June 1, 2018

Massachusetts Targets Old Inventories of Firefighting Foam

Holland & Knight Energy & Natural Resources Blog
Dianne R. Phillips | Deborah E. Barnard

On May 23, 2018, the Massachusetts Department of Environmental Protection (DEP), in conjunction with the Massachusetts Department of Fire Services (DFS), announced a program to inventory and dispose of pre-2003 firefighting foam potentially containing perfluorooctane sulfonate (PFOS) and structurally related compounds known as poly- and perfluoroalkyl substances (PFAS).

Firefighting foam, also known as aqueous film forming foam (AFFF), is a highly efficient type of fire suppressant agent used to attack flammable liquid pool fires, including petroleum fires. AFFF is often used at bulk petroleum facilities, refineries, military installations and airports. It is also used to prevent fires arising from gasoline tanker rollovers or highway accidents. Older versions of the product contain these long-chain fluorinated compounds, which are persistent, water soluble compounds identified by the U.S. Environmental Protection Agency (EPA) in drinking water health advisories. Given that AFFF appears to be the source of groundwater contamination associated with tanker rollover at a rotary on Route 28 near the Otis Air National Guard base's Falmouth gate, there is increased interest in removing AFFF stockpiles from use.

Accordingly, DEP and DFS are undertaking a unique “take-back” program to remove these foams from inventory so they won’t be used in the future. To date approximately 3,800 gallons have been identified by approximately 23 different fire departments across the Commonwealth. Fire departments are asked to notify DEP by June 15, 2018, if pre-2003 inventory is found to arrange for a state contractor to remove and properly dispose of the material.

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