Many of the bulk liquid products handled by ILTA member companies demand special precautions due to their flammable properties.
While significant fire events at terminals are rare, responsible facility management demands that terminal operators maintain capabilities to respond quickly and effectively to fire events when they do occur. For decades, the tank storage industry has relied upon aqueous film-forming foams (AFFF) to protect communities, workers, commodities and infrastructure from potentially dangerous fire hazards and environmental risks from fire events or spills, such as air pollution. The effectiveness of these foams was attributable to the unique characteristics of the perfluoroalkyl and polyfluoroalkyl substances (PFAS) they contained.
ILTA firmly supports a safe, strategic, well-managed transition to fluorine-free, or PFAS-free, firefighting foams while ensuring public and worker safety. It also recognizes that significant barriers must be addressed before a complete, industry-wide transition to safer alternatives is achieved.
Transitioning the liquid terminal industry’s existing stocks of firefighting foam
to fluorine-free foams will require collaboration between regulators and industry stakeholders, including terminal owners and operators, firefighters, foam manufacturers and disposal vendors. Alternative foams are not a drop-in substitute for AFFF. There are important research, development, deployment, training, disposal and other activities that should be strategically thought through in developing a transition timeline. For example, to be effective, the replacement foams may require higher foam volumes, additional labor and different application techniques and equipment. Additionally, there are potential safety risks associated with the transition without allowing appropriate time for coordination between stakeholders for testing, training, equipment replacement, disposal and other critical activities.
Terminal operators rely on the principle of mutual aid to ensure they can provide adequate responses to incidents. During an event, neighboring facilities may provide foam, equipment or fire-fighting personnel. Importantly, due to the foam flow rates and potential contamination concerns, equipment prepared to deliver PFAS containing foams cannot be used to deliver fluorine-free foams, and vice versa. For the largest fires, foam may be provided from other facilities across the region or even from across the country. This inherent interdependence of terminals makes it necessary to allow additional time for the entire industry to move together to eliminate PFAS containing foams.
Toxicity assessments change over time and do not necessarily tell us what we need to know. For example, when PFAS chemicals were first introduced decades ago, their toxicity and environmental persistence were not known. Industry leaders must take steps to ensure the next actions do not introduce regrettable substitutes. To ensure that the new chemistries in alternative forms are safe for decades to come, ILTA has encouraged EPA to consider a mandatory alternative foam certification program, such as Green Screen. Currently, little information is publicly available about the new alternative foam chemistries. Having an assessment or certification process would help ensure liquid terminal companies and staff, firefighters and the communities surrounding these facilities that the alternatives being implemented are as safe as possible.
Today, there is no universally accepted method of safe disposal of PFAS-based firefighting foams. Incineration of PFAS chemicals is banned in several states and a moratorium on PFAS incineration is in place at Department of Defense facilities. While new technologies to destroy PFAS in firefighting foams have recently entered the marketplace, more work is needed to validate these technologies for all legacy foams.
Overall, ILTA advocates for clear national standards to avoid a piecemeal approach across different states. A coordinated transition to fluorine-free firefighting foams is essential to safe incident response across the liquid terminal industry.
For more information, visit ilta.org, or call (703) 875-2011.
