Ford Int’l Takes Action to Manage Potential Environmental Impacts of Firefighting Foam

In 2016, dozens of U.S. communities were hit with alarming news: Harmful chemicals from a large family of man-made compounds known as PFAS (short for per- and poly-fluoroalkyl substances) had been found in their drinking water. In fact, a nationwide groundwater study detected PFAS-contaminated drinking water in 43 states. Many of the affected communities were near military bases, airports and industrial sites—a clue that inspired more research.

The issue hit close to home for Gerald R. Ford International Airport (GRR) last spring, when local media ran targeted news coverage about GRR’s use of aqueous film-forming foam (AFFF), the FAA-mandated firefighting material that contains PFAS. Like many others throughout the aviation industry, the Michigan airport had historically sprayed AFFF during training exercises and for equipment calibration, as required by law.

After a provocative seven-minute television expose aired, GRR became one of the first commercial airports to be propelled into what has become an industry-wide challenge related to PFAS exposure and possible contamination. And true to its reputation for environmental stewardship, GRR worked quickly to proactively address the issue and respond to questions from regulators and the public.

The airport’s voluntary, proactive measures include:

• switching to an FAA-certified AFFF formulation that does not contain the long-chain PFAS chemicals that are most often associated with possible health and environmental impacts;
• acquiring new equipment to test and calibrate AFFF-dispensing vehicles without having any AFFF released to the environment;
• developing a strategic environmental investigation plan;
• testing the soil and groundwater near its historic onsite firefighter training facility and other AFFF-use areas; and
• paying to test neighboring wells and drinking water to protect against any possible exposure above state standards.

“We have learned there are remnants of AFFF [sprayed during training exercises from the 1970s to the 1990s],” reports Casey Ries, P.E., the airport’s engineering and planning director. “There is PFAS in the dirt around the old firefighter training site; but we have not found any drinking water samples with levels above the Environmental Protection Agency’s (EPA’s) lifetime health advisory, nor have we identified a pathway from our former firefighter training area to a drinking water source.”

Airport officials note that they acted quickly, but responsibly—and plan to continue to do so. Given the public controversy and potential for litigation, GRR consulted its on-call environmental team including LimnoTech, Mead & Hunt, and the law firm of Barnes & Thornburg LLP.

“This issue is very complicated and challenging,” says Jeffrey Longsworth, a partner at Barnes & Thornburg. “It presents challenges because it’s emerging faster than the regulatory process can react. There are technology issues—in this case, being able to measure parts per trillion. There are health concerns that are real but still somewhat unquantified. And, we are still trying to assess risk, because there are approximately 4,000 of these compounds. This is a very challenging issue with a lot of public and media scrutiny involved.”

While GRR may have been “outed” early, PFAS contamination is an issue for all commercial airports that must use AFFF onsite. “Airports really factor into this discussion because of the material we carry on our fire trucks,” explains Ries. “Any federally-certified, commercial (also called “Part 139”) airport is required to have AFFF on hand and on our fire trucks, and ready to be discharged in an emergency. AFFF is mandated by the FAA and must contain PFAS.”

In other words, any Part 139-compliant airport is a potential source of PFAS contamination.

LimnoTech, an environmental engineering and consulting firm, helped lead the investigation. “Given the evolving regulations and the state of understanding, we felt it critical that the investigation be guided using a measured and data-driven approach,” explains Scott Bell, P.E., BCEE, senior environmental engineer and vice president at LimnoTech. “It has been our experience that regulators in these situations sometimes recommend activities that do not necessarily serve the long-term interest of assessing actual environmental impacts and that will support identification of appropriate follow-up actions.”

The airport addressed the implications in a recent press release: “Learning about PFAS and its impacts has become an evolving national conversation taking place at airports, military bases and other facilities across the country. Our commitment to environmental stewardship and our community has always been part of the airport’s foundation, and that commitment continues to guide our work moving forward.”

What are PFAS?

PFAS are known as emerging contaminants, because concerns about their environmental and human health effects are still being researched and much is still unknown. For these reasons, PFAS are the subject of evolving regulatory scrutiny and technical debate.

Longsworth explains that PFAS entered the scene in the 1940s, and are currently used in hundreds of common products and industrial processes. Consumers are regularly exposed to PFAS in non-stick cookware, water-resistant clothing, food packaging, cleaning products and personal care items. At airports, PFAS are used in firefighting foams, and it is these foams that are often implicated when PFAS are found in nearby groundwater, he explains, even though many sources exist beyond airports.

