INTERNAL AUDIT REPORT
Operational Audit - Aqueous Film Forming Foam (AFFF) Transition
As of August 15, 2024
Source: Port of Seattle - Fire Department
Issue Date: September 06, 2024
Report No. 2024-13
This report is a matter of public record, and its distribution is not limited. Additionally, in accordance with
the Americans with Disabilities Act, this document is available in alternative formats on our website.
Aqueous Film Forming Foam (AFFF) Transition
TABLE OF CONTENTS
Executive Summary................................................................................................................................................ 3
Background............................................................................................................................................................. 5
Audit Scope and Methodology............................................................................................................................ 6
Schedule of Observations and Recommendations ........................................................................................... 7
Appendix A: Risk Ratings .................................................................................................................................... 16
Appendix B: Estimated inventory amount of AFFF at POSFD and Tenants.................................................. 17
Appendix C: History of Discharges .................................................................................................................... 18
2
Aqueous Film Forming Foam (AFFF) Transition
Executive Summary
Internal Audit (IA) completed an audit of the Port of Seattle Fire Department (POSFD) through the period
ended August 15, 2024. The primary focus was to evaluate the efficacy of measures taken by POSFD
in mitigating the risk of exposure to Aqueous Film Forming Foam (AFFF) and their plans for transitioning
to Per- and Polyfluoroalkyl Substances (PFAS)-free alternatives. Given the health hazards associated
with PFAS chemicals, this audit aimed to provide insights into current practices and recommend
improvements to safeguard personnel and the environment.
The POSFD is taking proactive steps to address the risks associated with long-term exposure to AFFF,
which contains PFAS chemicals. Exposure to high concentrations of PFAS has been linked to cancer
and other related illnesses. As part of efforts to understand and mitigate these risks, some POSFD
firefighters participated in the Fire Fighter Cancer Cohort Study. Analysis of their blood samples revealed
elevated levels of PFAS compared to the general population, highlighting the potential health hazards
associated with AFFF exposure. Tragically, three POSFD firefighters have been diagnosed with
pancreatic cancer, with two having passed away.
The POSFD is compliant with RCW Chapter 70A.400, as no foam is discharged during their training
sessions. This law, enacted in 2018, prohibits the discharge or use of class B firefighting foam containing
intentionally added PFAS chemicals for training purposes. Furthermore, previously, the FAA required
the department to conduct tests that required releasing AFFF every six months to determine the
appropriate mixtures between AFFF and water. However, instead of this practice, the Port has acquired
an Ecologic System Foam Machine. This machine, which is external and connects to the fire truck,
simulates the AFFF proportioning (mixing) with water without the need for an actual discharge. This
solution not only assures compliance but also provides an efficient means of testing.
Several tenants within the Port of Seattle (Port), including the Alaska Hangar, the Delta Hangar, the
PACCAR Hangar, the Fuel Farm (leased to SeaTac Fuel Facilities LLC, operated by FSM Group), and
the Consolidated Rental Car Facility (CRCF), currently utilize AFFF within their fire suppression systems.
The CRCF is in the early stages of developing plans to switch to water sprinkler systems. Delta Airlines,
PACCAR, and the Fuel Farm consortium are also in the process of assessing their transition options. It
is evident that transitioning away from AFFF remains a work in progress for these tenants.
In general, Port management's internal controls are aligned with policies and procedures. However, our
audit identified opportunities where internal controls could be enhanced or developed. These
opportunities are listed below and discussed in more detail beginning on page seven of this report.
1. (Medium) A lack of AFFF Disposal Planning by the POSFD and AV-Env, posed potential storage
challenges after transition to PFAS-free foam.
2. (Medium) ARFF vehicle valves were actuated and were found to operate as intended with the new
F3 foam, however, the POSFD had not yet decided, if and when, to test the valves on ARFF vehicles
on an ongoing basis. Failure to test valves can pose a risk of valves malfunctioning due to prolonged
inactivity.
