Foam in focus – 1st National Foam Forum and Workshop on Fire Fighting Foam
Published: 09 December, 2011
Industrial Fire Journal reports on the 1st National Foam Forum and Workshop on Fire Fighting Foam that was held as part of the Contaminated Site Remediation Conference ‘CleanUp 2011’ in Adelaide, 11th September 2011.
The 1st National Foam Forum and Workshop on Fire Fighting Foam was held at the Adelaide Hilton on Sunday 11th September 2011. This forum and workshop was arranged as a short course forming part of the Contaminated Site Remediation Conference CleanUp 2011 by CRC Care, the main conference organisers, and sponsored by Solberg Asia-Pacific. The event was chaired by Dr. Marion Healy, Director of NICNAS (The National Industrial Chemicals Notification and Assessment Scheme, DoHA), the Australian federal regulator. A wide range of international speakers contributed coming from Australia, Canada, Germany, France, Norway, Singapore, the UK, and the USA. Approximately 40 delegates attended the event on the day. A minute’s silence was observed at the start of the Workshop commemorating the 10th anniversary of 9/11 and those who lost their lives.
The National Industrial Chemicals Notification and Assessment Scheme: Marion Healy
Marion Healy (NICNAS) opened the Forum and Workshop with a discussion of fluorochemicals and application of the Stockholm Convention on persistent organic pollutants (POPs). She described in detail the POP profile for PFOS, highlighting persistence, bio-accumulative potential, potential for long-range environmental transport, and toxicity. The inclusion of the potential for long-range transport distinguishes the POPs criteria from a standard PBT profile. International Actions as well as Australian Actions were summarised in two highly informative slides. The Conference of Parties (CoP) to the Stockholm Convention has decided to include PFOS, its salts and perfluoro-octanyl sulphonyl fluoride (PFOSF) in Annex B of the POPs convention. Of particular interest was the Australian Government’s position on PFCs of concern – perfluoroalkyl sulphonates (PFAS) and perfluorocarboxylic acids (PFCA) – or those fluorinated materials that may degrade to yield them. Data requirements for new chemicals related to this class of PFAS/PFCA apply to perfluorinated chain lengths of C4-C24; in the absence of specific data this will default to data for PFOS or PFOA, except for PFBS where a NICNAS hazard assessment will be used; and persistence, bioaccumulation and toxicity will be based on three substances unless additional data can be provided. Moreover, PFBS-based chemicals may only be used for non-dispersive applications, whereas PFAS/PFCA chemicals will be restricted to essential uses only, unless the default conditions can be shown not to apply; essential uses for PFOS and PFOA do not include fire fighting. Newer chemicals will be assessed based on data provided for PFHxA. Overall Marion Healy’s presentation indicated a very much heightened degree of awareness at Australian federal level that highly fluorinated chemicals require increased environmental scrutiny and availability of specific data for sensible decisions to be made.
Department of Environment and Conservation, Western Australian Government: Jimmy Seow
Jimmy Seow (Department of Environment and Conservation, Western Australian Government) discussed the issues of major concern to a regulator; the likely environmental impact of fire fighting chemicals; chemical analysis for their presence in various environmental compartments; disposal of fire fighting foam and contaminated fire-water run-off; possible remediation strategies for soil and groundwater affected by fluorinated foam products; the balance between operational fire safety and the environment; realistic cost-benefit analysis; and possible changes to fire fighting methodology and operational techniques. Comparative data on toxicity, BOD, biodegradability (persistence), bioaccumulation and oil emulsification were provided. Jimmy Seow also made the important points that currently no completely ‘environmentally benign’ fire fighting foam exists and that many agencies in Australia, unlike the UK or US, do not have any written policies on the use of fire fighting foam other than it must have minimal or no impact on the environment.
German Federal Environment Agency: Annegret Biegel-Engler and Christoph Schulte Annegret Biegel-Engler and her colleague Christoph Schulte (German Federal Environment Agency – Umweltbundesamt).
