Kevin Ferrara, AFSO21
Potentially, under the ground you walk on, lurks a hidden health hazard, a timebomb of sorts and you most likely don’t even know about it. Compared to the Flint Michigan water crisis that began in 2014 where over 100,000 residents were exposed, this larger hazard dates to the 1960s having and continuing to expose millions of innocent residents across America and around the world, significantly compromising their drinking water. This hazard so significant that in the past several years, it forced communities to stop drinking water from their wells and in some cases, public water systems once thought to be impervious to contamination.
This considerable hazard is associated with Per- and polyfluoroalkyl substances (PFAS) which have been found in products such as food packaging, non-stick cookware, stain-resistant carpeting, and some outdoor water-repellent clothing. PFAS are man-made chemicals that have been used in products dating to the 1940s and commonly found in firefighting agents, such as Aqueous Film Forming Foam (AFFF) as this discussion will focus on. (United States Environmental Protection Agency, 2019).
The Basics of AFFF
For those unfamiliar with AFFF, it is a man-made often clear or yellowish liquid used by fire emergency services (FES) agencies to combat certain types of fires, typically those involving hydrocarbons. Most AFFF used today is manufactured in a 3% or 6% concentration depending on the application requirement however, some manufacturers produce a 1% concentrate AFFF product. AFFF is mostly comprised of water however, chemicals called surfactants designed to reduce surface tension and allow the AFFF to form a thin layer or blanket on the surface of hydrocarbons such as aircraft fuel, are included. It is these surfactants found in PFAS that are considered a significant health hazard.
If applied directly, AFFF is ineffective because the concentrate alone does not expand and create a layer that adheres to the hydrocarbon’s surface. For AFFF to be effective, it must be properly mixed with water and then sprayed onto the hydrocarbon’s surface. AFFF is commonly mixed with water using an inductor; a device installed somewhere on a firefighting apparatus pump system. Or, AFFF can be mixed by using an eductor in which a device is affixed to a firefighting hose-line and a siphon wand is inserted into a nearby foam container, typically a 5-gallon plastic jug. As the mixture is discharged, it is applied onto the hydrocarbon’s surface using a ‘rain-drop’ effect, a technique where the AFFF is lobbed onto the fire using hose-lines and nozzles, or turrets like those seen on airport rescue firefighting (ARFF) apparatus. By using this technique, the foam falls to the surface of the hydrocarbon in small droplets that when reaching the surface of the hydrocarbon, do not cause such force as to disturb the surface tension, therefore allowing the foam to spread across the surface and create a thin barrier. Because fire normally requires three components to sustain itself; fuel, heat, and oxygen, it is the thin AFFF barrier that when applied effectively, can simultaneously remove oxygen, prevents fuel or fuel vapors from reaching an ignition source, and at the same time cools the surface.
Most FES apparatus in service today were manufactured within the last twenty years and likely have one or more foam tanks installed. Fire apparatus designed for structural firefighting, those you often see driving through your neighborhoods, will typically have at least one foam tank containing several gallons of Class A foam used for combustible materials such as wood, and certain cloth materials. Class A foam is designed to soak into the combustible material. Some apparatus such as ARFF vehicles will have a larger foam tank, some with as much as 400 gallons or more depending on the size of the apparatus. The foam tanks on ARFF apparatus are filled with Class B foam which is used for fires involving flammable and combustible liquids and gasses as well as petroleum gases, oils, gasoline and aircraft fuels, solvents, and alcohols. Class B foams are designed to repeal carbons. Additionally, some apparatus may be equipped with two foam tanks, one filled with Class A foam and the other filled with Class B foam just in case emergency responders need to choose once they arrive on scene. It should be noted that Class A foam is ineffective on many Class B fires, just as the case with portable fire extinguishers rated for certain types of fires. Some industrial areas like bulk fuel storage areas may have large silos containing flammable chemicals. Therefore, trailers containing thousands of gallons of foam may be prepositioned on site or nearby for FES agencies to connect to. Having learned how AFFF is applied, the next several paragraphs will provide information regarding the contamination and exposure risk of using AFFF.