3. (Medium) Internal Audit identified challenges in the maintenance of AFFF Fire Suppression Systems
at tenant locations. Additionally, the audit revealed potential operational safety risks associated with
delayed transitions to PFAS-free foam alternatives.
4. (Medium) The 1995 E-One 5190 120 was inadvertently omitted during the compilation of AFFF
inventory list.
5. (Medium) Internal Audit identified areas for Improvement in AFFF Management Policies,
Compliance, and Training Documentation.
We extend our appreciation to Port Management and staff for their assistance and cooperation during
this audit.
3
Aqueous Film Forming Foam (AFFF) Transition
Glenn Fernandes, CPA
Director, Internal Audit
Responsible Management Team
Sarah Cox, Director Aviation Environment Services
Sandra Kilroy, Sr. Director Environment, Sustainability & Engineering
Randy Krause, Fire Chief
Wendy Reiter, Director Aviation Security
4
Aqueous Film Forming Foam (AFFF) Transition
Background
The Navy received a patent for its invention of AFFF in 1966 and by the mid 1960's the 3M Company
was manufacturing AFFF for the military. By the late 1960's, the U.S. Navy required all its vessels to
carry AFFF. In the 1970's the Department of Defense (DoD) began using AFFF to fight fuel fires at all
military installations. In 1988, the FAA followed suit and mandated all commercial passenger servicing
airports to use AFFF to combat against Class B flammable fires.
AFFF's effectiveness lies in its ability to cool, separate flames, suppress vapors, and smother fires,
making it ideal for areas with flammable liquids. However, its composition, including
perfluorooctanesulfonic acid (PFOS) or perfluorooctanoic acid (PFOA), from the PFAS chemical
family, poses environmental and health risks. Firefighters, predominantly exposed during training and
emergencies, face various health issues linked to PFAS exposure, as noted by the U.S. Department of
Veterans Affairs.
Washington State Senate Bill 6413, enacted into law as RCW Chapter 70A.400, prohibits the
discharge or use of Class B firefighting foam containing intentionally added PFAS chemicals for
training purposes, starting from July 1, 2018. Furthermore, it imposes limitations on the production,
sale, and distribution of Class B firefighting foams containing PFAS chemicals, although exemptions
are granted for federally mandated uses (until September 2023, use of AFFF was mandated for use
at certificated airports by the FAA) and oil refineries. In September 2025, the law eliminates all
exceptions for the purchase of AFFF, now that PFAS-free alternatives are authorized for use by the
FAA. However, at the time of the audit, there were no explicit regulations governing the use of already
acquired AFFF.
As of September 2023, the FAA has approved the use of fluorine-free firefighting foams (F3) that meet
the new Military Specification (MIL-SPEC) set by the Department of Defense (DoD). The FAA's
acceptance of F3 at airports, marked a significant step, aligned with military standards. This approval
allows airports to opt for these environmentally safer alternatives to AFFF that contains PFAS.
The POSFD operates vehicles which were equipped with AFFF. While AFFF usage history includes
emergency responses and accidental discharges, the POSFD ceased on-site training with AFFF in
2003. In addition to presence in AFFF, PFAS is also known to be present in the water-resistent inner
linings of firefighter turnout gear. The POSFD is exploring PFAS-free turnout gear alternatives.
The POSFD initiated the transition to PFAS-free firefighting foam in June 2024, with the F3
implementation and the ARFF truck decontamination completed on August 6, 2024. Notice letters
were sent to tenants with AFFF fire suppression systems in February 2024. In this letter, the Port
indicated, waivers to requirements for annual system testing and backup supply requirements from the
POSFD, as the Authority Having Jurisdiction (AHJ), would no longer be granted to the tenants
following September 2025. Facilities currently receiving waivers may have to upgrade their systems to
assure compliance with AHJ standards.
See Appendix C for the history of AFFF discharges both by POSFD and Tenants.
