Document k6qy4Dojwn5Gb4BbXJX8VN7y0

Headquarters U.S. Air Force Integrity - Service - Excellence Replacement of Legacy AFFF COAs AFCEC/CXF 14Aug 15 Version 2 US00005235 Executive Summary Purpose: Provide Courses of Action (COAs) to replace AF inventory of legacy AFFF (Aqueous Film Forming Foam) ^ Findings: AF wants to transition to a "better" AFFF to improve health / environmental posture, offset future environmental liabilities and maintain mission critical me fighting agent performance capabilities Estimated cost to replace legacy (PFOS) AFFF in fixed systems and fire vehicles ranges from an immediate cost of $10.4M to $74.6M (based on FY15 costs) over 5 6 years, with cost reductions possible if efficiencies related to flushing can be achieved Disposal cost information based on $10.00 per gallon (5-gallon pails); cost reductions possible for bulk disposal methods AF has 2.01 M gallons of PFOS and/or mixed PFOS/PFOA AFFF in installed systems, fire vehicles and stockpiles (includes AFRC/ANG) Plan provides three COAs: two short-term & one long-term solution Recommendation: COA 2 as it ultimately satisfies all EPA and AF fire fighting concerns 2 US00005236 Tasking SAF/IE/IEE tasked key stakeholders to develop a plan to eliminate legacy AFFF from AF inventory A4CX directed AFCEC to develop COAs, costs, and interim guidance related to use and replacement of legacy AFFF AFCEC developed three COAs COAs 1 & 3 provide immediate action, less initial cost; allows out year funding forecast COA 2 provides long-term solution but is costly AF Fire Chief issued temporary directive to cease all testing/operational checks of ARFF vehicle AFFF systems nnrrnrnfflffffff Problem Statement and Situation What is AFFF? AFFF is a fire suppressant containing fluorinated surfactants for lowsurface tension used to extinguish flammable liquid fires Periluorooctane sulfonate (PFOS) is a long-chain perfluorinated compound (PFC) either present in legacy stocks of AFFF or a potential breakdown product of PFOS-based AFFF Periluorooctanoic acid (PFOA) is also a long-chain PFC, and while not an ingredient in AFFF, long-chain fluoroteleomer-based AFFF can break down to PFOA Prior to 2000, mostfluorosurfactants used in the AFFF MilSpecwere PFOSbased(MilSpec PFOS-based AFFFs are no longer available) Use of PFOS-based AFFF not currently restricted by US regulations EPA Fact Sheet- PFOS / PFOA - A t a Glance Legacy PFOS-based AFFF: No longer commercially available Blended C8-C6-based AFFF: Most environmentally-friendly MilSpecapproved AFFF currently available, but can potentially degrade into the environmentto form PFOA C6-based AFFF*: Industry moving to this AFFF. Commercially available, but not yet MilSpec-approved. One manufacturer now in progress to obtain MilSpec-approval, expected by end of 2015 Fluorine-Free Agent: Commercially available, but not MilSpecapproved. Early testing revealed potential problems on ability to meet MilSpec. Likely would not be a "drop-in" replacement agent and probably would require modified fire fighting techniques/procedures * Potential for some >C6 to occur as a result of manufacturing process (quantity is TBD) 3 US00005237 Current Status Current Situation PFOS and PFOA considered Emerging Contaminates that have resulted in EPA and state regulators directing corrective actions at several AF locations (Pease, Horsham, Eielson) AF Restoration Program (active and BRAC) anticipates hundreds of locations to have contamination above PHA levels, and accordingly have initially programmed ~$250M in the FYDP to address situation AF inventory composed mostly of legacy PFOS-based AFFF Where more environ mental ly-friendly, post-2000 AFFF have been used, those stocks have largely been intermixed with the legacy AFFF AF desires to transition to a "better" AFFF to improve health / environmental posture and off-set future environmental liabilities Current AF Inventory of AFFF Which AFFF should be AF replacement? C6-based AFFF is currently the industry "target" AFFF, based in large part on EPA PFOA Stewardship Program that has garnered industry support to withdraw from sale any fluorosurfactantwith a carbon chain length greater than C6 by 2015 Accordingly, AF should transition to C6-based AFFF that will soon be available...ratherthan transition to