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28 4.1 Overview AFFF is used in airport operations as a fire-extinguishing agent to prevent, extinguish, or control Class B fires, i.e., fires of flammable and combustible liquids such as crude oil, gasoline, and fuel oils. AFFF generates foam that retains water, separates fuel from flame, and ultimately results in dramatic, fast knockdown of Class B fires. Fluorocarbon surfactants and specifically PFASsâa large group of related human-made fluorinated organic chemicalsâare key ingredients in AFFF. As indicated previously, some PFASs used in AFFF have been shown to exhibit multiple problematic chemical, physical, and toxicological properties. The problematic properties have largely been attributed to âlong-chainâ PFASs, i.e., PFCAs with eight or more carbons (including PFOA) and PFSAs with six or more carbons (including PFOS). In the past, AFFF formulations were made with PFOS as the predominant active ingredient. Early alternatives to PFOS-based AFFF contained long-chain, telomer-based fluorochemicals that in some cases could breakdown to PFOA. Like PFOS, PFOA has been observed to be persistent in the environment. Consequently, AFFF manufacturers have shifted toward using short-chain (i.e., â¤ C6, having six or fewer carbon molecules) C6 and C4 perfluoroalkylated chemicals (7). Currently, the most common and widely used short-chain PFASs in AFFF are the C6-based fluorotelomers. While current AFFF formulations are believed to be potentially less problematic to human health and the environment than PFOS-based formulations, much remains unknown about the short-chain PFASs used in AFFF. Short-chain PFASs can be as environmentally persistent as long-chain substances or have persistent degradation products. A switch to short-chain and other fluorinated alternatives may not reduce the quantity of PFASs in the environment (70). In addition, because some of the short-chain PFASs are less effective than their long-chain counterparts, greater quantities of short-chain PFASs may be required to provide the same performance. Potential risks to human health and the environment may result from contact with or release into the environment of current AFFF formulations. Consequently, it is important for users of AFFF, such as airports, to develop best practices for managing the use of AFFF that mitigate potential impacts to human health and the environment. This chapter discusses management practices of AFFF at airports in North America related to procurement, storage, application (i.e., maintenance, use/testing, and training), and disposal (i.e., discharge to environment, containment, and treatment/off-site disposal). (See Figure 4-1.) Specifically, this chapter describes the following: â¢ Legislation, regulations, and/or guidance relevant to AFFF. Guidance from firefighting foam manufacturers is also identified. C h a p t e r 4 AFFF Management Within Airport Operations
aFFF Management Within airport Operations 29 â¢ The state of the practice of AFFF procurement, storage, application, and disposal at airports in North America based, in part, on a survey completed by 167 airports across the United States and Canada. Further detail on the survey is provided in Appendix A. â¢ Best management practices for North American airports related to procurement, storage, application, and disposal of firefighting foams. 4.2 Procurement Airports procure AFFF in the form of a liquid concentrate that, when mixed with water in the correct proportions and with the correct equipment, produces a foam solution. AFFF is procured for use in firefighting and fire suppression at civilian airports in the United States and Canada, pursuant to the requirements detailed in Section 4.2.1. The selection of firefighting foam is based on numerous factors, including compliance with governmental quality or performance specifications, cost, availability, compatibility with existing stock and systems, and environmental considerations. The following sections identify quality and performance-based procurement criteria for evaluating firefighting foams used in airport operations, describe AFFF alternatives acceptable for use in the United States and Canada, and identify best practices for AFFF procurement. 4.2.1 Procurement Criteria Quality and performance-based criteria for AFFF are established, in part, through standards established in the United States and Canada by federal agencies responsible for civil aviation (i.e., the FAA and Transport Canada, respectively). Additional considerations affecting the procurement of AFFF at airports are associated with performance, compatibility with existing firefighting equipment and systems, availability, and cost. In North America, FAA and Transport Canada regulations reference the following standards related to aircraft rescue and firefighting at airports: â¢ United States Military Specification (MIL-SPEC)âMIL-F-24385 (Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater). MIL-F-24385 is specific to AFFF and includes performance tests on the foam concentrate itself. It is a performance specification as well as a procurement specification for the U.S. military and federal government. â¢ Underwriters Laboratories Inc. (UL)âFoam Equipment and Liquid Concentrates (UL 162). UL 162 tests foam concentrates and equipment, evaluating specific foam concentrate/ proportioner/discharge device combinations. â¢ Standards Council of CanadaâCAN/ULC-S560-06 (Standard for Category 3 AFFF Liquid Concentrates). Figure 4-1. AFFF life cycle stages.
30 Use and potential Impacts of aFFF Containing pFaSs at airports In addition, the FAA cites standards by the National Fire Protection Association (NFPA). These standards provide guidance on ARFF services at airports. Standards referenced include the following: â¢ NFPA 11: Standard for Low-, Medium-, and High-Expansion Foam. â¢ NFPA 18: Standard on Wetting Agents. â¢ NFPA 403: Standard for Aircraft Rescue and Fire-Fighting Services at Airports. â¢ NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Fire Equipment. â¢ NFPA 1003: Standards for Professional Qualifications for Airport Fire Fighters. NFPA 403 defines the minimum requirements for ARFF services at airports. It should be noted, however, that the Code of Federal Regulations (CFR), Title 14 â Aeronautics and Space, Part 139, Certification of Airports takes precedence over the NFPA 403 standard, which in some areas exceeds FAA requirements. Unlike the United States, Canada does not have a fire protection association that specifically provides standards for firefighting foam, aircraft rescue, and firefighting at airports. Rather, Transport Canada references NFPA 412: Standard for Evaluating Aircraft Rescue and Fire- Fighting Foam Fire Equipment as a standard to be followed by Canadian airports for rescue vehicles. 4.2.2 Environmental Considerations As outlined in Chapter 2 of this report, releases of firefighting foam to the environment pose potential impacts to environmental media, wildlife, and human populations. Different fire- fighting foams have different chemical compositions, with varying properties (1, 71). A product manufacturerâs safety data sheet (SDS) may contain sections that provide toxicological, human health, and ecological information. If this information is not presented in the SDS, it can be requested from a product manufacturer. The indicator values presented on a SDS can be com- pared to identify better alternatives or options for an airport facility. For example, within the same species (e.g., rabbit), a higher LD50 or LC50 would be preferredâthis value indicates that a greater quantity or concentration of AFFF would be required to harm 50 percent of the rabbit test sample population. Some indicator values (LD50, LC50, and EC50) cannot be compared between species (e.g., rabbit versus guinea pig). Indicators typically found on SDSs are presented in Table 4-1. 4.2.3 Alternatives AFFF is the most widely used firefighting foam due to its film-forming and fast knock down properties. PFOS (part of the larger group of PFASs) was a key ingredient in AFFF until con- cerns were identified regarding its environmental persistence, bioaccumulative properties, and toxicity. In 2002, 3M voluntarily stopped production of AFFF that contained and/or degraded into PFOS. Subsequently, regulations in numerous jurisdictions, including North America, were developed to ban all production of PFOS-based products. In 2002, the U.S. EPA published a SNUR under the TSCA restricting the reintroduction into the market of the PFOS chemicals included by 3M in the voluntary phase-out. A 2007 SNUR broadened the scope to 183 chemicals within the class of PFASs. In Canada, as of June 2013, production, supply, and use of AFFF containing PFOS are banned, with some exemptions for military applications. As discussed, early alternatives to using PFOS-based AFFF were long-chain fluorotelomers, which in some cases can break down to PFOA. Later, it was found that, like PFOS, PFOA is very persistent in the environment. In response, a voluntary global directive by the U.S. EPAâ referred to as the U.S. EPA 2010/2015 PFOA Stewardship Programâwas introduced calling for a 95-percent reduction of plant emissions and product content of PFOA, PFOA precursors, and
