R 181817Z APR 24
MARADMIN 185/24
MSGID/GENADMIN/CMC L WASHINGTON DC//
SUBJ/POLICY AND PROCEDURES FOR THE PHASEOUT OF FLUORINATED AQUEOUS FILM FORMING FOAM (AFFF) AND ALCOHOL RESISTANT AFFF (AR-AFFF) FIRE SUPPRESSION SYSTEMS (FSS) IN MARINE CORPS FACILITIES//
REF/A/PUBLIC LAW 116-92/20 DEC 19//
REF/B/DOC/DEPARTMENT OF AIR FORCE STUDY ON AFFF FSS/31 MAR 21//
REF/C/DOC/UNIFIED FACILITIES CRITERIA (UFC) 3-600-01 CH6/6 MAY 21//
REF/D/DOC/UFC 4-211-01 CH3/20 APR 21//
REF/E/DOC/NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 409/2022//
REF/F/DOC/MIL-PRF-32725/17 AUG 23//
REF/G/DOC/CMC GF LTR 11000/28 MAR 24//
REF/H/DOC/MARINE CORPS ORDER (MCO) 5090.2 ENIVRONMENTAL COMPLIANCE AND PROTECTION PROGRAM/18 JUN 18//
REF/I/DOC/AFFF MARADMIN REPORTING TEMPLATE/04 APR 24//
NARR/: REF A IS NATIONAL DEFENSE AUTHORIZATION ACT FOR FISCAL YEAR 2020; REF B IS DEPARTMENT OF AIR FORCE FACILITIES RISK ASSESSMENT REPORT ON AFFF; REF C IS UNIFIED FACILITIES CRITERIA (UFC) FOR FIRE PROTECTION ENGINEERING FOR FACILITIES; REF D IS UFC FOR AIRCRAFT MAINTENANCE HANGARS, CHANGE THREE; REF E IS NFPA STANDARD ON AIRCRAFT HANGARS; REF F IS MILSPEC FOR FIRE EXTINGUISHING AGENT, FLUORINE-FREE FOAM (F3) LIQUID CONCENTRATE, FOR LAND-BASED, FRESH WATER APPLICATIONS; REF G IS HEADQUARTERS MARINE CORPS FACILITIES (GF) CANCELLATION OF IGNITABLE LIQUID DRAINAGE FLOOR ASSEMBLY (ILDFA) GUIDANCE FOR MILITARY CONSTRUCTION HANGAR PROJECTS. REF H MCO 5090.2 PROVIDES GUIDANCE ON SPILL PREVENTION AND ENIVRONMENTAL COMPLIANCE PLANNING; REF I IS MCICOM AFFF MARADMIN REPORTING TEMPLATE TO PROVIDE ACTION STATUS DESCRIBED HEREIN IN SECTION 3., 4., AND 5.//
POC/N. R. SPURLING/CIV/MCICOM GF-PW/HQMC/ 571-256-2785/DSN 260-2785/EMAIL: NICHOLAS.SPURLING@USMC.MIL//
GENTEXT/REMARKS/1.  Purpose. To establish policy and procedures for the phase-out of fluorinated AFFF and AR-AFFF FSS in Marine Corps facilities, both inside (CONUS) and outside the Continental United States (OCONUS), to support compliance with the Congressionally mandated phase-out of AFFF by 1 October 2024 (ref (a)). This policy does not apply to Marine Corps tactical nd non-tactical vehicles.
2.  Situation.
2.a.  The Assistant Secretary of the Air Force for Installations, Environment, and Energy led a joint effort across the Departments of the Air Force, Army, and Navy along with the Defense Logistics Agency to assess risks concerning replacing AFFF FSS in DoD facilities.
2.b.  After reviewing 32 years of historical data and 15 years of safety mishap data (as of 2021), the assessment team did not find a single instance where an aircraft fuel-related fire in a hangar resulted in the loss of an aircraft or life (ref (b)).
