CHANGE 1 TO THE MARADMIN 185/24 FOR THE PHASEOUT OF FLUORINATED AQUEOUS FILM FORMING FOAM

MARADMINS : 316/25

R 021415Z JUL 25 MARADMIN 316/25 MSGID/GENADMIN/CMC IL WASHINGTON DC// SUBJ/CHANGE 1 TO THE MARADMIN 185/24 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/MSGID:MSG/CMC/R181817ZAPR24// REF/B/PUBLIC LAW 116-92/20 DEC 19// REF/C/DOC/SECTION 322 (e) APPROVED ONE-YEAR WAIVER/06 AUG 24// REF/D/DOC/435C ASSISTANT SECRETARY OF THE NAVY (ASN) SUNDOWN POLICY/07 AUG 24// REF/E/DOC/NAVAL FACILITIES AFFF ORDERLY SHUTDOWN GUIDANCE// REF/F/DOC/NFPA 101 LIFE SAFETY CODE// REF/G/DOC/HMX-1 HANGAR FIRE SUPPRESSION SYSTEM RISK TO MISSION 15 JAN 25// REF/H/DOC/NFPA 101 STANDARD FOR LOW, MED AND HIGH EXPANSION FOAM// REF/I/DOC/GUIDANCE FOR FLUORINE-FREE FOAM USAGE AND ACCIDENTAL RELEASE ON MILITARY INSTALLATIONS AND NATIONAL GUARD FACILITIES 17 MAY 24// REF/J/DOC/OASD GUIDANCE FOR AFFF CHANGEOUT IN FACILITIES 30 JUL 24// REF/K/DOC/FOAM TANK FILL-DRAIN-FLUSH-DRY 03 OCT 24// REF/L/DOC/NAVY CRANE INSTRUCTIONS 114501.C DESIGN OF NAVY SHORE WEIGHT HANDLING EQUIPMENT 11 JUL 19// REF M/DOC/NFPA 70 ELECTRICAL CODE ARTICLE 610// REF N/DOC/AFFF MARADMIN REPORTING TEMPLATE/18 MAR 25// NARR/REF (A) IS MARADMIN 185/24 POLICY AND PROCEDURES FOR THE PHASEOUT OF FLUORINATED AQUEOUS FILM FORMING FOAM (AFFF) AND ALCOHOL RESISTANT AFFF (AR-AFFF) FIRE SUPPRESSION SYSTEMS IN MARINE CORPS FACILITIES RELEASED ON 18 APR 24; REF (B) IS NATIONAL DEFENSE AUTHORIZATION ACT FOR FISCAL YEAR (FY) 2020; REF (C) SECTION 322 (e) CONGRESS APPROVED ONE-YEAR WAIVER; REF (D) IS ASN SUNDOWN POLICY FOR FOAM-BASED FIRE SUPPRESSION SYSTEMS IN DEPARTMENT OF THE NAVY HANGARS RELEASED ON 07 AUG 24; REF (E) IS NAVFAC AFFF ORDERLY SHUTDOWN GUIDANCE; REF (F) IS NFPA LIFE SAFETY CODE; REF (G) HMX-1 HANGAR FIRE SUPPRESSION SYSTEM RISK TO MISSION 15 JAN 25; REF (H) IS NFPA STANDARDS FOR LOW, MEDIUM, AND HIGH EXPANSION FOAM; REF (I) GUIDANCE FOR FLUORINE-FREE FOAM USAGE AND ACCIDENTAL RELEASE ON MILITARY INSTALLATIONS AND NATIONAL GUARD FACILITIES/17 MAY 24; REF (J) OASD GUIDANCE FOR AFFF CHANGEOUT IN FACILITIES ON 30 JUL 24; REF (K) FOAM TANK FILL-DRAIN-FLUSH-DRY 03 OCT 24 PROCEDURES FOR P19R; REF (L) IS NAVY CRANE INSTRUCTIONS 11450.1C DESIGN OF NAVY SHORE WEIGHT HANDLING EQUIPMENT 11 JUL 19; REF (M) NFPA 70 ELECTRICAL CODE ARTICLE 610; REF (N) IS MCICOM UPDATED AFFF MARADMIN REPORTING TEMPLATE// POC/N. R. SPURLING/CIV/MCICOM GF-PW/HQMC/ 571-256-2785/ DSN 260-2785/EMAIL: NICHOLAS.SPURLING@USMC.MIL// GENTEXT/REMARKS/1. Purpose. This MARADMIN announces changes to ref (a). This update outlines new guidance to the policy, procedures, and execution in FY25 for the phase-out of ﬂuorinated AFFF and AR-AFFF FSS in Marine Corps facilities and safety mitigation for continued use of aircraft hangar crane system, both in the Continental United States (CONUS) and outside the Continental United States (OCONUS), to support compliance with the Congressionally mandated phase-out of AFFF by 1 October 2024 per ref (b). The Department of Defense has been granted the first of two one-year extension request described in ref (b) on 6 Aug 2024 (ref c) to allow time and requirements development for transitions efforts to occur. This policy does not apply to Marine Corps tactical and non-tactical vehicles. 2. Background. 2.a. Other than changes outlined in paragraph three and paragraph four; all instructions, details, and authorities specified in ref (a) remain in effect. Directed actions performed in ref (a) shall remain enforced with follow on actions directed in this guidance. 3. Changes and Clarifications. 3.a. Category 1 Facility. 