Is Your Facility Prepared to Use AFFF During an Emergency Response? 

By Reynolds B. Renshaw, Principal Consultant, EHS Support

Aqueous film-forming foam (AFFF) has been an effective flammable liquid firefighting tool for over half a century. Developed by the Navy to combat on-board ship fires involving fuel, AFFF became the standard emergency response tool at airports and industrial facilities worldwide. The effective chemical components of AFFF, however, are per- and polyfluoroalkyl substances (PFAS). These emerging contaminants have been found to be toxic at extremely low concentrations, causing birth defects, cancer, and other chronic illnesses. This paper uses lessons learned on two recent catastrophic facility fires involving AFFF to provide the reader with actions before, during, and after and emergency response. While the two fire incidents described were quite different, both required the use of AFFF to control the blaze, prevent further spread, and shield exposed petroleum from the fire.

The first fire was a large blaze near a densely populated area. The facility had nearly 3 million gallons of petroleum materials on the premises when the fire began shortly after sunrise. The facility, 300,000+ square feet, burned for nine days before flames were extinguished. Firefighters used 110 gallons of modern, short-chain AFFF materials to control the blaze during the initial days of the event. This fire produced significant smoke that required evacuation of nearby residents. The AFFF was used to extinguish a portion of the fire near high-volume oil tanks.

The second incident was a smaller blaze in a low-population area. The facility had 300,000 gallons of petroleum materials on-site when the fire erupted after the sun had set. The facility had multiple small buildings, totaling less than 50,000 square feet, but included a 60,000-square-foot containment area. Firefighters used approximately 700 gallons of modern, short-chain AFFF to combat the 16-hour blaze. AFFF was used to cover the large containment area, which held significant amounts of petroleum products.

Pre-Planning, Training, and Management Structure

Borrowing a motto from the Boy Scouts, today’s environmental, health, safety, and security (EHS&S) managers should “Be Prepared.” Any facility that houses bulk petroleum or chemicals has the potential for fire emergencies requiring AFFF materials. AFFF comes with its own environmental and health and safety risks. We recommend preparing for that potential AFFF response use now by considering the following key concepts.

War Gaming

Game-plan the most likely scenarios where AFFF will be used and the likely response. Because AFFF is used mostly for petroleum and chemical fires, understand the areas where those materials are used and stored in your facility, and then answer these questions:

  • Does the area of your facility have secondary containment that can handle a large fire response?
  • Where would the fire suppression and/or AFFF materials run off?
  • Where are the likely outfalls, storm sewers, and other runoff conveyances that could impact the surrounding environment? Are there sanitary sewer drains that need to be protected?
  • Are there sensitive receptors (e.g., rivers, lakes, or reservoirs) nearby that need to be protected?
  • If material is released into the environment, what notifications are necessary?

Review facility plans that should identify these critical areas, including the Stormwater Pollution Prevention Plan (SWP3) and Spill Prevention, Control and Countermeasures (SPCC) Plan. These documents should have figures and maps that indicate sewerage, culverts, and other conveyance locations.

Determine what countermeasures are needed to prevent AFFF from leaving the immediate area, such as plugging culverts, constructing containment berms, and shutting down pumping operations.

Inventory the equipment and materials on-site (or readily accessible) that could be used to counter spread of AFFF materials. Do you have backhoes/excavators and soil on-site to construct berms? How will you plug culverts and conveyances?

Once you have answered these questions and determined an AFFF runoff countermeasure plan, record the information in your Emergency Response Plan and communicate to on-site personnel. Additionally, meet and drill with local responders (see additional details in the following section).

Waste Management Planning and Disposal

Updating your facility’s Waste Management Plan to include AFFF/PFAS sampling information will save time and reduce confusion during the early fire aftermath. The following steps will be useful to your operations personnel:

  • Pre-identify disposal facilities. Work with your waste brokers/disposal partners to identify disposal options for AFFF liquids and AFFF-affected solid wastes (firehoses, soil, rubble). Contact these facilities to understand the PFAS analytical methods required for waste profiling, including analytes and detection levels. Also understand the restrictions these facilities have, including solid wastes limitations and physical properties (e.g., total suspended solids, pH, free liquids, or size restrictions) of the wastes.
  • Update your Waste Management Plan to include the PFAS sampling information and recommended sampling methods and strategies. Remember that other facility compounds/chemicals may be in the sample matrix.
  • Understand the decontamination procedures and sampling requirements for recycled wastes and reusable equipment. Allowing contaminated materials back into the general public could lead to unnecessary exposures.

Meet with Local Responders

A meaty, meaningful meeting with local responders is highly recommended. Many facilities have become complacent with annual notifications to the local fire department. The realization that AFFF can exponentially increase the overall cost of a fire will jolt facility managers to vigorously re-examine their communications with the local responders. A few topics to discuss with local responders:

  • Do you have AFFF material available for a petroleum/chemical fire? If so, what is the product name, manufacturer, and Safety Data Sheet? If their material is older and contains 8-chain carbon PFAS, consider purchasing your own modern 6-chain AFFF or PFAS-free AFFF materials.
  • What training and experience do the local fire departments have with AFFF? How would they attack a petroleum/chemical fire at your facility?
  • Communicate the facility’s AFFF runoff countermeasures plans, including isolating the AFFF fire water from other fire water as much as practicable, isolating the areas where AFFF would likely be needed, and preventing runoff from the immediate area.
  • Consider having the local responders participate in a response drill on a regular basis. There is no substitute in an emergency response for familiarity and experience at your facility.

