Attachment 16- AFFF Release SOP (08 MAR 21).pdf

FORT DRUM PUBLIC WORKS ENVIRONMENTAL DIVISION

STANDARD OPERATING PROCEDURES (SOP)

CLASS B FIRE SUPPRESSION FOAM RELEASE

1) Purpose: To provide procedures for cleaning up and reporting releases of all aqueous film forming foam (AFFF) concentrates including: Aer-O-Lite 3% AFFF and Chemguard C301MS. Procedures outlined in this SOP apply to cleaning up any foam spills on soil or pavement.

2) Spill/Release Response Procedures:

a. Spills of any quantity of fire suppression concentrate or foam shall be reported immediately to the Fort Drum Fire Department (call 911) then the Environmental Division.

b. Mobile sources of AFFF must have a spill kit to prevent spills from reaching the environment.

c. Immediately block discharges to storm drains, waterways and soil.

d. Stop and then control the flow of concentrate or foam if safe to do so.

e. Follow the procedures below depending on where the foam spill occurred:

Foam Spills to Soil

a. Examine the extent of the spill and determine where soil will need to be excavated to remove all contaminants. If needed, demarcate the impacted soil (e.g. flagging, spray paint). This will allow cleanup if foam on site has dissipated and area of impact is difficult to determine.

b. Call DPW Roads and Grounds (772-4448 or 772-2061) if a backhoe, loader or dump truck is required for cleanup.

c. Dig down 4” to remove the contaminated soil and place it in containers or a dump truck.

d. Soil samples (8 oz. bottle) must be collected in high density polyethylene (HDPE) containers after the area is clean. Sample bottles are kept in the grey cabinet in the hallway in Building 4838. Nitrile gloves must be worn before collecting a sample. Use the container to scoop and collect a soil sample ensuring no waterproof material, lotions, sunscreens or other materials that may contain per- and polyfluoroalkyl substances (PFAS) come in contact with the sample. No soil sample is required if the spill occurred in an area of historic contamination (Appendix B).

e. After the spill is cleaned up, contaminated soil will be brought to the soil barn (Building P-2018) and placed in the roll off dumpster located there.

The roll off dumpster must be closed or covered after cleanup is completed.

f. Call 772-0367 to have Building P-2018 opened, or if after hours, the keys to Building P-2018 are in the upstairs hallway key box in Building 4838.

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

Foam Spills on Pavement

a. If necessary use a defoamer (Plumbing Shop) to abate and eliminate excess foam.

b. Spread dry sweep or sand on the foam to absorb it.

c. Sweep up the area and place contaminated contents in containers or a dump truck.

d. After the spill is cleaned up, contaminated dry sweep or sand will be brought to the soil barn (Building P-2018) and placed in the roll off dumpster located there. The roll off dumpster must be closed or covered after cleanup is completed.

e. Call 772-0367 to have Building P-2018 opened, or if after hours, the keys to P-2018 are in the upstairs hallway key box in Building 4838.

Discharges to Storm Water Drains

a. If the spill reaches a stormwater drain, utilize the plumbing shop (772- 2260) for pumping. Inspect outfall/discharge point to verify that the spill was captured.

b. If the discharge isn’t captured it is likely to reach outfall #1 (Range 7 outfall). If it does, defoam and pump the concrete vault. Contaminated water can be pumped into totes at Building P-2018.

Discharges to Sanitary Sewer

a. If foam concentrate enters the sanitary sewer, PW Utilities will monitor lift stations at 2086 and 2175 and add defoamer if required.

b. Environmental will immediately call both DANC Warneck Lift Station and Watertown POTW to let them know the volume of AFFF that has entered the sewer system.

3) Reporting Requirements

a. Spills to soil, drains, waterways or over one pound of perfluorooctanoic acid (PFOA) (CAS No. 335-67-1), ammonium perfluorooctanoate (CAS No. 3825-26-1), perfluorooctane sulfonic acid (PFOS) (CAS No. 1763-23-

1) or perfluorooctane sulfonate (CAS No. 2795-39-3) must be reported within 2 hours to the NYS DEC Spill Hotline (1-800-457-7362).

b. A spill report (Appendix A) must be completed once cleanup is complete.

i. A copy of the spill report must be entered into the spill response database or the DPW Environmental hard copy form must be filled out and placed in the spill response log book within 24 hours of the spill occurrence.

ii. Photos taken during and after the spill are sent to the POL manager.

iii. Use MapsRUs to mark the location of the spill. Identify the mark with either the spill number (given by NYSDEC) or for non- NYSDEC reportable spills, label the mark with the date (YYYYMMDD) or work with the Geospatial Data Manager to identify/denote the location of the spill.

