Environmental Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (Afff) Products

Transcription

1 Environmental Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (Afff) Products Prepared for Defence Environmental Managers and Users Release Date: Jun 07 Release Authority: Directorate of Environmental Impact Management (DEIM)

2 Environmental Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (Afff) Products Prepared for Defence Environmental Managers and Users Release Date: Jun 07 Release Authority: Directorate of Environmental Impact Management (DEIM)

3 2

4 Contents 1 Executive Summary 4 2 Definitions 5 3 Quick Reference Guide for commonly used AFFF and other foam products 6 4 Key Information 8 5 Key Recommendations Procurement Storage Use Treatment/Disposal 9 6 Purpose 9 7 Background 9 8 Environmental results of the AFFF products in use 10 9 Regulatory requirements Responsibilities AFFF Management Process General Environmental requirements for Procurement of AFFF products Environmental requirements for Storage and Transport of AFFF products Environmental requirements for Fire Fighting/Emergency Environmental requirements for Class B Fire Fighting Training Environmental requirements for Testing & Flushing of Fire Fighting Vehicles, Equipment and Systems Environmental requirements for the purpose-built facility and supporting facility Environmental requirements for Transport, Treatment and Disposal of AFFF Wastes and Wastewater Environmental requirements for Maintenance/Replacement of test equipment, vehicles and systems Environmental requirements for Maintenance/Replacement of test facility and supporting facility Management of AFFF products/wastewater Decontamination of AFFF products Conclusions Contact 22 APPENDIX A - Consolidated results of the experiments on all three AFFF products 23

5 1. Executive Summary 4 The Aqueous Film Forming Foam (AFFF) products, complying with stringent performance specifications (DEF (Aust) 5706 or MIL Spec), have been used in Defence for decades as an efficient fire suppressing foam in protecting land based military assets, naval vessels and off-shore platforms from fire damage or destruction. Environmental concern was focussed to Light Water AFFF, supplied by 3M. Perfluorooctane sulphonate (PFOS) based surfactant was alleged to potentially cause significant environmental damage. Consequently, this product has now been phased out and its use restricted. Defence has a large stock pile of Light Water AFFF. Two new fire-suppressing products namely Ansulite and RF have been manufactured as an alternative to PFOS based AFFF product providing Defence similar performance criteria, but importantly reduced environmental risks. There are no other AFFF products available in the market that are suitable to meet Defence performance criteria. In order to derive a relative environmental risk ranking between these three products, Defence, in collaboration with the Cooperative Research Centre for Contamination Assessment and Remediation of the Environment (CRC CARE), conducted a range of environmental toxicity analyses, which formed the basis for a revamped AFFF management process. The research outcome shows that Ansulite products have the lowest environmental risk ranking, but all three AFFF products are environmentally toxic and persistent under normal operating conditions. They cannot be released into the environment. The results prompted the development of these AFFF guidelines, which propose improvements in the life-cycle management of AFFF in order to achieve a No Release AFFF management system. The guidelines provide best practice management guidance and environmental requirements in the key areas, viz, procurement; storage and transport; usage during emergency; usage during training and testing and calibration of systems; collection and containment of AFFF products and wastewater; design, maintenance and replacement of purpose-built and supporting facility; maintenance and replacement of equipment and systems in use; and reuse/treatment/disposal of AFFF wastewater. It is intended that these guidelines compliment any existing user documents on this subject prepared by Groups and Services, as well as Defence contractors, and should be implemented. Further research into the Ansulite product is being undertaken to better understand the risk parameters and the challenges so that appropriate management processes can be improved. The guidelines may be revised in the future when further research details are received. Defence also uses a range of other foam products with less stringent performance requirements for training, bush fire fighting and general fire fighting purposes for fighting both Class A and Class B fires. These products do not contain PFOS, but do contain other types of surfactants for which environmental risks are unknown. The determination of environmental risks for the training foams or other foams, including bush fire fighting foams are not included in the current investigation. However, until more details about the environmental risks of these products are known the users are encouraged to apply caution in dealing with these products. Alternatively, these guidelines may be adopted.

6 2. Definitions AFFF (Aqueous Film Forming Foam): is low expansion foam (20:1) which puts out fuel or hydrocarbon fires very efficiently, and complies with DEF (Aust) 5706 or MIL specifications. Bioaccumulation: refers to net accumulation over time of the persistent compounds (such as heavy metals or persistent organic compounds) within an organism originating from biotic or abiotic sources. Bioavailability: is the ability of a substance to be absorbed (such as environmental toxins) within a plant or an organism and to interact with its metabolism. Biodegradable: refers to decomposition of a substance under natural conditions, for example breakdown by naturally occurring micro-organisms. BOD (Biochemical Oxygen Demand): is a measure of how much oxygen is used up by bacteria and other micro-organisms over a stated period (generally 5 to 20 days). A lower value is desirable. Class A fire: is the fire resulting from combustible solid substances. Class B fire: is the fire resulting from hydrocarbon based fuels or solvents. COD (Chemical Oxygen Demand): is a measure of how much oxygen is required to change chemical to its most oxidisable state. A lower value is desirable. Ecosystem (terrestrial and aquatic): refers to independence upon and interaction between living organisms and their immediate physical, chemical and biological environment. Ecotoxicity: refers to any potential environmental impact on the Ecosystem by a toxic agent. EC50 (Effective Concentration 50): represents a statistically derived concentration of a toxicant that can be expected to cause a defined non-lethal effect exhibiting response in 50% of a given microbial activity under the given condition. A higher value is desirable. ICAO (International Civil Aviation Organisation): provides specifications for fighting Class B fires. LC50 (Lethal Concentration 50 relating to aquatic toxicity): where 50% of the population will survive at that concentration. A higher value is desirable. LD50 (Lethal Dose 50 relating to acute oral toxicity): where 50% of the population will survive at that dose. A higher value is desirable. MSDS: refers to Material Safety Data Sheet containing safety and safe handling information in respect of the product, including protection information regarding human health. Some MSDS may include information on protection of the environment. Persistence: is the length of time a substance stays within the environment, once introduced. This time will vary depending on if, and how readily, the substance can be broken down into other components. These components can also be toxic within the environment. PFOA (Perfluorooctanoic Acid): is used as fluoro alkyl surfactant, like PFOS, in some AFFF products. The AFFF products used in Defence do not contain any PFOA. PFOS (Perfluorooctane Sulfonate): is a fluoro alkyl surfactant known to have significant environmental toxicity and persistence, and has potential for bioavailability. 3M Light Water contains PFOS. Surfactant: is the detergent compound that promotes lathering. Surfactants could principally be fluorine-based or hydrocarbon-based. Surfactants in AFFF products are known to have significant environmental risks. Toxicity: the ability of a substance to cause death, disease or birth defects in plants and animals that ingest or absorb them. This can result in death when exposed beyond a critical concentration. Wastewater: Containing AFFF substances resulting from the use of AFFF products. 5

