Keeping it clean

Published:  19 June, 2017

Delegates at the recent foam management seminar in Queensland, Brisbane heard how a new, environmentally-neutral disposal method for fluorochemical waste that costs as little as US$1 per litre could revolutionise the way companies handle the disposal of fluorinated foam concentrates and contaminated soil and water.

This ground-breaking development was just one of many insightful presentations delivered at the seminar at the Brisbane Conference and Convention Centre, 21-23 February. It was organised by Nigel Holmes from the Queensland Department of Environment and Heritage Protection on the implementation of Queensland’s Policy on the Management of Firefighting Foam, which came into force on 7 July 2016.

Keynote Speakers included His Honour Justice Brian Preston, Chief Judge, New South Wales Land and Environment Court; Dr Erika Houtz, Arcadis USA; and Martin Cornelsen, Cornelsen Umwelttechnologie, Essen Germany.

Nearly 200 delegates attended from a wide range of sectors

Five major themes emerged from the three-day seminar, which was opened by Dr Steven Miles, Minister for Environment and Heritage Protection of Queensland, and which was attended by almost 200 delegates. The first addressed the legal obligations and liabilities for end users and regulators, with significant implications for the lifetime costs of foam.

The second looked at modern analytical methods for uncovering the full range of potential end products of degradation for fluorinated foams, so-called ‘dark matter’, using the Total Oxidisable Precursor Assay developed by Houtz and Sedlak.

The third theme covered the development of suitable disposal methods for fluorinated waste streams, such as firewater runoff or unused fire-fighting foam considered as regulated industrial waste.

Developments in remediation technologies for contaminated soil and groundwater was the fourth key content stream. Finally, the fifth stream addressed the overarching need to carry out a suitable assessment of environmental risk when using fire-fighting foam operationally or during training, and maintenance procedures including the adequacy of the information typically available in Safety Data Sheets.

The session that seemed to leave a lasting impression on most delegates focussed on the legal obligations and liabilities of both end users and regulators. Justice Preston introduced the session with a detailed explanation of the background and application of the Precautionary Principle and environmentally sustainable development in courts in Australia and around the world. These form three of the Principles (§5, §7 and §15) of the Rio Declaration on Environment and Development 1992, to which almost all UN members were signatories. Both end users and regulators are legally obliged, as part of environmental law in Australia as well as in many other jurisdictions, to apply the Precautionary Principle if certain precedents are met. Indeed, there are cases where ministerial decisions have been ruled fatally flawed by the Courts for not considering the Precautionary Principle.

Brian J Preston, Chief Judge of the Land and Environment Court of New South Wales

The key elements of the Precautionary Principle outlined by Justice Preston included: the spatial scale of the threat - for example local or international; the magnitude of possible impacts on both natural and human systems; the perceived value of the threatened environment; the temporal scale of possible impacts in terms of both the timing and the longevity – or persistence – of the impacts; the complexity and connectivity of the possible impacts; the manageability of possible impacts, having regard to the availability of means and the acceptability of means; the level of public concern, and the rationality of evidentiary basis for public concern; and the reversibility of the possible impacts and, if reversible, the time frame for reversing the impacts, as well as the difficulty and expense of reversing them.

As Roger Klein highlighted in his presentation on the holistic assessment of environmental risk for fire-fighting foams, a balance must always be struck between operational imperatives, ie bringing the fire under control and protecting human life and health, and the need to minimise the environmental impact of fire-fighting operations both in the short and long term. Application of the Precautionary Principle, as outlined by Justice Preston, points to the need for strategic planning using standard operating procedures aimed at containing all firewater runoff especially if it contains fluorinated material, ie the foam is an AFFF, FFFP or FP product. This should also be followed by collection and disposal as a regulated industrial waste.

Such a requirement forms one of the key features of the Queensland Policy as described at the seminar by Nigel Holmes and his colleagues from the Department of Environment & Heritage Protection. Fluorinated foams satisfy most of the required trigger conditions for invoking the precautionary principle.

