DEPARTMENT OF THE NAVY NAVAL RESEARCH LABORATORY 4555 OVERLOOK AVE SW WASHINGTON DC 20375-5320 ,m RcrL, RSr'ER to 7555 Ser 6180/0394 SEP 19 1000 From: Commanding Officer, Naval Research Laboratory To: Distribution Subj: DOD AFNk ENVIRONMENTAL MEETING Encl: (1)Minutes ofsubject meeting 1. The Navy Technology Center for Safety and Survivability ofthe Naval Research Laboratory hosted the DOD AFFF Environmental Meeting on 2-3 August 2000. The meeting was held to exchange information on environmental issues surrounding AFFF. The meeting was sponsored jointly by The Naval Facilities Engineering Command and the Naval Air Systems Command. 2. Enclosure(1)is a copy ofthe minutes of the meeting. 3. The NRL point ofcontact for this program is Dr. Frederick W. Williams, Code 6180,(202) 767-2476, email: fwilliam@ccs.nrl.navy,mil. Distribution Authorized to US Government Agencies and their Contractors Only: Al other requests shall be forwarded to: Commanding Officer Naval Research Laboratory, Wash. DC. THIS INFORMATION HAS NOT BEEN APPROVED FOR PUBLIC RELEASE. US00000605 Distribution: CNO(Code N-451H Barbeau) (Code N457C Ellis) NAVSEASYCOM (Code 05L4 McCrory, Williams) NAWC/WD (Code 4T3 OD Bowman) (Code 4T43 I OD Hoover, Wilson) (Code 4T42EOD Roper) MSC((DCE Parks) HQ/USMC(ASL-38 Bungcayao, Jr) (CSLE-ESE Romero) (LFL-6 Doherty) USACE(CECEW-ETE DiAngelo) USA/SFIM(AEC-EQC Scott) USA/FP (Kochhar) EPA (Dominick) (Code 6205J Rubenstein) FAA/TC(AAR-411 Bagot) NAVFACENGCOM (Donnally) (Code SF Gott) (Code ESC421 Lee) (CFPE Ruffini) (CFPE Simone) (F&MS Killen) HQ/AFCESA/CESM(Hansen, Walker) HQ/USAF/CEVQ (Shah) USAF(ARA Dierdort) MSC (Code N72PC1) NAVAIRSYSCOM (Code 4.3.5.1 Leach) (Code 8.1 Wolfe) NADEP(Code 4.3.4.7 Whitfield) DSC(Code IDA Klein) 2 US00000606 6380/0394A:F'WW September 12, 2000 Minutes Of the DOD AFFF Environmental Meeting Held at the Naval Research Laboratory Navy Technology Center for Safety and Survivability Washington, D.C. On 2-3 August 2000 End (1)to NRL Ltr 9555 6180/0394:FWW Distribution Authorized to US Government Agencies and their Contractors Only; All other requests shall be forwarded to: Commanding Officer Naval Research Laboratory, Wash. DC. THIS INFORMATION HAS NOT BEEN APPROVED FOR PUBLIC RELEASE. US00000607 Minutes of DOD AFFF Environmental Meeting Naval Research Laboratory 2-3 August 2000 Summary A meeting to discuss AFFF environmental issues within the Department of Defense(DoD)was held at the Naval Research Laboratory(NRL), Washington, D.C., on 2-3 August 2000. The meeting was hosted by Dr. Fred Williams, NRL, Director, Navy Technology Center for Safety and Survivability. The meeting was jointly sponsored by the Naval Facilities Engineering Command(NAVFAC)and the Naval Air Systems Command (NAVAIR). The agenda for the meeting is shown in Appendix (1). A list of attendees is provided in Appendix (2), along with a photo of attendees present at the opening general session on 2 August 2000. To facilitate future exchanges of information on this subject, Appendix(2)includes mailing addresses, phone numbers and E-Mail addresses for each attendee. Objective The overall objective ofthe meeting was to provide a forum for open discussion on AFFF environmental issues within DoD. Additionally, the meeting was called to address three specific objectives: (1) Assist NAVFAC in the development ofa DoD design policy for AFFF systems in aircraft hangars and other shore facilities to minimize adverse environmental impact. (2) Obtain information to assist NAVAIR in finalizing their AFFF Environmental Safety and Health Need Assessment Summary(ESH NAS)and in preparing the follow-on Development Plan. (3) Provide information for attendees on the relevant issues surrounding the decision by the 3M Company to phase-out production of AFFF and other products containing perfluorooctyl sulfonate(PFOS). Background There has been growing concern in the past few years about the potential adverse environmental impact of AFFF. This concern has been spawned by a number offactors: The establishment by EPA in 1994 ofthreshold quantities for reporting spills of AFFF due to the butyl carbitol commonly used as a solvent in AFFF Inadvertent activations of AFFF systems in hangars and the resultant clean-up and disposal Reports of problems created by the discharge of AFFF to waste water treatment facilities I US00000608 - Limitations on overboard discharges of AFFF by ships under the Uniform National Discharge Standards(UNDS)ofthe Clean Water Act Anecdotal reports of damage to aquatic life by discharge of AFFF to streams and waterways Various designations of AFFF waste, necessitating expensive disposal by specialty contractors Recognition ofthe persistence and limited biodegradability ofthe fluorocarbon surfactants in AFFF Publicity surrounding 3M's decision to phase-out production of AFFF and other chemicals containing perfluorooctyl sulfonate(PFOS) Claims by vendors of so-called "environmentally-friendly" AFFF alternatives As a result ofthese concerns, the affected Navy Systems Commands have undertaken various actions: - NAVFAC,under the auspices ofthe DoD Fire Protection Coordinating Committee, has started the development of design policy for shore facility Ai~PT systems to minimize discharges and to address environmental issues. NAVAIR has funded Concurrent Technologies Corporation to draft an ESH Need Assessment Study on AFFF, to be followed by a Development Plan that will recommend future action to alleviate identified problems. NAVSEA has reduced the frequency oftesting ofshipboard AFFF systems to minimize overboard AFFF discharge in compliance with the UNDS regulations. The meeting was called to share recent information and discuss issues relevant to the above concerns and on-going actions. Meeting Scope/Presentations The meeting consisted of general session discussions and presentations as well as two specifically focused breakout sessions. Copies ofthe general session presentations are provided as Appendices(3)— (10). Presentations given at the Hangar Facility breakout session are contained in Appendices(11) and (12). Overall summaries of each breakout session are provided in Appendices(13)and (14). Significant Discussion and Presentation Points There were many important points raised during discussion sessions or contained in formal presentations. Those considered to be the most significant are summarized below (additional details are contained in the appendices): - AFFF is a vital fire fighting agent for controlling and extinguishing flammable liquid fires. Within DoD, it is especially critical for fire scenarios where life safety is paramount, where ordnance is exposed or high value assets are threatened. 2 US00000609 The AFFF military specification (Mil Spec)is considerably more demanding than the applicable UL standard relative to speed ofextinguishment of a flammable liquid pool fire. The AFFF Mil Spec is widely cited in procurement specifications in the civil sector, especially at municipal airports. There are currently 5 manufacturers that have AFFFs on the Mil Spec Qualified Products List. There are many fire fighting foams that are commercially available. However, no non-AFFFs have been able to match the rapid fire extinguishment performance of AFFF. - At present there is no regulation or directive to modify the AFFF Mil Spec. - There is no recognized or universally accepted definition of"environmentally friendly" fire fighting foam. - NAVSEA is the designated DoD technical custodian ofthe existing AFFF Mil Spec. Only NAVSEA can formally change the Mil Spec, though it may be possible to develop a separate specification just for shore-based applications. Inconsistent policy and guidance have led to expensive and questionable secondary containment designs in recent shore facility projects. 3M is voluntarily phasing-out production of AFFF because the fluorocarbon surfactant in their AFFF biodegrades to perfluorooctyl sulfonate(PFOS). PFOS has been identified by EPA as environmentally persistent, bioaccumulative in blood, and toxic to aquatic life and laboratory animals(the degree varies by species). Levels ofPFOS measured in humans and found in blood banks is not considered to present a heath hazard at present levels. Concern is the potential for build-up over time. Other AFFF manufacturers do not produce AFFF that is currently believed to biodegrade to PFOS. It is not known if other AFFFs have a similar problem. EPA is currently in a fact-finding mode relative to other AFFFs. At present the EPA does not prohibit or limit specifically the manufacturing of AFFF. A comprehensive review offederal and local environmental regulations applicable to AFFF (and other foam agents) has just been completed (see Appendix (8)). All fire fighting foams have environmental properties and/or constituents that are regulated. Adverse impact on waste water treatment facilities is a major concern, primarily due to foaming. A "risk based" approach, using the Frequency Vs Severity concepts in Military Standard 882C, has been shown to be feasible for managing AFFF environmental issues in shore facilities. Such an approach may be applicable to other AFFF applications as well. The NAVFAC Facility AFFF Management Working Group will continue development of policy, with a completion goal of approximately 6 months. 3 US00000610 The next meeting ofthe NAVFAC Working Group is scheduled for October 12, 2000. NAVAIR will complete the AFFF Need Assessment Study and prepare the Development Plan to recommend a future course of action. There was a general consensus that a second follow-on DoD meeting should be held (host, location, dates — TBD). Depending on developments between now and the next meeting, a decision could be made to establish a governing charter for a DoD AFFF Environmental Steering Group and perhaps to designate a formal DoD "advocate" for the effort. 