New foam testing

Lastfire and Dallas/Fort Worth Airport are jointly embarking on the next phase of testing new-generation foams in October. Jose Sanchez de Muniain finds out more.

The planned tests at Dallas/Fort Worth Airport are based on the findings of previous work. They have beendesigned to test principles rather than to compare specific foams. (Photos: Lastfire and Gesip)

Two fluorine-free foams are to be tested on a large-scale fire using four different application methods at rates in accordance with NFPA 11.

The latest series of tests seek to answer some of the issues raised by extensive testing and research previously carried out by Lastfire (see IFJ Q1 2018 and IFJ Q3 2017).

Earlier work included a range of tests from small-scale through to large-scale bund and tank fires. These were

conducted with various fuels at critical application rates in accordance with recognised standards, such as NFPA, as well as using other application techniques and rates.

Earlier tests found that the new generation of fire-fighting foams, which include high-purity C6 foam and fluorine-free foam, provide a wide range of performance. The results suggested that it is not possible to make performance-based assumptions based on whether a foam is fluorine-free or high-purity C6, because both types extinguished fires in all the range of tests at rates equal to, or below, standard NFPA application rates.

The tests revealed some unexpected outcomes, such as that in some cases it seemed more difficult to extinguish Jet A1 fires than gasoline fires with some fluorine-free foams.

Other findings included that the use of a well-engineered and optimised CAF system, in the form of either a monitor or pourer, equalised the performance of different foams, suggesting that this system could be a highly efficient method of foam application for tank and spill incidents.

One major finding was that further testing of the flow capability over long distances of fluorine-free foams – and CAF-generated foam in particular – was required.

The protocols for the work with Dallas/Fort Worth Airport have been established based on this earlier work. The main tests planned for October will include two foams, both fluorine free, with one specifically formulated for spill fires and the other for tank-related incidents.

With a fire size measuring approximately 40m x 8m, the two foams will be tested using four application methods: conventional pourer, conventional monitor, CAF pourer and

26 < INDUSTRIAL FIRE JOURNAL < third quarter 2018 read our e-magazine at www.hemmingfire.com

foam

DFW Foam Summit 2018

The Summit will take place at the Dallas/Fort Worth International Airport’s Fire Training Research Centre on 16-18 October 2018. It will focus on balancing fire performance and environmental consequences and, as part of the event, a large-scale test of both C6 and fluorine-free foams is planned. The independently-managed event will also review the current situation related to selection, use, and management of firefighting foam, covering the current status and options for future foam policies concerning poly- and perfluoroalkyl substances. Scheduled speakers include Fay Purvis, past chair NFPA11 Foam Systems Committee, USA; Niall Ramsden, Lastfire coordinator, UK; Chief Brian McKinney, DFW Airport; Chief Randy Krause, SEATAC; Jaco Erasmus on behalf of Rod Rutledge, national process safety and regulatory advisor, Caltex Australia Petroleum; and Ian Ross, partner, global remediation, Arcadis. Dwight Williams is also due to give a presentation on some memories of large tank fires and the importance of getting foam performance right. To register, visit: https://lastfire.regfox.com/dfw-research-summit. For more information, email: info@lastfire.org.

CAF monitor, all at application rates in line with NFPA 11. Some of the tests have been introduced specifically to meet the needs of fixed systems being considered for 80m-diameter tanks.

In addition, a C6-based foam meeting the latest high-purity requirements will be tested with one application method as a comparison. The work will be supplemented at a later date with further tests involving other fuels and application methods.

According to Lastfire, the foams that have been chosen for the next round of tests were selected based mainly on the previous test results. This includes the results of proportioning tests that were carried out to determine the feasibility of using new generation foams with conventional proportioning systems while still achieving accurate pick-up rates. Niall Ramsden of Lastfire comments: “Lastfire would be pleased to test other foams at a future date in similar large-scale testing but the objective here is to test principles rather than compare specific foams.”

The tests are planned for 8–12 October and will be followed by a foam conference on 16-18 October (see box left). The conference, which is being organised in association with Arcadis and DFW, will cover the issues of whole-life foam assurance as well as including two demonstrations using a large fire pit.

No public immunity

Germany’s highest court of law has found a German fire service liable for AFFF used at an incident and has dismissed a claim of public-office immunity, reports Jose Sanchez de Muniain.

The judgement is in line with the principle that the polluter pays. (Shutterstock)

O n 14 June the German Federal Court of Justice in Karlsruhe, southwest Germany, ruled that the fire service of the city of Baden-Baden could not claim immunity from liability after using PFOS-containing foam during an emergency.