5
Aqueous Film Forming Foam (AFFF) Transition
Audit Scope and Methodology
We conducted the engagement in accordance with Generally Accepted Government Auditing Standards
and the International Standards for the Professional Practice of Internal Auditing. Those standards
require that we plan and conduct an engagement to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our engagement objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our
engagement objectives.
We used 100% sampling for all the below-listed tests except benchmarking and procurement tests,
where we used judgmental sampling methods to determine the samples selected. In those cases, the
results of the work cannot be projected to the population as a whole. The period audited was as of May
15, 2024, and included the following procedures:
Interviews & Process Walkthroughs
Conducted interviews and process walkthroughs at the fire department and with Port tenants using AFFF
in their fire extinguishing systems to understand the following:
•
•
•
•
•
•
•
Policies and procedures for handling AFFF.
Storage practices of AFFF POSFD and tenant sites.
Transition plans for moving to PFAS-free foam.
Preventive and detective controls in place for discharge/spill incidents.
Use and storage of bunker gear containing PFAS.
Training programs related to AFFF and the new PFAS-free foam.
Opportunities for improvement in these areas.
Document Review
Reviewed key documents related to AFFF handling, including the following:
•
•
•
•
Port policies, departmental procedures, and associated training materials.
State and Federal laws and regulations concerning AFFF procurement.
14 CFR Part 139 requirements from the Federal Aviation Administration (FAA).
Department of Ecology guidelines on AFFF storage and disposal.
Procurement
•
•
•
Past purchases: Obtained invoices for bunker gear and AFFF foam purchases.
Exemption: Reviewed a CPO-5 competition waiver allowing the Port to procure Globe firefighter
protective equipment from a specific vendor without a bidding process.
Authorization: Confirmed proper authorization for purchases.
Observations
•
•
POSFD - Examined the storage and maintenance of bunker gear, AFFF foam storage, and
quantities in ARFF vehicles, external totes, and buckets.
During site visits, we observed AFFF tank rooms at tenant locations, including the PACCAR
Hangar, the Delta Hangar, the Alaska Hangar, the Fuel Farm, and the CRCF.
Benchmarking.
•
•
Reached out to other airport fire departments transitioning to or already using PFAS-free foam.
Investigated their methods for AFFF foam storage and disposal.
6
Aqueous Film Forming Foam (AFFF) Transition
Schedule of Observations and Recommendations
1) Rating: Medium
A lack of AFFF Disposal Planning by the POSFD and AV-Env posed potential storage challenges
after transition to PFAS-free foam.
The POSFD is collaborating with the Port's Aviation Environmental Department (AV-Env) to prepare for
the transition away from AFFF. During our walkthrough at the fire department and interviews with
environment specialists, we learned that the plan was to store the AFFF in intermediate bulk containers
(IBC) totes. These totes, designed for handling hazardous materials like AFFF, were to be equipped
with spill containment pallets to mitigate any potential spills or leaks. However, a comprehensive plan
for AFFF disposal was lacking, raising concerns about potential storage issues after the transition.
Initially, the plan was to store AFFF outside the POSFD building and wait for the Washington State
Department of Ecology's takeback program, which would have provided free disposal. However, in our
recent discussions with the POSFD and AV-Env, they were considering disposing of AFFF at a
hazardous waste facility, which would be a more costly option than the takeback program but would
address the storage issues.
While the transition to PFAS-free foam was underway, AV-Env confirmed that AFFF, removed from
vehicles, was being temporarily stored outside the POSFD building as an interim measure, pending the
development of a proper disposal strategy.
IA also observed that, in addition to the ARFF vehicles, AFFF was stored in two IBC totes and several
5-gallon buckets with secondary spill containment in the apparatus bay at the POSFD. This apparatus
bay is used by the firefighters for training.
Furthermore, the Port is tasked with storing and disposing of approximately 1,000 gallons of AFFF at
the Consolidated Rental Car Facility (CRCF). This responsibility arises from the Port taking on the
project of transitioning from AFFF to a water sprinkler system at the CRCF, necessitated by the project
cost exceeding the dollar amount threshold outlined for improvement projects in their lease agreements.
