Report of the Committee on

Foam

Christopher P. Hanauska, Hughes Assoc., Inc., MN [SE] Chair

Laurence D. Watrous, HSB Professional Loss Control Inc., TN ['I] Secretary

William M. Care),, Underwriters Laboratories Inc., IL [RT] Salvatore A. Chines, Industrial Risk Insurers, CT [I]

Re.~p. Industrial Risk Insurers W. D. Cochran, Montgomery, TX [SE] Gene DiCiementi, Glenview Fire Dept., IL [E] Arthur IL Dooley, Jr. Dooley Tackaberry, Inc., TX [IM]

Rep. Nat'l Assn. of Fire Equipment Distributors Inc. Francis X. Dunigan,Jr. Angus Fire North America, NC [M] JROhn A. Frank, Kemper Nat'l. Insurance Cos., GA [I]

obert A. Green, Public Service Electric & Gas Co., NJ [U] Rep. Edison Electric Inst.

LarryJesclard, Engineered Fire Systems, Inc., AK [IM] Rep. Fire Suppression Systems Assn.

Dennis C. Kennedy, RolfJensen & Assoc. Inc., IL [SE]

J ohn A. Krembs, M&M Protection Consultants, IL [I] ohn Lake, Fire Protection Industries Inc., PA[M] Rep. Nat'l Fire Sprinkler Assn.

D. N. Meldrum, Malvern, PA[SE] Robert C. Merritt, Factory Mutual Research Corp., MA [I] Richard F. Murphy, Cranford, NJ [SE] Edward C. Norman, Aqueous Foam Tedmology, Inc., PA [SE] Keith Otson, Ansul Inc., WI [M]

Rep. Fire Equipment Mfrs. Assn. Inc Richard E. Ottman, 3M, MN [M] Fay Purvls, Nat'l. Foam, Inc., PA[M] Niall Ramsden, Resource Protection Int'l., England [SE] Steven F. Vieiru, Grinnell Corp., RI [M] Klaus Wahle, U.S. Coast Guard, DC [E] B.J. Walker, Walker & Assoc., MO [SE] Michel Williams, Ultramar Canada, Inc., PQ, Canada [U]

Rep. NFPA Industrial Fire Protection Section Jack Woycheese, Gage-Babcock &Assoc. Inc., CA [SE]

Alternates

Tony Cash, Angus Fire, England [M] (Air. to F. X. r)unigan)

William M. Cline, Factory Mutual Researcll Corp., MA [I] (/kit. to R. C. Merritt)

Dennis L. Doherty, Industrial Risk Insurers, CT [I] (Alc to S. A. Chines)

Peter E. Getchell, Kemper Nat'l. Insurance Cos., PA [I] (/kit. toJ. A. Frank)

Matthew T. Gustafson, U.S. Coast Guard, DC [E] (Air. to K. Wahle)

Kevin P. Kuntz, M & M Protection Consultants, NJ [I] (/kit. to j . A. Krembs)

Norbert W. Makowka, Nat'l Assn. of Fire Equip. Distributors (NAFED), IL [1MI

(Alt. to A. R. Dooley, Jr.) Francisco N. Nazario, Exxon Research & Engr, NJ [U]

(Voting alt. to API Rep.) David IL Riggs, SOTEC, LA [IM]

(Ah. to L.Jesclard) Joseph L. Scheffey, Hughes Assoc. Inc., MD [SE]

(Alt. to C. Hanauska) Bruce S° Shlpley, Nat'l. Foam, Inc., PA [M]

(Air. to F. Purvis) Christopher L. Volhnan, RoffJensen & Assoc. Inc., TX [SE]

(Alt. to D. C. Kennedy) Kenneth W. Zastrow, Underwriters Laboratories Inc., Northbrook. IL [RT]

(Alt. to W. M. Carey)

StaffLiaison: David tL Hague

This list r~]Oresents the membership at the time ttw Committee was balloted on the text of this edition. Since that time, changes in the membership ~ have occurred A key to classifications is found at the front of the book

Committee Scope: This Committee shall have primary responsibil- ity for documents on the installation, maintenance, and use of foam systems for fire protection, including foam hose streams.

The Report of the Technical Committee on Foam is presented for adoption.

This Report was prepared by the Technical Committee on Foam andproposes for adoption amendments to NFPA 11-1994, Standard for Low-Expansion Foam. NFPA 11-1994 is published in Volume 1 of fl~e 1996 National Fire Codes and in separate pamphlet form.

Th i s Report has been submitted to letter ballot of die Technical Committee on Foam, which consists of 28 voting members. The results offlae balloting, after circulation of any negative votes, carl be found in tile report.

N F P A 11 - - A 9 7 R O P

(Log~) I I - I - (Entire Docume~tt): Reject S ~ Robert L. Markle, United States Coast Guard, G-

RECOMMENDATION: Develop a new chapter to address design and installation requirements for low expansion foam systems aboard commercial ships. The chapter should address deck foam" systems on tank ships carrying hydrocarbons and polar solvents; machinery space foam systems; and other foam equipment applica- t iom on commercial vessels. SUBSTANTIATION: There does not currently exist industry developed consensus guidance for foam systerm and equipment used aboard commercial vegeb. A task group should be formed to

t ~ oposed new chapter. AL"HON: Reject.

COMMrr l 'Eg STATEMENT: No proposed wording. NUMBER OF COMMI'I 'rEE M]Dd[BERS ~JJGIBLETO VOTE: 28 VOTE ON 'COIVlMTITEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesdard, Lake, Nazario

(Log'#cPg) ii-2- (I-I(b), (c), (e), (f),and (g)): ~ccept " SUBMITTER: Technical Committee on Foam, RECOMMENDATION: Revise text to add reference to appropriate standards as follows:

(b) Foam-water deluge sprinkler or spray systems see, NFPA 10 "Standard for the Installation of Deluge Foam-Water Spinkler and Foam-Water SpraySystems" (1995). (c) Foam-wa/er dosed-head sprinkler systems see, NFPA 16A

"Standard for the Installation of Closed-Head Foam-Water Sprinkler S ~ e m s " (199@.

) Mobile Foam Apparatus see, NFPA l l G Standard for Mobile Foam Apparatus" (1995) and, NFPA 1901 "Standard for Pumper F'we A p p a r a ~ " ( I ~ I ) . -

(f) Medium- and ldgh-expansion foam systems see NFPA 11A "Standard for Medium- and High-Expami'on Fomn Systems (1994).

(g) C2ass A foam see, NFPA 208 "Standard on Fke Fighting Foam Chemicals for Class A Fuels in Rural, Suburban, and Vegetated Areas" (1994). SUBSTANTIATION: The Committee feels that reference to the

is in order. ON: Accept.

NUMBER OF COMMITIF.E MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log #CP2) 11- 3 :- (1-! (g) (New)): Accept SUBMITTE~ Technical Committee on Foam, RECOMMENDATION: Add~'ub-paragraph (g) to exclude class "A" foams as follows:

(g) Class "A" foam and systems. SUBSTANTIATION: The requirements and testprocedures for dass "A" foam is presently covered in NFPA 298 "~tandard on F'we Fighting Foam C~emicais for Class A Fuels in Rural~ Suburban, and Vegetated Areas" (1994). COMMFrYEE ACTION: Accept. NUMBER OF C O M M I T r ~ MEMBERSgLIGIBLE TO VOT]~ 28 VOTE ON C O M M I T r ~ ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesdard, Lake, Nazario

(LOg#4) 11 - 4 - ( 1-4 Concentration~: Accel~t in Prindple S[.~MTr~.,~ Gary 1~ Mitchell, FMGJetway Systems RECOMMENDATION: Add new text as fullow~

"A 1 percent concentrate is mixed with 99 parts water to 1 part foam concentrate." SUBSTANTIATION: Several foam concentrate manufacturers have UL listed I percentAFFF. Its fire-fighting capabilities are similar in - nature to 3 percent and 6 percent solutions. Use of 1 percent permits a smaller bladder tank and minimizes space requirements.

