ALCOAST 351/24 - SEP 2024 SUNDOWN POLICY FOR FOAM-BASED FIRE SUPPRESSION SYSTEMS IN COAST GUARD HANGARS

R 061830Z SEP 24 MID600117611968U
FM COMDT COGARD WASHINGTON DC
TO ALCOAST
BT
UNCLAS
ALCOAST 351/24
SSIC 13490
SUBJ: SUNDOWN POLICY FOR FOAM-BASED FIRE SUPPRESSION SYSTEMS IN
COAST GUARD HANGARS
A. COMDT (CG-43) memo 11000 of 11 Jun 2024
B. Aircraft Hangar Fire Protection Requirement, SILC-CSTO-36-11 55
13 25-02
C. Department of Air Force memo of 16 Nov 2021, "Sundown Policy for
Foam Fire Suppression Systems"
D. Department of the Navy memo of 07 Aug 2024, "Sundown Policy for
Foam-Based Fire Suppression Systems in Department of Navy Hangars"
E. Tactical Operations Product Line memo 11131/24-074 of 22 Aug 2024
1. In 2021, the Air Force led a joint DoD effort including the
Defense Logistics Agency to assess the risks associated with
replacing Aqueous Film Forming Foam (AFFF) fire suppression systems
(FSS) in DoD facilities. The effort reviewed 32 years of historical
data and found no hangar fuel-related fires resulting in the loss of
life or an aircraft. A review of 15 years of safety mishap data
uncovered 84 inadvertent activations of foam systems resulting in
$24.5 million of damage, one death, 21 injuries, and 120 damaged
aircraft.
2. Citing the 2021 Air Force Study, COMDT (CG-43) signed a charter
in June 2024 establishing the Aviation Hangar Fire Suppression
Integrated Project Team (IPT), REF (A). The IPT reviewed 35 years
of Coast Guard mishap data and found no documented Class Bravo fires
in any hangar and 26 accidental discharges, including three in the
last 12 months. In reference to those three incidents, preliminary
reports include damage to 12 aircraft with final damage estimates
still to be determined.
3. Based on the findings of the DoD and CG risk-informed analyses,
the Coast Guard will immediately begin the process to safely cease
operations of installed foam FSS in all Coast Guard aviation hangars
by completing following:
    a. No later than 30 days after release of this message, the Shore
Infrastructure and Logistics Center (SILC) and the Tactical
Operations Product Line (TOPL) in coordination with the Health,
Safety, and Work Life Service Center (HSWL-SC) and the Aviation
Logistics Center (ALC) shall release a time compliance technical
order (TCTO) to include an Enterprise Framework plan to ensure the
continued safe operation of activities within existing hangar
facilities while pursuing the safe discontinuation of foam FSS.
This Enterprise Framework plan shall include any risk-mitigation
strategies and processes required for safe interim use until
permanent code compliant solutions per the recommendations of the
Aviation Hangar Fire Suppression IPT are in place. The TCTO may
include updated maintenance or other safety procedures, enterprise-
wide mitigation measures or hangar-specific measures for unit
personnel to implement before placing foam FSS out of service
focusing on the safety of personnel and lowering the risk of hangar
fuel-related fires to the greatest extent possible while balancing
impact to operations.
    b. No later than 45 days after release of the TCTO, units shall
follow the guidance in the TCTO to implement interim mitigation
measures. All water sprinklers, alarm panels, and sensors are to
remain in operation unless specifically directed by TCTO.
    c. No later than 60 days after release of this message, the
Aviation Hangar Fire Suppression IPT will complete an inter-
disciplinary risk assessment in accordance with the 2022 update to
the National Fire Protection Association (NFPA) code to determine
the appropriate class bravo fire suppression system when required
and provide recommendations to senior leadership regarding the
appropriateness of installing water only fire suppression systems
in Coast Guard hangars.
    d. No later than 180 days after the conclusion of the Aviation
Hangar Fire Suppression IPT, SILC in coordination with appropriate
stakeholders shall initiate a plan to remove and dispose of AFFF
systems as required. SILC will also initiate projects per the plan
to replace existing foam FSS in all Coast Guard hangars in
accordance with the recommendations of the Aviation Hangar Fire
Suppression IPT. SILC shall track estimated timelines and resources
required to bring existing hangars into code compliance. The
provisions of REF (B) remain applicable to all Coast Guard
facilities, until superseded by approved IPT outcomes, and must be
used as the minimum standard for the planning and development of
projects and procurement of facilities. These projects shall be
prioritized for funding and execution per established policies
and processes.
4. For any questions, contact LCDR Erin Dougherty, COMDT (CG-437)
at (571)-613-1275.
5. RDML Amy B. Grable, Assistant Commandant for Engineering and
Logistics (CG-4), sends.
6. Internet release is authorized.