4 US00000611 List of Appendices (1) Meeting Agenda (2) List of attendees and photo (3) Presentation: "AFFF Performance Perspective," R.Darwin, Hughes Associates (4) Presentation: "NAVSEA Comments on the AFFF Mil Spec", R. Williams, NAVSEA (5) Presentation: "Hangar Facility AFFF Management Breakout Session Introduction", J. Gott, NAVFAC (b) Presentation: "AFFF Environmental Impact Breakout Session Introduction", J. Hoover, NAWCWD China Lake (7) Presentation: "Issues With 3M's Withdrawal from the Market", C. Hanauska, Hughes Associates (S) Presentation: "AFFF Environmental Impact Review", W. Ruppert, Hughes Associates (9) Presentation: "AFFF Management — Risk Based Approach", D. Verdonik, Hughes Associates (10) Presentation: "Phasing out a Problem: Perfluorooctyl Sul£onate", M.Dominiak, EPA (11) Presentation: Facilities Background and AFFF Issues", J. Simone, NAVFAC (12) Presentation: "AFFF Risk Assessment", A. Wakelin, Hughes Associates (13) Presentation: "Summary of Shore Facility AFFF Management Breakout Session", D. Verdonik, Hughes Associates (14) Presentation: "Summary of AFFF Environmental Breakout Session", J. Hoover NAWCWD China Lake and R. Darwin, Hughes Associates US00000612 APPENDIX (1) Meeting Agenda DOD AFFF Environmental Meeting Location: Building 207(Chemistry Building) Naval Research Laboratory, 4555 Overlook Ave, Washington DC,20735 Agenda: Wednesday August 2nd 0830 —0845 Welcome and Introduction -- Dr Fredrick Williams, NRL,Director, Navy Technology Center for Safety and Survivability. 0845-0915 AFFF Performance Perspective — Robert Darwin, Senior Engineer, Hughes Associates,Inc. 0915-0925 NAUSEA Comments on the AFFF Military Specification - Robert Williams, NAVSEA Fire Protection and Damage Control Division 0925— 0935 Hangar Facility AFFF Management Breakout Session Introduction Joseph Gott, NAVFAC,Director, Navy Facilities Safety and Health Office 0935 —0945 AFFF Environmental Impact Breakout Session Introduction —Dr.Jim Hoover, NAWCWD,Head, Combustion Research Branch 0945— 1000 Break 1000-1015 Issues Surrounding 3M Withdrawal from the Market — Chris Hanauska, Senior Engineer, Hughes Associates, Inc. 1015-1100 Presentation of AFFF Environmental Regulatory Aspects — Bill Ruppert, Senior Environmental Engineer, Hughes Associates,Inc. 1100-1130 Summary Presentation on Risk Assessment for Hangar Facilities — Dr. Dan Verdonik, Hughes Associates, Inc. 1130 —1230 Lunch 1230-1600 Breakout sessions Thursday August 3nd 0830 —0930 3M Withdrawal from Market — Mary Dominiak,EPA,Chemical Control Division, Office ofPrevention, Pesticides & Toxic Substances. 0930 —1230 Presentation of Breakout Session Conclusions. Discussion ofany further requirements to complete breakout session action items. US00000614 Hangar Facility AFFF Management Breakout Session Session Objectives and Details: The objectives of the Naval Facility Engineering Command(NAVFAC)hangar facility AFFF Management breakout session are: • To begin efforts toward developing a policy that details requirements for hangar facilities that will provide "adequate measures" to: (a) prevent an accidental AFFF discharge, (b)limit any adverse environmental impacts from a release. • To achieve an agreement on the definition of"adequate measures" and to begin to establish design criteria to meet them. Initial draft design criteria and costs ofspecific engineering solutions will be presented and discussed as a starting point. Agenda 1230 1315 1315- 1430 1430-1600 Facility Background and Issues — Joe Simone, Head Fire Protection Engineer, Naval Facilities Engineering Command Risk Assessment for Hangar Facilities — Alison Wakelin; Fire Protection Engineer, Hughes Associates, Inc. Design Criteria Discussion and Development List of Breakout Session Attendees: D. Verdonik (Chair) J. Gott W.Ruppert A. Wakelin J. Simone V. Donnally T. Ruffini D. Roderique G. Sadler L. Wolf K. Ellis M. Doherty K. Kochar B. Scott R. Talbot R. Hansen J. Shah F Williams US00000615 AFFF Environmental Impact Breakout Session Session Objectives and Details: The objective of this meeting is to share the technical data related to the environmental impact, status and the planned future use of AFFF. NAVAIR will use output from this session to ensure their Environmental Safety and Health(ESH)Need Assessment Summary (the where we are today)is accurate and complete, and to ensure their Development Plan (the where we go from here) is consistent with the need to provide sound fire protection in an environmentally responsible manner. The AFFF Environmental Impact working group will address the following questions: • What current and future environmental regulations impact AFFF use and why (data and politics)? • What data do we have(or lack) on the environmental impact of AFFF? • What technology or products exist that could help reduce AFFF releases into our environment or mitigate the impact ofthose releases? • What technology or products could be applied to recycle or reuse AFFF? • What alternatives to AFFF currently exist and how do they compare in effectiveness, cost, environmental impact, availability, etc? List of Breakout Session Attendees: J. Hoover(Chair) R.Darwin J. Scheffey C. Hanauska W.Leach D. McCrory R. Williams S. Wade M. Wade K.Bagot R. Morris B. Parks S. Johnson P. Bungcayo R. Lee R. DiAngelo D. Dierdorf J. LaPoint 1. Young US00000616 APPENDIX (2) List of? Attendees and Photo [B -L] Keith Sagot FAA FAA Technical Center AAR-411, Bldg. 296 Atlantic City International Ai Atlantic City, NJ 08405 Phone: 609-485-6383 bagot: kehh.bagot@tc.faa.gov Les Bowman NAWCWD China Lake Weapons Division Code 4T310D China Lake, CA 93555-6100 Paul G Sungcayao Jr USMC HOMC-ASL-38 2 Navy Annex Washington DC, DC 20380 United States Phone: 760-939-8813 Phone: 703-614-183v Fax: 703-697-7343 Phone: 410-737-8677 Phone Ext.: 228 Fax: 410-737-8688 Phone: 202-761-4803 Phone: 850-283-3734 Fax: 850-283-9797 Phone: 703-695-8541 Fax: 703-695-8550 doherty: dohertymc@hgmc.usmc.mil Mary F. Dominiak EPA U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington DC, MD 20460 dominiak: Dominiak.Mary@epamail.epa.gov Vincent R. Donnally Design Criteria Manager NAVFAC 1510 Gilt>ert Street Norfolk, VA 23511-2699 Christopher P. Hanauska Senior Engineer Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 21227-1652 Phone: 410-737-8677 Phone Ext.: 242 Fax: 410-737-8688 hanauska: hanauska@haifire.com Raymond Hansen Fire Protection Engineer USAF HQ AFCESAlCESM 139 Barnes Drive Suite 1 Tyndall AFB, FL 32403-5319 United States Phone: 850-283.6317 James M. Hoover Commander NAWCWD China Lake Naval Air Warfare Center Weapons Division 1 Administration Circle AItn:Code 4T431 OD, J.M. Hoover China Lake, CA 93555-6100 Phone: 760-939-1645 Phone Ext.: 473 Fax: 760-939-2597 hoover: HoeverJM@navair.navy.mil dierdorf: Doug.Dierdorf@tyndall.af.mil Michael C. Doherty Water Program Manager USMC Headquarters, U.S. Marine Corps (LFL-6) 2 Navy Annex Washington DC, MD 20380-1775 Phone: 202-685.9323 Hansen, Ray: Ray.Hansen@AFCESA.AF.MIL diangelo: Robert.M.DiAngelo@HQ02.USACE.ARMY.MIL Douglas S. Dierdorf Principle Scientist USAF (ARA) 139 Barnes Drive Applied Research Associates Suite 2 Tyndall AFB, FL 32403 Joseph E. Gott Director, Safety & Occupational Health NAVFAC Naval Facilities Engineering Command Code SF 1322 Patterson Avenue,SE Suite 1000 Washington Navy Yard, DC 20374-5065 gott: GottJE@navfac.navy.mil darwin: bdarwin@haifire.com Robert M. DlAngelo CECEW-ETE Army Headquarters U.S. Army Corps of Engineers 20 Massachusetts Avenue, NW Washington DC, MD 2031 4-1000 Phone: 703-602-2568 ellis: Ellis.Kathy@HQ.NAVY.MIL bungcayao: bungcayaoJRPG@hgmc.usmc.mil Robert L. Darwin Senior Engineer Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 21227-1652 Kathy Ellis Air & Wastewater Program Manager OPNAV(N45) Chief of Naval Operations, N4570 2211 Soulh Clark Place Rm 644 Arlington, VA 22206 Phone: 202-260-7768 Fax: 202-260-10% Samuel R. Johnson Enviromental Engineer MSC MSC code N72PC1 Washington Navy Yard Bldg 914 Charles Morris Ct, S.E. Washington DC, MD 20375 Kiran C.Kochhar Fire Protection Engineer Army P. O. Box 2250 201 Prince Frederick Drive Winchester, VA 22604-1450 Phone: 202-685-5765 Phone:540-665-3907 kochhar: Kiran.C.Kochhar@tacOl.usace.army.mil John LaPoint Manager Enviromental Processes Concurrent Technologies Corp. 9570 Regency Square Blvd. Suite 400 Jacksonville, FL 32225 Phone: 904-722-2505 lapoint: lapointj@ctc.com donnally: DonallyVR@efdlant.navfac.mil anrw. -Ct. w.w.m., US00000618 L-V William B. Leach Fire Protection Team Leader NAVAIR Naval Air Warfare Center Aircraft Division Attn: Bill Leach, Code 4.3.5.1 Bldg 562-3 Highway 547 Lakehurst, NJ 08777-5049 Phone: 732-323-1184 William H. Ruppert Senior Engineer Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 21227-1652 Phone: 410-737-6677 Phone Ext.: 283 Fax: 410-737-8688 ruppert: wruppert@haifire.com leach: LeachWB@navair.navy.mil Dr. Richard Lee Project Manager NFESC Code ESC421 Naval Facilities Engineering 1100 23rd Avenue Port Hueneme, CA 93043 Phone: 805-982-1670 Fax:805-982-4832 Joseph L. Scheffey Director Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 21227-1652 Dennis McCrory NAVSEA Naval Sea Systems Command Attn: Code 051-4 2531 Jefferson Davis Ffwy. Arfington, VA 22242-5160 Phone: 703-412-7687 Billy Ray Scott CWA Wastewater Program Manager Army SF I M-AEC-EQC BLDG E-4435 Aberdeen Proving Ground, MD 21010 Phone: 410-436-7073 Scott: Billy.Scott@aec.apgea.army.mii morris: morris_renee@bah.com Phone: 202-685-5764 Jay Shah USAF HQ USAF/CEVQ 1260 Air Force Pentagon Pentagon Washington DC, MO 20330-1260 Phone: 703-607-0120 shah: jayant.shah@pentagon.AF.mil Parks: Brad.Parks@msc.navy.mil Dawn Roderique TAMS Consultants, Inc. 2101 Wilson Blvd Suite 300 Arlington, VA 22201 Phone: 410-737-8677 Phone Ext.: 220 Fax: 410-737-8688 scheffey: joe@haifire.com mccrory: McCrMDM@NAVSEA.NAW.MIL Braddock L. Parks Damage Control Engineer MSC Military Sealift Command 914 Charles Morris Court Washington Navy Yard Washington DC, MD 2039&5540 Phone: 757-627-1112 sadler. gosadier@transystems.com