The judgement is the result of an eight-year legal battle between the owner of an industrial premises and the city of Baden-Baden. It is widely regarded as an important test case that will affect the fire service’s operations and its use of firefighting foam.

Sometime prior to 2010 the local fire service received a donation of old foam stocks from a chemical company on the Baden-Airpark industrial site. Without realising that it contained PFOS, the fire service used around 8,000 litres of this AFFF foam concentrate at an incident on 8 February 2010 involving a major fire that destroyed commercial warehousing and administrative buildings. As a result, the site in the district

of Sandweier became heavily contaminated with fluorochemicals.

Baden-Baden took landowner Claus Reformwaren to court for the remediation and clean-up costs in 2010, with court judgements in 2014 and 2017 finding against the landowner. However, the latest judgement from the highest court in Germany has unanimously reversed the previous ruling on the grounds that it was clearly faulty and incorrect.

The German Federal Court of Justice judgement dismissed the claim that the actions of the fire service incident commander were covered by immunity to liability (haftungsprivileg) because it was an emergency, but rather that their actions counted as contrary to the obligations of public office (amtspflichtwidrig).

The full court judgement* was clear in its denial of the appeal of the defendant, the city of Baden-Baden. It said that the lower court had correctly recognised that the decision of

28 < INDUSTRIAL FIRE JOURNAL < third quarter 2018 read our e-magazine at www.hemmingfire.com

the incident commander to use a PFOS-containing foam in order to prevent spread of the fire to an adjoining warehouse, represented a failure of judgement and was therefore a dereliction of duty in a public office, and that the incident commander had behaved negligently.

The judgement also ruled that neither the incident commander nor the defendant could claim immunity from liability in accordance with German Civil Code regulation §680 BGB (Security management).

Based on the requirements of the obligations of public office under §839 BGB (Liability in the case of official breach of duty), every degree of negligence establishes liability when public-office obligations are violated. This also applies in the case of an emergency incident and when ensuring protection against danger under public law. It also said that a reduction in the level of liability did not apply in such cases.

The judgment noted that office holders are obliged to respond professionally to an urgent danger and are typically prepared for the associated emergency situation; they are trained for this and can fall back on established procedures.

It said that the risk of a mistake by such emergency personnel was clearly smaller than for others involved by chance, and that public bodies with liability for public-office duty violations by their officers were better protected against the financial risks and costs associated with fire service incidents than private-sector emergency responders. The judgment noted that if a reduced level of liability were to be valid for all public danger protection as regards emergency situations, important areas of state business would be exempt from simple negligence. The judgement said that immunity from liability was neither compatible with the basic rules of

official liability nor was it necessary.

The clear message is that any degree of negligence by the incident commander nullifies any defence involving waiving liability in an emergency, removing immunity from liability or the award of civil damages, including the significant costs associated with environmental remediation.

The judgement is in line with the principle that the end-user – in this case the fire service and its employer the state of Baden-Baden – is responsible for the pollution caused and with the overarching environmental legal principle ‘the polluter pays’. Legal costs are estimated at around €1.9 million (US$2.2 million). Exact clean-up costs are unknown, but in January this year local reports quoted site remediation works, which include groundwater treatment, as amounting to €2 million (US$2.3 million) and rising.

*Bundesgerichtshof Karlsruhe (German Federal Court of Justice) 14 June 2018. “III ZR 54/17 Amtshaftung aufgrund Feuerwehreinsatzes bei Grosbrand” < http://juris. bundesgerichtshof.de/cgi-bin/rechtsprechung/document.py?Gericht=bgh&Art=pm& Datum=2018&nr=84457&pos=1&anz=106 >

Baden Baden is a spa town in Baden- Wurttemberg, southwest Germany. (Shutterstock)

Read our e-magazine at www.hemmingfire.com third quarter 2018 < INDUSTRIAL FIRE JOURNAL < 29

Risk contained

Once the liquidactivated carbon is pumped into the subsurface it coats the walls of the acquifer with a thin layer that stays in place for decades.

(Regenesis)

Innovative technology that stops a PFAS-contaminated plume from spreading beyond a site’s boundaries has shown its effectiveness at a facility in Canada where fire-fighting foam was used during training execises in the 1970s and 1980s, writes Jose Sanchez de Muniain.

Levels of PFOS and PFOA at the site decreased to lower than the method detection level in all the groundwater samples shortly after treatment using the colloidal activated carbon technology.

