Industrial Fire Journal - Fire & Rescue - Hemming Group Ltd
Solutions in foam
Published:  05 December, 2017
Dr Niall Ramsden

‘An opportunity, not a crisis’ was the underlying theme for the Foam Summit that took place in Budapest, Hungary, IFJ reports.

A ‘cradle to grave’ approach to foam is imperative; the time for discussing the detailed environmental chemistry associated with AFFF is past; and the industry needs to move on towards solutions, heard delegates attending the Foam Summit.

All aspects of dealing with large-scale atmospheric tank fires including both operational issues as well as tank-bunding design, protecting the environment and complying with national and international regulations were covered in detail during the two-day conference.

Niall Ramsden of Lastfire, the international forum of oil storage and processing companies related to storage-tank fire-hazard management, opened the conference with a comprehensive overview of the history of firefighting foams. He pointed out that although all of these classical AFFFs and their variants had stood the test of time, they were now being challenged by developments resulting from an increased environmental awareness and sensitivity.

Although modern purer C6-compliant AFFFs as well as fluorine-free Class B foams had been appearing on the market for some time, he explained, it was not yet clear whether either of these recent developments were able to achieve the operational efficiency of the older C6/C8 AFFF formulations. Hands-on research into the performance and characteristics of such foam formulations, coupled with the development of guidance on foam usage for the future, was one of the areas that Lastfire had taken on recently, including the establishment of a preferred partners list for its members.

Modern C6 foams, with effective removal of C8 and higher components, represent re-formulations of original AFFFs, explained Ramsden. These reformulated foams sometimes did not change in product name, even if necessitating re-approval and testing to international standards. He sounded a note of caution in assuming that just because the product name remained unchanged that the efficiency would necessarily be the same.

When choosing to use C6-compliant AFFF or a fluorine-free foam, Ramsden stressed that there were effectively no true ‘drop-in ‘replacements available. Fire-fighting efficiency and ability to use current equipment such as inductors because of the differences between Newtonian and non-Newtonian concentrates, as well as the appropriateness of retaining current standard operating procedures unchanged, all have to be considered.

Even with foam concentrates, whether AFFF or fluorine-free, with all the appropriate international approvals and certifications – for example, UL 162, ICAO, EN1568, etc – it was still absolutely necessary to test any new foam concentrate operationally under the conditions that the end-user will be using together with the available equipment and personnel to establish whether the product is fit-for-purpose.

Niall Ramsden also outlined Lastfire’s ‘cradle to grave’ assurance process – available as published material from – which covers all aspects of foam management from procurement, through testing, operational efficiency, the fire engineering necessary for delivery and containment, environmental protection and correct waste disposal. These last two had become progressively more important because of heightened environmental sensitivity at regulatory level as well as public perception leading to political, legal, financial and reputational fallout, all aspects of the true lifetime costs of using firefighting foam.

The increasingly tough regulatory environments in Europe and further afield were summarised by Thomas Leonhardt, Eurofeu’s FFA chair and convenor of two ISO working groups. These included actions or positions taken on PFAS levels by the Nordic Council, in Australia and New Zealand, Alaska’s Department of Environmental Conservation, the OECD, and notably the US Naval Systems Command setting maximum levels of PFOA and PFOS in foam of 800ppb.

Leonhardt reminded delegates of the 10ppm limit placed on PFOS content as well as the more recent limitations placed on PFOA, its salts and precursors. Germany and Norway had originally been pressing for a PFOA limit of 2ppb, but this had been realised to be unrealistically low and unattainable by the fluorochemical industry. A higher level of 25ppb with 1,000ppb for mixtures was agreed together with numerous important derogations, especially for fire-fighting foams already on the market prior to 2020.