lee: leed@nfesc,navy,mil Renee Morris Associate Booz, Allen & Hamilton, Inc. 1725 Jefferson Davis Highway Suite 1203 Arlington, VA 22202 George 4.Sadler Principal Glenn & Sadler 150 Boush Street Suite 1000 Norfolk, VA 23510 Phone: 703-312-1275 Joseph A. Simone Chief Fire Protection Engineer NAVFAC Naval Facilities Engineering Command 1322 Patterson Avenue SE Suite 1000 Washington DC, MD 20374-5065 Phone: 202-685-9177 simone: SimoneJA@navfac.navy.mil roderique: Droderique@TAMSCONSULTANTS.COM R Rubenstein EPA Code 6205 J U.S. EPA 1200 Pennsylvania Ave, NW Washington DC, MD 20460 Phone: 202-564-9155 Robert Talbot SVERDRUP 234 South Fraley Blvd. Suite 100 Dumfries, VA 22026 ta l bot: 9talborp@sverdrup.com rubenstein: rubenstein.reve@epa.gov T Ruffini NAVFAC c/o Chief Fire Protection Engineer 1322 Patterson Ave, SE Suite 1000 Washington DC, MD 20374-5065 P--61I Daniel P. Verdonik Director, Enviromental & Pollution Prevention Prog Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 21 227-1652 Phone: 202-685.9177 Phone: 410-737-8677 Phone Ext.: 236 Fax: 410-737-8688 verdornik: danv@haifire.com •]- P--KT'b N US00000619 [W -Y] S. Michael Wade Contractor ASN (S & S) OAS (I& E) Safety & SuvWbility Office Washington Navy Yard Bldg 36 720 Kennon Street, SE Rm 110 Washington DC, MD 20374-5028 Phone: 202-685-6858 Fax: 202.685-6862 wade: wade.stanleyghq.navy.mil Stanley R Wade Jr Senior Engineering Technician M. Rosenblatt & Sons 2341 Jefferson Davis Hwy Suite 500 Arlington, VA 22202-3885 Phone:703-415-7800 Phone Ext.: 640 Fax: 703-415-7828 Wade, S: swadeomrosenblati.amsec.com Alison Wakelin Fire Protection Engineer Hughes Associates, Inc. 3610 Commerce Drive Suite 817 Baltimore, MD 212274 United States Phone: 410-737-48677 Phone Ext.: 282 Fax: 410.737-8677 wakelin: awakelin@haifire.com Fred Williams Director NRL NRL Code 6180 4555 Overlook Avenue SE Washington DC, MD 20375 Phone: 202-767-2476 Fax: 202-767-1716 Wiliams: WI iam(Dccs.nrl.navy.ntil Robert B. Williams NAVSEA Naval Sea Systems Command,051_4 2351 Jefferson Davis Hwy. Arlington, VA 22242-5160 Phone: 703-602-5552 Phone Ext.: 301 williams: WilliamsRB@NAVSEA.NAVY.MIL Eric Wilson Materials Manager NAWCWD China Lake Commander 1 Administrative Circle Code 4T4310D (E. Wilson) Ridgecrest, CA 93555 Phone: 760-939-8064 Wilson: wilsone@navair.navy.mil Larry Wolfe NAVAIR Code 8.1 NAVAIRSYSCOM Bldg 404 22145 Arnold Circle Patuxant River, MD 20670-1541 Phone: 301-757-2132 wolfe: wotfelg@navair.navy.mil Iris Young Chemist-Analytical & Environmental Studies Canada National Defense Dept. of National Defense Quality Engineering Test Est. Ottawa, ON, Canada K1 OK2 Phone: 819-9941681 Fax: 619-997-4096 young: i.young@debbs.ndhq.dnd.ca RtvQm YIVIOW RYAN rN~MTI b 1MnlCM US00000620 Top Row: C. Hanauska, D. McCrory, J. Simone, L. Wolf, K. Bagot, M. Doherty, B. Parks, J. LaPoint, S. Johnson, R. Hansen, R. DiAngelo Middle Row: W. Ruppert, B. Williams, D. Roderique, J. Hoover, J. Gott, J. Scheffey, D.Verdonik, J. Shah, W.Leach, P. Bungcayo, R. Darwin, K. Kochar, R. Talbot, S. Wade Bottom Row: F. Williams, R. Morris, T. Ruffini, A. Wakelin, D. Dierdorf, B.R. Scott, I. Young, K. Ellis, G. Sandler, R. Lee, M. Wade US00000621 APPENDIX(3) Presentation: "AFFF Performance Perspective" R. Darwin, Hughes Associates, Inc. Baltimore MD US00000622 Robert L. Darwin,PE Senior Engineer Hughes Associates, Inc. AFFF Performance Perspective 2 August 2000 US00000623 History of Foam 1920-40 Chemical Foam 1940-70 Protein Foam (Air Foam) 1970-2000 AFFF AFFF Key Events: 1961 First experiments with fluorocarbon surfactants at NRL 1962 First Mil-Spec(Mil-F-23905, 1 Nov 63) 25 % concentration (fresh water only) Emphasis on twin agent application 1963 Large scale tests at NAS pensacola Led to procurement of 100 twin agent units 1964 Helo air borne TAU tests at NAS Miramar US00000624 1965 6% concentration developed by 3M (FC-194) 1966 Testing ofFC-194 in airfield crash trucks Selective conversion ofsome crash trucks 1967 Flight deck conflagration on USS Forrestal TAUS to aircraft carriers Push to develop seawater-compatible AFFF 1967 Seawater —compatible AFFF developed by 3M/NRL 1968 Additional crash truck tests at NAS Miramar 1968 Shipboard equipment tests w/ seawater at NAS Jacksonville First edition ofseawater/AFFF mil spec(Mill-F-24385) 1969 Flight deck conflagration on USS Enterprise Push to convert ships to AFFF 1970 Navy starts comprehensive conversion ofship systems and crash trucks 1973 USAF starts converting all USAF crash trucks US00000625 UL Listed Foams (Per UL 162-"Foam Equipment & Liquid Concentrates") AFFF — Aqueous Film Forming Foam FFFP — Film Forming Fluoroprotein FP — Fluoroprotein PF — Protein Foam Manufacturers Concentrates AFFF 24 110 FFFP 5 16 FP 12 26 PF 5 6 US00000626 Mil Spec Qualified Product List(QPL) Ansul Ansulite 3(AFC-5A)* Ansulite 6(AFC-5) * Type 3 Type 6 3M FC-203C FC-203CE FC-203CF Type 3 FC-206C FC-206CE FC-206CF Type 6 Chemguard C-301MS Type 3 National Foam Aer-O-Water 3-EM Aer-O-Water 6-EM Type 3 Type 6 Angus Tridol M Type 3 * Also UL Listed US00000627 "Application Density"(Defined as the Gallons of Agent Per Unit Area ofPool Fire Size) is the best measure of effectiveness for a flammable liquid pool fire Application Rate = GPM/Sq Ft of fire area Application Rate x Ext Time = Application Density GPM/Sq Ft x Minutes = Gals/Sq Ft Example Fire Area = 1000 Sq Ft Appl Rate of Agent — 200 GPM Ext Time = 0.5 minutes Appl Rate — 200 GPMJ1000 Sq Ft = 0.2 GPM/Sq Ft Appl Density = Appl Rate x Time = 0.2 GPM/SgFt x 0.5 minutes = 0.1 Gals/SgFt AFFF Performance Requirements Mil Spec(Mil-F-24385): Max Appl Density 2 gpm/28 sq ft x 30/60 minutes = .036 gal/sq ft = .12 gal/sq ft 2 gpm/50 sq ft x 50/60 minutes = .033 gal/sq ft Underwriters Laboratory: 2 gpm/50 sq ft x 3 minutes (Maximum extinguishment time is 5 minutes for fluoroprotein and protein foam) US00000629 Rapid Extinguishment ofPool Fires is Critical When: •Pool fire threatens high value assets(such as an aircraft hangar) •Pool fire under an occupied aircraft(must maintain fuselage integrity and rescue occupants) •Pool fire exposes weapons to potential "cook off' US00000630 Relative Performance ofFoam Agents on Pool Fires (Best) AFFF(Mil-Spec) AFFF(UL listed, non Mil-Spec) AFFF (non UL,non Mil-Spec) FFFP FP PF (Worse) Wetting Agents USOD000631 UL Listed Wetting Agents (Based on NFPA 18) "A liquid concentrate for addition to water to produce a solution having a greater fire extinguishing, efficiency than plain water" 13 Manufacturers: 11 Agents: US00000632 If Use Non-Film Formers: • Extinguishment time will be slower, unless application rate is increased • Higher application rate causes Greater system cost Greater quantity of agent emitted • Must consider possible need for "air aspiration" Replace nozzles Less reach than "non air aspirated" US00000633 AFFF Environmental Issue - 1994 Glycol Ethers(Butyl Carbitol), solvent in most AFFFs, placed on EPA list of hazardous air pollutants. Since no reporting threshold had been established, a default quantity of one pound per day was established for required reporting under CERCLA. Because Diethylene Glycol Butyl Ether(DGBE)typically comprises about 20 % of AFFF,spills ofjust a few gallons of AFFF had to be reported to the National Response Center and to State and local officials. One pound per day reporting requirement dropped in 1996. Some manufacturers substituted Propylene Glycol for Ethylene Glycol and declared their foam to be "environmentally friendly". US00000634 DOD Uses of AFFF • Shipboard Foam Systems • CFR Vehicles at Airfields • Aircraft Hangar Foam Systems • Misc Shore Facilities Hush Houses Jet Engine Test Facilities Hardened Aircraft Shelters Aircraft Fueling Stations Fuel Farms • Foam Sytems on Structural Pumpers US00000635 • Fires • Training Evolutions DOD AFFF Discharges • System Tests and Maintenance • Accidental/Malicious Discharges • Research and Development US00000636 There is a Need to Quantify and Characterize: • All DOD AFFF applications(What precisely do we use it for ?) • Precise quantities in service and in reserve stocks(How much do we have ?) • Annual emmisions(type and quantity)(How much do we discharge ?) US00000637 APPENDIX (4) Presentation: `NAUSEA Comments on the AFFF Mil Spec" R. Williams, Naval Sea Systems Command US00000638 NAVSEA Comments On the AFFF Military Specification Mil-F-24385F (Amendment 1 of 8/94) (Talking Points) Presentation to DOD AFFF Environmental Meeting 2 August 2000 Robert B. Williams Fire Protection & Damage Control Division Naval Sea Systems Command (Technical Custodian of the AFFF Mil-Spec) US00000639 1. I would like to express appreciation to NAVFAC and NAVAIR for sponsorship of this Conference. Also, I appreciate the opportunity to establish the NAVSEA perspective up front. 2. This conference is important and timely: Recently there has been a proliferation of Navy groups active in AFFF; usually with no focus, some scattered and uncoordinated EPA contacts. Recently there has been aggressive commercial marketing of so-called "environmentally friendly foams"; yet there is no established definition of "environmentally friendly foam". AFFF is subject of considerable hype: effect on sewage plants, danger to aquatic life, exposure results in mutant first born, etc. AFFF spills are media friendly- very visible, makes for good "films at 1111 , photos provide permanent record, helps stir up environmental activists Real issues from my perspective: 3M withdrawal and fall out relative to other QPL AFFFs Restrictions by AHJs; technical basis or not Unknown forthcoming EPA activity All are on agenda to be addressed 3. The product I personally desire of this conference is to specifically identify what the problems are regarding MILSPEC AFFF, and problems that are inherent to any foam alternative (visible, wastewater treatment plants). Appears money is & will be directed at AFFF. My concern is that funding needs to be attached to a focus on specifics that are documented as requiring resolution. US00000640 Navy labs and contractors see a golden egg out there on this topic; I personally don't want to see them going off into the sunset with a generic task to find an environmentally friendly firefighting agent. (whatever friendly means). The specific problems to be resolved require documentation before charging onto a search for solutions; doesn't always happen in correct order. The agenda appears to support what I hope is the conference objective. 