7 3. Quick Reference Guide for commonly used AFFF and other foam products 6 Relevant guideline Containment Disposal Lab/Field testing Fire Fighting foam Class - type of fire Contains PFOS Contains other surfactant Procurement Training use Normal Use Emergency use (UNISA field kit) (AFFF) (Methods of Disposal) (example) (Class B) (Yes) (No) (Choose highest EC50 value) (Trucks only) (Yes, hydrocarbon fires) (Yes hydrocarbon fires) (If not contained report to REO) UniSA AFFF Report, Nov, 2005; AFFF Report (2003); RAN AFFF, Accredited Laboratory; UniSA field kit. Ansulite AFFF 6% Class B No Yes LD50 No Testing and Flushing; and Calibration Air Crashes, Vehicle Fire, bldg fire etc. Natural attrition; Treatment Technology; Off-site disposal. If not contained report to REO UniSA AFFF Report, Nov, 2005; AFFF Report (2003) Natural attrition; Treatment Technology; Off-site disposal. Ansulite AFFF 3% Class B No Yes LD50 No Testing and Flushing; and Calibration Air Crashes, Vehicle Fire, bldg fire etc. If not contained report to REO Accredited Laboratory; UniSA field kit. RAN AFFF Policy Accredited Laboratory; UniSA field kit. Ansulite AFFF 3% (AFC-5-A) Class A & B No Yes LD50; LC50; and EC50 No Testing and Flushing; and Calibration Used by Navy for Vessels fire. Natural attrition; Treatment Technology; Off-site disposal. Contain where possible RAN AFFF Policy Accredited Laboratory; UniSA field kit. Ansulite AFFF Premium 6% (AFC-5) Class B No Yes Info not available. No Testing and Flushing; and Calibration RAN Offshore Natural attrition; Treatment Technology; Off-site disposal. Contain where possible Local Guidelines Accredited Laboratory; UniSA field kit. Ansul Training Foam - Formula Class A & B No Yes LC50; EC50; BOD, COD Yes Testing and Flushing; and Calibration No Natural attrition; Treatment Technology; Off-site disposal. If not contained report to REO

8 7 3M FC3155 Training Foam Concentrate Ansulite 6% AFFF AFC-3 Bushmaster A Class Foam NOWA AUSTRALIA, AFFF 6% 3M AFFF RF 6% Class A & B No Yes LC50; EC50; BOD, COD Yes Testing and Flushing; and Calibration No If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. 3M AFFF RF 3% Class A & B No Yes LD50; Surfactants Toxicity data not available Bushfire and other fire fighting Testing and Flushing; and Calibration Yes, bushfire If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. 3M AFFF Light Water 3% and 6% Class A No Yes Contains unknown surfactants up to 25% Bushfire and other fire fighting Testing and Flushing; and Calibration Yes, bushfire If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. Class A & B No Yes Info not available. Bushfire and other fire fighting Class B No Yes LD50 No Testing and Flushing; and Calibration Yes, bushfire If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. Class B No Yes LD50 No Class B Yes No Not to Procure Testing and Flushing; and Calibration Air Crashes, Vehicle Fire, bldg fire etc. If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. No; PFOS alert Testing and Flushing; and Calibration Testing and Flushing; and Calibration Air Crashes, Vehicle Fire, bldg fire etc. If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Accredited Laboratory; UniSA field kit. Air Crashes, Vehicle Fire, bldg fire etc. If not contained report to REO Natural attrition; Treatment Technology; Off-site disposal. Local Guidelines Local Guidelines Local Guidelines Local Guidelines UniSA AFFF Report, Nov, 2005; AFFF Report (2003) UniSA AFFF Report, Nov, 2005; AFFF Report (2003) UniSA AFFF Report, Nov, 2005; AFFF Report (2003) Accredited Laboratory; UniSA field kit.

