as some fire extinguishing systems do.

The liquid flow of Firebane TM 1170 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 used up to 10%, or in this case 455 liters , the

e ffect of Firebane TM 1170 is almost negligib le.

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 maintenance 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, identify the design concentration expressed volumetrically on a percent basis (for example, 5 percent v/v).

 For aerosol extinguishants, state the extinguishing application density and the design application density expressed in g/m 3

.

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

 What is the release rate of the fire extinguisher in g/sec?

 How does the fire extinguishe r material dispers e (e.g., is the charge distributed evenly throughout the room?)? Please provide information describing dispersal system (e.g., is the fire suppression agent a liquid which is vaporized upon release through the high pressure nozzle? Where are th e noz z les located?) Describe the behavior of the agen t upon release (e.g., agglomeration and settling).

 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 would provide proper ventilation in areas where the fire extinguisher would be used?

GSL: At this time, we are request ing that Firebane TM 1170 be considered as a n end

use 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