for testing or training purposes. (In other words,
they could only be used to extinguish emergency
fires.) The final regulation should be published this
year, which means that the restrictions on PFOS
foams would begin in 2013 or 2014.
Fluorine-free foams
As a result of the concerns raised by the PFOS
issue, foam manufacturers continue to evaluate
many types of potential products that do not con-
tain fluorosurfactants, but efforts to date have not
yielded working products with fire performance
across all fuels and in all operational circumstances
equal to film-forming foams. Some fluorine-free
foams can provide an alternative to AFFF in some
applications, but they are not currently able to
provide the same level of fire suppression capability,
flexibility, scope of usage, and independent
validation. A recent paper from the University of
Newcastle that shows that even the best available
fluorine-free foam would need to be replenished
three times as often as AFFF to provide the same
level of fire protection6.
Fluorine-free foams are often championed as
"environmentally-friendly" alternatives to AFFF.
Although such foams may not contain fluorine,
their environmental profile related to biodegrada-
tion, acute toxicity, chemical oxygen demand
(COD), and biochemical oxygen demand (BOD) is
typically no better than fluorine-containing prod-
ucts and in many cases is not as environmentally
responsible in use as AFFF. A recent study of
commercially available fire fighting foam agents
indicates that fluorine-free foams are at least an
order of magnitude higher in aquatic toxicity than
AFFF agents7.
FFFC assists in wastewater treatment
Another issue that has been brought to the
forefront in recent years is the containment and
treatment of wastewater from foam discharges.
FFFC and its member companies have been actively
involved in this issue, and recently provided
assistance to an oil refinery in Missouri that was
looking for help in dealing with a wastewater dis-
posal issue. The company had a fire at a bulk plant
that resulted in 1.1 million gallons of wastewater
containing gasoline, diesel fuel, and fire fighting
foam agents used to extinguish the fire.
FFFC put the company in touch with one its
members, Martial Pabon of DuPont, who had
done research on the use of activated carbon to
treat water that contained fluorosurfactants similar
to those used in AFFF. Based in part on the
information provided by Dr. Pabon, the company
successfully treated 1.1 million gallons of waste-
water in 15 days using granular activated carbon
(GAC) in a trailer-mounted system with two
pressure vessels each containing 5,000 pounds
of GAC8. Dr. Pabon has done additional
research on other methods to treat wastewater,
including nanofiltration, ultrafilitration, and reverse
osmosis9.
Conclusions
Fluorotelomer-based AFFF agents are the most
effective agents currently available to fight
flammable liquid fires in military, industrial, and
municipal settings. They do not
contain or breakdown into PFOS and are not
likely to be significant sources of PFCAs. They do
contain fluorosurfactants that are persistent, but
are not generally considered to be significant
environmental toxins. AFFF and fluorosurfactant
manufacturers are in position to meet the goals of
the EPA global stewardship program years ahead
of the target date with a new family of fluoro-
surfactants that provide the same fire protection
characteristics with reduced environmental
impacts.
References
1. Environmental Impacts of Fire Fighting Foams by
William H. Rupert, Daniel P. Verdonik, and Christopher
Hanauska of Hughes Associates, Inc. (2005)
2. Fluorinated Alkyl Surfactants in Groundwater at
Military Bases Contaminated by Aqueous Film-Forming
Foams (AFFF) by Dr. Jennifer Field, Oregon State
University (2003)
3. Presentation by AGC Chemicals, Asahi Glass Co. at
the US EPA PFOA Information Forum on June 8, 2006
4. Presentation by Stephen Korzeniowski of DuPont on
fluorotelomer products in the environment at the
Reebok fire fighting foam conference on September 2,
2007
5. Estimated Quantities of Aqueous Film-Forming Foam
(AFFF) in the United States, Robert Darwin, P.E., Hughes
Associates (2004)
6. Sealability Properties of Fluorine-Free Fire Fighting
Foams by Ted Schaefer, Bogdan Dlugogorski, and Eric
Kennedy, University of Newcastle (2007)
7. 96-hour LC50 Value in Fathead Minnows (flow-
through test), Report of tests on six fire fighting foam
agents performed by Aqua Survey Inc., Flemington,
New Jersey, USA and 96-hour LC50 Test in Fingerling
Rainbow Trout, Report of tests on six fire fighting
foams agents performed by Harris Industrial Testing
Service Ltd., Nova Scotia, Canada
8. Executive summary of a June 2005 report on the
emergency response water treatment operations at the
MFA bulk plant in Marshall, Missouri
9. Presentation by Martial Pabon of DuPont on new
developments in water treatment at the Reebok fire
fighting foam conference on September 2, 2007
IFP
34 INTERNATIONAL FIRE PROTECTION
AFFF INDUSTRY IN POSITION TO EXCEED ENVIRONMENTAL GOALS
FIRE FIGHTING FOAM COALITION

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