9 8 4. Key Information The key information of these guidelines is: 4.1 Aqueous Film Forming Foam (AFFF), complying with DEF (Aust) 5706 and MIL specifications for Class B (hydrocarbon or fuel fires) fires, is the most efficient fire fighting foam to protect Defence assets. Defence uses the following foams: 3M Light Water, 3M RF and Ansulite products for the purpose. There are no other suppliers of AFFF products. 4.2 The training foams used in Defence for fire training purposes are: 3M Defence Training Foam or Ansul Training Foam Concentrate. Several other foams are used in Defence for bush fire and general fire fighting purposes (for Class A and B fires). 4.3 Surfactants used in the formulation of all of the above AFFF products are alleged to be non-biodegradable, environmentally persistent and toxic to animals and humans. Of most concern is perfluorooctane sulphonate (PFOS) surfactant contained in the 3M Light Water. 4.4 Defence has completed an environmental fate and behaviour study conducted by the CRC CARE using the above three AFFF products. The study found that all of these products have significant environmental risks arising from toxicity and persistence characteristics and require management to ensure neither the products nor its wastewater is released to the environment. 4.5 The guidelines have been based on the study findings and incorporate best management principles during its storage, usage and disposal stages of its operational cycle. The user of training foams and other foams will follow the local procedures or guidance. Where such guidance is not available, these guidelines may be adopted. 5. Key Recommendations The key recommendations in these guidelines are: 5.1 Procurement AFFF product must meet the performance criteria requirements of DEF (Aust) 5706 and MIL specifications for Class B (fuel or hydrocarbon fire) fire. To date, there are only three AFFF products that meet these criteria, viz, 3M Light Water, 3M RF, and Ansulite M Light Water must not be procured Amongst the remaining two AFFF products, procure the AFFF product with low toxicity and low persistence characteristics based on the test results of the study. Alternatively, a direct comparison of environmental data can be made from products specification, where available. 5.2 Storage AFFF products should be stored in a cool, bunded and roofed building to avoid rain ingress and away from hazardous substances or hazardous environment No material handling or decanting will be carried out in the stores area. The bunded stores area will have a containment facility to contain any inadvertent spills or leaks Stockpiled 3M Light Water products should not be moved to other Defence establishments or be transferred to another agency, without approval. 5.3 Use AFFF products are to be used exclusively for their intended purpose of fire fighting and for equipment and system testing purposes No AFFF products, including 3M Light Water, are to be used for fire training or any other purposes. Instead, appropriate foams should be used in those circumstances Only small volumes of AFFF wastewater are to be generated during testing and flushing of fire fighting equipment or systems. The testing cycles should be in accordance with the local operating procedures (currently set at monthly cycles for fire vehicles) Testing and flushing activities must be conducted in an appropriately designed facility, which should be well maintained.

10 5.3.5 Testing facilities/infrastructure should be maintained or replaced when needed. All wastewater generated from testing and flushing activities is to be contained and directed to a designated tank or a clay lined evaporation tank Do not direct AFFF wastewater to stormwater drains, vegetation, soil, wetlands, groundwater, and/or sewerage treatment plant. The opportunity for the reuse of wastewater should be considered, where practicable While fighting fire avoid spraying vegetation and/or soil During an emergency fire fighting operation, where total containment of wastewater may not be achieved, the incident should be reported to the relevant REO who may initiate further environmental action. The same will apply where inadvertent release of AFFF wastewater has occurred The use of 3M Light Water should be restricted to emergency fire fighting. No 3M Light Water will be used for training purposes. 5.4 Treatment/Disposal The wastewater from Ansulite or RF products held in a tank or in an evaporation pond may degrade in-situ and under normal conditions to a varying degree. At least 4-6 weeks of holding time may be required for any appreciable natural attrition to take effect. A rapid field test should be implemented to monitor the concentration of AFFF wastewater for quality purposes. The progress of natural attrition should be monitored and reported to the REO or Directorate of Environmental Impact Management (DEIM). The wastewater from Light Water is unlikely to degrade by natural attrition Defence establishments should develop suitable AFFF wastewater treatment technologies, where practicable, in consultation with DEIM, to reduce the final disposal cost Where a treatment option is available on-site, the AFFF wastewater may be treated directly, or after a suitable holding time of 4-6 weeks (see Para 5.4.1), to increase the treatment plant efficiency, provided the natural attrition has worked well The post-treated wastewater may be reused, recycled or used for irrigation purposes where it qualifies with the required criteria Where AFFF wastewater can not be treated on-site, a waste contractor should be engaged to dispose of the wastewater to an approved treatment facility. The waste contractor should submit the record of deposit transaction to Defence from an approved treatment facility Any surplus 3M Light Water stock should be disposed of using an accredited waste contractor. Where such action is not practical, the regions should propose an alternative disposal method for consideration by DEIM. 6. Purpose 6.1 To ensure that AFFF products are procured, used and disposed of in an environmentally sound manner. 6.2 To ensure environmental requirements associated with AFFF products are understood and adopted throughout Defence to avoid adverse environmental risks. 6.3 To implement best environmental management practice in the management of AFFF products consistently throughout Defence. 6.4 To provide appropriate environmental guidance to Defence personnel who are facilitating the management of AFFF products and the consultants and contractors assisting them. 7. Background 7.1 AFFF has been used in Defence as a fire suppressant to fight Class B fire for air crash rescue and hydrocarbon (fuel) fire for decades. In early 2000, it became clear that the 3M Light Water products, containing perfluorooctane Sulfonate (PFOS) surfactant, had considerable potential impacts on the environment, including aquatic species, and a ban on the manufacture of PFOS was imposed. 7.2 In April 2003, the National Industrial Chemical Notification and Assessment Scheme (NICNAS) issued a PFOS alert and advised that the use of AFFF products containing PFOS should be restricted and the same should not be used for training purposes. 9