They provided the Workshop with a very thorough and comprehensive description of recent measurements made in Germany of fluorochemical contamination. Detailed analyses of PFCs in groundwater, soil and vegetables for PFCs were carried out by the Environment Agency of Nord-Rhein-Westfalen in Düsseldorf for an incident in May 2001 involving a plastic crates fire in Düsseldorf-Gerresheim at which 42m3 (42,000 litres) of AFFF were discharged. Ten years later groundwater in a plume running WSW from the incident site still showed PFCs levels in excess of 40 µg/l (40,000 ng/l), with PFOS and PFHxS as the predominant contaminants. Specific soil foci were also contaminated with PFCs levels > 1mg/l (1 ppm). Vegetables grown in local allotments showed plant-specific contamination; celery and beans were more highly contaminated with PFCs than other vegetables. PFC pollutants in surface water along the River Elbe are characterised by high levels of PFOS, PFOA and PFHxA; approximately 50% of the samples also contain significant levels of 6:2 FtS, the degradation product from fluorotelomer surfactants. Use of waste-water treatment plant (WWTP) sludge as agricultural top-dressing resulted in PFC pollution of water in the Möhnetal catchment area near Dortmund. Animals including man also become contaminated with PFCs. Annegret Biegel-Engler showed data from the German database for human blood plasma concentrations for 1982-2010; although PFOS concentrations in human plasma have shown a steady decline since the early 1990s, PFOA and PFHxS concentrations have remained substantially unchanged. Finally she addressed regulatory issues at national and international level, stressing that regulation was necessary. Representing the position of the German federal regulatory body, the take-home message from her slides was clear, although some in the industry would strongly disagree and take a different point of view: “....Per- and polyfluorinated chemicals replacing PFOS in fire fighting foams are not an environmentally friendly alternative....” and one should preferably “....do without per- and poly-fluorinated chemicals and prevent their discharge into the environment...”.
Cambridge, UK: Roger Klein
Roger Klein (Cambridge, UK) presented a brief historical review of the environmental concerns over the use of fluorochemicals that have surfaced subsequent to the 3M Company’s decision in May 2000 to withdraw from the manufacture of fluorosurfactants and related chemicals based on PFOS chemistry, including LightWaterTM and ATC TM fire fighting foams. These have led to banning of PFOS in European Members States from 27 June 2011, the inclusion of PFOSF, PFOS and its salts in Annex B to the Stockholm Convention on Persistent Organic Pollutants (POPs), as well as to continuing concern over the potential carcinogenicity of PFOA and higher perfluorocarboxylic acid homologues. An industry stewardship program aims to remove substantially PFOA contamination from products by 2015. European Directives and nationally based legislation affecting the discharge to groundwater of fire fighting foam run-off contaminated with fluorosurfactants, all of which are organohalogens, were considered in detail, especially the implications of the Water Framework Directive and its Groundwater Daughter Directive which come into force in 2013.
Solberg Scandinavian Norway: Jan Solberg
Jan Solberg (Solberg Scandinavian, Norway) gave delegates a thought-provoking insight into some of the ethical issues which face a foam manufacturer. In particular his catchphrase – ‘People, Planet, Profit’ – highlighted the competing priorities in producing and marketing any product that is to be used in a highly dispersive manner such as fire fighting foam. Balancing short-term profit against long-term liability, customer confidence and brand name reputation, requires a thorough analysis of a range of factors, some of which may not be directly quantifiable such as unforeseen and currently unknown future product impact on the environment or human health.
Alert Disaster Control Singapore: Mike Allcorn
Mike Allcorn (Alert Disaster Control Singapore) presented a highly experienced practitioner’s point of view on process risk management and incident remediation considerations within the oil and gas industry. His presentation stressed the need to eliminate or at least alleviate the impact of major incidents in the petroleum and petrochemical industries on human life and the environment as well as on property. In particular he highlighted the potential impact that mitigation procedures such as fire fighting might have. He showed many examples of very large fires involving storage tanks, oil rigs and well heads, also including shipboard fires. Fires on this scale had been successfully fought and brought under control using both AFFF-type and fluorine-free fire fighting foams. Mitigation activities, such as fire fighting, however, come with associated liabilities; these include a liability to protect human life and the environment from the procedures and products used. Moreover these liabilities may be subject to regulatory body oversight as well as civil or criminal legal proceedings.
University of Newcastle NSW: Tex H Schaefer, Bogdan Dlugogorksi and Eric Kennedy
F’ for fluorosurfactants. Copyright Thierry Bluteau Bio-Ex SA.
Ted H. Schaefer (with Bogdan Dlugogorksi and Eric Kennedy, University of Newcastle NSW) described laboratory-scale measurements of Class B fuel vapour suppression using various fire fighting foams. A layer of hydrocarbon fuel was covered with a foam blanket in a thermostatted enclosed test rig and mass transport of vapour through the foam blanket was detected by gas chromatography. Comparative data were given for AFFF and fluorine-free foams which, although showing breakthrough earlier than the sample of AFFF used, still had substantial vapour suppression capability in excess of what is actually required operationally in spite of the thin foam blanket used in the tests. Interestingly the drainage characteristics of the fluorine-free foam used were approximately five-fold better, ie, drained more slowly, than for AFFF indicating excellent foam blanket stability in the absence of fluorosurfactants.
