It took a ‘long road’ for New Hampshire to begin collecting PFAS-laden firefighting foam

The take-back program includes stops in all 10 counties throughout the month. (Courtesy of Revive Environmental)

In September 2019, a clock started ticking: The Department of Environmental Services had less than two years under a new law to institute a take-back program for PFAS-laden firefighting foam. It wasn’t such an easy task.

Most challenging was the question of how to get rid of the stuff. PFAS – or per- and polyfluoroalkyl substances – are called “forever chemicals” because of their exceptionally strong chemical bonds that take hundreds or thousands of years to break down in the environment.

The state weighed its options. Neither landfilling nor incineration were attractive ones. First, few places would accept aqueous film forming foams, or AFFF, the most common class of PFAS-laden firefighting foam . Incineration could risk not breaking down all the bonds or creating harmful byproducts.

The department commissioner, Robert R. Scott, wrote in a 2020 memo to the governor and other top officials that it would be difficult to meet the July 1, 2021, deadline set out in the 2019 law. He asked for a two-year extension from the Legislature, which was granted. By that deadline, the state partnered with an environmental company that presented a new option.

And this month, that take-back program envisioned years ago finally became a reality. Ten take-back events are scheduled throughout August, with one in each of the state’s counties. The department expects more than 100 participants, totaling a collection of more than 10,000 gallons of AFFF.

It’s possible because of a technology called the PFAS Annihilator, from Revive Environmental, that breaks down the powerful chemical bonds. The state has a $668,000 contract with the company, according to Amy Rousseau, the PFAS response administrator at DES.

“They’ve been waiting for a long time,” Rousseau said of the fire departments, “so we’re very excited to be able to assist them to get the PFAS out of their stations and off the streets.”

How it started

Firefighting foam has been a significant source of PFAS groundwater contamination in New Hampshire and elsewhere, posing risks to firefighters and the general public.

Not all firefighting foams have PFAS. Class A foams – used on wood, brush, vegetation, and paper – generally don’t have those chemicals. Class B foams – used on “gasoline, oil, and jet fuel” – that are fluorinated have PFAS, while the fluorine-free ones don’t, according to DES.

AFFF is the most common fluorinated foam, according to DES, making it the key target for take-back efforts. There are thousands of gallons of this foam in the state, a 2020 DES review found.

PFAS have been linked to serious health problems, including some cancers, weakened immune systems, developmental issues, and more.

Senate Bill 257 , which first went into effect September 2019, sought to stem contamination from firefighting foam in the state. It took a number of steps.

Starting in 2020, Class B foam with intentionally added PFAS could not be used in training or testing, unless DES had evaluated a testing facility to ensure its containment and disposal measures would not result in a release of foam into the environment. Fire departments were also newly required to report uses of the foam to DES within 48 hours.

The law also banned the sale of such foam in the state, except in cases where that foam is required by federal law. Chemical plants and places where flammable liquids would be stored or distributed were also exempt.

DES was also given a number of directives.

It would help state agencies, municipalities, and others avoid buying or using PFAS-containing foams. It was also required to survey municipalities across the state on how much of the foams they had and determine the cost of a take-back program. Those findings were reported to the governor and other officials in a December 2020 memo.

Fifty-eight percent of municipalities, or 135 of the 234, responded to the DES survey. About a third of those had no AFFF. Those that did reported a total of about 8,375 gallons.

Five nonmunicipal firefighting operations, such as Manchester-Boston Regional Airport Fire Department, also reported a total of 6,421 gallons of AFFF.

The memo laid out how an incineration-focused take-back program would work, but Commissioner Scott raised a number of issues, including limited treatment, storage, and disposal facilities that would accept the foam and uncertainty about the efficacy.

“New data has raised concerns regarding the effectiveness of incineration in destroying PFAS compounds,” Scott wrote, “and the potential for formation of fluorinated byproducts as a result of incomplete combustion. These processes are not well understood.”

The extension was requested with those concerns in mind. Last year, New Hampshire became the first state to partner with Revive Environmental.

Annihilation

On the outside, the PFAS Annihilator looks much like a metal storage unit.

The technology destroys PFAS’ powerful chemical bonds, and the resulting liquid is tested to ensure it is below contamination standards set by the Environmental Protection Agency before being released into the environment, said David Trueba, Revive Environmental’s CEO.

Revive Environmental treated 55 million gallons of PFAS impacted water last year, Trueba said. That doesn’t all end up in the PFAS Annihilator, he said; technology strips down the water and concentrates the PFAS first.

AFFF has different “recipes,” Trueba said. “Some of them have been around for over 30 years,” he said. “… People have been waiting that long to get rid of the PFAS.”

About 10,000 gallons have been registered for New Hampshire’s take-back events. Revive Environmental will need to process around 100 different varieties of AFFF, Trueba said. “It does take some time to make sure that we do it right,” he said. “And so the first time that we process takes a little bit of time.”

Eligible operations have already started to turn in their AFFF, with events spread throughout the state and month. Contractor staff test and inspect the material that’s brought in to ensure it’s eligible. Then, it gets shipped off to Columbus, Ohio, to get in line for annihilation.

Among those participating is Manchester-Boston Regional Airport. The transition to greener foam was an option that opened up when the Federal Aviation Administration first approved fluorine-free foam in January 2023.

“I challenged my team to see if there’s a way that we could participate in that,” said Ted Kitchens, director of the airport, “and to do so in a way that also allows us to be effective in our firefighting capabilities in case there is an aircraft accident here at the airport.”

His team came to him with a plan, and he approved it. Kitchens said the airport was giving up 720 gallons of foam. It’s not something the airport had to do, but Kitchens felt it was the right thing to do “to be a good neighbor.”

He said this is the first take-back program in the nation that he’s aware of to include airports.

After years of effort at DES to establish the program, Rousseau said, those involved are excited to finally “get it going.”

“We hit some bumps along the way, and it’s been a very long road,” she said.