a blended C8-C6 based AFFF that still has potential environmental issues Cost, effort and benefits of AFFF transition should be invested in long term solution Required AF Inventory of AFFF Application Fixed System s* ARFF Vehicles** Stockpile (PFOS-based) Stockpile (blended C8-C6) Total Gallons (K) 1,340 203 117 357 2,017 * Includes estimated 500K for ANG and Reserve systems ** Includes ANG and Reserve ARFF vehicles (Quantities based on draftAFCEC inputto TMT tasking) A pplication Fixed Systems* ARFF Vehicles** ARFF Resupply Stockpile Total Gallons (K) 1,340 203 203 1,746 * Includes estimated 500K for ANG and Reserve systems ** Includes ANG and Reserve ARFF vehicles (Quantities based on draft AFCEC inputto TMT tasking) 4 US00005238 COA 1 COA 1 is a short-term solution that immediately addresses fire vehicles and delays facility installed systems due to their static nature Incinerate legacy AFFF in fire station stockpiles Rinse(3X)/incinerate AFFF & effluent from tanks in fire vehicles and replace with available MilSpec C8 certified AFFF in inventory Purchase MilSpec AFFF to satisfy resupply requirement Delay action on facility installed systems until C6 AFFF is approved by NAVSEA; will require funding in out years (New bladders/AFFF) PROS: Immediately addresses potential AFFF discharges by firefighters Allows out year POMing action to address installed systems incrementally CONS: Does not eliminate EPA concerns current C8 MilSpec AFFF has been found to degrade into PFOA Potential exists for duplicative funding costs 5 US00005239 U.S. A IR F O R C E JAN 2016 APR 2016 AFFF Replacement COA 1 (FY15 Dollars) JUL 2016 OCT 20XX OCT 20XX OCT 20XX OCT 20XX OCT 20XX .1 M $1.2M Estimated cost ($22.00 gallon) to purchase AFFF (49,000 gallons) Immediate incineration of 3M legacy AFFF (117,205 gallons) $2.7M $2.7M $2.7M <=l N/A N/A N/A $1.1M Estimated cost assumes $10.00 per gallon (5-gallon pails) for ______ incineration of AFFF and effluent (1.2M gallons)______ $1.1M $1.1M $1.1M $1.1M Facility replacement/disposltion can be delayed since they are static and pose minimal threat to the environment COA allows facilities to be delayed until funding is available $7.9M $7.9M $7.9M $7.9M $7.9M Estimated cost ($22.00 gallon) is based on availability of approved C6 AFFF (1.3M gallons) & bladder tank replacement Estimated cost assumes $10.00 per gallon (5-gallon pails) for incineration $1.6M $1.6M $1.6M $1.6M $1.6M $2.3M $2.7M $2.7M $2.7M $10.6M $10.6M $10.6M $10.6M FY16/01 FY16/02 FY16/03 FY16/04 FYXX FYXX FYXX FYXX FY16 total vehicle cost = $10.4M IMMEDIATE TOTAL = $10.4 FYXX-XX total facility cost = $53M (Assumes delay) Total over the FYDP = $63.4 Integrity - Service - Excellence $10.6M FYXX US00005240 U.S. A IR F O R C E COA 2 COA 2 is a long-term solution that ultimately satisfies all AFFF fire fighting requirements and eliminates EPA environmental concerns Incinerate legacy AFFF in fire station stockpiles Rinse(3X)/incinerate AFFF & effluent in fire vehicles and replace it with C6 AFFF when MilSpec-approved by NAVSEA Replace/incinerate legacy AFFF in resupply stockpile with C6AFFF when MilSpec-approved by NAVSEA Replace/incinerate legacy AFFF in facility installed systems with C6AFFF when MilSpec-approved by NAVSEA PROS: Replaces all AFFF in AF inventory with the most environmentally friendly product commercially available Most cost effective life cycle approach Does not alter fire fighting tactics, techniques and procedures CONS: Have to wait for NAVSEA MilSpec certification (expected by EOY15), anticipate successful outcome Largest near term costs Integrity - Service - Excellence 7 US00005241 w U.S. A IR F O R C E 2016 $3M AFFF Replacement COA 2 (FY15 Dollars) APR 2016 JUL 2016 OCT 2016 OCT 2017 OCT 2018 OCT 2019 OCT 2020 __________________I ..................................I_________________I_________________ $3M $3M Estimated cost ($22.00 ga Ion) for approved C;6 AFFF (406,236 gallons) Immediate incineration of 3M legacy AFFF 117,205 gallons) /chicle , $1.2M $3.8M $3.8M $3.8M <=l Estimated cost assumes $10.00 per gallon (5-gallon pails) for incineration of AFFF and effluent (1.5M gallons), includes 356,859 gallons in stockpile N/A N/A N/A $1.1M $1.1M $1.1M $1.1M $1.1M $1.2M FY16/01 Facility replacement/disposition can be delayed since