Vandenberg AFB Halon Management Plan June 2020.pdf

THIRTIETH SPACE WING

Vandenberg Air Force Base, California

Halon Management Plan

June 2020

OPR: 30 CES/CEIEC

1028 Iceland Avenue Vandenberg Air Force Base, CA 93437

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Vandenberg Air Force Base

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EXECUTIVE SUMMARY

This plan details the approach to be implemented at Vandenberg Air Force Base to ensure compliance with federal and state regulations and Air Force directives regarding the management of systems and activities employing ozone depleting substances (ODS) and regulated substitute refrigerants. Specifically, the objective of this plan is to minimize, to the extent possible, the release of such gases into the atmosphere from existing systems and procedures employed at Vandenberg Air Force Base while implementing a proactive, cost effective approach to replace those systems, equipment, and procedures, which utilize such gases with environmentally safer alternatives. This plan details how Vandenberg Air Force Base will manage halon inventories in compliance with federal and state regulations, as well as Air Force policy. Halon is an ozone depleting substance (ODS) and greenhouse gas (GHG) used at Vandenberg Air Force Base (AFB) as a fire suppressant. This plan will assist Vandenberg AFB halon users and managers with managing halon resources and systems, while ensuring continued mission support.

The genesis of this initiative is the internationally ratified Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol) that entered into force on 1 January 1989 establishing a timetable during which the production of ODS are to be phased out. The United States incorporated the Montreal Protocol into Title VI of the Clean Air Act (CAA) as amended in 1990, and implementing regulations were published by the Environmental Protection Agency (EPA) in Title 40, Code of Federal Regulations, Part 82 (40 CFR 82), Protection of Stratospheric Ozone. In addition, Executive Order 13693 Planning for Federal Sustainability in the Next Decade, requires federal agencies to achieve greenhouse gas emissions reduction and reporting with associated EPA and local regulations.

Key Air Force directives relating to the management of ODS and regulated substitute refrigerants include Air Force Manual (AFMAN) 32-7002, Chapter 3 Hazardous Materials Management, which establishes the following policies and requirements:

Specific procedures for procuring Class I ODS—which are no longer being manufactured—including Senior Acquisition Officer (SAO) approval, as required, and Hazardous Materials Management Process (HMMP) Team authorization per Air Force (AF) Form 3952 or equivalent electronic forms within the Enterprise Environmental, Safety, and Occupational Health Management Information System

(EESOH-MIS);

Conserving existing inventories of Class I ODS and Class II ODS HCFC-22 and restricting their transfer out of Air Force control to sustain existing ODS-dependent weapon systems and fixed fire suppression systems (FFSS) until they are phased out;

Minimizing to the extent possible inadvertent releases of ODS into the atmosphere through formal training and certification of technicians and the employment of EPA-approved refrigerant recovery and recycling equipment;

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Strict prohibition against the intentional venting of ODS and regulated substitute refrigerants into the atmosphere;

Implementation of strategies to sustain, modify, or replace essential equipment, processes, and systems dependent on Class II ODS whose availability is steadily diminishing with the mandated complete phase-out of their manufacture by 2030.

Halon is an ozone depleting substance (ODS) and greenhouse gas (GHG) used at Vandenberg Air Force Base (AFB) as a fire suppressant. This plan will assist Vandenberg AFB halon users and managers with managing halon resources and systems, while ensuring continued mission support.

Halon management falls under the purview of the 30th Civil Engineer Squadron, including both the Operations Flight (30 CES/CEO) and the Fire Department (30 CES/CEF), with the support of other base organizations. The Air Force goal is to eventually eliminate the use of Class I and Class II ODS while ensuring adequate ODS supplies for existing refrigeration appliances and ODS- containing equipment and systems during their expected serviceable lifespan.

Activities governed by this plan include procuring, maintaining, and managing halons used in fire suppression systems. All personnel assigned to organizations that have activities with a potential to discharge ODS into the atmosphere are required to adhere to this plan. Sections of this HMP identify the key base organizations and positions that implement the halon management program at Vandenberg AFB, noting the major activities for which each organization and position is responsible.

