Document jBmJwg1Yppnx7YbkgX2XeNr2

From: To: CC: Sent: Subject: Barylski, Douglas J CIV SEA 05 Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; 'Ronald S. Sheinson'; Glover, Carl CIV CNIC HQ, N3; 'Bradley A. Williams' Davidson, Ross A CIV; Whalen, Shawn T LCDR NavAir 1.0, PMA251 ; Hunstad, Mary P CIV SEA 05; 'John P. Farley' 11/7/2007 12:56:49 PM RE: EC Governance Council Meeting Summary Memo There's no real difference in impact related to AFFF whether EPA discusses PFOS or PFOA. It is mostly related only to the 3M product which hasn't been produced in years. Phase-out has an impact depending on what is meant by that. Phase-out of production of PFOS/PFOA related materials is essentially OBE regarding AFFF since 3M was the only manufacturer dependent on that. There seems to be a concern that trace levels of PFOS/PFOA related chemicals may be in other AFFF products. I believe manufacturers agreed to monitor this. Phase-out of use of 3M would be a problem, since we estimated quite a few years before existing quantities aboard ship are used up- I believe more than 5 years. How big a problem depends on phase-out timeline. Formula of AFFF in shipboard tanks is not possible to trace, so inventory could only be identified by manufacturer's drums or cans. Not sure what is used for training, but AFFF has long been known to affect municipal sewage treatment, so I thought an alternative was used, if any foam agent is used at all. Don't need a foam agent for Navy firefighting training since the propane fire in the trainers is easy to put out. Labs would have to address clean-up of test facilities. I do not know how effluent is collected. R/Doug Barylski ---- Original Message---From: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680 Sent: Tuesday, November 06, 2007 22:47 To: Ronald S. Sheinson; Glover, Carl CIV CNIC HQ, N3; Bradley A. Williams Cc: Davidson, Ross A CIV; Whalen, Shawn T LCDR NavAir 1.0, PMA251; Hunstad, Mary P CIV SEA 05; Barylski, Douglas J CIV SEA 05; John P. Farley Subject: RE: EC Governance Council Meeting Summary Memo Good Morning Ron, Thanks for all the great details, especially a copy of the brief. What concerned my most about the ECGC Memo was that is specifically identified PFOA (vice PFOS), as quoted below. "Recommendation 2 - Perfluorooctanic acid (PFOA) - PFOA is fire-retardant chemical with critical uses in DoD platforms/systems in highperformance gaskets, o-rings, seals, and protective coatings. - PFOA is accumulating in humans and EPA completed a draft risk assessment that will lead to low toxicity values. - Manufacturers are phasing out production and the chemical may become unavailable. - Participants discussed the use of PFOA in DoD's supply of aqueous film-forming foam (AFFF), the potential for exposures, and the potential need to clean up fire training pits where AFFF was used. - The EC-GC unanimously approved the elevation of PFOA to the EC action list and development of a Phase II impact assessment with risk management options." Being under the impression that we have foams on the QPL that use PFOA, this US00007858 was the reason for my question about being in a more dire situation than in 2004. I knew from attending the Workshop in 2004 that we were sort of out of the woods with PFOS with 3M leaving, but I thought the PFOA issue was being looked at by the EPA. I believe they were conducting some sort of PFOA study involving the manufacturers. The content of the subject memo had me concerned that the study was complete and it was resulting in more manufacturers leaving the market. Do you have any update on the "study" the EPA talked of at the workshop? Thanks again for all the great info and support. Brian Brian Berchtold Manager/Lead Engineer, Carrier Aircraft Fire Suppression Program Crash and Salvage Lead, CVN21 Aviation IPT NSWC/CD Code 668 Damage Control and Firefighting (215)897-8683 (office) (215)897-1134 (fax) (609)432-1622 (cell) brian.berchtoid0navy.mil ---- Original Message---From: Ronald S. Sheinson [mailto:ronald.sheinson0nri.navy.mil] Sent: Tuesday, November 06, 2007 9:47 To: Glover, Carl CIV CNIC HQ, N3; Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; Bradley A. Williams Cc: Davidson, Ross A CIV; Whalen, Shawn T LCDR NavAir 1.0, PMA251; Hunstad, Mary P CIV SEA 05; Barylski, Douglas J CIV SEA 05; John P. Farley Subject: RE: EC Governance Council Meeting Summary Memo Carl & Brian, First off, only 3M AFFF of all the QPL AFFF products contains PFOS. 3M is not making any more fire fighting foams, AFFF or other types. There is residual 3M AFFF stock in DoD and in place in foam systems aboard ships. The EPA limitations are on manufacture or importation of PFOS, not on AFFF usage. The EPA addresses PFOS, not AFFF. In fact, AFFF is a minor user of PFOS compared with other applications. "Are we now in a more dire position regarding AFFF than we were at the Workshop in December 2004?" Not much has changed. 