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Fear of PFAS Disposal Costs Looms Over Firefighting Foam Switch

Nov. 16, 2022, 10:30 AM

Airports and other places that rely on PFAS-enabled foams to fight fires should start to prepare to manage the wastes they’ll generate by switching to non-PFAS alternatives, attorneys and consultants say.

Congress ordered the Pentagon to release requirements for firefighting foams made without per- and polyfluoroalkyl substances (PFAS) by the end of January.

Once new PFAS-free foams that meet the military’s standards are available, that will open the door to military facilities along with oil refineries, airports, fire departments, and other private entities replacing their existing stocks of the PFAS-based foam, or AFFF (aqueous film-forming foam).

But swapping the PFAS-based fire suppressants at just one facility can generate tens of thousands of gallons of waste, said Matthew Magnuson, a chemist with the Environmental Protection Agency’s research office. Pipes, valves, and other equipment that’s too contaminated to clean also may have to be replaced, and old AFFF stocks will have to be disposed of.

The 2020 National Defense Authorization Act requires the EPA to update PFAS-waste disposal and destruction guidance by December 2023. Facilities will have to comply with state requirements that may be based on this guidance. At this stage, it’s still not entirely clear which foams and waste disposal systems will work best.

Even so, companies, airports, and other facilities should take steps now, said Corey Theriault, principal water engineer with Arcadis, which began working on switching foams in 2017 in Australia.

Huge Disposal Cost

They should start by finding out how many gallons of AFFF they have and where, what fire trucks or other mobile equipment contains the foam, and how many buildings the foam is piped into in case of fire, Theriault said.

“Some of these larger conglomerates have more pieces and parts out there other than they’re aware of,” he said. “The disposal cost is huge.”

Neither Theriault nor disposal firms interviewed were willing to discuss specific costs, saying the estimate varies based on each site’s need.

But Gregory R. Sharpe, the fire chief at the Waxhaw Fire Department, in Waxhaw, N.C., said he paid about about $14,000 to replace 200 gallons of AFFF with a smaller, but sufficient amount of an alternative PFAS-free foam made by GreenFire, which also made arrangements with the Battelle Memorial Institute to destroy old AFFF.

“We had just gotten new equipment,” so the department didn’t have to worry about additional costs from cleaning out or replacing old equipment that had stored the AFFF, Sharpe said.

Companies also need to figure out what potential liabilities they’re comfortable with, Theriault said.

PFAS-disposal guidance the EPA released in 2020 identified landfills, waste incineration, and deep well injection as possible options. But, it also described limitations and unknowns including the possibility that some technologies might release PFAS.

Local and state laws also may restrict PFAS-containing wastes from incinerators or landfills, said Steve McKnight, strategy and government adviser for 374Water, which developed a technology that cleans water and destroys PFAS.

Factory Shutdowns

Companies have to think through how they’ll operate during the foam transition process, said Cynthia AM Stroman, an environmental practice partner with King & Spalding LLP.

“When you transition it’s not just switching out the foam. You’ve got to clean out tanks, pipes, and valves,” she said.

“You have to have fire protection if the plant is running,” so some industries will have to shut operations down while they transition, she said. “It takes a fair amount of planning.”

Firefighting foam transition guidance from the American Petroleum Institute underscores the need to plan.

The EPA’s research office continues to analyze different technologies that could be used to address AFFF-replacement and other PFAS wastes and ways to improve them, said EPA’s Magnuson and Max Krause, an engineer who also works with the agency’s research office.

The Department of Defense, which has relied on AFFF for decades, and the Water Research Foundation also are funding extensive research on a range of technologies, according to information from the Interstate Technology and Regulatory Council.

Destroying PFAS in Liquids

Technologies that deal with PFAS in water and other liquids are the most advanced.

Water utilities have already been using granular activated carbon (GAC), ion exchange resin, and reverse osmosis to remove PFAS and other contaminants from drinking water. Those technologies don’t destroy PFAS, the Interstate Council said. The PFAS that the filters, membranes, or other material remove still must be disposed or destroyed.

But tests of one technology, supercritical water oxidation (SCWO), showed it could destroy more than 99% of PFAS in liquids, according to EPA scientists.

The technology emerged from Duke University research that began in 2013 with seed money from the Bill and Melinda Gates Foundation, said Marc Deshusses, a civil and environmental engineering professor at Duke. The foundation sought technologies that would help developing countries destroy fecal matter contaminating water supplies, he said.

SWCO worked not only for human wastes but also for other contaminants including PFAS, said Deshusses who cofounded a company called 374Water to commercialize a version of the technology, AirSCWO.

Very hot water—374 degrees Celsius (705.2 degrees Fahrenheit)—and pressure breaks up PFAS and other chemicals, destroying them in the process, he said.

The AFFF-related wastes that AirSCWO can treat include the fire-fighting foam, contaminated water from cleaning equipment, and storage tanks containing runoff collected from airport hangar and other fires where the foam was used, Deshusses said.

‘Happy the AFFF is Gone’

Battelle’s version of SWCO, called the Annihilator, destroys the PFAS in those liquids and other material, like GAC filters that can be made into a slurry, said Amy Dindal, Battelle’s PFAS Program Manager.

Battelle used the Annihilator in September to destroy old AFFF the Waxhaw Fire Department had stockpiled.

Having heard the PFAS in AFFF were linked with cancer and other health problems, “we didn’t want this hanging around the fire station,” Sharpe, the fire chief, said.

The new foams work for gas station, railroad accidents, and other fires Waxhaw deals with, Sharpe said. And his firefighting crew is " happy the AFFF is gone,” he said.

Market Hesitancy

Other than SCWO, most PFAS-destruction technologies are still moving from the design and testing period toward potential use phases, said EPA’s Krause.

“I don’t know that that we would see them next year, but certainly within the next few years you would be seeing these,” he said.

Market dynamics are delaying deployment of new technologies, he said.

Fire departments, airports, and other parties that want to start switching foams want to use a technology with a proven track record, Krause said. “They don’t want to be the first ones to dip their toes in.”

Meanwhile vendors may be convinced their system could work, but aren’t fully ramping up due to market hesitancy, he said.

To contact the reporter on this story: Pat Rizzuto in Washington at

To contact the editors responsible for this story: Renee Schoof at; Zachary Sherwood at