Is AR-SFFF Allowed to Discharge to Storm Drains?

1/5/2024

Are foam system test headers allowed to flow outside and discharge the foam to the ground/storm water?

I see more and more places are banning AFFF from storm water.

What about flowing AR-SFFF to storm?

Any recommendations for capture if its not allowed to be send down the storm drain?

Thanks in advance.

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10 Comments

Pete H

1/5/2024 06:43:45 am

https://www.dyneusa.com/how-does-a-synthetic-fluorine-free-foam-sfff-differ-from-a-foam-containing-pfas-december-2020

According to the "Regulations" section of this site, disposal of SFFF foam may vary as per local regulations. So we'd need to check the locality.

Mike Morey

1/5/2024 08:16:34 am

Frankly I wouldn't send AFFF down any drain at this point, legal liability has already been pretty well established and every water purveyor etc is suing anyone involved for putting PFAS into their system that requires added and costly treatment steps and testing. Typically it's either trucked away to be disposed of properly or if possible/acceptable to the AHJ some places/companies are doing a "water equivalent" test where they only flow a small amount of mixed foam to show the proportioner works and then flow straight water, I don't totally understand the process but it minimizes the hazardous waste.

Danial Bartle

1/5/2024 08:24:24 am

This is an excerpt from National Foam's website. It is from the SDS for their "Green" SFFF:
Disposal Methods
This product, as sold, is not a RCRA-listed waste or hazardous waste as characterized by 40 CFR 261.
However, state and local requirements for waste disposal may be more restrictive or otherwise different
from federal regulations. Therefore, applicable local and state regulatory agencies should be contacted
regarding disposal of waste foam concentrate or foam/foam solution.
Concentrate
Prevent foam concentrate from entering ground water, surface water or storm drains. Small quantities of
foam concentrate may be collected on absorbents which can then be disposed of. Disposal should be
made in accordance with local, state and federal regulations.
Foam/Foam Solution
Prevent foam/foam solution from entering ground water, surface water or storm drains. Small quantities
of foam solution may be collected on absorbents which can then be disposed of. Disposal should be
made in accordance with local, state and federal regulations.

You would need to contact your region's authorities to determine the disposal requirements. In my opinion, none of the foams should be allowed to enter storm or sanitary systems. Most if not all WW treatment processes cannot remove the chemicals from the water.

Danial Bartle

1/5/2024 08:27:48 am

As an add to your question about containment, if hoses could be added to discharge directly to a frac container, you would be able to contain it there and have it disposed of properly. If you cannot do that, barriers would need to be set up so the liquid could be removed by a vac truck from a recovery company.

Jesse

1/5/2024 10:05:20 am

That's going to be as state and local environmental code question.

RYAN HINSON

1/5/2024 10:05:24 am

Always check the local environmental regulations. It is my experience that, if you put foam on the ground, there is a public presumption that it is the fluorinated stuff regardless of whether it actually is or not. As has been said, recommend capture of all discharge.

NFPA 11 provides options s to test foam systems without discharging foam either into an asset such as an oil-storage tank, a truck loading rack, or a secondary containment area where cleanup may pose an unacceptable challenge or 'might not be workable' as long as the system can still be demonstrated to function as designed with proportioning in the allotted range per Sections 12.2, 12.3, 12.4,12.5, 12.6, and 12.6.5. See also NFPA 11 (2021) Sections A.12.9.3.1(4), A.12.9.4, and Annex D for additional information.

Glenn Berger

1/5/2024 04:59:29 pm

Need to contact the local officials for a site specific determination.

Brett

1/18/2024 01:31:01 pm

That isn't advisable. The much better (albeit more expensive) solution is to perform the test into a frac tank. That is how we have been testing proportioners during acceptance. We then flow straight water to our foam deluge systems to check timing and head flows.

Mike

1/19/2024 02:34:28 pm

According to the USC Cross Connection Control manual AFFF/SFFF are classified as pollutants.

So no, do not discharge to a storm drain.

These flow to rivers, creeks and ultimately to the ocean.

Any water district should know this.

Also, since an RPPDDCA has a discharge outlet, it should be piped to a sanitary floor sink, as well.

Travis

5/17/2024 04:26:47 pm

What does the acronym RPPDDCA mean?

Also, a spill response situation of SFFF would be absorbent clay or pads and then the absorbed spilled material would be placed in a container and shipped off site for disposal as Non hazardous waste? Does this sound right?

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Is AR-SFFF Allowed to Discharge to Storm Drains?

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