Document JreeeD0QVkgvaLJwQNp9K46bX

US00002779 Public concerns over PFOS & PFOA - Need for Change Q's over alternatives: short chain C6 v F3 - Concerns and considerations : choices bring consequences - Leaching, impacts fire breakdown products, health risks - Remediation options Navigating this minefield...risks, liabilities and exposures Conclusions - potential way forward US00002780 Public Concerns lectro Chemical Fluorination (ECF) process - ceased 2002, exc )ng chain >C8 perfluorosulfonate chemicals degrade to PFOi `BT, mobile - UN Stockholm Convention POP listed PFOS 200S *FOS likely carcinogenic, transfers to unborn foetus and found in mothers milk, )lar bears & penguins! banned in EU 2011 & Canada 2013, import prohibited Singapore and NZ, no\ Breakdown product and impurity from the ECF - PFOS proo Iso unintended manufacturing by-product in Fluorotelomer pruuSS ippm levels hemical of high concern: PBT, mobile, and potentially harmful human effects Mows transition to more benign C6 agent usage with minute traces PFOA (ppb PFOS - stock and LEGACY issue; PFOA - under review Ison nsulting US00002781 US EPA Stewardship Program W illson 2006 major manufacturers and US EPA recognised N< Voluntary PFOA stewardship program - 2 key objects by 2010 - removal 95% PFOA from products & fa d I by 2015 - work towards elimination of PFOA from those facilities & prc Latest 2014 report shows major progress towards virtual elimination of Increasing development of short transition away from PFO ictants resulted, all< ECHA increasing PFOA restriction level to l,000ppb for foams to all C6 has no PFOA ingredients, cannot degrade to PFOA, just few ppb unavoidable trace from manufacturing process; + Not B, Not T; + Fast US00002782 Need for Change W illson isition from long chain fluorochemicals because: Very resistant to degradation, PP" PFOS, PFHxS & PFOA found widely in human blood and enviroi University QLD study showed average PFC levels of 15ppm in population, 30ppm in Australians, 60ppr some factory workers showed 800ppm+! Mostly derived from house dust, fish, seafood, food packaging etc Builds up, slow to decline as long half-lives in humans - avera* transitioning to short chain fluorotelom er foam s or F3 alternatives... i Need to transition away from PFOS and PFOA US00002783 Questions Over Alternatives? W illson C o n s u ltin g Users Qs - Which alternatives are most effective and responsible to use? - What foam should we transition to for the next 10+ years? ...C6 FluoroTelomer (FT) based or Fluorine Free? - Will other fluorinated agents follow PFOS and PFOA into restriction, prevention of use, or POP listing? - Which foam provides the most responsible environmental and usage profiles? - Which can combine delivery of the best environmental outcomes, most effective firefighting capabilities plus safety for firefighters, across diverse fuels and incidents? ....Does this even exist? Answering them lies in scientific research, critical fire testing and incident experiences... Choices bring Consequences in Risks, Liabilities and Exposures US00002784 Research Confirms C6 is Different Willson C o n s u ltin g Research highlights major differences between PFOS/PFOA and short chain <C6 FT surfactants C6 FT increasingly used at > 95% purity level in firefighting foams, embracing US EPA PFOA stewardship criteria. C6 FT NOT Bioaccumulative, nor Toxic, nor Carcinogenic, nor Mutagenic, nor Reproductive Toxicant (Chengalis 2009, Loveless 2009, Iwai 2011, Serex 2008, Hoke 2015). Although C6 FT persistent, no evidence to show harm to humans or environment. Potential POP listing assessment of C6 FT shows cannot be listed POP as only meets 1 of 4 essential criteria, although some questions about mobility C6 FT delivers more benign transition away from PFOS and PFOA - retains unique fire performance benefits NOT adequately provided by F3. US00002785 Short Chain <C6 Agents W illson Cb M S PFHxA extensively tested and confirme< Equivalents C6 to C8 achieves same MilF Spec fire performance Short chain PFHxA fully excreted through hui with half-life in humans averaging 28-32da' Also reviewed and approved by several global regulatory bodi including US EPA, UK EA, Danish EPA, ECHA, NICNAS Australia Avoid: agent: US00002786  Long chain, short chain and Fluorine Free Foams (F3) ALL pollute + firewater runoff (UK Environment Agency, 2014) Main choice: short chain C6 v F3 C6 persistent, F3 lOx more aquatically toxic C6 fuel shedding, fast, resists flashbacks, less usage F3 not fuel shedding, slower, picks up fuel -vulnerable to flashbacks, fires burn longer = more noxious runoff 3x more F3 often required, especially on Gasoline !!