5.1.1
Aqueous
Film­
Forming
Foam
(
AFFF)

This
discharge
consists
of
a
mixture
of
seawater
and
firefighting
foam
discharged
during
training,
testing,
and
maintenance
operations.
Aqueous
film
forming
foam
(
AFFF)
is
the
primary
firefighting
agent
used
to
extinguish
flammable
liquid
fires
on
surface
ships
of
the
Armed
Forces.
AFFF
is
stored
on
vessels
as
a
concentrated
liquid
that
is
mixed
with
seawater
to
create
the
diluted
solution
(
3­
6%
AFFF)
that
is
sprayed
as
a
foam
on
the
fire.
The
solution
is
applied
with
both
fire
hoses
and
fixed
sprinkler
devices.
During
planned
maintenance
of
firefighting
systems,
system
testing
and
inspections,
and
flight
deck
certifications,
the
seawater/
foam
solution
is
discharged
either
directly
overboard
from
hoses,
or
onto
flight
decks
and
then
subsequently
washed
overboard.
These
discharges
are
considered
incidental
to
the
normal
operation
of
Armed
Forces
vessels.
Discharges
of
AFFF
that
occur
during
firefighting
or
other
shipboard
emergency
situations
are
not
incidental
to
normal
operations
and
are
not
subject
to
the
requirements
of
the
rule.

AFFF
is
discharged
from
all
Navy
ships,
those
MSC
ships
capable
of
supporting
helicopter
operations,
and
Coast
Guard
cutters,
icebreakers,
and
tugs.
AFFF
discharges
generally
occur
at
distances
greater
than
12
n.
m.
from
shore,
and
in
all
cases
more
than
3
n.
m.
from
shore
due
to
existing
Armed
Forces
operating
instructions.
The
constituents
of
AFFF
include
water,
2­
(
2­
butoxyethoxy)­
ethanol,
urea,
alkyl
sulfate
salts,
amphoteric
fluoroalkylamide
derivative,
perfluoroalkyl
sulfonate
salts,
triethanolamine,
and
methyl­
1H­
benzotriazole.
Because
the
water
used
to
mix
with
the
AFFF
concentrate
comes
from
the
vessel's
firemain,
the
discharge
will
also
include
bis(
2­
ethylhexyl)
phthalate,
nitrogen
(
measured
as
total
Kjeldahl
nitrogen),
copper,
nickel,
and
iron
from
the
firemain
piping.

The
AFFF
discharge
produces
an
aqueous
foam
intended
to
cool
and
smother
fires.
Water
quality
criteria
for
some
States
include
narrative
requirements
for
waters
to
be
free
of
floating
materials
attributable
to
domestic,
industrial,
or
other
controllable
sources,
or
include
narrative
criteria
prohibiting
discharges
of
foam.
AFFF
discharges
in
State
waters
would
be
expected
to
result
in
violating
such
narrative
criteria
for
foam
or
floating
materials.
At
present,
the
Navy
uses
certain
management
practices
to
control
these
discharges,
including
a
self­
imposed
prohibition
on
AFFF
discharges
in
coastal
waters
by
most
Armed
Forces
vessels.
These
management
practices
to
control
discharges
of
AFFF
demonstrate
the
availability
of
a
MPCD
to
mitigate
the
potential
adverse
impacts
that
could
result
from
the
discharge
of
AFFF.
Therefore,
EPA
and
DoD
have
determined
that
it
is
reasonable
and
practicable
to
require
use
of
a
MPCD
for
this
discharge.
AFFF
discharges
occur
beyond
3
n.
m.
but
within
12
n.
m.
from
shore
infrequently
and
in
relatively
small
volumes,
and
preliminary
investigation
indicates
that
the
diluted
(
3­
6%)
AFFF
solution
does
not
exhibit
significant
toxic
effects.
Further,
any
discharges
that
do
occur
take
place
while
the
vessel
is
underway
and
will
be
dispersed
in
the
turbulence
of
the
vessel
wake.

5.1.11
Firemain
Systems
This
discharge
is
the
seawater
pumped
through
the
firemain
system
for
firemain
testing,
maintenance,
and
training,
and
to
supply
water
for
the
operation
of
certain
vessel
systems.

