Is your airport protected against the environmental risks of fire?

Water used to fight large fires can become contaminated with pollutants and find its way into underlying soils, surrounding rivers and groundwater.

In this case, the fire caused severe damage to an airport car park where 1,500 vehicles were parked. Firewater from the blaze mixed with chemicals, including fuel, oils, and toxic heavy metals used in electric vehicle batteries, such as lithium, cobalt, nickel and manganese.

Despite efforts to pump the firewater into tanks, much of it made its way into the local drainage system, seeping through large, unlined soakaways into a local aquifer, normally used for drinking water. The situation was exacerbated by heavy rain over the following days.

Car Parks may not be an obvious source of pollution at airports, but this case demonstrates that environmental incidents can come from where you least expect them.

High airport clean-up and remediation costs

The resulting serious environmental harm led to the regulator imposing a clean-up order. The airport was required to stop all further water discharge until the water reached drinking standard, requiring the installation of expensive filtration systems.

Investigations are currently underway to find out if drinking water has been contaminated in other parts of the site. If so, new infrastructure may be needed to provide an alternative water source.

The total cost is estimated at up to $5 million, including $500,000 for the mitigation work to pump contaminated water away. Costs could escalate further if civil engineering works are needed.

Fire pollution risks not covered by general insurance

None of the environmental damage or clean-up costs were covered by general liability or property insurance. General liability is triggered only when damage is caused to third parties.

But because all the runoff was within the airport’s perimeter, there was no third-party damage. Property insurance covered the physical damage to the car park, but not the environmental consequences.

Airports may not see fire as one of their main pollution risks. However contaminated firewater can find its way into rivers and groundwater, posing serious risks to human health, wildlife and plant life.

The size of airports means the damage is likely to be confined within the apron, so there’s no cover under general liability.

This can leave operators seriously exposed. Fortunately, in this case the airport had a standalone environmental impairment liability (EIL) policy which did cover both the first party clean-up costs and the loss mitigation costs to divert the firewater.

Firefighting foams are an added concern

Another fire-related pollution risk comes from firefighting foams. Most foams used to fight fires involving flammable oils and liquids contain PFAS chemicals, which pose a risk to the environment and human health.

These are used regularly in live training exercises at airports. Also known as ‘forever chemicals’ they migrate rapidly once in the groundwater and are very difficult to remediate.

In a recent incident, large quantities of foam were released from a storage facility at a U.S. airport leading to an extensive clean-up operation.

Most traditional policies now have blanket PFAS exclusions, but it may still be possible to get cover in some circumstances under an EIL policy.

Other pollution risks from airports

Airports also face a range of gradual pollution risks which would fall outside the sudden and accidental cover provided by most general insurance policies, including:

• Fuel storage: The tanks and bunkers and pipelines used for aviation fuels are often decades old and at risk of leaking or seeping into the soil and water sources over time.
• De-icing liquid: Large quantities of de-icing liquids are applied to planes and airport vehicles in winter, containing chemicals that can cause environmental damage.
• Historic landfill: In the past, waste from planes and terminals often went to landfill sites within the airport perimeter. Much of this waste remains buried, containing toxins that can leach into surrounding land.

How to mitigate pollution risks from fire at airports

Airports should make sure that fire is recognized as an environmental and not just a property risk. It should be addressed in the environmental management plan, as well as the fire safety procedures, with specific measures to mitigate the impacts. These may include:

• Installing wastewater treatment systems to reduce the toxic content of runoff water before it reaches the environment
• Exploring alternatives to firefighting foams containing PFAS and finding ways to manage foam to prevent it being released into the environment
• Inspecting airport facilities to assess potential fire hazards, how they might impact the environment, and how to mitigate them
• Awareness training on the potential pollution impact of fires and how to prevent it
• Emergency drills with local fire services to include pollution containment measures
• Fire prevention systems such as fire-resistant building materials and automatic sprinkler systems where needed
• Strict fuelling procedures to minimize the risk of fuel spills and leaks that could increase fire and pollution risks

How environmental insurance can help

Environmental impairment liability (EIL) insurance covers first party clean-up and remediation costs regardless of any damage to third parties or their property. It includes pollution caused by gradual and historic pollution, not just sudden and accidental incidents.

EIL also covers:

• Statutory clean-up costs if the regulator orders you to clean up a site
• Crisis management support to manage the media response after an incident
• Business interruption covering loss of profits if the business has to close
• Legal defence costs if a claim goes to court
• D&O liability for environmental breaches
• Biodiversity restoration
• Loss mitigation to prevent further damage during an incident

Conclusion

Airport fires are a pollution risk as contaminated firewater and PFAS chemicals in firefighting foams can run off into soils and water sources. This is in addition to risks of gradual pollution from fuel leaks, de-icing fluids and landfill waste.

Environmental insurance can provide protection against both sudden and accidental and gradual pollution including first party clean up costs not covered by general insurance.

To find out more about pollution risk from airport fires, how to reduce your risks and WTW’s environmental insurance solutions, get in touch.