Under the direction of the Air Force, Vandenberg Air Force Base has undertaken a proactive approach to identify, evaluate, and reduce the use of ODS to the absolute minimum levels necessary to support mission activities. This plan includes the steps necessary to manage ODS still needed to meet mission capabilities, and details procedures for Class I and II ODS procurement, use, and disposition.

Accordingly, this plan focuses on delineating those federal and state requirements relating to the management of ODS and regulated substitute ODS that are specifically applicable to operations and activities on Vandenberg Air Force Base. In particular, this plan details the approach by which Vandenberg Air Force Base complies with associated regulatory and Air Force requirements and specifically assigns roles and responsibilities as they relate to the maintenance of ODS-containing equipment, mandated record keeping and notification, technician training and certification, and the management system which will oversee implementation of the Vandenberg Air Force Base ODS Management Program elements.

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1.0 RECORD OF CHANGES

Log completed change action as indicated.

Change Number

Change Date of Entry Signature and Organization of

Individual Posting Entry

1 Deleted AFPAM 32-7089 reference

7/7/17 Mark Taberner, CH2M

2 Defined relative forcing 7/7/17 Mark Taberner, CH2M

Rewrote 32-7086 section based on Nov. 2015 update

7/7/17 Mark Taberner, CH2M

4 Updated reference dates 7/7/17 Mark Taberner, CH2M

5 Updated Plan Date 12/8/2017 Mark Taberner, CH2M

6 Updated Plan Date 12/30/2018 David Arokiasamy, CH2M

Updated Plan Date and AFMAN 32-7002

June 2020 Mark Kaschmitter, contractor

2.0 RECORD OF ANNUAL REVIEW

Log completed review action as indicated.

Reviewed By Organization Date Reviewed Remarks

Mark Taberner CH2M 7/7/17 See noted changes above

David Arokiasamy CH2M 12/30/2018 See noted changes above

Mark Kaschmittter Contractor June 2020 See noted changes above

3.0 DOCUMENT CONTROL INFORMATION

Ensure correct document control information as indicated.

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Document Control Information

Title:

Date of Issue:

Effective:

Number:

Supersedes

Author:

Hard copy distribution of this document is not controlled.

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TABLE OF CONTENTS

1.0 PURPOSE

1.1 ENVIRONMENTAL SIGNIFICANCE

2.0 RESPONSIBILITIES AND TASKING

2.1 GHG/ODS PROGRAM MANAGER (30 CES/CEIEC)

2.2 AEROSPACE SUPPORT SERVICE CONTRACTOR (ASSC)

2.3 HALON CONTAINER SERVICING CONTRACTOR (HCSC)

2.4 30TH CIVIL ENGINEER FIRE DEPARTMENT (30 CES/CEF)

3.0 HALON INVENTORY AND MANAGEMENT

4.0 REFERENCES

5.0 ACRONYMS AND ABBREVIATIONS

APPENDICES

Appendix A Glossary Appendix B List of Tasked Organizations

TABLE

1 Halon Type Used at Vandenberg AFB

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1.0 PURPOSE

The purpose of this Halon Management Plan (HMP) is to manage halon inventories in compliance with federal and state regulations, as well as Air Force policy. Halon is an ozone depleting substance (ODS) and greenhouse gas (GHG) used at Vandenberg Air Force Base (AFB) as a fire suppressant. This plan will assist Vandenberg AFB halon users and managers with managing halon resources and systems, while ensuring continued mission support. Halon management falls under the purview of the 30th Civil Engineer Squadron, including both the Operations Flight (30 CES/CEO) and the Fire Department (30 CES/CEF), with the support of other base organizations.

For halon management to be effective, it is imperative that the GHG/ODS Program Manager has the support of commanders and senior staff.

Subsequent sections of this HMP identify the key base organizations and positions that implement the halon management program at Vandenberg AFB, noting the major activities for which each organization and position is responsible.

1.1 ENVIRONMENTAL SIGNIFICANCE

The term ODS identifies a property of a substance for the purposes of categorization and regulation; likewise, with the term GHG. Therefore, a particular gas can be accurately categorized as both an ODS and a GHG, one of the two, or neither. Halon is both an ODS and a GHG.

