The summer conference for the Colorado Airport Operators Association (CAOA) always brings a good crowd of local airport and FAA staff and consultants to address current issues affecting the industry. This year the conference started off with a bang, addressing PFAS—aka per- and polyfluoroalkyl substances, aka potentially hazardous material likely present at commercial airports. Presenting on the topic were Mead & Hunt’s Dean Mericas, Environmental Manager at Denver International Airport (DEN) Jeff Arneson, and John Putnam from the Colorado Department of Health and Environment (CDPHE).
PFAS is a family of over 5,000 man-made chemicals developed in the 1940s that are included in a myriad of products like non-stick materials (i.e. Teflon), water-repellent fabrics, paints, pizza boxes, and, of particular importance to Part 139 airports, aqueous film-forming foam (AFFF). To date, the federal government has required commercial airports to use AFFF for fire protection at airports.
Of the 5,000+ chemicals that comprise PFAS, there are two specific components that have been found to lead to adverse health outcomes in humans: perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). While these two chemicals have been voluntarily phased out by industry, they are still persistent in the environment. The key elements that make PFAS-associated products so effective are unfortunately the same elements that make it so difficult to eradicate: it sticks! Earlier this year, the EPA issued a lifetime health advisory guideline of 70 parts per trillion but has not yet established any enforceable regulatory measures regarding PFAS. The agency is continuing to study the compound and could potentially designate it as a hazardous material in the future.
In the meantime…
Without federal guidance on how to eradicate the chemical, airports may now find themselves with years of built-up contamination left by firefighting training exercises or actual fire events. To address the issue, DEN is taking measures to safely dispose of the material. They have properly disposed of all C-8 PFAS liquids (the more toxic cousin to C-6 PFAS) and have shipped contaminated soils to a facility in Oklahoma. Additionally, the airport is researching how international airports sustainably discharge the water-foam mixture of fluorine-free products. To further prevent contamination, DEN has invested in no-foam testing equipment for training. The PFAS issue is not fully resolved, but it can certainly be addressed appropriately.
The State of Colorado is also taking steps to address the issue. Recently, the Colorado legislature issued House Bill 1279 which bans the sale of Class B AFFF, bans PFAS foams for training and identifies provisions related to equipment used with AFFF. In absence of Federal direction, the CDPHE is developing a Comprehensive Plan and Strategy for Colorado to get ahead of the issue.
PFAS is an important issue affecting airports today. To tackle it appropriately requires an understanding of the background and challenges, how airports are currently responding, and what guidance may be issued in the future. We are committed to remaining educated on the topic so that we can address client PFAS concerns moving forward.
