Forever Chemicals in Firefighting Foam

SCOPE
This white paper covers the proper handling of firefighting and fire protection systems which contain the class of organofluorine compounds known as per- and polyfluoroalkyl substances (PFAS).

The goal of this bulletin is to inform the reader of the risks posed by existing PFAS foam systems, the testing required to safely maintain these systems, how to proceed if systems need to be replaced/retrofitted, and properly disposing of PFAS Foam.

INTRODUCTION
Per- and polyfluorinated alkyl substances are a group of over 4,000 manufactured chemicals, collectively referred to as PFAS, that have recently entered the national spotlight as emerging contaminants with serious adverse impacts on human health, even at low concentrations in the parts per trillion range.

The PFAS Action Act of 2021 is a bill that is attempting to further limit the use of per- and polyfluoroalkyl substances in firefighting foams. A majority US states (31 to date) ban the use of PFAS or AFFF foam for training or testing exercises, and several states (Washington, Minnesota, Colorado, New Hampshire, New York, Connecticut, California – starting in 2028) have enacted outright bans on the use (manufacture, sale, and distribution) of PFAS foams in firefighting systems. PFAS foam is typically used for extinguishing flammable liquid and petroleum hydrocarbon fires. Common labels for these foams are AFFF, AR-AFFF, FFFP, AR-FFFP, FP, and FPAR (“Fluorinated Foam”). The Fluorinated Foam ban will occur in phases and the law immediately bans the use of Fluorinated Foam for training or testing systems in almost all states.

The EPA has proposed to classify perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), better known as the Superfund Act. This “would require entities to immediately report releases of PFOA and PFOS that meet or exceed the reportable quantity to the National Response Center, state or Tribal emergency response commission, and the local or Tribal emergency planning committee (local emergency responders).” If this goes into effect, it will leave polluters financially responsible for cleanup.

Firefighting foam systems containing PFAS, such as AFFF (Aqueous Film Forming Foams), are found in a variety of chemical, aviation, and military occupancies. While not an exhaustive list, the following are examples of occupancies where PFAS agents might be found:

• Fire Stations
• Fire Training Facilities
• Refineries, Terminals, & Bulk Fuel Storage Farms
• Department of Defense/Military Bases
• Commercial and Private Airports
• Landfills (leaching from consumer products)
• Biosolids Land Application
• Rail Yards
• Chemical Facilities
• Plating Facilities
• Textile/Carpet Manufacturers
• Residential Septic Systems
• Marine Offshore Platforms

AFFF was the most common firefighting foam for decades, favored for its vapor suppression and flammable liquid fire extinguishing capabilities. These chemicals are being phased out in favor of less hazardous chemicals in order to protect public health, the environment, and firefighters.

DISCUSSION/EXPOSURE RISKS FROM RELEASE
Research performed by several entities has linked exposure to PFAS with an increased risk of cancer, birth defects, reproductive problems, and other negative health effects. While the firefighting foams are highly effective at their intended purpose, PFAS are also endocrine system disruptors, which can have negative effects on the parts per trillion scale. Endocrine system disruptors block hormones, which are naturally present at parts per billion concentrations in blood, from binding to the correct receptors in the body. The Improper disposal of PFAS containing firefighting foams provides a route for PFAS to enter the groundwater, surface water or soil, which can expose larger populations. The Federal EPA has a guidance limit in drinking water of 70 ppt. Many states have stricter laws regarding the allowable contamination levels in drinking water, and several have laws regarding allowable ground contamination levels.

To protect firefighters and the general public, it is important to minimize exposure to PFAS containing products, whether by switching to safer chemicals with similar firefighting properties, finding better methods to prevent discharged foam from coming into contact with firefighters, or avoiding exposure to release (accidental, testing, etc.) by capturing in containment systems.

AFFF and PFAS containing firefighting foams have been used extensively for decades in both manual firefighting and automatic fire protection systems. NFPA standards that include requirements for the design, installation, and maintenance of these foam systems include:

• NFPA 11 (Standard for Low-, Medium-, and High-Expansion Foam)
• NFPA 16 (Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems)
• NFPA 30 (Flammable and Combustible Liquids Code)
• NFPA 409 (Standard on Aircraft Hangers)

When a foam system is actuated, foam concentrate is added into the water stream through a proportioner using either bladder (pressure) tanks or a pump to move the foam concentrate from the storage tank to the proportioner. While the amount of foam concentrate stored in tanks may seem relatively small, because it is proportioned into the water stream at only 3% or 6% solutions, the effective volume of the release of PFAS is many times more than the size of the tanks on site

The PFAS foams are released into the environment when called upon to control fires, accidental discharges occur, and, most commonly, for routine required testing of these foam systems. NFPA 25 (Standard for the Inspection, Testing, and Maintenance of Water-Based Protection Systems), Chapter 11 details the minimum requirements of routine testing and maintenance to confirm the reliability of these systems. The “complete foam-water sprinkler system operational test” has an annual frequency recommended and, when multiple systems are present, it is recommended that “the maximum number of systems expected to operate in the case of a fire shall be tested simultaneously to assure the adequacy of the water supply and concentrate pump.” The discharge from such tests can therefore be quite large. Favorably, that standard also states: “where discharge from the system discharge devices would create a hazardous condition or conflict with local requirements, an approved alternate method to achieve full flow conditions shall be permitted.”