2.c.  The only aircraft fuel-related fire in the past 32 years in the DoD was suppressed by a water deluge system. The historical data in ref (b) revealed a trend of inadvertent activation of AFFF FSS across the DoD with 84 inadvertent activations over the past 15 years. The financial cost associated with these mishaps was in excess of $24.5 million and contact with chemicals in the foam has caused one death, injured 21 people, and damaged more than 120 aircraft.
2.d.  In Fiscal Year (FY) 23, two Marine Corps accidental AFFF hangar releases alone are expected to cost over $7.5 million for cleanup, treatment, and disposal.
3.  Mission
3.a. United States Marine Corps Installations will cease the use of AFFF and AR-AFFF products in facilities in accordance with ref (a) not later than 60 days from MARADMIN release, with the exception of Category 1 and Category 2 facilities described herein in 5.b.1.a and 5.b.2.a, and enact short, medium, and long term mitigations continued within.
4. Execution
4.a Marine Corps Regional Command and Installations shall take the following actions.
4.a.1. Immediately cease purchasing AFFF and AR-AFFF products and equipment for facilities. Purchase of fluorinated AFFF and AR-AFFF (i.e., containing more than one part per trillion per-or polyfluoroalkyl substances) is prohibited.
4.a.2. No later than 15 days of the issuance of this policy, all installations and Regional Commands shall provide a Facilities point of contact (POC), an Environmental POC, and a Fire Protection POC to support coordination and execution of this policy. Name, email address, phone number, and title shall be provided for each POC via MCICOM POC described herein in 8.a.
4.a.3. No later than 45 days of the issuance of this policy, categorize all hangars and other facilities using a fluorinated AFFF or AR-AFFF FSS into one of three categories as prescribed in 5.b.
4.a.4. No later than 45 days of the issuance of this policy, develop, implement, and enforce local fire and safety, operational, risk mitigation, and maintenance procedures to ensure compliance with this policy and continued safe operation of activities within facilities as prescribed in par 5. Defueling of aircraft is not required. Installation and Unit Commanders shall provide written notification to MCICOM POC described herein section 8.a. in the event they are unable to implement.
4.a.5. No later than 60 days of the issuance of this policy, deactivate and secure AFFF/AR-AFFF systems (Lockout-Tagout) for all Category 3 facilities (par 5.b.3) to prevent inadvertent discharge and environmental impacts as prescribed in 5.c. Provide written notification to MCICOM POC described herein section 8.a. in the event they are unable to deactivate and secure AFFF/AR-AFFF systems within the prescribed deadline.
4.a.6. No later than 180 days of issuance of this policy develop and submit FSS conversion projects to meet requirements associated with their designated facilities category via the Facilities Integration Website (FI Web) as prescribed in 5.d.
4.a.7. No later than 180 days of issuance of this policy Installations that require spill containment capabilities shall submit requests to MCICOM via FI Web as prescribed in 5.e.
4.b. Marine Corps Installations Command (MCICOM) Facilities Directorate shall take the following actions.
4.b.1. No later than 90 days of issuance of this policy distribute a phase-out plan to remove AFFF and AR-AFFF from all facilities as prescribed in 5.f.
5.  Coordinating Instructions
5.a.  Fluorinated AFFF and AR-AFFF FSS shall not be utilized in any existing facility or incorporated into facilities planned for FY24 and beyond.
5.b. AFFF/AR-AFFF Facility Categorization for existing facilities. All hangars and other facilities with fluorinated AFFF or AR-AFFF FSS shall be categorized by the following criteria.
5.b.1. Category 1 Facility.
