Change 1 to the MARADMIN 185/24 for the Phaseout of Fluorinated Aqueous Film Forming Foam (AFFF) and Alcohol Resistant AFFF (AR-AFFF) Fire Suppression Systems (FSS) in Marine Corps Facilities

1. Purpose. This MARADMIN announces changes to
ref (a). This update outlines new guidance to the policy,
procedures, and execution in FY25 for the phase-out of
fluorinated AFFF and AR-AFFF FSS in Marine Corps facilities and
safety mitigation for continued use of aircraft hangar crane
system, both in the Continental United States (CONUS) and
outside the Continental United States (OCONUS), to support
compliance with the Congressionally mandated phase-out of AFFF
by 1 October 2024 per ref (b). The Department of Defense has
been granted the first of two one-year extension request
described in ref (b) on 6 Aug 2024 (ref c) to allow time and
requirements development for transitions efforts to occur. This
policy does not apply to Marine Corps tactical and non-tactical
vehicles.
2.  Background.
2.a.  Other than changes outlined in paragraph three and
paragraph four; all instructions, details, and authorities
specified in ref (a) remain in effect. Directed actions performed
in ref (a) shall remain enforced with follow on actions directed
in this guidance.
3.  Changes and Clarifications.
3.a.  Category 1 Facility.
3.a.1.  Definition. Hangar with a fluorinated AFFF or AR-AFFF FSS
where the total loss of the facility or the loss of the aircraft
or assets serviced inside would result in mission failure at the
Department of Defense, United States Marine Corps, Combatant
Command or Sub-unified Command level. Category 1 designation may
also be considered for Host-Nation or other basing locations
with unique environmental requirements or operational concerns.
Marine Forces Command (MARFORCOM), Marine Forces Pacific
(MARFORPAC), and Marine Forces Reserve (MARFORRES) may submit
requests for Category 1 designations to Marine Corps
Installations Command (MCICOM) via Headquarters, Marine Corps
Plans, Policies & Operations (PP&O).
3.b.  Category Change Request.
3.b.1.Category change request by Marine Forces Command
(MARFORCOM), Marine Forces Pacific (MARFORPAC), and Marine Forces
Reserve (MARFORRES) may submit requests for category change
designations with detailed justification for the change request
to Marine Corps Installations Command (MCICOM) via Headquarters,
Marine Corps Plans, Policies & Operations (PP&O). MCICOM regions
seeking category change designations shall submit requests
directly to MCICOM POC described herein section 6.a. no later
than 45 days following issuance of this policy. Request must
include a detailed explanation on why the facility requires
category change.
3.c. No later than 60 days of the issuance of this policy,
deactivate and secure the water supply valves to each low level
suppression system zone (Lockout-Tagout) for all Category 3
(CAT 3) facilities defined in ref (a) with shutdown guidance in
ref (e).  Water supply to the overhead water sprinkler systems
must remain operational for life safety (ref f).  Provide written
notification to the MCICOM POC in the event they are unable to 
deactivate and secure LOTO of the water supply to low-level systems 
within the prescribed deadline in accordance with ref (e), ref (f), 
and ref (h). LOTO of the foam features of the AFFF/AR-AFFF completed
per ref (a) must remain enforced with ref (e), ref (f), and ref (h).
3.c.1. No later than 30 days after issuance of this policy,
HMX-1 hangars located at MCAF Quantico (ref g) shall complete
LOTO of foam systems and transition to CAT 3 fire protection
requirements to include development and implementation of fire,
safety, and environmental mitigation procedures directed in ref
(a) in accordance with ref (e) to ref (h).
3.c.2. No later than 360 days of issuance of this policy develop
and submit FSS conversion projects to meet requirements
associated with their designated facilities category ref (a) in
accordance with ref (f) to ref (h) via the Facilities
Integration Website (FI Web) as prescribed in ref (a). A
National Fire Protection Association (NFPA) 409 Risk Assessment
and Performance Based Design per ref (d) for the P201 Aircraft
Maintenance Hangar project at Marine Corps Air Station Miramar
is underway that aims to find a near term alternative fire
protection solution. A separate effort is underway that aims
for an enterprise wide long term design solution for a water
only fire protection that is estimated to complete in November
2025.  In the event that results from the NFPA 409 Risk
Assessment and Performance Based Design performed determines an
alternative fire protection requirement detailed in ref (a), then
design for a water only fire protection solution shall supersede
ref (a).
