Use and Potential Impacts of AFFF Containing PFASs at Airports (2017)

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1 For decades, aqueous film-forming foam (AFFF) containing per- and polyfluoroalkyl substances (PFASs) has been used at airports across the United States and Canada for extinguishing fires and in training firefighters. While PFASs provide the principal efficacy of AFFF as a firefighting agent against Class B fires, the discharge to the environment of AFFF containing PFASs presents potentially unacceptable human health and ecological risks. Since the 1990s, data have been collected showing that earlier formulations of AFFF contained some PFASs that are persistent and bioaccumulative. Environmental regulation and guidance have developed in response to ecotoxicological studies, the establishment of standard field sampling techniques, and increased accuracy of laboratory analytical methods. In response to the introduction of U.S. EPA Significant New Use Rules (SNURs) in the United States and pursuant to the Canadian Environmental Protection Act, manufacturers have changed their AFFF formulations so that they are free of perfluorooctane sulfonic acid (PFOS), and manufacturers are in the process of developing formulations that are free of perfluorooctanoic acid (PFOA) (PFOS and PFOA are two of the most prevalent and potentially problematic PFASs.) Although advances have been made in risk management strategies and remediation technologies, research to identify applicable, cost-effective approaches to managing the impacts of AFFF and related PFASs at airports is ongoing. Under ACRP Project 02-60, a survey was conducted of 167 airports across the United States and Canada. Airport representatives, including emergency responders and environmental managers, were asked 42 questions about the management of AFFF at various life cycle stages at their airport, including procurement, storage, application, and disposal. In addition, the survey asked how airports may have addressed legacy environmental impacts associated with PFASs in environmental media (i.e., soil, groundwater, sediment, surface water) at airports where such environmental assessment and remediation had taken place. The research also included a literature review of peer-reviewed (e.g., scientific journal articles) and non-peer- reviewed (e.g., industry articles) materials and consultation with subject matter and industry experts. Based on the ACRP Project 02-60 research, this report identifies current regulations and regulatory guidance regarding the management of AFFF at the various life cycle stages and the impacts of PFASs on the environment, the current state of practice at civilian airports in the United States and Canada, and best management practices to help guide airports in mitigating future potential impacts associated with AFFF use and managing historical impacts associated with AFFF application. At the procurement stage, U.S. and Canadian airports are required to purchase fire- fighting foam that meets jurisdictional specifications MIL-F-24385 (MIL-SPEC) and CAN/ ULC-S560-06, respectively. As a result, alternatives to AFFF containing PFASs are limited. S u m m a r y Use and Potential Impacts of AFFF Containing PFASs at Airports

2 use and Potential Impacts of aFFF Containing PFaSs at airports Moreover, all firefighting foams, even those that do not contain PFASs, have the potential to impact the environment. Providing information on potentially adverse environmental impacts and other environmental considerations will help to foster the responsible purchase, use, and disposal of firefighting foams at airports. Survey results indicated that storage conditions for these chemicals vary among airports. Storage conditions should, at a minimum, meet the requirements listed on the product sheets provided by suppliers. At many airports, application and disposal of AFFF involve multi-departmental activities. Often, environmental personnel are the most aware of the implications associated with PFASs in AFFF, but they may not be aware of all of the ways that AFFF is tested or used by emergency response and/or operations personnel. For instance, in the survey conducted as part of this research, it was found that firefighting personnel may be aware that they are handling a chemical, but they may also falsely assume that the chemical is “safe” for the environment because historically they have been allowed to discharge/use it broadly. Awareness of methods for collection of discharged AFFF and disposal was not consistent among airports. Standardized sampling methodologies have been adapted for investigating the impacts of PFASs. Given the ubiquity of PFASs and their ability to stick to many different surfaces, cross-contamination is the largest concern in ensuring that samples collected are repre- sentative and will provide meaningful results. Standardized analytical methods have been developed for PFASs in drinking water—reinforcing the need for airports to use accredited laboratories with standardized testing methods for PFASs that will produce reproducible results. To help airport representatives apply the findings of the ACRP Project 02-60 research, a screening tool (i.e., a macros-enabled Microsoft Excel™ workbook) was developed that allows airports to better integrate best management practices into the AFFF life cycle at their 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 PFASs. Best management practices for airports managing AFFF and addressing environmental impacts related to PFASs are presented in Table S-1. Procurement: Regulatory Requirements regulatory requirements for safety/use. Meet the requirements of • ), Title 14 – Aeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139), in the United States • and Aerodromes, Part III Aerodromes, Airports and Heliports, in Canada Use short-chain fluorotelomer based AFFF (i.e., carbon chain C6 and below). Do not use long-chain (>C6) AFFF that may contain or degrade into perfluorooctanoic acid (PFOA), (PFOS), their salts and/or precursors. Comply with • U.S. EPA Significant New Use Rules (40 CFR 721.9582) • Canadian Environmental Protection Act Life Cycle Stage Recommended Best Description Management Practice The Code of Federal Regulations (CFR Canadian Aviation Regulations, Standard 323 Aircraft Fire Fighting at Airports Use firefighting foam that fulfills Table S-1. Best management practices for managing AFFF and addressing environmental impacts related to PFASs.

