Firefighting Foam: What on Earth is going on? · considering that fluorine-based fire-fighting foams could have negative environmental, human health and socioeconomic impacts due

Protecting lives, the environment and critical assets

Firefighting Foam: What on Earth is going on?

© Angus Fire

The JOIFF Foam Summit 2020

10th February 2020 – London, UK

Presenter: David Plant

Protecting lives, the environment and critical assets © Angus Fire

The firefighting foam industry from 40,000 feet


Firefighting foam concentrates

Fluoro’surfactant

Hydro’surfactant

Solvents

Polymer

Water

Supply chain

Manufacturing

Point of sale

Point of use

End of life

EHS and OHS (CLP)

Fire performance

Formulation R&D

Raw mat. R&D

Formulation


Foam should be boughtwhich meets

site-specific needs

Manufacturers have products, end-users assess their risks,then buy the product which best meets their needs.


Some site specific needs – nothing here is new

Hazard management

Geography & hydrology

Reputation

Fire performance

DestructionApplication techniques

Training & SOP

Legislation


“C6 purity compliant”

… no one can substantiate statements that fluorotelomerproducts are “PFOA free” or have “Zero PFOA” even if test results are below the limit of detection.

“

Source: DuPont (2007), Chemours (2019)

What does “C6 Purity Compliant” mean?


Angus Fire’s guidance

Foam choice is always up to the user and the offering will be governed by regulations (both performance and environmental) which manufacturers will continue to comply with.

PFOS should not be used and should be responsibly disposed of.

Users must decide your position on C8 and C6 containing at least

traces of PFOA and precursors then take responsible action.

The use of F3 for uncontained, dispersive releases should be considered.


Australia regulations (QLD, SA, NEMP) – covers use

https://www.google.co.uk/url?sa=i&rct=j&q=&esrc=s&source=imgres&cd=&cad=rja&uact=8&ved=2ahUKEwi0k460s_jZAhUKbhQKHU2xBgMQjRx6BAgAEAU&url=https://www.marinas.net.au/industryprograms/international-clean-marina-program&psig=AOvVaw18okRKla_klzOqZLGAKv1G&ust=1521549413624719


US States – many different approaches

Washington

– 2018: Ban on training with PFAS foams

– 2019: Duty of manufacturers to inform users

– 2020: Ban on sale of PFAS firefighting foams

– 2024: Permitted exemptions expire (i.e. tank storage)

California

– Proposition 65 (Safe Drinking Water and Toxic Enforcement Act)

– Three routes of exposure; Occupational, Consumer, Environmental

– Bounty hunter provision (¼ and ¾)

– 2018: Listing of PFOA as developmental toxicant

– 2019: Discharge prohibition comes into effect

Kentucky

– 2020: Ban on uncontained release of PFAS foams

– Unless it is in an emergency


US Federal – the wider political backdrop

Congresswoman, for PFOA and PFOS our answer is yes.

“

Source: DuPont (2019)

Source: EWG (2018)


▪ Federal Aviation Authorisation Reauthorisation Act

– 2021; FAA must permit the use of F3 at certified airports

▪ National Defence Authorisation Act

– 2023; F3 mil-spec must be available (currently mandates fluorosurfactants)

– 2023; Services must be able to buy from it (i.e. commercially available)

– 2023; Prohibits Services buying PFAS foams (i.e. >1ppb of C8 or C6 PFAS)

– 2024; Prohibits use of PFAS foams (exemptions for shipboard use)

▪ Toxic Release Inventory (Right to Know Act)

– 2020; 100lbs of certain PFAS, incl. PFOA (huge volume of foam, even for C8)

– 2022; EPA to consider adding PFHxA (C6) to the list

▪ PFAS Action Act (veto threat from White House)

– 20xx; Listing PFOS & PFOA as hazardous therefore legally mandating clean-up

– 20xx; Disposal of PFAS foams only via incineration at specialist facilities

US Federal – the wider regulatory backdrop


Global public opinion (largely factory emissions)

Extraordinary true story of a kind of cover-up in corporate America, that I didn’t know.

“

Source: Graham Norton (2020)


Canadian drinking water regulations

Exposure to PFAS in drinking water is not considered to pose a risk to Canadians if levels fall below the Health Canada screening values.

“

Source: Health Canada (2019)

Health Canada has set drinking water screening values for C4, C5, C6, C7, C8, C9 and precursors 6:2FTS and 8:2FTS.


United Nations – covers production & use

... use alternatives to PFOA, its salts and PFOA-related compounds, where available, feasible and efficient, while considering that fluorine-based fire-fighting foams could have negative environmental, human health and socioeconomic impacts due to their persistency and mobility.

