Document 9LLwNmRmJ35RJxeaLv3dna1M3

US00006835 From: To: DEPARTMENT OF THE NAVY , NAVAL SHIP RESEARCH AND DEVELOPMENT CENTER HEADQUARTERS BETHESDA, MARYLAND 20034 ANNAPOLIS LABORATORY ANNAPOLIS, MD 21402 CARDEROCK LABORATORY BETHESDA, MD 20034 IN REPLY R EFER TO: 286:CSA 9593 2863-515 5 OCT 1976 Commander, David W. Taylor Naval Ship R&D Center Commander, Naval Ship Engineering Center (SEC 6159) Subj: Candidate Environmental Impact Statement (Draft) on Dis charging Firefighting System Aqueous Film Forming Foam (AFFF) into Harbors; Status and Synopsis of Ref: (a) DTNSRDC RDT&E Work Unit Summary 2863-514, AFFF Harbor Dispersion Study, of 1 June 1975 1. Preparation of a draft Candidate Environmental Impact State ment (CEIS) on the discharge of AFFF from naval ships testing their machinery space firefighting foam generating systems in port (the proposed action) will be completed by 30 October 1976. Difficulties obtaining adequate information for the preparation of the CEIS have been encountered. These include the lack of information on components of 3M Company FC206 AFFF concentrate (which is proprietary), the unavailability of data on the quan tities of AFFF generated both aboard ships during system testing and in each port facility and the frequency of such generation, the .wide variation in the environmental conditions at naval port facilities which makes generalization of existing site character istics very difficult, and the limited data available for pre dieting the rates of dispersion and assimilation of AFFF dis charges into the harbors. '' '' ' . . 2. The above problems have been solved on the basis of informa- tion obtained from tie sources listed below, and of the stated assumptions. ' i j ^ *j a. As stated, the 3M Company has not provided any useful information about the components of FC206. However, estimates of composition have been made by the U. S. Air Force,and results of various tests indicate that FC206 is nearly 100% biodegradable. Waste streams containing FC206 have also been successfully treated by conventional activated sludge techniques in concentrations of 200 to 1000 mg/1 with sewage although foaming problems were not considered. ^ b. The quantities of AFFF that could be generated in Navy ports were estimated on the basis of operational experience of the Fire Fighting Assistance Team (FFAT), known equipment charac teristics, and ship location information. The numbers and types of ships in each Navy homeport .were listed. Using the number of AFFF machinery space systems aboard each ship and the conclusion US00006836 286 :CSA 9593 2863-515 that one-sixth of all system tests are conducted in port, the quantity of AFFF that could be generated per year for each port was calculated. Twelve Navy ports discharge 90% of the potential yearly total (the remaining ports discharge less than 30 gallons of AFFF concentrate per year). c. The U. S. Navy Hydrographic Office (now NAYOGEANO) from 1959 through 1963 conducted studies of the relative flushing capa ; bilities of eighteen harbors. Nine of these harbors are included in the 12 Navy ports with the highest potential AFFF discharge volume. It was possible to construct hypothetical examples of the worst case AFFF discharge for 9 ports and predict the rate of decrease of AFFF concentration in the discharge area based upon existing data. (Use of these data reduced the estimated project cost from $125K to $60K.) 3. Alternatives to the proposed action were investigated. These included utilization of an alternative nontoxic concentrate for tests; revising or refining test procedures to reduce the volume of discharge; rescheduling tests for- discharge to pierside sewers, collection barges or open sea; performing tests with AFFF discharge contained as part of a closed system; redesigning shipboard main tenance plans to eliminate flow test; and enhancement of system component reliability to eliminate requirements for flow test. The alternatives as well as the proposed action were evaluated to determine the operationally and environmentally most acceptable alternatives. 4. A CEIS does not give specific conclusions or recommendations concerning a proposed action. It details the effects on the human environment of an action and of its alternatives. In a draft statement, an alternative may be favored- Also discussed are considerations that offset the adverse environmental effects of the proposed action. 5. The content of the CEIS can be summarized as follows. The preferred approach in the statement in preparation is continuation of current practice: discharging minimum quantities of AFFF into the waters of those harbors where collection and treatment or dis posal of test effluent is not now practiced. Procedures are now available and are often used that both minimize the quantity of effluent generated and eliminate foaming of the discharge. Some Navy port facilities, on their own initiative, are evaluating pro cedures for collecting AFFF discharges in shipboard wastewater collection, holding and transfer (CHT) systems for transfer to pierside sanitary sewers or waste collection barges. A recommended 2 US00006837 286:CSA 9593 2863-515 minor modification of test procedures and effluent collection equipment, if coinciding with the Ship-to-Shore Sewage Transfer 'Program, could potentially eliminate AFFF discharges to harbor waters in major ports by calendar year 1981. Copy to: NAVSEA (SEA 0492P) 3 US00006838 A003774 FOR OFFICIAL USE ONLY A003774 CANDIDATE ENVIRONMENTAL || IMPACT STATEMENT |* . DISCHARGING AQUEOUS FILM FORMING FOAM (AFFF) TO HARBOR WATERS DURING TESTS OF MACHINERY SPACE FIRE-FIGHTING FOAM SYSTEMS ABOARD U.S. NAVY SHIPS January 197ft Prepared by the David W. Taylor Naval Ship Research and Development Center for the Naval Sea Systems Command in accordance with OPNAVINST 6240.3D in compliance with Section 102(2)(c) of the National Environmental Policy Act of 1969 FOR OFFICIAL USE ONLY US00006839 LIST OF APPENDICES Appendix A - NAVSEA message 1915238 Feb 1975, AFFF Testing (unclassified) Appendix B - Comparisons of the Various Parameters of AFFF's Appendix C - FP-180 Water Motor Proportioner Appendix D - AFFF System Test and Waste Disposal Procedures Appendix E - Biodegradability and Toxicity of FC-206 Appendix F - Small Scale AFFF/Dye Dispersion Test Appendix G - Tentative Allocation Plans and Construction Schedules for Ship CHT Systems, SWOB's, and Pier Sewers I ii US00006840 AFFF ASAP AvGas BOD bod5 BOD u C CEIS CHT cm3 CNM r^oD DO FC-200 FC-206 FFAT FP-180 ft FWPCA g gal gpra HCFF LIST OF ABBREVIATIONS AND SYMBOLS - aqueous film forming foam - as soon as possible - aviation gasoline - biochemical oxygen demand - five-day biochemical oxygen demand - ultimate biochemical oxygen demand - degree Celsius - candidate environmental impact statement - collection# holding and transfer (tanks aboard ship) - cubic centimetre - Chief of Naval Material - chemical oxygen demand - dissolved oxygen - type of "Light water" AFFF, 3M Company - type of "Light water" AFFF# 3M Company - fire-fighting assistance team - water motor proportioner for mixing fire fighting foam concentrate with sea water - foot - Federal Water Pollution Control Act - gram - gallon - gallon per minute - high capacity fog foam iii 1 US00006841 JP"4 JP-5 A Navy aircraft fuel Navy aircraft fuel litre LC50 A/s m _in 3 mg mg/A NAVFAC concentration of a toxic substance that will kill 50 percent of test organisms within a specified time period litre per second metre cubic metre milligram milligram per litre Naval Facilities Engineering Command MAVFAc'WESTDIV Naval Facilities Engineering Command, Western Division NAVOCEANO Naval Oceanographic Office NAVSEA Naval Sea Systems Command NAVSEO Naval Ship Engineering Center NCBC Naval Construction Battalion Center NFPA National Fire Protection Association NPDES National Pollution Discharge Elimination System NRL Naval Research Laboratory NSC Naval Safety Center, Norfolk, Virginia PH . negative logarithm of the hydrogen ion concentration I PKP PMS potassium bicarbonate powder preventive maintenance schedule iv US00006842 Ppb ppm SHIPALT SWOB TC TDS TSS 3M Vl/l - part per billion (1 x 10") - part per million (1 x 10") - ship alteration - ship waste off-load barge - total carbon - total dissolved solids - total suspended solids - Minnesota Mining and Manufacturing Company - microlitres per litre V US00006843 i - CEIS PREPARATION COST ESTIMATES i .' * . _ ' . The following estimate of preparation costs for this si - document against the catagories identified below are listed in accordance with OPNAVINST 6240.3D, paragraph 4302b. 1. Salaries of military and civilian personnel. $30K. ^ 2. Associated travel costs. None. 3. Directly associated research costs. $4.4K. 4. Contract and consultant costs directly related. $22.3K. 5. Indirect but related costs. $1.3K. 6. Administrative costs. $2K. 7. Costs of public hearings. None. 1 t* iLJi r !f t- ;L? vi US00006844 /"N i. I SECTION 1 SUMMARY 1. This is a Candidate Environmental Impact Statement (CEIS). f 2. Title; Discharging Aqueous Film Forming Foam (A*FFF) to Harbor Waters During Tests of Machinery Space Fire-Fighting Foam Systems Aboard U.S. Navy Ships. Action: Administrative. ' 3. Action Description; Regular in situ testing of AFFF fire fighting systems aboard ship is imperative in the interest of personnel safety and material protection. Each test of a machinery space system generates approximately 90 gal (0.34 m 3) of AFFF at a concentration of 3.5 to 6 percent in sea water. Containment and disposal of AFFF test mixtures is difficult due to design configuration, foaming, or the unavailability of containment vessels. Therefore, AFFF is discharged overboard as it is produced. a. All AFFF fire-fighting equipment that is newly installed, repaired, altered or converted from protein foam by an industrial activity is tested to insure proper operation and required output. b. All AFFF fire-fighting equipment is tested on a six- month PMS. . Location; AFFF fire-fighting equipment is tested aboard naval ships located in 33 ports in the continental United States and Hawaii and in 6 naval shipyards servicing surface ships. Approximately 90 percent of the AFFF discharged is produced at naval installations in the following 10 locations. ,, 1-1 US00006845 San Diego, California Norfolk (Naval Base), Virginia Charleston, South Carolina Honolulu (Pearl Harbor), Hawaii Philadelphia, Pennsylvania Mayport, Florida Norfolk (Little Creek Amphibious Base), Virginia Long Beach, California Bremerton (Puget Sound), Washington Alameda, California 4. Environmental Impact: a. Air - no impact. b. Navigable waters. (1) Physical, chemical, biological. (a) Discharge into harbors with inadequate natural mixing may result in localized areas of chemicals concentration initial dilution and dispersion rapidly reduce chemicals concen tration. (b) Chemicals interaction with other contaminants already in the harbor is unknown - the possible effects of AFFF are reduced by discharging limited quantities and by rapid dilution. (c) Certain concentrations of AFFF are toxic to marine organisms - the toxicity of AFFF has been determined, and the concentration of AFFF in harbor waters after discharge ^ i s well below acute toxic levels. 1-2 US00006846 (d) The BOD of AFFF is very high - the BOD an' COD of AFFF. are nearly equal, indicating that the substance is nearly 100% biodegradable. c. Socioeconomic - Port areas are normally associated with industrial activity and are not used for commercial fishing or recreation. The discharge of limited quantities of AFFF will have no socioeconomic affect on the port area. d. Aesthetic - Testing with the recommended non-foaming nozzles will eliminate unsightly foam on the water surface previously associated with AFFF discharges. 5. Alternatives: a. Test with substitute concentrate material. . b. Redefine test procedures to reduce discharge volume. c. Adjust test schedules for discharge only when collection, treatment, and disposal facilities are available. d. Perform tests with discharge contained as part of a closed system. e. Eliminate shipboard flow test by redesigning maintenance plan. f. Eliminate shipboard flow test by enhancing system com ponent performance reliability. g. Preferred Approach - Discharge minimum quantities of AFFF into harbors where collection and treatment or alternate disposal of test effluent is. not now practiced. Gradually eliminate dis charge by utilizing collection, treatment, and disposal facilities now being constructed, as*they become available for service. fr r 1 I ' 1-3. . I' US00006847 6. Envxronmental Significance f*-v a. This statement concludes that the impact of the proposed action on the environment will not be environmentally significant. Given the low volumes of AFFF discharged, the infrequency of the discharge, and the rapid dilution that takes place in the receiving water, the proposed action . v' ' . . should not be environmentally controversial when considered with the criticality of the fire protection function aboard 'i ' .' >. .. ship. The environmental impact will be further reduced as ' adequate facilities for collection, treatment, and disposal of AFFF tests effluents become available for service. 1-4 US00006848 SECTION 2 INTRODUCTION 1. Project Description Proposed Action: Discharge Aqueous Film Forming Foam (AFFF) to Harbor Waters During Tests of Machinery Space Fire Fighting Foam Generation Systems Aboard U.S. Navy Ships. a. Each surface ship of the Navy is equipped with a fire fighting system with a capacity and state-of-readiness to combat and extinguish fires within the range of severity which could occur as a result of normal day-to-day operations or offensive or defensive combat incidents. b. Criticality of the fire protection function dictates that equipment and fire-fighting crews be exercised on a regular basis as part of the maintenance program. A naval message from Commander, NAVSEA 0945D, appendix A, requires, "All AFFF fire fighting equipment that is newly installed, repaired, altered or converted from protein foam by an industrial activity shall be tested to insure proper operation and required output." The message states that the following procedures be observed when testing AFFF hoses. (1) The minimum acceptable concentration of AFFF in the output mixture of the system is 3.5 percent. ' (2) The foam should be generated for one minute before i sampling. After the sample has been taken, the system should be secured ASAP to avoid excessive use of AFFF concentrate. 2-1 l US00006849 (3) If the only work done on a system was on the foam generator (proportioner or pump), then only one hose shall be tested with AFFF to verify foam generator performance. One and one-half inch variable flow nozzles shall be tested at 95 gpm (6 Jl/s) in machinery spaces and 125 gpm (7.9 l/s) in hangar bays or flight decks. Two and one-half inch variable flow nozzles should be tested at 250 gpm (15.8 Jl/s) . (4) The above requirements apply, and the systems shall be tested and certified in port prior to ship trial runs, for testing of the machinery space AFFF fire-fighting system aboard active ships and new construction. c. Critical areas of greatest fire potential (such as .aachinery spaces, hangar and flight decks, weapons elevators, and helicopter landing areas) are protected by fire-fighting foam generation equipment that employ AFFF as the extinguishing agent. 2. Background a. Many fire-fighting formulations have been evaluated for efficiency and safety. Because oil floats on water, the application of water on an oil fire could spread the flaming oil, but by generating and applying a foam, an oil fire could be extinguished by smothering the flames. A protein-based "mechanical foam" was developed that, when mixed with water and air, would spread over the surface of an oil fire and prevent the vapors from escaping, mixing with air and burning. However, protein foam has the disadvantage of being fragile. If the foam 2-2 blanket is disturbed and broken, volatile vapors could escape /"*N and a flashback could occur. In a congested machinery space, it is likely that with the movement of firefighters and their equipment, this could occur.1 b. AFFF was developed in the mid-1960's. It has the advantage of producing a more rugged vapor sealing blanket than protein foam. It can be vigorously sprayed on a fire and a vapor barrier would remain intact in foot traffic. The active ingredient in AFFF is fluorocarbon surfactant. Fluoro carbon surfactants function as effective vapor securing agents based upon their outstanding effect in reducing the surface tension of water and of their controllable oleophobic and hydrophilic properties, and on their chemical stability. Thus, the physical properties of water can be controlled so that it can foam, float, spread across and remain on the surface of a hydrocarbon fuel even though water itself is denser than the fuel. The term "light water" was based upon those proper ties. "Light water" appeared in several early military speci fications defining the properties of this class of agents. The NFPA later adopted the term "aqueous film forming foam" to refer to fluorocarbon surfactant-based fire-fighting agents. The term "light water" has become associated with the fire fighting products of the 3M Company.1 1Superscripts refer to similarly numbered entries in Section 10, References. 2-3 US00006851 c. To improve shipboard protection against fires, the Navy is converting all protein foam generating fire-fighting equipment aboard ship to AFFF.2 The AFFF concentrate speci fied for use in testing fire-fighting systems must conform to MIL-F-24385 (Military Specification Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, Six Percent, for Fresh and Sea Water, Amendment 2, 25 June 1970). Approved AFFF concentrate (Light Wate: FC-206, manufactured by 3M Company) is obtained from the Federal Supply under NSN-9C-4210-00-087-4742 for 5 gal (19 i) containers and NSN-9C-4210-00-087-4750 for 50 gal (190 i) drums. d. A common type of AFFF currently used aboard naval ships is Light Water FC-200 manufactured by 3M Company. The stocks of FC-200 are gradually being replaced by FC-206. A comparison of various parameters of AFFF's are contained in appendix B. The constituents of the AFFF formulas are trade secrets and have not been disclosed to the Navy. e. By design, the fire-fighting mixture should consist of 94% firemain water and 6% AFFF concentrate. However, acceptance test criteria allow for a mixture to contain, as a minimum, 3 1/2% AFFF concentrate. Considering the test use of a 1 1/2 inch nozzle at 90 gpm (5.7 i/s), an output of from 3.15 gal (11.9 l) to 5.4 gal (20.4 2.) of the AFFF concen trate could be discharged overboard during each minute of the test. Since the ship would not be moving at the time of ight Water - Registered Trademark, 3M Company. 2-4 | - effluent discharge, its dispersion would be totally dependent .upon the initial dilution of the discharge and diffusion due r'- . j to local tidal movements, current flow, etc. tJ' . ' . . .. ' r" '- . . f. The foam proportioning.equipment installed aboard '. . , # !l Navy ships for machinery space fire control in most cases is r the FP-180 foam proportioner. A description of the FP-180 i .V . . ` and a diagram of a typical permanent installation in contained r": : in appendix C. . . g. The FP-1000 foam proportioner and the AFFF Two Speed Injection Pump are often installed in ship hanger bays and on flight decks. These highflow systems are not installed n in machinery spaces and will not be tested in port (see section 3.a.(2)). Therefore, they will not be discussed further. ' i? 3. Site Characteristics a. Obligatory in-port testing of AFFF fire-fighting systems is required after work on the system and during regular PMS testing: (1) The message in appendix A states, "All AFFF fire fighting equipment that is newly installed, repaired, altered or converted from protein foam by an industrial activity shall be tested to insure proper operation and required output." For the purpose of this statement un "industrial activity" is defined as a facility at which the construction, conversion, or repair of ships is accomplished. Most industrial activity aboard Navy surface ships is done at the six naval shipyards listed below 2-5 US00006853 ' . Activity City_________ State f*'. Naval Shipyard: Philadelphia Philadelphia, PA Naval Shipyard: Norfolk Portsmouth, VA . Naval Shipyard: Charleston Charleston, SC ` Naval Shipyard: Long Beach Long Beach, CA Naval Shipyard: Puget Sound . v, ' . Naval Shipyard: Pearl Harbor Bremerton, WA Honolulu, HI ' ' (2) All AFFF fire-fighting equipment is also tested on a six-month PMS. For the purpose of this CEIS, it is assumed that regular PMS testing of non-machinery room AFFF system can be delayed until the earliest opportunity when a ship is underway in unrestricted waters. AFFF generated by these system tests can then be discharged directly over- ^ board. However, the criticality of machinery room AFFF systems for personnel safety and material protection makes it imper ative that these systems be tested at regular intervals (according to ship PMS) even though a ship may be in port. AFFF generated during in-port PMS testing is discharged over board. Generation rates are based upon unclassified informa- tion about U.S. Navy commissioned surface ship inventories on 3. a homport basis. The relative locations of U.S. Navy home- ports are shown in figure 2-1. Estimates of the quantity of AFFF discharged overboard in each Navy port are given in table 4-4. The ports are ranked based upon the estimated quantity of AFFF discharged during in-port testing. Estimates of newly installed, repaired, altered or converted AFFF systems ;- .. 2-6" ; ' " . ' . V . L t tL 1 r & til. r fr- US00006854 ~2 ;) .,x I-- ,! r a iizi c m c m c m Seattle B rem erton Portland Concord San Francisco A lem eda Long Beach San Diego o P earl Harbor HAWAII cm cm cm cm v-m j i-- j ortland P ortsm outh Newport --Brooklyn Bronx * New York Perth Amboy Norfolk Littie Creek Charleston ' Mayport St. Petersburg Tampa Panama City FIGURE 2-1 RELATIVE LOCATIONS OF U.S. NAVY PORTS ... US00006855 ?' 1 I are added onto port totals for PMS testing only when alterna P !f tives to direct discharge disposal procedures are not practiced (see table 4-2). Approximately 90 percent of the AFFF dis- r. charged is generated in the ten ports listed in table 2-1. The annual discharges in each of the remaining ports are esti' . 3 / '. mated at less than 32 gal (0.12 m ) of AFFF concentrate per year. Thesje quantities can be considered negligible. ; ' .. ' I Table 2-1 jSummary of Estimated Volumes of AFFF Discharged Overboard in Navy Ports Per Year During Tejsting of Machinery Space Fire-Fighting Systems Concentrate 6% AFFF AFFF, Porj Location gal (m3) gal (m ) San Diego, dA 9480 (35.88) 568.8 (2.12) Norfolk (Naval Station) , VA(a) 7770 (29.41) 466.2 (1.76) Charleston, 'sc(a ) 3690 (13.84) 221.4 (0.84) Honolulu (Pearl Harbor), HI(-b} 3360 (12.72) 201.6 (0.76) Philadelphia;, PA 2760 (10.45) 165.6 (0.63) Maypor-c, FL j 2640 (9.90) 158.4 (0.60) Little Creek; Norfolk, VA 1950 (7.31) 117 (0.44) Long Beach, CA(s) 1560 (5.85) 93.6 (0.35) Bremerton (pjaget Sound) , WAib) 940 (3.56) 56.4 (0.21) Alameda, CA \ 660 (2.47) 40 (0.15) Other Navy Hjomeports 4163.3 (15.77) 249.8 (0.95) (a) Excluding shipyard tests. (b) Including shipyard tests. ' ' [ E il 0 b. Thej information contained in table 2-2 was supplied by l \ the Navy Environmental Support Office, NCBC, Port Hueneme, Cal ifornia. ijt tabulates the water quality classifications and I . .parameters for which water quality standards have been adopted for each harbor area listed in table 2-1. Li i\ t. " 2-8 US00006856 )1 Table 2-2 Wa t e r Qu a l it y Re f e r e n c e s for Se l e c t e d Na v y Po rts ' Harbor Area San Dieso Bay San 01eso, CA . . ' . 11' * * . / * Code Dc."..-;ficial or Protected Use C".asciricatior. UescrioticnCa) Coastal ir:o :.av REC-l rlEC-2 COMM . > ' SAL RARE \ MAR KIGR . SHELL . . r Cc-do N/A * . * \ Long each Haroor Long Beach, CA * - **'. *t.*','**..', ' *' . t e ** '* Coastal nay REC-2 . CG'M RARE . MAR SHELL- . ;* N/A . t San Francisco Bay Alasela, CA . ; t' K \* * , RESI 7(73 .'EC-2 NA7 MAR F.ARE VilLD ' CC.CM i ino ; '; SHELL rA.,, 1cable 'ds/Cn >r-i:t1v?s . . 1 Pa?ar.eter(r Hater Q uality References Interstate/State/ Lccal Water Q uality Manae.rr.ent Agencies COLCR TASTE l ODOR FLOATING SOLIDS TSS "Csit:;v.c-':ivsive LYudC* OvcJUXlJ C a lifo rn ia Water Convict PC.V. OKlie. Ssn Q uality Central 5d., V-itja Sitiis. {Aia-tmat), < San Diego Region (303 3-jJjj 1975" planr.ing(c) SZ7TLEALE SOLIDS. OIL t GREASE ' TUREIDITY pi! Source: San Ciego Regional Hater Q uality Control Bd. 6154 Mission Gorge Rd. San Diego, CA Comprehensive Plann in g Organization of the San Diego Region (2CS planning'3 7 UO BACTERIA * TEY.? TOXICITY Curerai non- . quantified lim ita tio n s on waste fren vessels CCLCP. TASTE S ODOR FLOATING MATERIAL TSS SETTLE,',OLE SOLIDS "UzClA. ftiziiZj CO.lClOi PCirt {o-\ he Lea A/.gj-iu Riva* E.151, Hm. 1975" Source: Los Angeles Re gional Hater Q uality Cor.