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 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 answers 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 irritation. 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. It can be used, however, as the 

surfactant in detergents. For GSL’s FirebaneTM 1170 agent, Tween 20 is used as an 

emulsifier.

MITCHAEL C. FREEMAN

VICE PRESIDENT, PRODUCT DEVELOPMENT & TESTING
For 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 substitute 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: FirebaneTM 1170 has shown documented success extinguishing a wide variety of 

metals, including magnesium, titanium and lithium. FirebaneTM 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 CO2 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 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 explosion occurs. 

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

burn can exceed 2,500°F. Because of these excessive temperatures, the water molecules 

dissociate into hydrogen and hydrogen oxide (H2O  H

+

+ OH-). Thus, 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 (meaning 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 rotations. 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 (degrees of freedom), the higher the heat capacity.

The state of FirebaneTM 1170 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 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 FirebaneTM 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.

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 1170 is intended to be sold for use 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 

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)? 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 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 

extinguishers are internally pressurized with nitrogen. When activated, the FirebaneTM 

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

FirebaneTM 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 of FirebaneTM 1170. The bottles will be 

bolted to the sidewalls of the HMMWV.

The typical compartment size of the protected vehicle into which FirebaneTM 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.

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

the airflow of FirebaneTM 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 

FirebaneTM 1170 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 small. Therefore, FirebaneTM 1170 is not 

extinguishing fire by depriving the compartment of oxygen, as some fire extinguishing 

systems do. 

The liquid flow of FirebaneTM 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 

effect of FirebaneTM 1170 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 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/m3.

 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 which the fire extinguisher will be used.

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

 How does the fire extinguisher material disperse (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 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 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: At this time, we are requesting that FirebaneTM 1170 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