SOLUTION/GUIDANCE

NEW FIRE FIGHTING FOAM SYSTEMS

• All new firefighting foam systems should utilize UL-Listed or FMG Approved synthetic fluorine-free foam (SFFF) agents. There are now several listed/approved SFFF agents with additional foams regularly being added to market.
• Where local regulations prohibit the discharge of firefighting foam for testing purposes, alternate means of completing the full flow testing should be provided per NFPA 25 chapter 11. It may be desirable to provide a means to use a recognized surrogate liquid for testing regardless of the local requirements to reduce liability exposures.

PFAS Foam Issue | 4

• Where possible, provide containment and drainage to a safe location as part of the original building planning process.

EXISTING FOAM SYSTEMS MANAGEMENT

• Determine your specific State requirements and laws on the use of PFAS Foams in firefighting systems – complete ban on PFAS Foam and/or AFFF system replacement required, satisfactory to keep in place, etc.
• Weigh whether the replacement of traditional fluorine-based foams with fluorine-free foam alternatives will achieve any desired Environmental, Social, and/or Governance (ESG) company initiatives.
• If required by State Law, replace or retrofit existing PFAS Foam Fire Fighting systems with a firefighting foam that is UL-Listed or FMG Approved, synthetic fluorine-free foam (SFFF) agent.
• Consider replacement of the PFAS firefighting foam systems with acceptable alternative fire protection schemes/systems (water based – spray/mist, deluge, SafeSpill System, etc.) for the specific fire hazard.
• Clients should carefully plan for the expense, impairment, etc. for retrofit or replacement.
• Retrofitting or converting an existing PFAS – AFFF Fire Fighting System to a Fluorine-Free Foam Checklist Guide:
  1. Account for environmental components before starting
     – Disposal of existing concentrate and equipment
     – Cleaning of remaining equipment
     – Soil contamination
     – Concrete contamination / leachate
  2. Select the foam concentrate
     – Green Screen Certified?
     – Is alcohol resistant foam needed?
     – Listed for use on the fuel it will be protecting?
     – Is a Military Specification needed?
     – When evaluating suitable replacement foams, consider items such as:

• Effectiveness at Vapor Suppression
• Fire Extinguishing Efficiency
• Ability to Form a Reliable and Self-Healing, Cohesive Blanket
• Burnback Resistance
• Heat Resistance
• Ability to Seal against Hot Surfaces and Prevent Edge Flickers
• Stability
• Flowability
• Fuel Resistance – Oleophobicity, Resistance to Breakdown by Volatile Hydrocarbons (Eg. Gasoline), and Water Soluble Fuels (Eg. Alcohols), etc.
• Determine design density and application rate – Higher densities and/or application durations may be required to achieve the same level of suppression.
  – NFPA 11 & manufacturer’s density requirements
  – Listing requirements (which may exceed NFPA 11)
  – Fuel type
  – Discharge type
  – Expected fire area (tank, spill, diked area, etc.)
• Determine Discharge type
  – Required expansion ratio – can discharges meet it?
  – Sprinkler heads
  – Foam makers / chambers
  – Directional nozzles
• Piping and supporting infrastructure
  – Can existing piping system meet flow rates? If not, modify or replace the system
  – Did the discharge type change (i.e., was sprinklers, now foam makers?)
  – Pipe – “keep and clean” or replace?
• Foam proportioning
  • Is new concentrate listed with existing proportioning system? If not, replace:
  – Proportioner
  – Foam pump, if applicable
  • Has the flow rate changed outside of existing capabilities
• Foam Storage
  – New flow rate x duration – is existing storage enough?
  – Is existing storage system listed with new concentrate?
  – Is existing storage contaminated with old foam?
• Water Supply
  – Can existing supply (including fire pump if there is one) meet new demand?
  – Is a new backflow preventer needed?
• Plan Review
  – Ensure foam replacement is acceptable to the Authority Having Jurisdiction (AHJ)
  – Solicit plan review comments from the lead incumbent property insurance carrier, as well as the environmental carrier.
• Update Emergency Response Plan and Inform/Train Employees
  – Fluorine-free foam is an effective alternative to AFFF, but the two agents are different. Fluorine-free foam has different application methods, discharge rates, and more. Therefore, it is important to update your testing and emergency response plans accordingly.
  – Inform and train your employees on your new fluorine-free foam fire suppression system. The new solution will not work unless properly used. Provide appropriate personnel with documentation and/or host a training workshop to ensure all essential information is covered. Of course, your employees will not be the only ones involved in emergency fire response. Therefore, it is necessary to also inform your local fire department of this change to ensure they have the training to use the new extinguishant effectively.