aFFF Management Within airport Operations 31 related homologue materials by 2010, and a 100-percent reduction (i.e., elimination) by 2015. In 2010, Environment Canada also published the decision to regulate PFOA (C8), its salts, and its precursors. These chemicals are now listed in the List of Toxic Substances Managed Under CEPA (Schedule 1). As of the publication of this report, amendments to include PFOA have been proposed for Environment Canadaâs Prohibition of Certain Toxic Substances Regulations, 2012. The implementation of regulations banning the production of PFOS and the voluntary stewardship program have brought about substantial research and development into alternative firefighting foams that do not breakdown into PFOS, PFOA, or other types of PFASs. Alternatives are described in two categories, fluorinated foams and fluorine-free foams. While fluorine-free foams are described as alternatives and are being used in some applications in Europe and Australia, there are currently no fluorine-free foams that meet specifications for use in emergency response at North American airports. All AFFFs contain fluorocarbon surfactants. The most widely used alternative for North American airports continues to be AFFF that con- tains fluorocarbon surfactants that are manufactured using telomerization and are referred to as short-chain fluorotelomers. While persistent in the environment, PFCA chemicals with fewer than eight carbons and PFSA compounds with fewer than six carbons are generally believed to be less toxic and less bioaccumulative in wildlife and humans, although limited toxicological data are available. AFFF containing these short-chain PFASs can still degrade to other PFASs in the environment. The use of these compounds has persisted as testing has shown that, for a given application rate, no alternative foam agent can equal the performance of AFFF for airport applications (72). Appendix B describes AFFF alternatives in further detail, identifies their advantages and dis- advantages, and lists properties of available products in the marketplace. The following sections identify the currently acceptable AFFF alternatives available in the United States and Canada. 188.8.131.52 Acceptable Alternatives Available in the United States In the United States, the FAA issues operating certificates to airports that comply with certain operational and safety standards. The regulatory requirements related to firefighting at LD50 Lethal dose at 50 percent (LD50) is the amount of an ingested substance that kills 50 percent of a test sample (short-term exposure). Same species (e.g., species are both rabbit), higher values. LC50 Lethal concentration at 50 percent (LC50) is the lethal concentration required to kill 50 percent of the population (longer-term exposure). Same species, higher values. EC50 Half maximal eï¬ective concentration (EC50) is the concentration of a substance that gives half-maximal response. Used as a measure of the substanceâs potency. Same species, higher values. BOD Biochemical oxygen demand (BOD) is the amount of dissolved oxygen needed by aerobic biological organisms to break down organic material present in a given water sample at a certain temperature over a speciï¬c time period. Lower values. COD Chemical oxygen demand (COD) is the amount of dissolved oxygen needed by chemicals to break down organic material present in a given water sample at a certain temperature over a speciï¬c time period. Lower values. Indicator Description Look for Table 4-1. Environmental indicators on AFFF product SDSs.
32 Use and potential Impacts of aFFF Containing pFaSs at airports airports, as overseen by the FAA, are found in CFR, Title 14âAeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139) and, specifically, 14 CFR Part 139, 139.317 Aircraft rescue and firefighting: Equipment and agents. The FAA also issues guidance documents and resources such as Advisory Circulars and CertAlerts to provide further guidance for airports on how to comply with 14 CFR Part 139. Up-to-date information can be found on the FAA website under Airports. The most recent Advisory Circular on Aircraft Fire Extinguishing Agents, AC 150/5210-6D, states that foam concentrates must meet the performance test requirements of the MIL-SPEC, MIL-F-24385, to comply with 14 CFR Part 139. Further guidance by the FAA on the procure- ment of AFFF notes that â¢ Any foam purchased since July 2006 must be on the United States Department of Defense Qualified Products Database (QPD) list indicating that the foam meets the MIL-SPEC requirements. The QPD serves as the official repository for qualification information regard- ing producers and manufacturers and is accessible to the public at http://qpldocs.dla.mil/. â¢ AFFF in concentrations lower than 3 percent is not acceptable for the use at airports. AFFF is available in 1-, 3-, or 6-percent concentrates. The percentages refer to the percentage of concentrate mixed with fresh water or seawater by a proportioning nozzle to create a foam solution. The 1-percent concentrate should not be used in ARFF applications because of the difficulty in consistently providing an accurate mixture. Firefighting performance is an important, if not the primary, procurement consideration for AFFF. In addition to understanding the standards used to evaluate and certify firefighting foams, the FAA suggests that airport managers request proof of tests on performance and quality by a recognized testing laboratory (e.g., UL) from prospective firefighting foam concentrate suppliers. System and equipment compatibility is also an important consideration in the procurement of firefighting foams. Guidance by the NFPA on firefighting foams suggests that â¢ The type of foam concentrate used should be a type that has been indicated as suitable for the system and equipment that will be used. â¢ Converting to use of a different type of foam concentrate requires consultation with the equipment manufacturer. â¢ Flushing of the system is required prior to using a new foam concentrate. â¢ Recalibration and resetting proportioning equipment may also be required. Regulations in the United States do not currently prohibit the purchase of AFFF contain- ing long-chain fluorocarbon surfactants (i.e., C8 or longer); however, there are regulations that prohibit the manufacture and import of this material. Existing stock of foams containing PFASs that may break down into PFOS or PFOA still exists and may still be used in the United States. A productâs adherence to the U.S. EPA 2010/2015 PFOA Stewardship Program can often be found in the manufacturerâs product information sheet, indicating that the foam concentrate formulation contains C6 or short-chain fluorochemicals rather than the long-chain fluorochemicals. 184.108.40.206 Acceptable Alternatives Available in the Canada In Canada, Transport Canada administers the CARs, which require airports to have a safety management system in place and comply with airport safety standards and security requirements, including firefighting capabilities. Per Transport Canadaâs CAR Standard 323âAircraft Fire Fighting at Airports and Aerodromes, operators of âdesignated airports,â where the total of the number of passengers that are enplaned and the number of passengers that are deplaned is more than 180,000 per year, are to provide aircraft firefighting service with both the principal and the complementary extinguishing agents.