The technology that has been deployed in Canada is called Plume Stop. It has been developed by the California-based company Regenesis, a remediation company that operates along the same lines as the pharmaceuticals industry by identifying an environmental problem and then attempting to solve it from its laboratory in San Clemente.

Regenesis’ Plume Stop technology focuses on widespread low-concentration contaminant ‘plumes’ that have previously been considered impossible or impractical to treat. These sites often rely on hydraulic containment using ‘pump-and-treat’ systems or ‘monitored natural attenuation’, a passive approach whereby natural attenuation processes are relied upon to achieve site-specific remediation objectives over many years.

Plume Stop was first developed for dealing with contamination of chlorinated solvents and petroleum hydrocarbons, as found in a wide variety of sectors including manufacturing, petrochemical, and dry-cleaning industries. After a six-year development period, it was launched in the US in 2014 and in Europe in 2015. The technology has been deployed at over 150 sites across the world, including Volvo Car Gent in Belgium, the largest Volvo plant in terms of the

number of cars produced, where it is being used to deal with a range of contaminant plumes.

Plume Stop consists of the first true liquid form of activated carbon. Granular activated carbon is widely used for remediation in pump-and-treat systems, however it is too large to be injected into the subsurface. Regenesis has taken the approach to dramatically reduce the size of the carbon particles, which in the Regenesis solution are only one to two microns in diameter. Another key difference is that the small carbon particles are pre-treated with a coating that prevents them from clumping together. The end result is a suspension of particles, or colloidal liquid, very similar to ink.

This liquid-activated carbon is pumped into the subsurface, and as it travels, it coats the walls of the aquifer, whether sand or clay, with a thin 1-2 micron-thick layer that stays in place for decades. “What you are left with is an underground activated carbon filter,” says Gareth Leonard, managing director of Regenesis’ international arm. When a contaminant encounters the carbon particles, it is adsorbed and begins biological degradation. Once degraded, the carbon can then begin adsorbing further contaminants, hence the filter regenerates itself ‘in situ’.

Previous to its injection, a site is surveyed to locate the so-called flux zones, through which the groundwater carries the contamination. The application of the liquid-activated

30 < INDUSTRIAL FIRE JOURNAL < third quarter 2018 read our e-magazine at www.hemmingfire.com

carbon targets these flux zones by injecting through temporary points. “In terms of volume per point, you might apply approximately 1,000 litres per injection point, then you work across the site stitching these points in. You might do five or ten of these a day, depending on the site and the depth,” says Leonard.

Regarding PFAS treatment, the technology differs from traditional remediation in a number of ways. The standard pump-and-treat method requires drilling wells, installing pumps, running the water through activated carbon filters, and then disposal of the carbon filters through either landfill or incineration. “As PFAS plumes spread so readily in groundwater, the equipment required is on a very large scale. To put a line of pump-and-treat systems every 10m along a 1.5km of plume is very expensive. Moreover, it has to stay there for a long time, until the source of contamination runs out. The operation and maintenance costs are therefore huge and ongoing,” he points out.

Leonard is familiar with fire-fighting foam. Before his 15 years in the remediation industry, he worked offshore on oilrigs and trained with fire-fighting foam. One of his memories is walking across the shallow training tanks that had been extinguished with foam and watching the footprints created in the foam reigniting behind him.

A key aspect of Plume Stop is that it does not aim to destroy the contamination itself, but rather eliminate the risk posed by the PFAS. The treatment will stop the PFAS from advancing and thus remove the possibility of exposure to the contaminant. The approach can be applied over entire plumes, but is also flexible and can be targeted on problem areas. “If the plume is not causing a problem, but in one area it’s getting into a stream,

or drinking water, then we can inject around those areas and protect those receptors,” says Leonard.

Interestingly, the possibility of using Plume Stop for contaminants other than chlorinated solvents and hydrocarbons had not been considered by Regenesis until after its launch. “We didn’t think about PFAS at all during development. It was only when people started exploring what the product could do, that we started looking into whether it could adsorb PFOS and PFOA.”

When the company started carrying out laboratory tests using Plume Stop with PFOS and PFOA, it found that Plume Stop adsorbed them better than some of the typical chemicals it was already treating.