TESTING & MAINTAINING EXISTING PFAS BASED FOAM SYSTEMS – UNTIL RETROFITTED/REPLACED

• Do not release/use foam for any training or testing exercise for manual firefighting purposes.
• Conduct acceptable alternative foam system testing methods in accordance with NFPA 25 to reduce or eliminate foam release.
• Follow guidance of NFPA 11 Annex E.
• Fluorinated foam discharge should be avoided where possible, especially for proportioner testing, by using surrogate liquid or water equivalency test methods.
• Surrogate liquids have similar physical characteristics (viscosity, refractory index) as the foam concentrate. These liquids are environmentally friendly and typically non-foaming.
• Water equivalency testing verifies there no proportioner obstructions and that proper flow rates can be achieved. A correction factor for viscosity differences must be applied. This testing is best suited with comparable results from a traditional proportioner test or with manufacturer data.
• Closely review annual foam concentrate testing to ensure no deterioration. The refractive index, density, foam expansion, and drain time should be reviewed. Concentrate testing should also identify if the sample extinguished a test fire. If poor results, recommend foam replacement.
• Verify foam tank volume is sufficient to provide 20-minutes of foam supply at the required proportion based on a supply calculation. Obsolete, older existing foam systems may have depleted tank volumes from annual testing and inability to replace like-in-kind foams.
• Verify pre-planning/action plan is in place for containment and adequate disposal of foam release events.

PFAS FOAM RELEASE – CONTAINMENT & DISPOSAL

• Foam system releases during testing (i.e.: annual concentrate testing) should be kept to an absolute minimum and managed to a controlled location. Some best practices for AFFF containment include:
  • Developing a firewater runoff collection plan prior to discharge
  • Installing primary and secondary containment systems at the discharge site
  • Blocking nearby sewer drains
  • Building temporary dikes or booms

• Where fixed containment is not installed to control accidental release, pre-planning to manage an accidental release is recommended. Best practice is to involve the responding fire department with this process.
• Once AFFF is contained, it should be transferred to an accredited disposal facility. Disposal of fluorinated foams should be in accordance with local AHJ (consult with local fire marshal) and/or manufacturer guidance. High temperature incineration is the most common method recommended. These materials require thermal destruction at specially equipped incinerators having fluorine scrubbing technology, typically at a cost of $5-$6/gallon (2019). Deep well injection is an alternative at a cost of $1-$2/gallon (2019).
• Determine if available and utilize any existing state/local PFAS AFFF Take or Buy Back Programs for collection and disposal of contained, unused, or accidentally released foam. For instance, the state of Connecticut has established a PFAS AFFF Take Back Program.
• If AFFF is spilled on soil, that contaminated area should be treated to prevent a plume from contaminating surrounding surface water and groundwater. Contamination of water supplies could lead to significant risk of a CERCLA lawsuit. Currently the best option is in-situ remedial reagent (ISRR) treatment where the soil is injected with reagent to reduce hydraulic conductivity of the affected area. Cost is estimated at approximately $150 per ton of soil. Thermal desorption is another option, but it is currently facing issues with rollout. Cost is estimated at $100 per ton of soil.

CONCLUSION

The regulatory environment continues to evolve where PFAS materials are concerned. A proposed rule was issued by the EPA on September 6, 2022, which would list these materials as hazardous under CERCLA and require reporting of releases to the National Response Center. While existing systems are not required to be replaced at this time on a national basis, some states have banned the agent, and replacement may be required under state law. An overall risk assessment for your site may indicate that replacing existing foam agents with a non-fluorinated foam is desirable, even if not required. The replacement may require significant revamping of existing fire protection systems. New systems should use one of the available non-fluorinated agents and should be designed in accordance with the applicable NFPA standards and any restrictions in the listing of the agent used.

Sigma 7 Paragon Risk Engineering can provide risk analysis and loss prevention services (Focused visits or plan review for new/retrofit of existing AFFF Installations) for owners and operators of sites that have existing AFFF Systems.

Sigma7 Paragon Risk Engineering is a worldwide risk engineering provider with over 200 engineers in 35 countries with extensive industry experience and technical expertise. We are fully independent of any insurance company or broking entity and are part of the Sigma7 group of companies, with colleagues working in other specialized areas such as forensic post loss accounting, Business Interruption pre-loss assessments, worldwide /security threat monitoring, online e-training for site personnel and financial/risk due diligence. For more information about how Sigma 7 \ Paragon Risk Engineering Consultants can help protect, contact to learn more.