• COMMITTEE ACTION: Accept in Principle, | Revise the definition of concentration as follows:

Concentration. The percent of foam concentrate contained in a foam solution. The type of foam concentrate used determines the percentage of concentration required. For example, a 3 percent t~oam concentrate is mixed in the ratio of 97 parts water to 3 parts foam concentrate to make foam solution. COMMITTEE STATEMENT: The definition is not meant to restrict the percent of concentration used, it is meant to define concentra- lion. NUMBER OF CO--MEMBERS FAJGIBLE TO VOTI~ 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(LOg#7) 11- 5-- ( 1-4 Concentration): Reject SUBMITTER: James Detonshlre, Oiemguard, Inc. RECOMMENDATION: At the end of the current paragraph add the following wording:

"A 1 percent concentration is mixed with 99 parts water to 1 part foam concentrate." SUBSTANTIATION: With developments in both foam concentrates and hardware it seems that this particular paragraph is limiting the standard in scope. There are I percent AFFF concentrates from several manufacturers listed by U.L through various proportioning and discharge devices. The fire performance is similar in nature to both the 3 percent and 6 percent AFFF products. Due to space and weight limitations, several end users of foam concentrates have noted this omission and requested that we address this issue with the committee. COMMITTEE ACTION: Reject. COMMrlWEE STAT]~V[ENT: See Committee Action for Proposal .ii- o (Log #cPs) .

OF COI~t~I~E MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON C O l ~ ACTION: AFFIRMATIVE: 25 NOT RETURNED: 3 Jesdard, Lake, Nazari0

- (Log ~PS) 11- 6 - (1-4 Foam Concentrate (c), 1 Aqueous F'dm-Forming Foam (AFFF) Concentrates): Accept S U B M r r r E ~ Technical Committee on Foam, RECOMMENDATION: Revise definition of Aqueous Film Forming Foam concentrates as follows: A_queous Film'Forming Foam (AFFF) Concentrates. These

concentrates are based on fluorinated surfactants plus foam stabilizers and usually diluted with water to a 1 percent, 3 percent ¢/r ~- 6 percent solution. The foam formed acts as a barrier both to exdude air or oxygen and to develop an aqueous film on the fuel surface capable of suppressing the e~oludon of fuel vapors. The foam produced with AFFF concentrate is dry chemical compatible and thus is suitable f6r combined use with dry chemicals. SUBSTANTIATION: The standard should, recognize the existence of one percent foam. [See Proposal 11- 4 (Log#4)and Proposal 1 I- S ( #7)I - ' C ( O ~ ACTION: Accept. NUMBER OF C ~ M]~VlfBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrrTEE ACTION: AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log ~ ) 11- 7-(3-3.3.2.2): Accept . SUBMrlt~'~ l~ith Olson, Ansul Fire Protec~oo REC~KrlON: Revise text as follows:

3-5.3.2.2 Below-the Seal or Weather ShieldSystem. The design _parameters for the application of fixed foam~dischar~e outlets below the seal (or weather s~eld) to protect open-top floating roof tanks shall be in accordance witti ~ . Ttie requirements given in the table apply to tanks containing hydrocarbous, or, flammable and combustib]e materials requiring alcohol-resistant foams. The required minimum application rates given in ~ apply unless listing for specific woducts require higher application rates when Type II fixed foam ~lischarge outlets are used. (See Figure 3- ~.S.2.2.) - Note ttmt the only changes above are underlined compared to what is currently in NFPA 11. Table 3-3.3.2.2 follows with changes corresponding to Details A-D of Figure 3-3.3.2.2.

N F P A 11 ~ A 9 7 R O P

Table 3-3.3.2.2 Below-the-Seal Fixed Foam Discharge protection for Open-Top Floating Roof Tanks (See Figure 3-3.3.2.2)

Applicable Minimum .Application Rate - Minimum Illustration Detail gpm/f t 2 [ (L/min) /m 21 Discharge Time

s ~ Xrp~ (~n) Maximum Spacing B~ween

Discharge~Ou~e~}

Mech,'micalShoeSeal A 0.5 (20.4) 10 130 ft (39 m) - Foam dam not required

Tube Seal with more than 6 in. (152 mm) between top of tube and top of pontoon

B 0.5 (20.4) 10 60 ft (18 m) - Foam darn not required

Tube SeM with less than 6 in. (152 ram) between top of tube and top of pontoon

C 0.5 (20.4) 10 60 ft (18 m) - Foam dam required

*Tube Seal with fo,-un discharge below metal secondary seal

D o.5 (20.4) 10 60 ft (18 m) - Foam darn not required

*A metal secondary seal is equivalent to a foam dam.

SUBSTANTIATION: None . COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesda rd , Lake, Nazario

(Log #6) 11- 8 - (3-3.3.3.4): Accept SUBMITTER: Richard F. Murphy, Exxon Research & Engineer ing

l RECOMMENDATION: Revise pa ragraph to read as follows: "The foam dam shall be at least 1 ft (0.3 m), bu t no t more than 2 ft

(0.6 m), f rom the tank shell." SUBSTANTIATION: T he foam dana should be d imens ioned f rom the tank shell, no t the edge o f the floating roof. This is consistent with the d imens ion ing shown in Figures 3-3(d), A-3-3.3.1.1 (a), and A-3-3.4. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 N O T RETURNED: 3 Jesdard , Lake, Nazario

(Log #9) 11- 9 - (3-4.1 (New)): Accept in Principle SUBMITTER: E L Blumquist , PETREX, Inc. RECOMMENDATION: Add new text as follows:

5-4.1 Types of Fires Anticipated. W here a covered floating roof is o ther than described in 3-4 a design for full surface protect ion shall be used. For a covered floating roof as described in 3-4 a design for seal a reapro tec t ion shall be permit ted . SUBSTANTIATION: (1) The prob lem is tha t these paragraphs require foam protect ion to cover the full l iquid surface when the internal f loating is no t made f rom steel.

Tile under lying assumpt ion appears to be that if it is no t made from steel, the internal floating roof will be consumed by a fire and expose the full liquid surface.

(2) Recently, PETREX conduc ted fire tests witnessed by Profes- sional Service Industries, Inc., Pi t tsburgh Test ing Laboratory Division which seem to refute the idea that a l u m i n u m would be quickly c o n s u m e d by fire.

NOTE: Suppor t ing material is available for review at NFPA Headquarters .

(3) Tbe first test was with an a l u m i n u m honeycomb panel, with a 6-in. hole in the center, f loating on gasoline. The gasoline in the bole was igni ted and allowed to burn for 90 minutes . T he a l u m i n u m a round the hole was not consumed and the panel con t inued to float.

(4) The second test was with an a l u m i n u m honeycomb panel with a per imeter extrusion a t tached and floating on gasoline. T h e per imeter extrusion is used to at tach the seal to the floating roof. In the test the panel was posi t ioned so the per imeter extrusion was 6 in. f rom the test tank wall, which is typical construction.

