MANAGING THE DELUGE:Industry Perspective on AFFF Use and Planning

October 8th, 2019

Dr. Audra Liggenstoffer

Sr. Environmental Engineer, American Airlines

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Introduction to the Deluge

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• A need to control and rapidly extinguish flammable liquid fires led to the development and mandated use of Class B firefighting foams.

• Aqueous film-forming foams (AFFFs) are a type of Class B foam that have demonstrated superior performance and have unique film-forming properties that provide shorter extinguishment times and greater after-fire protection.

• Originally manufactured by 3M beginning in the late 1960s.

• US Naval Research Laboratory (NRL) development led to the US Military Specification (Mil-Spec) MIL-F-24385F, requiring the use of fluorinated foam at Department of Defense (DoD) facilities.

• Only products listed on the US DoD Qualified Products Database (QPD) are approved for military applications.

• The Federal Aviation Administration (FAA) requires all US airports to carry AFFF agents that meet the Mil-Spec and are listed on the QPD.

• Use of AFFF mandated to Protect People and Investments.

(www.fffc.org)

AFFF Foams…So everyone will make it home safely tonight.

A Deluge of Challenges

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❑ Unknown chronic toxicity

❑ High costs of fluorinated foams (fluorosurfactantsrepresent 40-80% of the foam costs)

❑ Replacement of concentrates

❑ Volume of foam wastewater

❑ Cleanup and removal

❑ Use of these foams for incidents and exercises can negatively impact the environment

Why Fluorinated Foams?

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O2

FUELHEAT

Fire

Foams• Cool the Fuel

• Exclude Oxygen

• Suppress fuel vapor

• Prevent (re)ignition

Aqueous film-forming foam (AFFF) composition:

• Fluorinated surfactants (PFASs)

• Film-forming

• Hydrocarbon surfactants (also used in Fluorine-free Foams)

• Foam-forming

• Organic solvents

• Additional modifiers (polymers, salts, chelating agents, buffers, corrosion inhibitors, and biocides)

(Hinnant et al., 2018)

PFAS in Aqueous Film-Forming Foam (AFFF)

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• Aqueous film-forming foams (AFFFs) contain fluorinated surfactants belonging to the Per- and Polyfluoroalkyl Substances chemical family (PFAS)

• Legacy PFOS AFFF “Lightwater” – contains PFOS and PFOS-precursors; PFOA; shorter-chain PFSAs (ex. PFHxS)

• Legacy Fluorotelomer AFFF – long and short-chain PFAS; PFOA and PFOA-precursors; other PFCAs

• Modern Fluorotelomer AFFF – short-chain PFAS, do not break down to PFOS; may contain trace quantities (ppb) of PFOA and PFOA-precursors as byproducts

“Long-Chain PFAS”:

• Perfluoroalkyl carboxylates (PFCAs) with eight (8) or more carbons, including PFOA

• Perfluoroalkane sulfonates (PFSAs) with six (6) or more carbons, including perfluorohexane sulfonate (PFHxS) and PFOS

“Short-Chain PFAS”:

• PFCAs with seven (7) or fewer carbons, such as perfluorohexanoate (PFHxA)

• PFSAs with five (5) or fewer carbons, such as perfluorobutane sulfonate (PFBS)

(ITRC-AFFF, 2018)

Inventory and Industrial End-Users

• Fluorinated foam concentrates – contain a mixture of PFASs (undefined).• Types of PFASs in AFFF vary by year of production and manufacturer.

• Individual fluorinated surfactants in foam concentrates range from low ug/L (parts per billion) levels to g/L (parts per thousand) levels.• Current regulatory guideline concentrations are in parts per trillion.

• Large quantities of AFFF concentrate required to be maintained on-site for large facilities.

• Major Industrial End Users and Facilities:

❑Aviation Industry• Aviation Rescue and Firefighting

• Fuel Storage

• Terminal Buildings

• Hangars and Maintenance

• Engine Test Cells

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❑Military Defense Facilities

❑Municipal Fire Departments

❑Oil and Gas, Petroleum Refineries, Fuel Storage Farms

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A Selection of Best Management Practices (BMPs) for Managing AFFF and the Environmental

Impacts Related to PFAS

BMPs - Managing AFFF and the Environmental Impacts Related to PFAS

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FOAM CONCENTRATE

Best Management Practice (BMP) Description

Current Inventory

Use firefighting foam that meets requirements for safety/use.

Meet requirements of• Applicable NFPA standard for industry users• Underwriters Laboratories Inc., UL-162:

Foam Equipment and Liquid Concentrates• For Department of Defense (DoD) and US

Federal Aviation Authority (FAA) certified facilities:

• United States Military Specification (MIL-SPEC), MIL-PRF-24385F (2017), Qualified Product Listing (QPL)

• 14 CFR Part 139• NFPA 403

Identify chemical composition

Fluorinated component(s) may be provided on manufacturer’s

• SDS*• Certificates of Composition**

Purchasing Records• Keep records of Manufacturer-Type,

Quantity, and Purchase Date

Historical Inventory Identify & Record Historical AFFFs• Keep records of historical AFFFs used at

facility

* Information provided in SDS usually insufficient for determining fluorinated composition of AFFF.** Certificate of Composition – available by request from manufacturer.