aFFF Management Within airport Operations 33 The regulatory requirements related to firefighting at airports are guided by CARS Part IIIâ Aerodromes, Airports and Heliports, Standard 323âAircraft Fire Fighting at Airports and Aerodromes. Information specific to firefighting foams is provided in Standard 323, Section 323.08âExtinguishing Agents and Equipment. Section 323.08 requires the follow- ing of foams provided as principal extinguishing agents: âAFFF shall meet the latest relevant performance specifications of CAN/ULC-S560.â As it relates to system and equipment compatibility, Transport Canada requires that the principal extinguishing agents for aircraft firefighting service be foams suitable for the type of equipment used. Civilian airports in Canada can no longer purchase PFOS-based AFFF in accordance with the Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations (2008), which prohibit the manufacture, use, sale, offer for sale, and import of PFOS and products containing PFOS. Environment Canada has proposed amendments to existing regulations that would prohibit PFOA and products containing PFOA (e.g., possibly including AFFF formulations containing PFOA and/or its precursors). 4.2.4 State of the Practice In the survey of North American airports, about two-thirds of the respondents (65.7 percent) indicated that the most important procurement criterion for the acquisition of AFFF was com- plying with government regulations. In the United States, most respondents specifically high- lighted the need for the AFFF purchased to be in compliance with the MIL-SPEC and meet FAA requirements. Canadian respondents identified Transport Canada guidelines as the defining regulations. Other important criteria mentioned included cost or price, the use of an external pur- chasing agency or organization, the availability of sufficient quantities, and the use of a required list of vendors. For many airports, cost influences procurement decisions. Once foam compatibility and compliance with regulations is known, many airports seek bids from a variety of suppliers. For a handful of respondents, procurement is based on municipal procurement policies and may involve selecting suppliers from a pre-approved vendor list, obtaining a minimum number of bids from suppliers, and/or working with a supplier under contract. Some Canadian airports specifically made mention of a joint procurement process for major airports and bulk buying AFFF from suppliers. Procurement decisions were also said to be made based on the required quantities and the amount a supplier could sell. In both the United States and Canada, certain quantities of firefighting foam must be held at an airport by law, driving the procurement of new foams when existing stocks are consumed or disposed. When asked about alternative formulations of AFFF, roughly a quarter of respondents indi- cated that they were aware of alternative formulations, but most respondents who were aware of alternatives were unable to name specific formulations or products. As noted, some respondents indicated that procurement and the consideration of alternatives was the responsibility of others. In general, however, the survey indicated that AFFF alternatives were rarely used, principally because alternatives were not compliant with government regulations. 4.2.5 Best Management Practices Table 4-2 identifies the best management practices associated with procurement of AFFF. Consideration of these practices will allow an airport to make an informed decision on what type of AFFF will meet its current and future needs.
34 Use and potential Impacts of aFFF Containing pFaSs at airports Legislation and Regulations Comply with legislation, regulation, and/or guidance in the United States â¢ To meet the requirements of the Code of Federal Regulations (CFR), Title 14 â Aeronautics and Space, Part 139, Certiï¬cation of Airports (14 CFR Part 139), 139.317 Aircraft rescue and ï¬reï¬ghting: Equipment and agents. To follow FAA Guidance Documents (Advisory Circulars and Cert Alerts). To align with the targets of the U.S. EPA 2010/2015 PFOA Stewardship Program. Comply with legislation and regulations in Canada â¢ To meet the requirements of the CARs, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes, which identiï¬es the requirements to comply with Part III Aerodromes, Airports and Heliports. Section 323.08 of the Standard, Extinguishing Agents and Equipment. â¢ Comply with Perï¬uorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations (2008), which prohibits the manufacture, use, sale, oï¬er for sale, and import of PFOS and products containing PFOS. AFFF Performance Meet ï¬reï¬ghting foam performance standards in the United States Use foam that is a 3-percent or 6-percent concentrate. â¢ FAA requires that AFFF meets the requirements of the MIL-SPEC, MIL-F-24385. Qualiï¬ed AFFF products are listed on the QPD, found at http://qpldocs.dla.mil/. â¢ As suggested by the FAA, foam concentrate must be either a 3-percent or 6-percent concentrate. Foam concentrate at 1 percent should not be used because of the diï¬culty in consistently providing an accurate mixture without the use of a computer-controlled system. In addition, there is no room for error when using a foam concentrate at a low percentage; if a discharge is on the lean side, eï¬ectively, plain water will be applied to the ï¬re. Further information on the selection of 3-percent and 6-percent foam is included under âSystem and Equipment Compatibility.â Meet ï¬reï¬ghting foam performance standards in Canada â¢ As per the CARs, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes, AFFF purchased must meet the latest relevant performance standards of CAN/ULC-S560. Request proof of tests on performance and quality from prospective ï¬reï¬ghting foam concentrate suppliers. â¢ To conï¬rm that the foam purchased meets the relevant performance standards required for the country. Area Best Management Practice Rationale Environmental Considerations Do not purchase PFOS-based AFFF â¢ All new production has been banned in the United States and Canada, and the sale (and purchase) of PFOS-based AFFF is prohibited in Canada. Do not use AFFF that has >=C8 ï¬uorotelomers â¢ To align with the targets of the U.S. EPA 2010/2015 PFOA Stewardship Program and to be in compliance in advance of the incumbent Environment Canada regulations that would ban the use of >=C8 ï¬uorotelomers that can break down to PFOA. Select AFFF that contains C6- based ï¬uorotelomers where available (Information can be found in a productâs manufacturing sheet.) â¢ While persistent in the environment, PFCAs with fewer than eight carbons, such as perï¬uorohexanoic acid (PFHxA), and PFSAs with fewer than six carbons, such as perï¬uorobutane sulfonic acid (PFBS), are believed to be generally less toxic and less bioaccumulative in wildlife and humans. Review environmental data, where available, from a productâs speciï¬cation. If available, choose a foam with the following criteria: â¢ Highest lethal dose â Lowest BOD â Lowest COD â Highest LC50 â¢ Some ï¬reï¬ghting foams can have greater environmental impact based on the physicochemical properties of the ï¬reï¬ghting foam product. â¢ It is important for those working with the products to understand the type of potential impacts a product may have so it can be dealt with accordingly. Table 4-2. Best management practices associated with procurement of AFFF.