3M is out of the AFFF manufacturing business. Concerns are still present on AFFFs in general and restrictive regulations are increasing world-wide. Mary Dominiak's (EPA) statement that it would be prudent to investigate alternatives still holds. (I don't expect too much more from the EPA under the current administration.) But the other shoe has not dropped yet. We probably (I am not an International Law expert) can still use AFFF as long as we are not flagrant in releasing any into the littoral environment unless really needed for platform / life safety. Be careful within national coastal boundaries and transit waterways (e.g., straits and channels). PFOS is unique and identifiable as a 3M product. It was easily singled out for legislation. That is not to say there are not limitations on AFFF release in general. There definitely are, within the US (including a patchwork of local restrictions on wastewater contamination), and by individual countries and international agreements, for 3M PFOS AFFF AND the other AFFF products. US00007859 At the recent Buncefield fire in the UK, about 18 million gallons of foam / water "hazardous waste" from the extinguishment efforts had to be contained and processed. In fact, the fire fighting with foam could not even begin until containment dikes were first set up. And this was for foams NOT containing any PFOS. For general information I am attaching a background briefing I presented at the two day December 2004 "Workshop on Fire Fighting Foams in the Military" which Brad Williams of my group ran for ONR. Also an older proceedings article from the Marine Environmental Engineering Technical Symposium (MEETS) 2003 Arlington, VA, 21-22 August 2003. You may already have these. We are definitely interested in fire fighting foam developments but do not have active programs and have not been following recent legislative developments closely. While I had developed a roadmap for a comprehensive fire fighting foam development program which was POMed by NAVSEA, with other AFFFs on the QPL still allowed, no Operational Requirement for less environmentally damaging foam, and much more pressing claimants for Navy resources, that effort was dropped. The only task we currently have on fire fighting foam is a very small NAVSEA one supporting addressing the issue of hydrogen sulfide (H2S) generation from stagnant AFFF-seawater mixtures in shipboard piping. Brad and I had investigated mitigation strategies and possible effects on AFFF performance. MPR in currently following through for shipboard implementation, including tests they are running at NRL CBD. I do continue to interact with the Fire Fighting Foam Coalition whose web site you give as a reference for information. We have presented our work at their meetings and continue to attend doe discussions as appropriate. Do recognize they are an advocacy group, specifically not including 3M, primarily of MilSpec AFFF and component surfactant producers. They were in large part formed in my opinion for damage control so that the PFOS issue with 3M AFFF (and it does apply directly only to 3M products) would not tar their products. They have cooperated with EPA, but I feel sometimes slowly. The way EPA initially approached the PFOS matter (in my opinion) was very heavy handed and indiscriminate. This was largely the result of an administrator basing the EPA 'ruling' on language from an EPA chemist who misconstrued a definition of telomers. I was unable to convince the EPA person otherwise, even with International Union of Pure and Applied Chemistry on-line definitions. It could have threatened DuPont's telomere processes which are widely used and would have fallout on a very large fraction of their product line, unrelated to PFOS or AFFF. They had to get into the issue. 3M used an electroforming process to generate their foams. It resulted in a mixture of sulfur containing fluorosurfactants of the general class PFOS. There are probably about 90 different components, "p f " is for "perfluoro" which means all the fluorines that were possible, as opposed to other elements such as hydrogen, on the carbon structure. With only fluorines exposed around the carbon molecular backbone, these compounds are extremely resistant to degradation, and thus their long life in the environment. The other foam manufacturers use a different polymerization process (telomerization) which makes perfluorosurfactants, but does not make PFOS. It is also a more expensive process, which is probably why 3M with