11 In May 2003, an internal Defence AFFF study 1 was carried out on environmental issues associated with the use of AFFF products to alert the users of the environmental risks. 7.4 AFFF products containing PFOS have recently been phased out. However, Defence holds a large stockpile of Light Water, which cannot be returned to the supplier. 7.5 Two new fire-suppressing products namely Ansulite and RF have been manufactured as an alternative to PFOS-based AFFF, and sold to Defence based on similar performance criteria, but with reduced risk to the environment. There are no other AFFF products available in the market that are suitable to meet Defence performance criteria. 7.6 The environmental toxicity data of these new AFFF products was not available from the published MSDS, nor was the supplier able to provide the required environmental data. 7.7 In order to derive a relative environmental risk ranking between these three products, Defence, in collaboration with the Cooperative Research Centre for Contamination Assessment and Remediation of the Environment (CRC CARE), conducted a range of environmental toxicity analyses, which latter formed the basis of a revamped AFFF management process, captured in these guidelines. 7.8 The research program, in collaboration with CRC CARE, included a scientific study 2 on three AFFF products currently in use, viz, Ansulite (3% and 6%), 3M RF (3% and 6%) products, and the 3M Light Water AFFF (6% only), as a basis, to determine the environmental risks. 7.9 The Royal Australian Navy (RAN) had been trialling other high performance AFFF products Alcohol resistant and protein based foams for vessel fires. Recently, RAN has used Ansulite Premium 6% (AFC-5) and (AFC - 5A) and also Ansulite 6% (AFC-3) AFFF concentrate. All of these trial results are expected to be included in the future RAN AFFF policy Several other foams are available on the market from a multitude of suppliers for fire fighting training, bush fire and general fire fighting purposes and are used in Defence. These foams do not contain PFOS surfactant, but the environmental risks associated with the surfactants used in these products are not known. The environmental data supplied in their respective MSDS is often inadequate. A quick reference life-cycle use guide for a range of commonly used AFFF and other foams is provided in Section 3 table The guidelines presented in this document are based on the environmental research data received to date and the guidelines cover management requirements of these three AFFF products. It is intended that these guidelines would compliment existing user documents on this subject prepared by Groups and Services, as well as Defence contractors. The guidelines should be implemented. DEIM reserves the right to update the guidelines in the future, based on any new information derived during further investigation The determination of environmental data for the fire fighting training foams or other foams, including bush fire fighting foams, are not included in the current investigation. However, until more details about the environmental risks of these products are known, the users are encouraged to apply caution in dealing with these products. Alternatively, these guidelines may be adopted. 8. Environmental results of the AFFF products in use 8.1 The CRC CARE study (2005) found all three AFFF products, as concentrate, or, as wastewater, are toxic and persistent in the environment and are unsuitable for release into soil, groundwater, stormwater drains, wetlands and water courses or sewage treatment plant. 8.2 The study has also compared the risks of 3M RF and Ansulite products together with the 3M Light Water 6% concentrate. The summary of results of the study on all three AFFF products is provided in Appendix A. 1 Environmental issues associated with Defence use of Aqueous Film Forming Foam (AFFF) by Sonia Colville and Nicole McCarron, Environmental Stewardship, EH&R Branch, CSIG, May Environmental Fate of New Fire Suppressing Products (Ansulite AFFF & 3M RF) compared to Light Water: A verification of Manufacturer s claims by University of South Australia, 2005 (CRC CARE study (2005)).

12 The key results are presented below: The environmental toxicity and persistence of 3M Light Water, 3M RF and Ansulite products are comparable and are mostly influenced by the type of the surfactants, emulsifiers, and modifiers used in each product, and its weight percentage. Surfactants are the detergent compound that promotes lathering. In Ansulite the surfactants are fluorine-based, whereas in 3M RF, the surfactants are hydrocarbonbased. 3M Light Water ranked highest in environmental persistency criterion. However, in regards to environmental toxicity, the 3M RF products ranked highest. The Ansulite products performed better in both environmental persistency and toxicity criteria in relative terms. The relative persistence ranking from highest to lowest is as follows: 3M Light Water >3M RF > Ansulite. The relative toxicity ranking from highest to lowest is as follows: 3M RF >3M Light Water >Ansulite. The 3M Light Water also showed some bioaccumulation characteristics. While Ansulite products would appear to be the best option so far on the basis of the study (2005), further investigations of Ansulite AFFF products are in progress to understand the risk parameters and the true nature of the environmental risks so that appropriate management practice can be further developed and adopted. 9. Regulatory requirements 9.1 There are no established regulatory control measures in place for these products. Hence, the management processes and practices relating to AFFF products have grown, to some extent unsystematically, without any environmental considerations. These guidelines are intended to correct the current situation and apply consistently the best known scientific principles in the management of AFFF products throughout Defence. These guidelines are to be treated as Defence policy and should be implemented. 9.2 Based on the current study, all three AFFF products are now to be treated as hazardous substances from the environmental management point of view. Release of these products in the environment in any form is not permitted. The guidelines below stipulate how these AFFF products should be managed to minimise/eliminate the environmental risks. 9.3 The EPBC Act 1999 may trigger where AFFF products have caused significant environmental damage to soil, groundwater or biota, affecting sensitive species. Defence is required to exercise its environmental obligation in a proactive manner. 9.4 All AFFF products must also meet and be used in accordance with the requirements of the OH&S (CE) Act 1991 and the corresponding Regulations, SAFETYMAN and Defence OH&S Policy. 10. Responsibilities 10.1 The key personnel involved in the management of AFFF products are: Regional Managers of Defence Support Group (DSG) - responsible for the overall life cycle management of AFFF products and the provision of appropriate training facilities and testing facilities within their respective regional jurisdictions; Respective Group managers and Services commanders - responsible for ensuring that the operational readiness for fighting Class A and B fires are maintained at the highest level and the fire fighting equipment and systems are tested and calibrated on a regular basis to support operational readiness; Defence Materiel Organisation (DMO) procurement staff - responsible for the procurement of major fire fighting equipment, vehicles and accessories and AFFF products, incorporating environmental considerations; Defence contract administrators (CA) - responsible for ensuring that the requirements for carrying out fire fighting services, including testing of fire fighting vehicles, portable and fixed equipment and systems and any other tasks are clearly specified in the contract, incorporating all environmental requirements described in these guidelines. The CA ensures that the contractors are able to provide Defence accurate information about the logistics of all AFFF wastes, when requested, especially when the AFFF wastewater is disposed of off-site; 11