5.b.1.a. Definition. Hangar with a fluorinated AFFF or AR-AFFF FSS where the total loss of the facility or the loss of the aircraft/assets serviced inside would result in mission failure at the Department of Defense, United States Marine Corps, Combatant Command or Sub-unified Command level. Category 1 designation may also be considered for Host-Nation or other basing locations with unique environmental requirements or operational concerns. Hangars supporting Marine Helicopter Squadron 1 (HMX-1) are the only currently approved Marine Corps Category 1 facilities. Marine Forces Command (MARFORCOM), Marine Forces Pacific (MARFORPAC), and Marine Forces Reserve (MARFORRES) may submit requests for additional Category 1 designations to Marine Corps Installations Command (MCICOM) via Headquarters, Marine Corps Plans, Policies & Operations (PP&O). MCICOM regions seeking additional Category 1 designations due to host-nation or other local basing concerns shall submit requests directly to MCICOC described herein section 8a. Requests for Category 1 designation must be received no later than 45 days following issuance of this policy. Requests must include a detail explanation on why the facility should be designated as Category1.
5.b.1.b. Requirements. All Category 1 facilities shall be replaced with an approved F3 foam that meets the requirements of ref (f). Initial replacement AFFF/AR- AFFF with F3 will be performed as part of the Army Corps of Engineers (USACE) Multiple Award Task Order Contract (MATOC) described in paragraph 5.f. Aircraft hangar bays shall be considered extra hazard occupancies when referring to ref (c). Installations with Category 1 facilities shall coordinate with MCICOM POC described herein section 8.a. to immediately plan, program, and execute these conversion requirements.
5.b.2. Category 2 Facility.
5.b.2.a. Definition. Facilities (generally non-hangar facilities) with a fluorinated AFFF or AR-AFFF FSS where the materials stored or used inside are incompatible with a water-only FSS (e.g., bulk fuel storage, flammable/ combustible/ hazardous material storage, boiler plants). MCICOM installations shall identify Category 2 facilities in consultation with a licensed Fire Protection Engineer and submit requests to MCICOM POC described herein section 8.a.  no later than 45 days of issuance of this policy. Installation and Unit Commanders shall provide written notification to MCICOM POC described here in section 8.a. in the event they are unable to implement.
5.b.2.b. Requirements. Fluorinated AFFF and AR-AFFF for Category 2 facilities shall be replaced with an approved F3 foam that meets the requirements of ref (f). Initial replacement AFFF/AR-AFFF with F3 will be performed as part of the Army Corps of Engineers (USACE) Multiple Award Task Order Contract (MATOC) described in paragraph 5.f.
5.b.3. Category 3 Facility.
5.b.3.a. Definition. All facilities with a fluorinated AFFF or AR-AFFF FSS not designated as Category 1 or Category 2. These represent the majority of our facilities that currently use fluorinated AFFF and AR-AFFF.
5.b.3.b. Requirement. Installations with Category 3 facilities shall work with MCICOM to plan, program, and execute replacement of the fluorinated AFFF or AR-AFFF FSS with an automatic water sprinkler system and decommission the foam system of the AFFF/AR-AFFF FSS and only utilize the water suppression feature. MCICOM will not be implementing Ignitable Liquid Drain Floor Assembly (ILDFA) in hangars and non-hangar facilities for the near term. MCICOM will reassess implementing ILDFA pending successful completion of a pilot project (P-201 MCAS Miramar) and positive operational assessment by tenant units.
5.c. AFFF/AR-AFFF Lockout-Tagout Procedures. Installations shall deactivate and secure AFFF/AR-AFFF systems (Lockout-Tagout) for all Category 3 facilities to prevent inadvertent discharge and environmental impacts. Category 1 and Category 2 facilities will continue to utilize the AFFF FPS until the activities to meet facility requirements described herein 5.b.1.a, 5.b.1.b, 5.b.2.a and 5.b.2.b. can occur.
5.c.1. To initiate deactivation, ensure existing water only features are in working order.
5.c.2. For ball valves and wheel handle valves purchase lock-out devices and seal the valves in the appropriate position using aircraft safety wire and seals or plastic seals which must be broken to change the valve position.
5.c.3. For electrical switches use approved lock-out devices for the specific type of switch or breaker devices and seal the switch in the appropriate position using aircraft safety wire and seals or plastic seals which must be broken to change the switch/breaker position.