An ODS is a gas that contributes to depletion of the stratospheric ozone layer when released into the atmosphere. Ozone is a naturally occurring atmospheric gas found between 20 and 30 miles above the earth. This ozone layer filters out a large percentage of ultraviolet radiation generated by the sun, protecting living organisms on earth. ODS regulatory requirements are intended to help protect the ozone layer. Many ODSs are refrigerants, generally chlorofluorocarbons. The other main type of ODS is halon, a class I ODS used for fire-fighting operations.

AFMAN 32-7002 Chapter 4 establishes a framework for all Air Force installations to comply with air quality requirements, and explains how to assess, attain, and sustain compliance with the Clean Air Act as well as other federal, state, and local environmental regulations. In relation to halon management, AFMAN 32-7002 references USEPA 40 CFR Part 82, for Air Force-wide ODS compliance.

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2.0 RESPONSIBILITIES AND TASKING

The Vandenberg AFB HMP is implemented through the efforts of several key offices and positions on base. Success of the HMP depends on the ability of these personnel and offices to effectively communicate with each other and coordinate their respective efforts in carrying out the management program outlined in this document. The Vandenberg AFB Environment, Safety, and Occupational Health Council is responsible for overseeing these efforts.

2.1 GHG/ODS PROGRAM MANAGER (30 CES/CEIEC)

The GHG/ODS Program Manager (30 CES/CEIEC) is responsible for the following:

Developing, maintaining, and providing instruction and guidance related to the

HMP.

Ensuring a current HMP is prepared and maintained in accordance with AFMAN 32-7002 Section 3 Hazardous Material Management.

2.2 AEROSPACE SUPPORT SERVICE CONTRACTOR (ASSC)

The Aerospace Support Service Contractor (ASSC)1 is responsible for the following:

Overseeing proper storage, safety, and security of fire suppressant Halon 1211 bottles in accordance with AFMAN 91-203 Safety, Section 24.3.3.6, Fire Extinguishers and Section 24.6.3.4, Working Materials.

Deploying and removing the Halon 1211 bottles during each aircraft landing and takeoff on the flight line in accordance with AFMAN 91-203, Section 24.8.2.5, Fire Fighting Equipment, and Air Force Technical Order (AFTO) 00-25-172, Table 3-1: Fire Protection Equipment Requirements.

Performing a monthly visual inspection and maintaining a log to document the condition of the halon fire bottles. This documentation will address any visible evidence indicating a possible release point of a Class I ODS, in accordance with AFMAN 91-203, Section 6.2.4.8, Maintenance and Tests.

Immediately notifying 30 CES/CEF in the event of a potential leak.

Informing the 30 CES/CEIEC GHG/ODS Program Manager of any noncompliant halon activities.

1 Although halon management may not be directly mentioned in the ASSC, it may be inferred by the contract clauses that direct transient aircraft activities related to fire safety are the responsibility of the ASSC.

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2.3 HALON CONTAINER SERVICING CONTRACTOR (HCSC)

The Halon Container Servicing Contractor (HCSC) is responsible for the following:

Performing all tasks specified in the halon container servicing contract.

Performing an annual detailed inspection to determine the serviceability of the halon fire bottles in accordance with AFMAN 91-203, Section 6.2.4.8, Maintenance and Tests; AFTO 13F4-4-121, Fire Extinguisher, Wheeled Liquified Gas, 150 Lb. Capacity, Part No. 03496 and 05673. Generally, this inspection can be conducted according to National Fire Protection Agency (NFPA) 402: Guide for Aircraft Rescue and Fire Fighting Operations or NFPA 12A: Standard on Halon 1301 Fire Extinguishing Systems.2

Immediately servicing or replacing any halon fire bottles that have been used in a flight line fire emergency event, determined to be in an unserviceable condition, and/or discovered to have a potential leak through direct inspection by 30 CES/CEF or ASSC. Any replacement halon fire bottle will meet the proper specifications according to NFPA 10: Standards for Portable Fire Extinguishers.

Measuring and documenting the quantity of Halon 1211 released during a flight line fire emergency event. This information will be made available to 30 CES/CEF for use in an official incident report.