- C a lifo rnia Hater Q uality Control Board, Las Angeles Region .(303 planning) OIL 6 GREASE tro l Board CICSTIHJLANTS 107 S. Broadway, Tl'F.GIOITY Suite 4027 pH Los Angeles, CA 90312 CO . CACTERIA ' TEMP TOXICITY PESTICIDES COLOR TASTE S ODOR FLOATING MATERIAL TSS SETTLEA3LE SOLIDS CIL GREASE D.'OSTIM.XANTS * "L'aia* QpsZL&j Corjbioi ?Lzn C alifornia Hater 1:1 Ses. F*a.tita co Bay Q uality Control Board, Sea-in, JUtJ 1975" Bay Area Region ' Source: Bay Area Regional (3G3 planning) Hater Q uality Control Bd. Association of Say ' I l l Jackscn St. Area Government* Oakland, CA 94607 (2C3 planning) TURBIDITY K>**.' DO CACTERIA Tr S? ' . Bay Conservation D is t r i c t Ccnvnissicn (coastal zone manage ment) TOXICITY PESTICIDES (Continued) US00006857 0 J Table 2-2 r.ATER CUALITY REFERENCES FOR SELECTED NAVY PORTS (CONTINUED) , iCCGO Serafici al cr Protected Use Applicable C lassificatio n i-oscrisf.onva; | ceSdtaendards/CS`iercctrivc ez *e r (b) Water Qualfty Refererces Ir.tersutc/Stzto/ . Loral Water Quality JVnaoe-.sflt Atercias , . Wf1Jaughby Bay Norfolk, VA L tttle Creek Virginia Beach, VA * , 11Sa in s * ESTUARINE KUN R.EC-1 KAA FREE FLOW STR. '.UN ` REC-1 KAR II III 3 '' rUn\J pK TEI1P DO TPE'IK? BACTERIA ' I ' >u2 Cdoit-c w.ucib to tic Virginia l.'ater Control Q urvU tj V.xtn Riponi, O u 7 i" Board (3C3 planning) Source: Virginia In stituto Marine Science > a Harpton Roads Hater Attn: Dr. Brute lietison Quality Agency (208 Gloucastcr Paint, VA ' planning) t ViAciiU a. Wataii Qv.xUx.ij ' S tn n isA d i, e rx n d id Km 74 "fc'iie /i QunUXij h x z rX c r.u a Bureau of Shellfish ** . >" Sanitation ' A ll Class Ganaral nonquantified 305|b) Rapavi, A; V i " "Lo .;yi Ja r.n Z iv y i S ^ ir. sesie) Riponi |Pizr.rU.,.3 U - #' ,* 0, liciitacions I t t i n 117(3!, J j . l j 1974" on flo a tin g ,.. Source: Virg inia Water Con texic, and tro 1 Board \ deletarious sustar.ces. P.O. Box 11123 2111 H.- Koc.iTton St. * 1^ Richmond, VA 23230 ..Cooper River Charleston, SC SC TIDAL REC-2 CC M ' ' KAR * SC rLCAT. soucs DO BACTERIA ?H General nonquantified t Scura C i z n i ( i c j . U u / j {o. Siate oj S taili Cv l U ko. u n n d id 9/1/71 e Caia* CCaiai-iaacisiU Siv.dfixiii S jt i & s , cirindod 1974 o South Carolina Cept. Health and Environmental Control (303 planning) e Serliely-Charlestsn-ilorchesUr Planning round) (2S3 pluming) 'k Ile i taticr.s on toxic and deleteriaus substances "S a n iti-C o o p tA Rtaia Eoain tnta* Q v s .iiij ILo-x j c e lti Pisa, 1975" . Scurco: SC Cept of Health e South Carolina W ild life and Marine sources Center (coastal zone manacarent) " St. John's River Kayport, f l .. f* .. 111 REC-1 REC-2 MAR WILD pii CO ASTERIA TURC10ITV TCS FLUC'IICES ClLCRI CES t r i Enviror-c-r.tel Control t "Si. J o r s .'i Riva* 3attr. F x a " Source: F lo rid i Cept. of Envlronr.antal Regulatlons Tallahassee, FL Florida Cast, of nvirer.7.er.tal Regulation (2C3 and 2CS planning) o Bureau of Coastal 2;r.a Management, Department of Natural Resources ' (c o ita l zone aanagesent) . * r .. * ' cy n cP * ' CORRER . 2me CliRCMIUM ?..Ef;0LS LEAO CSTERCENTS ('.SxCuRY li:--.? 5ent r i l nonq ie n tific d ir.itatio n s cn toxic end deletcrious substanMs . ** (C o ntinued ) - US00006858 Harbor Area Sinclair Inlet Brenerton, WA .. Delaware estuary .. (Zone 01.C20) Philadelphia, PA .. ' . \- T a b le 2-2 Wa t e r Qu a l it y Re fer en c es for Selec ted Na v y Ports (Co n t in u e d ) Cede A * Beneficial or Protected Use Classification Uescnotiori* ) Hi Gil WHO REC-1 REC-2 INO NAV coxa SHELL . 1.2 WARM 1.3 % KIGR ` 2.2 i;:D 2. WILD , 3.1 REC-2 boating 3.2/ REC-2 fishing 4.1 POW 4.2 NAV 4.3 WASTE Applicable Standards/Ctjcctives .. . Cede Paro.Teteir'.DV Water Quality References Interstate/Stete/ Local Water Quality Menacrent Agencies . A BACTERIA None available _ State Department of CO ' ' # Ecology (303 and 2C3 . TEMP planning, coastal TOTAL DISSOLVED zone management) . GAS ' pH TURBIDITY t General non- . quantified Vimi tatlons 0* on toxic and dolc-tcrious substances . ai * b* pH CD Tc"? ! 25 PA Coda Ckcp-Car. 93. t'iian PA Sept of Envircrmcr- QuniECy .Cn/LCar U a , c r v . d t d tal Resources (303 6/ 23/ 74. planning) * d , TEMP a CS3S 7l z p o . i t 'w'aCcA Sa- a Delaware River Basin e<, TU3 actihcca Paca (c-t Pcnjoj.yZva- Commission (2C2 coor- H Cf.CTERIA Jj S. - X I U c t v i Q iL c U t t g cir.ator, coastal zone TCP.3I0ITY 92 Saccada" management). . ALKALINITY Source: Cistrict Chief, a Delaware Valley h Water Resources Division" Regional Planning Com 9 2 PHENOL Federal Euildir.g mission (2C3 plan-' W l P./OICACTIVITY P.0. Sox 1107 nir.g) h Tc:;(e> Harrisburg, PA 171C3 IT-3 ( * )p ie abbreviated descriptions re modeled a fte r the designations used by the Regional Water Quality Control Boards o f C alifornia. The following description fo r each abbreviated designation is intended to provide a generalized concept rather than the specific definition offered by each lOCalS* ' IUO - Includes uses which do not depend p rim a rily on water q u a lity such as mining, cooling water supply, hydraulic conveyance, crave! washing. f ir e protection, and o il well repressurlzatlcn. * * KAV - Includes commercial and naval shipping. ' ` POW Uses fo r hydropower generation. `. ' REC-1 . . ' REC-2 Includes a ll recreational uses.Involving actual body contact with water, such as swimming, wading, waterskilr.g, skin diving, surfing. Sport m fn n g , uses in therapeutic spas, and other uses where ingestion of water is reasonably possible. Recreational uses which involve the presence of water but do not recuire contact with water, such cs picnicking, sunbathing, hiking . beachcombing, capping, pleasure boating, a c tiv itie s as well as sightseeing. tldepooi and marine lif e study, hunting, and aesthetic enjoyment in conjunction with the above *' CCfM _ Jhc commercial collection of various types of fish and s h e llfis h , including those taken for bait purposes, end sport fishing In ocean bays, estuaries ar.d sim ila r non-freshwater areas. . t US00006859 y (Continued) WASH - Provides a warnwator habitat to sustain aquatic resources associated with a warranter environment. SAL - Provides an Inland saline water habitat fo r aquatic and w ild life resources. UILO - Provides a water supply and vegetative habitat fo f the maintenance of w ild life . . NAft - Provides fo r the preservation of the marine ecosystem including the propagation and sustenance o f fis h , s h e llfis h , marine annalS. waterfowl, and vegetation such as kelp. . HIGR - Provides a m igration route and temporary aquatic environment fo r anadromous and other fis h species. . RARE - Provides an aquatic nabltat neccsiary, at least 1n p art, fo r the survival of certain species established as being rare end endangered species. * * SNELL - The collection of s h e llfis h such as clams, oysters, abalonc, shrimp, crab, and lobster fo r e ith e r commercial o r sport purposes. KUN *. Includes usual uses In community or m ilita ry water systems and domestic uses from individual w attr supply systems. .- . HASTE - ^ re ce ivin g bedy fo r treated waste water e fflue n t re fle ctin g levels of treatment necessary to preserve a ll designated beneficial use 0*H pecific quantified o r non-quantified lim itatio n s are Id e n tifie d fo r each parameter In the appropriate area w a ttr q u a lity docusants. m (c )Plann1ng pursuant to Section 3 , PL92-500. '. ' M V lan n lng pursuant to Section 208, PL92-500.. . .. . . , _(*)Thrshold Odor Number.^ . ! ... .. . 12 US00006860 SECTION 3 RELATIONSHIP OF PROPOSED ACTION TO LAND USE PLANS, POLICIES AND CONTROLS FOR THE AFFECTED AREAS 1. The proposed action relates to the marine environment. There is no direct impingement upon land use plans, policies or controls. A possible indirect effect caused by the imple mentation of the proposed action would be increased levels of BOD in a localized portion of the harbor water immediately after receiving an AFFF discharge. When considered in com bination with the existing (or projected) levels of contamina tion in the water, the action, if it occurs frequently enough, might prohibit a new land use which would generate a pollution level in excess of allowable limits established for the site ^ by local or federal standards and regulations. However, the limited quantity of AFFF and the infrequency of testing causes an insignificant contribution to water quality degradation in comparison to the highly developed industrialized land uses already associated with surrounding shorelines. 2. The Navy has committed itself to assure that the operation of naval complexes has been reconciled with local land/water use plans, policies and controls.1* Navy-wide programs to improve ship-to-shore waste collection, handling and disposal will continue to reduce the environmental impact on areas surrounding naval bases and shipyards. The eventual disposal 3-1 US00006861 of shipboard generated AFFF test solution will be incorporated into current environmental enhancement programs for which their relationship to land use plans, policies, and controls has been assessed. < t r> n 3-2 US00006862 SECTION 4 PROBABLE IMPACT OF THE PROPOSED ACTION ON THE ENVIRONMENT 1. Introduction a. It is essential that newly installed and modified AFFF fire-fighting systems be tested prior to ship departure for sea trials. U.S. Navy ships are presently having their pro tein foam generating fire-fighting equipment aboard surface ships converted to AFFF. The first systems converted were aircraft carrier hangar deck and flight deck equipment. SHIPALT's have been issued to convert aircraft carrier pro tein foam equipment to AFFF in the HCFF stations, hangar sprinkling systems, machinery spaces, fixed flight deck fire fighting washdown systems, and hard hoses for hangar space and flight deck. Machinery space protein foam equipment for all other types of surface ships is also being converted by SHIPALT to AFFF use and combined ("twinned") with PKP. PKP is an effective fire-fighting agent for oil fires when the oil is in spray form and burning in space.5 Figure 4-1 is a diagram of a twin agent (AFFF and PKP) fire extinguishing system. The AFFF system can be operated independently of the PKP units for testing or fire fighting. b. There are two circumstances when machinery space AFFF systems need to be operated to test the FP-180 foam proportioner: 4-1 US00006863 -w- GLOBE VALVE GLOBE VALVE LOCKED OPEN GLOBE VALVE LOCKED CLOSED -e-- GATE OR BUTTERFLY VALVE GATE OR BUTTERFLY VALVE LOCKED OPEN -4- GATE OR BUTTERFLY VALVE LOCKED CLOSED BALL V A LVE 1/4 TURN CHECK VALVE VALVE NORMALLY OPEN VALVE NORMALLY CLOSED 3 W AY 2 PORT COCK PRESSURE ACTUATED VA LVE , FAIL CLOSED X PRESSURE ACTUATED VALVE, FAIL OPEN QUICK ACTIN G STRAINER FLEXIBLE C O N N E C T IO N SALTWATER (90-10 CU. N l.) AFFF CONCENTRATE (90-10 CU. N l. OR CRES. 304, 310, 316) c o o AFFF/ALT WATER SOLUTION (90-10 CU. N l.) --- DRY CHEMICAL (STEEL) TTFi ACTUATING GAS CONTROL (90-10 CU. N l.) --- HYDRAULIC CONTROL (90-10 CU. N l.) SOFT SEAT SPRING LOADED CHECK VALVE Figure 4-1 Twin Agent (AFFF and PKP) Fire Extinguishing S y s t e m 5 4-2 US00006864 ^ the first is after equipment is newly installed, repaired, altered or converted by an industrial activity; the second is scheduled preventive maintenance. NAVSEA 0993-LP-023-6010 technical manual requires preventive maintenance semiannually or more frequently if conditions warrant it.5 Appendix D contains a copy of the Long Beach Naval Shipyard procedures for testing AFFF/PKP fire-fighting systems. These procedures are representative of those used in other shipyards. c. The environmental assessment parameters which relate to the proposed action and the appraisals of the magnitude of the resulting impacts are given in table 4-1. There are no apparent air quality impacts of the proposed action. 2. Navigable Waters Impact. The ecological effect of any chemical introduced into a given environment for the first time is a function of many factors. Its physical and chemi cal structure will determine what physiological influences it could exert on life forms with which it may come into con tact. However, its concentration at any point in time is a measure of the probability of such effects occurring. There fore, an assessment of maximum concentration expected and the speed with which the chemical is purged from the environment are essential elements in the formulation of impact estimates. Since these evaluations must precede a proposed action, direct i measurements are not possible. Therefore, the best indirect evidence available has to be applied to the construction of a 4-3 US00006865 ) Assessment Parameter Physical/ Chemical/ Biological Flow Variations, (concentration time factors) Table -1 Appraisal of the Proposed Action's Impact Upon the Environmental Assessment Parameters Data or Observations for Effect of the Proposed Action Evaluation of Parameter Impact ) The discharge o f a quantity of AFFF into harbor wafers with inadequate natural mixing capability may result in localized acreas of chemical con centration. Information with regard "to tidal, current and wind movements has been acquired in order to calculate the flushing capability o f the receiving waters. Associated Chemical Contaminants The physical-chemical AFFF with other major interaction of chemical contam Qualitative major types and quantitative data regarding the of contaminants normally found in a inants normally found in a particular particular harbor would determine the degree of harbor could result in altered disper chemical interaction witli AFFF. Natural mixing in sion, degradation, and toxicological receiving waters and the extremely low concentra properties of some of the reactants. tion of chemicals and AFTF will minimize environ This could influence the "self purifi mental effects. cation" capability of the harbor. Toxicological Properties of AFFF It is possible that finite concentra tions of any chemical will have a detrimental effect on some biological entity in a particular environment. Therefore, the nature of this influ ence, the spectrum of biological life affected, and the concentration constraints imposed within a partic ular environment will determine if AFFF and its anticipated usage will constitute an ecological hazard. The influence of AFFF on marine life in a harbor and contiguous waters must be determined. These effects should be evaluated within the practical range of chemical concentrations anticipated if the proposed action is implemented and should include short-range (acute and sub-acute) and long-range (chronic) toxicity testing. Data cur rently available (appendix E) supplies the req uisite information. I US00006866 )) Assessment Parameter pH of AFFF Effluents AFFF Pollution Loading Poten tial Table 4-1 Effect of the Proposed Action The pH of the AFFF product in ques tion, FC-206, is identified at approximately the neutral point, 7.8, in appendix B; therefore, there should be minimal impact on the pH of the harbor waters. cont'd) ' Data or Observations for Evaluation of Parameter Impact The applicable procurement specification, MIL-F- 24385, for the AFFF allows as acceptable a range of pH from 4 to 8 . The specification should be changed to conform more closely to the reported control value of pH 7 to 8 . The BOD and COD of FC-206 are very high (appendices B and E) . This means that high chemical concen trations could temporarily deplete the DO content of the receiving waters if discharged in large quan tities. The fact that BOD and COD values for FC-206 are relatively the same is indicative that this material is highly biodegradable. The fact that the BOD5 is 65% of the BODu indicates the mater ial is rapidly biodegradable. Socioeconomic Fishing (com mercial and recreational) Water Skiing and Swimming The discharge of AJFFF is not ex pected to affect commercial fishing or recreational use. Harbor areas associated with shipyards are cen ters of industrial activity and are not used for recreation. Rapid dilution and biochemical degradation of AFFF within the industrial harbor areas should reduce concentrations to within acceptable limits while within the harbor whereby normal fish feeding or recreational water uses outside harbor areas are not affected. Aesthetic Water Surface The surfactant and. film forming characteristics of the AFFF mix ture could result in an unsightly film on the harbor surface. AFFF testing can be conducted with nonfoaming nozzles. When discharged overboard the AFFF dis penses beneath the surface (appendix F). US00006867 r* . hypothetical case. Before constructing such a case, the following information must be obtained: (a) the quantity and frequency of potential AFFF discharges; (b) the dilution of a discharge and natural mixing within the harbor; and (c) the rate of removal of the discharge from the receiving waters by natural flushing and by decomposition. a. While specific data on the generation rates of AFFF from machinery space system testing are not available, it is possible to estimate the quantity of AFFF solution generated per system test and the frequency of those tests using data and information obtained from naval shipyards and experience /"rained by the FFAT. (1) Quantities of AFFF generated at naval shipyards as a result of machinery room FP-180 testing are contained in table 4-2. These have been provided by the shipyards cited. They were derived by multiplying the number of ships having their fire-fighting foam systems converted from protein to AFFF by the quantity of foam generated while testing each system. No data are available on the generation rates of AFFF from semiannual PMS maintenance aboard ships in port; however, experience of the FFAT has shown that approximately 90 gal (0.34 m 3) of 6% AFFF solution are generated per test and that ships' operating schedules usually obligate in-port PMS testing at a frequency of about once every three years. sOther PMS testing is conducted at sea. The above estimates 4-6 are reasonable compared with data in a report on handling ship industrial wastes in San Diego, California. The report is being prepared by contract for NAVFACWESTDIV. The monthly generation rate of AFFF was compiled based on NAVSEC (SEC 6159) survey data from 1972 and on contacts with cognizant commands in the area. Typical AFFF waste generation rates were reported at 530 gal (2.0 m 3) for 40 ships at the Naval Station, 660 gal (2.5 m 3) for 5 ships at North Island, and 30 gal (0.1 m 3) for 4 ships at the Submarine Support Facility.6 The report estimates include some non-machinery space AFFF equipment testing. Table 4-2 Quantity of AFFF Generated During In-Port Fire-Fighting Foam System (NSY) Activity Portsmouth NSY Number AFFF Period Disposal of Ships (gal) (m3) (years) Procedure -- * Philadelphia NSY Norfolk NSY 11 - 150 5.7 ---^1 -80 30.3 None Yes Charleston NSY 3 225 0.9 1 Yes Long Beach NSY Mare Island NSY 9 110 4.2 1 ** * Yes Puget Sound NSY Pearl Harbor NSY 1 iTT 1.5 ** *** 1 ' None `Calendar year 1975 estimates. **No surface ships serviced during CY75, " `Data not available. (2) The numbers of machinery spaces and proportioner aboard ships with fire-fighting foam systems are given in table 4-3. The quantity of 6% AFFF that could be generated aboard ship per year is estimated for each significant Navy port in table 4-4. Estimates were obtained by multiplying the output 4-7 US00006869 per proportloner by the total number of FP-180 proportioners aboard the ships in the group. The experiences of the FFAT indicate that approximately 90 gal {0.34 m 3) of AFFF are gen erated during a single test. For in-port PMS testing once every three years, the total quantity of AFFF concentrate generated per port per year is also estimated in table 4-4 assuming maximum generating conditions of 90 gal (0.34 m 3) AFFF solution at 6%. Table 4-3 FP-180 Proportioners in Machinery Room Spaces Aboard U.S. Nfavy Ships by Class Grouping Number FP-180 Group Proportioners Ship Classes in Group 1 1 AE, ASR, ARS 2 2 AD, AFS, AG, AO, AOE, A06, AOR, AR, AS, ATF, FFG, LCC, LKA, l!>D, LPH, LPA, LSD, ATS, MSC, MSO, LHA, AF 3 4 CG (DLG), DD, DDG, FF, LST, CGN 4 6 CV, CVN (3) The AFFF generation estimates from the shipyards given in table 4-2 are included in table 4-4. When a shipyard is in the same harbor area as a homeport (i.e., Norfolk, VA), the shipyard generation rates were combined with those esti mates of PMS testing. Shipyards not associated with homeports (i.e., Long Beach, CA) are listed and ranked with those ports in table 4-4. 4-8 J i3 iaI Table 4-4 Estimated Yearly Quantity of AFFF Generated Aboard Ships In Port Based Upon 90 Gal (0.34 m 3) U.S. Navy Port Listing'3 ' Alameda, CA Baltimore, HD Bayonne, NJ Bronx, NY Number of Ships in Group Total Number Rank Group of Proportion- (b) 1 2 3 4 ers In Port 10 2 3 22 14 14 14 Estimated Gal (m3) of 6 AFFF Generated Port Shipyard 660 (2.47) 120 (0.45) 120 (0.45) 120 (0.45) Estimated Total Gal <m3) of AFFF Concentrate Dis charged Per Year 40 (0.15) 7.2 (0.03) 7.2 (0.03) 7.2 (0.03) Bremerton, WA 9 2 21 18 540 (2.02) 400 (1.51) 56.4 (0.21)lC) Brooklyn, NY 1 4 120 (0.45) 7.2 (0.03) Charleston, SC 3 3 10 25 123 3690 (13.84) 225 (0.85) 221.4 (0.84) ^ Concord, CA 8 8 240 (0.90) 14 (0.05) Groton, CT 1 1 30 (0.11) 1.8 (0.01) Fall River, HA 1 2 60 (0.22) 3.6 (0.02) Galveston, TX 1 4 120 (0.45) 7.2 (0.03) Pensacola, FL 1 6 180 (0.67) 11 (0.04) Portland, ME 2 4 120 (0.45) 7.2 (0.03) Little Creek, VA 7 3 11 10 65 1950 (7.31) 117.0 (0.44) KO Long Beach, CA 8 3 10 1 52 1560 (5.85) 1100 (4.16) 93.6 (0.35) Mayport, FL 6 2 7 15 2 88 2640 (9.90) 158.4 (0.60) New London, CT 11 6 180 (0.67) 10.8 (0.04) New Orleans, LA New York, NY Newport, RI 1 2 14 4 120 (0.45) 8 240 (0.91) 18 540 (2.04) 7.2 (0.03) 14 (0.05) 32 (0.12) Norfolk, VA 2 3 29 42 5 259 7770 (29.41) 8000 (30.28) 466.2 (1.76) Panama City, FL 1 2 60 (0.23) 3.6 (0.01) Pearl Harbor, HI 4 8 13 20 112 3360 (12.72) 201.6 (0.76)'d) Perth Amboy, NJ 2 4 120 (0.45) 7.2 (0.03) Philadelphia, PA 5 1 10 42 1260 (4.77) 1500 (5.68) 165.6 (0.63) Kc} Portland, OR 12 10 300 (1.14) IB (0.07) Portsmouth, NH 1 2 60 (0.23) 3.6 (0.02) Tampa, FL 1 4 120 (0.45) 7.2 (0.03) , San Dieqo, CA 1 2 41 55 2 316 9480 (35.88) 568.8 (2.12) San Francisco, CA 72 18 540 (2.04) 32 (0.12) Seattle, WA 3 12 360 (1.36) 22 (0.08) St. Petersburg, FL -2 4 120 (0.45) 7.2 (0.03) Tacoma, WA 11 6 180 (0.68) 11 (0.04) (a) U.S. homeports for naval surface ships.3 (b) Ranked by estimated quantity of AFFF generated per year during testing. (c) Includes AFFF generated by shipyard tests; no alternate disposal procedure. (d) Excludes AFFF generated by shipyard tests; alternate disposal procedure practiced. US00006871 b. The long-range effect of a contaminant on the harbor environment is dependent on the contaminant's rate of removal. Theoretical analyses of the dilution and flushing capabilities for each of 18 harbors were made by the U.S. Navy Hydrographic Office (now NAVOCEANO) from 1959 through 1963. The analyses were based on available measurements of the physical and dynamic characteristics of the site. The results of each theoretical analysis were reported separately for each port, and the dilu tion and flushing capabilities of each port were compared in a summary report.7 The summary report states: "...The major factors, not necessarily in order of importance, which deter m i n e the reduction of concentration of an introduced contaminant are: (1) volume of water available for dilution, (2) rate at which the contaminant is dispersed throughout this volume, and (3) rate of advection (i.e., movement by currents)."7 The methods of investigation and the conclusions of the report are summarized in the following paragraphs. (1) The Hydrographic Office report states that the volume of water available for dilution is not actually a criterion of flushing capability, although it is of obvious importance since a harbor with poor flushing characteristics still might be safe from contamination if great dilution takes place; a harbor with a small dilution volume and a relatively high rate of flushing might retain a high amount m^of contamination for a relatively long period of time. 4-10 US00006872 Examples are Long Beach, California which has a large dilution volume and Mare Island Strait, San Francisco, California which has a high flushing rate as shown in figure 4-2. (2) The amount of turbulence within a water area will determine the rate at which a contaminant is dispersed through out the dilution volume. For the most part, tidal currents are the source of turbulence. However, horizontal or vertical motion induced through seiches, waves, winds, etc. may serve as a mixing agent. The distribution of conservative