The aqueous film-forming foam, or AFFF, used in Marine Corps Logistics Base Albany Fire & Emergency Services’ trucks, until recently, had an unknown amount of per- and polyfluoroalkyl substances. This presented a possible health risk.

“It can get into drinking water and be consumed by the population, in and out of the fence line,” Brian Wallace, head, Environmental Branch, Installation and Environmental Division, MCLB Albany, said.

The fire trucks now have an AFFF containing less than 3% of the product.

“We moved forward with replacing it,” Wallace said. “Headquarters Marine Corps contracted out a company (to drain out the old product and put in a new one).”  

The entire class of approximately 600 per- and polyfluoroalkyl substances are commonly known as PFAS. A variety of industries use PFAS because they help reduce friction, including the aerospace, automotive, building and construction and electronics industries.

The Department of Defense said it began using AFFF containing perfluorooctane sulfonate, or PFOS, and in some formulations perfluorooctanoic acid, or PFOA, in the 1970s. Both are two chemicals in the larger PFAS class.

AFFF is mission-critical because it quickly extinguishes petroleum-based fires.

“In a car fire, it supresses a fire a lot quicker than water,” Steve Waltermon, deputy chief, MCLB Albany Fire & Emergency Services, said. “It also works well with dumpster and structure fires.”

PFOS, PFOA and other PFAS, due to the potential harm on human health, are the subject of increasing regulations worldwide.

“It’s really good stuff, but it is a carcinogenic,” Daniel Tompkins, captain, MCLB Albany Fire & Emergency Services, said. “The (former product was in use) since 1999 or 2000. It is the best thing since sliced bread, but we didn’t know about the carcinogenic.”  

It takes the heat out of a fire by essentially coating it. 

“It doesn’t allow oxygen to get into it,” Wallace said. “It was originally designed for aircraft and later used by NASCAR. It is not immediately lethal to humans, but its long-term impacts are not fully known.”

“It has been used by every fire department in America. Once you spray it on a fire, there is no way to truly clean it up. When it rains it flows with the water, so it goes into lakes, rivers and acquifers. It even gets into the drinking water.” 

The U.S. Environmental Protection Agency issued a lifetime health advisory in 2016 for PFOS and PFOA in drinking water of 70 parts per trillion. One ppt is equivalent to one drop of water in 20 Olympic-sized swimming pools.   

Tompkins said AFFF is more commonly used in situations in which there is a more dangerous fire with a limited supply of water. Small amounts of PFAS consumed regularly can result in measurable levels in exposed people due to its ability to build up in the body.

The Department of Defense said in 2019 it used AFFF containing PFOS and PFOA in firefighting and crash response vehicle testing, fire training exercises, crash crew training exercises, hangar system operations and testing, responses to fuel fires or spills and emergency response actions. The DOD also uses materials that can contain PFAS in the vapor suppression systems at plating shops. Releases to the environment can result from use, spills and leaks of these materials during handling or in storage, wastewater treatment and disposal locations. 

The product recently brought into use at MCLB Albany has been approved for DOD use. The installation was one of several to have recently put it into their fire trucks.

“This project has been done through the Marine Corps,” Wallace said. “Some larger installations have already gone through this process.”

The new product is the same as the old in terms of effectiveness, only with a less harmful formula.

“It is the same, just less hazardous,” Waltermon said. 

The EPA’s guidance and is not an enforceable drinking water standard, but the DOD said it proactively addresses drinking water impacted by DOD releases. The Department acts on PFOS and PFOA in drinking water from DOD activities under the Comprehensive Environmental Response, Compensation and Liability Act of 1980. 

The DOD follows the CERCLA process to fully investigate releases, prioritize responses and determine appropriate cleanup actions based on risk. Under CERCLA, DOD investigates if a release occurred, takes short-term cleanup actions where there is an immediate need and implements long-term cleanup actions to address any remaining unacceptable risks. The process from the initial assessment to the beginning of actual cleanup is a multi-year effort.