aFFF Management Within airport Operations 35 System and Equipment Compatibility Determine the compatibility of foam with existing systems and equipment. Use the type of device required for the foam concentrate. Check the compatibility of any new foam with the previous foam type/batch â¢ Based on the foam concentrate, diï¬erent equipment or systems may be required (i.e., an aspirating vs. non-aspirating device). In addition, diï¬erent equipment may only be compatible with a foam concentrate of a certain percentage. Older equipment may only be compatible with 6-percent foam. â¢ The type of foam concentrate should be compatible with the system and equipment to avoid coagulation concerns. Recalibration and resetting proportioning equipment may also be required. â¢ Consult with the equipment manufacturer prior to using a diï¬erent type of foam concentrate in the equipment. â¢ Flushing of the system is required prior to using a new foam concentrate. Area Best Management Practice Rationale Select 3-percent foam concentrates, when system and equipment compatibility allows. Look to upgrading ï¬reï¬ghting equipment to be compatible with the use of less foam concentrate, when applicable â¢ 3-percent foams require half of the volume of concentrate to produce the same amount of foam, making them more cost-eï¬ective, reducing on-site storage requirements, and requiring less product in ARFF vehicles. â¢ Newer equipment is compatible with 3-percent foam concentrate, which requires the use of less foam concentrate as an input. Table 4-2. (Continued). 4.3 Storage Proper storage of AFFF concentrates used for firefighting purposes alleviates the likelihood of accidental releases, spills, or concentrate contamination and prolongs the shelf life of the product. At most airports, AFFF is stored within ARFF vehicles (i.e., in the vehicleâs designated foam tanks), on-site in the manufacturerâs containers, in on-site storage tanks, and/or within hangar deluge systems. The following sections identify legislative requirements governing AFFF storage, the current state of the practice, and best management practices associated with AFFF storage. 4.3.1 Regulations Dictating Firefighting Foam Reserves Capacity The FAA and Transport Canada dictate how much AFFF airports need to store in reserve. Reserve storage requirements vary by the size of the airport and the type of aircraft the airport services. In the United States, the FAA requires an on-airport reserve firefighting foam supply either in a single container, storage tank, or storage area that has capacity sufficient to fill all vehicles with at least twice their assigned capacity (i.e., bunded storage). Transport Canadaâs guidance related to firefighting foam reserves is included in Standard 323.08. It requires that a sufficient quantity of foam concentrate is held in reserve to allow four complete discharges (i.e., assuming that at the proper concentrate-to-water ratio [or percentage], there is enough concentrate on hand to empty the total water volume available within the ARFF vehicles four times). The amount held in reserve can be considered to include the volume carried on the ARFF vehicles. 4.3.2 State of the Practice The following sections describe the state of the practice associated with key storage consider- ations: storage areas and type of containers.
36 Use and potential Impacts of aFFF Containing pFaSs at airports 220.127.116.11 Storage Areas Survey respondents characterized storage areas for firefighting foams to be as follows: Most Likely Storage Areas Least Likely Storage Areas â¢ Enclosed â¢ Covered â¢ Have a cement or concrete ï¬oor â¢ Have double containment â¢ Underground storage tanks â¢ Have an earth or gravel ï¬oor The survey responses suggested that enclosed storage was substantially more common in the United States (95.3 percent) than in Canada (77.8 percent). While double containment for storage was not common, responses showed that larger airports were more likely than smaller ones to use double containment. The two countries also differed in the quantity of AFFF storage areas that have an earth or gravel floor. In the United States, virtually none (99.3 percent) of the respondents have such floors, whereas approximately 6 percent of Canadian airports reported storing their AFFF in storage areas with earthen or gravel floors. 18.104.22.168 Containers Regulations in the United States and Canada do not dictate how foam concentrates should be stored. On-site storage of firefighting foams at North American airports is often in tanks or in the manufacturerâs containers. Guidance on conditions for storage reserves and general storage of foam concentrates can be found in a foam concentrate manufacturerâs product information sheets such as an SDS and/or a technical data sheet. Additional guidance on storage conditions, storage containers, and mixing, among other things, can be found within the standards used to accredit firefighting foams (i.e., NFPA, MIL-SPEC, and UL). Manufacturers of foam concentrates suggest storing the product in its original shipping con- tainer or in tanks or other containers that have been designed for foam concentrate storage. Above-ground storage tanks designed specifically for foam concentrate storage are produced and sold by a number of manufacturers, including select AFFF manufacturers. Recommended construction materials for storage containers include stainless steel (Type 304L or 316), high- density cross-linked polyethylene, or reinforced fiberglass polyester with a vinyl ester resin. Manufacturers of storage tanks for foam concentrates suggest that above-ground storage tanks be placed on a level surface. Conditions To avoid evaporation, foam concentrate storage should be in a container that is sealed to prevent the free exchange of air. The recommended storage environment should be within the temperature range listed in the product manufacturersâ information sheet. Storage tempera- tures for AFFF concentrates are generally listed as being between 2Â°C to 49Â°C (36Â°F to 120Â°F). If stored in the correct environment, following manufacturerâs guidelines and not otherwise contaminated, AFFF concentrates can reportedly last between 20 and 25 years. Mixing Mixing of different foam concentrates is not recommended. However, on a case-by-case basis and in consultation with the manufacturer, mixing may be acceptable. Current guidance regard- ing mixing includes the following: â¢ Different types of foam concentrates (e.g., AFFF and fluoroprotein based) should not be mixed. Different brands of the same type of concentrate should not be mixed unless data are provided by the manufacturer to, and accepted by, the authority having jurisdiction (e.g., FAA, Transport Canada) to prove that they are compatible under NFPA 11.
