UNCLASSIFIED//
ROUTINE
R 131854Z OCT 21 MID200001224877U
FM CNO WASHINGTON DC
TO NAVADMIN
INFO CNO WASHINGTON DC
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UNCLAS
NAVADMIN 227/21
MSGID/GENADMIN/CNO WASHINGTON DC/N4/OCT//
SUBJ/AQUEOUS FILM FORMING FOAM (AFFF) USAGE AND SPILL RESPONSE AND
REPORTING//
REF/A/DOC/DOD/13JAN20/NOTAL//
REF/B/DOC/ASN/28FEB20/NOTAL//
REF/C/DOC/DOD/18SEP20/NOTAL//
REF/D/DOC/CNIC/22JAN19//
REF/E/DOC/01JAN21//
REF/F/DOC/DOD/11AUG16//
REF/G/DOC/OPNAV/25JUN21//
NARR/REF A IS ASD(SUSTAINMENT) MEMO, AQUEOUS FILM FORMING FOAM (AFFF) USAGE
AND SPILL REPORTING.
REF B IS ASN(EI&E) ACTION MEMO, AFFF USAGE AND SPILL REPORTING REQUIREMENTS.
REF C IS ASD(SUSTAINMENT) MEMO, PROHIBITION OF TESTING AND TRAINING WITH
FLUORINATED FILM FORMING FOAM.
REF D IS CNICINST 5214.1B, COMMANDERS CRITICAL INFORMATION REQUIREMENTS AND
SIGNIFICANT EVENTS REPORTING.
REF E IS THE FISCAL YEAR 2021 NATIONAL DEFENSE AUTHORIZATION ACT.
REF F IS DODM 3025.01, VOL. 2, DEFENSE SUPPORT OF CIVIL AUTHORITIES: DOD
INCIDENT RESPONSE.
REF G IS OPNAV-M 5090.1, ENVIRONMENTAL READINESS PROGRAM MANUAL.//
POC/MR. BERRY, GREGG/CIV/CNO WASHINGTON DC/OPNAV N4I/E-
MAIL: GREGORY.F.BERRY.CIV@US.NAVY.MIL/TEL: (703)695-5147//
RMKS/1. This message consolidates policy requirements and highlights
implementing instructions necessary for responding to and reporting use and
spills (collectively referred to as releases hereinafter) of Aqueous Film
Forming Foam (AFFF) ashore, including releases from Navy ships while in port
at Navy installations. In July 2019, the Secretary of Defense created a Per-
and Polyfluorinated Alkyl Substances (PFAS) Task Force to develop policies
and procedures to address releases of these substances, and mitigate the
effects of PFAS on military installations and surrounding communities. AFFF
is used as a fire-extinguishing agent and vapor suppressant for flammable and
combustible liquids and has historically contained PFAS. In January 2020,
Assistant Secretary of Defense (ASD)(Sustainment) established policy via
reference (a) requiring all AFFF releases to be tracked and reported.
Subsequently, the Assistant Secretary of the Navy, Energy, Installations and
Environment (ASN(EI&E))issued reference (b) directing Commander, Navy
Installations Command (CNIC) to immediately task installation commanders to
begin AFFF release reporting. The requirements cited in this NAVADMIN are in
addition to, and do not supersede, any other applicable operational or
environmental reporting triggered due to an AFFF release.
2. Applicability. AFFF release response and reporting requirements apply to
releases that occur at Navy installations, including releases from ships in
port that impact surrounding waters. AFFF release response and reporting
applies to both unintended/accidental releases at Navy installations, and the
use of AFFF pursuant to emergency responses whether on or off installation.
Response and reporting procedures described in this NAVADMIN do not apply to
routine management of AFFF in conjunction with supply, maintenance, repairs,
or other planned events in which the AFFF is contained and not released to
the environment. Note that AFFF use in testing and training is prohibited at
most shore locations per direction in reference (c).
3. AFFF Release Response. AFFF, whether in concentrate or mixed solution,
is a hazardous material (HAZMAT) and installations will respond to releases
accordingly. Every effort must be made to arrest the release, and contain,
collect, and properly dispose of the released product. Initial cleanup may
include removal of obviously impacted soil and water to the extent
practicable. Installation environmental staff will assess the need for, and
extent of, subsequent cleanup actions. Following an accidental or unintended
release onboard a Navy installation, the installation will initiate a root
cause analysis to identify underlying reason(s) for the release (if not known
at the time of the initial release report).
4. AFFF Release Reporting.
a. Management of AFFF Release Reporting. CNIC has overall
responsibility for AFFF Release Reporting ashore. In this capacity, CNIC
will receive initial reports of AFFF releases and maintain the master list of
Navys AFFF Release Reports. CNIC will transmit an annual AFFF release report
and reports of significant releases to the Office of the Deputy Assistant
Secretary of Defense for Environment and Energy Resilience (ODASD(E&ER)) via
the chain of command, and facilitate all other reporting described below.