IA has identified potential storage issues if a proper plan is not established promptly.
See Appendix B for an estimated inventory amount of AFFF at POSFD.
Recommendations:
1. The POSFD, working with AV-Env, should promptly finalize a storage and disposal plan for
AFFF.
2. Assure all storage containers are clearly labeled and regularly inspected for leaks and damages.
3. The Aviation Project Management Group (AVPMG), and Aviation Commercial Management,
should work closely with Av-Env to come up with a disposal plan for AFFF from the CRCF project.
Management Response/Action Plan:
7
Aqueous Film Forming Foam (AFFF) Transition
DUE DATE: 10/31/2024
8
Aqueous Film Forming Foam (AFFF) Transition
2) Rating: Medium
ARFF vehicle valves were actuated and were found to operate as intended with the new F3
foam, however, the POSFD had not yet decided, if and when, to test the valves on ARFF
vehicles on an ongoing basis. Failure to test valves can pose a risk of valves malfunctioning
due to prolonged inactivity.
The fire suppression systems within the ARFF vehicles essentially mix AFFF and water to create to
required mixture to extinguish fires. Each system stores AFFF in a large tank within the vehicle with
only a few entry points. A valve between the AFFF tank and a pump controls the water-to-AFFF mixture.
If a firefighter happens to open a valve, AFFF will be introduced within the pump and AFFF will be
exposed to all the pump lines within the ARFF fire suppression system. Although the FAA mandates biannual testing of the water-to-AFFF mixture, the FAA does not explicitly mandate testing of the valves.
However, the FAA does state that testing the system is an integral part of maintaining ARFF vehicles in
optimal condition for an emergency response.
Since RCW Chapter 70A.400 prohibited the use of PFAS-containing firefighting foam for training on July
1, 2018. The POSFD acquired an Ecological Foam Machine in 2020, eliminating the need to open the
AFFF valve to meet required FAA testing. This machine mimics blending the AFFF concentrate with
water without actually blending or discharging AFFF, eliminating environmental or health risks. During
our audit, discussions with the POSFD staff revealed concerns about valve functionality and potential
corrosion due to prolonged inactivity.
As part of the AFFF transition to F3 foam work that occurred from June to August, the foam valves in all
ARFF vehicles were actuated and reportedly operated as intended. However, the POSFD had not yet
decided whether to maintain the same safety protocols used for AFFF after transitioning to the new
foam, given the potential risk of a PFAS rebound since the existing ARFF tanks and pipelines were not
replaced. They also considered starting to test the valves if their tests indicated low levels of remnant
AFFF.
If the valves are not tested for extended periods, there is a potential risk of malfunction due to corrosion.
We reached out to fire departments at other airports, including Reno Airport and Jackson Hole Airport,
which had either completed or were in the process of transitioning to PFAS-free foam, to benchmark
their experiences. These departments emphasized the critical need for valve functionality testing due to
the risk of malfunction caused by corrosion. To ensure proper functioning, these departments
implemented various measures, such as hiring third parties for testing to reduce exposure risks to
internal staff, designating areas for foam discharge with proper cleanup protocols, or acquiring new
apparatus with built-in systems for valve functionality testing without foam discharge.
Recommendations:
1. Going forward the POSFD should establish standard operating procedure (in conjunction with
the AV-Env) to identify a process for valve functionality testing in ARFF vehicles to mitigate the
risk of malfunctioning due to corrosion or prolonged inactivity.
Management Response/Action Plan:
As part of the AFFF transition to F3 foam work that occurred in June-August, the foam valves in all
ARFF vehicles were actuated, and found to be fully functional and operational in all vehicles. Testing
of valves is recommended by the manufacturer, however it is not possible to test valve functionality
without discharge of foam which then carries the potential for firefighter and mechanic exposure, as
well as environmental discharge. It is not currently known what degree of PFAS rebounding will occur
in the new F3 foam as a result of remnant AFFF presence in the vehicle tanks and piping. Until the
concentration of PFAS intrusion into the F3 foam is known, the Fire Department will continue to restrict
valve actuation and foam discharge to minimize risk of exposure, and risk of release to the
environment.
