Document V3VVeKQJO0aOn0dD5XKYpZ3j

GAO RevieFwolloofwD-uOpDQDureinsktiinognsWoanteArFCFoFnPtarmodinuacntsts (100947) In our prior conversations with Navy officials, we have been told that DOD's AFFF MILSPEC pcasreahpeqlaprlssuleloiafrcnoerosnrmneAteshlFniwasFtttshFotehsfnppefrleuuorceosdielrfueoidecvcdtafsaonhrtrbtoeiolrtascennoinigsnnauutteafratfniegnadrec.ePtaTidFsnhCpatesuss.rmppfoBlaoulaltssoesewroe.iadts"hl eo(sfnrrhocaomolulmhrpapraevogveueinen5dwosoaofadftshtvheereerdsqAeouFcierFuefmFfdeecMtontItoLc):nSon"PtChfEoeorCnmh,ceeitatonlttthrhaeotefs 1. Is the term "fluorocarbon surfactants" in the MILSPEC interpreted as synonymous with PFCs? If not, how is the term interpreted, and where in the MILSPEC does it require AFFF to contain PFCs? "PFCs" are "Perfluorinated Chemicals". From the EPA website on PFCs and PFASs: of toxic "Perfluorinated chemicals that cinhcelumdiecsalsPFisOaAtearnmd that some scientists use to refer to the group PFOS and other per- and polyfluoroalkyl substances (PFASs). Organizations that have used the abbreviation "PFCs", referring to perfluorinated chemicals, include U.S. EPA, U.S. Centers for Disease Control and Prevention (CPC) and the U.N. Organisation for Economic Co-operation and Development. EPA is now trying to use "per- and polyfluoroalkyl substances (PFASs)" rather than "perfluorinated chemicals (PFCs)" consistently to collectively describe PFOA, PFOS and the other chemicals in this group." Yes, the term "fluorocarbon surfactant" is synonymous with PFCs. 2. To what extent has DOD/Navy considered revising the MILSPEC to remove the requirement for "fluorocarbon surfactants," provided the performance requirements of tRheemMoIvLinSgPEthCe cflouuolrdocsatirllbboen msuertf?actant requirement would put the foam in the fluorinefsruerefafcotaamnt (tFh3a)t chaatsegboereyn. Taboledatote,mteheetrethheaMs inlsoptebcefeirneapeprrfoodrumcatnwciethroeuqtuaireflumoernotcsa.rbon MIL-F-24385F additionally mandates specific chemical and physical requirements to ensure the candidate foam products are compatible with existing military foam proportioning systems and firefighting appliances. The current F3 products have dcoemmpoantsibtrialittey,dapbriolitbyletomfautnicctisiosnuewsitwh itnhonre-agsaprdiratotintgheniroczozlnecse,natnradteinvcirsecaosseitdy,asceuatewtoaxteicrity to aquatic life forms (particularly fish) due to their higher levels of hydrocarbon surfactants, in comparison to AFFF. 3. We understand that the Air Force uses high-expansion foam in some of its hangars. a. Is high-expansion foam subject to AFFF MILSPEC requirements, or is it subject to other requirements? No, high-expansion foam is not subject to the AFFF Milspec requirements. There is no military specification that governs high-expansion foam. High-expansion foam is tested and listed to Underwriters Laboratories Standard, UL-139.. US00006549 M'rti<;iikl \>'> -ri<;l Hi il high - '/imfim tfi f nm n u< A nn '41^ In fir ^ -vlingui'rhing jg yrif [<;r dill iiir^ Iid/di4d IIh I nr-' pr</l-",,l"d Lv / I I I wJ'dr.d In d^Jilr/n high '/{> jfim < (</riff '.y i'rrin cirri'' willi fli-^ir >wn v 4 4 lirnifdli *fi'. irK ItKlifKj- dritig-'r b. tTo> fwddhda'rtfieFix't'eII ndtddf'o4e/ s high-expansion foam contain PFCs? To our knowledge, the Navy has not conducted any testing to determine if high expansion foam contains PFCs. Available literature on the topic claims that high expansion foam concentrates do not contain PFCs. It is not known to what extent this claim applies to current and past products. pNearvfoyromffaicnicaelsrheaqvueireamlseonttosldlauids othuetrien athree AcuFrFreFntMlyILnSoPPEFCC.-WfreeehAaFvFeFrepvrioedwuecdtsththeawt embeseittetsheof some manufacturers that are on DOD's AFFF QPL, and it appears that some of those manufacturers (e.g., Solberg, ICL Performance Products) claim to sell firefighting foam products that may not contain PFCs (e.g., "fluorosurfactant-free" and "fluorine-free"). 