aFFF Management Within airport Operations 37 â¢ In the United States, MIL-F-24385F qualified product should not be mixed with other foam concentrates that are not qualified. â¢ In Canada, foam concentrates of different types or from different manufacturers should not be mixed except where it has been established that they are completely interchangeable and compatible (CAR Standard 323, Section 323.08). 4.3.3 Best Management Practices Table 4-3 identifies the best management practices associated with the storage of AFFF. Proper storage following these practices can reduce the likelihood of accidental releases, spills, or concentrate contamination and prolongs the shelf life of the AFFF. Storage Containers Store in speciï¬c types of containers: â¢ Original shipping container â¢ 55-gallon drums/plastic barrels â¢ Above-ground storage tanks (double walled) â¢ To allow for product integrity and shelf life to be maintained and to minimize the risk for leaks and spills. Read and follow the storage procedures outlined in SDSs and TDSs for the product â¢ To meet product manufacturersâ recommendations for storage. Use containers with recommended materials: â¢ Double-walled stainless steel (Type 304L or 316) â¢ High-density cross-linked polyethylene (XLPE) â¢ Reinforced ï¬berglass polyester with a vinyl ester resin â¢ Recommended composition of storage containers are inert, so the product will not change nor will the concentrate be contaminated. Label storage containers and storage tanks to identify the type of foam concentrate and concentration. â¢ To prevent mixing of foams of diï¬erent brands and/or concentration and prevent inappropriate use or disposal. Storage Conditions Store under storage conditions as described in a manufacturerâs product information sheet: â¢ Sealed â¢ Secured â¢ Temperature (ranges) â¢ Mixing (do not mix foam concentrates or brands) â¢ To meet product manufacturersâ recommendations for storage, to allow for product integrity and shelf life to be maintained, and to alleviate the risk for leaks and spills. Store in a storage facility/environment that is â¢ In an area designated for the storage of these chemicals â¢ Roofed/sheltered â¢ Rack system in place when totes are used â¢ The designated storage area provides an area where foam concentrates are stored away from incompatible materials (as outlined in a productâs SDS). A designated area should also allow the recommended storage conditions to exist and for storage to be away from any potential hazards (e.g., electrical). â¢ Roofed/sheltered areas are to avoid weather damage (rain, snow) that could compromise the integrity of the product. Area Best Management Practice Rationale Make use of other bunded storage methods: â¢ Secondary containment (e.g., drums sit on top of a tote) â¢ In the event of a leak or spill the product would be contained until remedial action can take place. Store on level ground with a hard surface (e.g., concrete, asphalt) â¢ In the event of leak or spill, to reduce the risk of the product permeating the ground surface. Reserves Follow the recommended reserve quantities to be stored â¢ The FAA requires that an on-airport reserve of ï¬reï¬ghting foam have the capacity suï¬cient to ï¬ll all vehicles with at least twice their assigned capacity. Transport Canada requires that the amount of foam concentrate held in reserve should allow for four complete discharges with the required quantity of water. Table 4-3. Best management practices associated with the storage of AFFF at airports.
38 Use and potential Impacts of aFFF Containing pFaSs at airports 4.4 Application AFFF is applied as an extinguishing agent for Class B fires (i.e., fires of flammable and com- bustible liquids such as crude oil, gasoline, and fuel oils). The application of AFFF serves to â¢ Coat a pool of flammable or combustible liquid, acting as a barrier to prevent oxygen from fueling the fire. â¢ Form an aqueous film of the water/concentrate after the foam has dissipated on the fire surface that suppresses fuel vapor and seals the fuel surface. â¢ Provide additional fire suppression through the water in the foam providing a cooling effect. The following sections describe applications where AFFF is used, handled, or tested; the current state of the practice with regard to AFFF application at airports; and best management practices associated with AFFF application. 4.4.1 Firefighting Foam Application in Airport Operations AFFF is used in airport operations for the primary purposes of preventing, extinguishing, and controlling fires involving flammable liquids. The application of AFFF occurs during aircraft rescue situations, training, testing, and/or as a result of a discharge from deluge systems in aircraft hangars. In addition, for the purposes of this report, application also refers to handling of AFFF concentrate, including the periodic removal and replacement of AFFF concentrate from vehicles during maintenance. Please note that this report does not address how AFFF should be deployed to prevent, extinguish, or control a fire. Guidance on how to deploy AFFF for these purposes should be sought from airport emergency response personnel. 22.214.171.124 Aircraft Rescue Aircraft rescue is the firefighting action taken to prevent, control, or extinguish fire involving, or adjacent to, an aircraft (FAA 2004). Federal law in both the United States (14 CFR 139) and Canada (CAR Subpart 3 âAircraft Rescue and Fire Fighting at Airports and Aerodromes) requires that all airports operating regularly scheduled commercial flights have firefighting capabilities appropriate for the aircraft serviced. In the United States, 14 CFR Part 139 establishes the minimum firefighting capability to respond to aircraft rescue situations. The different types, quantities, and flow rates of AFFF are described for ARFF Category A to E airports. The FAA requires airports to meet 14 CFR Part 139, but encourages them to provide greater ARFF capability, consistent with NFPA Standard 403: Aircraft Rescue and Fire-Fighting Services at Airports. In Canada, the CARs (Section 303.05) define critical categories for firefighting based on aircraft length and maximum fuselage width and the number of passenger and aircraft movements. The critical category determines the minimum aircraft firefighting service that must be provided by operators of designated airports or participating airports. Specific quantities of water, extinguish- ing agents, and the minimum number of ARFF vehicles necessary to provide a discharge capacity of foam related to the category of firefighting are provided in Section 303.09 of the regulations. Further, as per Standard 323.08, the quantity of foam concentrate on board ARFF vehicles should be sufficient to produce foam for at least two full loads of the required quantity of water specified in Section 303.09 of the CARs. 126.96.36.199 Training AFFF is most commonly used for training purposes at airports, specifically during live-fire drill training. In the United States, the FAA requires that following initial ARFF training, all
aFFF Management Within airport Operations 39 airport firefighting personnel who are involved in firefighting complete at least one live-fire firefighting drill every 12 consecutive calendar months. As per Advisory Circular 150/5210-17C, live-fire drills involve a pit fire with an aircraft mock-up using enough fuel to simulate the type of conditions that could be encountered during a rescue situation at that airport. If training of air- port firefighting personnel who are involved in firefighting does not occur within the 12-month period, an airport will be considered out of compliance with 14 CFR 139. While not required by 14 CFR 139, FAA recommends that airports also follow NFPA 1003: Standards for Professional Qualifications for Airport Fire Fighters. The FAAâs Advisory Circular 150/5220-17B: Aircraft Rescue and Fire Fighting Training Facil- ity provides guidance for airports on the design, construction, and operation of ARFF training facilities. Some facilities are located on airport properties due to convenience for training. Transport Canada requires live-fire drill training to be provided to all aircraft firefighting personnel every 12 months. The required training involves a live-fire drill to simulate a realistic firefighting situation that could be encountered on a typical aircraft at an airport. During these drills, fire-extinguishing equipment that will be used in the event of an accident includes the use of firefighting foams. Where training is conducted, if at all, varies by airport. Many airports have designated fire- fighting training areas. If training is not conducted in a designated training area or the desig- nated training area is not an engineered system designed to contain discharged AFFF and fuel, AFFF discharge may result in PFASs being released into the environment. 188.8.131.52 Testing AFFF has the potential to be released to the environment during testing of an AFFF mixture and equipment. In the United States and Canada, testing of firefighting foam equipment on ARFF vehicles is done in accordance to NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment. Transport Canada, per Standard 322.08, requires the NFPA tests to determine that the correct discharge rate is being delivered and the required foam physi- cal characteristics are being met. In addition to performance testing done by manufacturers on foam concentrates, NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment states that ARFF vehicles should be tested on a schedule set out by the authority having jurisdiction (e.g., FAA, Transport Canada) in the following criteria areas: expansion ratio, drainage 25 percent, and proportioning and distribution pattern. Tests for these criteria involve allowing a foam solution to discharge from a hoseline or turret. Methods for testing these criteria include the following: â¢ Expansion ratio, drainage 25 percent, and proportioning: â Selecting foam samples representative of the foam produced by the nozzle as it would be applied to a fire. â Collecting foam samples through a foam sampling apparatus or foam collector, where a foam nozzle is aimed into a collector so that discharge is collected in a 1,000 mL graduated cylinder. â Observing the level of accumulation at timed intervals and the total weight of the foam sample and performing calculations to analyze the results. â¢ Distribution pattern: â Ground sweep nozzle and hand line nozzle tests: b Discharging from ground sweep nozzles and hand line foam nozzles onto a paved surface for a period of 30 seconds.