4. A few quick comments about the MILSPEC and shipboard applications: NAVSEA is custodian; only NAVSEA can revise. appointed cannot. Self However, an alternate extinguishing agent specification under someone else's cognizance could be created. For example, it might be feasible to develop a separate specification just for shore facility use (fresh water only, one percent, universal foam, no refractive index requirement, etc). NAVSEA goal regarding the spec: Satisfy environmental requirements without degradation of firefighting effectiveness. If maintaining performance requirements is not possible, then where do we draw the trade-off line in the sand? (fish vs. sailors; national defense vs. environment) MILSPEC contents - shipboard oriented, even though it is essentially the national standard ashore and afloat: AFFF is for two dimensional shallow spill fires, rapid control and extinguishment are essential. No "foam-of -themonth" has matched the performance of mil-spec AFFF. Environmental provisions in spec; fish kill, BOD/COD limits, chemical restrictions. Compatibility: seawater effectiveness, intermixing of products from different manufacturers on QPL. It is an integrated match with our capital investment in hardware: viscosity, corrosion, pipe & tank materials, effect on seals/gaskets, a refractive index, container size & strength. US00000641 5. Our primary environmental involvement has been with the Uniform National Discharge Standards (UNDS) program which is relative to overboard discharge of liquids; basically a Clean Water Act action item. Our imput to EPA, which has been accepted thus far, is discharge management: New construction/alterations - no repeat testing, at sea Preventative Maintenance - reliable hardware, reduced testing periodicity Fewer ships Geographic restrictions: no discharges within 3 miles of coast, must be making at least 10 knots for discharges within 3-12 miles, preference for only discharging when greater than 12 miles out 6. In closing, I pass along that as custodian of the MILSPEC, I have no direction, pressure, or formal or informal tasking to conduct an environmental review of MILSPEC AFFF aside from the UNS. At NFPA aviation committee meetings I have queried major airport fire chiefs, all of whom stated no direction to pursue an alternative to MILSPEC AFFF. However, we at NAVSEA know whether politically, technically, or regulatory driven, environmental restrictions on AFFF may be coming. We fully support this conference, identification of problems & potential problems, and initiation of remedial research/actions. US00000642 APPENDIX(S) Presentation: "Hangar Facility AFFF Management Breakout Session Introduction" J. Gott, Naval Facilities Engineering Command US00000643 Hangar Facility AFFF Management Breakout Session Introduction (Talking Points) Presentation to AFFF Environmental Meeting 2 August 2000 Joseph Gott Director, Navy Facilities Safety and Health Office Naval Facilities Engineering Command US00000644 AFFF DOD Meeting 'Talking Points • Need a consistent DOD position on AFFF management • If we are not proactive, AFFF will become our next halon 1301 • AFFF is only product on market right now that meets our needs • Time for the design engineers, and environmental engineers to come together • The services have already done this with the Unified Design Guidance Group • As past chair ofDOD HE committee, we wrote the first tri-service design criteria • Fixed containment systems are affecting our mission because they have already caused the omission of AFFF from some hangars resulting in the air wings inability to perform their mission • This is the beginning ofa working group to address this important issue • Need to get all the right players • Need to address AFFF management from a risk assessment approach • Need to dismiss all the myths and fears and address the facts • Need to give the local regulators something to reference as adequate protection • Need to determine if additional research is needed to produce a different AFFF • Discuss changes to NFPA 409 - mandatory drains, reduced AFFF, various protection options • NAVFAC has long history in fixed AFFF systems, their behavior, problems, and design characteristics US00000645 APPENDIX(6) Presentation: "AFFF Environmental Impact Breakout Session Introduction" J. Hoover, Naval Air Warfare Center China Lake CA US00000646 AFFF Environmental Impact Breakout Session Introduction ('Talking Points) Presentation to DOD AFFF Environmental Meeting 2 August 2000 Dr. Jim Hoover Head,Combustion Research Branch NAWCWD China Lake US00000647 The purpose of the AFFF Environmental Impact Breakout Session will be to share technical information within the DoD on AFFF use and environmental impact. This information will be used to assist the completion of two environmental planning documents used by the Naval Air Systems Command (NAVAIR)- an Environmental Safety and Health Needs Assessment Summary(NAS)and a Development Plan. The NAS will provide a "snap-shot" of technical issues surrounding AFFF use and environmental impact, and the Development Plan will recommend a strategy for future efforts within NAVAIR. Background: The importance of AFFF in protecting Navy personnel and assets must not be understated. Likewise, public safety and commercial assets are highly dependent on AFFF for fire protection. Its firefighting performance remains unmatched and much remains unknown about its human health and environmental effects. Other services and agencies have data and experiences with AFFF that could assist the Navy in future decision making,so a forum for technical information exchange is needed. In planning for the future, all aspects of technical knowledge about AFFF (and all of its formulated components) should be considered. These should include costs, performance/function, human health and environmental effects, availability, inventory, alternatives, etc. Break-out Session Format: The following questions will be asked of the participants to promote discussion and information exchange. Participants will be invited to provide other questions. 1. What current and future environmental regulations impact AFFF use and why (data and politics)? 2. What data do we have (or Iack) on the environmental impact of AFFF? US00000648 3. What technology or products exist that could help reduce AFFF releases into our environment or mitigate the impact of those releases? 4. What technology or products could be applied to recycle or reuse AFFF? 5. What alternatives to AFFF currently exist and how do they compare in effectiveness, cost, environmental impact, availability, etc? b. What related planning documents exist with other services or agencies? 7. Whatfollow--on strategies should be considered? US00000649 APPENDIX (7) "Issues With 3M's Withdrawal From the Market" C. Hanauska Hughes Associates, Inc_ Baltimore MD US00000650 Issues with 3M's Withdrawal from the Market AFFF DoD Meeting Christopher Hanauska HUGHES ASSOCIATES, INC. FIRE SCIENCE & ENGINEERING August 2, 2000 US00000651 Purpose of this Presentation ■ Mary Dominiak of EPA will provide more detailed information tomorrow ■ Provide some background for her presentation ■ Frame the issue relative to the subjects of this meeting ■ This presentation is only an executive summary US00000652 Fluorochemical Surfactants (FC's) ■ FC's are a component of AFFF - One of several components in AFFF - FC's are difficult and expensive to make - Formulators have minimized (and attempted to eliminate) the FC content for 30 years - Necessary for performance (especially for CFR) • rapid fire knockdown • relatively low application rates US00000653 What is an F ? ■ CU17-functional group ■ Length of carbon chain varies ■ Fluoronated carbon chain is very stable ■ Functional group gives different properties j USOODO0654 FC's for AFFF Do Not Fully Biodegrade ■ 3M's FC's => PFOS (Perfluorooctyl Sulfonate) ■ Other FC's => ? ■ Functional group may biodegrade, but something is always left ■ Ultimate fate unknown ■ "Persistent" ~a USOODO0655 3M Performed Testing (Last 2 Years) ■ Found PFQS - in blood banks around the US - in fish and birds ■ Discovered toxicity issues - reproductive sub-chronic studies ■ `Bioaccumulative" and "Toxic" Vj US00000656 3M Voluntarily Phasing Out PFOS Related Chemicals ■ Scotchguard, Scotchban, industrial uses, AFFF ■ About 2 years for complete halt of production ■ Decision made at highest level of3M - were in discussion with EPA at the time ■ An unexpected and extreme action Vj US00000657 If Only 3M PFOS FC's are a Problem ■ Other non-PFOS FC based AFFF's are on the QPL ■ Possibly a short term supply issue ■ Should not be a major fire protection/environmental concern US00000658 Do Non=PFOS FC's Have a Problem-? ■ EPA has asked manufacturers to examine and test ■ What constitutes a "problem" uncertain - "Bioaccumulative""Toxic" ■ EPA will do risk/benefit and risk/risk analysis - Understanding of importance of AFFF to fire protection US00000659 Conclusions ■ No FC specific regulations exist ■ No apparent short teliii(1 year) problems ■ Mid-teint(2-3 years) problems related to supply only - as 3M withdraws from market ■ Potentially no long term problems(3+ years) ■ Unless other FC's have significant problems US00000660 APPENDIX(8) Presentation: "AFFF Environmental Impact Review" W. Ruppert Hughes Associates, Inc. Baltimore MD US00000661 Aqueous Film Forming Foam (AFFF) ENVIRONMENTAL IMPACT REVIEW Bill Ruppert HUGHES ASSOCIATES, INC. FIRE SCIENCE & ENGINEERING u.cnnnnnaao Background: AFFF Constituents ■ MILSPEC based on Performance, not Constituents ■ Must be on Qualified Products List - QPL ■ Main Ingredients in Firefighting Strength Foam: - WATER = 98%-99% - Butyl Carbitol (Glycol Ether)= 0.5%-1.1% - Fluorosurfactants & Hydrocarbon Surfactants = 0.03%-0.45% - Ethylene Glycol(Not in all formulations)= 0.34%-0.60% - Urea(Not in all formulations)= 0.2-0.4% V~ US00000663 Background: AFFF `Environmental' Properties ■ MIL-F-24385F Requirements - Chemical Oxygen Demand 3% Concentrate - 1,000,000 mg/L Max 6% Concentrate - 500,000 mg/L Max • Calculated Firefighting Strength - 30,000 mg/L Max Biochemical Oxygen Demand (20 Day) • =(0.65 X COD)or greater - Aquatic Toxicity (LC50, Killiefish) • 3% Concentrate - 500 mg/L Min • 6% Concentrate -1000 mg/L Min • Calculated Firefighting Strength - 16,667 mg/L Min ■ Persistence and Bioaccumulation Only Fluorosurfactants - Not in other constituents -- example: Butyl Carbitol log BCF = 0.46 ■ Foams j US00000664 Background: AFFF Properties Typical QPL Product FF MIL-F-24385F Requirements 6% 3% 22400 6% 341,000 3% 1,000,000 5009000 30,000 7509000 Max Max Max 21,600 >1000 >1000 (0.