Emergency Response Planning and Training

Calm command and control during the event will result in less wasted effort during the fire aftermath. Understanding the goals of AFFF usage response and planning for the event is key. The Emergency Response Plan should include a designated role responsible for AFFF management. All response personnel should be trained to understand the three key steps:

  • Stop the spread.
  • Segregate AFFF-impacted materials from other fire response-related wastes.
  • Store the AFFF-impacted materials quickly in appropriate containers.

Risk Management Tools

Risk management personnel should have a keen understanding of the potential issues posed by AFFF foams. Organizations should meet with their insurance broker and discuss the following:

  • Some insurance policies state the insurer must be notified immediately; others say as soon as practicable. What do those terms mean exactly? Is immediately now? Within 24 hours? As soon as practicable when the fire is out, or after your vacation? Understand the exact steps and content of insurance claim so coverage is not jeopardized.
  • Which policy responds? Many facilities have a pollution legal liability coverage in addition to the property coverage. Which policy will respond to the AFFF waste costs? This is important, as the limits and deductibles can be different on these coverages. Most Pollution Legal Liability (PLL) policies have a PFAS exclusion, but does that include the use of AFFF to extinguish a facility fire? Are there other restrictions on the policies? The broker should re-examine the policy package to ensure no gaps exist between coverages.
  • Insurer recommendations. Insurance companies often have requirements and recommendations for facility preparedness and response. Speak with your broker to ensure your facility is up to date with these.

What to Do During the Event

If AFFF is to be used on a facility fire, these actions may reduce future liability and costs:

  • If time and circumstances allow, discuss the decision to use AFFF with first responders and regulators on-site.
  • Stop the Spread. Take actions to prevent AFFF firefighting material from leaving the immediate area of the fire response. Plug stormwater sewers/conveyances. Build berms in likely runoff areas. Turn off any on-site pumping wells. Remove spent AFFF material as soon as possible via vacuum truck or pumps.
  • Separate, Isolate, and Containerize the AFFF. Segregating spent AFFF firefighting materials from other wastes will reduce disposal costs. Utilize on-site tanks/containments to hold the AFFF‑impacted materials to prevent cross-contamination with other fire response materials. Temporary bladder tanks and secured (read: plugged) truck bays also make good temporary AFFF storage areas until proper frac tanks are delivered to the site. Clear labeling of AFFF containments helps reduce confusion.
  • Who, What, Where, and How Much. Recording the AFFF usage will be useful later in the cleanup and investigation process. Filming the AFFF spray locations will help with post‑fire assessments. Records of the exact material and how much was used are also excellent data for the post-fire investigations and reporting.
  • If containment options are breached and AFFF‑impacted materials are released into sensitive areas and/or municipal sanitary sewer system, make the appropriate notifications in a timely manner.

Post-Fire Actions

AFFF Waste Transportation and Disposal

Management of AFFF‑impacted wastes is difficult in the current uncertain regulatory environment. The United States Environmental Protection Agency (USEPA) and States are in the throes of writing and promulgating regulations for PFAS compounds. Disposal facilities are rightfully cautious of which compounds to accept. Until the PFAS regulations mature, there will be an element of uncertainty for all stakeholders. As discussed earlier regarding the pre‑planning phase, familiarity with potential disposal options ahead of any need will certainly expediate the ability to have materials transported off-site in a timely manner.

  • Designate a person or group for all AFFF waste decisions. There will be many contractors and consultants trying to assist, which may lead to confusion and overlapping offers. Establishing a single point‑of‑contact for waste disposal decisions will reduce the confusion, especially during the early stage of the post-fire event.
  • Waste profiling AFFF wastes can be exhaustive and expensive. Understand the compounds likely to be in the waste materials, not just the AFFF but also the on-site materials that would have been released during the fire. Ensure the waste sampling procedures, analytical methods, and analyte lists are coordinated and match potential disposal facility requirements.
  • AFFF waste disposal operations may require additional steps than other wastes. For example, AFFF wastes may re-foam with agitation during transport. Waste facilities charge hefty fees when trucks arrive with foam leaking out the hatches and vents. Test your liquid wastes prior to shipment, and consider using a sequestering agent to prevent re-foaming of the waste.

AFFF is an effective firefighting tool that can help save lives and property and shorten emergencies. But the PFAS components within the AFFF have costly downsides with potential long-term liability. Preparing for AFFF use now will limit the negative impact to human health and the environment and conserve your resources.

If you have questions or would like to discuss the contents of this article, please contact Reynolds Renshaw at Reynolds.Renshaw@ehs-support.com, Joe Biss at Joe.Biss@ehs-support.com, or Jerry Hincka at Jerry.Hincka@ehs-support.com.

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