9
Aqueous Film Forming Foam (AFFF) Transition
Rebound testing of PFAS into the F3 product is planned, and will begin as soon as a Work Plan for
this activity is finalized - anticipated in mid-August 2024. Once these data are obtained, this
information will be used to inform the process for vehicle maintenance and foam discharge moving
forward, including actuation of the foam valves. Once a decision is made by the Fire Department, all
associated policies, procedures and practices will be updated to reflect the new condition.
DUE DATE: 03/31/2025
10
Aqueous Film Forming Foam (AFFF) Transition
3) Rating: Medium
Internal Audit identified challenges in the maintenance of AFFF Fire Suppression Systems at
tenant locations. Additionally, the audit revealed potential operational safety risks associated
with delayed transitions to PFAS-free foam alternatives.
As part of our audit, we conducted walkthroughs for each of the airport's tenants that use AFFF in their
fire suppression systems: the Alaska Hangar, the Delta Hangar, the PACCAR Hangar, the Swissport
Fuel Farm, and the Consolidated Rental Car Facility. During our walkthroughs, we toured their facilities,
spoke with their employees, and inspected their AFFF system rooms. Some of the observations noted
during audit testing were as follows:
1) Tenant Maintenance of their Fire Suppression systems.
•
•
Leaks and Spills: Inspections identified instances of leaks and spills of unidentified substances
at two tenant facilities (see Appendix D). These occurrences were observed in indoor areas
without direct connections to Port utilities or systems. While such incidents are part of the
operational challenges in complex industrial settings, they highlight the importance of ongoing
maintenance and prompt remediation to minimize potential health risks to tenant staff. Tenants
are responsible for their own system maintenance and internal leaks and spills of this nature are
not required to be report to the AV-Env.
Maintenance Challenges: Despite regular maintenance, some tenants have old systems with
recurring faults. The cause for these faults not being identified during maintenance remains
unclear. Multiple accidental discharges due to system failures have been reported to AV-Env
(see Appendix C). While breakdowns in aged industrial equipment aren't unusual, these
incidents highlight the ongoing challenge of maintaining older systems.
2) The Transition from AFFF containing PFAS.
•
•
•
•
Regulatory Requirement and Tenant Progress: Washington state legislation, Chapter
70A.400 RCW, prohibits the manufacture, sale, or distribution of class B firefighting foam
containing intentionally added PFAS chemicals as of July 1, 2020. This regulation initially
exempted airport facilities using AFFF under a federal mandate until viable PFAS-free
alternatives became available. The exemption for airport facilities is set to expire on September
18, 2025. The Environmental team has formally notified tenants about recent regulatory
developments regarding AFFF usage. The Consolidated Rental Car Facility plans to transition
to a water sprinkler system in their initial phases. Delta Airlines is exploring the transition to a
water sprinkler system and is currently conducting a Fire Risk Assessment to determine the best
approach. There are no set plans for other tenants, who are still evaluating their transition plans.
Depleting AFFF supplies and Operational Safety Risk: Depleting AFFF inventories due to
accidental discharges, combined with the state ban on new AFFF purchases, could compromise
fire suppression capabilities across the airport, making it essential to switch to alternatives.
Environmental and Reputational Risk: Continued use of PFAS-containing foam increases the
potential for environmental contamination. Delays in transitioning to PFAS-free alternatives may
impact the Port's image as an environmentally responsible entity.
Waivers from POSFD: In February 2024, tenants were notified via letters the Washington State
ban on the purchase, sale, and distribution of AFFF.The Port also indicated that fire code waivers
for non-compliance items such as annual system testing and backup supply requirements from
the POSFD, as the Authority Having Jurisdiction (AHJ), will no longer be granted after September
2025. Facilities currently receiving waivers may need to upgrade their systems to comply with
AHJ standards.
