Document re0LrQ50mo5MRQd5aKV82j8Gv

From: To: CC: Sent: Subject: Barylski, Douglas J CIV NAVSEA HQ, SEA 05 Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; 'Darwin, Bob' Hunstad, Mary P CIV NAVSEA HQ, SEA 05; Davidson, Ross A CIV; Whalen, Shawn T CDR NavAir 1.0, PMA251; scheffey, Joe 8/28/2008 11:31:31 AM RE: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c As a matter of protocol, I am the custodian of MIL-F-24385, and any actions associated with mil spec AFFF should be handled through me. That said, the OSD (l&E) memo does not assign new actions, and does not have any new information. The issue seems to be that EPA is concerned with PFOA, but PFOA has not been listed as PBT (persistent bioaccumulative and toxic). Since PFOA is not listed as PBT, EPA authority is limited. DoD is correct that we don't see any significant impact, and industry is looking at PFOA. This isn't something you just look up data for products on the QPL. 3M was the only AFFF mfgr that had 8-carbon chain constituents (PFOA has an 8-carbon chain). But apparently trace amounts of 8-carbon chain fluorosurfactants may be in some products, including possibly AFFF. The AFFF mfgrs are not responsible for controlling these trace materials, but rather the fluorosurfactant mfgrs, such as Dupont. I understand EPA is working with these mfgrs to consider manufacturing process changes that would further control this trace 8-carbon chain production. This is not an AFFF issue, as AFFF is only about 5% of the market for fluorosurfactants, but is potentially a broad manufacturing issue. But as I noted, since PFOA is not PBT, EPA cannot regulate it. There is also the potential for future regulation that would prevent use of stocks of PFOS containg materials, such as 3M AFFF. By the time such regulation comes out, we won't have any identifiable 3M aboard ship. Since 3M AFFF hasn't been produced for like seven years, there is very little left. I don't recommend writing up a paper on this, unless Bob has some new information to add. If you want to read more on the subject, I can send a couple of articles. R/DB ......Original Message...... From: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680 Sent: Thursday, August 28, 2008 6:03 To: Darwin, Bob Cc: Hunstad, Mary P CIV NAVSEA HQ, SEA 05; Barylski, Douglas J CIV NAVSEA HQ, SEA 05; Davidson, Ross A CIV; Whalen, Shawn T CDR NavAir 1.0, PMA251 ; scheffey, Joe Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c Hi Bob, Could you please forward this to the person at Hughes that has been charged with oversight on the AFFF issues in support of W1819. I think it would be prudent to go through all the current individual Mil-Spec AFFF products on the QPL and assess if there is an impact to that product via the PFOA phase-out and if so, what mitigation is planned by the mfr/supplier to address the impact. A quick little report on the results of the assessment would be very useful for us. Thanks for the help. 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) US00002939 brian.berchtold@navy.mil ......Original Message...... From: Davidson, Ross A CIV Sent: Wednesday, August 27, 2008 18:12 To: Berchtold, Brian D CIV NSWCCD Philadelphia, 6680; Whalen, Shawn T CDR NavAir 1.0, PMA251 Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c Shawn and Brian, In case you have not seen this. The real info is in the attachment. Thanks, Ross ......Original Message...... From: Bowman, Howard L CIV Sent: Wednesday, August 27, 2008 13:57 To: Davidson, Ross ACIV; Wilson, John E. USNCIV NAVAIR 31600, NA, 101F; 'bdarwin@haifire.com'; 'danv@haifire.com' Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c FYI. ......Original Message...... From: Merwin, Lawrence CIV NAVAIR 498200D Sent: Wednesday, August 27, 2008 7:31 To: Guenthner, Andrew J; Fallis, Stephen; Nelson, John G NAVAIR, 434000D; Webber, Cynthia K; Bowman, Howard L CIV; Quintana, Roxanne CIV NAVAIR 4T42300D Cc: Nissan, Robin A Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c Will clearly impact seals/gaskets and AFFF. ......Original Message...... From: Sullivan, Roger M CIV Sent: Tuesday, August 26, 2008 14:28 To: Merwin, Lawrence CIV NAVAIR 498200D Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c Larry, This came across my desk so I thought I would pass it on to you in case you see any opportunities for wing 6 or anticipate any problems for the Navy with this phase-out. Sincerely, Roger ......Original Message...... From: Smith, Donna [mailto:donna.smith2@navy.mil] Sent: Friday, August 22, 2008 10:35 To: Code 35 Subject: FW: "E" information only - Phase-out of Perfluorooctanoic Acide (PFOA) - 2008UGENERAL-014345c For yo 2008UGENERAL-014345c.pdf ur information/retention only. V/R, Donna US00002940