their patented process) had the DoD contracts so long. 3M as the only manufacturer and marketer of PFOS products saw PFOS in the environment all over the world, and knew it came from them. Think Tobacco liability. So they got out of the business. The "0" in PFOS is for octyl, meaning eight. The carbon molecular skeleton of the perfluoro part of the surfactant is eight carbon atoms long, called C-8. The 'other' foam manufacturers and the FFFC have made much of the fact that the 'other' non-PFOS foams are not C-8, but are C-6 (six carbon atoms long). (That is largely true, but they do contain a carbon chain length spread and do include perhaps 5-15% C-8 surfactants.) To some extent, the C-8 issue is an US00007860 overblown 'red herring'. The larger issue in my mind is that the telomere foams, while not purposefully containing perfluoroalkyl acid compounds, can still probably make them as degradation products. Although they are likely primarily C-6 products, (and some C-8), and are thus PFHxA (a C-6 compound, Hexyl for six) and not PFOA (a C-8 compound), they still have some as yet not completely quantitated hazard properties. 3M Australia did later develop non-fluorosurfactant fire fighting foams which we evaluated for NAVFAC. While they were not up to DoD AFFF MilSpec fire suppression performance requirements, one product was quite good and closest to it by far than any other environmentally friendly AFFF attempt. Our thought was that a product with slightly less capability, and far less environmental baggage, could be appropriate for protection needs not involving platform survivability or sailor life safety from rapidly developing large scale fires involving ordnance. This would include many land based facilities. However, after 3M started marketing the product in Asia, they made a corporate defensive decision to totally disengage from such products designed to be released into the environment. They may have sold or licensed the technology since then. Other potential fire protection approaches: There are other commercial products existing or developable related to AFFF for possible future interest. This includes the possibility of MilSpec qualified AFFF at 1% concentration for better space / weight / logistics, and alcohol resistant and high expansion (HiEx)foams, for which there are not military standards. The topic of high expansion foams is very interesting as AFFF is effective for two dimensional fuel spill / pool fires, but not effective for three dimensional fires. HiEx may serve as a total flooding mechanism for delivering water in thin films that would rapidly evaporate and efficiently attack fires both via energy abstraction and air flow obstruction. Water mist is being used as a total flooding agent in the LPD 17 Class machinery spaces, and it would be advantageous to be able to use water mist in other types of spaces and fire threat scenarios, including replacing the halon replacement systems I was instrumental in developing. The LPD 17 system was designed empirically aboard the NRL ex-USS Shadwell. The design carries over for many, but not all types, of spaces. It is difficult to see how to optimize water mist to enable it to have acceptable performance in very obstructed spaces. HiEx is essentially low density water but still higher concentrations of water than can be achieved with small drop water mist. And it flows between and around obstacles. It should work well in cluttered spaces such as flammable liquid storage rooms and be an alternative to halon replacements such as HFP. HiEx fire protection dynamics are not well characterized. The Air Force uses commercial HiEx foam systems for hanger protection. But they employ a safety factor of from 2.5 to 4 on commercial systems to cover uncertainties. Better HiEx foam suppression mechanism and dynamics characterization should allow more optimum system design for reduced impact shipboard systems. And HiEx foams do not need to contain fluorosurfactants. No PFOA or PFOS issues. Ron Sheinson ---- Original Message---From: Glover, Carl CIV CNIC HQ, N3 [mailto:carl.glover0navy.mil] Sent: Tuesday, November 06, 2007 6:54 AM To: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; Ronald S. Sheinson; Bradley A. Williams Cc: Davidson, Ross A CIV; Whalen, Shawn T LCDR NavAir 1.0, PMA251; Hunstad, Mary P CIV SEA 05; Barylski, Douglas J CIV SEA 05; John P. Farley Subject: RE: EC Governance Council Meeting Summary Memo All, as we understand the issue, we currently do not have a general plan US00007861 regarding the elimination of PFOS AFFF. To date, it has only been an issue in EU...they want it use be phased out within 5 years. Is the problem only with 3M AFFF, not the other manufacturers. New