Recommendations:
1. Enhance the Port's existing inspection protocols by incorporating AFFF storage areas into
11
Aqueous Film Forming Foam (AFFF) Transition
regular facility assessments.
2. Establish a definitive deadline for tenants to submit their transition plans to the Port.
3. Continue and potentially expand technical assistance to tenants for PFAS-free alternative
implementation.
Management Response/Action Plan:
the Port
staff have
However, the Port is not a regulatory agency and
w
there is no practical mechanism for
the Port to require tenants' transition. Further, doing so could expose the Port to certain legal risks.
T
our approach.
comply with the Port SWPPP
included
DUE DATE: 09/25/2024
12
Aqueous Film Forming Foam (AFFF) Transition
4) Rating: Medium
The 1995 E-One 5190 120 was inadvertently omitted during the compilation of AFFF inventory
list.
The POSFD contracted TRS Group, Inc. to clean and decontaminate the ARFF vehicles containing
AFFF in preparation for transitioning to PFAS-free foam. During our audit of the POSFD's AFFF
inventory and transition plans, we identified an oversight in the AFFF Inventory Compilation. One
vehicle, a 1995 E-One 5190 120, containing 30 gallons of AFFF, was not included in the inventory and
the TRS Group decontamination contract. This older vehicle requires a different approach for AFFF
removal compared to the newer ARFF vehicles covered by the TRS Group decontamination contract.
POSFD and AV-Env have acknowledged this oversight, confirming that the vehicle won't be added to
the TRS Group contract due to its unique requirements. Currently, a specific plan for managing the AFFF
in this vehicle has not been determined.
Recommendations:
The POSFD, in collaboration with AV-Env, update the AFFF inventory to include this vehicle, and
develop a documented plan for managing its AFFF that aligns with overall phase-out timelines and safety
standards.
Management Response/Action Plan:
Port Fire Department and Port-Env appreciate identification of this inventory oversight. The AFFF has
already been removed from the onboard tank of the E-One 120. Port Fire Department mechanics will
disconnect the piping and place a blank plate over the foam switches inside the rig. The vehicle can no
longer discharge AFFF. The vehicle has been equipped with a stand-alone mobile tank of NovaCool, a
PFAS-free firefighting foam, consistent with the other two engine vehicles in the fleet that were drained
of AFFF and converted to NovaCool in 2020. Completion of the piping isolation and switch plate cover
will be completed before the end of the year.
DUE DATE: 12/31/2024
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Aqueous Film Forming Foam (AFFF) Transition
5) Rating: Medium
Internal Audit identified areas for Improvement in AFFF Management Policies, Compliance, and
Training Documentation.
During our audit, we examined a wide range of documentation related to AFFF management, including
operational policies, handling procedures, safety guidelines, and training records. Our review revealed
the following observations:
1. Current Policy and Procedure for AFFF
•
Policy and Procedure No. 316 was outdated, mentioning discontinued practices like annual
AFFF discharge for FAA compliance.
•
No specific policies have been drafted for the new PFAS-free foam being introduced in June
2024.
2. AFFF Management and Regulatory Compliance
• Currently, Aqueous Film-Forming Foam (AFFF) is not regulated under the Resource
Conservation and Recovery Act (RCRA), which governs hazardous waste management.
However, AV-Env proactively classifies AFFF as a hazardous substance, even though this
classification is not legally mandated.
• The Spill Prevention, Control, and Countermeasure (SPCC) Plan governs the handling and
storage of hazardous substances. Since AFFF is treated as a hazardous material by AV-Env, it
falls under the regulations outlined in the SPCC Plan. However, the current SPCC Plan does
not explicitly list AFFF as a hazardous substance.
3. Training Documentation:
•
Regular AFFF training sessions are conducted, including an annual session every February.