4. Has the Navy tested any available PFC-free firefighting foam products (or products that claim to be PFC-free) from these or other manufacturers to determine whether they can meet the performance requirements in the AFFF MILSPEC? a. If so, what were the results? NRL is well aware of the Solberg (formerly 3-M Australia) Re-HealingTM foam products, which are non-fluorinated and designed to have mechanical properties to compensate for the lack of film formation. Under a previous Cooperative Agreement with 3-M Australia and with the current Non-Disclosure Agreement between NRL and Amerex Corporation, NRL has been conducting fire testing and laboratory studies to help further investigate the potential possibilities for developing a fluorine-free product that could meet the MILSPEC AFFF fire performance requirements. The products NRL has tested still fail to meet the MIL-F-24385F 28 ft2fire performance test at full strength. Since the products have not been successful at the 28 ft2fire performance test at full strength, NRL has not pursued more demanding test requirements of the MILSPEC that include half strength, quintuple strength, and aged concentrates. In addition, the AFFF MILSPEC has several other key requirements that must be considered, including compatibility among vendors, dry chemical compatibility, burn back, and viscosity. Integration and compatibility with existing installed AFFF systems and equipment will also be a factor. Although Solberg has western foreign Navies, bUeSeCnGsommielitwarhyavt essuscecless,safunldinthteheFAcoAmsmtillerrecilaylomnarket; the MILSPEC AFFF and require its use for Class B (flammable liquid) fire applications where rapid extinguishing performance is mandated. b. If not, why has testing not occurred? N/A. See testing discussion in 4.a. 5. To what extent has the Navy funded (or plans to fund) any research into developing rPIneFleCFaY-sf1ree7de, AFFF products? athseolSictirtaattieognictoEdnevvireolnomp eantfaluloRrinees-efarercehsuarnfdactDaenvt efolorpmmuelanttionPrfoogrraumse (iSnEARFDFPF). Three projects were selected for funding including a proof of concept project led by US00006550 l(NeSad0v.a5b3ly2AtMhireoWNvaearrvfaathrlereReCeseyeenaaterrcsrh)W. TLeahabeposoernastporrDoyjiev(ci$stis1o,nw8Mil(l$bo2ev0e0inrKitfiofaouterrdoyneoeavresyr)e,tahrae)n,ndaebxmtyfueNlwtia-tymioenoanar tlhpFsro.ojaemct awIlnsitohadcthdoeintitordinbeuvtoteeltodhpe(m$F2eY,n11tM7o,fNFeRYnLv1iS7ro-E2nR0m)DePSnctpaierllonygc-freraiem&n,dTtlheyecshuNnrRofalLocgtCayonr(tesS&6foT.2r) Research Program has ffiurenfdiginhgtintgo ffouartmhes,r awshsicisht accounts for the desired low fuel permeability capability that is inherent with the current AFFF formulations. 6. What implications, if any are known, would selecting a PFC-free firefighting foam product (or product that claims to be PFC-free) have on the current infrastructure and systems used to store and use AFFF? The current commercially available PFC-free/F3 products have demonstrated problematic issues with regard to their concentrate viscosity, sea water compatibility, their ability to function with non-aspirating nozzles, and increased acute toxicity to aquatic life forms (particularly fish) due to their higher levels of hydrocarbon surfactants in comparison to AFFF. Viscosity is a characteristic that is critical in the ability for foam concentrates to work in current AFFF systems and equipment. Even disregarding the known difference in fire extinguishing effectiveness, no existing PFC-free firefighting foam product is known to be a viable drop-in replacement that would be compatible with existing MILSPEC AFFF proportioning systems. And PFC-free AFFFs may not be cinocmlupdaetibinletegwriathtioonnecra;n1,o1.thceorrr.ipRjleilbsiellailyr,chanindt.ocodmevpealtoibpiilnityg a PFC-free AFFF will with existing installed need AFFF to systems and equipment. US00006551