13 12 Defence fire fighting personnel, or contractors - responsible for conducting fire fighting and training duties and are also responsible for developing and maintaining procedures for testing of equipment and vehicles. Defence fire fighting personnel and contractors maintain records/details of the AFFF wastes logistics, and ensure waste contractors for AFFF waste disposal produce evidence of disposal of AFFF wastes when requested to do so. The contractors are also responsible for their sub-contractors, where they are engaged; DEIM - responsible, as the sponsor of this document, for developing guidelines and policy regarding the management of AFFF products. The SEAs and REOs are responsible for providing environmental advice on the management of AFFF products in their respective regions. Directorate of Design Acceptance (DDA) - responsible for developing Fire Protection Engineering policy and maintaining the currency of the Manual for Fire Protection Engineering (Chapter 15 of MFPE lists some generic environmental guidance on AFFF products) and also for the provision of fire safety engineering advice; Regional Fire Safety Officers provide advice on Regional issues; Australian Defence Force (ADF) Logistics Section Fire Vehicles (DMO) - responsible for developing Fire Vehicles policy, specifications and setting the fire vehicles testing frequency; and Director General Occupational Health, Safety and Compensation (DGOHSC) and Defence Health Services (DHS) - responsible for the provision of occupational health and safety policy issues associated with AFFF products. Regional OH&S coordinators are responsible for providing OH&S advice. 11. AFFF Management Process 11.1 General The AFFF product for Defence use will meet DEF (Aust) 5706 and MIL specifications or ICAO B specifications and not contain any PFOS or PFOA substances in the formulation The OH&S requirements for the product are detailed in the accompanying Material Safety Data Sheet (MSDS) of the product. Any OH&S issue associated with the product should be referred to Regional OH&S coordinator, or DGOHSC or DHS The principal activities and supporting infrastructure associated with the AFFF products include: Procurement; Storage and transport; Fighting Class B (hydrocarbon or fuel fire) fire in emergency situation, viz, air crashes, crash rescue, vehicle fire etc, or in fire fighting training sessions; Testing of fixed equipment and systems, viz, hangers, fuel farm etc; Testing of fire vehicles and equipment; Testing of portable equipment, viz, extinguisher; Purpose-built test and training facility; Separation and containment of AFFF wastewater; Transport, treatment, and disposal of AFFF wastes and wastewater; Maintenance/Replacement of test equipment, vehicles and systems; and Maintenance/Replacement of testing and training facility and supporting plants, equipment and infrastructure AFFF products need to be procured in accordance with the environmental requirements presented in Section 11.2 below AFFF products are to be stored and transported in accordance with the environmental requirements presented in Section 11.3 below.

14 The environmental requirements for fighting Class B fire in emergency situation are described in Section 11.4 below. The environmental requirements for Class B fire fighting training are presented in Section 11.5 below The testing and maintaining the fire fighting equipment and systems are to be kept in best order to avoid spills, leaks and environmental incidents. The testing of vehicles, fixed and portable equipment should be performed onsite or off-site, as necessary, in accordance with the established procedures in the regions. The environmental requirements for testing and flushing of fire fighting vehicles, equipment and systems are presented in Section 11.6 below The users of AFFF products must ensure that all non-emergency tasks, including fire fighting training, are performed in a purposebuilt facility with dedicated AFFF/wastewater separation system and foam retaining wall, and containment systems, so that the release AFFF products from its use into the environment are minimised. The environmental requirements for the purpose-built facility and the supporting plants, equipment and infrastructure are discussed in Section 11.7 below AFFF wastes and the wastewater may then be pumped or transported to holding areas for treatment or disposal off-site. The environmental requirements for transport, treatment or disposal are presented in Section 11.8 below The environmental requirements for the maintenance/replacement of test equipment, vehicles and systems are presented in Section 11.9 below Finally, the environmental requirements for the maintenance/replacement of testing and training facility and supporting plants, equipment and infrastructure are presented in Section below. Section 12 provides details on environmental requirements regarding management of AFFF wastewater Environmental requirements for Procurement of AFFF products The environmental data for AFFF products is scarce. The product MSDS carries some environmental information, but more detailed environmental data on the toxicity and persistence characteristics of a range of surfactants, emulsifiers and modifiers used in the formulation of the AFFF products are needed for an appropriate assessment. So far, the suppliers are not obliged to fully disclose the environmental data of their product, especially the surfactants, emulsifiers and modifiers etc. Even though these components only appear in small percentages, research has shown that they contribute significantly to the overall environmental toxicity and persistence of the product. The procurement staff should take note of this situation and insist that a full environmental data disclosure, as a mandatory requirement, is incorporated into their procurement contract with suppliers The environmental criteria for procurement of AFFF products have been developed based on the information that can be found in a typical AFFF product MSDS: The procurement staff will review the supplier provided product information or MSDS, and focus on surfactants and its corresponding environmental toxicological data/information; The types of surfactants in the AFFF product may be comprised of nonfluorinated or fluorinated compounds, and both types are acceptable, but they must not contain any Perfluorooctane Sulfonate (PFOS) surfactant; The environmental toxicological data of the surfactants may be expressed as EC50 (microbial toxicity) or LC50 (aquatic toxicity) or LD50 (acute oral toxicity) value format for each surfactant composition in the product. Select the product that has the highest EC50 value or LC50 value or LD50 value. Where the environmental toxicological data for the surfactants are expressed in BOD or COD format, select the product which has lowest value. 13

