Document GaX2XMVmmKXXMR34rxgDed9r

MEMORANDUM FOR SEE DISTRIBUTION SUBJECT: Request Information on Usage of Perfluorooctly Sulfonates Containing Materials We would like you to provide information on the impact of the U.S. Environmental Protection Agency's (U.S.EPA) proposed rule that calls for the phase-out of 90 perfluorooctly sulfonate (PFOS) chemicals (See attachment). The Mil Spec for Aqueous Film Forming (AFFF) allows the use of PFOS, perfluorooctanoic acid (PFOA), and telomers to produce fluorochemical surfactants which are key to helping other AFFF's agents meet low fire-fighting surface tension requirements. AFFF is used in a number of critical life saving situations in DoD and currently, there are no known substitutes that are as effective as the materials in the Mil Spec. The U.S. EPA released data this past year that indicates PFOS chemicals are persistent, bioaccumulating and toxic. PFOS has been found in the blood of the general US population, in wildlife, and in people overseas. The U.S.EPA will prevent manufacture or import of PFOS after the phase-out period, including PFOS-based AFFF, unless a 90-day notice is filed and approved. They are also evaluating PFOA and telomer chemicals. PFOA and telomer are also persistence in the environment and may pose significant health risks. Because o f this, PFOA and telomer may also be subject to manufacturers' withdrawal from the market place (similar to 3M's action for PFOS) or future EPA rule making. Request you perform an assessment of the impact of EPA's phase-out of PFOS to your organization and provide a copy to my office by 08 Jul 01. This assessment should include the quantity (in lbs.) and type of materials that contain PFOS. Include the amount of AFFF or PFOScontaining material in stock, number of systems and the amount (in lbs.) used per year. Also list the operations where AFFF or PFOS-containing materials are used and identify all mission critical uses, amounts, usage rate, stockpile, and potential substitutes, if any. Mission critical uses are uses where there are no available substitutes and phase-out of PFOS will negatively impact operational effectiveness and operational suitability of combat missions or contribute significantly to the degradation of combat capability. In addition, please explain the mission impacts if a fire suppression system is not replaced, cost o f replacement options and estimate quantities needed for stockpiling for mission critical uses. Identify any operations that release PFOS-containing materials to the environment and take appropriate steps to prevent or stop these releases. We will use this information to develop a DoD AFFF and PFOS-containing material replacement strategy. My POC is Mr. Gary Hamilton. US00002948 He can be reached at (703) 604-1820, email: gary.hamilton@osd.mil. If you have any questions, please contact him Attachment: As stated Curtis M. Bowling Assistant Deputy Under Secretary of Defense (Force Protection) US00002949 DISTRIBUTION DASA (ESOH) DASN (E&S) DASAF (ESOH) DEFENSE LOGISTICS AGENCY DEFENSE AGENCIES' DESIGNATED AGENCY SAFETY AND HEALTH OFFICIAL US00002950