40 Use and potential Impacts of aFFF Containing pFaSs at airports b Plotting the outline of the effective foam pattern. b Establishing, measuring, and recording straight stream and fully dispersed nozzle settings. â Turret ground pattern tests: b Preparing a foam solution with the type of foam concentrate to be used during actual emergencies with the proportioner set for normal firefighting operations. b Performing discharge tests to establish foam patterns produced and the maximum range attainable by a turret nozzle for a period of 30 seconds. b Recording and analyzing results. Further details on performance criteria, test methods, and calculations are available in NFPA 412. 184.108.40.206 Handling Handling of AFFF may occur during an emergency response incident, training, testing, or vehicle maintenance. Procedures for safe handling apply not just to firefighting personnel. Due to the potential for spills and leaks, airport personnel responsible for handling AFFF need to exercise caution and practice safe handling procedures. Procedures for safe handling of foam concentrates are included in the manufacturerâs product SDSs. Examples of these procedures from a manufacturerâs SDSs include the following: â¢ Limit all unnecessary personal contact. â¢ Wear protective clothing when risk of exposure occurs. â¢ Handle in a well-ventilated area. â¢ Avoid contact with incompatible materials. â¢ Wash hands with soap and water after handling. 220.127.116.11 Aircraft Hangars Fixed fire protection systems use AFFF to extinguish Class B fires that could occur in facilities that house aircraft. Most fire protection systems for aircraft hangars are designed in accordance with NFPA 409: Standard on Aircraft Hangars. In the United States, requirements for adherence to NFPA 409, or specific sections of NFPA 409 as it relates to aircraft hangars, are contained in the International Building Code. In Canada, local building code requirements are followed and often reference NFPA 409. There are no specific requirements by the FAA or Transport Canada related to fire suppression and the use of firefighting foams in aircraft hangars. NFPA 409 considers four aircraft hangar groups classified on the basis of aircraft access door height, single fire area, and, in some cases, the aircraft that they store. The aircraft hangar classification determines the appropriate fire protection systems. Aircraft hangars housing larger aircraft (Group I and II) have several options for protection systems, including a fixed foamâwater deluge system, whereas Group III hangars do not usually require any fixed protection system, and Group IV hangars can use an automatic water sprinkler (meeting specific criteria), or high- or low-foam expansion systems. The following application rates are required for fixed foam systems in hangars: â¢ Group I: 0.20 gpm per sq ft for AFFF â¢ Group II and IV: 0.10 gpm per sq ft for AFFF Firefighting foam can be intentionally released from an aircraft hangar fire protection system in the event of a fire, or it can be released due to human error, mechanical malfunction, or electrical malfunction. A release may also occur during periodic testing of a deluge system. Trench drainage systems should be designed in a hangar system to collect and contain fuel to prevent fire hazards, but can also assist with the containment of AFFF and other discharge for
aFFF Management Within airport Operations 41 subsequent treatment. Per NFPA 409, trench drainage systems, in addition to sufficient floor pitch to allow liquids to flow into drain inlets and be collected, are to be a part of the aircraft hangar design. Curbs, ramps, drains, or appropriate sloping of the floor at all openings of the hangar are also suggested to prevent any releases of liquids. Trench drainage systems are meant to have oil separators and a bypass around each separator to allow for emergency direct disposal of water and flammable liquid when the foam-water systems are in use in the event of a fire. The flammable liquids are then meant to be discharged to a tank, cistern, or sump away from any potential exposure. 4.4.2 State of the Practice While these events may be infrequent, close to three-quarters of the responding North American airports surveyed have used AFFF for actual firefighting purposes. The extent to which AFFF has been used for these purposes varies by airport size, with the largest airports having the highest frequency of use and the smallest airports having the lowest. The more common use of AFFF at airports was found to be training and testing. Most airports have held firefighting training on their premises at some point in time, and the majority used AFFF in the training exercises. Of the 167 North American airports that completed the survey, 97.6 percent indicated that they conduct foam tests of both the AFFF mixture and equip- ment. The majority of respondents indicated that these tests are conducted every 6 to 12 months (54.6 percent); the second largest group of respondents indicated that they conduct their tests every 4 to 6 months (33.1 percent). The survey also suggested that the testing frequency increased with increasing airport size. When handling AFFF, staff and trainees wear various types of protective equipment. Almost all respondents outfit those handling AFFF with work gloves and eye protection; strong majorities provide safety boots, turnout gear, and fire-retardant clothing. Substantially fewer respondents reported use of nitrile or other one-time-use gloves. The survey also indicated that equipment testing of deluge systems in airport hangars occurred infrequently, with only 7 percent of responding airports indicating that such test- ing is conducted. 4.4.3 Best Management Practices Table 4-4 identifies the best management practices associated with the application of AFFF at airports. 4.5 Disposal Given the potential environmental implications associated with PFASs (as documented in Chapters 2 and 5 of this report), proper disposal of AFFF and/or AFFF concentrate is required. The unique properties of PFASs, however, present challenges in disposing of AFFF in an envi- ronmentally responsible manner. Moreover, traditional disposal methods suitable for other waste streams may not be effective. Regardless of waste stream or application scenario, AFFF and/or AFFF concentrate should not be directly discharged or deposited to the environment. The only exception is when AFFF is being used in an emergency response. The following sections discuss various disposal consider- ations, the state of the practice as determined from the industry survey conducted as part of this research, and best management practices.