physical properties indicates the relative degrees of mixing. (3) Figure 4-2, Comparison of Dilution Volumes and Flushing Capability of 18 Harbors, taken from this report, was based upon the following assumptions and conclusions.7 (a) The initial dilution volume was taken to be the volume of water defined by the length of a flood tidal excursion and the width and depth of the body of water through which the tidal excursion is measured. Where possible this volume was calculated, however where current speed data were not available and the embayment was considered sufficiently small, the volume of the embayment was taken as the dilution volume. (b) Flushing also affects the concentration of contaminant within a harbor. A contaminant will be removed ) from an area either by net flow from it or by mixing of the I i harbor water and the currents passing the entrance of the harbor. These factors were reflected in the exchange ratio = 4-11 US00006873 C O N C E N T R A T IO N O F C O N TA M IN A N T (U N IT/C U . FT . O F W A TER ) r* 4 6 8 10 .12 T IM E (T ID A L C Y C L E S ) 4-12 US00006874 <**' t i | * for each of these harbors, and this ratio was adjusted to account for the fraction of the tidal prism that is lost during each tidal cycle. It was further assumed that a volume of new uncontaminated water replaces the lost fraction of the tidal prism. These considerations were applied to nonestuarine embayments and to harbors in estuarine embayments in which the point source of contamination was not more than one flood tidal excursion from the entrance. (flood excursion is defined in the study as the distance traveled by a "particle" of water or of contaminant between one slack before flood and the succeeding slack before ebb.) If the point source was located more than one flood tidal excursion from the harbor entrance, and the harbor was estuarine, the distribution of the contaminant between the point source and the harbor entrance was calculated. It was assumed that the contaminant contained in a segment at a given time was uniformly distributed through out the high tide volume of that segment. The concentration within the segment was calculated, and the highest concentration found within the estuary at a given time was plotted in figure 4-2. The curves show the rate of decrease of peak concentration within a harbor over 14 tidal cycles. Their relative slopes afford a comparison of the rates of contaminant decrease among the harbors. The position of the curve at time * 0 reflects the amount of dilution that the contaminant would undergo within the first tidal cycle after introduction (assuming that 100 4-13 US00006875 units of contaminant are introduced and the dilution volume is the volume of water defined by the length of a flood tidal excursion and the width and depth of the body of water through which the tidal excursion is measured). (4) Advection is the true flushing agent as other processes mentioned tend only to reduce the concentration of a contaminant? they do not remove it from the area. Currents immediately offshore from the harbor serve as a mode of trans port to oceanic areas where dilution volumes are virtually unlimited. (5) For analyzing the relative flushing capabilities ^ of the harbors, the data available were inadequatefor examining many of the probabilities involved in the event of contamination. In some locations stratification of water results from density differences, and the net inflow in the bottom layer of this type of estuary would be upstream rather than seaward. Should the bottom layer of this type, of estuary become contaminated, the flushing time would be prolonged greatly. (6) The Hydrographic Office summary report cautioned that in light of their information, the flushing analysis for each harbor is believed to be valid insofar as the data avail able at the time would allow. The limitations imposed by data deficiencies are pointed out in each of the 18 reports for the individual harbors. 4-14 US00006876 c. To verify the results of the theoretical flushing analyses, the Hydrographic Office conducted actual dye tracer field tests for a group of harbors representing the types of harbors studied for their relative flushing capabilities (dye being a conservative substance during the periods observed). The dilution factors measured during five field tests conducted at large Navy ports are summarized in table 4-5. The peak concentration of any conservative contaminant at a time after release can be predicted by multiplying the total amount of contaminant released (concentration x volume) by the dilution factors in the table for that time. (1) The field test procedures consisted of releasing a quantity of dissolved tracer dye (rhodamine-B, or fluorescein) and monitoring its dilution and dispersion until dye concentra tions had decreased below the detection limit of the analytical equipment (two parts of dye per hundred billion parts of water) or until the dye had been transported out of the harbor. Field measurements of the test areas included collection of water samples for analysis of dye concentration and salinity, current and temperature measurements and aerial photographs. (2) A comparison of the results of the flushing analyses and field tests indicates the usefulness and the limitations of the tidal prism method. One of the basic assumptions of the tidal prism theory is that the contaminating material must be distributed uniformly both horizontally and vertically throughout 4-15 US00006877 ) Table 4-5 Dilution Factors for Five Navy Harbors Determined from Field _________Measurements of Dye Dilution and Dispersion________ Time After Dilution Factor (per litre) ----------------------------- 5 ----- Release Mayport Pearl Harbor3 San Diego10 San Francisco11 Hrs. Min. Basin8 (Southeast Loch) (Ballast Point) (Mare Island Strait) 0 10 6.6E-7* 0 30 6.6E-9 1.8E-7 1 0 2.2E-9 9.2E-10 1.2E-7 2 0 1.2E-9 9.5E-8 3 0 5.5E-10 1.0E-10 5.7E-8 40 1.2E-7 3.3E-8 5 0 4.9E-10 1.0E-7 1.6E-8 60 8.0E-8 2.6E-11 80 6.2E-8 10 0 3.3E-10 4.8E-8 12 0 4.4E-8 1.3E-11 15 0 2.2E-10 24 0 1.IE-10 2.6E-8 48 0 1.1E-11 9.7E-9 72 0 3.3E-12 6.6E-9 96 0 4.4E-9 120 0 3.2E-9 240 0 2.9E-9 Superscripts 8-12 refer to references, Section 10. *PORTRAN exponent form: 6.6E-7 = 6.6 x 10~^ Norfolk12 (Hampton Roads) 2.2E-7 7.1E-8 1.1E-8 1.3E-10 2.4E-11 7.7E-12 2.6E-12 1.5E-12 i -16 US00006878 the harbor. Thus, valid comparison of the predicted decreasing peak concentration curve and the observed curve cannot be made until the dye is uniformly distributed throughout the basin. For the Mayport Basin field test this occurred within six hours.* Application of the tidal prism method to the entire volume of Pearl Harbor failed to give realistic estimates of the decreasing concentration of a contaminant released within the harbor; however, concentration decreases within the South east Loch where the shipyard and naval station are located can be estimated fairly accurately after mixing of the dye within the loch is complete at 48 hours after release.9 A comparison of the other field tests with the theoretical analyses indi cated that the predicted reductions in peak contaminant concen trations as shown in figure 4-2 are valid for predicting the flushing rate of a contaminant from a harbor. (3) In all cases field tested by the Hydrographic Office, the initial dilution rate as seen from peak concen tration curves is very rapid. This fact has also been borne out by other dye dispersion studies.1* (4) To confirm that a 6% AFFF solution will disperse in a manner similar to that of a dye release, a small scale test was conducted in Dungan Basin at the David W. Taylor Naval Ship Research and Development Center, Annapolis Laboratory. The experiment involved the release of 20 gal (75.7 ) of 6% AFFF mixture composed of 1.2 gal (4.5 ) of AFFF concentrate 4-17 I US00006879 mixed with 18.8 gal (71.2 l) of dilution water and dyed with rhodamine WT dye to an initial concentration of 100 ppm by weight. The experiment proved the applicability of using dye to obtain dilution factors applicable for AFFF. (The experimental procedure and results are contained in appendix F. d. The dilution factors contained in the Hydrographic Office field reports can be used to estimate the maximum con centration of AFFF within a harbor after a discharge and to estimate the rates of removal from the harbor by flushing. (1) Based upon the Hydrographic Office dilution factors and the estimated quantity and frequency of potential ^FFF discharges, hypothetical cases for an AFFF release can oe developed. Each case is hypothetical in the sense that the discharge from a single ship (point source) is used in the calculations whereas it is possible that discharges from additional ships could enter the harbor at the same time. Furthermore, it is assumed that the ship will discharge its AFFF in a harbor location where there is good mixing; it is possible that AFFF would sometimes be discharged in less desirable areas such as those sheltered from the diluting effects of tidal flows. To offset these possibilities, the worst case conditions are assumed: the maximum quantity of AFFF would be discharged per ship and biological decomposition of the AFFF would not occur. 4-18 fI I | /-s , ' i t | ( ^ * (2) Theoretical peak AFFF concentrations have been calculated in table 4-6 based upon the dilution factors given in table 4-5. Sample calculations for five ports are based on the hypothetical discharge of AFFF from the largest ship ' likely to be berthed at those locations since it would emit the largest volume of AFFF and would thus provide a more rigorous test. It is recognized that all systems would not be checked simultaneously but would probably be exercised over a period of a few hours. Each test could involve the generation of about 90 gal (0.34 m J) of maximum 6% concen- tration AFFF. The system will be secured as soon as possible after sample collection. In order to evaluate the worst possible case, calculations are based on the unlikely assurnp- tion that all machinery space FP-180 proportioners are tested simultaneously and the ship represents a single point source. (3) A sample calculation for determining peak AFFF concentration following testing aboard an AS-type ship berthed at the Submarine Support Facility, Ballast Point, San Diego, follows. (a) AFFF generated during testing of two FP-180 machinery space proportioners aboard an AS-type ship is 180 gal (0.68 m s) of 6% solution containing 10.8 gal (40.9 ) of concentrate. (b) The dilution factor (DF) in San Diego ten minutes after release is 6.6 x 10"7/litre.10 4-19 US00006881 GO 00 -20 ) Time After Discharge Hrs. Min. 0 10 0 30 10 20 30 40 50 60 80 10 0 12 0 15 0 24 0 48 0 72 0 Table 4-6 Peak AFFF Concentrations in Four Navy Harbors at Intervals After Discharge of 6% AFFF Test Mixture Peak AFFF Concentration in mg/Jl Mayport Pearl Harbor* San Diego** San Francisco* Basin* (Southeast Loch) (Ballast Point) (Mare Island Strait) 28.0 0.28 23.0 0.27 0.04 15.0 0.15 12.0 0.07 <0.01 7.1 15.0 4.1 12.0 2.0 10.0 7.8 0.06 6.0 5.5 0.03 0.02 3.3 <0.01 1.2 0.8 *CV-type ship, six FP-180's tested, 540 gal 6% AFFF (32.4 gal concentrate). **AS-type ship, two FP-180's tested, 180 gal 6% AFFF (10.8 gal concentrate). Norfolk* (Hampton Hoads) 27.0 1.4 0.02 <0.01 \ US00006882 (c) Therefore, the AFFF concentration at that time can be calculated. (40.9 litre AFFF) (-L-..2JTiAFFF> 4.2 x 10hg AFFF (4.2 x 10-g AFFF)ild^x_l|l!DF) (10>g) 28 mg AFFF per litre !/ Using the same procedure, the predicted AFFF concentration after one hour is further reduced to 0.04 mg/. e. Based upon the results of the Hydrographic Office ( i studies as shown in figure 4-2, it is apparent that there is considerable variability between harbors with regard to the i dispersion of substances within harbors and the rate substances will be flushed from harbors. This is due to differences in harbor volumes, tidal flow volumes, eddies, currents, etc. Therefore, it was impractical to experimentally measure actual peak AFFF concentrations in Navy harbors after shipboard AFFF system test effluent discharges. However, from the information presented thusfar on the limited quantity and frequency of AFFF discharges, on the rapid dilution of a discharge, and on the rate of removal of AFFF from a harbor by natural flushing, it is possible to predict concentrations of AFFF after discharge, and the following conclusions can be drawn. (1) Immediate Effect of an AFFF Discharge. The initial dilution (determined by measuring peak dye concentration imme diately after completion of the release) of the dye released during the Hydrographic Office dye dispersal field test for 1I 4-21 US00006883 Key West was approximately 1000 times.1* Key West had the lowest dilution predicted for the 18 harbors studied, as shown in figure 4-2. During coastal dye dispersion studies using 5000 gal (18.9 m 3) of a seawater-sewage-dye mixture, initial dilutions of 1000 to 2000 times were measured at the point of discharge.13 The small scale AFFF/dye discharge into Dungan Basin discussed in appendix F indicated initial dilu tions of 3200 times. Thus, the initial concentration of AFFF (60,000 ppm maximum) can be expected to be reduced to no more than 60 ppm very soon after impact with the receiving waters. This concentration is only 5% of the 40-hour LCjq concentration found toxic to brine shrimp during bioassay tests conducted at .ie David V?. Taylor Naval Ship Research and Development Center. Therefore, the immediate effect of the proposed action, dis charging AFFF to harbor waters during in-port testing of machinery space fire-fighting systems, on the environment is considered negligible based upon the dilutions expected during the discharge. Appendix E contains toxicity data on six other representative saltwater organisms tested by the Center as well as tests on additional fresh and saltwater organisms conducted by other laboratories. (2) Long-Term Effect of AFFF Discharges. The chronic effects of AFFF have not been evaluated and total quantities of chemical discharged during the simultaneous testing of fire fighting equipment from several ships have not been measured 4-22 US00006884 (although based upon the assumed in-port testing frequency and the relatively small number of machinery space proportioners, the likelihood of multiple tests being conducted at the same time and location is remote). However, it can be concluded from the concentration data in table 4-6 and the toxicity data in appendix E that the dosage of AFFF required to kill 50% of the organisms after 96 hours of exposure (LC^q ) was' considerably higher than the residual AFFF concentration calculated to persist in any of the five selected harbors at the end of that period of time. In fact, for even the largest theoretical AFFF discharge given in table 4-6, the concentra tion of AFFF in the marine environment will be reduced in minutes to levels well below those acutely toxic to marine organisms. Furthermore, biodegradation data for FC-206 (appendices B and E) indicate that within the accuracy of the BOD and COD tests, AFFF FC-206 is virtually wholly bio degradable. j I i 4-23 US00006885 i SECTION 5 ALTERNATIVES TO PROPOSED ACTION 1. Th6 U. S. N a v y is c o m m i t t e d to p r o v i d i n g a d e q u a t e fire protection for the prevention, containment, and extinguish ment of fires. Testing is necessary to verify the readiness of fire-fighting equipment to effectively respond, as called upon, to combat fires. Confidence in both equipment and personnel is achieved by exercising the fire-fighting stations on a regular basis and verifying system performance after alterations or repairs. a. The need for maintaining a fast, effective system for shipboard fire fighting has been repeatedly demonstrated. Since 1969 alone, over 1100 shipboard fires have been reported to the Naval Safety Center. Major losses in that period of time include the USS KENNEDY/USS BELKNAP collision and fire in 1975 (now estimated at $213M, 8 deaths), USS NEWPORT NEWS in 1972 ($6.5M, 21 deaths), USS FORCE in 1973 (total loss), USS KITTYHAWK in 1973 ($1M, 6 deaths), USS FORRESTAL in 1972 ($20M) and in 1967 ($20M, 133 deaths), USS ENTERPRISE in 1969 ($5M, 27 deaths) and USS ORISKANY ($10M, 43 deaths). NSC reports 106 property damage accidents involving fires in machinery spaces aboard surface ships from July 1974 to January 1977, totalling $5.8M in material damage and 36 casualties. b. As ships and ships' systems become more sophisticated and the use of aluminum and composite structural materials in creases, the vulnerability to fire also increases. To keep pace 5-1 US00006886 with the need for more sophisticated fire-fighting strategy, methods for the prevention, containment, and extinguishment of fires have been improving. One such improvement was the development of AFFF in the mid-1960's to replace protein foam.15 c. Tests by NRL demonstrated that "light water" was two to three times as effective as protein foam in extinguishing bilge fires and recommended that a dual discharge system of "light water" and PKP be adopted for rapid, improved extin guishment of fuel fires in shipboard engine room spaces.16 Further testing by NRL, NAVSEC, and NAVSEA continued to demon strate the superiority of AFFF over protein foam for extin guishing fires involving AvGas, JP-4, and JP-5.17 d. The objective of Navy fire protection strategy is to markedly reduce the vulnerability of ships, aircraft, facili ties, and personnel to the hazards and damages of fire from both hostile and peacetime action.15 AFFF systems are an integral part of a ship's fire-fighting capability. The following proposed action and alternatives are analyzed with that objective in mind as well as the environmental impact of AFFF system testing. 2. Proposed Action; Overboard Discharge of Foam. The ob jective of the proposed action is to dispose of effluent produced by machinery space AFFF fire-fighting foam system testing. The current approach to testing AFFF systems is to generate foam through one nozzle on each proportioner, to /"^quickly sample the discharge for determination of AFFF 5-2 US00006887 concentration in the mixture, and to secure the system as soon as possible to prevent excessive use of AFFF concentrate. The foam is usually discharged directly overboard due to the unavailability of collection and/or treatment facilities. 3. There are six basically different alternative approaches to the proposed action. They are summarized as follows. a. Alternative (A). Test with Substitute Concentrate Material. Direct research and development efforts toward obtaining a substitute material for fire equipment test use which is more acceptable environmentally and which is func tional as AFFF. b. Alternative (B). Refine Procedures to Reduce Discharge Volume. Refine the test procedures to reduce the volume of the AFFF mixture produced. c. Alternative (C). Adjust Test Schedules for Discharge Only When Collection, Treatment and Disposal Facilities are Available. Establish that tests only be conducted when the AFFF discharge can be handled in an environmentally acceptable manner. This includes discharge to pier sewers, collection barges or on the open sea while underway. d. Alternative (D). Perform Tests with Discharge Contained as Part of a Closed System. Provide, as ancillary shipboard equipment, a dedicated holding tank capability to support the AFFF flow test and cause minimal scheduling interference. The AFFF mixture test effluent could be dis posed of in accordance with the plan of alternative (C). 5-3 US00006888 The implementation of alternative (B) would improve the feasibility of the portable tankage alternative by reducing the volume to be handled. e. Alternative (E). Eliminate Shipboard Flow Test by Redesigning Maintenance Plan. Redesign the plan of maintenance for the fire-fighting equipment to eliminate the shipboard flow test requirements. f . Alternative (F). Eliminate Shipboard Flow Test by Enhancing System Component Performance Reliability. Enhance system reliability by modifying equipment to increase confi dence of system performance to an acceptable level without egular flow testing using AFFF. 4. Figures 5-1 through 5-6 summarize the adverse and bene ficial effects (including those with cost and risk elements) in flow chart form, and develop the follow-on technical and administrative actions necessary for the conclusive acceptance or rejection of each alternative. 5. When the objective of alternative (A), test with a sub stitute concentrate material, is considered with regard to the environmental assessment parameters in table 4-1, it is concluded that by the nature of the change to a less harmful material, the potential for harmful impact is measurably reduced. 5-4 Adverse Conditions Requires modification to fire-fighting system to provide valving for in put of the alternate material during test. Requires post-test flushing and clean-up to restore the system to the prime mode (AFFF) readiness to perform. PMS procedural document is required for control and confidence. The hardware added to the system for the test op tion introduces an elementL of risk regarding the fire-fighting system's readiness to perform. The alternate (non-toxic) material adds one more item to the ships' stores. Beneficial Conditions Allows for test/check of the fire-fighting equip ment, personnel and pro cedures with a non-toxic and possibly less expen sive material,__ Provides for checks and test with possibly a min imal design and equipment change. ______________ Follow-On Activity Figure 5-1 Alternative (A) Test with a Substitute Concentrate Material Flow Chart US00006890 > Adverse Conditions llow-On Activity > Figure 5-2 Alternative (B) Refine Procedures to Reduce Discharge Volume Flow Chart US00006891 Adverse Conditions Follow-On Activity Figure 5-3 Alternative (C) Adjust Test Schedules for Discharge Only When Collection, Treatment and Disposal Facilities are Available Flow Chart US00006892 ) Adverse Conditions 0Ui01 Fo^aow-On Activities Perform design study to define the tankage hard ware required to hold the AFFF mixture. Verify the design objectives by test.__________ Accomplish the design, procurement and issue steps to equip the Fleet. Summarize and evaluate the technical, time and cost parameters. acceptable, implement not acceptable, turn to an alternative Figure 5-4 Alternative (D) Perform Tests with Discharge Contained as Part of a Closed System Flow Chart US00006893 Adverse Conditions Requires development of a maintenance concept to eliminate AFFF system flow tests aboard ship. Requires post-assembly, system pressurization with sea water to check integrity of joints. Involves development, procurement, check-out time and cost. Eliminates the opportunity for the crew to use the system for shipboard training. Beneficial Conditions PMS procedural document is required for control and confidence. Follow-On Activity Figure 5-5 Alternative (E) Eliminate Shipboard Flow Test by Redesigning Maintenance Plan Flow Chart US00006894 Adverse Conditions Requires design review of all AFFF fire-fighting systems to upgrade the reliability of perfor mance to eliminate flow tests. May involve system modifi cation to add: sensing elements; redundancy; parallel circuits; a con stant, low velocity flow loop; derated perfor mance levels; built-in test equipment, etc._____ Development, procurement and check-out time and costs are required.____ Eliminates the opportunity for the crew to use the equipment for shipboard training. Beneficial Conditions Avoids AFFF mixture ef fluent discharge in the port waters. Reduces volume of AFFF used by all ships. Eliminates the extra man handling of the fire fighting equipment for the flow test checks and the need for clean-up after test to assure readiness to support emergencies. ^5 llow-On Activity Perform design review and failure mode and effects analysis with an objective of the modification of systems and components to enhance performance.____ Develop plans and proce dures for installation and check-out of modified systems and components. Verify concept by confidence testing program. Implement the design, hardware modifications and system alterations aboard ship. Train crews to achieve confidence in system performance Suimnarize the technical, time and cost para meters. acceptable, implement not acceptable turn to an alternative Figure 5-6 Alternative (F) Eliminate Shipboard Flow Test by Enhancing System Component Performance Reliability Flow Chart US00006895 a. This alternative has already been investigated by NRL.18 The NRL report considered several test materials | which duplicated AFFF concentrate in viscosity and had a ' suitable refractive index for analysis using the hand-held refractometer presently used. Glycerin was one of the materials found to give the desired performance, was readily available and was low in cost, and it was therefore evaluated. The NRL study concluded, "It is feasible to simulate AFFF concentrates for proportioner testing by adding appropriate agents to water to give it the proper viscosity and refrac tive index."18 However, the use of a substitute material was not recommended. The report further stated, "It is ^ believed that the logistical problem of having a simulated concentrate in the supply system, the operation of change over from real concentrate to simulant and then back to real concentrate for each test, and the increased potential for introducing errors and confusion would not be justified on the basis of the differential costs per gallon of the simulated and real concentrates."18 b. NAVSEC considered glycerin as an AFFF substitute for testing but found it unacceptable from an operational stand I point although glycerin has a lower toxicity than FC-206 I (appendix E ) . They stated the following. 