The rim space between the test tank ad panel was igni ted and allowed to bu rn for 120 minutes .

The panel was buckled in a few places and there was one small burn through. The a l u m i n u m was no t consumed and the panel con t inued to float.

(5) A third test was conduc ted by PETREX, but without an outside witness. This test was similar to the first test except the hole as 12 in. in d iameter and bu rned for 120 minutes as required by U. S. Army Corps of Engineers specifications.

The fire did no t grow beyond the 12-in. bole, the a lum in u m was not consumed and the panel cont inued to float.

(6) In all three tests i nhe ren t features of the a l u m i n u m honey- comb panel contr ibuted to the ou tcome of the tests. These features are:

(a) A l u m i n u m is an excellent thermal conductor. Tbe gasoline m the tank kept the a l u m i n u m panel cool and prevented distortion that could have exposed a greater gasoline surface for burning.

(b) A l u m i n u m is non-combust ible . (c) The honeycomb panel is inherent ly buoyant due to thousands

of liquid t ight cells (pontoons.) (d) T h e h o n e y c o m b a l u m i n u m panel floats in the liquid with the

bot tom surface displaced approximately 5 /16 in. above the liquid, similar to a foam blanket. A punc tu re or void does not permi t liquid fuel to flow on top of the panel, as with a steel f loating roof, being below the liquid level; nor does it permi t the escape of t rapped vapors, as with a skin and pon toon floating roof, being above the liquid level. See Sketch A below:

(7) We recognize that no internal f loating roof will absolutely prevent a fire or no t sustain some damage dur ing a fire. We submi t that our tests have demons t r a t ed that the a l u m i n u m hon ey co m b full surface contact internal floating roof has fire safety characteristics equivalent to a steel internal f loating roof. An addit ional feature of file honeycomb roof is that it will no t sink when punc tu red or

tiPNPoed. TE: Suppor t ing material is available for review at NFPA

Headquarters . COMMI'I~ITEE ACTION: Accept in Principle.

Revise text to read: 3-4.1 The following types of roof construct ion shall be considered

suitable for seal area protect ion systems:

N F P A 11 ~ A 9 7 R O P

(a) steel double deck (b) steel pon toon (c) full liquid surface contact, closed cell honeycomb, of metal

construction conforming to AP1650 Appendix H requirements. All other types of root" construction shall require full surface

{[~rotection. OMMI'VITEE STATEMENT: The Committee feels that tile

performance of Type C roofs is acceptable based on fire test data submitted. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log #CP6) 11- 10- (3-7.1, 3-7.1 (a) and (b), and Table 3-7.1.1): Accept SUBMITTER: Technical Committee on Foam, RECOMMENDATION: 1. In 3-7,1, 3-7.1(a), and Table 3-7.1.1 revise by removi,n~ the word "fixed."

2. 3-7.1(b) add Foam Hose Lines" to read as follows: (b) Foam monitors or Foam Hose Lines.

SLIBSTANTIATION: This section should include a reference to foam hose protection. COMMITrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, l ake , Nazario

(Log #3) 11-11 - (5-3.2): Reject SUBMITTER: Emilio 1L Nieves, Oxy Peru RECOMMENDATION: Replace existing section 5-3.2 by the following new statement:

"As far as it is practical, the supply of foam concentrate, should not depend on energy source other than its own." SUBSTANTIATION: In remote locations, where fire water systems are diesel engine driven and the electrical supply is serf generated, a failure in the generator(s) will result in the impairment of the foam fire fighting equipment.

The use of electrical driven pumps to proport ion foam concen- trate-water should be considered improper, if no t dangerous, and will make necessary the use of portable electrical generator to drive the electrical pump.

In my opinion, foam equipment should be bladder balanced PCressure or n i t rogen/a i r driven type.

OMMITrEE ACTION: Reject. COMMITrEE STATEMENT: The reliability of power supplies is addressed in 5-3.1 NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrITEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log #CP7) 11- 12 - (Chapter 6 (New)): Accept SUBMITTER: Technical Committee on Foam, RECOMMENDATION: Add new Chapter 6 on Marine Applica- tions, and renumber existing Chapters 6 and 7 as Chapters7 and 8.

Chapter 6 Marine Systems 6-1 GENERAL. 6-1.1 All requirements of NFPA 11, "Standard for Low-Expansion

Foam, shall apply to merchant vessel foam systems, except as modified by this chapter.

6-2 Fixed Low Expansion Foam Systems Protecting Machinery Spaces

6-2.1 Low expansion foam systems for fire extinguishing systems protecting machinery spaces shall be capable of discharging a sufficient quantity of 'foam to provide a foam depth of at least 6 in. (152.4mm) over the largest single area over which fuel oil is likely to spread within 3 to 5 minutes. The system shall be capable of generat ing foam suitable for extinguishing hydrocarbon fires. Means shall be provided for effective distribution of tlae foam through a permanent system of p i p i n g a n d control valves to suitable discharge outlets and for die foam to b e effectively directed by fixed foam oudets onto other fire hazards in the protected space.

6-2.2 System controls shall be readilyaccessible, simple to operate mid. grouped together in as few locations as possible at positions not hkely to be cut off by a fire in tile protected space.

6-3 FIXED DECK LOW EXPANSION FOAM SYSTEMS

6-3.1 The foam system shall be capable of delive ring foam to the entire cargo tanks deck area, as well as into any cargo tank, the deck of which has been ruptured.

6-3.2 The main control station for the system shall be located outside the cargo area, adjacent to the accommodat ion spaces and readily accessible and operable in the event of fire in the main area protected.

6-$.$ Operation of a deck foam system at its maximum foam solution flow rate shall still permit the simultaneous use of other devices operating f rom the main system.

6-3.4 The rate of application of foam solution for spill fires on deck shall not be less than the greatest of the following:

A. For Hydrocarbon Fuels (1) 0.16 gpm/sq f t (6.52 l / m i n / m 2 ) over 10 percent of cargo tanks

deck area, where cargo tanks deck area is the maximum breadtl~ of the ship multiplied by the total longitudinal extent of the cargo tank spaces or,

(2) 0.24 gpm/sqf t (9.78 I / r a in /m2) of the horizontal sectional area of the single tank having the largest such area (Note: This is for a single tank incident, f fmore than one tank can be involved in an incident, the application rate should be applied over the total number of tanks that can be involved.) or,

(3) 0.07 gpm/sq f t (28.52 I / m i n / m 2 ) of the area protected by the largest monitor, such area being entirely forward of die monitor, but not less than 330 gpm (1250 I /min) .

B. For Polar Solvent Fuels (1) 10percen t of the highest foam application rate for the polar

solvent fuel that can be transported by the ship times the cargo tanks deck area, where cargo tanks deck area is the maximum breadth of the ship multiplied by the total longitudinal extent of the cargo tank spaces or,

(2) 4.5 Percent of the highest foam application rate times the area protected by the foam monitor or,

(3) the ilighest foam application rate for the polar solvent fuel that can be transported times the area of the largest tank. (Note: This is for a single tank incident, f fmore than one tank can be involved in -an incident, the application rate should be applied over the total number of tanks that can be involved.)

6-3.5 Discharge Duration -Sufficient foam concentrate shall be supplied to ensure at least 30 minutes of operation.

6-4 Foam Outlet Devices - At least 50 percent of the foam solution supply rate shall be delivered f rom each monitor.