Firemain
systems
distribute
seawater
for
firefighting
and
other
services
aboard
ship.
Firemain
water
is
provided
for
firefighting
through
fire
hose
stations,
sprinkler
systems,
and
foam
proportioners,
which
inject
aqueous
film­
forming
foam
(
AFFF)
into
firemain
water
for
distribution
over
flammable
liquid
spills
or
fire.
Firemain
water
is
also
directed
to
other
services
including
ballast
systems,
machinery
cooling,
lubrication,
and
anchor
chain
washdown.
Discharges
of
firemain
water
incidental
to
normal
vessel
operations
include
anchor
chain
washdown,
firemain
testing,
various
maintenance
and
training
activities,
bypass
flow
from
the
firemain
pumps
to
prevent
overheating,
and
cooling
of
auxiliary
machinery
equipment
(
e.
g.,
refrigeration
plants).
UNDS
does
not
apply
to
discharges
of
firemain
water
that
occur
during
firefighting
or
other
shipboard
emergency
situations,
because
they
are
not
incidental
to
the
normal
operation
of
a
vessel.

Firemain
systems
aboard
Armed
Forces
vessels
are
classified
as
either
wet
or
dry.
Wet
firemain
systems
are
continuously
charged
with
water
and
pressurized
so
that
the
system
is
available
to
provide
water
upon
demand.
Dry
firemains
are
not
continuously
charged
with
water,
and
consequently
do
not
supply
water
upon
demand.
Dry
firemain
systems
are
periodically
tested
and
are
pressurized
during
maintenance
or
training
exercises,
or
during
emergencies.

With
the
exception
of
small
boats
and
craft,
all
Armed
Forces
vessels
use
firemain
systems.
All
Navy
surface
ships
and
some
MSC
vessels
use
wet
firemain
systems.
Submarines
and
all
Army
and
Coast
Guard
vessels
use
dry
firemains.
Firemain
system
discharges
occur
both
within
and
beyond
12
n.
m.
from
shore.
Flow
rates
depend
upon
the
type,
number,
and
operating
time
of
the
equipment
and
systems
using
water
from
the
firemain
system.

Samples
were
collected
from
three
vessels
with
wet
firemain
systems
and
analyzed
to
determine
the
constituents
present.
Because
of
longer
contact
times
between
seawater
and
the
piping
in
wet
firemains,
and
the
use
of
zinc
anodes
in
some
seachests
and
heat
exchangers
to
control
corrosion,
pollutant
concentrations
in
wet
firemains
are
expected
to
be
higher
than
those
in
dry
firemain
systems.
Pollutants
detected
in
the
firemain
discharge
include
nitrogen
(
measured
as
total
Kjeldahl
nitrogen),
copper,
nickel,
iron,
and
bis(
2­
ethylhexyl)
phthalate.
The
concentrations
of
iron
exceeded
the
most
stringent
State
chronic
water
quality
criteria.
The
concentrations
of
nitrogen
exceeded
the
most
stringent
State
water
quality
criteria.
Copper,
nickel,
and
bis(
2­
ethylhexyl)
phthalate
concentrations
exceeded
the
relevant
chronic
Federal
criteria
and
State
chronic
water
quality
criteria.
These
concentrations
contribute
to
a
significant
total
mass
loading
in
the
discharge
due
to
the
large
volume
of
water
discharged
from
wet
fir
emain
systems.
Circulation
through
heat
exchangers
to
cool
auxiliary
machinery
increases
the
temperature
of
the
firemain
water,
but
the
resulting
thermal
effects
do
not
exceed
State
mixing
zone
criteria.

Firemain
systems
have
a
low
potential
for
transporting
nonindigenous
aquatic
species,
primarily
because
the
systems
do
not
transport
large
volumes
of
water
over
great
distances.
In
addition,
stagnant
portions
of
the
firemain
tend
to
develop
anaerobic
conditions
that
are
inhospitable
to
most
marine
organisms.

EPA
and
DoD
believe
that
dry
firemain
systems
may
offer
one
means
for
reducing
the
total
mass
of
pollutants
discharged
from
firemain
systems.
The
use
of
dry
firemains
for
Coast
Guard
vessels
demonstrates
that,
for
at
least
some
types
of
vessels,
this
option
may
be
an
available
control
mechanism.
Another
possible
MPCD
option
for
achieving
pollutant
reductions
is
the
use
of
alternative
piping
systems
(
i.
e.,
different
metallurgy)
that
provide
lower
rates
of
pipe
wall
corrosion
and
erosion.
The
use
of
dry
firemains
and
the
potential
offered
by
alternative
piping
systems
demonstrates
the
availability
of
controls
to
mitigate
potential
adverse
impacts
on
the
environment.
Therefore,
EPA
and
DoD
have
determined
that
it
is
reasonable
and
practicable
to
require
the
use
of
a
MPCD
for
firemain
systems.