42 Use and potential Impacts of aFFF Containing pFaSs at airports Handling Follow industry-recommended practices: â¢ NFPA 402: Guide for Aircraft Rescue and Fire-Fighting â¢ Have a safety spill plan in place when transferring containers/testing equipment and systems â¢ So that industry-recommended operational procedures are followed to provide the basis for airport representatives to respond to an aircraft emergency in the minimum possible time and employ rescue and ï¬reï¬ghting techniques eï¬ectively. Provide personnel training: â¢ Staï¬ is educated in safety and environmental concerns â¢ Staï¬ is trained in standardized procedures designed for safety and environmental concerns â¢ Have two or more people available to move containers with AFFF Require personnel to wear PPE: â¢ Includes but not limited to work gloves, eye protection, safety boots, and protection from contact with skin â¢ To promote awareness of the potential impacts to human health and the environment if the product is mishandled and to provide an understanding of mitigation measures. â¢ To minimize any potential health hazards during the handling of the foam concentrate. Read and follow the handling procedures outlined in SDS and TDS for the product (e.g., work in a ventilated area/ Never use galvanized pipe and ï¬ttings in contact with undiluted concentrate. â¢ To meet product manufacturerâs recommendation that may be speciï¬c to the product. â¢ A galvanized pipe and ï¬ttings would be at risk of corrosion upon contact with foam concentrate. When applicable, limit the distance travelled between storage areas and ï¬lling areas. â¢ Limiting the transportation of foam concentrate when not stored in ï¬xed tanks minimizes the potential risk of leaks and spills during handling Aircraft Rescue Follow industry-recommended practices â¢ NFPA 402: Guide for Aircraft Rescue and Fire-Fighting â¢ Fire control is often an essential condition to provide protection for the occupants in an aircraft rescue event. Following industry-recommended operational procedures provides the basis for airport representatives to respond to an aircraft emergency in the minimum possible time and employ rescue and ï¬reï¬ghting techniques eï¬ectively. Area Best Management Practice Rationale Provide personnel training: â¢ Staï¬ is educated in safety and environmental concerns. â¢ ARFF personnel possess a sound knowledge of ï¬re behavior, as per NFPA 403 Section E.4.3 (2014). â¢ Staï¬ is trained in standardized procedures designed for safety and environmental concerns. â¢ Hazardous waste/spill response team nearby to carry out clean-up activities after the emergency has â¢ Responding to an emergency response incident safely should be the ï¬rst priority; however, having environmental response teams ready and mobilized following the emergency can contribute to reducing the potential environmental impacts by containing and establishing a perimeter to help control the extent of environmental impacts. Require personnel to wear appropriate PPE: â¢ Including but not limited to: nitrile or latex gloves, eye protection, safety boots, and protection from â¢ To minimize any potential health hazards during response activities. Operations avoid inhalation). Operations. contact with skin. been mitigated. and transport. Implement training that follows industry-recommended â¢ FAA Advisory Circular No. 150/5210-17C. â¢ NFPA 1003: Standard for Airport Fire Fighter Professional Qualiï¬cations. â¢ Staï¬ is educated in safety and environmental concerns. â¢ Staï¬ is trained in standardized procedures designed for safety and environmental concerns. â¢ To promote awareness of the potential impacts to human health and the environment when the product is released during training exercises and an understanding of mitigation measures. practices Training Table 4-4. Best management practices for the application of AFFF at airports.
aFFF Management Within airport Operations 43 Follow a deï¬ned training schedule as deï¬ned by the authority having jurisdiction. â¢ In the United States, each Part 139 Certiï¬cate holder must ensure all ARFF personnel participate in at least one live-ï¬re drill every 12 consecutive calendar months. â¢ Transport Canada requires live-ï¬re drill training to be provided to all aircraft ï¬reï¬ghting personnel every 12 months. Use a regional training facility or host live-ï¬re training for multiple airports at one location. â¢ To reduce the potential environmental impact for individual airports and lower the frequency of ï¬reï¬ghting foam use for training activities. Require personnel to wear appropriate PPE: â¢ Including but not limited to: nitrile or latex gloves, eye protection, safety boots, and protection from contact with skin. â¢ To minimize any potential health hazards during the handling of the foam concentrate. Area Best Management Practice Rationale Prepare for training exercises: â¢ Safety spill plan in place when transferring containers/ testing equipment and systems. â¢ In the event of a leak or spill as a result of preparing for training exercises, a plan is in place for rapid response and containment. Training locations: â¢ Conduct training in an area where AFFF water/foam solution can be contained and collected for treatment â¢ Conï¬gure training area with a sump to allow collection and disposal of material used during training. â¢ Do not discharge to ground. â¢ Consider constructing a lined ï¬re training pit. â¢ Locate training exercises away from storm drain inlets, drainage facilities, or water bodies. â¢ To prevent migration of the discharged ï¬reï¬ghting foam to locations where it cannot be collected and properly disposed of. Make use of alternative foam products for training exercises. â¢ Other international jurisdictions (e.g., Norway, Australia) make use of training foams that do not contain ï¬uorine but have similar foaming properties for certain training exercises (e.g., equipment and/or live-ï¬re testing). These ï¬uorine-free foams are considered to present the lowest environmental impact. Optimizing ï¬reï¬ghting program (e.g., equipment, training, â¢ Diï¬erences in foam concentrate characteristics can be adjusted for by changing ï¬reï¬ghting procedures (e.g., bermed). Equipment and System Testing Follow industry-recommended best practices: â¢ NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment Discharge the minimum required to test the system/equipment: â¢ Use the same collected samples for multiple tests, where applicable. â¢ Collect discharge for storage and disposal. â¢ Put a safety spill plan in place. â¢ Maintain equipment in good condition to reduce spillage (e.g., ensure ï¬ttings are tight). â¢ To limit the amount of foam solution discharged during testing. NFPA 412 states that the portions of drained solutions used in drainage tests can be used for the âfoam solution sampleâ for other tests. Conduct ground pattern tests ï¬rst with water, then with the foam solution. â¢ To minimize unnecessary discharge of foam solution by using water in advance of testing when adjustments are being made on equipment and systems. procedures) Table 4-4. (Continued). (continued on next page)
44 Use and potential Impacts of aFFF Containing pFaSs at airports 4.5.1 Disposal The means by which an airport disposes of AFFF or AFFF concentrate can vary based on the nature of activity resulting in waste for disposal, the nature of the material being disposed (e.g., aspirated residual AFFF, AFFF concentrate, and wastewater containing AFFF or PFASs as a result of vehicle or equipment system maintenance), an airportâs waste management facilities and associated capacity, and applicable regulations. Given the stringent and evolving regulatory standards surrounding PFASs, please note that proper disposal is not to be predicated on the volume of material to be disposed (i.e., even very small quantities of material discharged into the environment could have significant human health and environmental impacts and result in significant costs to address). 18.104.22.168 Discharge Disposal Discharged AFFF will likely result in residual foam. Uncontrolled releases pf AFFF to land and surface water can occur in the event of an accidental discharge or a fire emergency; where possible, residual foam (or, if washed down, residual AFFF wastewater) should be contained so that the amount directly released to the environment is minimized. Generally, in accordance with the manufacturerâs SDSs, residual AFFF/AFFF wastewater drains to existing infrastructure on the airport property and then is directed to a wastewater treatment facility (i.e., either on-site or via a municipal sewer infrastructure). Such facilities, however, vary widely in their ability to address the impacts of PFASs effectively, if at all (i.e., many studies have shown no removal of PFASs via wastewater treatment), depending on the treatment train. Prior Area Best Management Practice Rationale Aircraft Hangers Construct the aircraft hangar following local building code: â¢ NFPA 409: Standard on Aircraft Hangars. â¢ Local building codes often reference NFPA 409, which contains the minimum requirements for proper construction of aircraft hangars and for ï¬re protection at aircraft hangars. Design deluge (foam) testing systems with the following â¢ Away from storm drain inlets, drainage facilities, or water bodies. â¢ Discharge AFFF waste to a sanitary sewer (industrial wastewater permitting may be required). â¢ AFFF waste should not be discharged to storm drains or water bodies. â¢ Paved with concrete or asphalt or stabilized with aggregate base. â¢ Bermed to contain AFFF and to prevent run-on. â¢ Conï¬gure discharge area with a sump to allow collection and disposal of AFFF. â¢ To mitigate the potential eï¬ects of AFFF discharge in the event of a testing exercise or an incident in an aircraft hangar. Discharge the minimum required to test the system/equipment. â¢ Have a safety spill plan in place Have piping that connects the foam to the ï¬re suppression system be above ground over a concrete ï¬oor. â¢ To limit the amount of foam solution discharged during testing. â¢ In the unlikely event that a pipe burst, above-ground piping would provide for more rapid leak detection and spill response. Provide protection for the aircraft hangar, including electrical and mechanical equipment exposed to possible damage during â¢ Sandbags or similar means. â¢ To prevent migration of the discharged ï¬reï¬ghting foam to other locations in the aircraft hangar and to protect the mechanical and electrical equipment. characteristics: discharge tests. Table 4-4. (Continued).