Summary 3 concentrates where possible. Upgrade equipment to be compatible with lower percentage use, when applicable. Storage Use appropriate containers. Read and follow storage procedures outlined in AFFF concentrate: • Material safety data sheets (SDSs) • Technical data sheets (TDSs) Store under appropriate conditions. Read and follow storage procedures outlined in Material SDS and TDS for the product. Containers for AFFF concentrate storage should be • Sealed • Secured • Stored in appropriate temperature ranges • Not be mixed (with other foam concentrates or brands) • In a designated area • Roofed/sheltered • Use bunded storage methods • Not stacked more than two drums high Application: Handling Store the recommended reserves. Know the current aircraft rescue and firefighting (ARFF) category of the airport and store the recommended reserve quantities as per the FAA (United States) or Transport Canada (Canada) requirements/recommendations. Staff awareness of PFASs and AFFF. Train all staff who could come into contact with AFFF about the human health and environmental implications associated with historical and current AFFF formulations. Train staff and follow industry- recommended procedures. When handling AFFF • Have a Safety Spill Plan in place when transferring AFFF • Read and follow handling procedures outlined in product SDS • Read and follow NFPA 402: Guide for Aircraft Rescue and Fire-Fighting Operations • Wear the appropriate personal protective equipment (PPE) (at a minimum as detailed in the product SDS) • Do not use galvanized pipe and fittings in contact with undiluted concentrate • Limit distance between storage and filling areas • Where possible, have more than one person assisting with moving AFFF containers Application: Firefighting Training Training practices. Firefighting training should • Follow a prescribed training schedule that aligns with the appropriate guidelines and regulations • Involve preparation in advance of training practices (e.g., develop and review safety spill plan in advance, communicate so that personnel are aware of and understand activities in advance) Life Cycle Stage Recommended Best Management Practice Description Procurement: AFFF Performance Confirm that AFFF purchased meets relevant performance standards. in the United States and Canada as follows: Demonstrate performance and quality meeting the performance standards for AFFF • United States Military Specification (MIL-SPEC): MIL-F-24385 (Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater) • Underwriters Laboratories Inc. (UL): Foam Equipment and Liquid Concentrates (UL 162) • Standards Council of Canada (SCC): CAN/ULC-S560-06 (Standard for Category 3 AFFF Liquid Concentrates) Procurement: Environmental Review environmental data, where available, from a product’s Choose a foam with the following criteria: • Highest lethal dose (LD50) • Lowest biochemical oxygen demand (BOD) • Lowest chemical oxygen demand (COD) • Highest LC50 • Highest half-maximal effective concentration (EC50) Procurement: System and Equipment • • Previous/existing AFFF type/batch Check compatibility with Existing systems and equipment AFFF that meets the above specifications comes in 3 percent and 6 percent concentrate formulations. Consideration specification. Compatibility Check compatibility of AFFF. Shift toward using 3 percent AFFF Table S-1. (Continued). (continued on next page)

4 use and Potential Impacts of aFFF Containing PFaSs at airports • Take place in an area where water/foam solution can be contained and collected for treatment • Consider using alternative foam products for training exercises Use appropriate training facilities. • Use a regional facility or host live-fire training for multiple airports at one facility • Configure training area to allow collection and disposal of discharged AFFF used during training • Do not discharge to ground (i.e., discharge of AFFF during training should be to an engineered, lined fire training area) • Locate training exercises away from storm drain inlets, drainage facilities, and surface water bodies Application: System and Equipment Testing Discharge and collect minimum volumes of AFFF. • Discharge the minimum volume of AFFF needed to test the system/equipment • Use the same collected samples for multiple tests, where applicable • Develop and employ a Safety Spill Plan • Collect discharge for storage and disposal • Conduct ground pattern tests first with water (ensure set-up), then with the foam solution • Ensure fittings are tight and secure • Maintain equipment in good condition to reduce spillage/waste Application: Aircraft Hangars Construct the aircraft hangar following local building code and to mitigate AFFF impacts. • Read and follow NFPA 402, 403, and 409 • Have piping that connects the foam to the fire suppression system be above ground, over a concrete floor • Provide protection for the aircraft hangar (including electrical and mechanical equipment) potentially exposed to AFFF during discharge tests Application: Firefighting Training/ Aircraft Rescue Provided standardized, industry- recommended training. • Educate and train staff in standardized procedures for safety and environmental concerns of AFFF • Follow industry-recommended practices, e.g., NFPA 403 Section 3.4.3 (2014); NFPA 1003, FAA Advisory Circular No. 150/5210-17C Application: Emergency Improve communication and response between environmental personnel and firefighting • Hazardous waste/spill response team should be nearby to provide preliminary containment and conduct clean-up activities as soon as feasible after emergency has been mitigated Life Cycle Stage Recommended Best Management Practice Description • Firefighting team should alert environmental team when deploying, moving, and/or testing AFFF Application: Discharge Dispose of foam-water, foam- hydrocarbon, and foam-soil mixtures as appropriate given the local guidelines, legislation, and regulations. • Personnel handling AFFF should wear appropriate PPE • Record AFFF types, quantities, and disposal method/destination • Dispose of discharged AFFF at an authorized, licensed location Disposal: Removal from Equipment or Systems Transfer by pump to containment vessel. • Personnel handling AFFF should wear appropriate PPE • Containment vessel should have secondary containment during removal/ transfer process • Flush/clean out equipment thoroughly, retaining rinse water • Use propane as a fuel source in lieu of flammable hydrocarbons Response personnel. Table S-1. (Continued).