3.a.1. Definition. Hangar with a fluorinated AFFF or AR-AFFF FSS where the total loss of the facility or the loss of the aircraft or 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. Marine Forces Command (MARFORCOM), Marine Forces Pacific (MARFORPAC), and Marine Forces Reserve (MARFORRES) may submit requests for Category 1 designations to Marine Corps Installations Command (MCICOM) via Headquarters, Marine Corps Plans, Policies & Operations (PP&O). 3.b. Category Change Request. 3.b.1.Category change request by Marine Forces Command (MARFORCOM), Marine Forces Paciﬁc (MARFORPAC), and Marine Forces Reserve (MARFORRES) may submit requests for category change designations with detailed justification for the change request to Marine Corps Installations Command (MCICOM) via Headquarters, Marine Corps Plans, Policies & Operations (PP&O). MCICOM regions seeking category change designations shall submit requests directly to MCICOM POC described herein section 6.a. no later than 45 days following issuance of this policy. Request must include a detailed explanation on why the facility requires category change. 3.c. No later than 60 days of the issuance of this policy, deactivate and secure the water supply valves to each low level suppression system zone (Lockout-Tagout) for all Category 3 (CAT 3) facilities defined in ref (a) with shutdown guidance in ref (e). Water supply to the overhead water sprinkler systems must remain operational for life safety (ref f). Provide written notification to the MCICOM POC in the event they are unable to deactivate and secure LOTO of the water supply to low-level systems within the prescribed deadline in accordance with ref (e), ref (f), and ref (h). LOTO of the foam features of the AFFF/AR-AFFF completed per ref (a) must remain enforced with ref (e), ref (f), and ref (h). 3.c.1. No later than 30 days after issuance of this policy, HMX-1 hangars located at MCAF Quantico (ref g) shall complete LOTO of foam systems and transition to CAT 3 fire protection requirements to include development and implementation of fire, safety, and environmental mitigation procedures directed in ref (a) in accordance with ref (e) to ref (h). 3.c.2. No later than 360 days of issuance of this policy develop and submit FSS conversion projects to meet requirements associated with their designated facilities category ref (a) in accordance with ref (f) to ref (h) via the Facilities Integration Website (FI Web) as prescribed in ref (a). A National Fire Protection Association (NFPA) 409 Risk Assessment and Performance Based Design per ref (d) for the P201 Aircraft Maintenance Hangar project at Marine Corps Air Station Miramar is underway that aims to find a near term alternative ﬁre protection solution. A separate effort is underway that aims for an enterprise wide long term design solution for a water only fire protection that is estimated to complete in November 2025. In the event that results from the NFPA 409 Risk Assessment and Performance Based Design performed determines an alternative ﬁre protection requirement detailed in ref (a), then design for a water only fire protection solution shall supersede ref (a). 3.c.3. No later than 360 days of issuance of this policy Installations that require spill containment and/or isolation capabilities (e.g., shut off valve or emergency shut oﬀ for the pump station to prevent run oﬀ into the environment, etc.) shall submit requests to MCICOM via FI Web as prescribed in ref (a). 3.d. MCICOM Facilities Directorate shall take the following actions. 