%*COD) (0.80*COD) 2745000 16,667 BOD20 > 0.65 x COD 500 Min 1000 Min >16,777 or >33,333 720,000 FF MILSPEC vs. Typical QPL Product Property Chemical Oxygen Demand (mg/L) Biochemical Oxygen Demand (mom) Aquatic Toxicity (Killiefish) (mg/L) E US00000665 Approach Codes and Standarus Survey ■ Electronic Review ■ Federal Environmental Regulations - "AFFF" - MILSPEC AFPF Constituents(19) • Surfactants • Fluorosurfactants • Glycol Ethers • Urea, etc. - AFF'N "Environmental" Properties • Biochemical And Chemical Oxygen Demands • Aquatic Toxicity • Foaming ■ DOD,State And Local Regulations 46 MILSPEC AYFF Constituents j US00000666 Codes and Standards Survey Federal Environmental Regulations ■ Clean Air Act(CAA) - Air Emissions Air Discharge Permits ■ Emergency Planning and Community Right-to-Know Act(EPCRA) Toxics Release Inventory(TRI) Chemical Storage and Use ■ Comprehensive Environmental Response, Compensation,& Liability Act(CERCLA) Superfund Amendments and Re-authorization Act(SARA) Spills and Clean-up Of Spills ■ Resource Conservation and Recovery Act(RCRA) - Hazardous Waste ■ Safe Drinking Water Act(SDWA) - Regulates Contaminants in Treated Drinking Water ■ Clean Water Act(CWA) - Water Discharges Water Discharge Permits j US00000667 Federal Environmental Regulations Results ■ Clean Air Act(CAA) - Glycol Ethers In AFFF Are Hazardous Air Pollutants(HAPs) - HAP Releases Are Regulated by the Installation Air Permit • Major Sources for HAPs Might Have Potential Permit Issue ■ EPCRA and TRI - Glycol Ethers are Covered Because CAA Defines them as HAPs. - Chemicals Released Above a Reportable Quantity(RQ)Must Be Reported • Default RQ was One(1)Pound • EPA Established a No RQ - At-4F 'Discharges Do Not Currently Need to Be Reported Under EPCRA and TRI - Ethylene Glycol Specifically Listed - No Other Constituent is Currently Regulated by EPCRA and TRI VUS00000668 Federal Environmental Regulations ■ CERCLA and SARA Results - Glycol Ethers are Covered Because CAA Defines them as HAPs Glycol Ethers May Need to Be "Cleaned Up" After a Spill • Air Pollutants So Expected to be Volatile — Are not volatile when mixed with water • Biodegradable So Might Be "Cleaned Up" Naturally ■ Resource Conservation And Recovery Act(RCRA) - AFFP and Its Constituents are Not Classified as Hazardous Waste - RCRA Does Not Apply ■ Safe Drinking Water Act: - Primary Drinking Water Regulations (Health Properties) • Does not regulate AFFF or its constituents - Secondary Drinking Water Regulations (Aesthetic Properties): • Foaming Agents <0.5 mg1L in drinking water • Do not regulate foaming agents in source water • Guideline for State Regulations Only(Not Federally Enforceable) j US00000669 Federal Environmental Regulations Results(Continued) ■ Clean Water Act(CWA) - Installations Require Discharge Permits • Storm Water • Treated Sewage from Installation Wastewater Treatment Plant • Raw Sewage to Public Wastewater Treatment Plant(Locale Specific) - Regulates Wastewater that: • Foam • Remove Oxygen From Water • Disrupt Wastewater Treatment Plants, etc. - AFFF • Persistent Foam • Removes High Amounts of Oxygen From Water(High BOD and/or COD) • Untreated, Undiluted AFFF Will Disrupt Wastewater Treatment Plant • (Even Diluted AFFF Can Disrupt Wastewater Treatment Plant) SDWA Vj US00000670 Codes and Standards Survey State/Local Environmental Regulations ■ State Regulations Can be More Strict Than Federal - No Specific Instances Found for AFF'F - Storm Sewer Regulations Emphasized ■ Nothing Additional in County and City Regulations ■ Representative Jurisdictions - Telephone Surveys - Focused on Jurisdictions In: • Virginia • Hawaii • Florida • California ■ Local Anecdotal AFFF `Problems' - Sewage Treatment Plants Becoming `Bubble Baths' - Pump Stations Burned-up' - Storm Sewer Overflowing With Foam j US00000671 State/Local Environmental kegulations (Continued) ■ Foaming the Greatest Concern ■ Perception: - Foam Is Highly Toxic to Everything - No Concentration is Okay for a WWTP ■ Results - Local Jurisdictions CAN and DO Regulate AFFF by Name - Have Water Discharge Permit Authority - Local Waste Water Treatment Plants Often Ban AFFF • Based on Direct Experience with a Disruption • High Oxygen Demand • Foaming ~a US00000672 Environmental Consequences ■ Media Considered - Air - Groundwater - Soil - Surface Water • Via storm water • Via wastewater treatment plant ■ Both Constituent Characteristics and AFFF Solution Properties V,~ US00000673 Environmental Consequences Media: Air ■ HAPS: Butyl Carbitol, Ethylene Glycol ■ Low Migration Potential(All Constituents) - Highly Soluble in Water • Tends to stay with liquid water • Not very volatile - If Volatilized, Half-lives in Air 4 Hr - 3.5 Days US00000674 Environmental Consequences Media: Groundwater ■ Consequence Varies Depending on Subsurface Conditions ■ Fluorosurfactants: Not Mobile ■ All Other Constituents: - Highly Soluble, Highly Mobile - Degrades Rapidly in Soil • 30% Degradation Over 24 Hour Period ■ Drinking Water Wells `Under the Influence of Surface Water' Could Receive Undegraded AFFF Constituents ~j US00000675 Environmental Consequences Media: Soil ■ Consequence varies depending on soil type ■ Fluorosurfactants and break-down products - Persistent in soil - No quantified environmental impact - EPA will discuss further tomorrow ■ Other constituents highly mobile in water, will not adsorb to soil ~j US00000676 Environmental Consequences Media: Surface Water Via Storm Water ■ Foaming: - Aesthetic Concern ■ Oxygen Demand - Robs Oxygen from Water - Usually near water's surface ■ Aquatic Toxicity Considered `Practically Nontoxic' by the US Fish and Wildlife Service. - Lowest toxicity value in 40 CFR 300 ■ Surface Water May influence Groundwater ■ `Environmental' Threat - Depends on Sensitivity of Receiving Water: Worst Cases • Kaneohe Bay, HI Risk Analysis "Potential for significant ecological damage ... relatively small" • Wetlands — Waterfowl-Fluorosurfactant Interaction being studied in St. Johns River Basin in Florida. • LC50 > 1000 mg/L in concentrate • --160 mg/L in most sensitive species • Much Lower Toxicity in Firefighting Strength - Anecdotal Reports of Higher Toxicity j US00000677 Environmental Consequences Media: Surface Water Via Direct Discharge to WWTP ■ Disrupts plant through: - Foaming • Disrupts mechanical devices • Causes `sludge bulking' • Causes Froth - High Oxygen Demand ■ Disrupted plant: - Contaminates receiving water - Could cause fish kill - Makes water unfit for: • Drinking • Recreation, etc. • Removes all oxygen - killing microorganisms used to treat sewage • Causes `sludge bulking'. - Aquatic Toxicity • Of lower concern than Foaming and Oxygen Demand • May cause `sloughing' of organisms from certain processes ~a US00000678 700 600 T- 500 X ® 400 v ca ® 300 200 COD t 600 Foaming Foaming w/anti-foaming 60 Kiiliefish Aquatic Toxicity- 60 (EC50) Microbe Toxicity 100 IN Foam Solution (Firefighting Strength) Representative Dilution Factors for Treatment of MAX M ILSPEC AFFF at a WWTP BO D20 agent Oyster Larvae Toxicity US00000679 70 y. 60' - ,--~ 50 X 0 40 U tC LL C 30 0 0 20 60 46 ❑ Baby Shampoo (1%) •Fluoro-Protein Foam (3%) •Non-MILSPEC AFFF(3%) ■ Baby Shampoo(3%) ® Protein Foam (3%) ❑ Class A Foam (1 %) El HI-EX (1 %) ❑ MILSPEC MAX(6%) ® MILSPEC MAX (3%) ■ QPL (MILSPEC)AFFF(3%) Representative Dilution Factors for COD of Foam Solution (Firefighting Strength) 60, 46 22 16 12 vo US00000680 Summary ■ Under Context of Current Laws/Regulations, AFFF and all other Foams Regulated Based On: - Properties • BOD,COD,Foaming and Aquatic Toxicity - "Listed" Chemical Constituents • Butyl Carbitol, Surfactants, Ethylene Glycol, Urea, etc. - Water Issues are Most Prevalent - Foaming is Major Issue for WWTP ■ Potential Environmental Impacts Generally Low - Impacts Consequence of • Foaming • 02 Demand • Aquatic Toxicity - Upset of WWTP Creates Greatest Impact J US00000681 APPENDIX(9) Presentation; AFFF Management — Risk Based Approach" D. Verdonik Hughes Associates, Inc. Baltimore MD US00000682 AFFF Management Risk Based • pproach HUGHES ASSOCIATES, INC. FIRE SCIENCE & ENGINEERING Dr. Dan Verdonik vi 1 US00000683 Why a isk. Based ■ From Environmental Review - AFFF / Foams have Similar Environmental Impacts • Based on the Properties of Foams in General • Worst Impact for WWTP - Hazard Exists - Cannot Alter What Would Happen IF Released ■ Can Reduce the If or Likelihood of Release . Coach- - Example - Double Hulled Oil Tankers • Hazard Exists from Potential Oil Spill • Double Hull Reduces Probabili~v of Having the Oil Spill • Double Hull Does Not Reduce Environmental Impact IF Have Oil Spill • Reducing Probability Reduces the Risk to the Environment ■ Need to Evaluate Probability ofFoam Release s Probability + Severity = Risk 