5.c.4. Tag the deactivated valve/system as “Do Not Turn On, AFFF for removal”.
5.d. FSS Conversion Projects. Installations shall develop and submit FSS conversion projects to meet requirements associated with their designated facilities category via the Facilities Integration Website (FI Web). Project requests must include AFFF Conversion in the title.
5.e.  Spill Containment.
5.e.1. All facilities that previously used AFFF FSS shall have a containment system that allows sufficient capacity to store, test, and if necessary, treat wastewater prior to discharge. Containment studies conducted by the Naval Facilities Engineering Systems Command may be useful in assessing installation specific spill containment requirements. Requests for funds should be submitted via FI Web and include AFFF Conversion–Spill Containment in the title.
5.e.2.  All new hangars that have never used AFFF FSS shall be constructed with containment that prevents direct discharge of fuel and water to a stormwater or sanitary sewer system.
5.e.3.  Additional containment requirements for F3 are being developed by OSD and further guidance will be provided at a later time.
5.f. AFFF/AR-AFFF Management and F3 Support. The Marine Corps is pursuing the use of a USACE MATOC to support implementation of the AFFF/AR-AFFF management and F3 effort. Beginning in FY24, the USACE is expected to issue MCICOM funded regional Marine Corps task orders for a single rinse (tanks and associated lines), and disposal of fluorinated AFFF and AR-AFFF. Category 1 and 2 facilities will replace the fluorinated AFFF and AR-AFFF with an approved F3. MCICOM GF will be coordinating with regions/installations to develop the schedules.
6. Local environmental, fire and safety, operational, risk mitigation, and maintenance procedures to ensure compliance with this policy and continued safe operation of activities within facilities.
6.a Coordinate with the Installation Environmental Office to develop plans for spill prevention, response, clean up, and disposal to ensure they comply with applicable environmental requirements (ref (h)).
6.b. Review current fire access routes and coordinating courses of action/plan with the Fire and Safety Director or equivalent.
6.c. Ensure fire alarms, fire detection systems, automatic water sprinklers, and portable fire extinguishers are installed, inspected, and in working order.
6.d. Designate a safety officer to ensure mitigation measures are implemented in standard operational procedures.
6.e. Identify and assess near miss fire incidents and root causes to implement operational changes to reduce the risk of future life and safety mishaps.
6.f. Report fire hazards and incidents such as electrical issues, hazardous spills, or blockages to the unit’s designated safety officer for resolution. Call 911 (fire and emergency services) to report emergency situations.
6.g. Ensure personnel inspect equipment and tools properly and store combustibles, chemicals, and flammable liquids in appropriate containers and spaces with proper labeling.
6.h. Increase personnel access to fire guard and portable fire extinguishers on site.
6.i. Increase safety training and fire evacuation drills implementing the updated procedures.
6.j. Ensure proper markings are visible and posted throughout the facility such as “This Hangar Does Not Have a Foam Fire Suppression System” or markings approved by the Installation Base Safety Office.
6.k. Develop and present briefs to appropriate staff on fire and safety prevention strategies, maintenance protocols, and procedures.
7. Administration
7.a. Reporting. Installations shall submit a monthly report to MCICOM POC prescribed in 8a., using ref (i) identifying progress and status in executing each of the actions prescribed in 3.a. via MCICOM GF-PW SharePoint site at https:(slash)(slash)usmc.share point-mil.us.mcas-gov.us/sites/mcicom_gf_pw/SitePages/Home.aspx.
7.b This MARADMIN is applicable to the Marine Corps Total Force and is effective from its date of publication.
8. Command and Signal
8.a. Point of contact for questions or additional information is Nicholas Spurling, Facility Sustainment Program Manager, (571) 256-2785, nicholas.spurling@usmc.mil.
8.b.  Release authorized by LtGen E. D. Banta, Deputy Commandant, Installations and Logistics.//