•
Vector Solutions, used to track trainings, is infrequently updated and may not reliably indicate
all conducted trainings.
•
Some training sessions are verbal and not documented in Vector Solutions.
Recommendations:
1. Update Policy and Procedure No. 316 to reflect current practices and remove references to
discontinued practices, such as the annual discharge of AFFF for FAA compliance.
2. Develop and implement policies for the new PFAS-free foam introduced in June 2024.
3. Update the SPCC plan to explicitly mention AFFF as one of the hazardous substances managed
under the plan.
4. Improve documentation of safety trainings sessions for both AFFF and PFAS-free foam.
Management Response/Action Plan:
Transition of the Port ARFF fleet to fluorine-free foam was completed Monday August 6th, 2024. Policy
#316 has been updated to reflect the transition to F3 foam, and current practices for use and
discharge of F3 foam. This policy is undergoing department review, in accordance with policy revision
protocol, with the policy review period ending September 4, 2024.
Policies for the new PFAS-free foam is included in the revised Policy #316.
As noted in the audit observations above, PFAS is not yet a federally listed Hazardous Substance
under RCRA, and therefore AFFF is not specifically identified in the SPCC Plan as a hazardous
substance. Port-Env will review the SPCC Plan and SWPPP and identify areas where language can
be revised to reflect and include the Port's handling of AFFF in the same manner as if it were a
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Aqueous Film Forming Foam (AFFF) Transition
hazardous substance in the absence of a Federal listing. Any updates to the SPCC and/or SWPPP will
be made in conjunction with the 5-year updates and as needed the minor annual document revisions.
Please note that some of the tenants also have SPCC plans specific to their facilities and operations at
SEA. If any updates are made to the Port SPCC it would only be reflective of Port-owned
infrastructure that falls under this regulatory requirement.
The fire department is currently compliant with all regulatory and policy-related requirements for
firefighter training. Trainings specifically related to use and handling of F3 foam and AFFF have been
updated in the training database Vector Solutions to better reflect ALL trainings and safety discussions
that have been conducted related to the new F3 foam. Future trainings specific to foam will be
documented in Vector Solutions.
DUE DATE: 12/31/2024
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Aqueous Film Forming Foam (AFFF) Transition
Appendix A: Risk Ratings
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will be
evaluated and may or may not be reflected in the final report.
Rating
High
Financial/
Operational
Impact
Significant
Internal
Controls
Compliance
Public
Commission/
Management
Missing or
partial
controls
Non-compliance
with Laws, Port
Policies,
Contracts
High probability
for external audit
issues and / or
negative public
perception
Requires
immediate
attention
Partial
compliance with
Laws, Port
Policies
Contracts
Moderate
probability for
external audit
issues and / or
negative public
perception
Requires
attention
Mostly complies
with Laws, Port
Policies,
Contracts
Low probability
for external audit
issues and/or
negative public
perception
Does not
require
immediate
attention
Partial
controls
Medium
Low
Moderate
Minimal
Not
functioning
effectively
Functioning
as intended
but could be
enhanced
16
Aqueous Film Forming Foam (AFFF) Transition
Appendix B: Estimated inventory amount of AFFF at POSFD and Tenants
Organization
Port of Seattle - Fire Department
Swissport - SeaTac's Fuel Farms
Delta Airline's Hangar
Alaska Airline's Hangar
PACCAR's Hangar
Consolidated Rental Car Facility (CRCF)
Storage Type
ARFF 1 - 2021 Rosenbauer Panther 6X6
ARFF 2 - 2009 Oshkosh Striker 3000
ARFF 3 - 2016 Oshkosh Striker 4500 HRET
ARFF 4 - 2005 Oshkosh Striker 3000
ARFF 5 - 2021 Rosenbauer Panther 6x6
E-303 - 1995 Darley 5190 120
Storage Tanks
5-Gallon Buckets
Estimated Total
Tank #1
Tank #2
55-Gallon Drums
Storage Tanks
Estimated Total
Tank #1
Tank #2
Tank #3
Tank #4
Hanger Tanks
Estimated Total
Tank #1
Tank #2
Estimated Total
Tank #1
Tank #2
Estimated Total
Tank #1
Tank #2
Estimated Total
Consolidated Estimated Total
17
Estimated Gallons (gal)
420
420
640
420
420
30
395
50
2,795
6,000
6,000
880
275
13,155
2,140
2,169
2,161
2,229
800
9,499
4,400
4,400
8,800
1,200
1,200
2,400
500
500
1,000
37,649
Aqueous Film Forming Foam (AFFF) Transition
Appendix C: History of Discharges
Organization
Port of Seattle Fire Department
Date
Unknown
Accidental discharge through training
2021
Unknown
Two new ARFF vehicle apparatus testing
Unknown
Last known report of FAA bi-annual testing before
switching to Ecologic Foam Machine
Unknown
Brush Fire
Unknown
Aviation Fuel Tanker explosion on Interstate 5 at
Federal Way
Unknown
Unknown
De Havilland Dash Plane Crash.