6~j US00000684 Risk and ji,sk Assessments: ■ Military Standard 8820: System Safety Program Requirements - Define Terms • Risk - Combination of hazard severity AND hazard probability • Hazard Probability: Aggregate probability ofthe individual events • Hazard Severity: Consequences of worst credible mishap • Control: Action to Eliminate Hazard or Reduce Risk Applicable to All DOD Systems and Facilities Identify the Hazards and Impose Design Requirements and Management. Controls to Prevent Mishaps Tailor to Application • AFFF/Foam Discharge from Facility Fixed Fire Suppression System • Accidental Discharge • Pre-planned testing ■ Have Hazard Severity, Need Hazard Probability - Determine Risk - Risk Decision ~a US00000685 M1L =STD=882D 4.5,2 Hazard Probability ■ Potential occurrences per unit of time, events, population, items, or activity - Quantitative probability for potential design generally not possible - Qualitative probability • Derived from research, analysis, and evaluation of historical data ■ Given for Specific Individual Item or Fleet / Inventory ■ Assign Probability of Having Environmental Consequence USOD000686 REMOTE OCCASIONAL PROBABLE FREQUENT (E) (D) (C) (B) (A) Unlikely but possible to occur in the life of an item Likely to occur some time in the life of an item Will occur several times in the life of an item Likely to occur frequently obabl"f ty LevelS Quafitative ® r Specific Individual Item IMPROBABLE Vj So unlikely, it can be assumed occurrence may not be experienced 5 US00000687 4.5.' eat ■ Hazard Severity Category Definition - Provide Qualitative Measure of Worst Credible Mishap - Result of: • Personnel Error • Environmental Conditions • Design Inadequacies • Procedural Deficiencies • System, Subsystem or Component Failure or Malfunction US00000688 Q (4) (3) (2) (1) Minor Injury, Minor Occupational Illness, Minor System or Environmental Damage Severe Injury, Severe Occupational Illness Major System or Environmental Damage Death, System Loss, or Severe Environmental Damage itatiVre Hazard Severity Categories CATASTROPHIC CRITICAL MARGINAL NEGLIGIBLE Less Than Minor Injury, Occupational Illness, Less Than Minor System or Environmental Damage V-J US00000689 CATEGORY B - PROBABLE A - FREQUENT FREQUENCY I I CATASTROPHIC L 2 CRITICAL 3 MARGINAL 4 NEGLIGIBLE Risk. ji ssessment and Acceptance t C - OCCASIONAL D - REMOTE E - IMPROBABLE I im m Risk Index - Suggested Acceptance Criteria in MIL-STD-8820 Unacce 9 table: IA,IB,1C.2A.2D4 3A Undesirable: ID 2C 2D 3B 3C Acceptable w/ Review b DanalinI Activi Acce stable w/out Review: 4Cs_4D,,4E10 US00000690 eSJ.a] wit M,n Cn, ena ■ Design for minimum risk Review design criteria for inadequate or overly restrictive requirements Design to eliminate hazards If hazard cannot be eliminated • Reduce risk to an acceptable level through design selection • Interlocks, redundancy, fail safe design, system protection, fire suppression, and protective clothing, equipment, devices, and procedures ■ Recommend new design criteria supported by study, analyses, or test data. s VO US00000691 Probabilities Estimation System Description Hazard Identification Risk Determination Risk Acceptance Operate System Consequences Estimation Modify System US00000692 Probability Estimation VLI Likelihood of environmental consequence 3 Parts to Probability Estimation Probability of foam release Reliability of system controlling foam movement 11 USOD000693 -- it FIRE NO FIRE SUCCESSFUL SYSTEM RELIABILITY OF FOAM CONTROL MEASURES fit , Estwimati ba ' Normal Operating Condition PROBABILITY OF FOAM RELEASE NO FOAM SYSTEM ACTIVATION FOAM SYSTEM ACTIVATION SYSTEM FAILURE I CONSEQUENCE LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE ~~ NO CONSEQUENCE' CONSEQUENCE NO CONSEQUENCE US00000694 U011 E E E E E C D Sensitive Body of Water _ C C D D E E E E E E E E E E Soil Ground Water E E E E E E E E D D D D C D Wastewater Treatment Plant C E D E nee E C E E E D C D D E E E E E AIR E E E E E E E E E D C D D E D D D D E E E E E Accident Probability Est ental, Conse Of Environ 1. Sanitary sewer, WWTP 2. Segregated Storm Sewer 3. Plugged, Storm Sewer 4. Pavement, Plugged Storm Sewer/drains 5. Pavement, Plugged Combined Sewer/drains 6. Pavement, Combined Sewer WWTP 7. Pavement, Storm Sewer 8. Unlined Pond, Percolates 9. Lined Pond, Pump Off-Site 10 Lined Pond, evaporate 11. Lined Pond, Meter WWTP 12. Lined Pond, Meter Storm Sewer 13. Lined Pond, Degrade WWTP 14. Lined Pond, Degrade Storm Sewer 15. Tank, Pump Off-Site 16. Tank, Meter WWTP 17. Tank Meter Storm Sewer 18. Tank, Degrade WWTP 19. Tank, Degrade Storm Sewer ,3~ai US00000695 Consequence Estimation Severity of Environmental Impact Marginal Negligible/Marginal* Sensitive Body of Water Marginal Critical Soil Ground Water *Air becomes marginal if foam in WWTP US00000696 1. Sanita sewer, WWTP 2. Se re ated Storm Sewer 3. Plu ed, Storm Sewer 4. Pavement, Plugged Storm Sewer/drains 5. Pavement, Plugged Combined Sewer/drains 6. Pavement, Combined Sewer WWTP 7. Pavement, Storm Sewer 8. Unlined Pond, Percolates 9. Lined Pond, Pume Off-Site 10 Lined Pond, evas orate 11. Lined Pond, Meter WWTP 12. Lined Pond, Meter Storm Sewer 13. Lined Pond Des rade WWTP 14. Lined Pond, Degrade Storm Sewer 15.* Tank, Pum....Off-Site 16. Tank, Meter WWTP 17. Tank Meter Storm Sewer 18. Tank Des rade WWTP 19. Tank Des rade Storm Sewer 3E-' 4E 4E 4E 4E 3E L; 3D 3E,. 3E, 3E 3D 3D .3E 3E A -44 Sensitive Body of Soil Water Ground Water.......... 3C r.:3E .... .. ..i . .. .......... .. .. . .... . . .. ....................... !.%. ,. L 4E 2D 2C E A 00fE Q 2E ` ......213 Wastewater Treatment Plant 2C ... .. . . . . .... . . .. .. . . . . . 2E' 21) 2D 2D 3D gg " ~hl' z-I IM4i 3E E . 3E 3E 3E 3E 3E 21) 4E 4E 4E 3E 4E 4E 2D 2D 21) 20 3r3D 4E 3E 3E. 3E 3E 3D3E 313 3E 4E 3E 4E US00000697 Summary, ■ Control and. Management of AFFF Solutions - Based on Risk of Environmental Consequence • Risk Decision • Probability AND Severity - No "Unacceptable" Risks from Accidental Discharge - "Undesirable" Risks Avoidable through Design - Remaining Options All have Equivocal Residual Risk ■ Basis for Design Criteria - Ensure Risk is "Acceptable w/ Review by Managing Activity" Category - Minimizes Risk to the Environment - Does Not Increase Risk to Life-Safety/ Fire Loss 16 ~L US00000698 APPENDIX (1 o) Presentation: "Phasing Out a Problem: Perfluorooctyl Sulfonate" M. Dominiak Environmental Protection Agency US00000699 .iawnwi a. a we. . . wwym?k? .2: ?g 52. L. :PFOS is a very,stable chemical that does not''' .,:break down or degrade in the environment;.. =once it's thee, it stays,;. - PFOS can build up over time; its ha~flli "human blood is about 4 yeas: — Higher-ups in the food chain are exposed to the . Mull dose of what has. built up in their food US00000704 nfo .. . .: .. .xrqun xx?. . ?a my. . ?1123:, $35 ?may . .H . . . .xwmy 2 Em, W, 9.: i. y. yw .APB'• ~ ^'~ 3M will stop manufac PFOS for S`urf'ace ,-; treatment products by 12/31/2000; includes~~~~~~~ fabricicarpetlleather soil and stain resista~ Oe man paper coating products, bil cludingfood contact n • Caveat: May request permission for extended production for specific performance uses for; which adequate substitutes do not exist or can' s tracleo s, national, qualified in time; risk/risk security, technical performance issues US00000711 • All documents on PFOS in public EPA Administrative Record, File AR-226 — Includes all health studies submitted on PFOS — Available in hard copy or on CD ROM. 401 ;VI St, SW,Room NE B-607, Wash., DC,noon to 4 PM Eastern, Monday-Friday; telephone 202 260-7099. • Workin:g on website; not up yet, stay tuned • Interim:EPA "Voice of PFOS:" Mary Dominiak, phone 202-260-7768; doiiiiiiialc.iiiaryi~epa.crov US00000716 APPENDIX(11) Presentation: "Facilities Background and AFFF Issues" J. Simone Naval Facilities Engineering Command US00000717 Facilities Background And AFFF Issues Presentation to Hangar Facilities Breakout Session DOD AFFF Environmental Meeting 2 August 2000 Joe Simone Naval Facilities Engineering Command US00000718 FACILITIES BACKRCUND • Facilities that use AFFF - Aircraft Hangars, HAZIFLAM Buildings, Fire Fighters Test Facilities, Hush Houses, and others • Variety of Fire Protection Criteria in dw Last 10 Years • Variety of Containment Requirements • No Risk Analysis with respect to Environmental • Budget Proposals Guess or Don't Address Funding NAVAIR/NAVFAC HANGAR PROJECTS • Evaluated Detector & Sprinkler Response Time in Hangars • Evaluated Removing AFFF from Overhead Sprinkler Systems — Evaluated Using Lower AFFF Application Rate • Evaluated New Low Level AFFF Distibution Systems • Evaluated Variety of Optical Flame Detectors • Developed New Fire Protection Criteria s 3 US00000719 DESIGN PREVIOUS DESIGNS • Deluge AFFF Sprinklers • High Volume AFFF System (20,000 sq.ft. _> 5,000 gpm AFFF). • AFFF is used in the Ceiling and Low Level Systems • Full Discharge Testing • May or May not have Drainage System CURRENT DESIGNS • Closed Head, Water only Sprinklers • Low Volume AFFF System (20,000 sq.ft. _> 2,000 gpm AFFF & 3,000 gpm water) • AFFF is used in the Low Level System only • Test Ports for Discharge Testing • Drainage • Detection Technology • Can Include Abort Switches 3 AFFF MANAGEMENT ISSUES • Environmental Hazard is Not Quantified -- Toxicity?, Air?, Water? • No Uniform Criteria for AFFF Management(site specific) • Current Containment Requirements are Based on Worst Case • Cost of Containment Exceeds Project Funding • Exceeding Project Funding Results in Removal of Fire Protection Systems from Hangars - Impaired Mission 4 2 US00000720 CONTAINMENT ISSUES If Containment is Required: • Manual Intervention or Fixed Containment? • How Do You Size Containment(10 minutes of AFFF supply)? • Disposal - Is it necessary? 