5852 Baker Road • Minnetonka, MN 55345

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

10/29/13

Ms. Rebecca Von Dem Hagen

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

United States Environmental Protection Agency

Washington, DC 20460

Re: EPA Follow up Questions of 16 September 2013

Dear Ms. Von Dem Hagen:

Thank you for the time spent with us today on the conference call. Please find our 

response to your questions below:

QUESTION 1

In response to Question 2a, Part II, the submitter indicates that Stat-X will be used in 

occupied spaces for marine applications. Please provide the minimum and average 

volumes and ventilation rates (prior to system activation) of the normally occupied 

spaces in which Stat-X will be used. We will use this information to do modeling of 

occupational exposure, and minimum volume is more relevant than maximum volume.

QUESTION 2

In response to Question 2a, Part IV, the submitter provided a list of Stat-X generator 

models and the maximum room volume that each model can protect. The diagram 

provided in response to Question 2b, however, illustrates seven generators “spaced 

evenly” in a single room. Please clarify whether multiple models are anticipated for use 

in a single room, as well as any constraints/guidance for the generator configuration 

(i.e., maximum number or generators allowed per room). 

In response to both Question 1 and Question 2, we offer the following:

We have provided exposure test data demonstrating that there are no adverse effects 

when our systems are used at an application density of 100 g/m3. In most cases, our 

application densities are in the range of 67 to 72 g/m3and we never exceed an 

application density of 100 g/m3in normally occupied spaces. This is the case for 

applications of all sizes (in terms of hazard volume) and for all system configurations 

(that is, those requiring single or multiple generators to achieve the proper application 

density). In all cases, our systems are configured to shut down ventilation before 

discharging the agent. If for some reason (like an unwanted discharge without a fire) 

the ventilation system is not shut down before agent discharge, then it is unlikely we 
will be able to achieve or maintain the design application density (which is even safer 

from an exposure standpoint). 

QUESTION 3

We would like a brief written substantiation of the reasons for CBI claims—for example, 

you are claiming the information as confidential business information in order to protect 

information, that if made public, would make your product less competitive.

In answer to Question 3, we offer the following:

We have marked as CBI any information that:

1. Relates to the exact chemical composition which is proprietary, and 

2. Relates to the identification of laboratories and the test data they have 

generated and we have submitted since the selection of these qualified 

laboratories followed an arduous and expensive path for us which we are 

unwilling to make public. 

QUESTION 4

The discussion on egress times, although informative, does not address the question. 

We want to know how reduced visibility might effect egress times. What is your 

estimate of the maximum egress time expected in situations where visibility is reduced 

in the protected space?

In answer to Question 4, we offer the following:

Our systems employ a pre-discharge alarm and time delay which are designed to alert 

personnel in the protected space to evacuate immediately and prevent the system 

discharge for a period of 30 seconds while they are exiting. In addition, our discharge 

time for the generator always installed in large spaces approaches 40 seconds and for 

approximately half that time obscuration from the discharged agent is not disorienting. 

So for all practical purposes, personnel have about 50 seconds to exit the space before 

obscuration can become disorienting. In all but very large or congested spaces this 

should be adequate time for personnel to safely exit the protected space.

Furthermore, we have to keep in mind that the agent application density employed in 

most cases (67 to 72 g/m3) is well below the 100 g/m3our test data has shown to be 

safe for at least 5 minutes exposure. 

However, recognizing that there is a possibility personnel cannot exit the space in the 50 

seconds of no or only partial obscuration, we have plans to incorporate supplemental 

means to guide personnel out of the protected space. There are several approaches to 

this and the one we prefer at the moment is the use of directional sound devices. We 

have provided you with several documents describing these devices and the science 

behind their use.
That being the case, we are prepared to accept a SNAP use restriction on our systems as 

follows:

“When used in normally occupied spaces, supplemental means shall be employed to 

guide personnel from the space if they are unable to exit before obscuration produced 

by the agent discharge causes disorientation.”

Please contact me if you require any further information.

Sincerely,

Marc V. Gross

President