Technical Bulletin ANSUL ®

Number 60

ANSUL INCORPORATED
MARINETTE, WI 54143-2542
Foam and The Environment

In the last few years, we have witnessed an increase in concern about firefighting agents being released into the
environment. The production of gaseous agents like Halon 1301 and 1211 has been phased out, dry chemicals
require proper disposal, and foam agents require new and sometimes expensive treatment.
The release of a foam solution (versus foam concentrate) into the environment is a concern of the fire authority
having jurisdiction, the insurance company, and the end-user or owner of the system.
The release of foam solution can come from three conditions:
1. A fire situation
2. False activation/discharge
3. System commissioning or testing
In the fire situation, there is little concern over the foam solution (water to foam concentrate ratio is typically 99:1,
97:3 or 94:6). Of greater concern are the flammable chemicals or fuels themselves as well as the thermal break-
down/decomposition of the flammables (Class A, B & D) consumed in the fire. The cleanup required from a
major fire (structure or contents) is a major task and under the control of the local authority having jurisdiction
and environmental office.
Conditions two and three, while similar, are different in that a false activation/discharge is unpredictable and
uncontrolled, whereas the performance test is both controlled and predictable.
The following information should help in handling conditions two and three.
A few years back, there was a claim made by a European foam manufacturer that the “Natural” foams (protein)
are inherently more ecologically friendly than the synthetic foams (AFFF & AR AFFF). This was hotly debated
and may be true in some discharge scenarios and totally false in others. There is probably no one type of prod-
uct, from a compositional standpoint, that is superior to all others when all of the possible discharge scenarios
are taken into consideration.
A number of factors need to be taken into account when looking at the environment friendliness of foams: aquat-
ic toxicity, biodegradability, (both aquatic and terrestrial ecosystems), sewage plant treatability, and nutrient load-
ing.
Aquatic toxicity is a concern because much of the foam solution in the non-fire case may find its way into some
type of aquatic ecosystem. Here we are concerned with the level of toxicity with which foams may affect both
fish populations as well as the lower members of the food chain such as micro-invertabrates and algae.
Manufacturers look at the types of chemicals they use in their formulations to ensure that they do not choose
those which will cause fish kills due to the toxicity of the chemicals. Chemicals are considered to be “practically
non-toxic” if they do not cause more than 50% of a particular fish test population to die in 96 hours of exposure to
concentrations of 100 mg/L or higher. (For more information consult ANSUL Technical Bulletin No. 52.)
Biodegradability is a measure of how quickly, and to what extent, a chemical breaks down in the environment
due to the natural biological action of bacteria and fungi. Also of importance is whether or not a chemical can
“bio-accumulate” as was demonstrated in PCB’s and pesticides.
Ideally, foam concentrates should be capable of being 100% biodegraded in both aquatic and terrestrial ecosys-
tems. In reality, however, few chemicals biodegrade 100%. Generally speaking, the raw materials used in fire-
fighting foams are readily biodegradable whether they be protein, surfactants or solvents. The fluorosurfactants
used in Aqueous Film Forming Foam (AFFF) are, however, only partially biodegradable. While the surfactant
backbone of the chemical is readily biodegradable, the fluorine functional group of the chemical is resistant to
biodegradation. Fortunately, this fluorine functional group is relatively unreactive and is unlikely to cause much
harm in the environment.
Sewage treatment plant treatability is very important because in many applications the foam discharge is sent
to municipal or private treatment plants as a means of disposal. In fact, this is usually the most economical
means of disposing of discharged foam. If recovery and transportation is required, it can cost $.20 to $.30 per
gallon and $500 per day for the truck.
All types of firefighting foams can cause potential problems at waste treatment plants, especially those which
use the activated sludge process. That problem is in the foaming itself. The generation of foam at treatment
plants tends to transport solids and raise the pollutant level of the facility’s discharge stream. Unfortunately,
there is little that can be done to solve the foaming problem at this point. Firefighting foams, by their very nature,
are easily foamed with little energy input and, once foamed, are relatively stable. Ansul and other manufacturers
are also aware that their foams must not be toxic to the micro-organisms of the treatment plant and must not
have too high a biological oxygen demand (BOD is a measure of how much oxygen, which is dissolved in the
water, will be consumed as the micro-organisms “biodegrade” the chemicals). Care must be taken so that not
too much BOD is present to deplete the oxygen levels to a point where the micro-organisms will die. Waste
treatment plants have established limits on the allowable BOD for incoming materials so as to avoid this oxygen
depletion. Those which are high in BOD will have to be metered into the plant at slow rates or pre-diluted to get
to the desired BOD level.
The solution in a performance foam test, which is in control, is for the contractor to use an anti-foamer/defoaming
material after the test and prior to the foam solution entering the waste treatment facility. An example being Dow
Chemical’s H10 defoamer.
Nutrient loading is also of concern because the potential exists for releases of firefighting foam into natural
waterways either directly or through treatment plants. If they contain large amounts of nitrogen or phosphorous,
there is a potential for the foam to cause water quality problems in the form of algal blooms. The synthetic foams
tend to be low in these nutrients simply from the choice of surfactants used in their formulations.
Recent focus has centered on the type of solvent system which is used in the foam concentrates. Solvents are
used in the formulations in order to modify viscosity, to keep active ingredients in solution and provide additional
foam stability. Many of the synthetic agents use diethylene glycol monobutyl ether (commonly called DB or butyl
carbitol). Most of the protein-based agents use hexylene glycol.
Diethylene glycol monobutyl ether is part of a family of chemicals known as “glycol ethers.” The major use of
products in this family is in the paints, coatings and ink industries where it is used to control the drying rate. As
such, in these applications, these chemicals are designed to evaporate into the air. (This is not the case with
their use in foam concentrates where they most often end up in an aquatic ecosystem.) Because of this, the
United States Environmental Protection Agency included glycol ethers as hazardous air pollutants in its Clean Air
Act Amendments of 1990. Additionally, the glycol ethers category became subject to reporting under Section
313 of Emergency Planning and Community Right-to-Know (EPCRA) and the Superfund Amendments and
Reauthorization Act Title III (SARA Title III). This meant that any releases of one pound or more of glycol ethers
into the environment required reporting to the EPA. The one pound reportable quantity came about as a default
value because nobody within the EPA had come up with data to support a reasonable quantity. In June of 1995,
after reviewing data presented to them, the EPA decided that there was no need for a reportable quantity for gly-
col ethers. Consequently, foams containing any of the glycol ethers as solvents are not subject to EPA
reporting.
The initial reportability requirement caused at least two manufacturers of synthetic foam concentrates to formu-
late DB out of their formulations. Diethylene glycol monobutyl ether is an ethylene oxide based glycol ether. The
manufacturers who switched away from DB went to another glycol ether or combinations of glycol ethers which
are based on propylene oxide. These propylene oxide based glycol ethers were exempted from reporting by the
EPA at the start of the reporting program. The reasons for this are somewhat vague. Having formulated the DB
out of their formulations, these manufacturers have started marketing their formulations as “environment-friendly”
or “green.” As can be seen from the previous discussions, simply changing solvents does not necessarily mean
the foam is “friendly” or “green.”
In conclusion, consider this statement:
A true environment-friendly foam is one which extinguishes the fire the fastest resulting in the
least amount of pollution to the air and water from the fire itself – and is formulated to provide
the least amount of environmental upsets as a result of any type of release.

Form No. F-97136 1997 Ansul Incorporated Litho in U.S.A.