AFFF (after 2002) is not PFOS AFFF? An excellent site for information about AFFF is at http://www.fffc.org/afff.html. They have lots of great information. Good discussion topics Carl B. Glover, Jr. Director, Navy Fire & Emergency Services Commander, Navy Installations Command (CNIC) Operating Forces (N3) 2713 Mitscher Road, SW STE 300 Anacostia Annex, DC 20373-5802 Phone: 202-433-4775 (DSN 288) Cell: (202) 498-6348 E-mail: cari.giover0navy.mil ---- Original Message---From: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680 Sent: Monday, November 05, 2007 18:17 To: sheinson0code6185.nrl.navy.mil; Brad Williams Cc: Glover, Carl CIV CNIC HQ, N3; Davidson, Ross A CIV; Whalen, Shawn T LCDR NavAir 1.0, PMA251; Hunstad, Mary P CIV SEA 05; Barylski, Douglas J CIV SEA 05; John Farley Subject: FW: EC Governance Council Meeting Summary Memo Brad and Ron, Were you aware of the attached actions at the Emerging Contaminants Governance Council Meeting? If so, are there copies of supporting documents available? To your knowledge, are we now in a more dire position regarding AFFF than we were at the Workshop in December 2004? Any additional info would really be appreciated. Thanks in advance. Brian Brian Berchtold Manager/Lead Engineer, Carrier Aircraft Fire Suppression Program Crash and Salvage Lead, CVN21 Aviation IPT NSWC/CD Code 668 Damage Control and Firefighting (215)897-8683 (office) (215)897-1134 (fax) (609)432-1622 (cell) brian.berchtoid0navy.mil ---- Original Message---From: Glover, Carl CIV CNIC HQ, N3 Sent: Monday, November 05, 2007 7:03 To: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; Davidson, Ross A CIV; US00007862 Whalen, Shawn T LCDR NavAir 1.0, PMA251 Cc: Brockman, Ricky N CIV CNIC HQ Subject: FW: EC Governance Council Meeting Summary Memo Brian, I seem to remember you had someone who was participating in the EPA group a year or so back on the PFOA issue?? Please review attached and comment. Ross and Shawn ... FYI Thanks Carl Carl B. Glover, Jr. Director, Navy Fire & Emergency Services Commander, Navy Installations Command (CNIC) Operating Forces (N3) 2713 Mitscher Road, SW STE 300 Anacostia Annex, DC 20373-5802 Phone: 202-433-4775 (DSN 288) Cell: (202) 498-6348 E-mail: carl.glover0navy.mil ---- Original Message---From: Kaminski, Art, OSD-ATL [mailto:Art.Kaminski0osd.mil] Sent: Monday, November 05, 2007 6:41 To: AF1; AF2; Armyl; Bouley GS14 Paul J; DLA1; DLA2; DUSD(I&E); Fire Academy; Kaminski, Art, OSD-ATL; Means, Dale F Mr IMCOM/MPRI; Glover, Carl CIV CNIC HQ, N3; Brockman, Ricky N CIV CNIC HQ; Roush Allen Ctr AF/A7CXR; Ruffini GS14 Thomas A; USMC-mil2 Subject: FW: EC Governance Council Meeting Summary Memo - Please note section on PFOA - What are we doing in Services to phase out ? limited training etc? Thanks - Art Art Kaminski DDESB-OSD Liaison Department of Defense Explosives Safety Board Environmental Readiness & Safety ODUSD(Installations & Environment) Office of the Secretary of Defense 3400 Defense Pentagon Washington DC 20301-3400 Phone: (703) 604-1621 (DSN 664) FAX: (703) 607-1244 art.kaminski0osd.mil "Eliminate Illness & Injury from DoD" ---- Original Message---From: Yaroschak, Paul, Mr, OSD-ATL Sent: Thursday, November 01, 2007 12:24 PM To: Smith, Bradley, Mr, OSD-ATL; Marqusee, Jeffrey, Dr, OSD-ATL; Seibert, John, Mr, OSD-ATL; Asiello, David, Mr, OSD-ATL; Bowling, Curtis, Mr, OSD-ATL; Choudhury, Shah, Mr, OSD-ATL; Thomas, Jonathan, LtCol, OSD-ATL; Ann Engelberger (Ann.Engelberger0dla.mil); Morefield, Deborah A CIV OASN (I&E), ODASN (E); Harrell, Rob A CIV OPNAV, CNO N45; Leblanc, Carole Ms OSD ATL; Mach, Richard G CIV OASN (I&E); Indermark Michele Civ SAF/IEE; Misha Turner (CMC); Moore, Wendell A COL ASA(I&E); Newsome, Richard E Mr ASA-I&E; Ross Elaine Civ AF/A7CAR; Jossell, Stanley J CDR USN, ODASN (Safety); Weisman Wade Lt Col SAF/IE Cc: Cunniff, Shannon, Ms, OSD-ATL; Sherri Hutchens (Sherri.Hutchens0us.army.mil); Long Cornell Civ AFIOH/RSRE; Steve Kistner (CHPPM); Yvonne Walker NEHC; Bonnie Packer (AEC); Colmie, Karen, Ms, DoD OGC; Dr. Vivian Rush; Ed Corl (William.Corl0Navy.Mil); Engbert, James NSWCDD; Garg, Malcolm J ACSIM; Gonser, Kent (AEC); Greg O'Conner (ARDEC); Guinivan, Thomas L USAEC; Harvey, Gregory J Civ ASC/ENVR; Laurie Roszell US00007863 (CHPPM); Palur Gunasekar (EHEL); Randy Cramer (randall.cramer0navy.mil); Sheets, David A Mr OASA(I&E); Steve Larson (ERDC); Wilfred McCain (wilfred.mccain0us.army.mil); Donald Yee (ARDEC); Wolfe, Hew Mr ASA (I&E); Isleib, Chris Mr OSD PA; Marqusee, Jeffrey, Dr, OSD-ATL; Johnson, George (OSD_HA); Stemniski, Peter CIVAMCBT; Tretiak, Stefan, Mr, OSD-ATL; Weisman Wade Lt Col SAF/IE Subject: EC Governance Council Meeting Summary Memo Colleagues: Attached FYI. Paul US00007864