“

Source: POPRC (2019)

By the end of 2022 … but no later than 2025, restrict uses of fire-fighting foam that contains, or may contain PFOA, its salts and PFOA-related compounds to sites where all releases are contained.

“

Source: POPRC (2019)


End of life destruction

Should purchasers now be looking at whole-life-costing for foam concentrates?

When disposal of [fluorinated] Class B foam concentrate is required, it is recommended that it be sent for thermal destruction (high temperature incineration) to a facility capable of handling halogenated waste or the equivalent.

“

Source: The Firefighting Foam Coalition (2016)


The future isn’t what it used to be …

Source: backgroundpictures.org


High performing F3is available


What is meant by

viable alternative

Foam formulators must be part of the conversation, but end-users and regulators (performance and environmental)

must work together to set the rules and targets.


Does it work?

Can I use it?


“Does it work?”

The curves are a “worst case” representation of the firefighting capabilities of a specific foam and are NOT meant to be an actual curve fit of the data.

“

Source: Fire Protection Research Foundation (2020)

FFFs are not a “drop in” replacement for AFFFs. However, some can be made to perform effectively as an AFFFalternative with proper testing and design.

“

Source: Fire Protection Research Foundation (2020)


“Does it work?” – Respondol ATF

Features– High performing AR-F3 (Alcohol Resistant Fluorine Free Foam)

– Class A & B – hydrocarbons and polar solvents

– EN1568 pt 3 & 4; 1A/1A (FW & SW)

– UL162; Heptane, 15% ethanol/gasoline blend (Direct – FW & SW)

– UL162; IPA, Ethanol, Methanol (Indirect – FW & SW)

– Lastfire; Semi-aspirated, Aspirated & System (FW & SW)

Benefits– Low viscosity for ease of induction

– Versatile application techniques; direct and indirect

– Combination of Class A & B, hydrocarbons and polar solvents



Source: Lastfire (2017)

Prop size: 100 m2

Fuel: Prem. gasolinePre-burn: 2 minFreeboard: 250 mmFlow rate: 1,000 L/minApp. density: 6.5 L/min/m2

Prop size: 100 m2

Fuel: Prem. gasolinePre-burn: 2 minFreeboard: 250 mmFlow rate: 410 L/minApp. density: 4.1 L/min/m2

Successful extinguishment(aspirating & non-aspirating nozzles)

Successful extinguishment(system pourer)



40m x 7.5m x 150mm Jet-A = Extinguished in 3’27”30m x 7.5m x 150mm Jet-A = Extinguished in 2’23”(Compressed Air Foam: ACAFS pourer at 2.0 L/min/m2)

33m x 2.25m x 150mm Jet-A = Extinguished in 2’32”(Aspirating foam chamber at 4.1 L/min/m2 – NFPA rate)

Source: Lastfire (2018)

Prop size: 300 m2

Fuel: Jet-APre-burn: c. 1 minFlow rate: 594 L/minApp. density: 2.0 L/min/m2

Successful extinguishment

Prop size: 74 m2

Fuel: Jet-APre-burn: c. 1 minFlow rate: 300 L/minApp. density: 4.1 L/min/m2

Successful extinguishment


“Does it work?” – Respondol ATF test results

Applications Supporting Data

Foam branches

Wharves & jetties

Monitor range finding

Foam chambers

Tanker loading racks

Mobile monitors

Rim-seals

Fixed foam monitors

Subsurface injection

Water miscible products

Min foam qualities

Min application density

Monitor drop-out

Corrosion

Viscosity

Vapor suppression

Test data available


“Can I use it?” – Respondol ATF

GreenScreen Certified makes it simpler for purchasers to identify safer firefighting foams by certifying that they meet rigorous environmental and health criteria.

As more PFAS-free firefighting foams become available we need to ensure these alternative products are not equally hazardous to firefighting personnel or the environment.

“

Source: San Francisco Department of the Environment (2020)


Existing engineered systems – opening Pandora’s Box

Any source of great and unexpected troubles.

“

Source: Wikipedia (2020)


Our industry’s challenges

▪ Does it work? Can I use it?

– Site-specific needs and risks are paramount

– Independent environmental certification avoids regrettable substitutes

▪ The future is not what it used to be

– Containment, clean-up and disposal of C6 is advised and required

– High performing F3 foams are available where needed

▪ Existing engineered systems are a challenge

– ‘Zero’ or ‘PFAS free’ is not possible or practical. “How clean is clean?”

– Test data is available for a range of applications, installations and systems

Talk with suppliers, we have done this before.

Protecting lives, the environment and critical assets

Thank you, are there any questions?

© Angus Fire

[email protected]

Global Product Manager – Firefighting Chemicals

Presenter: David Plant

Documents

Firefighting Foam: What on Earth is going on? · considering that fluorine-based fire-fighting foams could have negative environmental, human health and socioeconomic impacts due