5-11 US00006896 HBecause glycerin might react with AFFF substances and make AFFF substances ineffective, use of glycerin for testing of foaming stations would require that the tanks be washed out fol lowing use of glycerin and refilled with AFFF. The chance of contamination of AFFF tanks by glycerin, which might make AFFF tanks inoperable or reduce the AFFF concentration to unacceptable limits, makes the use of glycerin for testing proportioning pumps less advisable. In addition, the use of glycerin for test ing could allow operational mistakes that affect ^ foam unit performance to occur. If a foam sta tion was accidently left filled with glycerin, the foam unit could be totally ineffective. If a second tank and valving were added, valves could be left set in the wrong position after testing. Any of these occurrences could turn a small fire into a major casualty if the foam unit malfunctioned. The subsequent possible loss of lives therefore makes this alternative unacceptable." l* c. AFFF is a highly developed fire-fighting substance. It is unlikely that a substitute substance could be found that is compatible with AFFF such that operational effectiveness 5-12 US00006897 is not degraded and a substance that is also environmentally more acceptable for discharge. d. Therefore, alternative (A), test with substitute con centrate material, has been rejected. 6. When the objective of alternative (B), refine procedures I to reduce discharge volume, is considered with regard to the environmental assessment parameters of table 4-1, it is con cluded that, by the nature of the change to reduce the volume of the discharge, the potential for harmful impact is reduced. a. Current testing time is now approximately one minute. Shorter times may be acceptable providing foam is being deliv ered from the nozzle in a uniform spray pattern and the hose has been previously flushed with salt water to verify that the hose is not clogged. However, if new in-line test devices (as described in section 9) are adopted, observation of nozzle spray pattern will be impossible. Also, even though the test operating time could theoretically be reduced, there is no assurance that the test team could or would minimize generation times. An AFFF discharge would still result. b. Alternative (B), refine procedures to reduce discharge volume, is rejected. 7. Alternatives (C) and (D) have as an objective, the elimina I tion of untreated AFFF discharges in port while still permitting system testing as currently practiced; therefore, the potentiai I for damaging the environment is eliminated if adequate treatment is provided. 5-13 US00006898 a. Alternative (C), adjust test schedules for discharge /-only when collection, treatment and disposal facilities are * available, relies on direct discharge to waste collection systems other than those specifically for AFFF containment. These waste collection systems include shipboard wastewater CHT systems, SV70B's, donuts and tank trucks. Also included in alternative (C) is discharge to open sea in unrestricted waters directly from AFFF systems undergoing tests or in d i r e c t l y throug h CHT s y ste m s . Such an a l t e r n a t i v e i s n o t c o n s id e r e d . v ia b le , however, as ship sa fe ty re q u ire s th a t m achinery space AFFF f i r e fig h tin g system s be te ste d p rio r to g e ttin g underway. (1) CKT systems are being installed on ships as part of the Navy program to eliminate the discharge of shipboard sanitary wastes into navigable waters. (a) CHT systems provide for the collection and transfer of sewage from waste drains as well as soil drains. Waste drains collect wastewater from hotel services such as showers, lavatories, laundries, galleys, sculleries, sinks, etc. Soil drains collect sanitary sewage from water closets and urinals. Separate soil and waste drains transport waste to collection headers for diversion overboard or to the holding tank. The holding tank contains sensing elements to control sewage pumps, a flushing system, and may contain an aeration system. Waste is transferred from the holding tank by sewage pumps, through discharge piping overboard either to the sea or through deck discharge fittings and hose to _ shore.28 5-14 a US00006899 (b) The major advantage of utilizing CHT systems for collection of shipboard generated AFFF is that the waste handling system is already aboard, and therefore extensive installation and alteration of a specific AFFF waste handling system is avoided. A lesser advantage from an AFFF waste handling standpoint is the initial dilution with other waste streams that the AFFF will have in the tank prior to pump-out. The degree of dilution will vary from ship class to class based upon the normal working capacity of the tank. Any dilution of AFFF waste prior to handling or treatment will lessen the possible waste handling problems due to foaming and lessen the possible waste treatment problems due to high BOD loading. A tentative installation schedule for CHT's is provided in appendix G. (2) SWOB's were originally conceived for the collec tion of oily waste from aircraft carriers, ships at anchor, and ships berthed at remote locations. The SWOB's procured in FY74 and FY75 were outfitted to handle only oily waste. Eighteen will be constructed with FY76 funds; thirteen will handle sewage, five oily waste. A sewage retrofit package developed in FY76 can be used at the discretion of the user activity to convert an oily waste barge to a sewage barge. (a) SWOB's scheduled for procurement in FY76 I are 75,000 gal (284 m 3) barges intended for the collection of sewage from ships at anchor, or berthed at locations where 5-15 US00006900 ** pier sewers are not planned because of high construction costs. The barges would transport the waste collected to \ available pier sewers or some other discharge location for f adequate treatment and disposal. A tentative allocation ^ plan for SWOB's is provided in appendix G. ' (b) The advantages of utilizing SWOB's for collection and transport of AFFF wastes are the same as those for CHT systems. (3) Waste oil rafts, or "donuts" as they are called, are for the collection and transport of oily waste from ships berthed at piers without oily waste collection facilities ,^and from ships at anchor. (a) A donut is a circular or elliptical cylinder with a flotation collar at the upper open end. The lower end of the cylinder extends several feet beneath the harbor water surface. The bottom is usually closed by baffles (older sys tems have open bottoms). Waste oil or waste oil-water mixture is discharged from a ship into the top of the donut displacing water within the donut. The water and oil separate gravi metrically within the donut. The floating oil is confined within the donut and any water added flows out of the donut and mixes with the harbor water. A donut can be towed from ship to ship until full, and then it is pumped out to an oil disposal or reclamation facility. 5-16 US00006901 (b) A donut is an unsatisfactory means of col lection and transportation for AFFF discharges. The specific gravity of sea water (1.02 - 1.03 at 4 * 0 and the specific f gravity of AFFF (FC-206, 1.020 at 4C) are nearly identical. Furthermore, they are fully miscible. Therefore, AFFF and sea water will not separate gravimetrically and a donut will have no separation or confining effect. (4) Liquid wa&tes are often removed from naval inst lations by contractors utilizing tank trucks. Wastes can be collected in shoreside tanks which are emptied by a contractor or discharged directly into waiting trucks. (a) Disposal of AFFF waste discharges by con tractor is an acceptable alternative that is practiced in some locations (i.e., Long Beach Naval Shipyard, appendix D ) . How ever, disposal by contractor involves additional coordination between ship, shore facility, and contractor, and therefore it involves additional expense and possibly delays. (b) Collection of AFFF in tanks could be an acceptable alternative until other more efficient alternatives become available. b. Alternative (D), perform tests with discharge contained as part of a closed system, relies on a designated shipboard holding tank for containing AFFF wastes. Alternative (D) differs from alternative (C) in that specific ancillary ship board equipment would have to be provided for alternative (D). 5-17 US00006902 (1) Allocating additional space and equipment aboard ship for handling only wastes from AFFF testing is not attrac tive. A closed test system would only be used during infre quent in-port testing (estimated as once every three years). It would have to be fabricated of materials compatible with AFFF and cleaned and serviced after use. The added benefit derived from dilution with other shipboard waste streams (in CHT system collection alternative (C)) prior to disposal would also be lost. Strict shipboard size and weight limita tions would make location of an AFFF collection system difficult. Therefore, the operational and physical disadvantages of pro viding a separate, closed AFFF test system makes alternative <D) much less attractive than utilizing existing waste handling systems, alternative (C). (2) Alternative (D), perform tests with AFFF discharge contained as part of a closed system, is rejected. 8. Alternative (E), eliminate shipboard flow test by rede signing maintenance plan, has as an objective the elimination of shipboard flow testing with AFFF and thus the generation of the waste aboard ship. a. This option recognizes that the fire-fighting systems are comprised of electro/mechanical/hydraulic components con nected electrically and/or hydraulically aboard ship. System evaluation could identify the key components requiring AFFF flow test for operational confidence. With some design change, the critical components could be given quick connect/disconnect capability to allow the scene of confidence checks of the com ponents to shift from the ship to shore side where the AFFF discharge could be more easily disposed of without contamination of harbor waters. An overall shipboard fire-fighting system pressure/flow confidence check could be performed using sea water. A program of design, procurement, training and instal lation is involved. The implementation of this alternative accrues a dividend by increasing the effectiveness of main tenance capabilities. b. Although alternative (E) eliminates shipboard testing, implementation of a maintenance plan would require time. Ship board testing would have to continue in the interim period. Alternative (E) is rejected. 9. Alternative (F), eliminate shipboard flow test by enhancing system component performance reliability, has as an objective the elimination of shipboard flow testing with AFFF. a. A systems analysis could be performed with the objective of changing equipment design to maximize the operational reli ability and thereby, by performance, assure confidence in the system without regular flow tests using AFFF. Consideration of the classic paths to increased reliability such as: redun dancy, added sensing circuits or parallel circuits, derated performance requirements, built-in test equipment, etc. are warranted. 5-19 US00006904 r^- b. Alternative (F), like alternative (E), also eliminates shipboard testing. However, also like alternative (E), alter native (F) would require time to implement. Thus, alternative (F) is rejected. 10. Table 5-1 summarizes the advantages and disadvantages of the six alternative actions considered. The alternatives are rated satisfactory or unsatisfactory based upon evaluation criteria under the environmental and operational objectives. Each alternative was evaluated based upon the same criteria in table 5-1. Implementation of any of the alternatives would reduce the navigable waters impact of the proposed action; how ever, alternatives (A), (D), (E), and (F) all have operational disadvantages and were therefore rejected. Alternatives (B) and (C) have been rated most satisfactory based upon the oper ational objective and are therefore most desirable. However, neither alternative (B) nor (C) can be implemented immediately. Therefore, due to the firm safety requirement for continuing AFFF system testing, the following approach is preferred. 11. Preferred Approach. Considering the proposed action and the alternative actions with a high regard for safety as well as the environment, the preferred approach to testing AFFF fire-fighting systems is continuation of current practice: in port, discharge minimum quantities of AFFF into the waters of those harbors where collection and treatment or alternate disposal of test effluent is not now practiced, and at sea, conduct as many of the necessary tests as possible while a dhip is underway in unrestricted waters. 5-20 US00006905 Table 5-1 Comparative Summary of the Affects of the Alternative Actions Evaluation Criteria Alternatives (A) (B) (C) (D) (E) Environmental Objective: Reduce Environmental Impact 1. Navigable waters impact reduction. 2. Lead time to begin implementation of alternative. SSSSS UUu Uu (F) S 0 Operational Objective: Reliable, Efficient, Simple Operation Maximize; 1. Crew confidence by direct check of equipment on-line. 2. Crew experience through actual equipment use. sSs S0 s S s SU Minimize; 1. AFFF system complexity. 2. AFFF equipment redesign or modification. 3. Ancillary equipment not otherwise available. 4. Logistical support. 5. Maintenance (manpower) requirement. 6. Additional training requirement. 7. Imposition of test scheduling restraints. uSs U sU sss S u ssU su u s s Uuu V s U sus u u s ss ssu sss S - satisfactory U - unsatisfactory TOTAL S 5 9 8 6 5 4 TOTAL U 6 2 3 5 6 7 US00006906 a. AFFF system test procedures can be used that both minimize the quantity of effluent generated and eliminate the foaming of the discharge on the harbor surface. Some Navy port facilities, on their own initiative, have imple mented procedures for collecting AFFF discharges in portable tanks, pierside sanitary sewers, waste collection barges, or tank trucks (Norfolk Naval Shipyard, Charleston Naval Ship yard, Mayport Naval Station, San Diego Naval Station, and Long Beach Naval Shipyard). Appendix D includes disposal procedures used by Long Beach Naval Shipyard (an example of tank truck disposal) and Norfolk Naval Shipyard (an example disposal in a sanitary sewer). Until adequate collection and disposal procedures are tested and implemented at other port facilities, direct overboard disposal of AFFF test effluents will be necessary. Adoption of test procedures using the in-line test device recommended by the FFAT, and further development of more environmentally acceptable AFFF formulations would continue to reduce the impact of overboard discharges (see section 9). b. Table 5-2 shows the capabilities for treating AFFF dis charged to the sanitary sewer system at the ten major naval port facilities listed in table 2-1. Estimates of the daily sewage flows from the naval installations and the operating capacities of the listed sewage treatment plants have been 5-22 ) )) Table 5-2 Treatment Capabilities for AFFF at Major Naval Port Facilities Tank Truck Sewage Treatment Naval Port Facility Approximate Daily Flow in Millions Location gal (m3) Plant Name San Diego, CA: City of San Diego Naval Station, 1.0 (0.004) Metropolitan Sewage North Island, 1.5 (0.006) Treatment Plant, Point Loma 0.2 (0 .001) Point Loma Norfolk, VA 4.0 (0.015) Hampton Roads Sani tary District, Army Type Primary Primary (E.1979) Pumpout Rate Plant Influent Operating for 200 vl/l AFFF Concentration Daily Flow Port Facility with 200 ]il/i Port in Millions Discharge Facility Discharge gal (m3) gpm (/m) ul/l 100 (0.378) 2.0 0.14 (0.53) 0.21 (0.79) 0.03 (0.10) 16 (0.060) 0.56 (2.1) 50 Charleston, SC Base Plant 1.4 (0.005) North Charleston Sewer District Primary 11 (0.042) 0.19 (0.74) (E.1980)* 25 Plant Pearl Harbor, HI 5.5 (0.021) Fort Kamehameha Tri Secondary 5.5 (0.021) 0.76 (2.89) services Treatment 200 * Plant Philadelphia, PA 1.0 (0.004) City of Philadelphia Primary 136 (0.515) 0.14 (0.53) South East Water (E.1980) 1.4 Pollution Control Mayport, FL Plant 0.6 (0 .002) Mayport Naval Sta tion Treatment Secondary 0.6 (0 .002) 0.08 (0.32) 200 ' Plant Little Creek, VA 1.0 (0.004) Hampton Roads Sani Secondary 16 (0.060) 0.14 (0.53) tary District, 12 Elizabeth River Long -ach, CA Plant 1.0 (0.004) Port of Long Beach, Secondary 11 (0.042) 0.14 (0.53) City of Los Angeles, 18 Terminal Island Bremerton, VIA Alameda, CA Treatment Plant 0.6 (0 .002) Charleston Treat ment Plant 1.1 (0.004) East Bay Municipal Utilities District Primary (E.1980)* Primary (E.1977) 6 (0.023) 80 (0.303) 0.08 (0.32) 0.15 (0.58) 20 2.8 Treatment Plant Estimated completion date of secondary treatment plant. -23 US00006908 /'"`"'obtained from the Navy Environmental Support Office (Code 25) , Port Hueneme, California, and NAVFAC Engineering Field Divi sions. A maximum target AFFF concentration of 200 vl/l in the port facility has been selected to minimize foaming in the municipal sewer system. Based upon findings of a USAF study (appendix E), operational problems due to foaming oc curred in a bench scale-activated sludge sewage treatment plant at concentrations above 200 \xl/l. The USAF study con cludes that FC-206 can be successfully treated at concentra tions of 200 vl/l on a continuous basis. Tests reported by the 3M Company (appendix E) showed no microbial inhibition at concentrations less than 1000 mg/. Therefore, it appears that the degree of foaming and not the treatability of AFFF effluents will determine acceptable discharge concentrations. c. Dilution of an AFFF test effluent within the port facility will occur in two stages: first, initial dilution in the CHT tank; second, dilution in the port facility sewer system. Figure 5-7 illustrates the initial dilution required in a CHT tank such that, when combined with the dilution in the sewer system, the AFFF concentration leaving the facility does not exceed 200 y/. Figure 5-7 assumes collection of 90 gal (0.34 m J) of 6% AFFF solution (5.4 gal (20.4 Jl] AFFF) per CHT tank discharge. Pumping rates of 100 gpm (6.3 l/s) and 150 gpm (9.5 l/s) are most common; exceptions are 400 gpm (25 l/s) pumps aboard two NIMITZ class ships, 800 gpm (50 l/s) pumps aboard five TARAWA class ships, and 20 gpm (1.3 l/s) 5-24 US00006909 pumps aboard one ALBANY class ship.21 Ships with a combination CHT tank capacity and pumping rate that plots below their facil ity location line in figure 5-7 would have to find alternative disposal or dilution procedures (i.e., separate holding tank, SWOB barge, etc.). d. Thus, completion of shipboard CHT tank installation, pier sewer construction, and SWOB delivery could eliminate AFFF system test effluent discharges to harbor waters by calendar year 1981. 1 ! 1 5-25 US00006910 Tank Volume, Gallons CHT pump capacity, gpm Figure 5-7. CHT Tank Dilution Volumes Required to Maintain AFFF Concentrations at or Below 200 ul/1 in the Port Facility Discharge. US00006911 SECTION 6 PROBABLE ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSAL BE IMPLEMENTED 1. Although the quantities of 6% AFFF mixtures that will be discharged are very small compared to other wastes discharged in and around harbor areas, a single assessment of the environ mental effects of an action which occurs in many varied loca tions and under differing circumstances is difficult. Regu larly scheduled testing of AFFF fire-fighting systems will occur aboard less than 500 Navy ships scattered in not less than 33 ports. 2. The chronic effects of AFFF chemicals on marine iife are as yet unknown. Potential toxicities of residual chemical forms and the possible bioaccumulation of AFFF chemicals in plants or animals has not yet been determined. However, existing evidence on the high degree of biodegradability of AFFF and the treatability of AFFF mixtures by conventional biological treatment plants, provides supportive evidence that AFFF can be assimilated into the environment with little if any harmful effect (appendix E). i 6-1 US00006912 SECTION 7 THE RELATIONSHIP BETWEEN LOCAL SHORT-TERM USE OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY 1. The current discharge of AFFF test effluents into harbor waters for disposal should have no immediate or short-term effect upon the use of a harbor area for industrial purposes. It is unlikely that the industrialized uses of port facilities will change in the near future because commerical aquatic or recreational uses of the environment are not currently compat ible with an industrialized area. Therefore, long-term pro ductivity of the harbor area as currently defined will not be affected. t 7-1 US00006913 SECTION 8 ANY IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES THAT WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED 1. The tests and bioassays reported in appendix E are all of a comparatively short-term duration. The long-range impact resulting from the continued use and discharge of AFFF mixtures is not known. It has been recognized that persistent contamination at low levels of toxicity may be more harmful to marine life than sporadic occurrences of higher concentrations.22 Discharges of AFFF test mixtures into harbors are only avoidable in those ports in which facilities for collection and transfer of liquid waste from ship to shore are operational. Preceding implementation of preferred alternative solutions identified in section 5, water quality in the immediate vicinity of an AFFF dis charging vessel will be adversely affected for a short time. There are no corroborating data from long-term tests at low levels of AFFF concentration. The level of any irrever sible or irretrievable commitment of natural resources by implementation of the proposed action, if it were to continue unchanged, is not known. I 8-1 US00006914 SECTION 9 CONSIDERATIONS THAT OFFSET THE ADVERSE ENVIRONMENTAL EFFECTS 1. The CNM/NAVSEA FFAT has found that many shipboard installed fire-fighting systems and foam proportioners were unreliable for a variety of reasons (i.e., proportioners worn, valving faulty and/or misaligned, electrical circuitry incomplete or otherwise inoperative and piping integrity severely degraded). One of the principal reasons for the conditions found has been attributed to the lack of adequate testing of proportioners and associated systems due to environmental considerations. Because of such considerations, current in-port test proce dures require that foam discharges must be collected on board in a tank or discharged to a suitable containment vessel. Atsea test procedures specify that a ship must be underway at 10 knots and be outside the 12-mile limit prior to conducting tests that discharge foam solutions overboard. As a result, when the foregoing requirements cannot be met, many foam pro portioners and associated systems are not properly tested prior to a ship getting underway. In event of a shipboard fire such lack of testing presents an undue hazard to the ship as well as to personnel aboard. Together with routine PMS > testing requirements, tests are particularly needed after com pletion of alterations, repairs, or installation of AFFF sys tems during ship overhauls or after construction. A firm requirement exists to conduct tests in port prior to sea trials. 9-1 US00006915 AFFF discharge from some systems cannot be easily contained due to necessary design configurations and the amount of foam produced. The problem of containment is further complicated in some instances because suitable collection vessels are not readily available, and ship's bilges, tanks and/or barges usually contain small amounts of oil making them unsatisfactory for receiving AFFF mixtures. Disposal of mixtures of oil and AFFF solutions is extremely difficult from a practical stand point in that AFFF renders the oil unsuitable for disposal by conventional means. It is therefore imperative, in the interest of personnel safety and material protection, that fully operable and reliable fire-fighting systems be main tained aboard ship. This requires regularly scheduled opera tional PMS testing and operational testing after equipment is newly installed, repaired, altered or converted. Until prac tical means of collection and alternate means of disposal are developed, it will be necessary to discharge AFFF mixtures overboard. 