Document 2Rogva4rNd2KNj26jZvByoxrb

E50 NEW PRODUCT ENG Fax:757-688-0506 Mar 6 '01 1=34 P.02 P o s l-ir F ax Mote l N / mY C o /D eo i^v Phon* 7671 Oic b [(f / pagis* J " ~ d ' P f a <r*Tt Co. Fax f Z X J draft only '1 PAPER James Rudroft, jS-1? 21 Feb Cl SUB.": AQUEOUS FILM FORKING FOAM `AFFFi 2S0I1 I3SUSU BACKGROUND Aqueous Film Forming Foam (AFFF) was developed in tht 196Cs to provide better fire protection than tne existing protein foam- A FF is the primary DOD manusl fire-Iiqhting agent for protecting nigh value assets .. A class of chemical substances referred to as Perrluoroocyt*. ^ Sulfonates (PFOS), are components and degradation product o. some commerical AFFFs. PFOS can potentially degrade back to FFOSA (acid), which is highly persistent in the environment end has a ^ strong tendency to bioaccumulate. Studies indicate that exposure -o PFOSA is widespread and recent tests have raised concerns about long term potential effects in people (developmental, reproductive, ana systemic toxicity) and wildlife. DISCUSSION . EPA has a proposed Significant New Use Rule (5NUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA) for 90 dif^ere:.. perfluorooctyl sulfonates (PFOS) compounds. . Under the SNUR, entities potentially affected by the requirements ot the proposed rule may include, but are not limited to. manufacturers, importers, and exporters = the PFOS compounds-The SNUR requires EPA notification at least 90 days oeiore commencing the manufacture or import of the 90 PFOS compounds. . Primary commercial manufacturer of PFOS compounds began voluntary phase out of the production of certain PFCS compounds on :1 December- 2000 Steady reduction on production volumes for remaining PFOS compounds will continue through 2001 and 2002, with final phase-out by 31 December 2C02. A^l currant Navy-approved AFFF formulations contain either PFOS, PFOA or fluorir.ated Telomers. c EPA commercial manufacturers are conducting hazard assessments c,. FFOA and Telomers respectively. Both are PFOS precursors arc. may be subject to future regulation. ^ SNUR comment period ended 01 Jan 01. EFA is reviewing puttie comments and responses to the SNUR. Estimate next EPA public meeting or this issue in March 2001. RECOMMENDATION Frovided as information to DUSD(ES) For Navy: Action-NAVSEA/NAVAIR . Provide f'irefightinq/survlvability technical review and impact assessment of currently approved MILSPEC AFFF materia..s with regards to SNUR requirements. . Participate in r.nrrenl- *nd future meetings to monitor anc provj.de technical input on issues related to potential impacts pcsed by tills SNUR, cn Navy lirefigntir.g/survivability requirements. PRELIMINARY DRAFT ONLY