2.4 30TH CIVIL ENGINEER FIRE DEPARTMENT (30 CES/CEF)

The 30th Civil Engineer Fire Department (30 CES/CEF) is responsible for the following:

Implementing the provisions of the HMP for Vandenberg AFB.

Following any applicable reporting and recordkeeping requirements specified in 40 CFR Part 82 for Halon 1211 as a Class I ODS.

Following the contractual requirements for Class I ODSs specified in AFMAN 32- 7002 when renewing or establishing new contracts with an ASSC and an HCSC.

Verifying that Vandenberg AFB’s halon technicians are certified in accordance with USEPA requirements.

Communicating with the 30 CES/CEIEC GHG/ODS Program Manager regarding the HMP and applicable regulations.

Verifying and documenting that ASSC is properly deploying and removing the Halon 1211 aircraft fire extinguishers for each applicable aircraft landing and

2 Vandenberg AFB has Halon 1211 on the flight line, and there is no NFPA standard for Halon 1211. Therefore, NFPA 12A is being referenced here as a guide for designing, installing, testing, inspecting, approving, listing, operating, maintaining, decommissioning, and removing halogenated agent systems, so that such equipment will function as intended throughout its life.

Page 4 Halon Management Plan takeoff on the flight line in accordance with AFMAN 91-203, Section 24.8.2.5, Fire Fighting Equipment.

Verifying and documenting that ASSC is performing its monthly halon fire bottle inspections according to its contract.

Immediately notifying HCSC if a potential leak is reported by ASSC to prevent release of Halon 1211.

Ensuring that a current halon container servicing contract is in place to cover monthly and annual inspections, as well as a 6-year complete maintenance of the halon fire bottles in accordance with AFMAN 91-203, Section 6.2.4.8, Maintenance and Tests.

Ensuring the proper transportation and disposal of used halon fire bottles.

Managing current stocks of Halon 1211, while proactively evaluating future replacements, when Air Force-approved substitutes are determined according to

AFMAN 32-7002.

Documenting any release of Halon 1211 for an emergency event on the flight line in an incident report, for recordkeeping purposes and official notification to Higher Headquarters.

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3.0 HALON INVENTORY AND MANAGEMENT

The USEPA regulation establishes requirements that prevent halon from knowingly being released or vented during technician training, testing, maintaining, servicing, repairing, or disposal of halon containing equipment. Conditional exemptions to these prohibitions are only granted in the following circumstances for fire extinguishing equipment:

Residual release during recycling and recovery

Release during emergency situations

Release during testing, if all the following conditions apply:

- No alternatives are available.

- Halon is essential for demonstration.

- Failure of the system would pose great risk.

- A simulant agent cannot be used for technical reasons.

Since further halon production was prohibited by USEPA, Vandenberg AFB must effectively manage its existing supplies of halon to ensure continued mission support with the resources available. Vandenberg AFB has approximately 1,800 pounds of Halon 1211 in 12 flight line fire bottles used as extinguishers, which HCSC maintains. ASSC maintains a record of each halon fire bottle, using a serial number label as a unique identifier along with the bottle’s corresponding weight. The bottles are inspected monthly for leaks and proper maintenance. As the owner of this halon, Vandenberg AFB bears the ultimate responsibility for compliance with USEPA requirements. Because this halon is only used in case of a fire emergency, and never for testing, it is allowable by the USEPA regulation.

AFTO-00-25-172, Table 3.1 defines the fire protection requirements for each type of flight line operation. These requirements vary by operation, ranging from one Halon 1211 fire bottle per three aircrafts for certain types of aircrafts, to two Halon 1211 fire bottles per aircraft, for other types of aircraft. The last release was approximately 10 years ago, in response to a flight line fire emergency. Vandenberg AFB does not have a phase out plan for its stock of Halon 1211, but its supplies are adequate to support the mission without relying on the Defense Logistics Agency Class I ODS Reserve stocks.

Vandenberg AFB does not have excess supplies of Halon 1211. Therefore, this HMP does not contain procedures for sending excess supplies to the Defense Logistics Agency Class I ODS Reserve.

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4.0 REFERENCES

National Fire Protection Association. NFPA 10: Standards for Portable Fire Extinguishers.