The German Federal Environment Agency is nevertheless pushing for much more severe limitations on the use of fluorochemicals as sources of environmental contamination with persistent PFCs, including a proposal under the Reach regulations for a complete ban on the manufacture, use and import of C9-C14 PFCAs and their precursors within the EU. This would not only impact on older AFFFs but would seriously affect the textile and leather treatment industry and the production of PPE. The German Ministry of Health is also working towards establishing threshold limits for all PFCs in drinking water and food including short chain materials such as C4, with levels for C7+ of the order of tenths of a microgram per litre or kilogram.

The very stringent controls on PFC contamination of the environment proposed by the German regulatory authorities includes regulation or banning of PFOS as well as PFOA and its precursors (all C8 compounds) as well as those with chain lengths greater than C8; regulating C6 materials, including precursors; regulating down to C4 PFCs; and the ultimate aim of a 100% PFC-free environment by 2025.

This last aim, although laudable, is almost certainly both impractical and unattainable, representing an extreme view of the issues surrounding the impact of perfluorochemicals. On human health and the environment, it may however help to drive the debate towards lowering the contamination levels to which the environment is exposed.

How regulators expect industry to follow new requirements was exemplified by Nigel Holmes of the Queensland Department of Environment and Heritage Protection, who explained how it had developed its Foam Management Policy, in force since 7 July 2016, and how this was being implemented.

Key elements in the Policy were that all foams where the PFOS level exceeded 10ppm should be taken out of service immediately; modern C6 AFFF foams could continue to be used if the total level of PFOA and PFOA-precursors, including all higher PFCA homologues, did not exceed 50ppm; and that any runoff containing fluorinated firefighting foam was fully contained and disposed of as regulated industrial waste.

Fluorinated AFFF should only continue to be used if there were compelling operational reasons, based on verifiable evidence not marketing hearsay, for their use rather than using fluorine-free alternatives.

As part of the Policy the allowable transition period for changing the type of foam being used could be extended, especially for large complex sites which might need substantial retro-engineering work or changes to discharge equipment to be carried out with major financial implications, but only with the agreement of the Queensland DEHP based on a concrete plan and timescale which would then become part of the site’s legally enforceable operating licence conditions.

Any changes to the nominal three-year transition period specified by the Policy ending 7 July 2019 would have to be agreed on an individual site-to-site basis.

A series of myths and ‘myth-information’ was also corrected by Holmes. These were:

• that foam spilt on waterways can be contained by oil-spill booms – it can’t because the majority of the foam will dissolve in the water column;

• marketing claims that some foams are 10 times more toxic than others – largely irrelevant as all foams are practically non-toxic to relatively harmless, with the acute oxygen stress BOD5 being far more significant, with all foams having extremely high BOD values, and with little difference on average between fluorinated and non-fluorinated foams;

• alternative short chain C6 and lower PFAS are harmless if released – significant evidence has emerged of potential health and environmental effects including enhanced mobility, uptake in crops, bioaccumulation, binding to proteins, increasing levels of exposure, very difficult to capture, as well as very difficult to clean up;

• air emissions from smoke are environmentally more harmful than the use and release of fire-fighting foam – although smoke columns may be spectacular and give rise to political problems and adverse reaction from the public, these disperse rapidly and are diluted out to below levels of concern compared to the permanent local and broader long-term pollution and environmental harm associated with using fluorinated foams, which far outweighs transient short-term plume effects;

• certain foams allow the mobilisation and dispersion of oil and other products from skimmers or separators – discharge of fluorinated foam to the aquatic environment is unacceptable, whilst on the other hand detergents are used intentionally to disperse and aid the degradation of oil spills on waterways and at sea.

Holmes also explained the legal obligations under the Precautionary Principle to which regulators and end-users are subject, especially in the context of end-user liability arising from the ‘polluter pays’ principle embedded in environmental law.

How the petrochemical industry was implementing the Queensland Government’s Foam Policy was outlined by Rod Rutledge of Caltex Australia, who also highlighted the extensive nature of the stakeholder consultation process.