they are static and pose minimal threat to the environment $6.8M $6.8M $6.8M $7.9M $7.9M $7.9M $7.9M $7.9M Estimated cost ($22.00 gallon) for approved C6 AFFF (840,000 gallons) & bladder tank replacement $1.6M $1.6M $1.6M $1.6M $1.6M I istimated cost assi mes $10.00 per galk n (5-gallon pails) f >r incineration $10.6M $10.6M $10.6M $10.6M $10.6M FY16/02 FY16/03 FY16/04 FY17 FY18 FY19 FY16 total vehicle cost = $21.6M FY17-21 total facility cost = $53M TOTAL OVER THE FYDP = $74.6M Integrity - Service - Excellence FY20 FY21 US00005242 U.S. A IR F O R C E COA 3 COA 3 is a short-term solution that eliminates potential contamination by firefighters but uses current AFFF in installed systems where contamination is unlikely or can be contained Incinerate legacy AFFF in fire station stockpiles Rinse(3X)/incinerate AFFF & effluent in fire vehicles and replace it with C6 AFFF when MilSpec-approved by NAVSEA Replace/incinerate legacy AFFF in resupply stockpile with C6AFFF when MilSpec-approved by NAVSEA Use existing C8AFFF for facility installed systems and purchase C6for remaining systems PROS: Replaces all AFFF in fire vehicles with the most environmentally friendly product commercially available Utilizes existing stock of C8 in low-threat environment CONS: Does not eliminate EPA concerns and the potential exists for future funding action to replace C8AFFF Integrity - Service - Excellence 9 US00005243 w U.S. A IR F O R C E 2016 AFFF Replacement COA (FY15 Dollars) APR 2016 JUL 2016 OCT 2016 OCT 2017 OCT 2018 OCT 2019 OCT 2020 /chicle , $1.2M $3M $3M $3M Immediate incineration of 3M legacy AFFF Estimated cost ($22.00 gallon) for approved C6 AFFF (406,236 gallons) $2.7M $2.7M $2.7M <^=i Estimated cost assumes $10.00 per gallon (5-gallon pails) for incineration of AFFF and effluent (1.2M gallons) N/A N/A N/A $1.1M $1.1M $1.1M $1.1M $1.1M Use current stockpiles of AFFF for initial _____________ replacement____________ Facility replacement/disposition can be delayed since they are static and pose minimal threat to the environment $2.2M $2.2M $9.4M $9.4M $9.4M Estimated cost ($22.00 gallon) is based on availability of approved C6 AFFF (983,141 gallons) 7 bladder tank replacement x x xx Estimated cost assumes $10.00 per gallon (5-gallon pails) for incineration. $1.6M $1.6M $1.6M $1.6M $1.6M $1.2M $5.7M $5.7M $5.7M $4.9M $4.9M $12.1 M FY16/01 FY16/02 FY16/03 FY16/04 FY17 FY18 FY19 FY16 total vehicle cost = $18.3M FY17-21 total facility cost = $46.1 M TOTAL OVER THE FYDP = $64.4 Integrity - Service - Excellence $12.1 M $12.1 M FY20 FY21 US00005244 Plan Implementation Follow-up actions Determine if there is an on-site method to reduce amount of flushing waste (i.e., drying bed, GAC w/ sanitary sewer)... now using same costs as disposal of full strength AFFF Refine disposal and service contract costs Validate amount and timing to support expected disposal needs After costs are refined and options chosen, confirm "per year" costs ... adjust timeline and approach to meet available budget if needed Implementation approach Begin with disposal of excess backup stock, then AFFF in ARFF vehicles, and lastly fixed systems (less chance of contamination) Best to replace AFFF in ARFF vehicles first, but may need to adjust if flushing is required and efficiencies can be gained by having same service contract do flushing of both ARFF and fixed systems on an installation wide basis Priority given to US locations not overseas Timeline / targets may be adjusted as "best practices" are gained P la n Tim eline* TBD based on COA selection Policy/ Guidance Policy: Existing AFIs and OSD documents address PFOS/PFOAfrom a an emerging contaminate/ cleanup perspective, as well as from a public health drinking water perspective The cleanup and public health com munties are currently expand ing / clarifying responsibilities and procedures to improve protection of environment and personnel There are various "fact sheets" from EPA, OSD, AFCEC and Fire Fighting Foam Coalition related to the emerging risk of AFFF, as well as various Working Groups to address the AFFF and larger PFOS/PFA issue Pending SAF/IEE decision to proceed with replacement of legacy AFFF, A4C and AFCEC staffs will work with SAF/IEE to develop requisite policy and implementing instructions 1 1 US00005245