AFFF Management and fire extinguisher disposal
At a glance
GHD was entrusted with safely disposing of 13 Tri-Max fire extinguisher units containing AFFF (aqueous film-forming foam) for The Oregon Military Department (OMD) at an Aviation Support Facility. AFFF contains PFAS (per- and poly-fluoroalkyl substances) classified as emerging environmental contaminants. To achieve this, GHD developed a comprehensive process that addressed not only the safe draining of the tanks and control of AFFF release but also mitigated other potential challenges and risks.
The challenge
The Oregon Military Department (OMD) was in possession of 13 Tri-MaxTM 30 wheeled fire extinguisher units (Tri-Max units) at an Army Aviation Support Facility. The Tri-Max units are a compressed air foam (cold CAF) system, and each unit is comprised of one 30-gallon capacity cylinder containing 3% concentrated aqueous film-forming foam (AFFF), a discharge nozzle, two compressed air cylinders and a dispensing hose. GHD developed a process for safely draining the AFFF tanks and disposing the Tri-Max units. The hidden challenges and risks mitigated prior to GHD mobilization ensured a successful project, including:
- Mitigate safely hazard associated with the pressurized cylinders used to operate the Tri-Max units
- Controlling unintentional release of AFFF
- Mitigating foaming while draining and rinsing to contain AFFF and reduce the total number of drums required
- Minimizing rinseate volume
- Maximizing recycling and reduce landfill disposal
Our response
GHD developed a solution to support the OMD mission, incorporating safety and local facility requirements. Our team drained and containerized AFFF from the Tri-Max units, then rinsed residual AFFF and containerized the rinsate fluid. The work was completed within secondary containment and on top of temporary tertiary containment to prevent AFFF from potentially entering the facility infrastructure. The Tri-Max units were modified to make them inoperable for any use prior to recycling. Worker safety was maintained by developing safe procedures and ensuring personal protective equipment was compatible with AFFF. Through creative planning and operations foam generation during tank draining and rinsing was kept to a minimum and effectively mitigated.
The impact
Per- and polyfluoroalkyl substances (PFAS) are classified as emerging environmental contaminants, which have been associated with potential risks to human health and the environment. At the time of project completion, PFAS were not regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Emerging regulations have since evolved from the EPA and state governments. GHD worked with the OMD to develop a risk based PFAS management strategy associated with the project materials to prevent future liability associated with anticiapted emerging regulations.
Fluorinated foams include:
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Legacy AFFF
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Legacy fluorotelomer AFFF
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Modern fluorotelomer AFFF
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Alcohol-resistant AFFF (AR-AFFF)
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Film-forming fluoroprotein foam (FFFP)
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Alcohol-resistant FFFP (AR-FFFP)
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Fluoroprotein foam (FP)
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Alcohol-resistant fluoroprotein foam (FPAR)
Fluorinated foams are commonly present at:
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Department of Defense facilities (including state National Guard facilities)
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Airports
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Petroleum refineries and fuel terminals
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Oil drilling platforms
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Industrial and manufacturing facilities
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Fire departments
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And many more federal, state, municipal, and commercial facilities
Some facilities have initiated or completed the process of replacing fluorinated foams with fluorine-free foam (F3), but fluorinated AFFF is still present at many facilities across the country. The viscosity of some F3 products may not be compatible with existing AFFF infrastructure, which requires infrastructure upgrades or complete replacement.
GHD is supporting the Department of Defense, local governments, and commercial infrastructure by preventing PFAS releases and implementing drinking water treatment technologies to protect public water supplies. GHD’s Dr. Tamara House-Knight offered an in-depth analysis on the national drinking water regulation in her latest article.
Check your labels, check your Safety Data Sheets and check your inventories. Is it time to reduce your PFAS risk, dispose your fluorinated AFFF, or replace your fluorinated AFFF and associated infrastructure with F3 and F3-compatible infrastructure?
Find out more about our customized and cost-effective PFAS responses here