AFFF Contamination and Exposure
Depending on their size and configuration, large ARFF apparatus may have a water tank capacity of 4,500 gallons and a foam tank capacity of 540 gallons. If the apparatus is equipped with 6% AFFF, by the time the entire 540 gallons of AFFF is used, 9,540 gallons of firefighting agent (water and foam mixed) will have been discharged. Typically, ARFF apparatus water tanks are sized to require one refill before the onboard AFFF tank is depleted however, depending on the size and configuration of the ARFF apparatus, more or less refills may be necessary. When using 6% AFFF, for every 100 gallons of firefighting agent discharged, 94 gallons will be water and 6 gallons will be AFFF. If using a 3% concentration, the amount of firefighting agent increases to 10,040 gallons; for every 100 gallons of firefighting agent discharged, 97 gallons will be water and 3 gallons will be AFFF. Assuming no runoff occurs, while maintaining a quarter-inch deep layer or blanket, 10,040 gallons of 3% firefighting agent could cover approximately 64,000 square feet of surface; that’s an area approximately 254 feet wide and 254 feet long. Depending on factors such as but not limited to the surface material, terrain, weather conditions, and application control, the square footage may decrease or increase.
Depending on the surface material such as soil, sand, water, snow, ice, stone, etc., the fuel may soak into or across the surface which may require an increase of firefighting agent to be used. Therefore, properly training those tasked with using AFFF is important and necessary. Many times, personnel, especially those who are unfamiliar with AFFF, find themselves using more agent than is necessary or discharging the agent in a manner causing unexpected runoff, thus resulting in the contamination area to potentially increase beyond containment capabilities of emergency responders. Many times, emergency responders are fixated on putting the fire out that they fail to see the runoff flowing down the street and into stormwater drains or manholes. Once contaminates enter these underground and often inaccessible storm water systems, locating the head of the flow and stopping it is extremely difficult. Due to the possibility of these unexpected runoffs, FES agencies using foam should preplan for and implement precautionary measures to minimize the area of contamination.
The Agency for Toxic Substances and Disease Registry, a division of the U.S. Department of Health and Human Services and the Centers for Disease Control and Prevention, states that some studies in humans with PFAS exposure show that certain PFAS may increase risk of cancer; affect the immune system; increase cholesterol levels; interfere with the body’s natural hormones; lower a woman’s chance of getting pregnant; and affect growth, learning, and behavior of infants and older children (Agency for Toxic Substances and Disease Registry, 2018).
For many FES agencies, they stock what is considered Legacy AFFF, firefighting foam manufactured in the United States between the late 1960s and 2016 (Interstate Technology Regulatory Council (IRTC), 2018). Recent studies have found that Legacy AFFF has increased levels of PFAS however, all AFFF, to include NextGen or environmentally friendly firefighting foam contains fluorosurfactants; synthetic chemical compounds designed to reduce surface tension (Jönsson, 2017).
Based on increasing concerns of possible ground-water contamination from communities surrounding military installations, the Department of Defense (DoD) recently reported over 524 military installations throughout the United States have been reviewed to determine what amount of if any, contamination indicates increased levels of PFAS. From those installations reviewed, 401 active and former military installations were found to possess some level of contamination with 24 having exceeded the Environmental Protection Agency’s (EPA) Health Advisory (HA) level of 70 parts per trillion (ppt) (Vergun, 2019). Because of the contamination and increasing concern of health risks associated with PFAS, the DoD began to take swift action in providing funding for exposure assessments to include blood testing for FES personnel, individuals who often come in direct contact with AFFF during training and emergency response.