Picture: Caltex Australia

In implementing the policy, Rutledge pointed out that during the transition period certain types of fire would still be fought using fluorinated AFFF type foams, such as deep-seated fires. However, where operationally possible fluorine-free foam would be used for less critical applications, with a need for further testing of the newer C6 AFFFs and fluorine-free products appearing on the market to ensure effectiveness and safety under operational conditions. Rutledge posed the question that if one decided to stay with modern AFFFs rather than using fluorine-free foams, would one find in a few years’ time that even the newer pure C6 products suffered from the same environmental and health problems as the older AFFFs and that this was not money well spent – what he labelled as a ‘regret spend’?

The complex procurement and assurance process involved in changing from fluorinated to fluorine-free firefighting foam for ARFF at one of the world’s major airports was presented by Graeme Day of Heathrow Airport.

This procurement process involved holding an e-auction, operational testing, awarding the contract, transitioning to the new foam and purchase of new appliances. All done in conjunction with a working group consisting of specialists for particular components of the project such as those with legal, environmental or technical expertise, guided by the regulator and the CAA. It also involved three areas of the business working together that had not previously done so in order to deliver an environmentally sustainable solution,

Some of the key issues regarding firefighter training and choice of foam for aviation rescue and firefighting were presented by Brian McKinney of Dallas Fort Worth Airport, US.

Dallas Fort Worth has excellent training facilities with fuel fire pits designed so that fuel and runoff do not lead to offsite contamination with foam, including an impressive A380 fire pit. As all airports in the US are required to use only Milspec foams listed by the FAA on a qualified product list, they are unable to move to fluorine-free foams, however good their performance.

Operational comparison testing was nevertheless undertaken by Dallas Fort Worth fire crews of AFFF versus a commercially available fluorine-free foam. The results demonstrated that it was important to carry out operational testing under real life conditions using standard equipment with appropriate operating procedures and normal fire crews rather than just relying on test-house approvals or batch certifications.

McKinney’s results for the fluorine-free foam were particularly notable in that the fluorine-free product extinction efficiency was virtually indistinguishable from that of the AFFF used.

Picture: Dallas Fort Worth Airport

Criticisms from some parts of the industry that fluorine-free products suffer from fuel pickup with foam flammability and poor burn-back resistance or drainage characteristics proved to be unfounded. As shown in a video, the fluorine-free foam blanket would not ignite when exposed to a propane torch; and disturbance of the foam blanket with either a water jet or having a hose dragged through it did not result in fuel re-ignition. In addition, breaking of the foam blanket resulted in rapid flowing back or re-sealing of the foam coverage in spite of the fluorine-free foam not being aqueous film-forming in the sense that AFFF is, suggesting that film formation was not a necessary prerequisite for effective fire extinction and knockdown. This was especially noticeable in the A380 test pit results in which knockdown using the fluorine-free product was rapid; and when excess fuel was burned off by injecting propane under the foam blanket, this promptly re-sealed after the source of ignition was removed.

The operational testing carried out demonstrated that the fluorine-free foam used would have been totally suitable for aviation firefighting had this been allowed under the terms of the FAA qualified product listing.

The challenges of compliance with increasingly stringent regulations in North Rhine-Westphalia, Germany, were outlined by Martin Neuhaus of BP Gelsenkirchen. He described some of the ongoing work at the BP refinery areas of GE-Horst and GE-Scholven that was necessary to achieve Werkfeuerwehr compliance with the new regulations. Having a Works Fire Brigade, or Werkfeuerwehr, using professional firefighters is a legal requirement under German law for industrial sites. Compliance included controlling the use of fluorinated foam operationally, prohibiting its use for training or system testing, and requiring containment and treatment of any firewater runoff.

The key questions for the industrial fire service attending a simple spill were; ‘Should we be using (fluorinated) foam at all for this incident? Are there alternatives? Is its use really necessary?’ The overarching operational considerations remain, however, safety first, and making the system straightforward to use and fool-proof at 3am on a cold morning. Significant problems remained over suitable containment and disposal technologies if fluorinated foam were to be used.