^ll!ligi!El!ILi;iil!Ml4l US00002787 High detergent levels mean F3s typically lOx more aquatically toxic than AFFF If 3x more used, then 30x greater toxicity from specific incident Wetting Agent 0.1-1% (F3) Class B 3% F3 - Foam A Class B 3% F3 - Foam B Milspec 3% AFFF AR-AFFF 3x3% UL3% AFFF 1.06 65 2,176 3,536 5,657 0.887 171 171 884 1,487 1,726 Source: FFFC AFFF update - Aquatic Toxicity of Firefighting Foams, 2006 US00002788 Can we use Water? Water sinks through fuel, lifti smoke and breakdown products = unsuitable BEST FOAMS like <C6 D! fast control & reduci improved life safety for casualties & firefighters rotection of investments ;duced business interruptic iduced financial & job loss iduced smoke, breakdown US00002789 Fluorine Free Foam (F3) Struggles W illson F3 agents suit some applications eg. Brigad Hazard Facilities (MHFs) including Airports Major F3 Concerns: Removing fluorine = extra detergent (hydroca Fuel released as unreliable bubbles collapse Incandescent materials ignite vapour = sudden unpredictable flashbacks and flare Exposes casualties and firefighters to potential danger & unexpected escalatio F3 effectively limited to gentle aspirated application on volatile fuels (g Often 3x shorter vapour seal with F3 blanket than AFFFs (Schaefer 2008) So 3x more F3 and water resources needed than AFFF/FFFP on same incident! (Caite> Dlications = 3x more run-off, potentially 30x more Does this seem environmentally responsible? US00002790 Variabilitv on ICAO Level B test Independently witnessed ICAO Level B testing, Denmark, 2012 (60 sec extinguishment) Tested with Jet A l, UNI86 nozzle - fixed improved reproducibility All 5 x F3s failed ICAO Level B, incl. 3 certified to pass -best lm in24s (AR-F3), popular 6% F3 failed to extinguish Reasonable fire control, but delays from persistent edge flickers Contrary to expectations, when tested with Modified Military Spec Nozzle to mirror more fluid foam commonly used, control times extended for 2 of 3 foams, failing to extinguish (popular 6% extinguished lm in 58s) This heavier foam picks up more fuel than lighter foam from UNI86! Concern - Substantial drop off in performance when more realistic aspirated nozzle used Since 2013 ICAO changes, extinction in 120s not 60s Allows several previously inferior AFFF foams to pass - is that right? Typical ICAO Level B fire performance of tested F3 at 1 minute (from Danish testing -Hubert, Jho,Kleiner,2012) "Dumbed down" ICAO fire test seems to increase life safety risk US00002791 Incident Caltex Banksmeadow Sydney, 2013 Unleaded gasoline tank 901 - valve leaked into bund 3-4m high fountain, 130,000L unignited fuel in bund F3 blanket suppressed vapours for only 15-20 mins between "top-ups" Considered failing as unacceptably short Kurnell Refinery FP foam used, controlled vapours for 90 mins between "top-ups" = 4.5x longer FP allowed incident to be controlled reliably and effectively with minimal resources used Confirms Newcastle University research "...bestF3 provides only 30% durability ofAFFF on gasoline" (Schaefer, 2008) US00002792 X repeating ison nsulting 7L/min/m2for 15 minutes but NO control Increased 18.2 L/min/m2for further 15mins littl effect, until fuel burnt away and fire out! (virtually 11 recommendation of 6.51 2 weeks earlier, same fire extinguished in approx, mins with AR-AFFF at 10.4L/min/m2 jnging and no fuel shedding capability of F3 US00002793 "Simulated Storage tank fire" test, Beaumont Texas 2013 12.8m dia storage tank (128.7m 2) "fuel in depth" 1,703L EMI training fluid (assume jet version FP 40C) 10.3L/min/m2 application rate (l,325L/m in monitor) Extinguishes at 3min 5sec video, claimed extinction in 2min 5sec, but only 40sec preburn = 2min 25sec Looks impressive BUT... actual fuel depth only 1.33cm = spill only... High application rate for a jetfuel spill fire!! [almost 3x normal 4.1L/min/m2 rate)... Surprising results?? https://www.youtube.co m/watc h?v=0 Hlv9 DVOoa E. Also www.youtube.com/wateh?v=3MG2fogNfdQ. and www.youtube.com/wateh?v= iuKRU-HudSU US00002794 confirms "Compared with fluorine-basedfire-fighting foams (AFFFfoams) around twice as much water andfoam concentrate are required when extinguishing liquidfires. According to some analyses fluorine-free fire fighting foams may give less protection against re-ignition which means that the