5 3 US00000721 APPENDIX(12) Presentation: "AFFF Risk Assessment" A. Wakelin Hughes Associates, Inc. Baltimore MD US00000722 Aqueous Film, Forming Foam (AFFF)Risk Assessment For discharges of AFFF from fixed fire protection systems in shore facilities Alison Wakelin HUGHES ASSOCIATES, INC. FIRE SCIENCE & ENGINEERING August 2, 2000 US00000723 Overview ■ Develop physical control options - Performance Criteria ■ Probability Estimation ■ Consequence Estimation ■ Risk Assessment ~j US00000724 Probabilities Estimation System Description Hazard Identification Risk Determination Risk Acceptance Operate System Consequences Estimation M od ify System V-j - US00000725 Develop Physical Options c ®ntrol ■ Hangar drainage requirements(NFPA 449) ■ Foam to the WWTP? ■ Other options for maintaining positive control of foam E US00000726 AFFF Discharge Hangar Floor Drainage No Hangar Floor Drainage I Sanitary Drains, Oil Water Separator, etc I To WWTP V-j US00000727 AFFF Discharge Hangar Floor Drainage No Hangar Floor Drainage Diverted from WWTP to? . ___j Apron/Pavement Vj US00000728 Diverted from W WTP to? Storm System Ditch/Pond Containment Tank Apron/Pavement with drainage E US00000729 Ditch/Pond Containment Tank Storm System Apron/Pavement with drainage Hold in Storm System r Percolate Evaporate Dilute Into WWTP or Storm System Pump & treat off-site Degrade into WWTP or Storm System r Environment V11 US00000730 Physical Control Options ■ 19 different control options ■ Sufficient number to show range of risks ■ Three options will be presented - data from all available on request Vj US00000731 ;le Physical C Sanitary System WWTP 1. Sanitary sewer with direct access to WWTP Hangar Floor Drains Diversion Normal Operation Pump & treat off-site Sanitary Sewer Do- Normal Operation Evaporation Percolation Sanitary Sewer Plugged Storm Sewer 2. Plugged, totally segregated storm sewer Hangar Floor Drains AFFF Release Diversion 3. Pond, Percolate (drains into soil) Hangar Floor Drains Unlined AFFF ~~~~~~~~~ Ditch/Pond US00000732 Performance Criteria ■ Detailed investigation of control options ■ What are performance goals of control options? - How much of a discharge needs to be controlled? ■ Accidental discharge shut-off in 3 mins? ■ Accidental discharge of all foam? V-] US00000733 Proposed Foam Control Criteria ■ Conservative approach all foam has drained to beyond diversion point ■ No emergency shut-off ■ 6 min drainage time ■ Single "module hangar 100 ft by 200 ft ■ Total flow - 16 min @ 2000 gpm = 32,000 gal Vj US00000734 Drainage Underground Drainage Pipes T Hangar Bay Floor Drainage Trenches I 01 Proposed Foam Control Criteria Diversion Point Trenches x-50 it on center—~ Single Module l~ Hangar Bay 200 it by 100 it US00000735 Probability Estimation Likelihood of environmental consequence 3 Parts to Probability Estimation Probability of foam release Reliability of system controlling foam movement -,/I 11~,- E US00000736 ~ ~ FIRE NO FIRE SYSTEM FAILURE SYSTEM SUCCESSFUL RELIABILITY OF FOAM CONTROL MEASURES 1~ ~ CONSEQUENCE NO CONSEQUENCE CONSEQUENCE NO CONSEQUENCE I. LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE ProbalbalI!t , Estimation Normal Operating Condition PROBABILITY OF FOAM RELEASE NO FOAM SYSTEM ACTIVATION FOAM SYSTEM ACTIVATION a. 00 US00000737 D REMOTE C OCCASIONAL B PROBABLE A FREQUENT So unlikely, it can be assumed occurrence may not be experienced Unlikely but possible to occur in the life of an item Likely to occur some time in the life of an item Will occur several times in the life of an item Likely to occur frequently Probability Estimation ~ation E IMPROBABLE V-0 US00000738 FIRE, i~0 FiR P .011ty Estulmati asii SYSTEM SUCCESSFUL RELIABILITY OF FOAM CONTROL MEASURES Foam System Activation Normal Operating Condition PROBABILITY OF FOAM RELEASE NO FOAM SYSTEM ACTIVATION ACTIVATION FOAM SYSTEM. ~ SYSTEM FAILURE I NO CONSEQUENCE CONSEQUENCE LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE b. CONSEQUENCE NO CONSEQUENCE 0a US00000739 Probability Estimation Foam System Activation ■ Accidental activation of a low level foam system ■ Likely to occur some time in the life of an item Occasional C Vj US00000740 -I. ffRF NO FIRE Pre iabilityr AstiMatia, NO FOAM SYSTEM ACTIVATION Condition/,, ' Normal Operating PROBABILITY OF FOAM RELEASE SYSTEM SUCCESSFUL RELIABILITY OF FOAM CONTROL MEASURES Foam Control Measures • FOAM SYSTEM ACTIVATION SYSTEM FAILURE I i NO CONSEQUENCE CONSEQUENCE LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE 1* CONSEQUENCE NO CONSEQUENCE E US00000741 Probability Estimation Foam Control Measures ■ An engineered design of each control measure is evaluated for: - Reliability • Likelihood of Control System Failure is Established • Failure based on complexity of system V~ US00000742 Sanitary System W ML a_~MiltY r Normal Operation Plugged Storm Sewer Unlined Ditch/Pond Normal Operation 10 Evaporation Percolation Sanitary Sewer 0 treat off-site Pump & Sanitary Sewer t • t110a . .ac_..tioa Occasional C Improbable E gelihood of system talilure WWTP 1. Sanitary sewer with direct access to WWTP Hangar Floor Drains Diversion 2. Plugged, totally segregated storm sewer Hangar Floor Drains AFFF Release Diversion 3. Pond, Percolate (drains into soil) Hangar Floor Drains AFFF Release ~a US00000743 ~ FIRE NO FIRE /ormal\~ Operating \ondition; i RELIABILITY OF FOAM CONTROL MEASURES SYSTEM SUCCESSFUL ~ CONSEQUENCE NO CONSEQUENCE CONSEQUENCE LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE ability Esti'matuion FOAM SYSTEM ACTIVATION NO FOAM SYSTEM ACTIVATION PROBABILITY OF FOAM RELEASE Environmental Consequence ~ P. SYSTEM FAILURE NO CONSEQUENCE VI-1 US00000744 Pr aba f l Estmli at, f ~ ental Consequence EViron:m n AIR Frequent Occasional Occasional Sensitive Body of Water _ Improbable Soli Ground Water Improbable Improbable Frequent Wastewater Treatment Plant Remote Remote Occasional Soil Ground Water Frequent Occasional Occasional Wastewater Treatment Plant _ Improbable Remote Successful Foam Control (Risk By Media) Frequent Improbable Sensitive Body ~ of Water Remote Remote Remote AIR 1. Sanitary sewer, WWTP 2. Plugged, Storm Sewer Remote Remote Remote Remote Unsuccessful Foam Control (Risk By Media) 3. Unlined Pond, Percolates 1. Sanitary sewer, WWTP 2. Plugged, Storm Sewer 3. Unlined Pond, Percolates VI-1 US00000745 F---io- FIRE NO FIRE i SYSTEM SUCCESSFUL RELIABILITY OF FOAM CONTROL MEASURES abolillix y Esti mattl, Environmental Consequence /rural\\\ Operating I> condition/ %, \, PROBABILITY OF FOAM RELEASE NO FOAM SYSTEM ACTIVATION FOAM SYSTEM ACTIVATION -I. SYSTEM FAILURE NO CONSEQUENCE CONSEQUENCE NO CONSEQUENCE CONSEQUENCE LIKELIHOOD OF ENVIRONMENTAL CONSEOUIENCE ! 1~ va US00000746 1 0 rosabillity Estimation Environmental Consequences FOAM SYSTEM ACTIVATION NO FOAM SYSTEM ACTIVATION PROBABILITY OF FOAM RELEASE SYSTEM FAILURE SYSTEM SUCCESSFUL RELIABILITY OF FOAM CONTROL MEASURES NO CONSEQUENCE CONSEQUENCE OCCASIONAL NO CONSEQUENCE CONSEQUENCE IMPROBABLE LIKELIHOOD OF ENVIRONMENTAL CONSEQUENCE Option 2: Plugged storm sewer Sensitive body of water FIRE NO FIRE OCCASIONAL PROBABLE Vj US00000747 Probability Estimation Suggested Range A FREQUENT 10-1 > X > 10-2 X > 10 Frequency Estimation B PROBABLE .3 10-2 > X > 10 -1 C OCCASIONAL 10"3 > X > 10-6 10-6 > X D REMOTE E IMPROBABLE E US00000748 rosab"Efi y Estimation E E E AIR C D E Sensitive Body of Water E E E Soil Ground Water C D E Wastewater Treatment Plant Environrw,ien al Consequence 1. Sanitary sewer, WWTP 2. Plugged, Storm Sewer 3. Unlined Pond, Percolates V~ US00000749 Consequence Estimation Severity of Environmental Impact Marginal Negligible/Marginal* Sensitive Body of Water Marginal Critical Soil Ground Water *Air becomes marginal if foam in WWTP Vj US00000750 1D 1 CATEGORY CATASTROPHIC 2D 2 CRITICAL 3 MARGINAL 4 NEGLIGIBLE Risk Assessment, & Acce.ptanice FREQUENCY A - FREOUENT B -PROBABLE C - OCCASIONAL D - REMOTE '.1 A, 1 B,1 C,2A,2B,3XI7 E - IMPROBABLE UNACCEPTABLE: 1D,2C9 2D,3B9 3C 4C,4D,4E UNDESIRABLE: ACCEPTABLE WITH REVIEW: ACCEPTABLE WITHOUT REVIEW: US00000751 Risk Assessment AIR 4E 4E Sensitive Body of Water 3C Soil Ground Water Wastewater Treatment Plant 2C 2D Environmental Consequence 1. Sanitary sewer, WWTP 2. Pluqqed, Storm Sewer 3. Unlined Pond, Percolates ~j 0600000752 FIRE NO FIRE FOAM SYSTEM ACTIVATION NO FOAM SYSTEM ACTIVATION ■ Normal Operating Condition PROBABILITY OF FOAM RELEASE Estimallt! O)nl RELIABILITY OF LIKELIHOOD OF i NO • NO CONSEQUENCE CONSEQUENCE CONSEQUENCE i —~= ~~ CONSEQUENCE ENVIRONMENTAL CONSEQUENCE SYSTEM FAILURE SYSTEM SUCCESSFUL FOAM CONTROL MEASURES Foam System Activation Pr d 6 j US00000753 Probability Estimation Foam System Testing ■ Should foam control systems be used for testing? ■ Foam system activation becomes probable ■ Reliability improved as testing supervised ~j US00000754 sk Assessment 313 Sensitive Body of Water For Foam Testing AIR 4D 4D 3C Sensitive Body of Water For Accidental Release AIR 4E 4E Soil Ground Water Soil Ground Water _ 2C 2D Wastewater Treatment Plant 28 2D Wastewater Treatment Plant Environmental: Consequence 1. Sanita sewer, WWTP 2. Plugged, Storm Sewer 3. Unlined Pond, Percolates 1. Sanitary sewer, WWTP 2. Plugged, Storm Sewer 3. Unlined Pond, Percolates V-- US00000755 Risk Assessment AIR Soil Ground Water 2D Wastewater Treatment Plant 2C 4E 4E 4E 3C 2D 21) 2D 2D 2D 2D 21) 21) 2C 2D 4E 4E 4E 4E 3C 4E 4E 4E 3C 4E 3C 4E Sensitive Body of Water 3C 3C Enviranmental. Consequence 1. Sanitary sewer, WWTP 2. Segregated Storm Sewer 3. Plugged, Storm Sewer 4. Pavement, Plugged Storm Sewer/drains 5. Pavement, Plugged Combined Sewer/drains 6. Pavement, Combined Sewer WWTP 7. Pavement, Storm Sewer 8. Unlined Pond, Percolates 9, Lined Pond, Pump Off-She 10 Lined Pond, evaporate 11. Lined Pond, Meter WWTP 12. Lined Pond, Meter Storm Sewer 13. Lined Pond, Degrade WWTP 14. Lined Pond, Degrade Storm Sewer 15. Tank, Pump Off-Site 16. Tank, Meter WWTP 17. Tank Meter Storm Sewer 18. Tank, Degrade WWTP 19. Tank, Degrade Storm Sewer US00000756 Costs ■ Single module, 16 minutes offoam discharge ■ Costs options we have identified are in the $0-200K range ■ More