Precautionary Steps
So, what does this mean for your community, especially if you don’t reside near a military installation? Based on the products previously mentioned where PFAS compounds are used in the manufacturing process, it is safe to assume every community throughout the United States has some type or level of exposure to PFAS. For obvious reasons, based on the hazards and health risks associated with PFAS, it would be ridiculous to believe an individual would willingly ingest a harmful product containing PFAS such as AFFF. The question then is, if AFFF is not intended for human consumption, is not considered biodegradable, and has been proven to be harmful to the environment and water sources, why are FES agencies continuing to use AFFF and why would local, state, and federal agencies continue allowing AFFF and other products containing PFAS to be discarded freely into the environment, particularly the soil?
Look around your community and you’ll likely find various FES providers. What you may not see or be familiar with are the tools and equipment, to include specialized mitigating materials or firefighting agents like AFFF these emergency response agencies employ to combat various types of incidents.
Communities should be aware that in most jurisdictions, regulations are non-existent regarding the storage, use, and disposal of foam, as is the case in Pennsylvania. According to the Pennsylvania Department of Environmental Protection (DEP), there are no state or federal maximum contaminate levels (MCL) for PFAS although in 2016, the U.S. Environmental Protection Agency (EPA) established a HA (Pennsylvania Department of Environmental Protection, 2019). The EPA’s lifetime HA is 70ppt. Currently, in Pennsylvania and in many other states, as well as with the EPA, HA’s are non-enforceable and non-regulatory. It is shocking to learn that despite scientific data showing there are health risks associated with products containing PFAS, no individual or organization using, providing, and subsequently subjecting individuals to these products without their knowledge can be held accountable. Rather, these HAs simply provide advisory information that is acknowledged or ignored by the using agencies.
Because of this, local, state, and federal government agencies must take immediate action to draft and implement their own enforceable and regulatory policies and laws regarding the storage, use, and mitigation of materials containing PFAS such as AFFF. Despite the EPA establishing a HA and acknowledging that it’s unenforceable, the continuation of missing or inadequate local or state policy and or legislation places current communities at risk as well as increases the risk to future generations of community members. Knowing there are existing and potential hazards and doing nothing to prevent or mitigate them does not solve the problem, rather it adds to it.
Because of the lack of regulations regarding HA’s and firefighting foam, many FES agencies such as rural volunteer fire departments may not be aware of the risks and hazards associated with firefighting foam. As a result, some FES agencies may store, use, and dispose of firefighting foam in a manner that according to similar agencies with protocols in place, places the environment, personnel, and if used in the vicinity, livestock at risk of exposure to PFAS. There exist numerous federal laws regarding agricultural pesticides that can cause various health and well-being illnesses and contamination to drinking water but, despite several actions by attorneys and organizations, no federal laws are in existence regarding certain chemicals such as those found in PFAS that cause similar or other health and well-being illnesses to include cancer as well as place drinking water at risk of contamination.
In a May 2019 article by John Hurdle, seventeen sites within Pennsylvania were found to be contaminated with PFAS such as the town of Horsham, a community located north of Philadelphia, where contamination levels reached 44ppt in 2014. For Horsham, because the contamination level was under the 70ppt threshold established by the EPA, recommendations for human health protection were suggested, not required (Hurdle, 2019). For many community members, they question at what point are human lives deemed important enough to warrant the reporting or banishment of harmful products, like those containing PFAS that are used within the community without their knowledge, only for them to learn of their existence when their health and well-being is compromised. By then, damage is already done, and recovery efforts may be too late. At what point did using products that minimize our time and efforts outweigh the health and safety of human lives?
It should be noted and somewhat alarming that despite having the authority to establish state MCLs, the Pennsylvania DEP states they are “not in a position to move forward with setting a state MCL at this time” (Pennsylvania Department of Environmental Protection, 2019). According to the Pennsylvania Safe Drinking Water Act, Section 4, paragraph (a), the Environmental Quality Board, shall adopt maximum contaminant levels and treatment technique requirements no less stringent than those promulgated under the Federal act for all contaminants regulated under the national primary and secondary drinking water regulations and that the board may adopt maximum contaminant levels or treatment technique requirements for any contaminant that a maximum contaminant level or treatment technique requirement has not been promulgated under the national primary and secondary drinking water regulations (Pennsylvania General Assembly, 1984).
