Airport_Business_December2019-January2020 - 16

ARFF
basis and has become
the "go-to" information
bank for environmental
professionals to keep abreast
of new requirements in this
ever changing regulatory
landscape.

Exposure to
PFAS can lead
to cancer
among other
conditions.

Contamination
investigations
at airport
The increase in regulatory
attention to PFAS has
led to rapidly evolving environmental
requirements for airports. So, it stands
to reason that airports across the country
are being tested for PFAS contamination
as it's considered to be a likely contributor
to PFAS contamination in the vicinity of
the airport. Although the presence and
extent of potential environmental impact
depends on the nature and history of past
AFFF use at each airport, the use of AFFF
has been mandated at airports across
the nation and consequentially PFAS
contamination is being found during
environmental investigations at many of
these airports.
The California State Water Boards
have decided to take a "phased approach"
in requiring different industries to
investigate their properties for PFAS
contamination. Not surprisingly,
Californian Airports are at the top of the
Phase I List. In March 2019, the State
Water Boards requested that 27 airports in
California submit workplans to test their
facilities for PFAS. Investigation typically
involves drilling borings to collect soil
samples and installation of temporary
or permanent groundwater monitoring
wells to collect groundwater samples. The
investigation will likely not only need to
be conducted where the AFFF was used
for storage and training but also where it
was used during an emergency response.
Often this is near active runways and in
other high risk areas. All environmental
assessment work is difficult and expensive
and is a complicated logistical dance
between different divisions, who operate
somewhat independently at airports.
Add in the need to investigate these
difficult access areas with additional
permitting/coordination, and the
logistical dance becomes a nightmare. A
total of 524 airports across the US were
required by the FAA to use AFFF and

SCS ENGINEERS

all can be considered suspect for PFAS
contamination. However, as of yet no
other regions in the US have state-wide
mandated airport investigations, but the
environmental industry anticipates that
it is coming soon.
The list is still growing, but so far
152 airport/heliport sites in Canada
and 20 airports in Australia have
confirmed releases of PFAS at airport
facilities. The Department of Defense is
investigating past PFAS contamination
and has identified over 400 military sites
with significant legacy PFAS concerns,
many of them either at air bases or
airports. Airports are not required by
law to investigate PFAS contamination.
Still, there are more than 75 lawsuits
across the country against entities that
have discharged the foam containing
PFAS, and the number is growing. In
Europe, Stockholm Arlanda Airport and
Copenhagen Airport may be important
sources for long-term contamination of
the nearby environment with PFAS.

PFAS-related operations/environmental
management and
litigation
As a result of the growing concern over
PFAS, airports face operational and
environmental challenges relative to
the existing and previous storage, use,
testing and/or disposal of AFFF. The
primary impacts to operations are related
to firefighting activities - specifically,
how airports procure, store, handle,
apply, remove and dispose of AFFF. With
regard to environmental management,
PFAS will have a potentially significant
impact on how environmental media
are investigated and remediated and
has the potential to significantly affect
capital improvement projects should

contamination of PFAS be encountered.
A l l air ports should careful ly
examine their current and past use of
these foams and take steps to manage
the liability risks associated with them.
Some airport industry officials hope that,
because the FAA requires airports to use
firefighting foam that contains PFAS, the
airports won't be held liable for letting it
contaminate their properties. Not every
lawyer thinks this argument will hold
up and a lobbying group for the airport
industry is pushing Congress to pass a law
that will limit their financial exposure. As
the legal questions get sorted out, airports
across the country are deciding whether
and how to respond to the potential
health consequences for residents who
live nearby.
To gauge the level of awareness
and gain a better understanding of
management practices, the Transportation
Research Board (TRB), a division of
the National Academies of Science
Engineering Medicine, conducted an
extensive survey of 167 North American
airports. As a result, the TRB published a
document regarding the Use and Potential
Impacts of AFFF containing PFAS at Airports.
Within this document is a link to a
screening tool (i.e., a macros-enabled
Microsoft Excel™ workbook) to better
integrate best management practices into
the AFFF life cycle at airport facilities,
identify and manage potential risks
associated with historical and/or current
AFFF use at their site, and prioritize
where resources need to be allocated to
address concerns regarding AFFF and
PFAS. The tool can be accessed at the
TRB website.
The very basic best practices are:
* Avoid direct release to the environment
to the greatest extent possible.
* Collect, treat and properly dispose of

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