2. The following actions are currently being undertaken and will directly or indirectly either reduce the volumes of AFFF discharged or lessen the environmental impact of those dis charges. a. In view of the chronological improvement in the toxi cological character of AFFF formulations as supported by evi dence contained in appendix E, it is reasonable to assume that f** j' variants could ultimately become available that would be environmentally even more acceptable than currently avail able AFFF's. A study has begun to develop new formulations of AFFF material to improve environmental characteristics (Contract No. N00173-76-R-B-039). The development of exper imental AFFF formulations that would exhibit a reduced impact on the environment while retaining fire-fighting effective ness will be explored. The study will examine the effect of AFFF formulation components on the BOD, COD, biodegrad ability, toxicity toward sewage bacteria, fish toxicity, effect of component concentration on selected environmental/ biological parameters, formulation design experiments, and analytical methods evaluation. New AFFF formulas will be selected and screened for fire-fighting performance and physiochemical properties. Alternate analytical methods for determining solution concentration shall be conducted to determine if a simpler method for use in the field is feasible. b. The Navy has embarked on a program to eliminate t discharge of shipboard sanitary wastes into navigable waters in accordance with PL 92-500, its implementing standards and regulations. To accomplish this program, pier sewers are being constructed to collect ship CHT system discharge for shoreside treatment. Pier sewer construction began in FY73 and is scheduled for completion in FY81. Pier sewers will provide 9-3 US00006917 an environmentally acceptable means for disposal of shipboard generated AFFF testing mixtures to sewage treatment plants. The construction schedule for major port wastewater collection facilities ashore as of 15 October 1976 is contained in appen dix G. c. The discharge into a harbor of AFFF solutions through an aeration nozzle has, in the past, produced unsightly expanses of foam floating on the harbor surface. Through the adoption of an in-line foam testing device developed by the FFAT, the aeration nozzle is no longer required for testing and the foaming problem is being eliminated. The device consists of sa standard nozzle gauge adapter now required for foam testing, a small drain valve for sample collection, and a selection of interchangeable orifice plates for obtaining desired flow rate. The open end of the hose run from the device may be inserted directly into a tank top or held beneath the surface of a receiving body of water. It prevents the normal 5 to 1 expan sion of foam that causes a collecting tank to fill and over flow rapidly or that causes the unsightly foam layer floating on a harbor surface. I 9-4 US00006918 SECTION 10 REFERENCES 1. Geyer, G.B., "History, Research, and Foam Developments," Proceedings of a Seminar on Fire Fighting Foams - Their Characteristics and Uses in Fuel Conservation, John Hopkins University, APL/JHU FPP B74-1, December 1974. 2. Chapman, K.H., "Shipboard Foam Fire Fighting Equipment Conversion from Protein Foam to AFFF," NAVSHIPS Tech News, pp. 15-22, February 1974. 3. DTNSRDC Report TM-1863-5-76, "Catalog of U.S. Navy Commissioned Surface Ships and Shipboard Waste Management Systems," December 1976. 4. OPNAVINST 6240.3D of 24 August 1975, Chapter 1, Part 1, Paragraph 1103. 5. NAVSEA 0993-LP-023-6010 Technical Manual, Type 1, Operation and Service Manual with Illustrated Parts List for Fire Extinguishing System, Twin Agent (AFFF and PKP), 10 January 1975. 6. "Ship's Industrial Waste Handling Report," Draft, Prepared by Lowry and Associates, San Diego, for NAVFACWESTDIV, September 1976. 7. Ridley, E.W., "The Relative Flushing Capability of Eighteen Harbors," unpublished manuscript 33-60, U.S. Navy Hydro graphic Office, July 1960. 10-1 US00006919 # Fisher, L.J., "Field Report, Mayport Basin, Florida, Dye Dispersal Tests," unpublished manuscript 38-63, U.S. Naval Oceanographic Office, August 1963. 9. Fisher, L.J., "Field Report, Pearl Harbor Dye Dispersal Tests," unpublished manuscript 102-61, U.S. Navy Hydro graphic Office, July 1961. 10. Cline, C.H. and Ridley, E.L., "Field Report, San Diego, Dye Dispersal Tests," unpublished manuscript 14-60, U.S. Navy Hydrographic Office, May 1960. 11. Fisher, "Field Report, Mare Island Strait Dye Dispersal Tests," unpublished manuscript 0-26-62, U.S. Navy Hydrographic Office, April 1962. Cline, C.H. and Maloney, W.E., "Field Report, James River Dye Dispersal Tests," unpublished manuscript 1-60, U.S. Navy Hydrographic Office, February 1960. 13. "Dispersion of Sanitary Wastewater Discharges from Navy Ships," NSRDC Report 4194, August 1974. 14. Fisher, L.J., "Field Report, Key west Harbor Dye Dispersal Test," unpublished manuscript 13-61, U.S. Navy Hydrographic Office, May 1961. 15. "Strategy on Fire Protection," NRL Memorandum 6180-428:HWC: pij to NAVMAT 03T, 12 August 1976. 16. Jablonski, E.J., Peterson, H.B., and Tuve, R.L., "A Compara tive Testing Study of Fire Extinguishing Agents for Ship board Machinery Spaces," NRL Memorandum Report 1696, 15 April 1966. 10-2 US00006920 17. Darwin, R.L. and Jabionski, E.J., "Full Scale Fire Test Studies of Sea Water Compatible 'Light Water' as Related to Shipboard Fire Protection," GPO 1969-394-017/S109, 1 25 August 1969. 18. Gipe, R.L., Butler, C.S., and Peterson, H.B., "A Substitute Liquid for AFFF Concentrate for Checking Proportioners," NRL Memorandum Report 2733, February 1974. 19. Environmental Impact Assessment/Report, "The Effect of Discharging Aqueous Film Forming Foam (AFFF) to the Sea," NAVSEC 6159, July 1974. 20. NAVSEA 0901-005-0002 Technical Manual, Chapter 9005, Section V - Sewage, 1976. 21. Rice, M.S., Liu, H., and McClellan, G.E., "CHT Ship/Shore Interface Information Book," Hydronautics Technical Report 7607.41-1, Prepared for NAVSEC 6159, October 1976. 22. Warren, C.E., "Problems of Toxic Substances in Biology and Water Pollution Control," W.B. Saunders Co., Phila delphia, 1971. I 10-3 US00006921 t Ir* APPENDIX A EXCERPT FROM NAVSEA MESSAGE 1915238 FEB 1975 AFFF TESTING H \i US00006922 FM COMNAVSEASYSCOM WASHINGTON DC TO (SHIPYARDS) A. COMNAVSHIPSYSCOM WASHINGTON DC 230053Z FEB 74 (NOTAL) I f B. COMNAVSHIPSYSCOM WASHINGTON DC 010005Z NOV 74 (NOTAL) ( 1. The requirements of ref A are superseded by this message. I { Naval industrial activities must test each shipboard AFFF fire fighting system that has been newly installed, modified or repaired by the activity prior to ship departure. The tests shall be conducted using only approved AFFF concentrate solutions and results certified to the ship's commanding officer. If the test solutions must be collected, they shall be clearly identified and disposed of in accordance with local regulations. End of summary. i 2. All AFFF fire fighting equipment that is newly installed, repaired, altered or converted from protein foam by an indus trial activity shall be tested to insure proper operation and required output. It is recommended that ship's force verify proper lineup and operational integrity of all other fire fighting systems not included in the foregoing. The following shall be observed when testing AFFF hoses: a. The minimum acceptable concentration of AFFF in the l output mixture of the system is 3.5 percent. b. Allow foam to be generated for one minute before taking t a sample. After the sample has been taken the system should be secured ASAP to avoid excessive use of AFFF concentrate. A-l US00006923 c. If the only work done on a system was on the foam generator, (proportioner or pump), then only one hose shall be tested with AFFF to verify the foam generator performance. It is recommended, however, that all other hose lines be tested by use of salt water to verify system line up. d. All systems shall be tested with the installed nozzle at maximum trigger depression or maximum handle throw. 1 and 1/2 inch variable flow nozzles shall be set at 95 gallons per minute, (gpm), in machinery spaces, and 125 gpm in hangar bays or flight decks. Set 2. and 1/2 inch var. flow nozzles at 250 gpm. e. Output concentration shall be determined by refracto^ n e t e r analysis, using American Optical Inst. Co. Refracto- meter No. 10402 or 10430 or equal, NSN 1H 6650-00-107-8509, estimated unit price is $83.00. Samples for refractometer analysis shall be taken at the discharge of the nozzle and analyzed IAW MRC 13 C33R or 24 D82U within two hours after collection. Results of refractometer analysis shall be cer tified in writing from the industrial activity to the ship commanding officer prior to ship departure. 3. After extensive investigation and tests, it has been deter mined that AFFF fire fighting systems must be tested with AFFF concentrate to confirm specified system operation and concen tration output. No substitute testing liquid is acceptable. The AFFF concentrate shall conform to MIL-F-24385 as identified A-2 US00006924 in ref B. Approved AFFF concentrate is available in the supply system under NSN 9C-4210-00-087-4742 for 5 gal. con tainers and NSN 90-4210-00-087-4750 for 50 gal. drums. Direct proprietary purchase of AFFF from any other source rather than the Navy Supply System shall not be made without prior approval of NAVSEA. Some previous 3-M products not on the qualified products list (QPL) that may be found aboard ship are still acceptable for Navy shipboard use. These for mulations are the 3-M Co. formulations FC 195 and FC 199. These formulations are compatible with currently stocked Q P L concentrates. 3-M formulation FC 196 should not be used due to its high free chlorine ion content which promotes pitting and corrosion of stainless steel. 4. For testing of the machinery space AFFF fire fighting systems the following requirements are applicable for active ships and new construction: a. The requirements of paras 2 and 3 apply. b. The systems shall be tested and certified in port prior to ship trial runs. c. When testing in port AFFF/water foam shall not be dis charged into harbor water since such discharge may be harmful to marine life. The AFFF/water foam can be either collected and contained in drums, tanks, tank trucks, sludge barges, closed bottom donuts, YO's or other suitable containers, or the foam can be discharged into the machinery space bilge. A-3 US00006925 If the AFFF/water foam is tested by discharging into the bilge, then bilge discharging shall be deferred until the ship is outside the 50-mile limit. d. The AFFF/water foam should not be commingled with reclaimable waste oil products. e. In port disposal of collected foam shall be governed by local regulations. Guidance information for in port dis posal is available from the Environmental Branch of the cog nizant NAVFAC Engineering Field Divisions. 5. For testing of AFFF fire fighting systems other than machinery space AFFF fire fighting system, the following requirements are applicable for active and new construction s ships: a. The requirements of paras 2 and 3 apply. b. The required tests may be conducted while ship is at dockside, when the ship is outside the 3 mile limit and under way at a speed of at least ten knots or when the ship is out side the 1 2 mile limit, whichever is the most practical. c. If the tests are conducted at dockside, the require ments of paragraph 4.c to 4.f apply. d. If conducted while ship is outside the 3 mile limit and underway at ten knots or when ship is outside the 1 2 mile limit the AFFF/water foam may be discharged overboard as they are discharged from the system. e. Aircraft carrier flight deck washdown systems (flush xdeck and deck edge nozzles) shall be tested outside the 1 2 mile limit. It is recommended that prior to AFFF/water foam testing the flight deck washdown system be thoroughly flushed with salt water to remove any oil and dirt that may have drained through the nozzles into the system. 6 . NAVSEA is to be notified in the event that local authority prohibitions or other circumstances preclude testing and cer tification of shipboard AJFFF systems as required by this msg. The point of contact at NAVSEA is Mr. P. Hans, SEA 0495D, Autovon 222-8504. 7. This msg does not authorize the expenditure of customer funds nor does it authorize change orders without prior NAVSEA or TYCOM approval. A-5 US00006927 APPENDIX B COMPARISONS OF THE VARIOUS PARAMETERS OF AFFF'S US00006928 )> Comparison of Various Parameters of AFFF's* Parameter 3M - Light Water FC199 FC200 FC206 National Foam Systems AOW 3 AOW 6 PH 4.6 7.6 7.8 7.8 7.9 Specific Gravity Water Diethylene Glycol Monobutyl Ether COD (X10}) TOC (XIO*) BODu (X10J) BOD5 (% BODu ) 1.02 0.989 59% 1.020 70% 1.062 72% 1.031 72% 550 mq/l 18 mq/l 37 39% 730 mq/l 235 mg/. 450 mq/l 2 27% 500 mq/l 96 mq/l 411 mg/ 65 10% 500 mg/, 130 mq/l 354 mq/l 45 10 350 mq/l 1 0 0 mq/l 300 mq/l 45 01 *USAF EHL(K) Rept. 74-26, November 1974. (FOUO) US00006929 r* APPENDIX C FP-180 WATER MOTOR PROPORTIONER Naval Ships Technical Manual, Chapter 9930, Fire Fighting - Ship, Articles 9930.120 to 9930.123, September 1967 edition. (FOUO) \ US00006930 i 9930.120 FT-ICO W ATER MOTOR PROPORTIONER 1. The I-T-IPO w a te r motor proportion has 2!4-inch connections it both tire inlet and outlet sides and two M inch foam pickup tubes. It is a positive displacement foam liquid pump driven by a positive displacement water motor. 4. The water motoe proportioner is designed to propor Flow through the water motor causes the foam pump to tion 6 percent foam liquid into the fire lines at inlet pres- * inject a metered amount of foam into the fire stream, de sures of 75 to 175 psi and with flows of 60 to 1SO g.p.m. pending on the position of the foam valve. (See figure 993Ck-"" \ 5. Foam can be dispensed by any of the four following 39.) ( //<'combinations: 2. The foam valve has 3 positions, 1 for each of the 22 \1/f pickup,tubes and an " otT' position. A'plexi^Iass tight tulJe Enables the operator to determine when to shift Trom L pickup tube to the other as a foam.can becomes empty, thVs ^muring a'eoniinuotis supply of foam. In the " o ff' position, with How through the fire line, water it delivered a. One 114-inch fine equipped with foam nozzle and proportioner supplied by either a 114- or 214-inch hose line. b. Two 1inch lines wyed off from the 214-inch out let. Both lines equipped with foam nozzles. c. Three 114-indi Lines with foam nozzles. d. One 214-indi line equipped with foam nozzle. through the foam pump under pressure, and both watermotor and pump " float" on the line making the fire line available for conventional fire fighting. 9930.121 OPERATION O F TH E PO RTABLE FP-180 PROPORTIONER 1. Connect inlet to 214-inch hose line and connect dis 3. The FP-180 may be permanently installed for some charge lines, within capacity of proportioner and as needed. applications. In this case flexible couplings must be at (On ships having 114-inch fireplugs single 114-inch inlet and tached to the water motor inlet and outlet and a fixed outlet lines can be used.) pipe leading from an installed foam tank will be attached 2. Set foam valve to "o f f position. Foam valve should to one pickup tube inlet and the other inlet will be plugged. always be in " o ff' position except when actually drafting The foam valve is placed in one position only. foam. Chaptar 9930 NAVSHIPS Technical Manual I C-l ORIGINAL FOR O FFICIA L USE ONLY US00006931 FOR OFFICIAL USE ONLY 3. Insert each pickup lube in M l Foam can. i--4- Actuate hose line. To start proportioning foam, shift 2. After draining.a few ounces of light lubricating oil should be squirted into the motor through the suction and f to "foam" position. The valve is so designed that, in discharge openings. Ol should also be squirted into the intermediate positions, a jet of water flows through the foam valve and foam pump. To pot oil into the foam pump, pickup tube, purging air and ensuring an rmmcdiate prime U ,2 ~ ) place the foam valve in a "foam" position and pour oil of the foam pump. No noticeable dwell at i n t e r m e d i a t e i n t o the corresponding pickup tube opening. Turn the ex positions is necessary to complete the action. If I'o arrr- tended shaft several revolutions by hand to distribute the liquid color does not show in the plexiglass tube withrn a oil within the proportioner. few seconds, shift to the other foam position and check 3. The proportiocer should periodically be checked {or *for a blocked pickup tube or an air leak in the line. free turning. Always replace the cover over the extended 5. When a foam can is almost empty, shift to other motor shaft to prevail oil leakage or entrance of foreign " foam" position and replace empty can. matter. .. 6. After proportioning foam, always flush the foam 4. If the unit fails to turn freely and there are no pump by running the proportioner two or three minutes foreign objects in the water motor visible through inlet or in the "off" position, then work the valves two or three outlet connections, loik for dried foam liquid or foreign times when the unit is running. Return valve handle to matter in the foam pump. Have the foam valve in one of "o f f position when finished. the "foam" positions. Hour water through the correspond ing inlet connection and turn the rotors first o::: way then 9930.122 OPERATION OF PERMANENTLY INSTALLED FP-180 FOAM PROPORTIONER 1. Installed FP-180 foam stations are arranged the tame on all ships but may differ in type of controls used to actuate the system. Controls may consist of local man ual control valves or remote hydraulic control valves. . 2. The station will be composed of an FP-ISO, 50gallon foam tank and associated piping and valves. The foam tank is arranged for quick filling from 5-gallon cans. Fitted with a vent, drain connection gage glass and access the other. Hot water dissolves caked foam liquid deposits faster than cold watr. Never use gasoline or any solvent to wash out dried foam liquid. It may he necessary to re move the foam valve and accessory piping from the pump nd pour water directly into the pump ports. At any lime that this is done, it is well to clean all foam-carrying ac cessories before they are replaced on the unit. plates for cleaning. 3. The stations are installed to supply foam for machin ery spaces and helicopter landing platforms. Proporticners for landing pistfonns are arranged for local manual control at the station. Those for machinery spaces may be arranged ^""'emote control from the foam hose outlets in the ma c. .ery and/or local manual control at the station. Figure 9930-40 shows the latest machinery space foam installation. The system is activated by turning the control cock to " drain", relieving pressure on value 1 which opens admitting seawater. Valve 2 is then opened by fircmain pressure ad mitting foam liquid to the proportioner. This type system fails open, that is. any breech of control lines actuates the foam proportioner. The foam outlet valves stiil have to be opened to supply the hose lines. 4. On older installations, valve 1 is similar to valve 2 and is opened by turning the control cock to a position which admits fircmain pressure to the valve bonnet, opening the valve. This type system fails closed when the control lines are breeched. 5. On still older installations the foam outlets are lo cated outside the space on damage control deck with the foam station. In this case, one must leave the space to ob tain the hose line and activate the station 9930.123 CARE AND MAINTENANCE OF THE FP-180 WATER-MOTOR PROPORTIONER I . Foam liquid dries into a hard-surfaced sticky film that may prevent operation of the proportioner. it is there fore important that the pump and water motor be carefully flushed after each use. The unit should be thorouglily drained after flushing. Stand the unit on the water motor discharge and turn the extended shaft clockwise with a wrench applied to the milled flats on the end of the shaft. Chapter 9930 ^AVSHIPS Technical Manuri C -2 US00006932 US00006933 FOR O FFICIAL USE ONLY Chapter 99 NAVSHIP: .lical Manual C-3 ORIGINAL FOR O FFICIA L USE ONLY 1 APPENDIX D AFFF SYSTEM TEST AND WASTE DISPOSAL PROCEDURES 1. AFFF/PKP Fire-Fighting System Test Procedures for Long Beach Naval Shipyard (18 pages) 2. Hazardous Waste Disposal Procedure No. 10 from Norfolk Naval Shipyard (1 page) 3. "Disposal of Aqueous Film Forming Foam (AFFF) Wastes," Pollution Solution, Naval Environ mental Protection Support Service, PS-003A, 18 September 1975 (4 pages) US00006934 WRP:nn(303) 2 April 1976 MEMORANDUM From: V. R. Prince, Operational Safety Advisor, LBNS To: Craig Alig, Code 2863, Naval Ship R. and D. Center Subj: Disposal of AFFF 1. Craig, below is the information you requested: a. Based on nine regular overhauls per year, we dispose of approxi mately 1100 gallons of AFFF per year. b. It is off loaded into a 2500 gallon sludge tank, transported to a holding area, picked up by an outside contractor, and dumped in a Class I Sanitation dump. 2. Hope this information will be of some benifit to you. Q Bill Prince D-l US00006935 i * j US00006936 ( a f ff system T ES T PROCEDURE 1 .0 PURPOSE; 3 * nd d e te rm in e s t r e n g t h and t ig h t n e s s o f n e w ly in s L & lle d * 8 * n t f i r e e x tin g u is h in g system and to dem onstrate s a t is f a c t o r y o p e ra tio n 2 .0 REFERENCES: 2 .1 OPNAV IN ST 6 2 4 0 .3C o f 20 Apr 1973 2 .2 NAVSEA N o tic e 9930 o f 13 Sep 1973 2 .3 NAVSEA MESG R 2300537 Fe b 74 2 .4 NAVSEA T e c h n ic a l M anual 0993-023-6010 F i r e E x t in g u is h in g System , Tw in Agent (AFFF and PKP) 2 .5 T y p e -5 0 7 -4 5 0 6 6 3 - C l FP1 80 - Foam L iq u i d P r o p o r t io n e r M o d if ic a t io n s 2 .6 Typ e-507-4506918 - O p eratin g Diagram M achinery Spaces F i r e F ig h tin g System D -3 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006937 3 .0 PREREQUISITES P IP IN G * 3 .1 A l l e x is t in g p ip in g not removed by co n v e rsio n s h a ll be in sp e c te d f o r p re s e n c e o f p r o t e in foam d e p o s it s , i f fo u n d , c le a n a s f o llo w s : 3 .2 (a) One f l u s h i n g w it h h o t w a te r f o r p e rio d o f 15 m in u te s . (b ) One f lu s h in g w ith s o lu t io n of hot w ate r and 102 A FFF. PROPORTIONER 3 .3 The e x is tin g FP180 p ro p o rtio n er/s ( to ta l to be te ste d ( ) ) s h a ll be te ste d fo r proper o p eratio n . 3 . A P ro p er o p e ra tio n o f the p ro p o rtio n cr i s determ ined by c o lo rco m p ariso n a n a l y s i s o f th e p r o t e i n - s a l t w a te r m ix t u r e w ith known a d m ix tu re s of 2 , A, 6 , and 8 p e rce n t or by measurement of the m ixtu re u sin g a r e f r n c t o m e te r . F i v e p e r c e n t p r o t e in i n th e m ix t u r e i s th e minimum a llo w e d and i n d i c a t e s proper p ro p o rtio n er o p eratio n . For operation of the re fra cto m e te r, see M a in te n a n c e R eq u ire m e n t C a rd s (MRC) 92 B88V Q f o r th e p ro c e d u re of A FFF s y s tems i n m a c h in e ry s p a c e o f MRC 13 C33R A f o r AKFF/HCFF S t a t i o n s . 3 .5 P ro p o rt io n e d f a ilin g to p ass the re fra cto m cte r t e s t s h a ll be re p la c e d w ith new FP180 p r o p o r t lo n e r s . ' 3 .6 P ro p o rtio n e rs w hich pass refra cto ra e ter t e s t s h a ll be flu sh ed in acco rd an ce w ith paragraph 3 . 2 . (a ) and 3 . 2 . (b ). , 4 .0 T ES T EQUIPMENT 4 .1 Supply of sm a ll co n ta in e rs 4 .2 1-1/2" ` fire h o se (s u f fic ie n t length) 5 .0 SERV ICES REQUIRED . 5 .1 S a lt water a ervieea . D -4 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. {SHEET REV. US00006938 tt 7 .0 PRECAUTIONS . 7 .1 In com pliance w ith the environm ental p ro te ctio n p o lic ie s of r e f e r e n c e ( 2 . 1 ) , Aqueous F i lm Fo rm in g Foam (A F F F ) may be h a rm fu l to m a rin e l i f e and s h a ll not be d isch a rg e d in to n a v ig a b le w a te rs . D e sp ite t h is r e s t r i c t i o n , i t i s e s s e n t ia l th a t new ly I n s t a l le d and m o d ifie d A FFF f i r e f ig h t in g system s be te ste d p r io r to sh ip d e p a rtu re f o r se a t r i a l s a s s p e c i fied in reference (2 .3 ). - 7 .2 T h e re fo re , a l l AFFF f i r e fig h tin g equipment new ly I n s t a l le d , re p a ire d , a lt e r e d , o r co n verted from p r o te in foam, by in d u s t r ia l a c t i v i t s , s h a l l be te s te d to In s u re d e sig n o p e r a b ilit y and o u tp u t. These t e s t s s h a l l be conducted and th e r e s u lt s re tu rn e d to D esig n Code 260.15 fo r w r it t e n c e r t i f i c a t i o n to th e commanding o f f i c e r p r i o r to t r i a l s o r d e p a rtu re . 