In closing, an important question to ask is, what’s the future for communities that have or might have PFAS contamination? The process should begin with community members acting in a proactive manner by asking their local FES agencies if they have firefighting foam and if so, how are they storing, using, disposing of it as well as mitigating environmental and human exposure. Community members should ask for a tour of their local FES facilities and see firsthand what they are using and then, ask questions to determine if FES personnel are knowledgeable of the products they are using like AFFF. Asking for a tour should not be made to throw anyone under the bus and make the visit negative, rather it should be a learning opportunity for both the FES providers and the community members. Next, community members and leaders must come together by working diligently to create a task force, committee, or panel that will research, compile data, develop their own health limits for PFAS, and with the future in mind, create one of more course of actions (COAs) to ensure the community is well protected. Then as a collective, work intimately with their local, state, and federal government to enact policies or legislation that will ensure contamination, and exposure risks and hazards associated with firefighting foam are prevented and or mitigated. If this PFAS crisis is left to continue without community involvement, future generations will be responsible for undertaking what is already expected to be a massive cleanup operation to ensure their health and wellness is preserved. In a February 2019 report, Safer Chemicals states the DoD has already spent $200 million just to study and test for PFAS contamination and estimates that cleanup costs for 126 military installations will cost taxpayers $2 billion (Safer Chemicals, Healthy Families, 2019). Additionally, the report states the military has spent to date, $2.5 million on research and development (R&D) seeking a PFAS-free firefighting foam solution. The PFAS crisis is not going to heal itself and as such, we as inhabitants of what is considered an already fragile environment have an obligation to ensure future generations have clean drinking water. In this case, it’s broke so we must fix it by removing PFAS in drinking water.
References
Agency for Toxic Substances and Disease Registry. (2018, January 10). What are the Health Effects? Retrieved from Agency for Toxic Substances and Disease Registry: https://www.atsdr.cdc.gov/pfas/health-effects.html
Hurdle, J. (2019, May 6). PFAS Chemicals Have Contaminated 17 Sites in Pennsylvania, Data Shows. Retrieved from State Impact Pennsylvania: https://stateimpact.npr.org/pennsylvania/2019/05/06/pfas-chemicals-have-contaminated-17-sites-in-pennsylvania-data-shows/
Interstate Technology Regulatory Council (IRTC). (2018, October). Fact Sheets. Retrieved from PFAS – Per- and Polyfluoroalkyl Substances: https://pfas-1.itrcweb.org/wp-content/uploads/2019/03/pfas-fact-sheet-afff-10-3-18.pdf
Jönsson, D. J.-E. (2017). Fact Sheet on C6 Fluorinated Surfactants. Tyreso: Dafo FomtecAB.
Pennsylvania Department of Environmental Protection. (2019, October 27). State MCL Considerations. Retrieved from Pennsylvania Department of Environmental Protection: https://www.dep.pa.gov/Citizens/My-Water/drinking_water/Perfluorinated%20Chemicals%20%E2%80%93PFOA%20and%20PFOS%20%E2%80%93%20in%20Pennsylvania/Pages/Establishing-a-State-MCL.aspx
Pennsylvania General Assembly. (1984). Pennsylvania Safe Drinking Water Act. Harrisburg: Pennsylvania General Assembly.
Safer Chemicals, Healthy Families. (2019). Costs of PFAS Contamination – Safer States – February 2019. Washington D.C.: Safer Chemicals, Healthy Families.
United States Environmental Protection Agency. (2019, October 28). Basic Information on PFAS. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/pfas/basic-information-pfas
Vergun, D. (2019, September 18). Pentagon Official Provides Update on Work of Firefighting Foam Task Force. Retrieved from US Dept of Defense: https://www.defense.gov/explore/story/Article/1964686/pentagon-official-provides-update-on-work-of-firefighting-foam-task-force/
