Modernizing infrastructure to comply with the Air Force Sundown Policy for foam fire suppression systems
At a glance
Congress gave the Department of Defense (DoD) an Oct. 1, 2024 deadline to stop using aqueous film forming foam, or AFFF, to fight fires when it passed the 2020 National Defense Authorization Act.
The mission
In November 2021, in response to the congressional mandate, the U.S. Department of the Air Force released a Sundown Policy for foam fire suppression systems, which requires the removal of aqueous film-forming foam (AFFF) fire protection systems, which contain PFAS (per- and polyfluoroalkyl substances). These substances continue to raise concerns globally as we learn more about the very large scope, scale and impacts of their presence and potential risks to human health and the environment.
The Sundown Policy, and subsequent memorandum, states that all Air Force hangars and similar facilities equipped with fire suppression systems, categorized as Tier 2 Fire Protection Facilities, must be upgraded to include extra hazard automatic sprinkler systems using water instead of foam.
The challenge
Building 1225 (Hangar 8) is a 43,800-square-foot aircraft maintenance hangar with 17,700 square feet of office and administration space located at Joint Base Andrews in Prince George's County.
When Hangar 8 was previously upgraded in response to the Air Force Sundown Policy, the hangar bay and parts of the office space were left unprotected when the AFFF system was locked out/tagged out, leaving the hangar facility and military personnel at risk of PFAS release impacts, should there ever be a fire or false activation of the fire suppression system.
Our response
GHD was contracted by the Air Force to design the corrective actions necessary to provide proper fire protection for the aircraft and hangar facility.
We prepared construction documents for a comprehensive renovation of Hangar 8, including modernization to upgrade the fire suppression system in accordance with Unified Facilities Criteria (UFC) 4-211-01 Aircraft Maintenance Hangars; UFC 3-600-01 Fire Protection Engineering; and UFC 4-010-01 DoD Minimum Antiterrorism Standards for Buildings, with Change 2; in addition to the Air Force Sundown Policy for foam fire suppression systems.
As the designer of record, we provided project management, field surveys, life safety analysis, fire protection engineering, structural engineering, architecture, hazardous materials surveying/testing, and electrical engineering.
After 50 percent submission, the Air Force issued Change 2 of the Sundown Policy, which required GHD to modify the design documents for Hangar 8. We removed infrared flame detection from the design and other provisions for a future foam releasing system that were no longer applicable to the latest Sundown Policy received during the design period. Even with this modification, we were able to deliver 95 percent of the design documents within the original deadline.
GHD has provided deliverables on time and with limited comments and reviews to the proposed design. Despite the changes related to the updated Sundown Policy, GHD kept the cost under the construction cost limitation.
The impact
Our understanding of converting systems to comply with the Air Force Sundown Policy and AFFF disposal, along with our fire protection engineering and contaminant assessment and remediation experience, allows us to anticipate and interpret design, cost and schedule impacts. It also enables us to help our federal clients improve decision-making for site-specific conditions of PFAS investigation, identification, assessment and remedial technologies.