Exception: On tankers less than 4000 tons dead weight, hand hoselines only may be installed provided that the capacity of each hand hoseline is at least 25 percent of the total foam solution flow rate.

6-5 Monitors. 6-5.1 The capacity of any monitor shall be at least 0.07 gpm/sq f t

(2.85 I / m i n / m 2 ) of the deck a reapro tec ted by that monitor, with such area being entirely forward of the monitor. The capacity of each moni tor shall be not less than 330 gpm (1250 Ipm).

6-5.2 The distance from the monitor to the furthest extremity of the protected area forward of the monitor shall be not more than 75 percent of the moni tor throw in still air conditions.

6-5.3 A foam moni tor and hand hoseline connections shall be situated both port and starboard at the front of the accommodation spaces facing the cargo t:mks deck.

Exception: On tankers of less than 4000 tons dead weight, band hoseline connections only may be situated both port and starboard at the front of the accommodation spaces facing die cargo tanks deck.

6-6 Hand Hoselines. 6-6.1 Hand hoselines shall be provided to ensure flexibility of

action during firefighting operations and to cover ,areas obstructed from the monitors. The capacity of any hand hoseline shall be not less than 110 gpm (416.4 lpm) and die hand hoseline throw in still air conditions shall be not less than 50 feet (15.3 meters). The number of foam hand hoselines provided shall be not less than four. The number and location of foam solution outlets shall be such that foam from at least two hand hoselines can be simultaneously directed onto any part of the cargo tanks deck area.

6-7 Isolation Valves. 6-7.1 System control valves shall be provided in the water, foam

concentrate and foam solution mains where this is an integral part of die deck foam system, immediately forward of any moni tor position, to isolate damaged sections from those mains. In addition each moni tor and hose stadon shall have an isolation valve.

6-8 Hangers, Supports, and Protection of Pipe Work 6-8.1 Where there is a possibility of explosion, pipework shall be

routed to afford the best protection against damage. 6-8.2 All hangers and piping supports shall be designed for marine

applications. Attachments can be made to steel members and equipment supports subject to review and approval by the Authority HavingJurisdiction.

N F P A 11 - - A 9 7 R O P

SUBSTANTIATION: T he Commi t tee feels that there is a need for mar ine applications and wishes to address fills subject in die s tandard. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 1 ABSTENTION: 1 N O T RETURNED: 3 Jesclard, Lake, Nazario

EXPLANATION OF NEGATIVE: PLJRVIS: Informat ion in Chapter 6 draft is inadequate and in

certain areas contradicts the existing U.S. Coast Guard regulations. For example the operat ing t ime for a hydrocarbon type system has not been defined. As stated the proposed design criteria is based on a spill fire. However in actual applications the fire scenario will likely be much worse d lan a spill fire on the deck area. In brief the chapter need fur ther rewrite and has too many discrepancies and errors to make it acceptable. EXPLANATION OF ABSTENTION:

MELDRUM: My reason for abs tent ion was simply because I did no t bare an oppor tuni ty to compare the proposed Chapter 6 with the cur rent r equ i rements o f the of the US Coast Guard, so I was reluctant to vote ei ther for or against the proposal.

(Log #2) 11- 13 - (6-3.$(0): Accept in Principle SUBMITTER: Fred M. Linde, National Foam, Inc. RECOMMENDATION: Delete (0 entirely

"foam quality (expansion and 1 / 4 drain t ime)" SUBSTANTIATION: I note with interest r equ i r emen t (0 for testing foam systems foam quality.

This part icular test has in the past been referred to as a laboratory type test in die appendix.

Reference 198g edit ion p a ~ g r a p h A-5.2.4 W h e n used ,as a laboratory type test u n d e r tightly control led test

field condit ions it is a very useful tool in the design of discharge devices and foam concentrate formulat ions. It also relates very well to compare full size devices against minia ture devices used for fire testing.

However this particular test is at best extremely difficult to control unde r field conditions. Appendix C even alludes to dais and indicates sampl ing variations that may create up to several h u n d r e d percent error in the recorded results. In addit ion to sampl ing variations of this magni tude there are no specified criteria to meet.

Paragraph 6-3.3 specifically defines the r equ i r emen t for acceptable ranges of foam concentra t ion but no r equ i r emen t for expansion and drainage (1 /4 life). How can a test be requi red with no criteria to adhere to?

I find it very difficult to justify the cost to the ult imate end user of per forming this test that produces nebulous results and doesn ' t have to mee t any specific requirements . I can foresee all kinds of problem being created by dais test r equ i r emen t du r i ng acceptance mad rout ine testing of foam systems.

It is also becoming more and more environmental ly d e m a n d i n g to collect all discharge f rom fire protect ion systems. Whatever m e t h o d is used to collect this discharge f rom the system may very well impact the character of the f inished foam such that expans ion /d ra inage results no longer represen t what came out of the discharge device. COMMITTEEACTION: Accept in Principle.

Delete last sen tence arid revise (f) as follows: (0 Foam quality (expansion and 1 / 4 dra in time) shall be con-

ducted or the foam discharge shall be visually inspected to ensure that it is satisfactory for the purpose in tended. COMMITTEE STATEMENT: T he Commit tee feels that a discharge test is necessary. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 N O T RETURNED: 3 Jesclard, Lake, Nazario

(Log #Sa) 11- 14 - (Appendix B): Accept in Principle SUBMITTER: Keith Olson, Ansul Fire Protection RECOMMENDATION: The following changes should be made to Appendix B Storage Tank Protection Summary as follows:

Hydrocarbon NotAppti~--dole Top-of-seal prote~cdon withfoarrkdam Application at 0.30 g p m / f t z (12.2 l p m / m z) Rates of annular fin~ area. Allq3elo~the-seai

with or withou~foam dam at 0.50 g p m / f t 2 (20.4 I p m / m 2)

SUBSTANTIATION: None. COMMITTEE ACTION: Accept in Principle. All applications below the seal with or without a foam d a m 0.5

gpm/sqf t . COMMITTEE STATEMENT: Meets the in tent of the submitter. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log #CP4) 11- 15 - (Appendix B): Accept SUBMITTER: Technical Commit tee on FoanL

I RECOMMENDATION: CharJge head ing Appendix B for floating roof tanks to:

"Applicable floating roof tanks (Open Top or Covered) Annular Seal Area." SUBSTANTIATION: Floating roof tanks are defined in 3-4.1 COMMITTEE ACTION: Accept- NUMBER OF COMM/TTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NEGATIVE: 1 N O T RETURNED: 3 Jesclard, Lake, Nazario

EXPLANATION OF NEGATIVE: OLSON: I do no t feel the head ing for Appendix B can be changed

to "Applicable Floating Roof Tanks (open top or covered) Annu la r Seal Area" because dais summary table covers all types of tanks. I believe the cur ren t tide "Storage Tank Protection Summary" is correct.

(Log #CP5) 11- 16 - (Appendix B): Accept SUBMITTER: Technical Commit tee on Foam, RECOMMENDATION: Revise Appendix B, Top Side Foam Application, Hydrocarbon Application Rates, Floating Roof Tanks, as follows:

"0.3 g p m / s q f t ( 1 2 . 2 L / m i n / s q m) of annu la r ring area, above seal, between tank wall and foam dam, (see 3-3)" SUBSTANTIATION: Further clarification of above seal protection is needed. COMMITrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 N O T RETURNED: 3 jesclard, Lake, Nazario

(Log #CP1) 11- 17 - (Appendix E (New)): Accept SUBMITTER: Technical Commit tee on Foam, RECOMMENDATION: Add Foam Environmental Issues Report to append ix E, r e n a m e existing append ix E to appendix F.