7 .3 T e st requirem ents s h a ll in clu d e v e r if ic a t io n th at the system output c o n t a in s a minimum A FFF c o n c e n t r a t io n o f 3 .5 p e r c e n t a s s p e c i f i e d In r e f e r e n c e ( 2 .2 ) . Output c o n c e n tra tio n s h a ll be determ ined by re fra c to m e te r in acco rd an ce w it h a p p lic a b le MRC c a r d s . Sam p les f o r r e f r a c t o m e t e r a n a l y s i s s h a l l be ta k e n a t the d isc h a rg e o f a hose n o z z le and an aly zed w ith in 2 hours a f t e r c o lle c t io n . 7 . A An e x c e p tio n i s g ra n ted f o r sam ple t e s t in g o f a i r c r a f t c a r r i e r f l i g h t d eck washdown f i r e f ig h t in g system s w h ile in p o r t . V e r if ic a t i o n of o u t p u t c o n c e n t r a t io n o f th e s e sy ste m s may be d e f e r r e d f o r p e rfo rm a n ce beyond th e 1 2 - m ile l i m i t b e c a u s e o f th e i m p r a c t i c a b i l i t y o f c o l l e c t i n g A FFF foam d is c h a r g e from s lu s h deck n o z z le s . A l l o th e r washdown system s t e s t s s h a l l be conducted p rio r to g e ttin g under way. 7 .5 M ix tu re s co n ta in in g A FFF, produced by th ese t e s t s , must be contained in drum s, ta n k s , slu d g e b arg es or c lo se d bottom donuts a s re q u ire d fo r o i l d is p o s a l in re fe re n c e ( 2 .1 ) . However, AFFF should not be co-m ingled w ith re c la im a b le w aste o i l p ro d u cts. The m ixtu re s h a ll not be d isch a rg ed in to harbor w aters s in c e AFFF could produce co n ce n tratio n s a ffe c tin g m arine l i f e . D is p o s a l, in c lu d in g in tro d u c tio n in to m u n icip a l sew er sy ste m s, s h a ll be go verned by lo c a l re g u la tio n s. 7 .6 Report im m ediately to the S h ip 's Sup erintend ent any d e fe c ts which may d e la y c o m p le tio n o f t e s t . 7 .7 L i s t the lo c a tio n s of b la n k s, e t c ., used during the conduct of t ig h t n e s s t e s t on S h e e t No. 7 .8 O b serve norm al s a f e w orking p r a c t i c e s in a cco rd a n ce w ith LBNSY In stru c tio n 5100.27C. Q < D -5 SIZE CODE IDENT. NO. 89219 SCALE NAVSEA DRAWING NO. |SHEET REV. US00006939  8 .0 SHIT/SYSTEM/PLANT CONDITIONS: . 8 .1 Ship - dockside 8 .2 System - m o d ific a tio n s com plete and ready fo r t e s t in g . 9 .0 T EST . PROCErmUF./TEST SPECIFICATIO N S i 9 .1 FR I`1,1 MTKAKY VISUAL INSPECTION - fHASE I 9 .1 .1 In s p e c t tlie e n t ir e i n s t a l l a t i o n fo r s a t is f a c t o r y workmanship and agreem ent w ith r e fe r e n c e s . 9 .1 .2 A s c e r t a in in s t r u c t io n and la b e l p la t e s a re p ro p e rly lo c a te d and c o rre ctly in scrib e d . 9 .1 . 3 d e te rm in e th a t foam li q u id tan k h a s been te s te d fo r t ig h t n e s s p r io r to in s t a lla t io n . 9 . 1 . A C ho ck t h a t foam p r o p o r t io n e r s have been f i l l e d to th e p ro p e r l e v e l w it h c o r r e c t g rad e o f now o i l . 9 .1 . 5 A s c e r t a in th a t 100 f t . o f 1 -1 /2 " hose and an A FFF n o z z le a re p ro v id e d w it h each new hose r e e l on th e 9 . 1 . 6 A s c e r t a i n th a t 50 f t . o f 3 /4 " h o s e , 50 f t . o f 1 - 1 / 2 " ho se and tw in a g e n t n o z z le a r e p ro v id e d w it h e a ch new ho se r e e l i n th e m a c h in e ry sp aces. 9 . 1 . 7 Remove c o v e r o v e r th e exten d ed m otor s h a f t and c h e c k e a ch p ro p o rtio n e r fo r fre e tu rn in g . Replace co ver. 9 .1 .8 Record data as re q u ire d on Sheets 9 .1 .9 REPORT The tw in agent f i r e e x tin g u ish in g system was v is u a l ly in sp e cte d and found s a t i s f a c t o r y on th e d a te in d i c a t e d . C / 2 6 0 .1 5 T e s t E n g r ./ T e c h . _________________________ D a te ________________ I i iiw o . n v i n .9 o ;o /? o r w r v . io -74 > n-6 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006940 * 9 .2 HYDROSTATIC TEST - PHASE II . 9.2.1 At each foaa station vlth the foam proportloner and AFFF tank isolated, teat new flremaln and foaa concentrate piping hydrostatically to 150 PSIG. 9.2.2 At each foaa station with the dry chemical and nitrogen tanks and the dry chemical portion of the machinery space hose reels isolated, test PKP supply piping to hose reels hydrostatically to 330 PSIG for 30 lnutes minimum and examine piping, valves, and fittings for tightness. After satisfactory completion of this test, drain water from piping and thoroughly dry out by blowing through with warm, dry air. 9.2.3 At each foam station with the new nitrogen piping between the 3 way hytrol valve and nltrogen-PKP tank assembly isolated, test this piping hydrostatically to 330 PSIG. After satisfactory completion of this test, drain water from piping and thoroughly dry out by blowing through with warm, dry air. 9.2.4 REPORT . i The AFFP piping system was given a hydrostatic test and was found satisfactory on the date indicated. C/260.15 Test Engr/Tech Date I Shop Personnel _ _ _ _ _ _ Date < Ship's Representative Date 9.3 PRE-OPERATIONAL TEST - PHASE III (PKP SYSTEM ONLY) 9.3.1 Make sure all noazles are closed. 9.3.2 Close black ball valve. 9.3.3 Remove the safety clip from the nitrogen cylinder valve and pull the quick opening "pull" handle. 9.3.4 Observe the opening of the powertrol and hytrol valves and the flow of AFFF solution from the normally open petcock. 9.3.5 Close the nitrogen cylinder valve, and Install the safety clip and lead and wire seal. 9.3.6 Open the blue ball valve. I D-7 SIZE CODE IDENT. NO. NAVSEA DRAWING NO. REV. A 89219 1 SCALE SHEET f US00006941 n * 9.3.7 flow ceases. Open Che dry chemical nozzle and hold open until evidence of 9.3.8 Close blue ball valve and replace pin and lead and wire seal. 9.3.9 Open green ball valve. Powortrol and hytrol valves should close lsmedlatcly and flow from the pctcock should gradually decrease to zero. 9.3.10 Walt 5 minutes. Close green ball valve. MOTE: If powertrol and hytrol valves close before green ball valve is opened probable cause Is faulty check valve. 9.3.11 Open black ball valve. 9.3.12 Check nitrogen cylinder pressure. If over 1500 PSI, system Is ready for use. If under 1500 PSI,replace vith spore cylinder. 9.3.13 Repeat steps 9.3.1 through 9.3.12 for remaining PKP units. 9.3.1A Return to eacli PKP unit in the previous order and open and close green ball valves to check for pressure build-up. NOTE: When shutting down the system after test or use leave .the green ball valve open for 5 minutes to insure that N2 pressure is relieved. 9.3.15 REPORT < The PKP units were pre-operated and where found satisfactory on the date Indicated. C/260.15 Test Engr/Tech ___________________ Date ___________ Ship's Representative __________ '___________ Date ___________ 9 . A OPERATIONAL TEST - PHASE IV 9.A.1 Fill the AFFF supply tank with fresh water.. 9.A.2 From each foam station operate the AFFF system using the local control valve as per operating chart of reference (2.6), discharging overboard through hose station on DC deck and using additional 1-1/2" fire hose as re quired. ) ) 1 D-8 SIZE CODE IDLNT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. J US00006942 I 9.4.3 Observe that the water level in the AFFF tank falls at a normal rate. (Approximately 5 GPM when discharging through a 1-1/2" nozzle). 9 4 .4. Demonstrate foam recirculation using the FF180 test procedure on operating chart of reference (2.6). 9.4.5 Perform the following operational test on the dry chemical extinguisher set: lever. (1) Remove safety clip from nitrogen cylinder valve and pull position. (2) Check that sea water and AFFF concentrate vaives are in open (3) Close cylinder valve and replace safety clip. (4) Seal cylinder valve with lead and wire seals. (5) Open and close dry chemical nozzles quickly and observe discharge of "Purple-K" dry chemical. (6) Open and close AFFF nozzles in the machinery space hose reels quickly and observe discharge. (7) Close black dry chemical valve. (8) Open blue hose clean out valve. (9) Open dry chemical nozzle to clear all dry chemical from hose line and relieve all pressure from tank. (10) Close blue hose clean out valve. (11) Replace ring pin and seal with lead and wire seal. . (12) Open black dry chemical valve. (13) Open green vent valve and check that sea water and AFFF concentrate valves close. (14) Close green vent valve. (15) Remove fill cap and replace "Purple-K" which was used, approximately 15 pounds. (16) Replace fill cap, hand tighten. (17) Replace nitrogen cylinder if pressure is less than 1500 PS1 at 70 F . (18) Replace any missing lead and wires. D-9 SIZE CODE IDENT. NO. A 89219 NAVSEA DRAWING NO. REV. SCALE SHEET US00006943 4 9.A.6 During the operation of AFFF system, tnke one (1) sample of the foam solution and submit to the lab, Code 13A.1, for refractometer analysis. NOTE: After completion of the refractometer analysis, the lab should submit results to Code 260.15. 9.5 KF.FRACTOMF.TFR ANALYSIS - PHASE V (Lab only) 9.5.1 A refractometer analysis shall he accomplished by the Industrial Lab to determine the AFFF concentration of the AFFF solution. NOTE: This procedure has been incorporated into the Maintenance Requirement Cards (MRC) for the AFFF system for machinery spaces (performed every six months) and the AFFF high capacity fog foam (Al'FF/HCFF) stations (performed annually) to en sure an adequate as well as an efficient amount of concentrate (3.5 to 6 percent) is available. During test operation of a foam-proportioning system, the pollution-control requirement must be adhered to; that is, foam generating tests of foam equip ment must be conducted when the foam generated is retained in a tank or barge. 9.5.2 To perform the rcfractomer analysis, the following equipment is required: 12-inch ruler Data sheet and graph paper Eye dropper Light water (AFFF concentrate) Clean bucket 100-ml beaker 50-ml beaker Sample bottles Lens tissue, 100 sheets 100-cc volumetric flasks (3), marked 2Z, 4Z, and 6Z and glass flask stoppers 1 Funnel 1.3330-1.3700 angstrom optical refractometer, American Optical Instrument Company No. 10420 or 0-30 scale AOIC No. 10A30 or equal, No. 10430 is available from STCC under FSN No. 1H6650-600-6154 10-ml measuring pipette f M Y i R .on ?n /)n r t o e v tn_74> D-10 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006944 Z''"** \ \ i 9.5.3 PREPARATION OF CALIBRATION CURVE 9.5.3.1 Since the concentration of aea water varies depending on the area or region where the ahip la operating, a new calibration curve must be developed for each refractometer analysis. Obtain about 50-ml of AFFF concentrate from the storage tank; this can be drawn from the gauge glass drain. To ensure that no sediment Is drawn out, drain and refill the gauge glass before taking the test sample. Next obtain from the firemaln about a gallon of sea water. First, clean and dry three 100-cc volumetric flasks and designate 2, 4, and 6 percent respectively. Then fill these flasks approximately 3/4 full with the sea water; Into the flask marked 2 percent, pipette 2-cc of the collected AFFF concentrate; Into the flask marked 4 percent, pipette 4-cc of AFFF concentrate; Into the flask marked 6 percent, pipette 6-cc of concentrate. Next fill the volumetric flasks up to the 100-cc line with water, Insert the glass stopper, and Invert each flask several times to mix thoroughly. The next step Is determining the refractive index of the sea water sample and the 2-, 4-, and 6-percent samples. With the aid of an eye dropper, place a few drops of the sea water sample on the glass surface of the refractometer. Make sure all air bubbles are expelled when the top prism plate Is moved Into Its closed position against the bottom glass surface. Best readings are obtained when the refractometer Is held level, pointed toward an overhead light source and a slight finger pressure Is applied on the upper prism. Read the number from the left-hand scale where the horizontal line appears between the dark and light fields and record the value of the data sheet (See Table 1). This value Is the refractive index of the sea water sample and will be the concentration "0 percent" value. Special care should be observed In cleaning the glass surface of the prism. The fluid should be removed by lightly blotting and wiping with lens tissue. A dry lens tissue should then be dipped in clean..fresh water and the glass surface should be lightly wiped with the wet tissue and then dried with a dry lens tissue. Using the same method as for "0 percent" concentration, obtain refractive index values for the 2, 4, and 6 percent standard solutions and record the readings on the data sheet. Special care should be taken to clean the refractometer'a glass surface and rinse out the eye dropper with fresh water after each reading. A calibration curve can now be plotted .using the refractive index as the vertical values and horizontal values in creasing from 0 to 10 percent (See Table 2). 9.5.3.2 Plot the values from Table 1 for the "0 percent" water sample and the 2, 4, and 6 percent standard solutions on the graph paper and draw a straight line through the four points; this will be the calibration curve for the particular station where the concentration sample was taken. If a straight line is not obtained, discard the samples and start again with fresh samples. This completes the preparation for analysis of the test samples. D-ll SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. ( US00006945  Table 1 Concentration Z Concentrate Z Water 1.0 100 (Water sample) 2.2 98 (Standard solution) 3.4 96 (Standard solution) 4.6 94 (Standard solution) 5.- -- (System test sample) Refractive Index from scale readings 1. 2. 3. 4. 5. Refractive Index Tabic 2 I t I lI I ) Percent of AFFF Concentration SIZE CODE (DENT. NO. A 89219 SCALE NAVSHIPS DRAWING NO. SHEET REV. I 1 US00006946  rK t.5.* FOAM SOLUTION TEST 9.5.4.1 Sample* of foam solution may be collected wherever It can be certain that the sample 1* a true representation of the system output. After allowing sufficient time to elapse after start up to ensure that the system has come to equilibrium (about one minute), a sample may be obtained by holding a container with a handle Into the edge of the handline stream (or from a pan set on the deck to catch some of the foam discharge from a flight deck fire fighting system flush deck nozzle.) 9.5.4.2 Now place a few drops of foam solution from the system test sample on the refractometer and obtain Its refractive Index (samples should be analyzed within two hours after the system test run). Using the refrac tive Index, the concentration of the sample can be obtained from the calibra tion curve. Record the concentration on the data sheet. If the test samples read less than 3.5 percent, attempt the following corrections and retest the system: Inspect foam concentrate tank supply lines to AFFF/HCFF FP1000 proportioner of AFFF Injection pump for obstructions and closed valves; clean the AFFF supply line strainer; Inspect foam or flight deck flush deck nozzles for obstructions; Increase flremain pressure, inspect FF1000 propor tioner foam pump for seizure or binding; check proportioner foam pump rotor clearances; using one and two hoselines respectively, compare the propor tioner RPM with that in the proportioner manual. If RPM is not up to speci fication, the proportioner should be repaired. If unable to obtain 3.5 to 6 percent station operating concentration, report deficiency to D.C. Central, and retain data sheets and graphs for comparison against future tests. D -13 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006947 r * _______ t REPORT AFFF AFFF/TKP AFFF/PKP AFFF/PKP AFFF/PKP STATION STATION STATION . STATION STATION 1. Workmanship 2. Agreement with ref. dwgs. 3. Instruction and label plates Tightness of foam liquid tank NA NA NA NA Pronortioner oil level NA NA NA NA Were the following provided at foam outlet on D.C. deck? '' -- (a) 1 foam nozzle NA NA NA NA (b) 125' of 1-1/2 hose NA NA NA NA 7. Were the following provided at each hose outlet in the machinery space? (a) 50* length 1-1/2" hose NA (b) 50' length 3/4 hose NA (c) 1 twin agent nozzle NA Hydrostatic Test (a) 150 PSI held for 30 minutes for SW piping NA NA . NA NA (b) 330 PSI held for 30 minutes for nitrogen piping NA___ D-14 SIZE CODE IDLNT. NO. A 89219 NAVSEA DRAWING NO. REV. SCALE |SHEET ) ! i? It II i t \ US00006948 \ r* REPORT tc) 330 PSI held for 30 ninutee for PKP supply piping 9. Operational Teat performed _ 10. Was dry chemical nozzle opened to d e a r all dry chem ical from hose line and relieve ell pressure from tank? 11. Were green vent valve and blue valve closed at end of test on dry chemical extinguisher set? 12. Was black valve open at end of test on dry chemical extinguishing aet? 13. Was "Purple-K" which was used replaced? ; 14. Was foam pump i flushed and . drained? 15. Refractometer tests results X AFFF AFF/PKP AFFP/PKP AFFF/PKP AFFF/PKP STATION STATION STATION STATION STATION HA HA HA HA HA KA___ HA HA___ HA HA __ NA NA___ -HA airs u r v i n ma > D-15 SIZE CODE I0ENT. NO. 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006949 r*> REPORT 1. Workmanship f 2. Agreement with ref. dwgc. 3. Instruction and label plates 4. Tightness of foam liquid tank 5. Proportioncr oil level 6. Were the following provided at foam outlet on D.C. deck? (a) 1 foam no sic (b) 125* of l*s hose N 7. Were the following provided at each hose outlet in the machinery space? 1 (a) 50' length ! (b) 50' length 3/4 hose (c) 1 twin agent nozzle 8. Hydrostatic Test (a) 150 PSI held for 30 minutes for SW piping (b) 330 PSI held for 30 minutes for nitrogen piping AFFF AFFF/rKP AFFF/PKP AFFF/PKP AFFF/PKP STATION STATION STATION STATION STATION NA NA NA NA NA NA NA NA NA NA NA NA NA NA HA NA - NA NA NA NA NA NA NA NA < D-16 SIZE CODE IDENT. NO. A 89219. SCALE NAVSEA DRAWING NO. SHEET REV. US00006950  REPORT (c) 330 PSI held for 30 minutes for PKP supply piping 9. Operational Teat performed 10. Was dry chemical nozzle opened to clear all dry chemi cal from hose line and relieve all pressure from tank? 11. Were green vent valve and blue valve closed at end of test on dry chemical extinguisher set? 12. Was black valve open at end of test on dry chemical extinguishing set? 13. Was "Purple-K" which was used replaced? 14. Was foam pump flushed and drained 15. Refractometer test results AFFF APTF/PKP APFF/PKP AFFF/PKP AFFP/PKP STATION STATION STATION STATION STATION NA NA NA '- JA NA NA NA NA NA NA NA NA NA D-17 SIZE CODE IDENT. NO. A 89219 SCALE NAVSEA DRAWING NO. SHEET REV. US00006951 r*IND-NSYLB NTS/M (47)) TES T EQUIPM ENT CALIB RATIO N V ER IFIC A TIO N T A B LE THE TABLE BELOV IS TO BE FILLED IN BT THE SHOP REPRESENTATIVE TO SUBSTANTIATE THAT THE STATUS OF TEST EQUIPMENT UTILIZED M CONJUNCTION WITH THIS TEST MEMO IS PROPERLY CALIBRATED. IF TEST EQUIPMENT IS NOT OF REQUIRED CURRENT CALIBRATION. DISCONTINUE TEST UNTIL PROPERLY CALIBRATED EQUIPMENT IS AVAILABLE. TYPE OF EQ UIPM ENT m anufacturer LBNS SER. NO. 13330-1.3700 angstrom optical refractometcr, American Optical In strument Company No. 10420 or 0-3< 1 scale AOIC No. 10430 or equal. No. 10430 I s available from SPCC under FSN. No. 1H6650-600-6154. DATE C A L IE EXPIRATION Da t e R EPR ES EN TA TIV E s T ________________________________ D-18 MEET___________ OP US00006952 I II PWINST 11350.1 CH 2 Code 403 23 April 1975 HAZARDOUS WASTE DISPOSAL PROCEDURE NO. 10 DATE ISSUED: 11 APR 1975 i* HAZARDOUS MATERIAL COVERED: Aqueous Filin Forming Foam (AFFF) Wastes I FSN 4210-00-087-4742 . FSN 4210-00-087-4750 t SPECIAL HANDLING INSTRUCTIONS: Collect AFFF wastes in containers of suitable size to permit easy handling. Containers may be flushed and reused. . * I DISPOSAL INSTRUCTIONS: Discharge to the Yard sanitary sewerage system at I a controlled rate not to exceed 10 gallons of undiluted AFFF per hour. o I Prepared by: Lt. C. V. Cecil, CEC, USN, Code 403 i Concurrence : Cod. 730 3 <V ^ C X n ^ i ( I t D-19 i US00006953 LU TIO N LO TIO N PS-003A (Rev. 18 Sep 1975) ENVIRrROONTMIUKNEJC'ANPTVOTIOAARNTLL ERVICE NAVY ENVIRONMENTAL SUPPORT OFFiCF Naval Construction Battalion Center, Port Uuentinc, California 93043 DISPOSAL OF AQUEOUS FILMFORMING FOAM (A FFF) WASTES I PROBLEM AFFF products are fluorocarbon surfactants used for fire fighting. A F F F wastes from firefighting system tests and training exercises inu6t be disposed of in accordance with local and federal guidelines. More Details of the Problem; Naval industrial activities must test each shipboard AFFF firefighting system that has been installed, modified, or repaired to ensure that the minimum concentration of AFFF in the output mixture is 3.5% (the optimum is 6%). The foam is generated for one minute at flow rates of 95 to 250 gpm before the sample is taken to measure AFTF concentration. In-port and under certain circumstances at sea, the effluent cont.ining AFFF must be collected and clearly identified for other than direct disposal to the ocean. AFFF wastewaters containing petroleum are produced from training operations at firefighting schools. For additional guidance in handling these wastes, see Reference 2. II SOLUTIONS The acceptable procedures for 6hore disposal of AFFF wastes are summarized from References 2 and 3 as follovs: A. Discharge Wastes to Sewage Treatment P l a n t ; A F F F wastes free from oil can be discharged to free flowing sanitary sewers at con trolled rates. Safe discharge concentrations to a secondary sewage treat ment plant (STP) depend upon the specific AFFF used and the average flow rate of the plant. If the A F F F is identified, the safe discharge c o ncen tration listed in the table below can be used to determine the discharge rate. It is advisable to discharge at the recommended concentration or at a concentration which will allow acclimation until it is certain that the plant is adapted to this type of waste. Conditions in some localities might allow discharge up to or exceeding the maximum. 11ND.C8C.3900/15 (1 1-7N) D-20 1 I ! US00006954 ! If the AFFF concentrate in the waste cannot be Identified but is known to be on the AFFF specifications^ qualified products list, the lowest discharge U n i t should be assuned (10 yl/1 recommended to 100 pl/1 maximum). TABLE 1 ! COMPARISON OF CONCENTRATIONS OF AFFF IN SYNTHETIC SEWAGE AMENABLE TO BIOLOGICAL TREATMENT (Data from Table 8, Reference 4) Manufacturer's AFFF Concentrate Label Recotmended3 b Maximum to for Treatment Sewage Treatment Plant pl/1 (ppm) pl/1 (ppm) (gal per million gal of secondary STP flow) FC-199 FC-200 FC-206 Aer-O-Water 3 Aer-O-Water 6 K74-100 25 10 20 150 150 25 250 10 200 1700 1700 250 a Based on reactions to microorganisms, aquatic life, and safety factors ID Based on activated sludge pilot plant studies using a synthetic sewage i consisting of glucose (160 ng/i.), peptone (160 mg/fc), urea (28.6 mg/JL) , sodium bicarbonate (102 mg/1), potassium phosphate (32.5 mg/i), and tap water B. Discharge Wastes to Receiving Body of Water Wastes can be discharged to a stream containing aquatic life within the following limits: I i RECOMMENDED MAXIMUM CONCENTRATION OF AFFF FOR i DIRECT DISCHARGE TO STREAM (From Reference 4) f AFFF MAXIMUM CONCENTRATION CONCENTRATE vl/1 (ppm)_____ FC-199 FC-200 FC-206 Aer-O-Water 3 Aer-O-Water 6 K74-100 20 5 54 60 22 55 D-21 US00006955 C. Filter Waste Through Activated Carbon; AFFF products can be adsorbed on carbon . The efficiency depends upon the particular AFFF concentrate, e . g . , 100 percent removal of FC-200 and 70-75 percent removal of Aer-O-Water 6 within 5 minutes of contact time. The effluent may be suitable for discharge to a 6tream or it can be discharged into a sanitary sewer at an appropriate rate. Pending development of techniques for recovering the adsorbed chemicals, the used carbon can be disposed of in incinerators, mixed with coal for coal-burning furnaces, or disposed of in landfill sites which accept household wastes. ' P, The attached flow diagram, Figure 1, can be used to determine the options and restrictions of disposal methods, including disposal at sea. III RECOMMENDATIONS The preferred method for disposal of AFFF wastes is discharging to a biological sewage treatment plant under controlled conditions. IV BENEFITS Disposal by controlled rate of discharge to a biological treatment ^plant is a simple and safe procedure which can be accomplished at most taval activities. This method reduces the possibility of environmental damage and eliminates costs of storage and special handling. V CONTACT Additional details regarding these disposal methods may be obtained from NAVFAC, Code 0451E, or by contacting NESO, Code 2522, Autovon 360-5071. VI REFERENCES 1. Naval Message 191523Z Feb 75 COMNAVSF.ASYSCOM, Washington, D.C. 2. N A V F A C E N G C O M l e t t e r 1042/WEG of 13 May 1975, to: NCBC P o r t H u e n e m e , SubJ : A q u e o u s F i l m f o r m i n g Foam; r e v i s e d d i s p o s a l guidance. 