Document G52GJ2Rwww7yV0qr2myNBp6R4
Briefing to Congress on Aqueous Film Forming Foam (AFFF) Replacements and Alternatives
Performing the Duties of Assistant Secretary of Defense (Energy, Installations, and Environment)
February 2022
The estimated cost of this report or study for the Department of Defense is approximately $3.650. This includes $1,750 in expenses and $1,900 in DoD
labor. Cost estimate generated on December 14, 2021 RefID: F-E963A41
Purpose
Official response to Public Law 116-283, Section 331, William (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021:
"SEC. 331. SURVEY OF TECHNOLOGIES FOR DEPARTMENT OF DEFENSE APPLICATION IN PHASING OUT THE USE OF FLUORINATED AQUEOUS FILM-FORMING FOAM.
(a) SURVEY OF TECHNOLOGIES.--The Secretary of Defense shall conduct a survey of relevant technologies, other than fire-fighting agent solutions, to determine whether any such technologies are available and can be adapted for use by the Department of Defense to facilitate the phase-out of fluorinated aqueous film-forming foam. The technologies surveyed under this subsection shall include hangar flooring systems, fire-fighting agent delivery systems, containment systems, and other relevant technologies the Secretary determines appropriate.
(b) BRIEFING.--Not later than 1 year after the date of enactment of this Act, the Secretary shall provide the congressional defense committees a briefing on the results of the survey conducted under subsection (a). The briefing shall include--
(1) a description of the technologies included in the survey; (2) a list of the technologies that were considered for further testing or analysis; and (3) any technologies that are undergoing additional analysis for possible application within the Department."
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Overview FY 2020 NDAA Sec 322 Summary of Non-Foam Alternatives Considered Detailed Descriptions and Assessments
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Option Ignitable liquid drainage floor (SafespillTM)
High expansion foam (Hi-Ex)
Trench Nozzles
Water-only sprinklers
Optical Flame Detection only
Water mist
Non-Foam Alternatives to AFFF
Cost
Pros
Cons
$$$$ Most effective fire containment & suppression Expensive
No chemicals involved so avoids
Longer to install
environmental and health concerns
Single supplier that must scale up to meet DoD demand
Fire code compliant
New product with unproven long-term performance
$$$$
PFAS Free Well-understood and trusted Fire code compliant
Very expensive Some structures unable to bear heavy foam generators Longer extinguishment time leads to more damage
$$$$ Very effective containment and suppression Expensive retrofit option Fire code compliant
$
Inexpensive
Not effective against fuel fires
Water-only avoids environmental concerns Does not meet DoD fire code for hangars with fueled
aircraft
$
Inexpensive
No chemicals involved so avoids
environmental concerns
Little to no maintenance
Will not suppress a fire Detectors alone are not compliant with DoD fire code
$$$ Excellent heat removal
Still under development
Water-only avoids environmental concerns Moderate cost to retrofit existing sprinkler systems
Not yet compliant with DoD fire code for hangars
with fueled aircraft
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Ignitable Liquid Drainage Floor
Description Ignitable liquid drainage is a perforated aluminum floor placed on a hangar floor. Holes draw the fuel into drainage channels as soon as it spills, effectively
containing and quenching a fire before it can grow.
Assessment Very effective at containing fuel fires No environmental or health concerns (uses only water) Easy to maintain High installation cost and longer retrofit times Only a few small manufacturers - concerns about scalability to meet potential DoD
demand Currently awaiting feedback from aircraft maintainers participating in test
applications
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High-Expansion Foam
Description High-Expansion (Hi-Ex) Foam systems fill up a space with foam, effectively starving the
fire of oxygen to extinguish it.
Assessment Hi-Ex Foam is well-understood in DoD, having been installed in hangars for years Mechanism (smothering) is effective against many types of fires Foam does not contain PFAS Time needed to fill a space with foam and smother the fire gives the fire time to grow and
cause more damage Foam generators are heavy, making them inappropriate for some hangars System is susceptible to accidental activation, which can cause damage to sensitive
electronic equipment in aircraft Very high installation and maintenance costs
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Trench Nozzles
Description A trench nozzle system is designed to contain a fuel fire within a grid of trenches cut in
the floor, then suppress it with fire nozzles in the trenches. Assessment Very good at containing and suppressing fuel fires Navy has a lot of experience with this type of system Very high retrofit/installation costs
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Water-Only Sprinklers
Description Existing AFFF sprinkler systems can be converted to water-only by turning off
the foam delivery parts of the system. Assessment Not effective at suppressing fuel fires No environmental or health concerns (uses only water) Less expensive option - however, some systems may have to be modified or
replaced when switching to water-only, negating the cost savings Does not meet current DoD fire code requirements for fire suppression in
hangars with fueled aircraft since the code requires protection against fuel fires
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Optical Flame Detectors Only
Description Optical flame detectors are faster at detecting fire than smoke or heat detectors. They
simply detect fire and transmit the information to an alarm system Assessment Based on historical mishap data, the likelihood of a fuel fire in a hangar is very low Detection system would alert firefighters to respond and allow time for occupants to
evacuate the building Does not meet current DoD fire code requirements for hangars with fueled aircraft since
it does not provide fire suppression (but could be combined with other options)
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Water Mist Sprinklers
Description Water mist sprinkler systems atomize water to deliver a large number of tiny water
droplets, improving the cooling effect of water Assessment System is still undergoing development and testing No environmental or health concerns (uses only water) This technology is not currently compliant with DoD fire codes for hangers with
fueled aircraft since it only controls a fuel fire rather than extinguishing it
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Conclusion There are many viable alternatives for replacing AFFF No single technology is suitable for every situation The Department continues to evaluate all available technologies
to find the best fit for each mission need and level of risk
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