Foam valve failure
1/12/2024
2,000 gallons
Sensor failure
4/27/2022
1,200 gallons
Short circuit in the fire panel
2020
2016
1998
Delta Airline's
Hangar
2020
Alaska Airline's
Hangar
PACCAR's Hangar
N/A - None reported as of 2021
12/27/2021
1/17/2024
Consolidated
Rental Car Facility
(CRCF)
Nature
5/12/2021
2021
Swissport SeaTac's Fuel
Farm
AFFF Discharge
Amount
11/7/2023
1/2/2022
2,000 gallons of
water/foam mixture
Dry sprinkler head failure
1,000 gallons of
water/foam mixture
The AFFF system ruptured at the drum's low points.
This was caused by freezing, which busted the
pipes, and then thawed
Unknown
1,800 gallons of
water/foam mixture
18
Leak within the AFFF system control room
The AFFF system ruptured at the low point drums.
This was caused by freezing, which busted the
pipes, and then thawed
Aqueous Film Forming Foam (AFFF) Transition
Appendix D:
Alaska Airlines' AFFF Tank Room with Spills and Leaks of Unidentified Fluid (likely hydraulic fluid).
Consolidated Rental Car Facility' AFFF Tank Room with Spills and Leaks of Unidentified Fluid potentially can be
AFFF .
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Aqueous Film Forming Foam (AFFF) Transition
Appendix E: Transitional Plans for AFFF.
Organization
Port of Seattle Fire Department
Swissport SeaTac's Fuel
Farms
Delta Airline's
Hangar
Alaska Airline's
Hangar
PACCAR's Hanger
Consolidated
Rental Car Facility
(CRCF)
Transitional Plans
The POSFD has contracted a professional cleaning company to decontaminate the ARFF
vehicles of PFAS in June 2024. After the decontamination process, the ARFF vehicles will
be refilled with the new F3 foam. The AFFF previously in the ARFF vehicles will be stored
in containers on site until the Washington State Department of Ecology AFFF takeback
program is restarted.
The Airline Consortium that operates the Fuel Farm is discussing transitional plans at
corporate level but local staff was not aware or could provide definitive answer on their
transition plan.
Delta Airline is still in the process of finalizing their transition plans. They are considering
implementing a water sprinkler system instead of a foam system. A Fire Risk Assessment
is currently underway to evaluate this option.
Alaska's management was not present during the site visit, so we were unable to obtain
the status of their transition plan.
PACCAR has reached out to vendors for an estimate to transition to a PFAS-free foam
system. However, they are having difficulty getting vendors to visit their facility due to its
smaller size. Additionally, with their lease ending in six years, they need to weigh the costs
and benefits of making the switch.
The Port has taken responsibility for replacing the AFFF system and disposing of the
AFFF. Currently, they are in the early design phase of this project. The CRCF is going to
be equipped with an all-water sprinkler system as part of this upgrade.
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