fire may flare up without warning. There are operations whose standards are such that currentfluorine-free fire-fighting foams are not acceptable alternatives. One example is the Swedish Armed Forces which, in the event of afire, allows 90 seconds to reach the location and a max'mum of 90 seconds to cool down the cockpit (Borgh 2014). " concludes "The technologically best alternatives to hazardousfluorinated chemicals are shortchain and less hazardous fluorinated chemicals with a fluorochain length of <C6 orfluoropolymers." Also "The short-chain homologues and their precursors (e.g. fluorotelomers based on short-chain fluorochemistry) generally seems to have a better human health and environmental profile than the substances based on long-chain fluorochemistry, but it is difficult on the current knowledge to assess to what extent non- fluorinated substances could be alternatives of less concern to the long-chain PFASs for some applications. " 15 years on ... F3 still not up to the ma US00002795 acknowledges "Regarding experience with Fluorine Free (FF) foams, LASTFIRE testing has undoubtedly shown that improvements in formulations have occurred since their introduction although, as yet, no fluorine free foam has shown the same level of consistency or high performance that had become the norm with good quality Multi purpose AFFFs Or Fluoroprotein foams. One typical issue that has been noted with some FFfoams is the tendency for small flickers offlame to occur for extended periods of time some distance (50-150mm) from the test tank wall." "These flickers reduce the overall scoring in the test and in some cases cause a "FAIL" classification because they continue to burn even when the total test period is completed." 15 years on ... F3 still not up to the mar US00002796 PFOS Still Leaching After Recent study found concrete fire training areas at some Airports saturated to 12cm with PFOS Despite thorough clean out PFOS in 2010, change-out to F3 PFOS still leaching when F3 used, or just water even when it rains! Predicted to continue for 25 years So why accept inherent fire performance and toxicity drawbacks of F3? Source: Baduel et al 2015-Perfluoroalkyl substances in a firefighting training ground, distribution and potential future release US00002797 Detergent is most toxic of all foam ingredients, increased in F3 More poisonous to bacteria and food of fish, than fish Can disrupt W W TP by killing critical bacteria (Source: British Water 2009 -Code of Practice - A Guide for Users of Sewage Treatment Systems; Can em ulsify with fuel carrying past fuel separators = potential pollution (source: uk-ea- PPG3) Destroys mucous layers protecting fish from bacteria Can cause damage to fish gills Most fish will die at >15ppm , 5ppm kills fish eggs (Source: Lenntechj Reduced surface tension allows 2x organic chemicals to be absorbed by fish at just 2ppm F3 is lO x more toxic to fish (Source: FFFC 2006 - Aquatic toxicity update) F3 typically uses 3x more on volatile hydrocarbons = 30x more toxic than AFFFs! F3 associated risks of sudden flashbacks as missing critical fuel shedding capability Where will replacement organisms come from to re-populate isolated waterways? US00002798 Wide-range of inhalation and skin contact hazards likely cause of increased cancer risks Smoke, breakdown products and firewater run-off produce VOCs and PAHs - some hazardous to humans, potentially carcinogenic Benzo(a)pyrene (PAH) is known carcinogen Increased risks with more attendance at vehicle fires Source: Australian Firefighter Study, 2015 Fast extinction helps reduce risks and exposures to firefighters, casualties and local communities Likely Cancer risk from fire breakdown products - average 79% fires attended were S,V,B! US00002799 Total Fires, All Agencies % of total fire count 1,228,200 100% 348,676 28.4% 445,047 36.2% 176,959 14.4% Monash University study of 224,000 Australian firefighters showed 79% of fires attended were Structural (S), Vehicle (V) or Bush (B) fires All firefighter groups studied showed increased risk of prostate cancer Class B Foams - whether fluorinated or fluorine free - NOT mentioned, as not normally required for these hazards Likely Cancer risk clearly from fire breakdown products - NOT Foams use 970,082 79% US00002800 Toxins Penetrate PPE Research shows fire breakdown products can enter skin under/through PPE during incident, overhaul and transfer back to station Off-gassing also inhaled during BA changes, overhaul and transport