The lifetime costs associated with fire-fighting foam were summarised by Roger Klein. These include original purchasing costs; any change in equipment or standard operating procedures; legal liability in criminal and civil courts including class actions, breach of license conditions and loss of operating license; decontamination and remediation costs for on-site and off-site pollution; waste disposal of unused foam concentrates, firewater runoff and contaminated soils; analytical plus consultancy and legal fees; as well as political collateral damage such as loss of reputation and brand image. As pointed out in this presentation many of these costs far outweigh the original cost of the foam concentrate and can be avoided or minimised by appropriate procurement procedures and use of due diligence when carrying out an initial assessment of risk.

Rory Ross and Peter Shannon of Shine Lawyers, an internationally known environmental legal practice associated with Erin Brockovich, shook up many of the delegates with their presentation. Using a mythical case study, they highlighted the considerable liability under Public and Civil Law that can be incurred from contaminating the environment – even without the intention of doing so. Keir Bielecke of Insurance Council of Australia closed the legal session by stressing that a separate insurance policy was required to cover environmental liability for owners and occupiers of premises.

The key issues with runoff from fluorinated foam were discussed from a regulator’s point of view. These were the extreme environmental persistence of perfluorinated end-point degradation products; scientific uncertainty as to their toxicity and potential for bioaccumulation; long-range transport; proven contamination of groundwater and drinking water supplies; difficulties in managing environmental impacts as well as reversing effects or remediation of contaminated soil and water; and political and public concern.

Triggers for the Precautionary Principle

In order to carry out a suitable and sufficient assessment of environmental risk the end user requires access to ‘suitable and sufficient’ information. Both Nigel Homes (Queensland DEHP) and Jimmy Seow (Western Australia DER) highlighted the requirements for specific information and the current deficiencies in what was available. Unfortunately, with some notable exceptions, the information provided by foam manufacturers and suppliers in Section 12 of most product Safety Data Sheets is woefully inadequate, and the let-out clause ‘no data available’ is over used. In addition, warnings from feedstock manufacturers not to release material to the environment are ignored and not passed on to the end user. Lastly, there is lack of consistency in how BOD (biochemical oxygen demand) and COD (chemical oxygen demand) values as well as acute and chronic toxicities are reported in the SDS. It was stressed by the speakers that this lack of information represented a significant risk for the end user and therefore should be treated with suspicion.

It was also emphasised that the Queensland policy makes absolutely clear what is required as a minimum in terms of BOD or COD information and which species should be used for reporting acute aquatic toxicity. BOD (5-day) and BOD (28-day) values should be quoted for the foam concentrate supplied and not for individual components, the latter being largely irrelevant given the potential for synergistic effects.

BOD5 reflects the acute oxygen stress to which the receiving body of water will be subjected; BOD28 gives a measure of degradation over a four-week period. Claims that fluorinated foams are ‘readily biodegradable’ are highly misleading because they take no account of the chemical stability of the fluorochemicals present. Confusion and misunderstanding are partly due to measures of degradability that are based on the percentage of COD represented by BOD28. However, standard analytical procedures for determining COD using acid dichromate fail to detect highly stable fluorochemical components in the formulation, thus yielding an artificially high estimate for degradation based on BOD/COD ratio.

Acute aquatic toxicities should be determined using standard protocols and species, preferably the most sensitive. The point was clearly made that in general the acute oxygen stress far outweighs the significance of acute aquatic toxicity at usual dilutions and range of toxicities. Moreover, acute aquatic toxicities are determined using standard protocols at an oxygen saturation of 65%. In a real life-situation, oxygen saturation levels would be much lower than this, making these toxicity values meaningless.

Aquatic organisms are very sensitive to dissolved oxygen levels, as explained in detail in the Queensland DEHP Explanatory Notes to the Policy. Acute oxygen stress, as indicated by BOD5, is the primary kill mechanism associated with pollution.

