Tech Focus: Considerations and Solutions for AFFF Transition Projects
As the conversation surrounding PFAS continues to grow, so does the focus on a widely used firefighting product known as AFFF, or Aqueous Film Forming Foam. These foams are used to suppress fires at facilities that contain petroleum products or other flammable chemicals, as well as municipal fire departments and airports. Yet, because of the environmental and health risks posed by AFFF, many users are exploring the complex and costly task of replacing their AFFF systems.
Implementing the right technology as part of your replacement program can make the complex process much easier to tackle. For instance, Langan’s PFAS experts collaborate with its digital solutions team to leverage GIS, EQuIS, and Power BI tools to help clients identify applicable regulations and assess AFFF liabilities on a site. By understanding the level of liability and cleanup needed—and having all the information easily accessible—teams are equipped to develop and execute the correct approach for their specific project, regardless of the location.
To date, over 30 states have proposed regulations to limit or eliminate the potential environmental and health effects of PFAS in AFFF. These regulations include additional reporting requirements, outright bans on the sale of PFAS-containing AFFF, AFFF take-back programs, and restricting the use of AFFF in firefighter training. AFFF has also started gaining federal attention through the inclusion of PFAS-free alternatives on U.S. Department of Defense-approved product lists and the designation of perfluorooctanesulfonic and perfluorooctanoic acids as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act. As a result of these state and federal regulations, many facilities and operations that use AFFF are assessing potential replacement options.
When a facility transitions away from an AFFF system, there are many considerations that need to be made beyond regulatory compliance. Oftentimes, replacing the PFAS-containing foam with a different product (e.g., Synthetic Fluorine-Free Foam or a water-deluge system) is not a viable option because of budget limitations, available space, or insurer requirements. Other factors can include physical and chemical components, such as the effectiveness of the replacement option to address the type of fire hazard (e.g., petroleum or other specialty chemical hazards) or a facility’s distribution infrastructure, as well as design components (e.g., upgrading utilities to increase water supply; capturing, containing and managing runoff; a water-storage system’s capacity; a roof structure’s ability to sustain simultaneous loads of two fire protection systems until the new system is engaged). Additionally, there are decommissioning considerations, including whether the existing foam system’s pipes can be sufficiently cleaned if they are not replaced. Regardless of the path forward, each aspect of the process must be examined, as they can all impact the cost of the upgrade or replacement project.
Langan has the regulatory experience, in-house technical expertise, innovative technology, and relationships with fire-safety MEP professionals needed to help clients develop and implement safe, practical, and cost-effective solutions for their AFFF transition projects.
Learn more about Langan’s AFFF services and experience.
Ryan Andersen, CHMM is an environmental professional with over 19 years of experience. He specializes in the investigation and remediation of industrial and hazardous waste sites, development projects, and state (New Jersey, New York, Pennsylvania) and federal (CERCLA, RCRA, TSCA, HUD) regulatory programs.