Bio-Ex France: Thierry Bluteau
Thierry Bluteau (Bio-Ex France) in his presentation entitled ‘Proper Formulations for Class A Fires’, after describing the general distinguishing features of Class A or carbonaceous fuel fires, indicated the essential properties required of formulations for a Class A foam (0.5%) or wetting agent (0.1-0.2%). Not only must the product be capable of reducing the surface tension of water from 72 mN/m to between 16 and 30 mN/m, but it must also have good wetting properties, ie, good penetration, for carbonaceous substrates. Standardised tests for wetting potential show that certain hydrocarbon surfactants are especially efficient whereas fluorosurfactants are rather poor at wetting and penetrating solid carbonaceous fuels. Delegates will remember Thierry’s eye-catching cartoons (see above) used to make this point – Monsieur H the hydrocarbon surfactant capable of penetrating a carbonaceous fuel, and Monsieur F the fluorosurfactant which could not do so nearly as efficiently. This distinction is important practically since fluorosurfactant-based Class B foams do not perform as well operationally on Class A fires, eg, wildland fires, as correctly formulated Class A products. There have been recent incidents with just this problem involving car tyre and plastics fires.
Airservices Australia: Craig Barnes
Craig Barnes (Airservices Australia) discussed the issues involved in managing the decision taken in October 2010 to move from AFFF to a fluorine-free product for ARFF use at the 39 airports in Australia under its control. Taking the decision on environmental grounds to move to an ICAO level B compliant foam that did not contain fluorochemicals but maintained operational requirements and was fit-for-purpose involved not only testing but ensuring stakeholder engagement. These included Commonwealth Departments, State EPAs, Sewer Authorities and the airports themselves. A number of significant legacy contamination issues became apparent: soil, sediment, surface and ground water; spill clean-up materials; training ground infrastructure, ie, concrete aprons and water treatment systems; equipment on trucks that had been in contact with foam, such as hoses and seals; and personal protective equipment (PPE).
Autopyro Canada: Bernard Valois
Bernard Valois (Autopyro Canada) was concerned with quality assurance tests for ARFF vehicle foam systems and their impact on the environment. Apart from the foam concentrate having to meet international standards such as the ICAO Airport Service Manual part 1, ICAO levels A and B (with ICAO level C pending), ISO, UL, BSI, or US MilSpec, it is essential the foam proportioning system is tested and that the finished foam provides the intended fire performance. Specific tests for properties such as drainage times may be especially important for ARFF use. Regulatory compliance involves in-service targets such as maintenance and testing downtimes, as well as the impact of operational use and training/testing on the environment. The first consideration should be requirements of the local jurisdiction and ICAO SARPs, followed by the expectations of local management and shareholders.
UTC Australia: Brett Staines
Brett Staines (UTC Australia) explained why, in his opinion, a reduction in the environmental impact of fire fighting foams whilst maintaining high performance could be best achieved with AFFF-type foams rather than fluorine-free foams, through using new generation fluorosurfactants based on C6-fluorotelomer chemistry, a point of view that some both in the industry and amongst regulators would currently take issue with. He rightly stressed that regardless of which type or generation of foam that is used, foam should not be released into the environment unnecessarily. His presentation contained a useful summary of measures to reduce environmental impact from fire fighting foam including product substitution, containing any release (ie bunding, catchment pits, sealing drains), waste water treatment, and modification of operational procedures and work practices.
DuPont USA: Stephen Korzenowski
Stephen Korzenowski (DuPont USA) gave forum participants an excellent update on progress being made by Martial Pabon and his colleagues at DuPont in collaboration with the Ecole centrale de Paris, on the development of technology to remove fluorosurfactants from the very large volumes of fire-water run-off produced at an incident. Early work, as described previously by Martial Pabon at one of the Reebok seminars in the UK, used granular activated carbon (GAC). Greatly improved industrial-scale methodology involving electrocoagulation in the presence of Al3+ ions, followed by floc separation using H2 bubbles and filtration, and finally a reverse osmosis step, is capable of reducing the concentration of the perfluorinated surfactant from 115 ppm to 10-16 ppb – an improvement of some 10,000-fold. Activated carbon can be used as a further purification step after reverse osmosis. Once the equipment is available this method has the major advantage of being relatively cheap to run – estimated cost less than $1 per cubic metre (1 tonne) contaminated effluent. Both electrocoagulation and reverse osmosis cells can be fabricated as mobile, transportable units on skids allowing post-incident on-site treatment of contained run-off. Details of this technique and its development have been published recently in Separation and Purification Technology 76(2011) 275-282. DuPont are to be congratulated on developing this thoroughly practical and potentially highly cost-effective approach to mitigating the environmental impact of contaminated fire-water run-off which, with scaling up, has operational potential for fire departments worldwide especially for large-scale incidents where volumes may run to tens of millions of litres.
Round table discussion
An extremely lively round table discussion was held at the conclusion of the forum and workshop with the aim of formulating a position paper on environmental best practice in specifying fire fighting foams for operational use. This position paper will eventually appear as a technical report published by CRC Care and edited by Marion Healy and Roger Klein.