Appendix E Foam Environmental Issues E-1 Overview. Fire Fight ing foams as addressed in dais s tandard

serve a vital role in fire protect ion t h r o u g h o u t the world. Thei r use has proven to be essential for the control of f lammable liquid fire threats i nhe ren t in airport operations, fuel farms and pe t ro leum processing, ltighway and rail t ransportat ion, mar ine applications, and industrial facilities. The ability of foarn to rapidly ext inguish f lammable liquid spill fires has undoubted ly saved lives, r educed property loss, and he lped minimize the global pollut ion which could result f rom the uncont ro l led bu rn ing of f lammable fuels, solvents, and industrial liquids.

However, with t he ever increasing envi ronmenta l awareness, recent concern has focused on the potential adverse envi ronmenta l impact of foam solution discharges. Tile pr imary concerns are fish toxicity, biodegradability, treatability in waste water t rea tment plants, and nut r ien t loading. All of these are of concern when the end-use foam solutions reach natural or domest ic water systems. Additionally, the US Environmental Protection Agency bas h ighl ighted a potential problem with some foam concentrates by placing glycol ethers and ethylene glycol, c o m m o n solvent const i tuents in some foam concentrates, on the list of hazardous air pollutants unde r the 1990 Clean Air Act Amendmen t s .

The purpose of this appendix is to: (a) Provide foam users with summary informat ion on foam

environmenta l issues, (b) Highl ight applicable regulatory status, (c) Offer guidefines for coping with regulat ions and provide

suggested sources for addit ional information, and (d) Encourage p lann ing for foam discharge scenarios ( including

prior contact with local waste water t rea tment plant operators).

N F P A 11 ~ A 9 7 R O P

It should be emphas ized that it is n o t the in ten t of this appendix to limit or restrict file use of fire f ight ing foams. The foam commit tee believes tha t the fire safety advantages of us ing foam are greater than the risks of potential env i ronmenta l problems. The ul t imate goal of dais section is to foster use of foam in an environmental ly respon- sible m a n n e r so as to minimize risk f rom their use.

E-2 Scope. The informat ion provided in this section covers foams for Class B combust ible a nd f lammable liquid fuel fires. Foams for this purpose include protein foam, f luoroprote in foam, f i lm-forming f luoroprote in foam (FFFP), arid synthetic foams such as aqueous film forming foam (AFFF).

Some foams contain solvent const i tuents wlfich may require report ing u n d e r Federal, State, or Local envi ronmenta l regulations. In general, synthetic fo~uns, such as AFFF biodegrade more slowly than protein based foartls. Protein based foams may be more p rone to nu t r ien t loading and t r ea tment facility "shock loading" due to their high a m m o n i a ni t rogen con ten t and rapid biodegradat ion respectively.

This section is primarily conce rned widl the discharge of foam solutions to waste water t rea tment facilities and to the environment . The discharge of foam concentrates, while a related subject, is a m u c h less c o m m o n occurrence. All marmfacturers of foam concentrate deal with clean-up and disposal of spilled concentrate in their MSDS sheets and product literature.

E-3 Discharge Scenarios. A discharge o f foam water solution is most likely to be the result o f one of four scenarios: manua l fire f ighting or fuel b lanket ing operations, training, foam equ ipmen t system tests, or fixed system releases. These four scenarios include events occurr ing at such places as aircraft facilities, fire f ighter t raining facility, and special hazards facilities (which include f l ammab le /haza rdous ~rarehouses, bulk f lammable liquid storage facilities and hazardous waste storage facilities). Each scenario is considered separately below:

E-3.1 Fire Fighting Operat ions. Fires occur in many types of locations and u n d e r many different circumstances. In some cases it is possible to collect the. foam solution used, and in others, such as in mar ine fire f ighting, it is not. These types of incidents would include aircraft rescue and fire f ight ing operations, vehicular fires (cars, boats, train cars), structural fires with hazardous materials, and f lammable liquid fires. Foam water solution which has been used in fire f ighting operat ions will probably be heavily con tamina ted with the fuel or fuels involved in the fire. It is also likely to have been diluted with water d ischarged for cooling purposes.

In some cases, the foam solution used du r ing fire d e p a r t m e n t operat ions can be collected. However, it is no t always possible to control or contain the foam. Tills can be a consequence of the location of the incideat or the circumstances su r round i ng it.

Event-initiated manua l con t a i nmen t measures are the operat ions usu~ly executed by the respond ing fire depa r t men t to contain the flow of foam water solution when condit ions and manpower permit. Those operat ions include the following measures:

(a) Blocking sewer drains. This is a c o m m o n practice used to prevent con tamina ted foam water solution f rom enter ing the sewer system unchecked. It i.s then diverted to an area suitable for conta inment .

(b) Portable dikes. These are generally used for land-based operations. They can he set up by tile fire depa r t men t personnel dur ing or after ex t ingu i shmen t to collect run-off.

(c) Portable booms. These are used for mar ine based operat ions which are set up to contain foam in a def ined area. These generally involve the use of floating booms within a natural body of water.

E-3.2 Training. Tra in ing is normally conducted u n d e r circum- stances conducive to the collection of spen t foam. Some fire training facilities have lind elaborate systems des igned and con- strncted to collect foam solution, separate it f rom the fuel, treat it and, in some cases, reuse the t reated water. At a m i n i mum, most fire t raining facilities collect the foam solution for discharge to a waste water t r ea tment facility. Tra in ing may include the use of special t raining foams or actual fire f ighting foams.

Tra in ing facility desigti should inchlde a con ta inmen t system. The waste water t r ea tment facility mus t first be notified, and give permission for the agen t to be released at a prescr ibed rate.

E-3.3 System Tests. Test ing primarily involves engineered, fixed foam fire ex t inguish ing systems. Two types of tests are conduc ted on foam systems: acceptance tests, conduc ted pu r suan t to installation of the system, and ma in t enance tests, usually conduc ted annual ly to ensure tile operability of file system. These tests can be a r ranged to pose no hazard to the envi ronment . It is possible to test some systems using water or o ther non-foaming, environmental ly acceptable liquids in tile place of foam concentrates Kthe Authori ty HavingJ

jurisdict ion permits such substi tutions. In the execut ion of both acceptance and ma in t enance tests, only a

small a m o u n t of foam concentra te should be disclaarged to verify the correct concent ra t ion of foam in the foam water solution. Desig-

na ted foam water test ports can be des igned into the piping system so tha t the discharge of foam water solution can be directed to a control led location. The control led location can consist of a portable tank wilich would be t ranspor ted to an approved disposal site by a l icensed contractor. Tile r ema inde r of the acceptance test and ma in tenance test should be conduc ted us ing only water.

E-3.4 Fixed System Releases. This type of release is generally uncontrol led, whether the result o f a fire incident or a malfunct ion in the system. The foam solution discharge in this type of scenario may be dealt with by event-initiated operat ions or by eng ineered con ta inmen t systems. Event-initiated operat ions encompass the same temporary measures flaat would be taken dur ing fire depart- m e n t operations; portable dikes, floating booms, etc. Engineered con ta inmen t would be based mainly on the location and type of facility, and would consist o f ho ld ing tanks or areas where the con tamina ted foam water solution would be collected, treated and sent to a waste water t rea tment facility at a prescribed rate.

