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Mitigating PFAS Cross-Contamination During AFFF Replacement Projects

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Tetra Tech’s David Fulton shares potential advances in firefighting systems per- and polyfluoroalkyl substances (PFAS) decontamination strategies using Tetra Tech’s PFAScrub™ cleaning agent coupled with sound program development and performance verification.

Recognizing the impact from legacy PFAS

Many firefighting foam users will be transitioning away from aqueous film forming foam (AFFF) containing PFAS, due to environmental, human health, and regulatory risks. A successful transition program recognizes that simply draining the old foam and replacing it with a new foam can result in cross-contamination with residual or legacy PFAS, leading to future environmental liabilities.

PFAS adheres to surfaces by forming multiple layers on interior piping and equipment, which means the interior of fire suppression systems can be coated with a significant mass of PFAS that will eventually rebound into the replacement foam. This cross-contamination effect will potentially negate the benefit of transitioning to a PFAS-free foam and could result in decades of environmental cleanup if released into the environment. Traditional approaches of flushing the system with water have only had limited effectiveness and generate large volumes of rinsate that require management and disposal.

Decontaminating retained equipment prior to transitioning to a new foam is the best way to prevent legacy PFAS cross-contamination.

Five steps to a successful transition program

An effective foam transition strategy involves the following five steps to mitigate the potential for long-term environmental liabilities:

Step 1: Take a step back and reassess the fire risk hazards and scenarios, and don’t assume it is simply a replacement-in-kind. Determine whether any fire suppression system modifications are required and what technology advancements may present viable options to consider. Federal and commercial entities are reevaluating fire risk and moving towards using water-based versus foam-based systems in lower risk areas.

Step 2: Evaluate multiple fire suppression strategies, such as system types, maintenance obligations, and secondary containment requirements, then balance the capital expense against the associated risk reduction potential.

Step 3: Conduct a thorough assessment of market-available, fluorine-free replacement foams that are green certified with all compounds labeled as biodegradable. Supply chain availability and demand from limited suppliers should also be considered.

Step 4: Reassess necessary operational, procedural, and maintenance changes, including any emerging regulations and potential regulatory reporting that might be required with new foams, or new systems.

Step 5: Implement a pre-transition decontamination program using a cleaning agent, such as PFAScrub™, combined with our associated cleaning methodologies, with performance verification documenting the reduction in PFAS concentration. Based on historical foam usage and prior system releases, determine if “hard-to-decontaminate” equipment should be replaced in conjunction with a system decontamination program.

These steps offer the best advantage for achieving environmental compliance now and in the future.

The consequences of not decontaminating your system could be substantial, including non-compliance with environmental regulations.

Benefits of using PFAScrub™

Tetra Tech’s PFAScrub™ cleaning agent and application methodology is engineered to remove residual PFAS. The cleaning formulation drives the dissolution and desorption of PFAS into solution and the repetition of flushing and residence time cycles could address the most difficult PFAS adhesion characteristic associated with pipe-wall layering. Other potential benefits include:

  • PFAScrub™ formulation can be reused until PFAS saturation levels warrant a change-out to a fresh solution
  • Recirculating PFAScrub™ formulation in a closed looped manner is more economical and effective compared to the excessive waste volumes generated through conventional water-flushing methodologies
  • Using our PFAScrub™ cleaning agent can avoid costly replacement of system components that cannot easily be accessed or would severely impact facility operations if a total replacement program were implemented

Right team, right approach yields positive outcome

Over the past 50 years, Tetra Tech has built a legacy of Leading with Science® by providing innovative, technical solutions for our clients. With our global footprint and experience with foam transition work across four continents, we can manage all aspects of a foam transition project, partnering with your existing team to enhance your forward-moving transition program. Together with our global teaming partners, we bring a highly qualified and experienced team to support your AFFF transition program with our PFAScrub™ consulting and environmental remediation services including:

  • AFFF program development and consulting
  • Equipment replacement
  • Fire suppression system decontamination using our PFAScrub™ cleaning agent
  • AFFF waste management
  • New equipment installation and foam replacement

Tetra Tech is equipped to provide solutions that minimize unnecessary replacement of system components, minimize expensive waste disposal, and reduce future environmental liabilities. Please contact us to support your AFFF transition projects.

About the author

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David Fulton

David Fulton is an environmental program director specializing in solutions related to PFAS remediation and firefighting foam transition projects.

With more than 30 years of experience in environmental remediation and engineering consulting, David specializes in providing interdisciplinary solutions for global clients seeking innovative and cost-effective environmental management solutions. He focuses on portfolio and program management techniques that integrate technology, strategy, and global resources to deliver customer value through efficient operations and quality standards.

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