PFAS Forum Date Change: Now September 9-11


Robert Bogert, P.E.

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Presentation Title

Considerations in Removal and Replacement of AFFF

Robert Bogert, P.E., Engineering and Environmental Solutions Service Line Manager, MSE Group, LLC

Abstract

• Recent regulations and best management practices related to Aqueous Film Forming Foam (AFFF) have resulted in large product replacement programs at military and non-military aviation facilities.  • Military specifications limit modern AFFF products to PFOS and PFOA concentrations less than 800 ppb.  • Recent bills have been introduced which if passed into law would require AFFF to be replaced with PFOS/PFOA-free concentrate within a few years.  Recent regulations and best management practices related to Aqueous Film Forming Foam (AFFF) have resulted in large product replacement programs at military and non-military aviation facilities.  Legacy AFFF, which contains unspecified PFAS concentrations of PFOS and PFOA and is characterized by products produced prior to 2016, have been targeted for replacement. Military specifications limit modern AFFF products to PFOS and PFOA concentrations less than 800 ppb. Current AFFF products, however, are not PFAS-free and there is a significant potential that all AFFF will no longer be used in the U.S. Recent bills have been introduced which if passed into law would require AFFF to be replaced with PFOS/PFOA-free concentrate within a few years.  There are many considerations associated with removal and replacement of AFFF from active flight lines, including but not limited to work in mission-critical military settings, Federal Aviation Authority (FAA) compliance requirements, structural and mechanical considerations for AFFF delivery systems, alarm deactivation and testing of active fire systems, and collaboration with many stakeholders associated with aviation facilities.  Additionally, environmental regulations and client best management practices are constantly changing relative to characterization, transport, and disposal of AFFF products, vessels, and personal protective equipment.  Successful implementation and risk control of such products involves careful consideration of many facets and requires adequately trained professional and construction staff.

Bio

Robert Bogert is a senior engineer serving as the Engineering and Environmental Solutions Service Line Manager at MSE Group. He has 25 years of progressive experience in program and project management, engineering design, and cost estimation in the civil and environmental engineering consulting fields.  Robert  is  well-versed  in  both  RCRA  and CERCLA  and has  focused  on  environmental  investigations  and remediation efforts related to impacts from a wide range of sources. As a professional engineer licensed in Florida, Georgia, and Mississippi, Robert has been directly responsible for managing over $65 million in projects and preparing proposals valued at over $40 million for the Department of Defense and other federal agencies. Rob is currently managing MSE’s Aqueous Film Forming Foam (AFFF) replacement projects, and a Preliminary Assessment/Site Inspection (PA/SI) for PFAS contamination at several DoD confidential locations.