E-4 Fixed Systems. Facilities can be divided into those without an eng ineered con ta inmen t system and those with an engineered con ta inmen t system.

E-4.1 Facilities Without Engineered Conta inment . Given the absence of any past requi rements to provide conta inment , many existing facilities simply allow the foam water solution to flow out of the building and evaporate into file a tmosphere or percolate into the ground. The choices for con ta inmen t of foam water solution at such facilities fall into two categories: event-initiated manual con ta inmen t measures, and installation of engineered con ta inment systems.

Selection of the appropriate choice is d e p e n d e n t on the location of the facility, the risk to the envi ronment , the risk of an automat ic system discharge, the f requency of automat ic system discharges and any applicable rules or regulations.

"Event-initiated manua l con ta inmen t measures" will be file most likely course of act ion for existing facilities without eng ineered con ta inmen t systems. This may fall unde r the responsibility of the respond ing fire d e p a r t m e n t and include such measures as blocking s torm sewers, cons t ruc t ing temporary dikes, and deploying floating booms. The degree of such measures will primarily be dictated by location as well as available resources and manpower .

The "installation of eng ineered con ta inmen t systems" is a possible choice for existing facilities. Retrofitting an eng ineered contain- m e a t system is costly, and may adversely affect facility operatioas. There are special cases, however, which may warrant the design .and installation of such systems. Such action is a considerat ion where an existing facility is immediately adjacent to a natural body of water and has a h igh f requency of activation.

E-4.2 Facilities With Engineered Conta inment . Any engineered con ta inmen t system will usually incorporate an oil /water separator. Dur ing normal dra inage condit ions (i.e., no foam solution runoff), the separator funct ions to remove any fuel particles f rom drainage water. However, when foam water solution is flowing tile oi l /water separator mus t be bypassed so that file solution is diverted directly to storage tanks. This can be accompl ished automatically by the installation of motorized valves set to open the bypass line upon activation of tile fixed fire extinguislt ing systems at the protected property.

The size of the con ta inmen t system is d e p e n d e n t on the durat ion of the foam water flow, tile flow rate, and the max i tnmn anticipated rainfall in a 24-hour period. Most new con ta inmen t systems will probably only accommoda te individual buildings. However, some con ta inmen t systems may be des igned to accommoda te multiple buildings d e p e n d e n t upon the topography of the land and early identification in file overall site p lann ing process.

Tile specific type of con ta inmen t system selected will also be d e p e n d e n t u p o n location, desired caIiacity and funct ion o f facilities in question. They include ear then retent ion systems, below g r o u n d t a n ~ , open-top ing round tanks, and sump and p u m p designs (i.e., lift stations) piped to aboveground or i ng round tanks.

The ear then re tent ion designs consist of open-top ear then berms, which usually rely upon gravity fed dra inage p ip ing f rom the protected building. They may simply allow the foam water solution to percolate into file ground, or may include an impermeable liner. Those conta in ing an impermeable l iner may be connec ted to a waste water t rea tment facility or may be suction p u m p e d out by a l icensed c o n t r a c t o r .

Closed-top, below g r o u n d storage tanks may be the least environ- mentally acceptable design approach. They usually consist of a gravity-fed piping a r rangement , and can be suct ion p u m p e d out or p iped to a waste water t r ea tmen t facility. A potential and often f r equen t problem associated with this design is file leakage of g r o u n d water or unknown liquids into the storage tank.

Open-top, below g r o u n d storage tanks are generally l ined concrete tanks which may rely on gravity-fed drainage piping or a s u m p and p u m p a r rangement . These may accommoda te individual or mult iple buildings. They mus t also accommoda te the m a x i m u m

N F P A 11 ~ A 9 7 R O P

anticipated rainfall in a 24-hour period. These are usually piped to a waste water t r ea tmen t facility.

Aboveground tanks incorporate a s u m p and p u m p a r r a n g e m e n t to closed, aboveground tanks. Such designs usually incorporate the use of one or more submersible or vertical shaft, large capacity pumps . These may accommoda te individual or mult iple buildings.

E-4.3 New Facilities. T he decision to design and install a fixed foam water solution con t a i nmen t system is d e p e n d e n t on the location of d~e facility, the risk to the envi ronment , possible impa i rmen t of facility operat ions, the design of the f ixed foam system (i.e., automatically or manual ly activated), the ability of the respond ing fire d e p a r t m e n t to execute event-initiated con t a inmen t measures a n d any per t inent regulations.

New fadli t ies may n o t warrant the expense and problems associated with con ta inmen t systems. Where the location of a facility does no t endange r g r o u n d water or any natural bodies of water, this may be an acceptable choice, provided the fire d e p a r t m e n t has p lanned emergency manua l c o n t a i n m e n t measures .

Where condit ions warrant the installation of eng ineered contain- m e n t systems, the re are a n u m b e r of considerations. T hey include size of conta inment , des ign a n d type of con t a i nmen t system, and the capability of the con t a i nmen t system to hand le individual or mult iple buildings.

Engineered con t a i nmen t systems may be a r e c o m m e n d e d protective measure where foam ext inguishing systems are installed

facilities tha t are immediate ly adjacent to a natural body of water. These systems may also be p r u d e n t at new facilities where site condit ions permi t to avoid impa i rmen t of facility operations.

E-5 Disposal Alternatives. T h e uncon t ro l l ed release of foam solutions to the env i ronmen t shou ld be avoided. Alternative disposal opt ions are as follows:

(a) Discharge to a wastewater t r ea tmen t p lant with or without pre t reatment ,

(b) Discharge to the env i ronmen t after pre t rea tment , (c) Solar evaporation, and (d) t ransportat ion to a wastewater t rea tment plant or hazardous

waste facility. Foam users, as part of their p lann ing process, should make

PalrOvisions to take the actions necessary to utilize whichever of these teruatives is appropr ia te for their situation. T he section below

describes the actions which may be taken, depend i ng on the disposal alternative which is chosen.

E-6 Collection and Pre t r ea tmen t of Foam Solutions Prior to Disposal.

E-6.1 Collection a nd Conta inment . The essential first step in employing any of these alternatives is collection of the foam solution. As no ted above, facilities tha t are protected by foam systems normally have systems to collect and hold fuel spills. These systems may also be used to collect and hold foam solution. Tra in ing facilities are, in general , des igned so tha t foam solution may be collected and held. Firefighters r espond ing to fires which are at o ther locations should at tempt, insofar as it is practical, to collect foam solution run-off with temporary dikes or o ther means.

E-6.2 Fuel Separation. Foam solution which has been discharged on a fire and subsequent ly collected will usually be heavily contami- na ted with fuel. Since mos t fuels present their own envi ronmenta l hazards and will interfere with foam solution pret reatment , an a t t empt shou ld be made to separate as m u c h fuel asposs ib le f rom the foam solution. As noted above, the tendency of foam solutions to form emuls ions with hydrocarbon fuels will interfere with rite operat ion of conventional fuel-water separators. An alternative is to hold the collected foam solution in a p o n d or lagoon until die emuls ion breaks and the fuel may be separated by skimming. This may take from several hours to several days. Dur ing this time, agitation should be avoided to prevent the emuls ion f rom refortrv ing.