15 Where environmental data is insufficient or not supplied, the procurement staff will seek further information from the supplier The AFFF product for use in maritime platforms or vessels may have different formulations and specifications and the Defence procurement staff may be required to comply with the RAN AFFF policy Defence training foams and other foams will have different formulations and specifications and the Defence procurement staff or its contractors may adopt the above environmental criteria for selecting those foams Environmental requirements for Storage and Transport of AFFF products AFFF products should be supplied in sturdy sealed containers. Broken seals on the container may reduce its shelf life. Care should be taken to ensure that the containers do not leak or spill during transport. All AFFF containers and extinguishers are to be stored appropriately in a bunded and roofed store house to avoid rain ingress or weather damage. The AFFF storage area should be away from incompatible hazardous substances or hazardous environment, including electrical devices Decanting AFFF products is not permitted in the storage area Leaking containers must be replaced promptly or placed within a clean container and sealed. Any spills or wastes that may be generated shall be soaked with an inert soaking material such as saw dust or vermiculite and disposed of in accordance with Section Empty containers should be disposed of by similar means. AFFF wastes must not be mixed with other wastes Where a large stock of 3M Light Water is held, the line management may either dispose of it in accordance with Section 11.8 or continue to use it for emergency use only. The excess stock of 3M Light Water products must not be distributed to other Defence establishments thereby avoiding the generation of future legacy sites Environmental requirements for Fire Fighting/Emergency In the event of fire fighting or during an inadvertent release of a large quantity of AFFF product, the spill may find its way onto soil or into the ground or a creek, river, lake or harbour. If this happens, the location details and the approximate quantity and type of AFFF released must be reported immediately to the line management and/or relevant REO/SEA who may initiate an emergency action. DEIM may be consulted for policy advice, when required. Possible responses may include: an emergency environmental action plan to protect the environment. The procedure for dealing with large spill is described in Section 13; assessment of the potential environmental impact of the released AFFF product on any terrestrial and/or aquatic flora and fauna; and development of a monitoring program or remediation action plan, as required Environmental requirements for Class B Fire Fighting Training The training foams used in Defence for fire training purposes are: 3M Defence Training Foam or Ansul Training Foam Concentrate. Restrictions will apply to the use of any other types of foams for the purpose. Neither 3M Light Water nor 3M RF and Ansulite AFFF products are to be used for Defence fire fighting training purposes Fire fighting training on a mock up building/ structure is to be conducted in a purpose-built facility. Similarly, all Class B (hydrocarbon or fuel fires) fire training must be conducted using appropriate facilities. The purpose-built facility or appropriate facility will incorporate a foam/ water separation system, foam retaining wall and containment system, which directs the flow into a holding tank or evaporation pond for either reuse or recycling of the wastewater or for ultimate disposal (see Section 11.8).

16 Where a purpose-built facility is not available, or where the facility is unusable for maintenance reasons or unable to contain the wastewater (either design problems or large cracks rendering containment of wastewater difficult), the training activity should cease and Section should be initiated Some precautionary environmental measures apply, but are not limited to: Training shall be planned for, and conducted during periods of no rainfall; Spraying shall be confined to the target area and at no time shall the foam be sprayed over a large area such as a 180 degree arc; Spraying of foam occurs on hardstand areas only and spraying on vegetation or soil is not permitted; Fire fighting equipment and facility should be maintained in good order. Refer Sections 11.9 and 11.10; The volume of water generated from the flushing of fire fighting equipment, and the washing of the hardstand and wall area of the training facility at the end of the training shall be kept to a minimum; All solid particulate and fuel (where applicable) should be separated from the foam/wastewater mix and disposed of as hazardous waste (see Section 11.8). The wastewater shall be contained; All personnel conducting the fire fighting training shall be aware of their environmental obligations and make every effort to ensure that foam substances are contained and thus assist in protecting the environment. The REO shall be consulted where necessary for further advice; and Training procedures and processes shall be reviewed periodically in line with the changing environmental requirements in consultation with the REO Environmental requirements for Testing & Flushing of Fire Fighting Vehicles, Equipment and Systems Defence personnel as well as contractors may be involved in the testing of fire fighting vehicles, equipment and systems for operational effectiveness. The types of vehicles, equipment and systems used may vary from region to region. So too, the testing cycles and schedules and the responsibility for testing may vary. Given these variables, it is appropriate that environmental requirements are presented with broader applicability. The SEA/REO can provide further site specific environmental advice when required The environmental requirements are that: The majority of the testing program should be planned and conducted using plain water, as far as practicable. This water may be recycled or reused for other purposes, but it is not to be mixed with AFFF wastewater; The AFFF product, in place of water, should only be used when it is essential, such as proportionality testing; The testing and flushing should not be conducted during periods of rainfall; The testing of vehicles and portable fire fighting equipment should be conducted in a purpose-built facility and the volume of generated foam should be kept to a minimum. The testing of fixed systems in the hangers or fuel farms should use water as a testing medium. The AFFF product will only be used when essential and the volume of the generated foam should be kept to a minimum. The fixed systems should be appropriately designed to separate, collect and contain the wastewater in a dedicated tank or an evaporation pond for storage until ready for disposal, as a hazardous waste (See Section 11.8); Similarly, portable equipment, such as extinguishers should be inspected or emptied/recharged on-site in the same purpose built area. Alternatively, the extinguishers should be emptied/recharged off-site; 15