b. Initial Release Reports. Initial AFFF release reports will be made
immediately upon discovery to the installation Command Duty Officer (CDO),
then promptly relayed to the CNIC Regional Operations Center (ROC) to meet
the requirements of reference (d). This includes releases by installation
activities, ships in port, and tenant organizations. For off-installation
mutual aid responses, and any other off-installation (Fire and Emergency
Services (F&ES)) incident responses, the initial report will be made to the
CDO of the nearest Navy installation. Initial reports will provide the
following in as much detail as is available:
(1) Date and time of release
(2) Location and physical address of the release
(3) Amount of concentrate (gallons)
(4) Amount of mixed foam (approximate volume of AFFF concentrate and
water, in gallons)
(5) Type of AFFF (% concentrate and manufacturer)
(6) Cause of the release (e.g. fire response, fuel spill,
accidental/unintended release). If accidental or unintended, describe the
immediate cause and circumstances, if known
(7) Summary of AFFF usage or spill (general description of the
events surrounding the release, its extent, and actions taken for
containment and cleanup)
(8) For releases onboard the installation: Name and contact
information for installation environmental staff notified of the release
(9) For releases off-installation: Name and contact information for
the off-installation representative notified of the release
(10) The name of the incident commander or public official who
requested AFFF use (if applicable), and
(11) The name and contact information of the individual making the
initial report.
c. Tracking and Follow-on Reporting. Upon receipt of an initial release
report relayed by an installation, the ROC will generate the Category II-9
Commanders Critical Information Requirements (CCIR) report in accordance with
reference (d), and applicable local and regional CCIR instructions. The CCIR
report will include the same information as the initial release report
described in subparagraph 4b. Thereafter, CNIC headquarters (HQ) will track
the release response, and prepare, maintain, and submit release reports to
ODASD(E&ER) per references (a) and (b). CNIC HQ will send the release
reports via the email address osd.pentagon.ousd-a-s.mbx.asds-
environment@mail.mil and will include copies to paula.monachelli1@navy.mil at
DASN(IE&F), richard.g.mach.civ@us.navy.mil at DASN(E&MR) and
chaela.m.smith.civ@us.navy.mil at OPNAV N4I to ensure the chain of command
remains informed. Timing and content of reports will vary as follows:
(1) 24-hour Reporting Requirement for Significant Releases. A
release of more than 10 gallons of AFFF concentrate, or more than 300 gallons
of AFFF mixed foam, or any other situation that may receive media attention,
constitutes a significant release. Significant releases must be reported to
ODASD(E&ER) within 24 hours of the initial release per references (a) and
(b). In addition, to comply with Section 318 of reference (e), installations
will prepare and submit an Action Plan (or Final Action Report if all follow-
up actions are complete) to CNIC HQ no later than 30 days after the initial
release notification. CNIC HQ will forward the Action Plan or Final Action
Report to ODASD(E&ER) within 45 days of the initial release report. The
Action Plan or Final Report will include a description of actions taken to
arrest and clean up the release, and a description of any coordination with
relevant local and State environmental protection agencies. Note that Action
Plans and/or Final Action Reports are not required for mutual aid responses.
(2) Annual Release Reporting. All AFFF releases must be reported to
ODASD(E&ER) in a consolidated report annually. This includes significant
releases already reported and all other releases reported that did not
trigger the 24-hour reporting threshold. CNIC HQ will provide the
consolidated report to ODASD(E&ER) by 15 November each year via OPNAV N4I.
(3) Additional Requirement for Off-Installation Releases. When Navy
F&ES is asked to use AFFF for fire suppression to protect the public in
accordance with mutual aid agreements, the Installation Commanding Officer
(ICO) will notify the off-installation entity that AFFF was used per their
request. The same notification requirement applies if the requestor does not
have a mutual aid agreement and has asked for immediate response under
reference (f). Notifications will be made no later than 15 days following
the end of the Navys participation in the emergency response.
5. Additional Guidance for Releases of AFFF from Ships in Port.
a. If AFFF is released into surrounding waters, the ship will:
(1) Make an initial report of the release to the installation CDO per
subparagraph 4b. The installation will support the ship with release
response as needed.
(2) If in a U.S. port, submit appropriate Uniform National Discharge
Standards (UNDS) non-compliance and Hazardous Substance Release reports in
accordance with reference (g), appendix C.
b. Ships in port that spill or use AFFF on or inside the ship and the
AFFF is not released into surrounding waters will:
(1) Ensure all AFFF is appropriately cleaned up and disposed of as
HAZMAT.
(2) If AFFF entered the bilge, inform installation Port Operations
and environmental office to ensure AFFF impacted bilge water is handled and
processed appropriately. The ship will follow installation directions when
offloading AFFF impacted bilge water to shore.
(3) UNDS non-compliance and Hazardous Substance Release reporting is
not required if the AFFF is not released into surrounding waters.
c. If AFFF is spilled or used on or in the ship and some AFFF is
released into surrounding waters, only the amount released into surrounding
waters must be reported.
6. Actions. Echelon II commands will ensure that personnel who use or
encounter AFFF are aware of the initial reporting requirements in paragraph
4.b of this NAVADMIN. CNIC will establish policies and procedures necessary
to implement and facilitate the reporting requirements of this NAVADMIN, to
include guidance for conducting root cause analyses cited in paragraph 3.
ICOs will incorporate AFFF release response and reporting into local HAZMAT
release response instructions and standard operating procedures.
7. Released by VADM R. L. Williamson, N4.//
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