aFFF Management Within airport Operations 45 to disposal (to the extent practicable, recognizing that weather conditions may drive runoff), airports should check with the local wastewater facility to confirm its ability to treat wastewater containing PFASs. At some airports, residual AFFF/AFFF wastewater is directed to stormwater drains that may not be directed to a treatment facility. In addition, airports need to coordinate with federal, state/province, and local authorities and other waste service managers to understand the applicable requirements and available disposal options. In the event that hydrocarbon fuels are mixed with the foam solution, a fuel-water separator can be used to allow for the AFFF/AFFF wastewater solution to be disposed of separately from the fuel. Prior to discharge, waste should be evaluated to determine whether flammable materials are still present at hazardous concentrations and to review the applicability of sewer restrictions (73). 22.214.171.124 Removal from Equipment or Systems Testing and/or maintenance may require the removal of AFFF concentrate from ARFF vehicles, equipment, and systems. Removal of AFFF from vehicles, equipment, or systems may also be required in the event that an airport switches to a different type of foam concentrate. Flushing during removal or testing generates wastewater that contains AFFF. 126.96.36.199 Disposal of AFFF Stockpiles AFFF has a long shelf life. This means that legacy AFFF containing PFOS or long-chain fluoro- carbon surfactants still exists in U.S. and Canadian inventories. The manufacture and import of new PFOS-based products is banned in the United States; however, existing stocks may still be used if they were manufactured or imported into the United States prior to the rules taking effect in 2002 (74). While there is no explicit regulation barring the discharge of wastewater containing AFFF, in the United States it can be regulated under the Clean Water Act that regulates pollutant discharges into water. In Canada, the Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations indicated that PFOS-containing AFFF should not be used or otherwise released to the environment as PFOS has been identified as posing a risk to the environment. Consequently, PFOS-containing AFFF should be disposed of at an authorized waste management facility. Prior to the proper disposal of AFFF, provincial/territorial authorities should be contacted. 4.5.2 State of the Practice Two-thirds of the responding North American airports indicated that AFFF discharged dur- ing testing is disposed of onto the ground. The remaining third of respondents discharge AFFF into an engineered containment system. For the one-third of respondents who used engineered containment systems, the type of system most widely used was a small or non-permanent vessel, and the next most widely used system was testing in a designated area such as a containment basin or training pit. Survey results regarding AFFF discharge during training activities were similar, with the majority of respondents (80 percent) indicating that AFFF was discharged directly onto the ground during training exercises. The remaining 20 percent responded that AFFF was discharged during training exercises into engineered containment systems. According to the survey, most respondents remove AFFF concentrate from firefighting equip- ment or systems for maintenance by draining or pumping AFFF into containers (e.g., a training pit, a holding tank, drums, barrels, and totes) for temporary storage of AFFF and then reuse it. 4.5.3 Best Management Practices Table 4-5 identifies the best management practices associated with the disposal of AFFF stock- piles or following use at airports.
46 Use and potential Impacts of aFFF Containing pFaSs at airports Discharge Disposal Dispose of foam-water solutions: â¢ Wastewater treatment, appropriate pretreatment steps taken. Dispose of foam-hydrocarbon solutions: â¢ Use fuel-water separator. Dispose of foam-soil mixtures. â¢ Industry guidance in the United States recommendations for disposal of PFOS-based AFFF concentrate is by incineration at a facility capable of handling the waste. â¢ Authorized disposal facilities can only dispose of waste for which they have been issued a certiï¬cate of approval or which meet their operating permits and are regulated by Province/Territory in Canada. Record all disposal. â¢ Recording what has been disposed of, in what volumes, and where provides a record of an airportâs disposal. Removal from Equipment or Systems Removal to containment vessel: â¢ Transfer by pump to containment vessel. â¢ Containment vessel should have secondary containment (e.g., underlying tote) during removal process. â¢ In the event of a leak or spill, the product would be contained until remedial action can take place. Practice proper handling protocol: â¢ Flush/clean out equipment thoroughly, retaining rinse water. â¢ Staï¬ handling AFFF transfer should wear appropriate PPE. â¢ To minimize any potential health hazards during the handling of the foam concentrate. Dispose of removed foam concentrate at an authorized location. â¢ The ability to dispose of unused foam concentrate may diï¬er by jurisdiction. Disposal should occur at an authorized location that handles hazardous waste. Disposal of AFFF Stockpiles Comply with legislation, regulation, and/or guidance in the United States. â¢ Industry guidance in the United States recommendations for disposal of PFOS-based AFFF concentrate is by incineration at a facility capable of handling the waste. Comply with legislation, regulation, and/or guidance in Canada. â¢ Authorized disposal facilities can only dispose of waste for which they have been issued a certiï¬cate of approval or which meet their operating permits and are regulated by Province/Territory in Canada. Area Best Management Practice Rationale Table 4-5. Best management practices for disposal of AFFF at airports.