3. Military Specifications, MIL-F-24385 (NAVY), 21 Nov 1969. 4. E. E. Lefebvre and R. C. Inman, "Biodegradability and Toxicity of Ansul K74-100, Aqueous Film Forming Foam," U.S.A.F. Environmental Health Laboratory, EHL (k) 75-3, Jan 1975. 5. R. K. Kroop and J. E. Martin, Treatability of Aqueous Filmr Forming Foams Used for Fire Fighting, Air Force Weapons Laboratory, Kirkland Air Force Base, AFWL-TR, 73-279, February, 1974. i i i D-22 US00006956 _ _ _ _ _ l_ _ _ _ _ Conducted 12 wiles or store from ahore direct disposal to ocean authorised by COKNAVSEASYSOm. Ua* standard pro* cedurea for iM jboard or ahora a*lntenance and atoraga. Consult local EFD. A. Control lad rate dtacharge to a sani tary aevage treatment plant. (Fara. IIA). g. Discharge waste directly to stream. (Fara. 111). C. Filter aolutlon through an activated charcoal column to rewove AFFF fro'? water beFore dis charge. (Para. IIC>. Bilge discharging to ocean *uat be deferred until the chip la out* aide the 50-mile Malt. .to Direct disposal to otean authorised by COKKAVShASYSCOH. FIGURE 1 Flow Diagram for Disposal of Waste From AFFF Firefighting Tests D-23 US00006957 \ \ i i i i ? j APPENDIX E . BIODEGRADABILITY AND TOXICITY OF FC-206 1. 3M Company letter to Mr. C. Alig, Subject: FC-206, dtd 25 June 1976 (3 pages) ; 2. NAVSEC letter to NAVSEA, 6159C/SD, 9360/ ^ 593.344, ETA 4088025, Ser 270, dtd 3 July 1974, enclosure (1), Bioassay Data (excerpt) (5 pages) 3. USAF Environmental Health Laboratory Report i EHL(K) 74-26, November 1974 (21 pages) l US00006958 \ 2 A ik i UM h-f.'tr 0 1 tfE R A L O F F I C E S * 3M C E N T E R 8 Al NT PA UL. M INNE 8 OTA 65101 * T E L . (6121 733-1110 U V I I O N K K M T A l CHQlNCEVINC ANO POLLUTION COMTNOL 3 COUPANT O.O. 8 0 1 39191 00 BUSH AVENUE SAINT PAUL. MINNESOTA BS I33 TEL. (317) 799 *099 June 25, 1976 ! Subject: FC-206 Mr. Craig Alig Naval Ship R 8 D Code 2863 Annapolis, MD 21402 P Dear Mr. Alig: This is in response to your request regarding the environmental effects of "LIGHT WATER" Brand Aqueous Film Forming Foam Concentrate FC-206. Hie 3M Company is conducting an ongoing program to evaluate and assess the environmental impact of its new and existing products. In accordance with this program, FC-206 has been subjected to a testing schedule designed to evaluate the product's overall environmental impact. Where possible, this product has been tested utilizing those existing methods and procedures which are outlined in "Standard Methods for the Examination of Water and Wastewater," 13th Edition, 1971. Due to the basic nature and function of FC-206, the wastewater discharge from its use in either an actual or simulated situation, is most likely to find its way to an aquatic ecosystem, usually being first conveyed to a wastewater treatment system. For this reason, the information presented in this letter will be directed toward the aquatic toxicity and biological treatability characteristics of FC-206. The freshwater aquatic toxicity studies which have been conducted on FC-206 have utilized a warm water and cold water fish (Pimephales promelas and Salmo gairdneri). The results of the studies on the concentrate as sold are as follows: Fathead minnow (Pimephales promelas) Rainbow trout (Salmo gairdneri) 96-Hr. LC50 3000 mg/1 Continuous Flow Test 1800 mg/1 Static Test m i N N E S O T A miN E-l Page 1 of 3 NG A ND M A N U F A C T U R I N G C 0 I D P A N Y US00006959 Mr. Craig Alig June 25, 1976 .ivertebrate aquatic toxicity studies have been conducted on FC-206. The species tested and their toxicity responses are as follows: Species 48-Hr. LC50 Water flea (Daphnia Magna) 5850 mg/1 Scud (Gammarus fasciatus) 5170 mg/1 Marine aquatic toxicity studies have been conducted on FC-206. The species tested and their toxicity responses are as follows: Species 96-Hr. LC50 Mummichog (Fundulus heteroclitus) Grass shrimp (Palaemonetes vulgaris) Fiddler crab (Uca pugilator) 1820 mg/1 Static Test 280 mg/1 Static Test 3260 mg/1 Static Test 48-Hr. LCS0 Atlantic oyster larvae (Crassostrea virginica) >100 <240 mg/1 .ie ability of an FC-206 wastewater discharge to be stabilized in a biological wastewater treatment system has been evaluated in accordance with parameters such as the biochemical and chemical oxygen uptake rate which are normally used in treatability studies. The biochemical and chemical oxygen demand test results are as follows: bod5 210,000 mg/1 BOD ult COD 420,000 mg/1 420,000 mg/1 The oxygen uptake tests by the dissolved oxygen probe method have shown that no microbial inhibition will occur at FC-206 concentrations less than 1000 mg/1. This concentration level has also been confirmed through tests which measure activity of microorganisms by the TTC* reduction in an activated sludge biological population. TTC (2 ,3 ,5-Triphenyltetrazolium Chloride) Re: "Dehydrogenase Enzyme as a Parameter of Activated Sludge Activities," Ford, et al. Proceedings of the 21st Industrial l/aste Conference, Purdue, May 3, 4, and 5, 1966. E-2 Page 2 of 3 US00006960 Mr. Craig Alig June 25, 1976 In addition, a conventional activated sludge pilot plant was successfully operated using a feed source which consisted of a mixture of settled domestic sewage and FC-206. At an FC-206 concentration of 1000 mg/1, the average reductions in COD and BOD levels were 73-i and 86', respectively. V/lien operating at an FC-206 level of 1000 mg/1, the average B0D5 concentration in the effluent from the pilot plant was 18 mg/1 . I In general, it is Advisable to treat FC-206 wastewater discharges in combination with either domestic or industrial wastewater in a biological or physiochemical wastewater treatment system. A combined raw wastewater discharge providing a maximum concentration of 1000 mg/1 FC-206 concentrate would permit satisfactory treatment. All statements, technical information and recommendations contained herein are of a general nature and are based on laboratory tests we believe to be reliable, but the accuracy, completeness or applicability to particular circumstances is not guaranteed. No express warranties are created herein, and implied warranties of merchantability and fitness for a particular purpose are disclaimed. A more complete evaluation of your specific situation should be based on the particular circumstances and factors involved, including consultation with the appropriate pollution control agencies. We hope this information will be of value to you. If we can be of further assistance, please contact Mr. D.L. Bacon on (612) 733-5453. RLB/mab Robert L. Bohon, Manager Environmental Laboratory E-3 US00006961 A BIOASSAY DATA EXCERPTED FROM ENCLOSURE (1), NAVSEC LETTER TO NAVSEA, 6159C/SD, 9630/593.344, ETA 4088025, SER 270, DATED 3 JULY 1974. FC-200 AFFF and FC-206 AFFF toxicities were determined by performing bioassays on seven representative saltwater organisms at the Naval Ship Research and Development Center, Annapolis Division. The seven saltwater organisms tested were carefully selected as representatives of the water column. Bioassays were also performed on two other commer cial alternative AFFF substances (Aerowater Number 3 and Aerowater Number 6 ), (manufactured by the National Foam Corporation) and on glycerine, a substance that was considered as a possible alternative to AFFF for use for pierside testing of foam station units. The organisms tested are listed in table 1. Because it is a representative marine fish species and can be raised in the laboratory, 2 to 3 inch length Killifish (Fundulus majalus) were used for testing. The two bottom organisms that were used were the common Atlantic Oyster (Crassostrea Virginia) and the Ribbed Bay Mussel (Modiolus modiolus)\ The barnacle used was the common white acorn species (Balanus eburneau). The brine shrimp (Artemia salina) Nested was the San Francisco Bay strain"] Although it is .iot found in brackish waters, its inclusion in a bioassay procedure has many advantages: (a) it is a standard bio assay organism used by many biology laboratories; (b) it is a reference organism used by EPA; (c) its life cycle, maintenance and culture conditions are very well documented; and (d) its response to a host of chemicals is known. Cyclotella nanna is a brown centric diatom, fully oceanic, but often found in brackish water. Pseudomonas nigrificans (American Type Cultural Collection No"] 193?5) is a marine bacteria belonging to that vast group of bacteria (Pseudomonas) which is found in almost all the salt waters of the world. Bacteria are the common denominator in water, so their in clusion in a b.i.oassay is absolutely necessary. These organ isms were selected and placed in test tanks or flasks. The desired amounts of the chemicals were added volumetrically, and at the end of 96 hours the LCcq (concentration of the chemical which is lethal to 50% of the test organisms) was recorded. (For brine shrimp, a 40 hour LCjq was determined.) Table 2 shows the actual number of organisms used for testing of each concentration of any one chemical. The LC5 0 for these chemicals are listed in table 3. Table 3 shows that the least toxic AFFF compound is FC-206, although glycerine is less toxic than FC-206. E-4 Il i Q c ! 1 ! 1 i t 1 US00006962 Table 1 BIOASSAY ORGANISMS Name Stage Habitat Killi Fish (Fundulus majalus) Fish Vertebrate Young Adult 2-3" long Estuarine Water Columns Bay Mussel (Modiolus modiolus) Mollusc Shelled Adult 1-2 " long - Brackish Bottom Brine Shrinp (Artemia salina) Bronchiopod Crustacean Adult Standard (2 weeks old) Bioassay Barnacle (Balanus eburneus) ' Cirriped Crustacean Adult Brackish 3/4-lV base Littoral Oyster (Crassostrea Virginia) Mollusc Shelled Adult 2" - 4" Brackish Bottom Diatom (Cyclotella nana) Algae 'Brown Green 1-2 x 10S cells/cc Oceanic Marine Bacteria (Pseudomonas Niqrificans) Bacteria 2 x 107 cells/cc Oceanic to Brackish E-5 US00006963 Table 2 NUMBER OF ORGANISMS AND CHEMICAL CONCENTRATIONS Organism Number of Organisms/ No. of Test Concentration Concentrations Killi Fish 6 ' (Control 9) X 3 Bay Mussel 6 (Control 9) X 3 Brine Shrimp 20 (Control & 9) X 3 Barnacle Oyster 10 (Control & 9) X 3 6 (Control 9) X 3 Algae . 2 test tubes each with 103 to 106 cells/cc (Control 9) X 3 Bacteria 2 test tubes each with 1 0 ' cells/cc (Control 9) X 3 Total No. of Organisms 180 180 600 300 180 60 tubes 60 tubes i I i ! iI E-6 US00006964 A Table 3 96 HOUR LC50 (40 hour LC50 for brine shrimp) Organism FC-200 AFFF (3M Company) 96 Hr. LC50 Fish Brine Shrimp Oyster Mussel Barnacle Algae Bacteria 76 ppm 80 ppm Greater than 60,000 ppm 26,530 ppm 283 ppm 110 ppm 1,000 ppm FC-206 AFFF (3M Company) Organism 96 Hr. LC50 Fish Brine Shrimp Oyster Mussel Barnacle Algae Bacteria Organism 2,679 ppm 1,187 ppm Greater than 60,000 ppm 10.000 ppm 10.000 ppm 1,560 ppm 10.000 ppm Glycerine 96 Hr. LC50 Fish Brine Shrimp Oyster Mussel Barnacle Algae Bacteria 51,870 ppm 17,275 ppm Greater than 60,000 ppm 35,660 ppm 45,000 ppm 33,500 ppm Greater than 100,000 ppm E-7 US00006965 A ,9 Organism Fish Brine Shrimp Oyster Mussel Barnacle Algae Bacteria Organism Fish Brine Shrimp Oyster Mussel Barnacle gae Bacteria National Foam Aerowater Number 3 (National Foam Corporation) 96 Hr. TC 50 850 ppm 727 ppm Greater than 60,000 ppm 150 ppm 155 ppm , 574 ppm 20,000 ppm National Foam Aerowater Number 6 (National Foam Corporation) 96 Hr. TC 50 900 ppm 8,567 ppm 35.000 ppm 80 ppm 427 ppm 980 ppm 20.000 ppm . E-8 ) i US00006966 USAF ENVIRONMENTAL HEALTH LABORATORY (AFLC) UNITED STATES AIR FORCE KELLY AFB, TEXAS 78241 BIODEGRADABILITY AND TOXICITY OF LIGHT WATER FC206, AQUEOUS FILM FORMING FOAM November 1974 . EHL(K) 74-26 EDWARD E. LeFEBVRE, Maj, USAF, BSC Consultant, Environmental Chemistry Reviewed By: QUUUllYYV/iLL^t*r ALBERT M. ELLIOTT, Lt Col, USAF, BSC C hief, Special Projects Division Approved By: ROGER C. INMAN, Maj, USAF, VC Veterinary Ecologist/Toxi cologi st Commander C ol, USAF, MC FOR OFFICIAL USE ONLY E-9 US00006967 NOTICE This subject report is released by the A ir Force fo r the purpose of aiding future study and research. Release of th is m aterial 1s not intended fo r promotional or advertising purposes and should in no way be construed as an endorsement of any product. The views expressed herein are those of the author/evaluator and do not n ece ssarily r e fle c t the views of the United States A ir Force or the Department of Defense. 1 FOR OFFICIAL USE ONLY E-10 ! i US00006968 TABLE OF CONTENTS I . SUMMARY...................................................................................................................... I I . INTRODUCTION............................................................................................................. I I I . DISCUSSION................................................................................................................. A. Composition................................................................................................... B. Respiration Studies............................................................................... C. P ilo t Plant Studies............................................................................... D. T o x ic ity Studies....................................................................................... E. Comparison with AFFF's previously studied........................... IV . CONCLUSIONS................................................................................... V. RECOMMENDATIONS...........................*......................................................................... V I. REFERENCES................................................................. ............................................. Appendix Particip an ts in Study.................................................................................... Figures 1. Biological Oxygen Demand as a Fuction of Time of FC206 by USAF Environmental Health Laboratory, K e lly AFB TX, 1974............................................. 2. Oxygen Uptake of Varying Concentrations of FC205 using the Warburg Respirometer............................................................... 3. Quantal Response curves of fis h exposedto FC206.......................... 4 . Changes in LC50 values with time ofexposure................................ Tables 1. Composition of FC206....................................................................................... 2. Summary of Data from Measurement of Extended BOD of FC206 at 25C with theE/BOD Respirometer..................................... 3. Composition of Synthetic Sewage Used in B io d eg rab ility S t u d ie s ...................................................................................................................... csj cm <*r r* c\j Pago 1 2 2 1 13 74 75 A-l 3 5 10 11 2 4 4 11 E- 1 1 US00006969 TABLE OF CONTENTS Tables 4 . Summary of Analysis of Samples from Activated Sludge P ilo t Plant No. 1 Receiving FC206 and Synthetic Sewage........................................................................................................................ 5. Summary of Analysis of Samples from Activated Sludge . P ilo t Plant No. 2 Receiving FC206 and Synthetics Sewage........................................................................................................................ 6 . Daily Measurement of MLSS in Plant No. 1 from 30th to 51st Days.......................................................................................................... 7. Comparison of VariousParameters of A FFF's..................................... 8 . Changes in T o x ic ity of AFFF's to Fathead Minnows with increase in time ofexposure.................................................................... Page 6 6 7 12 12 \ ! I , I hi E-12 I 1 US00006970 t I. SUMMARY ** J : 1^ * Water , FC206, is an aqueous film forming foam (AFFF) used for fire fig treated ht in ing. Biode controlled gradability stu concentrations dies up tosho2w00 thual/t1 i t in can be synth bio etic lo g ic a lly sewage on a continuous b a sis. Higher concentration appear amenable to treatment in oxidation ponds over long time periods. T o x ic ity studies with fathead minnow ju v e n ile and 170 s and fry indicate uIl*/)1? 96-hour LCcq respectively. that FC206 is less to xic than AFFF's fo r fathead minnow ju ve n ile s and fry Using a 0.05 application fa c to r, a pre were viously 1080 u l/1 concentration unit of 54 ul/1 is recommended fo r discharge to any waters containing aquatic 11T6 E-13 US00006971 II. INTRODUCTION This Is the fourth report on the biodegradability and to x ic it y o f a commercial aqueous film forming foam used to fig h t f ir e s by the A ir Force. The re su lts of studies of Light Water (FC206) a product of Minnesota Mining and Manufacturing C o ., St Paul, Minn, are presented here. The FC206 is used to make a s ix percent solution fo r the f ir e fig h tin g operations. This study was conducted at the request of Hq USAF/SGPA and Hq USAF/PREE. I I I . DISCUSSION A. Composition Results of an alysis at th is laboratory are shown in Table 1. The s p e c ific g ravity of the concentrate is 1.020 with a pH of 7 .8 . PARAMETER Table 1. Composition of FC206. Water Diethylene Glycol Monobutyl Ether Flurocarbon (Structure not Determined) Sodium Sulfate Chemical Oxygen Demand Total Organic Carbon Surfactants (MBAS as LAS) Fluorine QUANTITY ` 70% ` ` * 2721%%% 500,000 mg/1 95.000 41.000 mmgg//11 14.000 mg/1 B. Respiration Studies 1. Biochemical Oxygen Demand The need fo r measurement of biochemical oxygen demand (BOD) over incubation periods in excess of the standard fiv e days has been pointed out by several investigato rs and reported previously (5 ). A d d itio n a lly, incubation at 25C rather than the standard 20C allows determination of the Ultimate BOD in a shorter time period without adverse a ffe c ts on the micro organism composition although temperatures in excess of 30C would a lte r composition (2 ). Figure 1 is a curve showing the BOD over a 20-dav period as measured with the E/BOD Respirometer as previously reported (1 2 ). Table 2 is a summary of these E/BOD measurements. E-14 4 ` DAYS Figure 1. B iolo gical Oxygen Demand as a Function of Time o f ' FC 206 by USAF Environmental Health Lab o rato ry, K e lly AFB TX, 1974. . r K E-15 US00006973 Table 2. Summary of Data From Measurement of ^ Extended BOD of FC206 at 25C with the E/BOD Respirometcr E/BOD5 EF//BB0ODD1!5o e / bod20 mg/1 . 1 V 32..9658XX110055 ' 4.10X105 4.11X105 EP/eBrOcDe2n0t of 65.2 96.1 9$.7 2. Warburg Respirometer Studies Figure 2 shows the variatio n in oxygen uptake with respect to concentration of the FC206. Acclimation of the microorganisms can be seen by the increase in oxygen uptake rates at the higher concentrations with to a respect to time. Since the d ilu tio n s ix percent so lu tio n , oxygen up take of was FC206 from normal usage not measured beyond the i s10 percent solution. _ C. P ilo t Plant Studies . - - 1. Two bench-scale activated sludge p ilo t plants were fed in creasing concentrations of FC206 in synthetic sewage of composition shown in Table 3. The plants began to show solids loss at an FC206 concentration of 200 to 225 u l/1 . Most of the solids loss appeared to be physical in nature from the foaming action forcing the solids over the side of the reac plan to t. r. TaTbaleble6s 4 and 5 are summaries o shows the recovery of so f the lids measured in the f i r parameters fo r s t plant when each the FC206 concentration was lowered from 500 ul/1 to 200 u l/1 . Table 3. Composition of Synthetic Sewage Used in Biodegradability Studies Glucose Peptone UNkhare2aHCPOO43 Tap Water 160 160 10228.6 32.5 mmmmgggg////1111 mg/1 \ E-16 US00006974 Figure 2. Oxygen Uptake o f Varying Concentrations of FC 206 Using the Warburg Respirometer E-17 US00006975 2. Five Fathead minnows ( Plmephales promelas) were placed 1n ^-e,ach container receiving e fflu e n t from each of the plants at the beginning f the study. One fis h succumbed in the f i r s t plant e fflu e n t a fte r 27 days and one in the second plant e fflu e n t a fte r 43 days in d icatin g that the e fflu en ts were r e la t iv e ly non-toxic. Five giant water fle a s ( Daphnia magna) were placed 1n each e fflu e n t container on the 36th day and survived to the termination of the study (51 days). . No. of Days 5 3 5 3 B 5 141 3 Table 4. Summary of Analysis of Samples From Activated Sludge P ilo t Plant No. 1 Receiving FC206 and Synthetic Sewage. u l/1 FC206 50 21070050 300 400 500 230000 mg/1 Avg. MLSS 3045 3315 3363 3587 3016 2685 11700630 1513 pH Range 7.2-7.3 7.1-7.2 7.2-7.3 7.1-7.2 7.2-7.4 7 7 ..34--77..48 7.7 7.7-8.1 D.O. Rmagn/1ge 4.0-6.2 4.2-4.4 4 4 .C .0 - 55..66 45..08--66..02 665...600 -- 7.4 7.2 BPOeDrc5eRnetmoval Percent TOD Removal 97.8 No Data 98.9 98.8 92.1 97.6 94.8 17.7 85.7 >95.8 >95.4 >95.6 >99 >99 91.5 54.5 >99 No Data No. of Days 85 83 225 Table 5. Summary of Analysis of Samples from Activated Sludge P ilo t Plant No. 2 Receiving FC206 and Synthetic Sewage. u l/1 FC206 50 75 125 225 250 300 mg/1 Avg. MLSS 2397 2648 2863 3052 2985 2414 pH Range 7.2-7.5 7.2-7.3 7.3-7.3 7.2-7.4 7.0-7.2 7.1-7.4 D.O. Rmagn/1ge 2 4 4 ...860---655...086 4.6-5.4 4.6-6.0 4.4-7.0 BPOeDrc5eRnetmoval Percent TOD Removal 98.0 98.8 98.7 98.3 98.2 96.5 >96.1 >95.4 >99 >99 >97.9 >98.2 E-18 US00006976 I { Table 6. D ally Measurement of MLSS in Plant No. 1 From 30th to 51st Days. Day ul/1 FC206 mg/1 MLSS 30 500 2810 31 500 2650 32 500 2820 36 38 39 43 44 45 46 51 500 . 500 500 500 322200000000 1111081100400200000 1280 1460 1800 D. T o x ic ity Studies 1. METHODS AND MATERIALS a . Experimental Animals T o x ic ity studies used the fathead minnow ( Pimephales promelas) to determine the re la tiv e to x ic it y of FC206 solutions -- (Con centrate and p ilo t plant e fflu e n ts ). Sexually-immature fathead minnows were supplied by the National Fish Hatchery at Uvalde, Texas. The fis h were acclim atized to the laboratory conditions and local water fo r a minimum of 30 days before use. Mean fis h weight was 0.913 gm (c = 0.370). The fis h were fed a commercial fis h food*. Immature fathead minnow fry wusaesd21in stat days. ic bioassays were reared at EHL/K. Age of f r y at time of use ' b. Exposure Procedure ting equipment (1) Continual flow as developed by Mount type bioassays and Brungs (7) u( 8se)d. proportional d ilu These d ilu te rs supplied logarithmic scaled d ilu tio n s of the compound being tested to a flow through chamber fo r each concentration in which the experimental animals were held. Studies with fr y were s t a t ic bioassays with three fr y per each one- lit e r te st concentration. Tetramin, D is trib u to r, Tetra Sales Corp. Heyward, CA 94545. E-19 US00006977 (2) Bioassays were performed 1n accordance with princip les '"'^described 1n Standard Methods (12) and Sprague (9 ). Test animals were not fasted p rio r to te stin g . They were not fed during the actual assay period. Ten fis h were used for each concentration and the contro l. Exposure chambers were p la s tic ra t cages modified to contain 4 lit e r s of diluted to xican t. (3) Response of the te st animals v/as recorded throughout a 96-hour te st period. Probit an alysis was performed on the data recorded at 24, 48, 72 and 96 hours of exposure to evaluate quanta! response to graded doses. A fter the f i r s t bioassay, a true 96 hour rep licate was performed using the same procedures and concentrations as used in the f i r s t run. In a ll these bioassays the te s t animals were placed into the exposure chambers in a random order by using a table of random numbers. The chambers themselves were positioned in random order. The control chamber contained water from the same water tank as the water that was used as the diluent in the other te st chambers. The flow of of 2 hours. diluted This is toxica equal nt to inato6 the chamber was adjusted to a retention time hour, 95% replacement time and insures ade quate maintenance of the dissolved oxygen concentration. The quanta! response measured was death. A fis h was counted as dead when a ll g ill movement ceased. Dissolved oxygen and pH were monitored to insure that the cause of death was not lack of oxygen or changes in pH. c . D ilution Water Unchlorinated well water from a deep well was used as the d ilu tio n water in these stu d ies. The water was collected in 400 gallon i^ fib e rg la s tra ile r-ta n k s at an on-base well s it e . The water t r a ile r s were hauled to the Laboratory and allowed to s i t at le ast 24 hours before the water was used. A ir was bubbled through the water. The water was adjusted by heating The (as CpHaCw03as) or cooling to 7.2 was 1H60armdnge/1ss. 24C before i t (EDTA as mg/1 CwaCa0s 3r)unwasin t1o94t. heT optraolp oarltkioanl ai nl i d il ty u t e r . d. Treatment use of Data method as the o(Cf HLIi)t2c h f LC5QS* or TL50S were ie ld and Wilcoxon. ( 6d) eteOrtmhienreds te st fo r "Goodness of P it" were by t by the probit analysis a t is t ic a l treatments such standard formulas. (3) To be used in th is report and the previous reports on Fire-Fighting foam chem icals, to x ic ity study re su lts had to f u l f i l l two important c r it e r ia . 