Ian Ross of Arcadis explained some of the complex chemical background to the emerging problem of PFAS contamination and evolving technologies for developing remediation strategies. Millions of people are now exposed to PFAS contamination of their groundwater resources used for drinking water and agriculture. This has resulted in elevated population blood levels for PFCs and a variety of class actions and litigation worldwide.

Ross highlighted two legacy case histories involving PFOS contamination to illustrate the substantial costs of actual or potential groundwater contamination and its impact on drinking water supplies. The case histories were analysed from the point of view of the fate and modelling of PFOS contamination in a fractured chalk aquifer, as in Buncefield, and the use of risk assessment and remediation technologies to protect a vulnerable drinking water supply from multiple sources of PFAS contamination, as in Guernsey Airport.

The currently available technologies for remediating soils and groundwater order in terms of their state of development and feasibility were also summarised by Ian Ross. An additional method currently under development by Geocycle, part of Cement Australia, was highlighted by a delegate at the end of Ross’ presentation. High temperature incineration at 1,000-1,500°C in cement clinker kilns is capable of dealing with 100-200-tonne charges of wet slurry containing fluorochemicals. This method is by far the cheapest available and is environmentally neutral, resulting in the fluorine content ending up as harmless calcium fluoride in the clinker, which is then used to make cement. It also results in minimal emissions of hydrogen fluoride HF in the flue gases, reducing the need for efficient scrubbing unlike other incineration methods.

An established method for remediation using Perfluorad technology for enhancing the efficiency of absorption using granulated activated charcoal (GAC) was described by Martin Cornelsen of Cornelsen Umwelttechnologie.

The Perfluorad technology, which can be containerised and hence easily mobile, is widely used especially in Germany for remediating contaminated groundwater at sites contaminated with PFCs. This includes for example airports such as Dusseldorf and Nuremberg as a result of foam use for training or operations or at agricultural sites such as Brilon-Scharfenberg at the head of the Ruhr Valley catchment area in the Hochsauerland district in the east of North Rhine-Westphalia, the result of contaminated top-dressing being applied.

Cornelsen made it clear, however, that although GAC treatment was reasonably effective for the longer chain PFCs such as PFOS or PFOA, it was very poor at removing short-chain material, ie less than C6 in chain length. This was especially relevant as recent research internationally had confirmed that PFC chain lengths C2-C6 were poorly absorbed by GAC and were not removed effectively by waste-water treatment plant. In addition, these shorter chain lengths were far more mobile in the aquatic environment, becoming concentrated preferentially in grasses and crops with the potential to contaminate the food chain.

The latest technology for the sealing of bund containment areas or previously contaminated ground was presented by Steve Flynn of Rawell Environmental. He explained how the use of pre-hydrated, polymer stabilised bentonite membranes – Rawmat technology – gets around many of the problems of using untreated bentonite, such as ion-exchange and on-site contamination during installation leading to sealant failure.

Picture: Rawell Environmental

These PHB membranes can be retrofitted to tank bunds or contaminated ground without necessarily having to remove contaminated soil; the contaminated soil can be backfilled onto the membrane and thus isolated. Flynn showed an impressive example of retrofitting sealant PHB membranes underneath tanks up to 80m in diameter; this was made possible by hydraulically lifting the tank using a ring of hydraulic rams to allow installation underneath the suspended tank.

Firefighting foam – a crisis or a crossroads?
The Lastfire Foam Summit was organised jointly by Lastfire coordinator Dr Niall Ramsden and Dr Ian Ross of Arcadis, with local support from Zoltan Mészáros of the Hungarian Fire Service FER and MOL, the Hungarian multinational oil and gas company.
Approximately 130 delegates attended the conference with representatives from a wide range of stakeholders including the petrochemical and fuel storage industries, the aviation ARFF sector, fire engineering companies and consultants, fire brigades as well as a range of foam manufacturers.
The conference was opened by Sándor Fasimon, chief operating officer of MOL on 17 October.