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.
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.
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.
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.
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:
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:
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:
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.
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