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The emerging threat of PFAS contamination from aviation facilities

By Michael Bartlett

Posted on November 04th, 2019

Because of the unique ability of AFFF to rapidly suppress pool fires, both the Federal Aviation Administration (FAA) and National Fire Protection Association (NFPA) essentially mandate the use of aqueous fire suppressant foam for airport aircraft rescue and firefighting applications.

Testing has shown that no foaming agent can equal the performance of AFFF for airport applications.

Historically, aircraft rescue and firefighting services were required to use aqueous film-forming foam containing PFAS compounds for extinguishing fires and for fire-training exercises and equipment testing and calibration. Although the aviation industry phased out the use of PFAS in the early 2000s due to the health concerns, that doesn't mean the problem has gone away. Large volumes of toxic chemicals from the toxic foam may have entered the ground at the airports, contaminating the soil, groundwater or surface water. Because these substances can move quickly in the groundwater, this contamination could have been flushed into local streams and carried into surrounding neighborhoods, contaminating drinking water sources.

Why are PFAS-based AFFF products being used at aviation facilities?

Installations such as military bases, airports, fire stations, and refineries are potentially significant sources of PFAS contamination as a result of the use of AFFF to extinguish liquid hydrocarbon fires on these sites. The Department of Defense used it at all aircraft hangars, airfields, and aircraft fueling stations. The FAA adopted the foam to fight fires at all commercial and militaries airports.

Products with PFAS are demonstrably superior for extinguishing petroleum fires on air force bases than previously used protein-based foams. AFFF's chemical properties allow it to form a dense "foam blanket" that prevents oxygen from reaching the fire, making it highly effective at putting out hydrocarbon fuel fires such as oil, petroleum, and aviation fuels.

PFAS contamination at both military airbases and civilian airports

AFFF produces a thin aqueous film based on surface tension which spreads across the surface of the fuel, separating the fuel from oxygen, which suppresses vapor and can quickly extinguish petroleum fires on air force bases. Civil aviation is another user, for airport rescue and fire fighting vehicles as well as for the protection of aircraft hangars.

As the information on possible contamination with PFAS becomes more known, more commercial airports have detected levels of PFAS contamination on the ground, the impact of PFAS on groundwater affecting private drinking water wells adjacent to or near their facilities.

Many commercial airports share facilities with the U.S. military or are located at former military airbases. The Department of Defense has identified over 400 military sites with significant legacy PFAS concerns, many of them either at airbases or airports.

A legacy of PFAS soil and groundwater contamination

While PFAS can lead to cancer over time, many residents living near commercial and civilian airports must come to grips with the fact that they have been drinking contaminated water for decades.

The presence of PFAS identified in the soil, surface and underground waters around the following airports:

  • Los Angeles International Airport
  • San Antonio International Airport
  • King Salmon Airport
  • Dallas/Fort Worth International Airport
  • Washington Dulles International Airport
  • Pittsburg International Airport
  • Savannah-Hilton Head International Airport
  • Omaha Airport
  • Muskegon County Airport
  • Westchester County Airport
  • Bishop International Airport
  • Merced County Castle Airport
  • Adirondack Regional Airport
  • Maverick County International Airport
  • Rutland Southern Vermont Regional Airport
  • Dillingham Airport
  • Gustavus Airport
  • Milwaukee Mitchell International Airport
  • Gerald R. Ford International Airport
  • Fairbanks International Airports
  • Atlantic City International Airport
  • Philadelphia International Airport
  • Dane County Regional Airport
  • Tamworth Regional Airport
  • Rutland-Southern Vermont Regional Airport
  • Dowagiac Municipal Airport
  • Tucson International Airport
  • Manchester County Airport
  • Bemidji Regional Airport
  • Minneapolis-St. Paul International Airport
  • Salt Lake City International Airport
  • Klamath Falls International Airport
  • Reno Tahoe International Airport
  • Boise Airport
  • Great Falls International Airport
  • Salt Lake City International Airport
  • Sky Harbor International Airport
  • Cheyenne Municipal Airport
  • Will Rogers World Airport
  • Lincoln Municipal Airport
  • Hector Field International Airport
  • Tulsa International Airport

Last year, Congress passed legislation that will give commercial airports the option to switch to firefighting foams that do not include the highly toxic fluorinated chemicals. The measure would apply to 533 airports and aircraft companies in the U.S. and allow the airports to stop using foam containing those chemicals within two years of the law's passage.

A lot of commercial airports already switched to PFAS-free spurred on by the growing awareness of the potential threats fluorinated firefighting foam represents. However, this hardly eliminated the danger. In an extensive study conducted by a Washington-based activist organization, water wells around dozens of commercial airports tested a concentration of PFOS in excess of the minimum EPA safety guideline of 70 parts per trillion, with some reaching values as high as 13,700 ppt. The same sample, taken near Westchester County Airport, New York, contained a concentration of over 56,000 ppt for all PFAS chemicals.

How airports can be proactive about PFAS

Gaining a basic understanding of potential human health and economic impact from PFAS in the environment is the first great step in addressing these chemicals. Other important steps airports can take to address PFAS:

  • Identifying current and historic fire training locations, crash sites and testing areas and determine current and historic management practices for waste AFFF;
  • Identifying nearby drinking water sources, surface water bodies, and the basic geology - groundwater depth, the direction of flow, soil type, bedrock type;
  • Testing the soil and groundwater near its historic fire-training sites and other AFFF-use areas;
  • Inventorying existing AFFF stock is a prudent step to minimize the risk of potentially small issues from getting bigger;
  • Purchase of new equipment for testing and calibrating AFFF-dispensing vehicles without having any AFFF released to the environment;
  • Switching to an FAA-certified AFFF formulation that does not contain the long-chain PFAS chemicals;
  • Developing a public engagement strategy and effective remedial options.

Unfortunately, there are many airports that have yet to address PFAS, or even ask whether or not they should address PFAS.

PFAS compounds pose environmental risks at airport sites that should not be ignored or minimized. To tackle it properly requires an understanding of the background and consequences, how airports are currently responding, and what guidance may be issued in the future. Environmental Litigation Group is committed to remaining educated on the topic so that we can thoroughly address our clients' PFAS concerns.

How can Environmental Litigation Group help you

In recent years, there has been an emerging concern about potential health effects from exposure to high concentrations of PFAS. PFAS compounds pose environmental risks at airport sites that should not be ignored or minimized. To tackle it properly requires an understanding of the background and consequences, how airports are currently responding, and what guidance may be issued in the future. Environmental Litigation Group is committed to remaining educated on the topic so that we can thoroughly address our clients' PFAS concerns.

If you would like to discuss your PFAS-related concerns, please feel free to contact us. Our knowledgeable lawyers have many years of experience guiding clients through the complex legal issues presented by emerging chemical contaminants including per- and polyfluoroalkyl substances that have alleged to affect human health or the environment.