Moreover, when short-term and long-term BOD values are compared using a large database of commercially available fire-fighting foams, there is almost nothing to choose between AFFF-type foams and non-persistent fluorine-free foams. If anything, fluorine-free foams have short-term BOD values – ie BOD5 or BOD10 values – slightly lower than those for AFFFs on average, as shown in the data below left (courtesy of Nigel Holmes, Queensland DEHP), indicating marginally less acute oxygen stress.

On the other hand, some AFFFs on the market have BOD5 values that far exceed those for the fluorine-free foams as well as, of course, fluorinated materials that degrade to highly persistent perfluorinated end-products, indicating that these particular foams might not be the best choice for an environmentally or hydrologically sensitive environment.

As explained by Nigel Holmes, a key part of the Queensland Policy includes measures to control the release of all fluorinated AFFF foam waste to the environment by containment and correct disposal as regulated industrial waste through a licensed contractor.

PFOS-containing foams have been banned in Queensland and must be removed from inventories and disposed of properly. These requirements for containment of waste also include the modern, so-called pure C6 foams, which may continue to be used so long as the content of PFOA or PFOA precursors does not exceed 50ppm. This level is achievable using the purest C6 fluorochemical feedstock available with a purity of 99.7%.

It was stressed during the presentations that the Queensland Policy is not a ban on the use of AFFF and especially modern purer C6 products, contrary to ill-informed claims by some in the industry, but rather a requirement to control runoff to the environment by containment.

At large petrochemical, chemical process plant and tank farm sites, containment should be part of an engineered solution, including bunding and isolated drainage systems for example, at the strategic planning and construction stage as part of reducing overall risk.

Discharge of fluorinated foams onto open ground should be avoided, especially near waterways or near to drinking water aquifers. In most cases, fluorine-free foams are perfectly adequate for such situations, for example, tanker spills on roads or wharfing and fuelling facilities. The presentation from Niall Ramsden, LASTFIRE coordinator, underlined the importance of considering environmental impact when doing a holistic risk assessment. He pointed out that in most incidents involving large tank fires, life safety was not an issue and that a ‘let it burn’ solution might be the best solution from an environmental perspective, if not from a political or fire service culture’s point of view.

Innovative solutions can play a role in reducing the risk of environmental pollution. Airports are high on the list of sites of significant PFC contamination, historically caused by training or maintenance procedures. Training areas should have an impermeable concrete apron with isolated drainage and collection of waste for subsequent disposal. Regular testing of airside crash tenders using foam, where necessary or required by local rules or international regulations, can be carried out using a containment facility such as that at Düsseldorf International Airport, resembling a farm silage pit.

Erika Houtz, Arcadis USA spoke at length about the use of the Total Oxidisable Precursor Analysis method for uncovering so-called ‘dark matter’. This term has been adopted to cover the recently identified extensive range of perfluorinated end-products of degradation arising from fire-fighting foam.

The method has the advantages that a knowledge of commercially sensitive formulations is not required. In addition, the analytical oxidative procedure produces end-point perfluorinated species that closely mimic environmental breakdown. The TOPA method is a key tool for a regulator analysing fluorinated waste streams such as firewater runoff or legacy concentrates, as well as for determining the purity of C6-compliant AFFFs. TOPA is also useful for end users in checking contamination levels in foam stocks or foam delivery equipment and assisting with compliance issues.

A number of analytical consultancies gave updates on the commercial development of the TOPA method for use by regulators and foam end users. These contributions included presentations from Bob Symons of Eurofins/MGT Laboratories and Marc Centner of Environmental ALS.