17 16 Any solid waste resulting from foam/ wastewater separator should be disposed of as a hazardous waste (See Section 11.8); Decanting AFFF product from AFFF storage containers is to be carried out within a purpose-built facility or in the same facility to ensure no spills are released into the environment; The purpose-built facility (see Section 11.7) must be appropriately designed to direct the flow into the AFFF/wastewater separator, and be collected and contained in a dedicated tank or an evaporation pond for storage until ready for disposal (See Section 11.8); The flushing of tested fire fighting vehicles, equipment, and systems should be carried out within the purpose-built facility, using water. The volume of the generated rinsed wastewater should be kept to a minimum. It should be noted that the AFFF wastewater generated by testing and flushing could be of a significant volume. To keep the wastewater treatment costs or off-site disposal costs down (charges paid on the basis of volume), the volume of flushing should be tightly controlled. The volume of wastewater generated through testing and flushing is not to be diluted by mixing the AFFF wastewater with the plain water collected from the initial testing. Minimising the volume of wastewater is consistent with Defence s Waste Management and Minimisation Strategy; All personnel conducting the AFFF testing and flushing shall be aware of their environmental obligations and make every effort to ensure that AFFF substances are contained. The REO shall be consulted where necessary for further advice; and Where a purpose-built facility is not available, or where the facility is unusable for maintenance reasons or unable to contain the wastewater (either design problems or large cracks rendering containment of wastewater difficult), the testing and flushing activity should either cease or be conducted on hardstand areas provided that all wastewater generated is contained, and the requirements of Sections 11.8, 11.9 and are followed, as appropriate Environmental requirements for the purpose-built facility and supporting facility Purpose-built facility for Hangers and Fuel farms A purpose-built facility for hangers and fuel farms (for static systems) will include, as a minimum, a fully covered hardstand area (free of cracks and crevices) in a roofed hanger or facility, with static pop-up foam ejecting nozzles. An Annex facility will be designed to pump water or AFFF product for periodic testing of the functionality of the whole system as well as proportionality testing. The facility should be designed in a manner to collect and contain the foam/water, as a no release (closed) system. Purpose-built facility for Testing of Fire fighting equipment, Vehicles, Extinguishers and Decantation The plants, equipment and infrastructure associated with the purpose-built facility where testing of fire fighting equipment, vehicles, extinguishers, and decanting AFFF products occurs, will have different design features as distinct from the static systems design. This facility will: be designed with a hardstand area, surrounded by foam retaining walls without any gaps to contain at least 180 O arc of spraying of the foam by hand held nozzles; have bunding to fully contain foam/ wastewater, but should be able to divert rain water from the AFFF wastewater. The hardstand area and the walls should be large enough and be capable of conducting testing of vehicles and other mobile fire fighting equipment or extinguishers, and must be free of cracks or crevices; have a hardstand area installed on a HDPE layer supported by an impervious clay layer to avoid direct seepage of AFFF products into the soil, or groundwater and the facility should be placed away from stormwater drain or shallow water table; where the purpose-built facility does not have a roof, the testing and flushing of equipment, inspection or refilling of extinguishers and decanting AFFF from one container to another will not be conducted during periods of rainfall.

18 allow rainwater runoff from the hardstand area, diverted for recycling purposes during non-activity periods, but it must not be mixed with the AFFF wastewater; be designed in a manner to collect and contain the foam/water, as a no release (closed) system; be designed for fuel fire training use and the foam/water separator will be designed to capture any escaping fuel in the foam/ water; and be designed to accommodate decanting. All decanting of AFFF will be carried out within the facility. Supporting Facility The environmental requirements for supporting plants, equipment and infrastructure are common to both types of purpose-built facilities described above. Opportunities for integration of these common services may be feasible where the facilities are in close proximity. The following environmental requirements will apply for these common services: The foam/wastewater separator will be designed with appropriate capacity to avoid overflow from the flow channels and the residence time through the separator will be rated sufficiently to allow full coalescence of the foam; The separator will also have the ability to remove solid sludge from the separator periodically; Separated wastewater may be allowed to gravitate to a dedicated tank or an evaporation pond for storage of the wastewater. Where the separated wastewater is directed to a sump, consideration should be given to its integrity for the purpose and its capacity to hold wastewater without overflow. The pump for the wastewater from the sump should be sized and rated correctly and will be designed adequately to transfer the wastewater to a dedicated tank or an evaporation pond; The dedicated tank storage facility (above ground preferred) will hold at least the volume of wastewater generated from 6 weeks of operation plus the volume of wastewater that may be generated from any overspills. The tank will be covered to avoid rain ingress. The tank will be suitably coated internally to prevent corrosion, and accessible for periodic cleaning and sludge collection. The tank will be fitted with a dedicated pump (appropriately sized and rated) to transfer wastewater from the tank to a wastewater treatment plant on-site or to a disposal truck for disposal off-site; The wastewater stored in a tank resulting especially from 3M Light Water will have a gas venting arrangement to release any H 2 S gas that may be generated through the natural breakdown process. The emission level of H 2 S gas will be monitored periodically; The evaporation pond will be designated for the purpose and designed with sufficient capacity to capture any overspill as well as any rain ingress (in the case of an open pond). No stormwater will be directed to the evaporation pond; The evaporation pond will be made inaccessible for swimming and/or drinking by terrestrial fauna or birds; The evaporation pond will have a HDPE layer supported by impervious clay layer to avoid direct seepage of AFFF products into the soil, or groundwater and the pond should be placed away from the stormwater drain or shallow water table; The pond will have a sludge collection system for removal of sludge periodically. The sludge or any other particulate solid collected from the AFFF process will be disposed of off-site (see Section ); and The facility should effectively be a closed system. The designer will ensure that the wastewater will not be released into the stormwater drain or the environment under any circumstances. 17

