5852 Baker Road • Minnetonka, MN 55345

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com 10 / 29 /1 3

Ms. Rebecca Von D em Hagen

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

Re: EPA Follow u p Questions of 16 September 2013

Dear Ms. Von D em 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 i ndicates 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 mo del 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 f or 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/m 3 . In most cases, our application densities are in the range of 67 to 72 g/m 3 and we never exceed an application density of 100 g/m 3 in normally occupied spaces

. This is the case for applications of all s izes (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 wewill be able to achieve or maintain the design application density (which is even safer

from an e xposure 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 mak e 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 f ollowing:

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 di scharge 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 th e 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/m 3 ) is well below the 100 g/m 3 our 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 obscura tion, 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 docum ents 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