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AFFF and PFOS/PFOA DASN(E) Policy Memo July 2016 NAVSEA 05P5 Mary Hunstad What are PFOS and PFOA? PFOS (perfluorooctane sulfonate) and/or PFOA (perfluorooctanoic acid) are substances found in all MIL-spec AFFF. Both PFOS and PFOA have been found in ground and drinking water at public water utilities and military sites where testing, training, or firefighting with AFFF occurred. AFFF is only one source of PFOS and PFOA - others include manufacturing processes, packaging, and surface treatments such as Scotchguard and Teflon. - Major manufacturers have been reducing PFOA levels in their processes and products in response to a voluntary EPA initiative. The latest MIL-Spec AFFFs still contain trace amounts of PFOA. PFOS is only found in AFFF made by 3M Corporation. 3M ceased production in 2001/2002. On 19 May 2016, EPA issued lifetime health assessments of 70 ppt for PFOS, PFOA or the combination. 2 US00002893 DAS N (EI&E) Policy Memo DASN(E) policy memo of 17 June 2016 states DON intention to remove, dispose, and replace legacy AFFF containing PFOS and/or PFOA once suitable substitutes are identified. Until suitable replacements identified: Cease uncontrolled environmental release shore-side, except in emergency. Prevent environmental release for outdoor training; testing of firefighting crash and response vehicle AFFF systems; testing of hangar AFFF and other fixed systems, (shore based activities only) Update/implement requirements to ensure fire and emergency service vehicles and equipment at DON installations and facilities are tested and certified in a manner that does not allow release of AFFF to the environment. By end of FY 2017, remove and dispose of PFOS containing AFFF in drums and cans from local stored supplies of shore installations and ships. (Note - This is the 3M AFFF) o3 M AFFF US00002894 Short Term Way Ahead ASD(EI&E) hosted initial meeting in June to lay out way ahead. Attended by DASN(E), OPNAV, USFFC, DLA, NAVSEA, NAVFAC, Air Force, and Army. Followon mtg in August. DLA checking all inventory for 3M (PFOS) AFFF. Testing AFFFs currently or recently on the QPL to determine PFOA level. Results expected late July. - Based on data, identify which are the better (lowest PFOA) products. Issue letter to DLA identifying the better AFFF products for use in procurement. Develop testing methodology to enable a lower limit of detection for PFOA. Issue Naval message to TYCOMs recomm ending all ships identify and remove 3M AFFF in cans/drums. Other com m ands will be info'd and can use the message to forward actions within their command if desired. Revise the AFFF Mil-Spec (already underway) to incorporate PFOA limits. Long Term Actions - still under development, but will likely include a one time replacement of AFFF in Fire and Emergency Service vehicles, shorebased hangars and other shore-based systems, and shipboard tanks. 4 US00002895