E-6-3 Pre t r ea tmen t Prior to Discharge. E-6-3.1 Dilution. Foam manufac ture rs and foam users r e c o m m e n d

dilution of foam solution before it enters a wastewater t r ea tmen t plant. The re is a range of opin ion on the o p t i m u m degree of dilution. It is generally considered tha t the concent ra t ion of foam solution in the plant inf luent shou ld no t exceed 1700 p p m (588 gallons of p lant in f luent per gallon o f foam solution). This degree of dilution is normally sufficient to prevent shock loading and foaming in the plant. However, each wastewater t r ea tmen t p lan t mus t be considered as a special case, a n d those p l a n n i n g a discharge of foam soh.ltion to a wastewater t r ea tmen t facility shou ld discuss dais subject with the operator o f the facility in advance.

Dilut ing waste foam solution 588 to 1 with water is an impractical task for most facilities, especially when large quanti t ies of foam solution are involved. The r e c o m m e n d e d p rocedure is to dilute the foam solution to the m,xximum a m o u n t practical and t hen me te r the di luted solution into the sewer at a rate which will, based on the total volume of p lant influent, p roduce a foam solution concent ra t ion of 1700 p p m or less.

For example, if the discharge is to be made to a 6 mill ion g a l / d a y t rea tment plant, foam solution could be discharged at the rate of 7 g p m (6,000,000 g a l / d a y divided by 1440 m i n u t e s / d a y divided by 588 equals 7 gpm) . The difficulties of me te r ing such a low rate of discharge can be overcome by first di lut ing the foam solution by 10 or 20 to 1, permi t t ing discharge rates of 70 or 140 g p m respectively.

Dilution shou ld also be considered if the foam solution is-to be discharged to the env i ronmen t in order to minimize its impacL

E-6-3.2 Defoamers. The use o f d e f o a m e r s will decrease, bu t not eliminate, foaming of the foam solution du r ing pumping , dilution and t reatment . The foam manufac tu re r s h o u l d b e consul ted for r ecommenda t ions as to the choice of effective defoamers for use with a particular foam concentrate .

E-6-3.3 Othe r Pre t reatments . Several chemical and mechanical pre t rea tments such as precipitat ion, coagulation, absorpt ion on activated carbon and ultra filtration (reverse osmosis) have been s tudied experimentally. There was no known instance of these processes having been used in the field at the t ime of the prepara- t ion of this document . Foam users should contact the foam manufac tu re r for up-to-date informat ion on this subject.

E-7 Discharge of Foam Solution to Wastewater T r e a u n e n t Facilities. Biological t r ea tment of foam solution in a wastewater t r ea tmen t facilityis an acceptable m e t h o d of disposal. However, foam solutions have the potential to cause plant upsets and other problems if no t carefully handled. There are several reasons for this:

E-7.1 Fuel Contaminat ion. Foam solutions have a tendency to emulsify hydrocarbon fuels and some polar fuels which are only slightly soluble in water. Water-soluble polar fuels will mix with foam solutions. T h e format ion of emuls ions Will upse t the operat ion of fue l /water separators and potentially cause the carryover of fuel into the waste stream. Many fuels are toxic to the bacteria in wastewater t r ea tment plants.

E-7.2 Foaming. The active ingredients in foam solutions will cause copious foaming in aerat ion ponds, even at very low concentrat ions. Aside f rom the nuisance value of dais foaming, the foaming process tends to suspend activated s ludge solids in the foam. These solids can be carried over to the ouffall of the planL Loss of activated sludge solids can also reduce the effectiveness of the wastewater t reatment . This could cause water quality problems such as nu t r ien t loading in the water way to which the outfall is discharged. Because some surfactants in foam solutions are highly resistant to biodegra- dation, nuisance fomning may occur in the ouffall waterway.

E-7.3 BOD (Biological Oxygen Demand) . Foam solutions have h igh BOD's compared to the normal inf luent of a wastewater t r ea tmen t plant. If large quanti t ies of foam solution are discharged to a wastewater t r ea tmen t plant, "shock loading" can occur, canslng a p lant upset.

Before discharging foam solutions to a wastewater t rea tment plant, the plant operator should be contacted. This should be done as part of the emergency p lann ing process. The plant operator will require, at a m in imum, a Material Safety Data Sheet on the foam concen- trate, an estimate of the five day BOD content of the foam solution, an estimate of the total volume of foam solution to be discharged, the t ime period over which it will be discharged and, if the foam concentrate is protein-based, an estimate of the a m m o n i a ni t rogen con ten t of the foam solution.

The foam manufac tu re r will be able to provide BOD and a m m o n i a ni t rogen data for the foam concentrate , f rom which the values for foam solution may be calculated. The other requi red information is site-specific and mus t be developed by the operator of the facility f rom which the discharge will occur.

E-7.4 Foam concentrates or solutions may have an adverse effect on microboilogically based oily water t r ea tmen t facilities. The en d user should take due account of this before d ischarging foam systems du r ing test ing or training. E-8 Foam Product Use Repor t ing Federal (U.S.), State and Local envi ronmenta l jurisdict ions have certain chemical repor t ing requirements , which apply to chemical const i tuents within foam concentrates . In addit ion there are also requi rements which apply to file f lammable liquids to which the foams are be ing applied.

For example, according to the U.S. Environmenta l Protection A~_~nlcY (EPA) The following guidel ines mus t be adhe red to.

Releases of e thylene glycol in excess of 5,000 p o u n d s are reportable u n d e r U.S. EPA Comprehens ive Environmenta l Response Compen- sation & Liability Act (CERCLA) Sections 102(b) & 1- 03(a). Ethylene glycol is generally used as a freeze point suppressant in foam concentrates.

E-8.2 As of J u n e 12, 1995 the EPA issued a final rule 60 CFR 30926 on

several broad categories of chemicals. , including the glycol ethers. The EPA has no reportable quant i ty for any of the glycol ethers. Thus foams containing glycol ethers (butyl carbitol) are not subject to EPA reporting. Consult the foam manufac ture rs MSDS to

10

N F P A 11 ~ A 9 7 R O P

dete rmine if glycol ethers are conta ined in a particular foam concentrate.

E-8.3 The EPA does state tha t CERCLA liability cont inues to apply to

releases o f all c o m p o u n d s within the glycol e ther category, even ff repor t ing is no t required. Parties responsible for releases o f glycol ethers are liable for the costs associated with c leanup and any natural resource damages result ing from die release.

E-8.4 The end user shou ld contact the relevant local regulat ing authori ty

regarding specific cur ren t regulations. E-9 Environmental Prnperties of Fluorochemical Surfactants.

Some fire f ight ing agents contain surfactants. Two examples are AFFF agents and f luoroprote in foams. Fluorochemicals are organic (carbon-containing) c o m p o u n d s in which a por t ion of the Iwdrogen atoms have been rep laoedby fluorine atoms. Unlike chlorofluoro- carbons (CFC's) and s o m e other volatile f luorocarbons, f luorochemical surfactants are not ozone deple t ing and are no t restricted by tile Montreal Protocol or related regulations. Fluorochemical surfact~mts also have no effect on global warming or climate change.

Surfactants or surface active agents are c o m p o u n d s that bave both a strongly "water-loving" port ion and a strongly "water-avoiding" portion. Soaps and detergents are surfactants commonly used in c leaning products. Surfactants concentra te at d ie surface or boundary between two phases and they lower the surface tension of liquids in which they are dissolved. Tbe water-avoiding part of f luorochemical surfactants is the f luorocarbon portion.