3.d.1. No later than 120 days of issuance of this policy distribute a phase-out plan to remove AFFF and AR-AFFF from all facilities as prescribed in ref (d). 4. Coordinating Instructions. 4.a. AFFF/AR-AFFF Lockout-Tagout (LOTO) Procedures. LOTO of AFFF/AR-AFFF systems for all Category 3 facilities must remain secured in compliance with ref (a), ref (e), ref (f)and ref (h). The water supply valves to each low level suppression system zone must be deactivated and secured. CAT 1 and CAT 2 facilities will continue to utilize the AFFF FPS until the activities described in ref (a) are programmed and funded. 4.a.1. AFFF/AR-AFFF Management and F3 Support. The Marine Corps awarded three Regional task orders through USACE in Q4 FY24 (MCIPAC, MCIWEST, and MCB Hawaii) and one Regional task order in Q1 of FY25 (East Coast) to support implementation of the AFFF/ AR-AFFF management and F3 replacement effort. F3 backstock for the P19R assets at MCIWEST will be handled by the G-3/5. MCICOM funded regional Marine Corps task orders will provide for a single rinse (tanks and associated lines in facilities and mobile assets) (ref i), double rinse for P19R mobile assets (ref k), and disposal of fluorinated AFFF and AR-AFFF, and associated rinsate. CAT 1 and CAT 2 facilities will have the flourinated AFFF and AR-AFFF replaced with an approved MILSPEC F3. MCICOM GF will be coordinating with regions/installations to develop and implement the execution schedules for this effort. 4.a.2. Facilities risk assessments were conducted in Q1FY25 for Category 2 (CAT 2) assets through a task order with Naval Facilities Engineering Systems Command to assess the facilitity's F3 acceptance and project requirements for final transition. Project requirements shall be submitted to initiate programming activities described in ref (a). Preliminary reports for the assessments are estimated to be available in Q3 FY25. 4.b. Fire Safety and Risk Mitigation for Crane Systems Use in Aircraft Hangars. 4.b.1. Crane systems are designed to meet the requirements in ref (l) and ref (m). LOTO of the AFFF system does not suspend the use of crane system in aircraft hangars, however, fire and safety risk mitigation detailed in ref (a) shall be implemented. 4.b.2. Ensure that all aircraft hangar crane systems are inspected for fire safety compliance regularly. Inspections should include checking electrical systems (ref m), ﬂammable materials, and mechanical components for potential fire hazards. 4.b.3. Ensure personnel are trained to use the crane systems and monitored during operations in order to respond to any ﬁre emergencies. 4.b.4. Implement portable fire extinguishers access for cranes where feasible, ensure that all personnel are trained in the use of portable fire extinguishers and adherence to safety protocols. Regular drills should be conducted to ensure readiness and efficiency in case of a fire event. 5. Administration. 5.a. Reporting. Installations shall submit a monthly report to MCICOM POC prescribed in 6a., using ref (n) identifying progress and status in executing each of the actions prescribed in paragraph 3 via MCICOM GF-PW SharePoint site at https:(slash) (slash)usmc.sharepoint-mil.us.mcas-gov.us/sites/mcicom_gf_pw/ SitePages/Home.aspx. 5.b. This MARADMIN is applicable to the Marine Corps Total Force and is eﬀective from its date of publication. 6. Command and Signal. Point of contact for questions or additional information is Mr. Nicholas Spurling, Facility Sustainment Program Manager, (571) 256-2785, nicholas.spurling@usmc.mil. 7. Release authorized by MajGen J. G. Woodworth, Assistant Deputy Commandant, Installations and Logistics (Facilities).//