Document qkYy8p4rBBmqZeQOpkejaLkyj

MILITARY SPECIFICATION 24385F AQUEOUS FILM FORMING FOAM (AFFF) CONCENTRATE ISSUE: The current military specification for firefighting foams mandates the use of fluorinated chemicals that are harmful to military personnel and the environment. New technologies are available that avoid these risks, but the specification has not been updated to allow their use. What must be done to correct this situation? Original Military Specification Issued in the 1970's. Essentially right, AFFF was introduced to the Navy in 1970 (original MILSPEC was in 1967). Current Military Specification for firefighting foam dated August, 1994 (F Version) Correct. Requires all Products on the Qualified Products List (QPL) to contain fluorinated chemicals, which was the state of the art in the 1960's. Current MILSPEC Title is "Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater". The title for the UL 162 is "Foam Equipment and Liquid Concentrate". The current MILSPEC is specific for Film Forming Agents that provide rapid extinguishm ent (locks vapor at the fuel interface and also limits fuel transport through the foam blanket. The Specification does not allow for newer alternative technologies that are safer and less expensive Our main concern w ith Safety is w ith lim iting personnel exposure to large unconfined fires which may include ordnance, flight crew rescue, and lim it damage to vital assets. As far as costs, COTS AFFF is typically $20.00/gallon. Not sure w hat the M ilita ry pays when then buy in bulk quantities, but I would assume tha t it is less than the cost in the commercial market. Nl rue" m ilitary cost for ..I.I., which may be substantially lower t a CO.I.S Cost. Specific problems with current specification: o The fluorinated chemicals used in current Military Specification are: Environmentally Persistent (True) Bio accumulative ( Not true, only applies to 3-M PFOS AFFF, which was removed from the market in 2002) Toxic .I.in" h u l l ii ims.'i" OF if lo w "lin'd the acute toxicity to mairiii i- Ini' i- -p- iialllly fish) is greater for 1.. foams since they have higher levels of I.lydirocairlbon surfactants). o Fluorinated foams will remain in the environment for centuries, no biodegradation AFFF "concentrate" typically contains 2% flurosurfactants, 2-5% hydrocarbon surfactants, and 15-20% solvents. The rest of the form ulation is w ater (73-81%). This means that 98% of AFFF "concentrate" is biodegradable. NOTE: W e do not introduce AFFF "concentrate" into the environm ent. h I i iiilin dm (liiih lli in mi oiniiii nl i I I I ' lu tio n s .I.ype 6 (94% w ate r a n d 1 l l l i m i l |> i t I i ml I I I I, so the true am ount <i I I I introduced into the einv Iiron m erit is 99.45.99.95% lbHodeg rad alblie. o The 2015 USEPA Voluntary Stewardship Program targets: Elimination (99.9%) of Toxic Fluorosurfactants (I I'd</I I,now where the 99.9% figure came from) 2015 Compliance Date (I.Y15) All Current QPL Products must be re-qualified to Comply (Correct) Military Firefighters cannot conduct live training with Fluorinated Foams due to the safety and environmental concerns. The resulting lack of live fire training affects preparedness US00005826 TOTALLY MISLEADING. W e conduct training in Propane Training Facilities and do not use any actual firefighting agents. In these type of trainers the agent does not suppress the fire. The am ount of firefighting w ater applied is collected in a small tray and a sensor turns off the propane fire once an appropriate am ount of agent (water) has been applied. Additionally, all foam manufacturers have a training foam simulant (including Solberg) that is recommended for training. This is to help lim it foaming agents into municipal w ater treatm ent plants. o Military Specification foam is the most expensive of all firefighting foams Fluorine is the most expensive ingredient (Correct) Military Specification foam requires the greatest level of fluorine (.I.he level of fluorine has dramatically been reduced over the years). Military Specification foam is the most environmentally persistent of all foams ( I rue but the Navy has gone through a number measures to significantly reduce any ..I.I."Solutions" Into the environ merit). I understand that there are newer technologies available that avoid these problems, but those products are not allowed under the outdated specification: Re-Healing Fluorine Free Firefighting Foam o 100% Biodegradable increased acute toxicity In comparison id th e ir oxidation can depletion of oxygen, which may Increase th e ir COD as well as the iraliu ul IM 1* Pi <( i| u I.lyirdocairlbon surfactants provide food for the Aerobic Organisms In the Ocean ar , illy multiply arid continue to consume Oxygen. .I.his was a large environm ental Issue during the Deep W ater I.loirlzon oil spill In the Gulf of Mexico. o More effective in fighting fires, extinguishes more rapidly and requires less reapplication than fluorinated foams. (This statem ent only applies to COMMERCIAL (i.e., UL 162 AFFF) qualified AFFF foams not MILSPEC AFFF) o Globally Approved to all current International Standards UL, FM, ICAO, EN, ULC, SSL, Among others Fluorine Free foam does not expose Military Personnel to dangerous PBT Chemicals Lack of fluorine allows live exercises that improve readiness Because of lack of fluorine, cost is significantly less Sample list of Current Customers: o Statoil Norway o ConocoPhillips o British Petroleum o All Australian Airports (Not M ilitary) o Copenhagen, Frankfurt, Dubai, Manchester Airports (Not NATO M ilitary) a. Enbridge b. Flint Hills Refinery c. Alert Disaster Control (FAA requires the use of MILSPEC AFFF at all U.S. civilian Airports) What can be done to modify the specification to allow fluorine alternatives? I hi" i mi' i pi iii hi ul, r In <i iiiip ll, ill hi I hi" i i "ii i nil I I I I ( 1 u r n I id hip pi i i in qualified the I lire Ade 2000 Iype 6 I I product, which the first I I product to me t the Mil.SPEC arid also the ERA PI... (C8) requirements. NAVSEA will also be looking Into the future to sec J(: US00005827 o|diifir i| II..airline.1.iree 1.cram (1.3) or a 1.Iluoirllne.1. aqueous layer on the fuel surf. tha t will riot req"n ill..irosuirfactant to form an US00005828