1) of Graded s e ria l quanted responses d ilu tio n s in each had tes t to d e fin i chamber. t iv2e) ly re the late resu to lts the logarithms had to bere p li- I ' 1 j *LCo or Lethal Concentration 50%, is a concentration value s t a t is t ic a lly derived from organisms to athetoexsictaabnltis. hmTheentLCo5fQaredporsees-ernetlastetdhe response of best estim experimental ation of the dose required to produce death in 50% of the organisms. Note that a more to xic chemical has a sm aller LCcq. The time period fo r which the 50% response was derived must also Be indicated. s, E-20 . US00006978 cable. The establishment of dose-effect and tim e-effect relatio n sh ip s allowed s c ie n t if ic a lly based predictions of the ecological e ffe c ts of the tested ' chemicals on a body of water during use, accidental sp illa g e or dispo sal. Also the re la tiv e to x ic ity of one m aterial could be compared with another; perhaps with the goal of selecting one that would have the le a s t e ffe c t on aquatic minimal biota. effect F in a lly , the concentrations r e1nsubltosdiecos uoldf be used to water that set may "allowable" or receive these m aterials as waste. 2. Results of T o xicity Studies a. The sexually immature minnows were exposed to concentrations o f FC206 ranging from 800 ul/1 to 2500 ul/1 (see Figure 3 ). At 48, 72 and 96 hours of exposure there was 100 percent death at the 2500 ul/1 concentra tion and no deaths at the 800 ul/1 concentration. At 24 hours of exposure there were no deaths in the 1050 ul/1 concentration and 75 percent deaths In the 2500 ul/1 concentration.. ' b. Figure 4 Illu s t r a t e s the change in LCg with increasing time oLCf5eQxSp)o, stuhreer.e As is the percent a reduction of in deaths increase with time of exposure the slope of the curve between 72 and (lower 96 hours. The reduction in the slope indicates that the 96 hour value may be approaching the in cip ie for the FC206, in c ip ie the nt LC9650haonudr n1Xt 59LCgisg (leth al threshold concentration). Therefo considered to be an adaauate estimation of can be used to set acceptable concentration lim its re , o f FC206 fo r short periods of time. value that fo the r c. fr y compared with FC206 concentrate istheaThpe1p0r89o06ximuhola/u1ter lyvLCa6l5u0etifmofoersr 3 week old f r y the ju ve n ile more to xic to f was ish the 170 u l/1 . indicates fry than more mature forms. Thus that the lim its of safety exposure would provide ju sthutesaindingecqraueaa1tse/e1d0prasopetepnclsticiiotaintviiotanyndfoatfhctaimot rmaafto1ur/r2e0shfovoramrltuseteirnvm/doiucladt e s be more d esirab le. The E-21 US00006979 Fiqure 3 ) QUANTAL RESPONSE CURVlj* OF FISK EXPOSED TO FC 206 I US00006980 / Concentration in yl/1 E-23 US00006981 I E. Comparison with AFFF's Previously Studies 1. Table 7 1s a summary of the various parameters measured fo r each o f the ArrF products studied thus f a r . (4 ,5 ,1 3 ). The greater percentage of the ultimate BOD being measured in the f i r s t fiv e days on the newer products indicates a more rapid degree of biodegradability. Table 7. Comparison of Various Parameters of AFFF's PARAMETER 3M - LIGHT WATER FC199 FC200 FC206 NAT'L FOAM SYSTEMS AOW 3 AOW 6 pH Specific Gravity Water Diethylene Glycol Monobutyl Ether COD (X103) TOC (X103) BBO0DD5u (X10$) (% B0Du) 41..602 550 mg/1 18 mg/1 37 7.6 0.989 59% 39% 730 mg/1 235 mg/1 4502 mg/1 71..0820 70% 27% 500 mg/1 96 mg/1 411 mg/1 65 7.8 1.062 72% 10% 500 130 mmgg//11 354 mg/1 45 7.-9 1.031 72% 10% 315000 mmgg//11 300 mg/1 45 ^ 2. Table 8 summarizes the d a ily changes in LCso's during 96-hour bioassays fo r each of the AFFF concentrates previously studied. Table 8. Changes in T o x ic ity of AFFF's to Fathead Minnows with increase in time of exposure. LC50 (Concentrations in yl/1 ) 24-Hour 48-Hour 72-Hour 96-Hour 3M - LIGHT WATER FC199 650 588 450 398 FC200 * 135 97 97 FC120_6 _ 2*100 1810 1300 1080 NAT'L FOAM SYSTEMS AOW 3 AOW 6 1030 820 630 600 635 255 245 225 *No m ortality concentration (150 in yl / 214) hours in one in duplicate bioassay but bioassay. 505 in highest E-24 t IV. CONCLUSIONS A. No acute to x ic it y to activated sludge microorganlms was exhibited by FC206 up to 100,000 ul/1 of the concentrate in synthetic sewage/activated sludge. (60,000 uDl/i1lu) t. ion of the concentrate for fire fighting operations 1s six percent to B. Respiration concentrations up stotud10ie0s,00in0duicla/1te that could acclim ation of microorganisms occur and would allow successful waste treatment in oxidation ponds. C. Bench scale - activated sludge treatment plants e ffe c tiv e ly treated concentrations of 200 ul/1 on a continuous feed b a sis. Above th is concentra tio n s , sludge microorganisms were not able to build ra p id ly . This was probably due p rim arily to the physical removal of so lid s through foaming rather than d ire c t to x ic ity to the microorganisms. Fathead minnows and daphnia live d in e fflu e n t from the plant being fed 500 u l/1 . D. In acute to x ic ity studies in which the te s t fis h (Pimaphales promelas) were exposed to continously replenished concentrations of F'C205, the 95 hour LCgn was 1080 ul/1 (0.11%). The 96 hour value was considered to be an adequate estimation of the in cip ie n t LC5Q (le th a l threshold concen tra tio n ) and su itab le fo r use with application facto rs to predict "safe le v e ls " fo r short-term exposure periods. E. In comparing t o x ic it ie s , FC206 concentrate was approximately s ix times more to xic to fr y than the larger ju ve n ile Fathead minnows. A lso, FC206 con centrate was le ss to xic to Fathead minnows than previously tested f ir e fig htin g foams. E-25 US00006983 V. RECOMMENDATIONS A. Wastewater from fire -fig h tin g train in g operations should be passed through a g ravity o il separator. The v.'aste sho^d then be held in a pond fo r natural oxidation and decomposition or pumped to a secondary sewage treatment f a c ilit y at a controlled flow ra te . Secondary treatment could be provided with the domestic sewage such that the in flu en t to the sewage treatment plant w ill not contain in excess of 20 ul/1 of the FC206. This recommendation is based on train in g exercises and .1s not n ecessarily intended fo r operational use. B. Using the 96 hour LC50 of 1080 ul/1 and an application facto r of 0.05, the calculated "safe le v e l" of FC206 concentrate is 54 ul/1 fo r short term exposure. For situ atio n s 1n which the aquatic animals w ill be exposed more than 4 days, concentration of FC206 should not exceed 20 ul/1 in the affected body of water. E-26 1 i 1 i i 1) US00006984 VI. REFERENCES 1 . C airn s, 0 . , J r . , "Fish Bioassays - R ep rod ucib ility and Rating", Rev is ta de B io lo g ia, Vol 7, No. 21 & 2 , (1969), pp 1-12. 2 . Caskey, W illiam , Personal Communication, Dept o f Microbiology, Texas A & M U n ive rsity, College S tatio n , TX. 3. Dixon, W .J ., F. J . Massey, Introduction to S t a t is t ic a l A n a ly sis, 3rd e d ., McGraw-Hill, New York, 1969. - 4. LeFebvre, E .E . 1971. "Biodegradability and T o x ic ity of Light Water ." Report Ho. EHL(K) 71-36. USAF Environmental Health Laboratory, K e lly AFB, Tx. 5. LeFebvre, E .E . and J .F . T o x ic ity of AER-O-Water T3h-oamndasA. ER19-O73-W. a"tBerio6d egradab Aqueous ility Film and Forming Foam". Report No. EHL(K) 73-22. USAF Environmental Health Laboratory, K elly AFB, Tx. .6 L it c h fie ld , J . T. and F. Wilcoxon, "A Sim p lified Method of Evaluating Dose E ffe c t Experiments", J . Pharmacology & Experimental Therapeutics, Vol 96, (1949), pp 99-113. 7. Mount, D. I . and W. A. Brungs, "A Device fo r Continuous Treatment of Fish in Holding Chambers", Transactions of the American Fish erie s S o cie ty, Vol 96, No. 1, 20 Jan 1967, pp 55-57. .8 Mount, D .I. and W.A. Brungs, "A Sim plified Dosing Apparatus for Fish Toxicology Stu d ies", Water Res, (1967), Vol 1, pp 21-29. 9. Sprague, J . B ., "Bioassay Methods fo r Acute T o x ic ity " , Water Res. Vol. 3 , (1969), pp 793-821. .10 Sprague, J . B ., " U tiliz in g and Applying Bioassay R e su lts", Water Research, Vol. 4 (1970), pp 3-31. .11 Sprague, J . B ., "Sublethal E ffe cts and "SAFE" Concentrations Water Research, Vol. 5 (1971), pp 245-266. # .12 Standard Methods fo r the Examination of Water and Waste Water, 13 e d ., American Public Health Assoc. ," New York, (1971). 13. Thomas, J . F . and E. E . LeFebvre. 1974 "Biodegradability and T o x ic ity of FC200 Aqueous Film Forming Foam". Report No. EHL(K) 74-3, USAF Environmental Health Laboratory, K e lly AFB, Tx. E-27 US00006985 APPENDIX I Particip an ts in Study E-28 US00006986 PARTICIPANTS Biodegradability and T o x ic ity o f Light Water, FC206 Aqueous Film Forming Foam Biodegradability Studies: Project O ffic e r: Maj Edward E. LeFebvre Consultant, Environmental Chemistry lL t Thomas Doane, Consultant, Environmental Chemistry TSgt Samuel A. B r i t t , Laboratory Techician Mr. G ilb e rt Valdez, Physical Sciences Aide A1C Gregory K n e rl, Laboratory Techician Bioassays: ' Maj. Roger Inman, Veterniary Ecologist Toxicolo g ist MSgt Melvin Stru ck, Laboratory Animal Techician TSgt Jerold Akey, Laboratory Animal Techician ' i ! 1 : i i It FOR OFFICIAL USE ONLY. E-29 US00006987 \ i j , j I i l / APPENDIX F SMALL SCALE AFFF/DYE DISPERSION TEST i i US00006988 1. A small scale test was conducted in Dungan Basin at the David W. Taylor Naval Ship Research and Development Center, Annapolis Laboratory, on 3 September 1975. Released into the basin was a mixture of 1.2 gal (4.5 i) of AFFF (3M Co. FC-206) and 18.8 gal (71.2 l) of water drawn from the basin. The AFFF/water mixture was dyed to a concentration of 100 ppm (by weight) with rhodamine WT dye. The mixture was poured overboard at 1412 hours from a small boat in the center of the basin. Samples were pumped into collection bottles from depths of one foot (called surface samples, S), six feet, and nine feet from areas within the visible dye patch visually estimated to be those of highest dye concentration. Samples were analyzed for dye concentration, TC, and COD. Results of analyses are contained in table F-l. It was assumed that the increase in TC above background levels was due to the presence of AFFF. 2. Rhodamine dye concentration and TC data for samples col lected at the one foot (0.3 m) depth are plotted in figure F-l. The relationship between dye and TC demonstrates that dye can be used to simulate the dispersion of AFFF. Although the rate of change in AFFF and dye was different, the dilution factors remained the same. Therefore, dilution data from an in situ dye dispersion study can be used to develop dilution factors applicable for predicting the decrease in AFFF con centration after release of a known quantity of AFFF under similar conditions in the study area. F-l US00006989 Table F-l Results of Laboratory Analyses of Water Samples from Dungan Basin Before and Depth Time (ft) (m) Bkgd Bkgd Bkgd Bkgd TSTT 1 0.3 1 0.3 6 1.0 6 1.8 17413" 1 Til 5" 6 "T3TT 1 TiI7' 6 W1 1419 6 1420 1 1420 1 6 1422 1 1422 . G 1423 - 1 1423 6 1424 1 14~24" 6 ' 1425 1 1425 1425 6 O 1427 1 1427 6 1427 9 1430 1 1430 6 1430! 9 " 0.3 1.8 0.3 1.8 0.3 1.8 0.3 1 .n 0 .3 1.8 0.3 1 .8 0.3 1.8 0.3 1.8 2.7 0.3 1.8 2.7 0.3 1.8 2.7 Dye Concentration TC COD "TppF5 ' (mg/i.) (mg/) <2 <2 <2 <2 Release dye, 1 . 0 x 1 0 s ppb 8.9 BT3 40.6 " 49.5 2377 <2 21.8 <2 17.8 <2 10.9 <2 8.5 <2 3.7 <2 <2 11.9 <2 <2 2.1 <2 <2 15.6 128 13.8 125 14.8 " '6 8 ' 13.6 70 2.6 x 10- 1375 1377 2373" 3172 2T7B 14.6 23.8 14.8 22.4 14.8 19.4 14.1 - 18.2 15.3 16.6 14.1 14.1 19.2 14.6 14.1 17.3 13.6 14.8 96 ' 80 150 m 133 84 184 104 100 80 68 148 76 64 88 132 152 100 68 188 64 48 96 " J I I J US00006990 ) FIGURE F- I ) I US00006991 APPENDIX G ( ! TENTATIVE ALLOCATION PLANS AND CONSTRUCTION SCHEDULES FOR SHIP CHT SYSTEMS, SWOBS, AND PIFP. SEWERS (l I! US00006992 TABLE G-l ACTIVITIES WHICH HAVE/PLAN TO HAVE PIERSIDE FACILITIES FOR SHIP-TO-SHORE SEWAGE TRANSFER TOGETHER WITH FACILITY DESCRIPTION AND STATUS* 15 October 1976 PCR LOCATION MCON NO. NO. DESCRIPTION STATUS NORFOLK COMPLEX NAVSTA P-807 W289D PIERS 7,12,20,21,22,23 CONST.COMPL. FACILITY OPERATING PIER 24 UNDER CONST. UNTIL 6/78 PIER 25 UNDER CONST. UNTIL 7/77 NAB LITTLE CREEK P-206 W131J PIERS 56,57,58,59 CONST.COMPL. FACILITY OPERATING NAVSTA P-911 W289E PIERS 2,3,4,5,10 UNDER CONST. UNTIL 1/77 NSY PORTSMOUTH P-177 W164G WHARFS 1-12,15,23-27,29-33 UNDER CONST. UNTIL 4/77 35,36,38,39,41-45 NAB LITTLE CREEK P-207 W131K PIERS 1-8,11-15,16-19 UNDER CONST. UNTIL 3/77 NSY PORTSMOUTH P-999 W164A PIER C UNDER CONST. UNTIL 4/77 SAN DIEGO COMPLEX NAVSTA NSSF P-176 P-036 NAS NORIA P-313 NAVSTA P-179 NSC NUC NAB CORONADO P-191 P-198 P-022 P-023 P-059 P-057 P-093 W027D W304A W018L PIER 4 PIERS 5000,5002, DEPERMING PIER WHARFS I ,J,K W027F PIERS 5,6,8 W032j -- W209K W209j W028D W028C W220C SMALL CRAFT BASIN MOLE PIER PIERS 1,2,3 PIER 9 PIER 10 PIERS 11,12,13 BROADWAY PIER FUEL PIER PT.LOMA PIERS 1,2 PT. LOMA SAN CLEMENTE ISLAND PIERS 3,8,13 . CONST.COMPL. FACILITY OPERATING CONST.COMPL. FACILITY OPERATING CONST.COMPL.(MUNICIPAL CONN. COMPL.) Lift Station Pump Prob. UNDER CONST. UNTIL 5/77? PIER 5 CONST.COMPL. CONST.COMPL. CONST.COMPL. UNDER CONST. UNTIL 1/78 PLANNED EST.COMPLETION 12/78 PLANNED EST.COMPLETION 12/79 PLANNED EST.COMPLETION 12/80 UNDER CONST. UNTIL 12/76 UNDER CONST. UNTIL 12/77 PLANNED EST. COMPLETION 6/78 PLANNED EST. COMPITION 7/79 UNDER CONST. UNTIL 12/77 *NCBC letter to CNO, 25A1:WLRrhla, Control No. 610-23, Seria 5054 of 16 November 1976, enclosure (1). US00006993 } __________________________________________ TABLE ^ 1 (cont.)_____________________________ PCR ______LOCATION______ MCON NO. NO.____________ DESCRIPTION________________________STATUS CHARLESTON NSC P-903 W305A PIER A UNDER CONST. UNTIL 6/77 NSY NAVSTA NWS P-901 PIERS C,D,F,G,H,J,K,L,M PIERS N,P,Q,R,S,T,U W119H WHARF A, PIERS B,C, UNDER CONST. UNTIL 6/77 UNDER CONST. UNTIL 6/77 UNDER CONST. UNTIL 11/76 MAYPORT NAVSTA P-964 W049K WHARFS B,C,D,A CONST..COMPL. FACILITY OPERATING PEARL HARBOR COMPLEX NSB P-119 W057G PIERS Sl-S5,S8,S9 NAVSTA NSY NAVSTA NSC 0 K1J NSB NAVSTA NSC NAVSTA NAVMAG P-991 P-991A P-179 P-179A P-179B W165G W165H W165I W165J W165J PIERS B1-B26, B1-B21,GDl-GD5, 02, MR NO. 2 PIERS M1-M4, H1-H4, S10-S14,S20,S21 A1-A7,S15-S19,F1-F5 V1-V4,K3-K11 F12,F13 W1-W5 SAN FRANCISCC NAS A L A M E D A NWS CONCORD NSY VALLEJO NSC OAKLAND P-100 P-133 P-153 P-203 P-002,3,4 W007M W007N W008F W031F W019F PIER 3 PIERS 1,2 PIER 2 WHARFS 2-20,24 PIERS 21-23 CONST..COMPL. (awaiting sewage transfer hose) UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 2/77 UNDER CONST. UNTIL 10/77 UNDER CONST. UNTIL 10/77 UNDER DESIGN , EST.COMPL. 7/78 UNDER DESIGN , EST.COMPL. 3/79 CONST.COMPL. FACILITY OPERATING CONST.COMPL. FACILITY OPERATING PLANNED, EST.COMPLETION 6/80 PLANNED, EST.COMPLETION 5/78 PLANNED, EST.COMPLETION 5/78 PLANNED, EST.COMPLETION 12/79 PUGET SOUND NTS KEYPORT NSY BREMERTON NSC BREMERTON P-190 P-166 P-038 W146 j WHARF W144K PIERS 3-8 W147N FUEL PIER UNDER CONST. UNTIL 1/77 PLANNED, EST. COMPLETION 1/80 PLANNED, EST. COMPLETION 5/77 1 US00006994 ) )) LOCATION LONG BEACH NAVSTA NSY NAVSTA NWS SEAL BEACH GROTON/NEW LONDON NSB NEW LONDON NUSC PENSACOLA NAS WASHINGTON D.C. NAVSTA PORTSMOUTH N.H. NSY ADAK NAVSTA EARLE NWS NEW ORLEANS NSA PANAMA CITY NSCL MCON NO. P-131 P-172 P-133 P-096 P-157 P-116 P-999 P-194 ------ P-834 P-771 P-047 P-999 TABLE G-l (cont.) PCR NO. DESCRIPTION W014F W015I W014G WO 35C PIERS 9,11,15 PIERS 1,2,3,6,E PIER 7 WHARF STATUS CONST.COMPL. CONST.COMPL. UNDER CONST. UNTIL 1/77 PLANNED, EST. COMPLETION 7/78 W040D PIERS 1-4,6,8-10,12,13,15,17,31 CONST.COMPL.(awaiting sewage transfer hose) W332A PIER 7 PLANNED EST. COMPLETION 9/79 W051K PIERS 302,302 CONST.COMPL.(awaiting sewage transfer hose) W042 j PIERS 1,4 CONST.COMPL. FACILITY OPERATING -- " - PIERS 1,2,3 CONST.COMPL. FACILITY OPERATING WO 021 PIER 3 PLANNED, EST. COMPLETION 12/79 W190A PIERS 2,3 PLANNED, EST. COMPLETION 6/77 W063C PIER 1 PLANNED, EST. COMPLETION 8/79 W266B SOUTH DOCK, EAST DOCK CONST.COMPL (awaiting sewage transfer hose) US00006995 > LOCATION PORT HUENEME CBC YORKTOWN NWS PHILADELPHIA NSY MCON NO. P-332 PCR NO. W023K TABU (cont.) DESCRIPTION ' WHARFS 2-6,A P-336 W136C PIER 2 P-451 P-443 W106D PIERS 1,2,4 W106B PIERS 5,6 ROOSEVELT ROADS NAVSTA P-997 W111H PIERS 1,2,3 GUAM NAVSTA P-094 W064K A,B & V 0 1 NAVSHIPREPPAC NSD ik NAVMAG L,M,N,& 0 R,S,T, & U H NAVSTA P-107 W064R X PORTLAND, OR NAVRESCTR O&MN W258C PIERSEWER TACOMA, WA NAVRESCTR O&MN W151C PIERSEWER EVERETT, WA NAVRESCTR O&MN PIERSEWER STATUS -- ------------- PLANNED, EST. COMPLETION 9/79 UNDER CONST. UNTIL 1/77 UNDER CONST. UNTIL 11/76 CONST.COMPL.(awaiting sewage transfer hose) UNDER CONST. UNTIL 4/77 UNDER CONST. UNTIL 11/76 UNDER CONST. UNTIL 11/76 UNDER CONST. UNTIL 11/76 UNDER CONST. UNTIL 11/76 PLANNED, EST. COMPLETION 12/79 AWAITING AWARD OF CONST.CONTRACT (EST.COMPL. OF CONST. 4/77) AWAITING AWARD OF CONST.CONTRACT (EST.COMPL. OF CONST. 4/77) UNDER CONST. UNTIL 1/77 US00006996 >V LOCATION GALVESTON, TX NAVRESCTR MCON NO. MCNR P-032 TABLE G-l (cont.) PCR NO. DESCRIPTION W322A PIERSEWER STRUCT. #11 ST. PETERSBURG, FL NAVRESCTR MCNR P-241 W329A PIERSEWER STRUCT. #6 BRONX, NY (Fort Schyler) NAVRESCTR MCNR P-315 W324A PIERSEWER PERTH AMBOY NAVRESCTR MCNR P-346 W338A PIERSEWER PORTLAND, ME NAVRESCTR MCNR P-343 W340A PIERSEWER BALTIMORE, MD NAVRESCTR MCNR P-243 W072A PIERSEWER JACKSONVILLE, FL NO PIERSEWER PLANNED BOSTON, MA NO PIERSEWER PLANNED NEWPORT, RI (NETC) NAVSTA P-208 W116N PIERSEWER PLANNED ) STATUS PLANNED, EST. COMPLETION 7/77 PLANNED, EST. COMPLETION 7/77 PLANNED, EST. COMPLETION 1/78 PLANNED, EST. COMPLETION 12/78 PLANNED, EST. COMPLETION 10/78 PLANNED, EST. COMPLETION 10/77 __ _ US00006997 ) LOCATION______ MCON NO GREAT LAKES, IL > __________ TABLE G-l (cont.) PCR NO. DESCRIPTION NO PIERSEWER PLANNED YOKOSUKA, JAPAN LA MADDALENA, IT HOLY LOCH, SC KILL USE SWOB ROTA, SPAIN WILL USE SWOB BAHRAIN GAETA I NAPLES <y* j _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ BROOKLYN, NY (Floyd Bennett Field) NAVRESCTR MCNR P-319 W337B PIERSEWER PLANNED STATUS ( ) / US00006998 ) )) TABLE G-2 SHIPS WASTE OFFLOAD BARGE (SWOB) ALLOCATION PLAN AND DELIVERY SCHEDULE* FY74 PROCUREMENT FY75 PROCUREMENT FY76 PROCUREMENT TOTAL (OIL) (OIL) (OIL & SEWAGE) ALLOCATED TO BE ALLOCATED ALLOCATED ALLOCATED DELIVERED ALLOCATED DELIVERED DELIVERED (OIL) (SEWAGE) OIL SEWAGE NAVSHIPYD Portsmouth 0 0 0 0 1 0 0 1 0 WPNSTA Earle 0 0 2 0 l(Note 1) 1 0 2 0 NAVSHIPYD Philadelphia 0 0 0 0 0 2 0 20 WPNSTA Yorktown 1 1 0 0 0 0 0 10 NAVSTA Norfolk 3 3 3 3 0 0 2 62 NAVPHIBASE Little Creek 1 1 1 1 0 0 1 21 NAVSHIPYD Norfolk 1 1 3 0 0 1 0 20 NAVSTA Charleston 2 2 0 0 0 1 0 30 NAVSHIPYD Charleston 0 0 0 0 0 0 1 01 NAVSHIPYD Puget Sound 2 2 3 3 0 0 0 50 NAVSHIPYD Mare Island 1 1 0 0 0 0 0 10 NAVFUELDEP Point Molate 0 0 1 0 1-Jan '77 0 1 11 NSC Oakland 1 1 0 0 0 0 0 10 NAVSHIPYD LOng Beach 2 2 0 0 0 0 1 2 1 01 NAVSTA San Diego 3 3 0 0 0 0 2 32 -J NAS North Island 2 2 0 0 0 0 .0 2 0 NAVSHIPYD Pearl Harbor 1 1 0 0 0 0 0 10 NAVSTA Pearl Harbor 2 2 1 0 l(Note 2) 0 3 3 3 NAVSTA Guam 0 0 1 0 l(Note 2) 0 1 1 1 NAVSTA Subic Bay 0 0 1 0 l(Note 2) 0 0 1 0 FLEACT Yokosuka ,0 0 2 0 2 (Note 3) 0 0 20 NAVSTA Rota 0 0 1 0 1 (Note 4) 0 1 1 1 NAVSUPPO La Maddalena 0 0 1 0 1 (Note 4) 0 0 10 NAVSTA Roosevelt Roads 0 0 2 0 2-Jan '77 0 0 20 NAVSTA Guantanamo Bay 0 0 1 0 1-Jan '77 0 0 10 TOTALS 22 22 20 7 13 5 13 47 13 Information provided by Naval Facilities Engineering Command (NAVFAC 104), 10 January 1977. Notes: 1. One barge delivered by contractor stored at NAVSHIPYD Puget Sound to be delivered by contractox to final destination 2. Three barges delivered by contractor in July 1976 to NAVSHIPYD Long Beach to await a Navy tow of opportunity to final destinations. 3. Two barges delivered by contractor in September 1976 to NAVSHIPYD Long Beach to await a Navy tow of opportunity to final destinations. 4. Three barges delivered by contractor in July 1976 to INACTSHIPPAC Portsmouth to await a Navy tow of opportunity to final destinations._________________________________________________ US00006999 r r 'C G - 3 ) C H T COMPLL I n sSCHEDULE* i s e rr? ) nr-?) rt-u CUN OC*I t * M i ------- Ml sot $12 S -)l S M (4 ) I-* S*l8 L h i-) 66*10 GC-17 CC-27 00-98) D O C*II 006-1) 0*11 A 0-)7 A l-I| A t*ll AfS*8 A0-*8 A 0*U ? AOA-l DOC-|> 0X*4# rr-io vi rr* ton rr*to)8 rrc-t *? A S *ll ATr.100 A Tf-IO I A T7-I8I LP0-7 IS T - II? 9 LST-tlOt *r w * " my tr<o" `u m 00 UO-ll < u n ) IJ6 -H < ! ??) 06-18 (* to ? r c - H ( t * *1 66?- I I ( * In *7 D O -l)t N U (1 ) DO-811 ( 1 *1 DO-082 ( In * T DO-981 N U ( 1 ) DO-891 N t( ( 1 ) 00-898 ( In ' ? DOC-I ( I n *? t r - io lt (* In * T r .io i? < In *? I ? - I 0 ) l { In *7 >f - io o ( I n *1 r.-i ( In *7 tWOl. C 9 *8O (8 )< 0 ) A l - l l ( In '7 A 0-H 1 ( In ' AAh-8 ( In #? AAS-2) ( In #r A lS -2 8 AP>-2) A V M -ll A SR-I! K n it <11 < In ' 7 ( in * 7 ( In *7 ATf-18 ( In '7 A ir-108 ( In A T F - IIO <* In *7 ASM-18 S n ir ( A ) I M * i n V rn**T LPD-O ( I n *7 t n i- | I ( In * ? U P -1 0 ( In *7 I S T - I I I M * 1 *7 IS T -U I*< * In '? |W k |' . T |S 69*8? (8 ) nr- ? ! r t * 78-7T a w ru tts co w ttm 06*29 OC- J4 CCN-21 OD-11? 00*9)8 00*981 DU-9 .8 (10*9)0 00-78) (ID -798 00-9)7 AD- I# A IS-1 A(S* 7 A C -I)) AO-91 AON-2 " -- -- --" IM -U I III). 1 1.1*0*10 irn - u in - 7 tfM -10 66*18 IT - 108) 006*11 CC-2I rr- io ii DOC-34 DOC-8) 00*9)1 n o -ID rr-io )o rr- io n rr-t0 4 i rr* io )i 00-980 00*98) rr- io )i rr-1082 rr-1088 00-980 rr-io o ) tr-io ? one-8 ir- io v i ire - ) PW:-9 ri- io ii IIC -8 in .- 10 11-1071 n tc -li ir-1 0 7 ) ----* - -- AM S*If DIC-1 (IX -1 I D ie -JI rr-iq 7 8 rr- io n fl-IO fl A ll-8 9 A G I I *1 ire - ) AR>-8! A D - 19 A I-7A A > |8 A I-28 A (S-I A l 21 AT4. - ! ---- -- -- 1)0-1 A IS-0 act-) A T I - 101 A rr-io ) U T - 1180 A D I-I A T I-II) IS T -II8 ) AH*.-8 ATI' - | 8 l U r-1188 AIM -) U T -II8 7 A(M8 A -) U T - M i l -------- - -- * -- -- - - * * * - -- -- U t - 19 LSII-29 ie e -io (* In *78) LPA-788 LPA-181 LS D -)8 LS D -)9 rr-77 Cryr:r-f - n------------- 78 COM PUTI! C6-10 " ~ i r - i o r t C C -IJ rr-to so CC-28 r r - io ! CC- 10 r r - i08) C C -)I rr-to so D X - ll r r * t 08i O X - 11 r r -1088 P IC - 18 rr-to o ? |m r.*80 rr- io ti r - 1091 ir-1 0 8 1 ri- io ii M -IO ?] rr-io 7 8 ....... A O .ll M S-8) AC*2) A I-28 AS-1) A S - 18 AC-12 ATF-188 A f-1 8 A -)) ACS- I A o -n A O .) AOft-1 ' AA-8 ' CVT*18(8)f? ) ( ! ) . . .C.9.-.8. ). ( 8- ) ( 7 ) ( 9 ) 05-11 CC 1 ) one*! t'UC-O P IC -9 m - 18 U K -1 8 w r,.lo DfC-18 N C-O PIC-88 00-911 rr-iO A i rr-io o r r - i 08 rr-1093 ir - n n ir-i0 9 > ri- io i) i r -1018 rr- io i) I ' l l . '82 l T ) AC-2! A t-)) AM -) AN-8 A S - 19 A .-18 U O *)) LS D -18 IR A -II! L ro -il U T -II9 ) c o t r t n iois o r fARTtAI.9 rr-79 ow nnes 69*80 ( ? ) 07-41 ( ? ) 69-88 (? ) c v *.tM )( (ll c v - tt ;> GC-11 n x-l o x-1 1 etc-18 OX-17 DIC- 18 one-7 WC-81 00C-88 rr-1088 08*108? rr- io i? rr-to io A fs-I aim-8 ASM-11 A n -71 ACOf*1 IM-II? U f i- JO 1.90*11 w m ttM Or 7A8TIA U LIU -9 irn - il u n - 18 LM l-1 in i- it i n i* 11 U r -1188 L S T .II8 9 LS T -II9 ) co n rim o N S o r p a m tia is one*? 66*18 DU-888 rr-io )8 rr-io )7 ASA*1) 77 10)0 rr.to o o 1C-! IAi-8 )9 ASM-1 ) in - i IS O - 18 tNCACNtKTAU 0 7 -8 8 (8 ) COMPUTI OWS o r PAMl |A I S 06-28 C C H -)! AC-27 AMS-0 MM) AftS-1) irb -8 ATf-98 A TI-108 A Tr-110 U 0 -)2 ING.ftCHI.KtALf C 9-81(81 U O - 18 w -- -- " -- ~ " tNTNMtfTAIS c r - ii (8 ) 07-81 (8 ) IC C - 20 LK A -II) 1.1-ti.l ) LST-U 8) LSr-1188 IN MIHIWTAI S rV -8 |(8 ) C 9 *8 0 (8 ) C V 8 7 (8 )(8 ) CV-. 1 (8 ) C V -8 8 (6 ) G V -8 8 (7) IwrMtNMTAU o r-8 i(7 ) 07*11(8) ftn tn a i * - In O ltM ta < *fl tln n ! 4 i t t n ^ l ( l|* T til t^ flillu n Iw lw lt (M flf U I D - o ir . . . i . tn U I n t l i l U J , h w *t ( ) ) r M D I l a m l l u l a i cnm ^U tlnn <*>- T . k r . m i l , In r > - ' 77. ( ) ) Id w ^ iilr l ( i t Atcwnal t ln n ln f. (8 )* M . |ilR ln ( p n rtln n . ( 7 ) . A ft f l | l | f t it l M , ( ) * Tn8 p n itlv n . fT-80 C7W. aw . CT-MP) CC*) 006*1 OX-81 01- 07-*l(t| C 8 *8I(?| S l'W L 06*11 06*19 0(8*988 m r.-t| UC-11 nc-8 rr-1980 77-1081 07*81 ft| ..lU H iL A t.- I a*>-n *"lA-118*" tII-< IID-8 iin - i Iill-80 U T -II9 0 L s r - lftl i >t * u *8 U T -1198 MT-II17 rm AL c i^ rtrT to m ( t ) n w r, r? COHP. o r t A f t f. TOT ? i 10 10 *78 28 28 * 7) 8| 8| * 78* 7t 88 i l 79 *77 81 i 1 *78 1) i i ) i 71 28 ) J1 to ) ! *81 18 11 caaw m u ut FOR O F F IC IA L USF ONLY *CHT Ship/Shore Interface Information Book, Hydronautics Technical Report 7607.1 prepared for NAVSEC 6159, October 1976. 1 US00007000 FOR OFFICIAL USE ONLY FOR OFFICIAL USE ONLY