19 Environmental requirements for Transport, Treatment and Disposal of AFFF Wastes and Wastewater AFFF products or wastewater are corrosive in nature and should be secured appropriately during transportation to avoid spills and leaks In regard to the development of treatment options for AFFF wastewater, the following environmental criteria will apply: The plant and equipment used in the treatment operation will be of sufficient capacity and must be adequately designed to ensure the outflow wastewater quality meets the State/Territory requirements for discharge of wastewater in the environment; A rapid field test methodology will be applied to check the quality of the outflow periodically for compliance and results are recorded for future reference; Non-compliant wastewater must not be discharged into the environment, but should be retreated; Any spills or leaks should be promptly collected, contained and treated; The treatment operation will be a closed system and should be devoid of any gas emissions or particulate solids; and Any solid wastes generated by the plant must be disposed of appropriately. See Section and below Where the post-treated wastewater appears to be of very high quality. The outflow may not be directed to the STP on-site. Instead, it may be reused, recycled or used for irrigation purposes where it meets the required criteria Where the treatment option is unavailable, the degradation process of AFFF by naturally available microbes will be followed (See Section 12.4). Alternatively, an accredited trade waste disposal contractor shall be engaged to dispose of the wastewater off-site as hazardous liquid to an authorised State/Territory liquid effluent treatment centre or wastewater treatment centre. The contractor will submit, periodically, the details of the quantity of the wastes, where the wastes have been deposited and a formal acceptance receipt of the wastes from the receiver Any solid wastes generated from any of the previous activities or operation should also be disposed of as hazardous solid by an accredited trade waste disposal contractor. The contractor will submit, periodically, the details of the waste transferred to a receiving establishment, as stated in Paragraph above Environmental requirements for Maintenance/Replacement of test equipment, vehicles and systems The environmental requirements for the fire fighting test equipment, vehicles and systems generally coincide with the operational requirements and the user will adopt the following criteria, as a minimum, to achieve the necessary environmental requirements: All fire fighting assets are to be inspected and audited periodically; A preventative maintenance schedule should be in place and the risks established from the failure records/history or maintenance records; Spare equipment or components or inventory shall be kept for those critical components where failure rates are high; Where defects have been noted, the piece of equipment will be taken off-line and the repair/maintenance request should be placed with the CMS contractors; Where the repair/maintenance work is carried out on-site, all solid or liquid wastes arising from repair or maintenance should be appropriately classified in accordance with the State/Territory prescribed system and if these wastes are classified as hazardous wastes, the disposal action will be made in accordance with Sections and ; Repair records are to be kept for failure mode analysis and the repaired items should be certified before brought on-line; 3 Federal Office of Road Safety, Australian Code for the Transport of Dangerous Goods by Road and Rail, 6th Edition, AusInfo, Canberra, September Guidelines for Sewerage Systems, Use of Reclaimed Water, Vol 14, November 2000 by ARMCANZ, ANZECC and NHMRC.

20 Where fire fighting assets have reached the end of their useful life or where maintenance costs are increasing significantly, replacement options should be considered; The replacement of fire fighting assets may be raised by proponents through the DMO capital equipment procurement program for respective Groups and Services and will include state-of-the-art technology with due considerations of the environmental requirements, and less routine maintenance and calibration requirements. Where equipment replacement action also requires new infrastructure, Defence Infrastructure Management process for new infrastructure is to be followed. See Section for details; and Where disposal of old test equipment, vehicles and systems is required to allow for the installation of new items, the DMO and DEIM shall be consulted in the development of environmentally suitable disposal options Environmental requirements for Maintenance/ Replacement of test facility and supporting facility In order to support fire fighting operational requirements and operational effectiveness, a range of appropriate supporting facilities are required to be kept in good working condition. Any weakness associated with the supporting facility, plant and equipment can lead to release of AFFF products The environmental best practice principles will include, as a minimum, the following considerations: Adequate maintenance of storage, collection, containment, treatment and disposal systems shall be provided to ensure that AFFF products and its wastewater are prevented from entering into on-site or off-site stormwater systems, soil or groundwater, or water courses; The integrity of the foam retaining walls, hardstand area, flow channels, foam/water separator, containment tanks, pumps, etc should be inspected periodically and maintained in best working order; Evaporation ponds shall be checked for integrity or other damage. All problems must be raised and resolved with line management or the REO, as promptly as possible; The test facility and the supporting facility shall be audited periodically; Where defects have been noted, a work requisition for repair/maintenance should be placed with the CMS contractors (the procedures are detailed in Infrastructure Management Web page); A preventative maintenance schedule should be in place and a rolling program of repair/maintenance for the test facility and/ or supporting facility will be submitted by the users to Regional Infrastructure Planning Officers for consideration; The users will keep maintenance records for future reference; Where the repair/maintenance work is carried out on-site, all solid or liquid wastes arising from repair or maintenance should be appropriately classified in accordance with the State/Territory prescribed system. If these wastes are classified as hazardous wastes, the disposal action will be in accordance with Sections and ; Where test or supporting facilities have reached the end of their useful life or where maintenance costs are increasing significantly, or where such facilities do not exist or only exists in part, urgent replacement options shall be considered; The replacement of fire fighting test and supporting facilities or new facilities will be initiated by the Regional DSG office or by the respective Groups or Services identifying the needs with due considerations of the environmental requirements. The procedure for replacement or new fire fighting test or supporting facility will follow the Corporate 19