Red Hill leaked liquid AFFF concentrate - not firefighting foam

Officials downplay severity of the November, 2022 leak

By Pat Elder
December 19, 2022

 The “foam” leak at Red Hill likely looked more like this.     Image by Civil Beat

The Pentagon, EPA, and the Hawaii Department of Health have confused the public regarding the concentration of firefighting liquid released by the Navy at Red Hill on November 29, 2022.

The three agencies have failed to make it clear to the public that 1,300 gallons of the far more dangerous aqueous film-forming foam concentrate was released, rather than foam. This may explain why the Navy is so hesitant to release footage of the infamous video at Adit 6. The leaking substance looks like water, rather than the foamy material we’ve seen in photos and videos coating hangars and cars in parking lots. AFFF concentrate is made up mostly of water. It appears as a clear to slightly pale yellow liquid.  Chemguard 3% AFFF concentrate, for instance, is comprised of  90% water.

AFFF Concentrate, Solution, and Foam

AFFF Foam Concentrate – The liquid concentrate is supplied from the manufacturer. It is mixed with water to create the foam.  The concentrate is available from multiple manufacturers in 5 gallon pails, as well as 55 and 265 gallon drums.

AFFF Foam Solution - This is a solution of water and the  foam concentrate after they have been mixed together in the correct proportions. In this case, 3% concentrate and 97% water.

AFFF Foam – When the foam solution is properly mixed it exits an aerating discharge device. (shown below.)  Fire-fighting foam is an extraordinarily stable mass of small air-filled bubbles, which have a lower density than oil, gasoline or water. Foam is made up of three ingredients - water, foam concentrate, and air. When mixed in the correct proportions, these three ingredients form a giant, fluffy foam blanket that snuffs out fire.

       An overhead AFFF aeration system turns AFFF solution into foam.

 The authoritative PFAS-Specific Sampling and Analysis Plan, (SAP) prepared for the Navy, the day after the leak, refers to “1,300 gallons of AFFF concentrate” released on November 29, 2022.

1,300 gallons of concentrate, when mixed with water and sent through an aerator, may be expected to produce 43,333 gallons of foam. (43,333 x .03 = 1,300)

The December 8, 2022 letter  from the EPA and the Hawaii Department of Health to Mr. Ernest Y.W. Lau, P.E., Manager and Chief Engineer Board of Water Supply City and County of Honolulu fails to mention that AFFF concentrate was released. Instead, it refers to foam.

In its press release, the Hawaii Department of Health also failed to mention  that AFFF concentrate spilled.

Predictably, the Defense Visual Information Distribution Service, (the Pentagon), failed to mention  that AFFF concentrate was released.

Civil Beat reported that the Navy released “5,000 gallons of liquid” back on Sept. 29, 2020 after an “inadvertent trigger” of the fire suppression system. A former Red Hill employee explained  that foam and water flooded the floor of an underground pump house.

An engineer familiar with AFFF systems told Military Poisons, “When the pressurized liquid concentrate squirts out of the stainless steel pipe and hits a surface, the process involves a degree of aeration resulting in a small amount of foam being formed.”

Civil Beat reported an analysis  by Eurofins Scientific showed one sample from the September 29, 2020 spill contained PFOS at 200,000 parts per trillion, (ppt). We don’t know if they sampled the foam or the concentrate.

If the 200,000 ppt concentration is from the foam, the concentrate might be expected to contain 6.66 million parts per trillion of PFOS.  It’s not out of the question. According to FOIA-obtained reports at Kadena Air Base, PFOS was found in concentrations up to 9.5 Billion parts per trillion.

According to a 2018 analysis, all AFFF concentrate piping is made of stainless steel. The reports says Red Hill has two 1,450-gallon foam concentrate tanks. If  all 2,900 gallons of foam were mixed as a 3% solution with water, then the respective totals of the AFFF produced by the suppression system might contain 96,666 gallons.  

Special thanks to the Downs Law Group for their continued financial support. We couldn’t continue to create these reports at this pace without their help. The firm is working to create a multi-base coalition to provide legal representation and blood testing to individuals like firefighters and others with a high likelihood of exposure to PFAS.

Military Poisons and the Women’s League for Peace and Freedom are continuing to raise funds to cover the costs of PFAS seafood testing in south Florida. You can make a tax-deductible contribution here.  What’s in your fish? What’s in your blood?

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December 19, 2022 Letter from Hawaii congressional delegation to GAO misses the mark

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Explaining the Red Hill Disaster