The Department updated the military specification for AFFF so new supplies available for emergency firefighting responses do not contain detectable levels of PFOS or PFOA.

“We are being provided with an overall environmentally-friendly product that still meets mission requirements,” Wallace said. “We were mandated by the DOD and Headquarters Marine Corps to switch out products. 

“The goal long-term is protection of the drinking water system,” he added.

The use of AFFF for maintenance, testing and training on DOD installations worldwide is prohibited to prevent future releases to the environment. The Department is actively researching fluorine-free alternatives to AFFF.

The Department said it has three goals: mitigate and eliminate the use of AFFF containing PFAS, better understand the impacts of PFAS on human health and fulfill cleanup responsibility related to PFAS. 

“If the outside community sees we are doing this, that the DOD is going with a safer product and sees it works, they may switch their product,” Tompkins said. “We are all on the same aquifer in southwest Georgia.

“The base tries to be as environmentally friendly as possible,” he added. 

The DOD said in a 2020 briefing card it had identified 651 installations with known or suspected releases of PFOS/PFOA as of the end of Fiscal Year 2019. The Department tested its 524 DOD-operated drinking water systems, and 24 tested above EPA’s health advisory. Action was taken at these locations to reduce levels below the advisory.

MCLB Albany was not among those to raise a red flag.

“The water system has been tested and it does not contain the product,” Wallace said.

Wallace said the water system has been tested twice, in 2016 and 2020, and the tests came back clean both times. The base does not have an external water supply.

The DOD has initiated more than 100 projects with a total investment of approximately $100 million since 2011. Close to $80 million has been invested to date addressing characterization, toxicity and treatment of PFAS.

A PFAS Task Force established in a July 23, 2019 memo by then-Defense Secretary Mark Esper ensured a consistent and proactive approach. The operating principles for the task force was to identify six focus areas: health aspects, cleanup standards and performance, finding/funding an effective substitute firefighting foam without PFAS, science-supported standards for exposure and cleanup, interagency coordination and communications to the public and Congress.

The DOD said it supports the Agency for Toxic Substances and Disease Registry’s efforts to conduct an exposure assessment at eight military installations and a multi-site health study, as required by the FY2018 National Defense Authorization Act. Military departments are switching out AFFF from firefighting systems and backup storage lockers to ensure only the new military specification for AFFF without detectable PFOS or PFOA is available for emergency firefighting responses.

The EPA said PFAS have been manufactured and used in a variety of industries around the globe since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. PFAS can be found in:

• Food packaged in PFAS-containing materials, processed with equipment that used PFAS or grown in PFAS-contaminated soil or water.

• Commercial household products, including stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products and fire-fighting foams.

• Workplace, including production facilities or industries (e.g., chrome plating, electronics manufacturing or oil recovery) that use PFAS.

• Drinking water, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility).

• Living organisms, including fish, animals and humans where PFAS have the ability to build up and persist over time.

Certain PFAS chemicals are no longer manufactured in the U.S. due to phase-outs. PFOA and PFOS are no longer manufactured in the U.S., but they are still produced internationally and can be imported into the U.S. in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber and plastics, the EPA said.

The EPA also said studies indicate PFOA and PFOS can cause reproductive and developmental, liver and kidney and immunological effects in laboratory animals. Both chemicals have caused tumors in animals. The most consistent findings are increased cholesterol levels among exposed populations with more limited findings related to low birth weights, the immune system, cancer and thyroid hormone disruption.

The EPA said people can be exposed if they are released during normal use, biodegradation or disposal of consumer products containing PFAS. People who work at PFAS production facilities, or facilities that manufacture goods made with PFAS, may be exposed in certain occupational settings or through contaminated air.

Drinking water contamination is typically localized and associated with a specific facility, such as an industrial facility where PFAS were produced or used to manufacture other products, or an oil refinery, airfield or other location at which PFAS were used for firefighting, the EPA said.