Studies show that once PFAS are in the groundwater or environment, they stay there for a long time. And because our bodies are not very good at breaking them down, they tend to build up in our organs or tissues, which can eventually lead to health problems. Research finds that high levels of PFAS can change hormone levels, and affect liver, thyroid and pancreatic function. Studies also show PFAS can affect fetal and child development, leading to possible growth, learning or behavioral problems. Other research links them to cancer, immune system disorders and fertility problems.

Management Strategies

There are three broad categories of situations when airports might discharge AFFF. Ries urges airports to take a close look at each one to find ways to minimize the potential spread of PFAS.

Airports use AFFF during emergencies to suppress and extinguish fires. It is so effective that once sprayed across a fire, a safety “blanket” is formed, allowing passengers exiting an aircraft and personnel fighting the fire to do so safely.

Airports also use the foam for FAA-required equipment calibration. Every 12 months, airports must confirm that their crash trucks are discharging foam in the correct concentration. To do so, many discharge a small amount, test it and verify that the correct type and amount of foam was released. The most common formulation is 97% water and 3% AFFF, notes Ries.

Finally, airports may have historically discharged AFFF during some live fire training exercises. Typically, they limited the amount sprayed because of the cost of AFFF and challenges related to reigniting a burn pit once the AFFF material has been sprayed, Ries comments.

Because AFFF will continue to be the go-to fire suppression option for aircraft emergencies (at least until FAA certifies an alternative), GRR has developed new standard procedures regarding its use. “Safety of passengers is paramount and our No. 1 priority in an emergency,” Ries emphasizes. “In the event that AFFF is discharged, there is a physical cleanup process in place to capture soils and liquid runoff and contain them for disposal.”

The airport addresses other instances of AFFF/PFAS use in its remediation program. It stopped spraying foam during onsite training exercises decades ago, and firefighters now train at other facilities. “Many of our counterparts have done the same,” Ries reports.

In mid-January, FAA published Cert Alert 19-01, Aqueous Film Forming Foam (AFFF) Testing at Certificated Part 139 Airports, to provide information about optional equipment for testing AFFF systems on airport rescue and firefighting vehicles.

The Cert Alert recommended three FAA-approved systems that enable testing but limit or eliminate the need to dispense AFFF onto the ground:

• Ecologic, from E-One;
• NoFoam System, by NoFoam Systems; and
• Oshkosh Eco EFP (Electronic Foam Proportioning) System

The official notice also recommends establishing procedures for containing AFFF during training and/or testing, as well as establishing proper handling and disposal procedures during testing and re-servicing response vehicles that dispense AFFF.

GRR purchased Ecologic, a mobile test cart from E-ONE, for $35,000. It is an input-based testing system designed to test the accuracy of AFFF systems without the expense or environmental impact of using foam for output-based tests. A single, compact cart can test multiple trucks and is an excellent system for retrofitting vehicles currently in the fleet, says Ries.

“This small trailer has the ability to hook into any one of our crash trucks, so it can calibrate all three pieces of equipment in a mobile fashion,” he elaborates. “The Ecologic is retrofitted into the plumbing of the trucks to bypass the foam tank, but it is able to meter the draw out of the tanks to verify that the system is functioning correctly and the proportioning is appropriate.”

Test & Respond

“We conform to the minimum annual calibration of equipment; we don’t hold fire training on site; and fortunately, we have not had an aircraft incident in many years,” summarizes Ries. “So the rest of our environmental response has focused on historical use. We know that decades ago, foam was discharged in a training area on airport property. So we are working on moving forward as safely as possible.”

To understand the potential for harm, GRR worked with the Michigan Dept. of Environment, Great Lakes and Energy (EGLE), and county and state health departments.

GRR began the testing process by drilling five deep groundwater monitoring wells and 10 shallow borings on airport property. This helped the project team characterize conditions and plan subsequent steps. “Our scientific approach has been designed to address the highest areas of potential first, and is a continued, deliberate investigation,” explains Ries.  

The airport also tested the drinking water/wells of 28 private residences, after offering the service option to 44 homeowners. Test results showed non-detectible levels of PFOA and PFOS, two PFAS compounds for which Michigan has established criteria. Acceptable levels are below 70 parts per trillion (ppt) combined. Dean Mericas, Ph.D., of Mead & Hunt points out this is equivalent to 70 drops in an Olympic-sized pool or 70 seconds in about 32,000 years. State regulatory agencies confirmed that the low-level results at the homes tested do not pose health concerns.

“We applaud the airport’s efforts in going above and beyond the requirements to conduct off-site residential testing,” said Adam London, administrative health officer, Kent County Health Department, in a press release. “Based on the data and related results, we concur there is no need to continue additional residential testing at this time.”

His comments followed GRR’s June 2018 announcement that results for the presence of PFAS in groundwater on airport property fell below the state of Michigan PFAS health advisory level and cleanup criteria. Even though results were below health advisory levels, GRR went beyond regulatory requirements and tested off-site private drinking water wells northeast of the airport—the direction the groundwater flows.

