ILTA Conference 2023 – A Look Into the Evolving PFAS Landscape

ILTA Conference 2023 – A Look Into the Evolving PFAS Landscape

Over the course of two days and three panels, ILTA’s annual conference featured renown experts who delved into the challenges, advances and updates regarding PFAS chemicals and their presence in the firefighting foams commonly used by ILTA members. Importantly, the experts provided information on remediation techniques where contamination has occurred and on the development of PFAS-free foams for use at terminal facilities. Each of these panels provided both practical and strategic information aimed at ensuring participants have the tools needed to navigate this changing and complex issue. Here’s a quick look at what was covered:

PANEL 1: Firefighting foams – How the Chemistry and Tactics Need to Change

Kicking off with a deep dive into the history and chemistry of firefighting foams, this panel focused on explaining the challenges associated with replacing traditional foams with fluorine free foams. Initially, it was observed that fluorine free foams are getting closer to performing at the same level as AFFF, but that applications to manage fire events with water solubles and polar solvents continue to be a challenge. Paired with the significant differences in the mechanisms, drainage, foam composition and raw materials used in fluorine-free foam (FFF), these challenges mean new foams should not be considered “drop-in” replacements. Importantly, it was noted that there are also serious challenges associated to PFAS removal and extraction, at the levels required by different state regulations. Incorporating new cleaning agents and processes may be necessary.

PANEL 2: PFAS: Mitigating Risk at Liquid Terminals

Analyzing the risk factors associated with the use of PFAS at liquid terminals, this panel identified key actions for terminal operators to reduce their exposure to increasing regulations across jurisdictions. To set the stage, it was noted that the regulatory, technological and operational landscape surrounding PFAS is rapidly changing and becoming more restrictive, based on evolving science. The use of PFAS in firefighting foams and other processes means ILTA members should ensure they understand the regulations across different jurisdictions, audit their supply chains and facilities for exposure (even beyond firefighting foams) and develop a strategic plan to address these issues. It was highlighted that there may be unintentional exposure to PFAS both at terminals and from suppliers who may not have a complete understanding of the potential contamination found in their products or resulting from insufficient cleaning. As in the first panel, it was concluded that PFAS clean up will require new and additional technologies being incorporated into existing systems.

Importantly, it was noted that the regulations surrounding PFAS in the United States continue to be led by individual states, but that EPA is catching up, especially through its proposed CERCLA designation. EPA has informed it intends to use enforcement discretion to avoid financial impact on parties it doesn’t consider responsible. EPA is primarily targeting manufacturers of PFAS; however, the regulatory and legal details and potential ramifications are still in development. Specifically, EPA has proposed reaching legal settlements with involved parties to resolve litigation liabilities. To be considered for the discretion, EPA will analyze an organization’s level of involvement, its cooperation with EPA, its cooperation with local authorities and other elements.

PANEL 3: LASTFIRE Update

This panel provided information on LASTFIRE’s most recent testing of FFF and its implications for the industry. Recent tests, which are the most extensive to ever have been undertaken, demonstrated that there have been significant advancements in these foams. All the FFF’s that were tested worked, with greatly improved application rates. However, it was observed that there will need to be increased focus on the techniques and processes being used. For example, the test showed that a gentle and indirect application of the FFFs is required for them to be effective, as opposed to the direct and pressurized application of AFFF. The broad range of FFFs and their differences mean there is still a need for much more testing, but LASTFIRE is certain that FFF will be commercially available for safe application at terminal facilities.