3.c.3. No later than 360 days of issuance of this policy
Installations that require spill containment and/or isolation
capabilities (e.g., shut off valve or emergency shut off for the
pump station to prevent run off into the environment, etc.) shall
submit requests to MCICOM via FI Web as prescribed in ref (a).
3.d. MCICOM Facilities Directorate shall take the following actions.
3.d.1. No later than 120 days of issuance of this policy
distribute a phase-out plan to remove AFFF and AR-AFFF from all
facilities as prescribed in ref (d).
4.  Coordinating Instructions.
4.a. AFFF/AR-AFFF Lockout-Tagout (LOTO) Procedures. LOTO of
AFFF/AR-AFFF systems for all Category 3 facilities must remain
secured in compliance with ref (a), ref (e), ref (f)and ref (h).
The water supply valves to  each low level suppression system
zone must be deactivated and secured. CAT 1 and CAT 2 facilities
will continue to utilize the AFFF FPS until the activities
described in ref (a) are programmed and funded.
4.a.1. AFFF/AR-AFFF Management and F3 Support. The Marine Corps
awarded three Regional task orders through USACE in Q4 FY24
(MCIPAC, MCIWEST, and MCB Hawaii) and one Regional task order
in Q1 of FY25 (East Coast) to support implementation of the AFFF/
AR-AFFF management and F3 replacement effort. F3 backstock for
the P19R assets at MCIWEST will be handled by the G-3/5.
MCICOM funded regional Marine Corps task orders will provide for
a single rinse (tanks and associated lines in facilities and
mobile assets) (ref i), double rinse for P19R mobile assets
(ref k), and disposal of fluorinated AFFF and AR-AFFF, and
associated rinsate. CAT 1 and CAT 2 facilities will have the
flourinated AFFF and AR-AFFF replaced with an approved MILSPEC
F3. MCICOM GF will be coordinating with regions/installations
to develop and implement the execution schedules for this effort.
4.a.2. Facilities risk assessments were conducted in Q1FY25 for
Category 2 (CAT 2) assets through a task order with Naval
Facilities Engineering Systems Command to assess the facilitity's
F3 acceptance and project requirements for final transition.
Project requirements shall be submitted to initiate programming
activities described in ref (a). Preliminary reports for the
assessments are estimated to be available in Q3 FY25.
4.b. Fire Safety and Risk Mitigation for Crane Systems Use in
Aircraft Hangars.
4.b.1. Crane systems are designed to meet the requirements in
ref (l) and ref (m). LOTO of the AFFF system does not suspend
the use of crane system in aircraft hangars, however, fire and
safety risk mitigation detailed in ref (a) shall be implemented.
4.b.2. Ensure that all aircraft hangar crane systems are
inspected for fire safety compliance regularly. Inspections
should include checking electrical systems (ref m), flammable
materials, and mechanical components for potential fire hazards.
4.b.3. Ensure personnel are trained to use the crane systems and
monitored during operations in order to respond to any fire
emergencies.
4.b.4. Implement portable fire extinguishers access for cranes
where feasible, ensure that all personnel are trained in the use
of portable fire extinguishers and adherence to safety protocols.
Regular drills should be conducted to ensure readiness and
efficiency in case of a fire event.
5.  Administration.
5.a. Reporting. Installations shall submit a monthly report to
MCICOM POC prescribed in 6a., using ref (n) identifying progress
and status in executing each of the actions prescribed in
paragraph 3 via MCICOM GF-PW SharePoint site at https:(slash)
(slash)usmc.sharepoint-mil.us.mcas-gov.us/sites/mcicom_gf_pw/
SitePages/Home.aspx.
5.b. This MARADMIN is applicable to the Marine Corps Total Force
and is effective from its date of publication.
6.  Command and Signal. Point of contact for questions or additional
information is Mr. Nicholas Spurling, Facility Sustainment Program 
Manager, (571) 256-2785, nicholas.spurling@usmc.mil.
7. Release authorized by MajGen J. G. Woodworth, Assistant
Deputy Commandant, Installations and Logistics (Facilities