But the airport isn’t stopping its efforts there.

“We are looking at locations where foam could have been discharged, the soil type at these locations, and the flow of water—both surface and groundwater—at those locations,” says Ries. “We’ve taken water table samples, shallow water samples and soil samples to understand where we are today.”

The ultimate goal is to determine that there is no hazard. “But we are learning with PFAS, that is very, very difficult,” he explains. “As it moves through the environment, it changes. That makes it hard to follow.”

Open Communication Policy

“PFAS are out there, and airports need to be aware what’s going on,” advises Ries. “Unfortunately, a lot of airports don’t fully understand the issue; but they need to.”

For this reason, Ries, Longsworth and personnel from Mead & Hunt joined forces to present an educational webinar about the topic on June 20. The webinar, presented by the Airport Consultants Council, was designed to help participants identify likely sources of PFAS contamination at their airports, define potential risks and create a step-by-step plan to address and manage them. After it airs, the webinar will be available at the ACC Training Hub, found at https://training.acconline.org/live-webinars.

GRR’s participation in the webinar was not surprising. The airport believes in being open about its experience and efforts with fellow airports and the general public. “I always tell people that public relations is telling our story so that someone doesn’t tell it for us,” muses Tara Hernandez, the airport’s director of marketing and communications. “It’s very easy for the media to point fingers, especially when groundwater contamination is a concern. But we have taken efforts to really engage the community. We held community forums where residents could openly talk about the issue with Casey [Ries) and our CEO.”

Her advice to other airports grappling with the PFAS controversy? “When dealing with an environmentally sensitive issue, you want to communicate with the people it could potentially affect. Keep them aware of the steps you are taking and the testing you are doing.”

In fact, Hernandez suggests keeping the public informed every step of the way. In addition to holding public forums and granting media interviews, GRR posted information on the FAQ page of its website.

“Being open has gained us a lot of respect among community members,” Hernandez reflects. “They call us and visit us instead of posting about it on social media or going to the news media. They have trust in us because they know we are doing all that we can to be good environmental stewards.”

Act Now

Industry insiders tracking the PFAS issue foresee new regulations for airports.

“In the near-term, I anticipate that regulatory standards will be set at the national and/or state level to provide a basis for regulatory limitations, as well as response criteria,” states Mericas. “The USEPA PFAS Action Plan identified this as a priority. Given the evolving nature of scientific understanding on impacts, I wouldn’t venture a guess at this time as to where limits for various media and protected resources will be set.”

Even though federal standards are still pending, Longsworth advises airports to pay attention on the regulatory front. Many states are moving forward with regulatory actions as EPA continues to research the issues and develop possible regulations. Moreover, EPA released a national PFAS strategy in mid-February that focuses on multi-regulatory approaches, but most of the attention has been on developing drinking water standards. According to Longsworth, the agency plans to designate some PFAS as hazardous substances, perhaps in 2019. Congress also has entered the picture, with hearings and over 30 bills introduced in recent months in both the Senate and House of Representatives.

But new EPA standards will take time. “There are over 450 military bases that have problems with PFAS; so, the EPA cannot just promulgate regulations without buy-in from the Department of Defense and other federal agencies,” reasons Longsworth. “The EPA is working hard to move regulatory protections forward, to do the right thing, but it also needs buy-in and support from the rest of the government.”

Changes are also afoot at the FAA. An amendment to the 2018 FAA Reauthorization Bill requires the agency to research and approve a PFAS-free AFFF within three years. FAA has since built a research center to study PFAS alternatives.

“There are differing perceptions on how well fluorine-free AFFF works,” says Longsworth, noting that it’s currently used at some foreign airports and in non-airport settings in the U.S. 

Various states are also addressing the PFAS issue, with many establishing their own standards. Fresh on the heels of the Flint water crisis, Michigan is leading the way. It developed the Michigan PFAS Action Response Team, which is coordinating initiatives among the state’s environmental and health agencies.

California recently announced a measure that requires its 31 commercial airports to investigate for PFAS contamination, in what Longsworth describes as a “limited and for many an unreasonable timeline.”

Even with regulations in a state of flux, he encourages airports to determine their PFAS exposure, reduce use of AFFF, and begin remediation if necessary.

“If you believe your site may have PFAS contamination, and there may be a pathway for that contamination to get into the groundwater offsite, there is a risk to not investigating,” he advises. “It may ultimately come back to you as causing a health issue and a public relations problem, let alone expose you to significant potential liability. While there may be no legal obligation to investigate today, you should be considering all your options now. It won’t get any easier moving forward.”