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

iv. If a soil sample is taken, place the samples into the refrigerator in the downstairs storage room (1016 key). Place the chain of custody on the Drinking Water Program Manager’s desk. Blank chain of custody forms are located behind the blank spill reports.

c. If the spill is less than 10 gallons of concentrate or 300 gallons of mixed foam, it must be reported to your chain of command and the G4 IMCOM PFAS POC (Kenny Norman, kenneth.d.norman.civ@mail.mil, (210) 466- 0566)

d. If the spill is over than 10 gallons of concentrate or 300 gallons of mixed foam a commander’s critical information requirement (CCIR) will be required (Appendix D). The following information must be reported:

a. Gallons spilled or used

b. Type used

c. Personnel and environmental/facility resources affected

d. Suspected root cause

e. Short and long term mitigation measures

f. Notification plan for affected population

g. Resources needed if necessary

e. If any foam concentrate reaches a stormwater outfall, it must be reported to the Stormwater Program Manager.

f. If foam enters an oil water separator, report it to the Wastewater Manager.

*Ansul R-102 cannot be deliberately put down the drain. It must be cleaned up with dry sweep and rags. Call 772-6111 for disposal. If discharges reach a drain, then the spill needs to be reported to the Drinking Water/Wastewater Manager, 772-2678.

** ANSUL JET-X 2% (HEX – soap formula) does not contain PFAS and is therefore exempt from this SOP. Clean up procedures for ANSUL JET-X 2% can be found in the Hex Foam Clean Up SOP.

4) Points of Contact

a. Fort Drum Fire Department, 911.

b. DPW, Environmental Division Chief, James M. Miller, 772-5269.

c. Environmental Compliance Branch Chief, Ian Crawford, 772-5063.

d. POL/P2/EMS Compliance Manager, Anthony Rambone, 772-4154.

e. Drinking Water and Wastewater Manager, Chris Whitman, 772-2678.

f. Stormwater Program Manager, Michael Reome, 772-9471.

g. Utilities Branch Chief, Jon Parobeck, 772-2260.

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

h. DPW Roads and Grounds, 772-4448 or 772-2061.

i. Watertown POTW, 315-785-7840.

j. DANC Warneck Lift Station, 315-786-4000.

X James M. Miller Chief, Environmental Division

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

Appendix A

Appendix B-Historic PFAS Contamination Map

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

Appendix C- Foam Inventory

Location Product Tank Size

55 Gallon Drums

Actual Gallons

Pounds Notes

19855 National Foam- Aer-O-Lite 3%

300 0 300 2555 Purchased in 2006

Chemguard -

C301MS

0 6 330 2811 Inventory in Drums

Chemguard -

C301MS

0 9 495 4216 Inventory in Drums

Chemguard -

C301MS

390 0 390 3322 Crash Truck 1

Chemguard -

C301MS

429 0 420 3577 Crash Truck 3

Chemguard -

C301MS

429 0 400 3407 Crash Truck 4

Chemguard -

C301MS

1000 0 880 7495 Trailer

Note: Specific Gravity of concentrate is 1.02

“Revision control of this document is maintained electronically. If printed, individuals are responsible for ensuring use of latest revision." March 1, 2021

Appendix D

FOR OFFICIAL USE ONLY

CCIR REPORT

CCIR # 20-XXX Fort Drum, NY (POM will insert CCIR #)

1. Date/Time of Report: Follow-On Report:

2. Reported By:

3. Reporting Unit: IMCOM Directorate-Readiness/Fort Drum NY.

4. Category:

5. Type of Incident:

6. Date/Time of Incident:

7. Location:

8. Who:

9. What:

10. When:

11. Where:

12. Why:

13. Nature of Damage/Description of Incident:

14. Follow Up Summary:

15. Corrective Actions Taken To Remedy the Incident:

16. Remarks:

17. Publicity:

18. Point of Contact: (Name, Rank, Phone, E-mail address):

Approved for release

Eric F. Wagenaar Deputy to the Garrison Commander DD MMM YYYY (POM will insert DTG info)