Exposures contributing to increased cancer risk Recommends shower and change on fire-ground with PPE sealed in containers and laundered regularly. Source: Kirk &Logan, 2015 - Structural firefighting ensembles accumulation and off-gassing of combustion products Harmful fire exposures through PPE W illson C o n s u ltin a US00002801  Diverse options - varying degrees of effectiveness and complexity: Granular Activated Carbon(GAC) filtration Reverse O sm osis, electrocoagulation Catalytic advanced oxidation Reed bed technology - proven at UK airports for fire training areas. Adsorbing modified clays Specially modified clays -successfully treated > 1 million litres PFC contamination at 3 Australian airbases (QLD, SA, WA) - removed PFCs to below the reporting level of 5ppb - adsorbs PFOS and PFOA by binding them irreversibly into its structure - field trials shown more effective than GAC and biochar Sources: Environment Institute of Australia, 2016 - PerFluorinated Compounds Forum, CRC Care - Firefighting foam case study, 2014 B3 IT1T1T1T1TT US00002802 Requires more holistic approach to whole incident Assess risks, exposures and liabilities Identify key critical factors and life safety issues Seek strengths and weaknesses of alternatives Avoid misleading assumptions/interpretations Select solution based on: - delivering strongest fire performance - protecting people and communities - delivering environmental responsibility - protecting valuable assets - minimising risks, liabilities, exposures - providing containment and waste treatment options US00002803 Consider fire impacts: Risk of more noxious smoke and breakdown products Risk to life, communities, businesses, associated processes/equipment /value Incident escalation risk = more damage Slower control = more fire = more run-off = more harm? Larger Insurer pay-outs for more damage, more business interruption, more community disruption, more potential injuries UK Environment Agency leading field with more holistic views : All foams pollute; extinguish fires fast! US00002804  Consider liabilities as part of risk assessment process Employers duty of care -staff health/injury liabilities Business/property owners - increased damage/costs Longer disruption: lost jobs and revenue Insurer liability: extensive/larger pay-outs Potential insurance premium increases Penalties/prosecution for control failures - particularly escape offsite or surface/groundwater contamination Controlled burn also an option, if minimising impacts! oam Choices Make Difference: Quick Control v Failure to Extinguish US00002805 Impacts neighbouring facilities Heat damages people, buildings, processes, communities Escalation potential: slow control containment overflows, catastrophic failures Life safety, evacuation & rescue Reduce smoke & health exposure Extended environmental impacts - more smoke, more runoff, more toxicity, more community damage Foam Choice Makes Difference: Reduces or Increases Exposure US00002806  Many Fire Services believe F3 is "Right Answer" ...for smaller hazards Does it translate to Major Hazard Facilities & surrounding Communities? Fire breakdown products often toxic, persistent, maybe carcinogenic like PAHs - Benzo[a]pyrene, Fluorochemicals are widely used in buildings & vehicles -most now transitioning to short chain <C6 FTs. ...Concrete leaching PFOS? ALL potentially contaminate firewater run-off and receiving environment! C6 FT fast acting to extinguish quickly with minimal resources and run-off. F3 may slow extinction, encourage escalation = MORE fire; delays; smoke; life safety risk; breakdown products; runoff; ill-health concerns; disruption; damage; repair time; community upset; cost! Is that right? F3 also potentially 30x MORE toxic to aquatic organisms! Even leading F3 makers moving to C6 AFFFs & MilF spec! US00002807 I Most agree PFOS, PFOA and PFHxS undesirable legacy issues All foam types can pollute: F; F3, + firewater runoff alone F3 brings problems - flashbacks, escalation, life safety risks, high toxicity, more fuel emulsification, high detergency Fuel shedding is critical C6 FT advantage + environmentally more benign as behaves differently (not B not T) Careful risk assessment of whole incident and how it evolves, is critical to protecting life safety Minimising risks, liabilities and exposures usually keeps incident manageable, and facilitates best choices Fast extinction with C6 FT based fuel shedding agents = way forward All 30 slides Willson Consulting, 2016 US00002808