UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF
AIR AND RADIATION

June 23, 2014

Mr. Marc Gross

Fireaway Inc.
5852 Baker Road
Minnetonka, MN 55345

Re: Revised Completeness Determination for SNAP Submission for Stat-X/Aero-K

Condensed Aerosol System in Fire Suppression

Dear Mr. Gross:

Thank you for Fireaway Inc.’s submission to the Environmental Protection Agency (EPA) for
Stat-X/Aero-K Condensed Aerosol System in fire suppression. EPA established the Significant
New Alternatives Policy (SNAP) program to implement section 612 of the Clean Air Act. In
2006, SNAP published a final rule finding Powdered Aerosol D (under the trade names of Aero-
K® and Stat-X®) acceptable, subject to use conditions, as a halon 1301 substitute in total
flooding fire protection uses in normally unoccupied spaces only. Your submission for use in
normally occupied spaces and the additional information received on October 30, 2013, has been
reviewed for completeness. As we indicated in our letter to you sent on February 6, 2014, we
determined your submission to be complete. This letter is to confirm that your submission to use
Stat-X® in “normally occupied” spaces is for a use EPA has not previously reviewed under
SNAP. More than 90 days have elapsed since you provided a complete submission to EPA
regarding this use and thus that you may market Stat-X® systems for use in normally occupied
areas at this time.

Here is a summary of information concerning your submission:

Substitute name: Stat-X/Aero-K Condensed Aerosol System

Substance(s) the substitute will replace: Halon 1301
Sector: Fire Suppression
End-use: Total flooding applications in normally occupied areas
Date received: May 23, 2013
Most recent update received: October 30, 2013
Status of submission: Complete

We are currently reviewing your submission requesting that EPA list Stat-X® as acceptable for
use in normally occupied areas. If EPA determines to list Stat-X® as acceptable for use in
normally occupied spaces, we would take further action to revise the listing for Stat-X®. Before
issuing a final decision, we will review any public comments or other information that has
become available.

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If you have questions about the rulemaking process for your fire suppressant, please contact me
at (202) 343-9749 or Maranion.Bella@epa.gov.

Sincerely,

Bella A. Maranion
Alternatives and Emissions Reduction Branch
Stratospheric Protection Division