The installation of a Plume Stop barrier halts the advancement of PFAS. (Regenesis)

Read our e-magazine at www.hemmingfire.com third quarter 2018 < INDUSTRIAL FIRE JOURNAL < 31

PFOS/PFOA monitoring results of the well in Canada at 18 months after the injection of Plume Stop. (Regenesis)

The company then carried out some lab tests to see how Plume Stop performed against PFAS-containing shorter carbon chains, the result of a collaboration with a high-profile site in Italy. “We emulated two barriers by using serial batch tests. We took contaminated groundwater from the site and added Plume Stop, then agitated it for a period of time and analysed. We achieved a 98.5% reduction in the PFAS mass, with all of the large PFAS, such as PFOS and PFOA, being removed. Much of

the remaining contamination was PFBA, a very mobile PFAS compound that only has a four-carbon chain. We then took the treated water and ran it through a second batch test, emulating a second barrier and we achieved an overall 99% reduction, with 84% of the PFBA removed. So we absolutely can treat the shorter-chain carbon molecules, but as they aren’t as quick to adsorb you need more treatment, either using a wider barrier or multiple barriers.”

in-situ COMMERCIAL pfas remediation – A WORLD FIRST?

The project that alerted the world to the potential of liquid activated carbon for the remediation of PFAS contamination began in 2016 in Canada, with the results appearing this year in the paper, In situ treatment of PFAS-impacted groundwater using colloidal activated carbon, published by Remediation Journal. It was the first in-situ project carried out by Regenesis with PFAS, and it is believed to be the first commercial in-situ PFAS remediation project ever carried out in the world. The field study was carried out by hydrogeologist Rick McGregor of In Situ Remediation Services. The location in central Canada was a site where fire-training exercises using PFAS-containing foam had been conducted during the 1970s and 1980s, resulting in PFAS contamination in the shallow groundwater. Here, the PFOS and PFOA plumes were estimated to cover an area of 780m 2 and 700m 2 respectively, both extending from the surface of the water table, 0.9m below ground surface, to approximately 1.7m below ground surface. Prior to the treatment, wells in which PFOS had been detected had concentrations ranging from 280ng/l to 1,450ng/l, and wells in which PFOA had been detected had concentrations from 490ng/l to 3,260ng/l. A total of 290kg of Plume Stop liquid activated carbon and 176kg of oxygen-releasing material were mixed with 3,120 litres of water and injected into 20 temporary locations. The oxygen-releasing material was used to address the dissolved petroleum hydrocarbon compounds also present within the groundwater. Samples for PFOA, PFOS and 12 other PFAS-related compounds were analysed using liquid chromatography-mass spectrometry during the 18-month sampling event. Eighteen months after the injection, groundwater concentrations of PFOA and PFOS from samples collected from six monitoring wells were all below the method detection limits (MDLs) of 20 and 30ng/l for PFOA and PFOS, with the exception of one site with PFOS detected at 40ng/l in the groundwater. Groundwater samples for 12 other PFAS were also collected, representing a mixture of shorter carbon chain and longer carbonchain PFAS. Although the shorter carbon-chain PFASs were expected

to break through before the longer chain PFAS, all the PFAS were found to be below their respective MDLs, with the exception of perfluoroundecanoic acid, which was detected at 20ng/l. Encouraged by these results, Regenesis is currently involved with universities in Scandinavia, Italy and USA, and is working on potential projects in Australasia, USA and Europe. “Of course, I would like these sites to go ahead more quickly, however, you have to consider the scale of these issues,” says Leonard. The treatment process is not straightforward because each site is different, with different flux zones, contamination levels and ground conditions, all of which require a site-specific design, application method and product dosage. “We cannot take a design from the site in Canada and apply it to a different site in, say, Germany,” comments Leonard. Nevertheless, interest in the technology is high, as concerns are spreading around the world regarding PFAS. “It was probably only six years ago that this issue started showing its head," says Leonard. "Australia very much led the field and Scandinavia has woken up to it. It looks like the US will be taking this seriously, and once they begin enforcing regulation they will do a good job in ensuring sites are remediated.” Because of the attention, the company is expanding its traditional market of remediation in industrial sites and petrol refilling stations to airports, factories, fire-fighting training centres and chemical facilities. “The American EPA has suggested that six million people may be exposed to PFAS in their drinking water in the USA alone, so world-wide the scale is extraordinary.” For organisations that have used fire-fighting foam, the advantage of Plume Stop is its potential ability to eliminate possible subsequent liability, as Leonard explains. “If an airport has been using AFFF, the potential liability does not lie in human health on site because it doesn’t form vapours. It lies in the fact that PFAS is highly soluble in water and travels a long way through the groundwater. Therefore it will move outside the site boundary into the environment, creating an offsite liability for the polluter. You need to deal with the contamination going off site. You need to close that gate.”

32 < INDUSTRIAL FIRE JOURNAL < third quarter 2018 read our e-magazine at www.hemmingfire.com