Over recent years, airports have featured as major sources of both legacy PFC contamination and ongoing incidents from accidental discharge of hangar foam fire suppression systems.  As recently as 10 April, some six weeks after the Queensland seminar, a hangar foam deluge system accidentally discharged 22,000 litres of foam, some of which ran into a local waterway, Myrtle Creek, and then the Brisbane River. A similar incident had occurred at Toronto Pearson Airport more than 15 years ago contaminating Etobicoke Creek and the Great Lakes.  An historical perspective of site contamination and legacy issues, especially serious for airports, was presented by Ian Ross of Arcadis.

Martin of Cornelsen Umwelttechnologie and Ravi Naidu of CRC Care both spoke about current technologies for remediating contaminated sites. Cornelsen described Perfluorad, a technology that is designed to greatly improve the absorptive capabilities and lifetime of granulated activated charcoal for the removal of fluorinated waste products from water.  This technology, which is available as a portable ro-ro container unit, is especially useful for remediating contaminated groundwater. It has been successfully applied in Germany’s PFC contamination of the Moehnetal and Ruhr Valley water-catchment area, and also in the case of legacy airport contamination with fire-fighting foam (Düsseldorf and Nürnberg airports) resulting from fire training and aircraft incidents.

Naidu described methods being developed by CRC Care for remediating both contaminated soil and water with a proprietary modified montmorillite clay/mineral mixture. Matcare was developed on behalf of the Australian Department of Defence for remediating AFFF-contaminated sites by absorbing PFCs as part of mobile treatment units. A test kit suitable for field use has also been developed, Astkcare, capable of detecting residual anionic surfactants such as fluorotelomer sulfonates from degraded AFFF in samples that can be used by unskilled operators.

Correct disposal of fluorinated waste, whether unused foam concentrate, firewater runoff or contaminated soil, as regulated industrial waste using a licensed waste disposal facility forms a key part of the Queensland Policy. Robert Schiller of Geocycle, Cement Australia presented what is arguably the best practice currently available for disposing of fluorinated waste technology that can then be used for both solid and liquid waste.

The method was originally developed for handling fluorine-containing waste from the aluminium smelting industry containing up to as much as 10% fluorine by weight.

The method involves feeding the fluorinated waste into rotary cement klinker kilns that operate at extremely high temperatures – between 1,000-1,500°C. This is sufficient to mineralise all organic fluorine compounds to calcium fluoride because calcium carbonate, ie limestone, is also present. The beauty of this method, apart from it being the cheapest available, is that it is environmentally completely neutral. The calcium fluoride produced is identical to the mineral source of the fluorine originally used to produce the fluorochemicals. It does not even need to be removed from the klinker before it is used in the manufacture of cement.

Moreover, it is significantly cheaper than previously available methods of high-temperature incineration. Traditional methods are extremely expensive and not capable of handling large quantities of waste. Using this method costs have come down from something around US$17-20 per litre/kg to less than US$1 per litre/kg. This makes the disposal of an IBC of foam concentrate (1,000l), for example, a much smaller element of the lifetime cost of fire-fighting foam – a matter of great interest to end users who need to find a practical and cost-effective way of dealing with fluorochemical waste.

Geocycle is currently working on increasing capacity of the klinker kiln technology to deal with around 100-tonne waste charges as well as obtaining regulatory approval for licensing this disposal method.

The other major topic discussed in detail by Nigel Holmes and his colleagues from the Queensland DEHP was the timescale for compliance with the new Policy.

During both the consultation process and after the Policy had come into force, industry had complained that the three-year transition period specified for coming into full compliance was too short for large installations such as refineries or tank farms. It was made clear by the Department, both during the seminar but also in the Explanatory Notes that accompanied the published Policy document, that reasoned arguments for an extended timescale would be considered on a case-by-case basis if presented with a strategic plan containing realistic timings. This plan would then be incorporated into the site license conditions and become legally enforceable.

Event moderator Anne-Maree McInerney, founder of Models of Success and Sustainability, and Dr Steven Miles, Minister for Environment and Heritage Protection of Queensland.

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