Firefighting Foam: What on Earth is going on? · considering that fluorine-based fire-fighting...
Transcript of Firefighting Foam: What on Earth is going on? · considering that fluorine-based fire-fighting...
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
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The firefighting foam industry from 40,000 feet
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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
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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.
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Some site specific needs – nothing here is new
Hazard management
Geography & hydrology
Reputation
Fire performance
DestructionApplication techniques
Training & SOP
Legislation
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“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?
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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.
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Australia regulations (QLD, SA, NEMP) – covers use
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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
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US Federal – the wider political backdrop
Congresswoman, for PFOA and PFOS our answer is yes.
“
Source: DuPont (2019)
Source: EWG (2018)
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▪ 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
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Global public opinion (largely factory emissions)
Extraordinary true story of a kind of cover-up in corporate America, that I didn’t know.
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Source: Graham Norton (2020)
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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.
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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.
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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)
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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.
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Source: The Firefighting Foam Coalition (2016)
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The future isn’t what it used to be …
Source: backgroundpictures.org
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High performing F3is available
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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.
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Does it work?
Can I use it?
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“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.
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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)
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“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
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“Does it work?” – Respondol ATF
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)
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“Does it work?” – Respondol ATF
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
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“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
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“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)
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Existing engineered systems – opening Pandora’s Box
Any source of great and unexpected troubles.
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Source: Wikipedia (2020)
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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.
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Thank you, are there any questions?
© Angus Fire
Global Product Manager – Firefighting Chemicals
Presenter: David Plant