stringent control criteria can lead to much greater costs ■ However risk of an environmental consequence is not reduced ~j X300000757 APPENDIX(13) Presentation: "Summary of Shore Facility AFFF Management Breakout Session" D. Verdonik Hughes Associates, Inc. Baltimore MD US00000758 Summary of Shore Facility AFFF Management Break-Out Session Dan Verdonik 3 August 2000 US00000759 Facility AFFF Management Working Group • Decision to `formalize' a Working Group — Develop Facility Policy for AFFF Management • Changed name from "Hangar" to "Facility" to reflect broader scope • Target for Completion: Approximately 6 months — Develop a draft DoDI • Staff Through Environmental Side of Services • Present to OSD -- Next Meeting Scheduled for October 12 • Accepted-in-Principle the Risk Based Approach — Use as the Basis for the Policy -- Need to Review Details and Back-up Information — Report will be Provided Prior to Next Meeting US00000760 Office HQ NAVFAC HQ NAVFAC NAVFAC CNO N457C NAVAIR HQ NAVFAC (Contractor Representative) USACE USAGE ACSIM F&H USAGE/ACE AFCESA HQ USAF ILEV HQUSMC DCS/I&LFL HQUSMC DCS/I&LFF Name Joe Gott Joe Simone Vincent Donnally Ms. Kathy Ellis Larry Wolf Kim DePaul Dawn Roderique Bob DiAngelo K.C. Kochhar Bruce Park Billy Ray Scott Fred Walker Jayant Shah Michael Doherty Kevin King Facility AFFF Management Working Group -Membership Service Navy Navy Navy Navy Navy Navy Army Army Army Army USAF USAF USMC USMC _ • Additional Members To Be Identified Prior to Next Meeting US00000761 APPENDIX(14) Presentation_ Summary of AFFF Environmental Breakout Session" J. Hoover Naval Air Warfare Center China Lake CA R. Darwin Hughes Associates, Inc. Baltimore MD US00000762 Summary Of AFFF Environmental Impact Breakout Session Naval Research Laboratory 3 August 2000 Dr. Jim Hoover Head, Combustion Research Branch NAWCWD China Lake Robert Darwin Senior Engineer Hughes Associates, Inc. US00000763 Purpose ofBreakout Session Share Information on AFFF History, performance, chemical composition Environmental and human health impacts Regulations — current and future Replacement activity and status Future management strategy US00000764 (1) What current and future environmental regulations impact AFFF and why (data and policies)? Current: Different regulations affect different components of AFFF Presentation by Bill Ruppert yesterday provided good summary Except for UNDS,there are no definitive restrictions at present and no identified directives for change Future: Depends on future EPA assessment of AFFF as data is reviewed US00000765 (2) What data do we have(or lack) on the environmental impact of AFFF? Lacking: Component toxicityBOD/Persistence (Fate)/Bio-accumulation Accurate and appropriate dilution factors when AFFF discharged in open bodies of water Predictive capability/data regarding releases for estimating potential environmental damage. Must consider where the release occurs (shore hangars, runways, unpaved ground, ship bilges, at sea, etc) US00000766 (3) What technology or products exist that could help reduce AFFF releases into our environment or mitigate the impact ofthose releases? Depends on the type and location ofthe release Reducing releases: Reduction in system tests, efficiency improvements Spill response/advance planning/preparedness Mitigation: ASH (Air•sparged hydrocyclone) RO (Reverse osmosis) Biological/microbial systems Education and Planning: DOD guidance/standards on prevention, clean-up and disposal, training, intentional discharges US00000767 (4) What technology or products could be applied to recycle or reuse AFFF? Not considered to be feasible or cost effective (reformulation, losses, contamination) US00000768 (5) What alternatives to AFFF currently exist and how do they compare in effectiveness, cost, environmental impact, availability, etc ? None meet performance specification(mil spec) Development of an AFFF alternative was proposed as project under ONR Future Naval Capability Platform Protection Program Potential SERDP statement of need Some UK effort on environmentally friendly foam US00000769 (6) What related planning documents exist with other services or agencies? UK is reportedly working on a standard definition of"biodegradability" EPA presentation mentioned international dialog on AFFF PFOS issue USAF needs included in draft NAVAIR ESH-Needs Assessment US00000770 (7) What follow-on strategies should be considered ? Need accurate quantitative definition ofthe problem DOD inventory status How much AFFF in DOD/where used/in-service and reserve stocks/concentrate types DOD AFFF discharges How much released/consumed annually (training, system testing and maintenance, accidental discharges, research, fires) Review current DOD regs and policy Need a definition of"environmentally friendly"(need "green" definition—what are acceptable thresholds from an environmental standpoint) Persistence Biodegradability Bio-accumulation BOD/COD Toxicity US00000771 Follow-On Strategies(con't) Need for future research SBIR Goals for Universities ONR Need to develop small scale screening tests Develop"SNAP-equivalent" guidance Need for "worst case" transition plan (short/mid/long term) Information distribution to all levels(users, requirers, trainers, regulators, etc) Develop AFFF detection capability (learn method used by 3M) Define hazard protocols and appropriateness of AFFF(use and response) US00000772 Follow-On strategies (con't) Assess commercial state-of-the-art CBD announcement "Turkey shoot" of all available AFFF alternatives Quantify performance, chemical and physical properties Obtain EPA endorsement of screening tests Consider fixture mods to AFFF mil spec Prioritze requirements Consider trade-offs Establish formal AFFF working group Info sharing Formal charter DOD primary advocate? Future meetings/host/agenda topics US00000773 Summary Of AFFF Environmental Impact Breakout Session Naval Research Laboratory 3 August 2000 Dr. Jim Hoover Head, Combustion Research Branch NAWCWD China Lake Robert Darwin Senior Engineer Hughes Associates,Inc. US00000774 Purpose ofBreakout Session Share Information on AFFF History, performance, chemical composition Environmental and human health impacts Regulations — current and future Replacement activity and status Future management strategy US00000775 {1) What current and future environmental regulations impact AFFF and why (data and policies)? Current: Different regulations affect different components of AFFF Presentation by Bill Ruppert yesterday provided good summary Except for UNDS,there are no definitive restrictions at present and no identified directives for change Future: Depends on future EPA assessment of AFFF as data is reviewed US00000776 (2) What data do we have(or lack) on the environmental impact of AFFF? Lacking: Component toxicity/BOD/Persistence (Fate)/Bio-accumulation Accurate and appropriate dilution factors when AFFF discharged in open bodies of water Predictive capability/data regarding releases for estimating potential environmental damage. Must consider where the release occurs(shore hangars, runways, unpaved ground,ship bilges, at sea, etc) US00000777 (3) What technology or products exist that could help reduce AFFF releases into our environment or mitigate the impact ofthose releases? Depends on the type and location ofthe release Reducing releases: Reduction in system tests, efficiency improvements Spill response/advance planning/preparedness Mitigation: ASH (Air-sparged hydrocyclone) RO (Reverse osmosis) Biological/microbial systems Education and Planning: DOD guidance/standards on prevention, clean-up and disposal, training, intentional discharges US00000778 (4) What technology or products could be applied to recycle or reuse AFFF? Not considered to be feasible or cost effective (reformulation, losses, contamination) US00000779 (5) What alternatives to AFFF currently exist and how do they compare in effectiveness, cost, environmental impact, availability, etc ? None meet performance specification (mil spec) Development of an AFFF alternative was proposed as project under ONR Future Naval Capability Platform Protection Program Potential SERDP statement of need Some UK effort on environmentally friendly foam US00000780 (6) What related planning documents exist with other services or agencies? UK is reportedly working on a standard definition of"biodegradability" EPA presentation mentioned international dialog on AFFF PFOS issue USAF needs included in draft NAVAIR ESH-Needs Assessment US00000781 (7) What follow-on strategies should be considered ? Need accurate quantitative definition ofthe problem DOD inventory status How much AFFF in DOD/where used/in-service and reserve stocks/concentrate types DOD AFFF discharges How much released/consumed annually (training, system testing and maintenance, accidental discharges, research, fires) Review current DOD regs and policy Need a definition of"environmentally friendly"(need "green" definition--what are acceptable thresholds from an environmental standpoint) Persistence Biodegradability Bio-accumulation BOD/COD Toxicity US00000782 Follow-On Strategies(con't) Need for future research SBIR Goals for Universities ONR Need to develop small scale screening tests Develop "SNAP-equivalent" guidance Need for "worst case" transition plan (short/mid/long term) Information distribution to all levels(users, requirers, trainers, regulators, etc) Develop AFFF detection capability(learn method used by 3M) Define hazard protocols and appropriateness of AFFF(use and response) US00000783 Follow-On strategies(con't) Assess commercial state-of-the-art CBD announcement "Turkey shoot" of all available AFFF alternatives Quantify performance, chemical and physical properties Obtain EPA endorsement ofscreening tests Consider future mods to AFFF mil spec Prioritze requirements Consider trade-offs Establish formal AFFF working group Info sharing Formal charter DOD primary advocate? Future meetings/host/agenda topics US00000784