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FOAM CONCENTRATE

(continued)Best Management Practice (BMP) Description

Replacement Inventory

Search for alternative AFFFs with low environmental impact

• FAA Reauthorization Act of 2018 (HR 302) –allows use of Fluorine Free Foam (F3) within 3 yrs

• SERDP-ESTCP, evaluating F3 against MIL-SPEC; developing a new MIL-SPEC

• DoD, 2016 policy for replacement of long-chain AFFFs to short-chain (C6) AFFF and disposal of legacy foams

• USEPA 2010/2015 PFOA Stewardship Program• USEPA Significant New Use Rules (40 CFR

721.9582)• Take-Back Programs• Consider two-foam approach with F3 used to

respond to small incidents• Monitor developments in new foam

technologies

BMPs - Managing AFFF and the Environmental Impacts Related to PFAS

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STORAGE Best Management Practice (BMP) Description

CompatibilityDo not mix different types or brands of foam

• Do not mix newer AFFF formulations with legacy types

• Triple rinse or replace tank bladders

Containment

Store fluorinated foam concentrate tanks/containers in a covered area with secondary containment

• Designate transfer areas• Ensure adequate containment volume• Reduce environmental exposure

Labelling Clearly label each AFFF container

• Type of AFFF concentrate• Intended concentration in solution• Temperature requirements• Date of Fill

InspectionInspect areas containing AFFF concentrate or solutions

• Monitor condition of tanks, containers, equipment

• Ensure that leaks are addressed promptly• Record foam incidents and usages

BMPs - Managing AFFF and the Environmental Impacts Related to PFAS

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TRAINING & TESTING

Best Management Practice (BMP) Description

PreplanningPrioritize proper education and training

• Document methods and training, with schedule for review

Testing of Equipment and Training

Eliminate fluorinated Class B foams for testing and training

• FAA Part 139 CertAlert No. 19-01, January 2019, for ARFF vehicles

USE Best Management Practice (BMP) Description

Foam Solution/ Wastewater

Collect, Treat, and Properly Dispose of Foam Solution and Runoff/Wastewater

• Collect foam solution and produced wastewater for treatment and disposal

• Avoid direct release to the environment to the greatest extent possible

Planning

Document safe handling and environmentally-effective mitigation plans to reduce exposure and minimize environmental impacts

• Develop and communicate documented processes for a facility or installation

• Consider employee, firefighter and public safety first

• Use appropriate PPE• Record of previous foam usages

BMPs - Managing AFFF and the Environmental Impacts Related to PFAS

Summary

• Plan Early:

• Monitor developments in new foam technologies and requirements

• Evaluate and project future foam needs in advance of (re-)purchase

• More effective to dispose of concentrates than foam wastewaters

• “Find your Fluorinated” – identify what types of fluorinated surfactants are in your emergency response foams.

• Consider additional ingredients in fluorinated foams, mitigation chemicals (anti-foams) and flammable liquids when determining handling and disposal procedures.

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Thank You!

Additional questions may be sent to:Audra.Liggenstoffer@aa.com

References

• 14 CFR 139.317 Code of Federal Regulations, Part 139 – Certification of Airports, Section 139.317 - Aircraft Rescue and Firefighting: Equipment and Agents. https://www.gpo.gov/fdsys/granule/CFR-2006-title14-vol2/CFR-2006-title14-vol2-sec139-317

• 40 CFR 721.9582 Code of Federal Regulations, Part 721 – Significant New Uses of Chemical Substances, Section 712.9582 – Certain perfluoroalkyl sulfonates. https://www.gpo.gov/fdsys/granule/CFR-2011-title40-vol31/CFR-2011-title40-vol31-sec721-9582

• ACRP (Airport Cooperative Research Program). 2017. ACRP Research Report 173. Use and Potential Impacts of AFFF Containing Per- and Polyfluoroalkyl Substances (PFASs) at Airports. ISBN 978-0-309-44638-9 | DOI 10.17226/24800. National Academy of Sciences. http://www.trb.org/ACRP/Blurbs/175866.aspx

• DOD. 2017. “Performance Specification: Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF) Liquid Concentrate, for Fresh and Sea Water,” MIL-PRF-24385F(SH) Amendment 2, September 2017. http://quicksearch.dla.mil/qsDocDetails.aspx?ident_number=17270

• DOD. 2018. “Qualified Products Database: “Performance Specification: Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF) Liquid Concentrate, for Fresh and Sea Water,” MIL-PRF-24385F(SH). January 26. See “View QPD data” link under Revision History. http://quicksearch.dla.mil/qsDocDetails.aspx?ident_number=94307

• Federal Aviation Administration (FAA). 2004. “Advisory Circular 50/5210-6D. Aircraft Fire Extinguishing Agents.” U.S. Deptof Transportation. July 8, 2004. https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_150_5210-6D.pdf

• Federal Aviation Administration (FAA). 2019. “CertAlert 19-01. Aqueous Film Forming Foam (AFFF) Testing at Certified Part 139 Airports.” U.S. Dept of Transportation. January 17, 2019. https://www.faa.gov/airports/airport_safety/certalerts/media/part-139-cert-alert-19-01-AFFF.pdf

• Fire Fighting Foam Coalition (FFFC). 2016. Best Practice Guidance for Use of Class B Firefighting Foams. http://www.fomtec.com/getfile.php/1316325/Bilder/Media/FFFC_bestpracticeguidance.pdf

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References

• Hinnant K M, Giles S L, Ananth R (2017) Measuring fuel transport through fluorocarbon and fluorine-free firefighting foams. Fire Safety Journal, 91: 653-661.

• Interstate Technology & Regulatory Council (ITRC). 2018. PFAS Fact Sheets. https://pfas-1.itrcweb.org.

• NFPA (National Fire Prevention Association). 2019. https://www.nfpa.org

• UL (Underwriters Laboratories, Inc.). 2018. Foam Equipment and Liquid Concentrates. Standard 162, Edition 8. www.ul.com.

• USEPA. 2015. USEPA 2010/2015. “PFOA Stewardship Program.” https://www.epa.gov/assessing-and-managingchemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-program

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