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02.03.2021

PFAS: the extraordinarily costly liability you need to know about

Karen M. Reilly - Vice President, Product Line Manager - Ironshore Environmental

A new and massively costly complication is changing environmental liability: cleanup of hazardous per- and polyfluoroalkyl substances (PFAS) found in aqueous film-forming foams or AFFFs. Commonly used throughout the United States, these Class B firefighting foams are used to extinguish fires involving flammable and combustible liquids, oils, gases, and more. PFAS are held to some of the toughest cleanup standards among regulated contaminants. To make matters more challenging, there are few technologies proven to do the job – and many associated costs. 

Cleanup costs of PFAS compounds in AFFF can be 5 to 20 times more than those of fuels released from a petroleum storage facility.1

What creates such high costs?

PFAS waste is managed by waste disposal companies as a federal hazardous waste. Disposal costs are often nearly double the typical cost of disposal of petroleum-impacted waste. There are a number of factors at work here: 

  • Limited soil treatment options. The only proven methods for treating PFAS in soil are excavation followed by landfill disposal or destruction via incinerator – both of which are costlier than methods used to dispose of other contaminants. 
  • Limited soil treatment resources. Because of the potential for extraordinary liability, only a limited number of landfills and incinerators accept PFAS waste.
  • High transport costs. With facilities few and far between, transporting PFAS-impacted soil can be four times higher than transporting petroleum-impacted waste.1
  • Limited groundwater treatment options. Only ex-situ technologies that include groundwater extraction wells and above-groundwater treatment systems with granular activated carbon or ion exchange resins are proven to treat PFAS in groundwater.
  • Long-term groundwater costs. A groundwater extraction and treatment system may need to operate for as long as 40 years, entailing significant operation and maintenance costs. 
  • Strict federal standards. The acceptable rate of PFAS is notably low, requiring a greater effort and more funds to achieve.

Breaking down cleanup costs

This outline of cleanup costs associated with PFAS contamination following a typical energy industry fuel fire shows the considerable scope of this threat.

$2.25M

Collection and disposal of 1M gallons of AFFF, water, and fuel at hazardous waste management facility 

$12M to $54M

Projected cost for soil cleanup 

$10M to $15M

Projected cost for groundwater cleanup

$1.8M

One year of stormwater runoff management (collection, transport, and disposal of 800,000 gallons of runoff at hazardous waste management facility) 

TOTAL COSTS

$26.05M to $73.05M

How can vulnerable companies prepare?

  • Recognize that PFAS will be a massive exposure both in the energy sector and for other organizations that rely on AFFF materials to extinguish fires.
  • Factor PFAS containment and cleanup into all loss control evaluations. Even if AFFF isn’t stored on site, it’s highly likely that it will be introduced in the event of a fire, through the fire department, as a result of reciprocity agreements with other terminal operators, or via historic stockpiles.

There’s nothing better than a case study to illustrate how risks and costs impact real businesses. You’ll find just that in our white paper, which traces remediation after a routine firefighting response at a fuel storage facility. Click the link below to read more.

Download the white paper

1Data provided by Ironshore technical engineers and consultants, 2020.