National Fire Protection Association. NFPA 12A: Standard on Halon 1301 Fire Protection Systems.

National Fire Protection Association. NFPA 402: Guide for Aircraft Rescue and Firefighting

Operations.

United States Environmental Protection Agency. Title 40, Protection of Environment, Code of Federal Regulations Part 82 – Protection of Stratospheric Ozone.

United States Air Force. February 2020. AFMAN 32-7002 Chapters 3 and 4. , Hazardous

Material Management, Air Quality Compliance and Resource Management.

United States Air Force. . AFMAN 91-203, Safety

United States Air Force. January 2012. TO 00-25-172, Technical Manual: Ground Servicing of Aircraft and Static Grounding/Bonding.

United States Air Force. April 2005. Change 5, TO 13F4-4-121, Technical Manual: Fire

Extinguisher, Wheeled Liquefied Gas, 150 lb. Capacity, Part No. 03496 and 056.

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5.0 ACRONYMS AND ABBREVIATIONS

AFB Air Force Base

AFI Air Force Instruction

AFTO Air Force Technical Order

ASSC Aerospace Support Service Contractor

CCl3F trichlorofluoromethane

CFC-11 trichlorofluoromethane

CFR Code of Federal Regulations

CO2 carbon dioxide

GHG greenhouse gas

GWP global warming potential

HCFC hydrochlorofluorocarbon

HCSC Halon Container Servicing Contractor

HMP Halon Management Plan

NFPA National Fire Protection Agency

ODP ozone depletion potential

ODS ozone depleting substance

USEPA United States Environmental Protection Agency

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APPENDIX A GLOSSARY

GLOSSARY

Global Warming Potential (GWP) The concept of a GWP was developed to compare the ability of each GHG to trap heat in the atmosphere, relative to the reference gas of CO2. Thus, the GWP of CO2 is defined to be 1.0, and all other GHGs have greater GWPs. A GWP is calculated by determining the amount of heat trapped by one unit mass of the GHG over a specified period and dividing that value by the amount of heat trapped by the same unit mass of CO2 over the same period.

Greenhouse gas (GHG) means any gas that absorbs infrared radiation in the atmosphere. The primary regulated greenhouse gases include carbon dioxide, methane, nitrous oxide, ozone, chlorofluorocarbons, hydrochlorofluorocarbons, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Halons are also GHGs, but do not fall into one these categories. Halons are fluorocarbons with at least one bromine atom.3

Halon means any of the Class I, Group II substances listed in Subpart A, Appendix A of 40 CFR Part 82. This group consists of the three halogenated hydrocarbons known as Halon 1211, Halon 1301, and Halon 2402, and all isomers of these chemicals.

Ozone Depletion Potential (ODP) means a number that refers to the amount of ozone depletion caused by a substance. The ODP is the calculated as the impact of a chemical on the ozone layer, divided by the impact of the same amount of CFC-11. Thus, the ODP of CFC-11 is defined to be

1. All other ODSs have greater or lesser ODPs, ranging from 0.01 to 10.

Ozone depleting substance (ODS) means a family of manufactured compounds that includes, but is not limited to, chlorofluorocarbons (CFCs), bromofluorocarbons (halons), methyl chloroform, carbon tetrachloride, methyl bromide, and hydrochlorofluorocarbons (HCFCs). These compounds have been shown to deplete stratospheric ozone, and therefore are typically referred to as ODSs.

3 U.S. Department of Energy. 2012. Name that Compound: The Numbers Game for CFCs, HFCs, HCFCs, and Halons. Available:

http://cdiac.ornl.gov/pns/cfcinfo.html. Last updated 26 September 2012. Accessed 6 April 2020.

APPENDIX B LIST OF TASKED ORGANIZATIONS

LIST OF TASKED ORGANIZATIONS

ORGANIZATION: OFFICE SYMBOL/ACRONYM

30th Civil Engineering Squadron, Civil Engineer Installations Flight, Environmental Section, Compliance 30 CES/CEIEC

30th Civil Engineering Squadron, Fire Department 30 CES/CEF

30th Civil Engineering Squadron, Operations Flight 30 CES/CEO

Aerospace Support Service Contractor ASSC

Halon Container Servicing Contractor HCSC