Fluorocbemical surfactants bare a property that makes them uniquely suited for use in foams used to prevent or ext inguish fires of f lammable liquids. They create the lowest surface tension of any known class of surfactant. This low surface tension allows aqueous films or foams c o n u d n i n g these surfactants to spread over and seal the surface of hydrocarbon liquids, ext inguishing the f lames and prevent ing evaporation of tile f l ammable liquids. No o t t e r type of surfactant can do this as effectively. Thus , if all o ther factors are equal, fire f ight ing agents conta in ing f luorocbemical surfactants can ext inguish f lammable liquid fires more quickly and with smaller amoun t s of exdnguishilag agen t than agents without f luorochemical surfactants. The many envi ronmenta l advantages of this and the potential benefits to life and proper ty are obvious.

There are envi ronmenta l concerns with f luorochemical surfactants which mus t be kept in m i n d wben us ing these products for ext inguishing fires or fi)r fire ex t ingu i shment training, such as listed below:

(a) Fluorochemical surfhctants, like all surfactants, have toxicity. (b) Like other surfactants, they cause foaming. (c) Like some surfactants, dley are persistent; in fact, the

f luorochemical port ions of fllese surfactants are no t known to fully biodegrade.

(d) Also like some other surfactants, t heya re mobile in the envi ronment . They can move with water in aquatic systems and leach th rough soil.

(e) In some cases, f luorochemical surfactants may have some affinity for living systems.

In the following paragraphs, we will explain what each o f these propert ies mean and what this m e a n s in te rms of bow these c o m p o u n d s should be handled.

E-9.1 Toxicity ofFluorocbemical Surfactants. Firefighting agents, used responsibly and following label and material safety data shee t iustrnctions, pose little toxicity risk to people. However, some toxicity does exist. The toxicity of the surfactants in fire f igbdng foams, including the f luorochemical surfactants, is a reason to prevent unnecessary exposure to people a n d to the envi ronment . It is a reason to contain and properly treat AFFF wastes whenever feasible. O n e shou ld always make plans to contain wastes f rom training exercises and m treat t hem following the suppl ier ' s disposal r ecommenda t ions as well as the requ i rements of local authorities.

Water flint foams when shaken due to contaminat ion f rom firefighting foam shoultd no t be ingested. Even when foaming is no t present, it is p ruden t to evaluate the l ikelihood of dr inking water supply contaminat ion, and to use al ternate water sources until one is certain tha t suffactant concentrat ions of concern no longer exist. Suppliers of f lrefighting foams should be able to assist in evaluating the hazard and r e c o m m e n d i n g laboratories that can do appropriate analysis when necessary.

E-9.2 Fluorochemical Surfactants and Foaming. Fluorochemical surfactants can cause 133truing a tvery low concentrat ions. This can cause aesthetic p rob lems in rivers a n d streams, and both aesthetic and o p e r a d o n a l p r o b l e m s in sewers and wastewater t r ea tmen t systems. W h e n too m u c h firefighting foam is d ischarged at one time to a wastewater t r ea tmen t system, serious foaming can occur. The bubbles of foam that form in the t r ea tmen t system trap and br ing flocks of the activated s ludge that t reat the water in the t r ea tmen t

system m file surface, f f t h e foam blows o f f the surface o f the t r ea tmen t system, it leaves a black or brown sludge residue where the fomn lands and breaks down.

If too m u c h of the activated s ludge is physically removed f rom the t r ea tmen t system in foam, the operat ion o f the t r ea tmen t system can be impaired. O the r waste passing th rough the t r ea tment system will be incompletely treated until tile activated s ludge concentra t ion again accumulates . For this reason, the rate off i ref ight ing foam discharge to a t r ea tment system has to be controlled. For this reason, die rate of f irefighting foam discharge to a t r ea tment system has to be controlled. Somewhat h igher f irefighting foam discharge rates may be possible when and-foaming agents are used. Foam concentra te suppliers shou ld be contracted for guidance on discharge rates and effective ant i-foaming agents.

E-9.3 Persistence ofFluorochemica l Surfactants. The f luorochemical port ions of f luorocbemical surfactants are known to be very resistant to chemical and biochemical degradat ion. This means dlat while die non-f luorochemical port ion of these surfac- t in t s may break down, a persistent f luorocbemical port ion will remain. Tbe persistent f luorochemical port ion is most likely to still be a surfactant. This means that after f luorochemical surfactant conta in ing f irefighting waste are fully treated, the waste residual could still form some foam when shaken. It could "also still have some toxicity to aquatic organisms if it is no t sufficiently diluted. Some non-f luorochemical surfactants are resistant to t rea tment too. The mos t desirable t rea tment me thods for large volume firefighting waste s t reams conta in ing f luorochemical surfactants are physical chemical pre t rea tments that remove most of the f luorocbemical surfactant prior to discharging the residual waste to a wastewater t r ea tment system.

E-9.4 Mobility of Fluorochemical Surfactants. Tests and experi- ence have shown that some f luorochemical surfactants can leach th rough at least s o m e soil types. The resistance o f f l u o r o c h e m i c a l surfactants to biodegradat ion makes the mobility of such surfactants a potential concern. While a readily degradable c o m p o u n d is likely to degrade as it leaches t h rough soil, this won ' t h a p p e n to a f luorochemical surfactant. Tbus , if allowed to soak into the ground, f luorochemical surfactants that d o n ' t become b o u n d to soil componen t s may eventually reach g r o u n d water or flow out of the g r o u n d into surface water. If adequate dilution has not occurred, they may cause foaming or concerns about toxicity. Therefore, it is inappropriate to allow training waste to continually seep into soil especially in areas where water resources could be contaminated .

Fluorochemical surfactants that enter aquatic env i ronments may bind to solid materials, but thi s b inding would he reversible an d temporary. Fluorochemical surfactants are thus expected to move widl the flowing water in aquatic env i ronments until dley reach and dilute to extremely low concentra t ions in die oceans.

E-9.5 Fluorocbemical Surfactants and Living Systems. Fluorochemical surfactants or their persistent degradat ion products are likely to be anionoic or negatively charged compounds . As such, they could form s t rong ion pairs with positively charged molecules. Since positively charged molecules are f requent ly found in living organisms this could be a mechan i sm of affinity for livinl~.s.ystems. The release of f luorochemical surfactants back into non-uwng port ions of die env i ronmen t could be slow because these ionic associations could be strong. SUBSTANTIATION: With ever increasing envi ronmenta l aware- ness, recent concern has focused on die potential adverse environ- mental impact of foam solution discharges. It is the Foam Commit tee ' s in tent to include this appendix to provide foam users with summary informat ion on foam environmenta l issues, h ighl ight applicable regulatory status, offer guidel ines for coping with regulations, provide suggested sources for additional information, and encourage p l a n n i n g f o r foam discharge scenarios ( including contact with local waste water t rea tment plant operators). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NEGATIVE: 1 N O T RETURNED: S Jesclard, l ake , Nazario

EXPLANATION OF NEGATIVE: MELDRUM: My reason for file negative vote on the proposed

Appendix E, Foam Environmental Issues, relates to page 4 with the paragraph beg inn ing "Flourochemical surfactants have a property ... and ending ... and property are obvious."

This paragraph is inappropriate even as appendix material in an NFPA Standard. It is too "selly", o ther foam c o m p o u n d s have no similar t reatment , and it is irrelevant to the discussion. In addition, it is no t entirely technically correct, i nasmuch as the film is not an effective vapor suppressan t on some aromatic hydrocarbons.

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