Summary 5 Disposal: Removal from Equipment or Systems Disposal. • Dispose of discharged AFFF at an authorized, licensed location • In the United States, meet the requirements of the Code of Federal Regulations (CFR), Title 14 – Aeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139), 139.317 Aircraft Rescue and Firefighting: Equipment and Agents. Follow FAA Guidance Documents (Advisory Circulars and Cert Alerts); align with the targets of the U.S. EPA 2010/2015 PFOA Stewardship Program • In Canada, meet the requirements of the Canadian Aviation Regulations, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes and comply with Part III Aerodromes, Airports and Heliports of the Regulations. Section 323.08 of the Standard, Extinguishing Agents and Equipment • In Canada, comply with Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations (2008), which prohibits the manufacture, use, sale, offer for sale, and import of PFOS and products containing PFOS Legacy: Sampling for PFASs Use standardized field procedures, adapted for PFASs. • Avoid using polytetrafluoroethylene (PTFE), glass, and/or metals in sampling materials • Follow U.S. EPA Method 537 or modified U.S. EPA Method 537 – “Determination of selected perfluorinated alkyl acids in drinking water by solid phase extraction and liquid chromatography/tandem mass spectrometry (LC-MS/MS)” with respect to guidance for sample collection as appropriate for the sample media under investigation • Follow Transport Canada’s Perfluorochemical Sampling and Analysis Guidance • Follow United Nations Environment Programme (UNEP) Chemical Branch “PFAS analysis in water for the Global Monitoring Plan of the Stockholm Convention – set-up and guidelines for monitoring” Avoid cross-contamination. • Avoid using PTFE, aluminum foil, glass, and/or metal in sampling materials and containers • Verify drilling/hydroexcavation water is free of PFASs Life Cycle Stage Recommended Best Management Practice Description • Verify field equipment is cleaned in between sampling locations using water free of PFASs • Avoid wearing water resistant, waterproof, or stain-treated clothing during field programs • Avoid using waterproof fieldbooks/paper during field programs • Frequently change disposable, single-use gloves (e.g., nitrile or latex) • Do not bring food on-site in any paper packaging (e.g., fast food) • Field personnel should wash hands after eating and prior to donning PPE and engaging in sample collection • Field personnel should avoid directly contacting samples after touching their footwear (e.g., tying shoelaces) Legacy: Analysis of PFASs Avoid suspended particulate matter in aqueous samples. • Groundwater sampling should follow the field procedures established for low-flow purging (with adaptations to address the cross-contamination concerns identified above) • Surface water samples should be collected avoiding suspended and/or particulate matter in retrieved water samples Sampling frequency. Sampling programs should assess seasonal considerations and be conducted more than once to assess whether site conditions are changing (e.g., precursors transforming/ degrading to PFOS, PFOA). Quality assurance/quality control. • Use laboratory-supplied water free of PFASs • Use laboratory-supplied sample containers free of PFASs • Use appropriate QA/QC samples: field duplicates, and equipment and field reagent blanks Table S-1. (Continued). (continued on next page)

6 use and Potential Impacts of aFFF Containing PFaSs at airports • Contact the analytical laboratory prior to sampling to confirm that PFASs are included in their standard analysis and confirm the sampling requirements • Confirm that your commercial laboratory reports PFOS values that include both branched and linear isomers • Consider precursors’ influence in environmental quality assessment and discuss available precursor analyses with laboratory • Quality assurance and quality control flags should be reviewed with the commercial laboratory prior to accepting or rejecting the results Legacy: Risk Management Identify source areas at the airport. As part of the development of a conceptual site model (CSM), identify: • AFFF storage areas (i.e., where the potential for leaks and spills existed) • Areas where AFFF was applied as part of an emergency response • Firefighting training areas, burn pits, or other areas where AFFF may have been discharged as part of training • Areas where AFFF was discharged as part of foam testing • Areas where AFFF was loaded or removed from ARFF vehicles during vehicle maintenance • Historical disposal areas (e.g., where expired or contaminated AFFF concentrate was disposed to the environment or where AFFF foam was directed following release [including lagoons and retention ponds]) • Use MAPA Screening Tool to identify areas of potential environmental concern on or near the airport Identify and evaluate exposure pathways at the airport. As part of the development of a CSM, identify: • Human health—dermal contact and/or ingestion, potable water, fish consumption • Ecological—ecological soil contact, groundwater to surface water • Lateral migration pathways (e.g., surface runoff) • Vertical migration (e.g., infiltration/percolation) Legacy: Remediation Identify receptors at the airport. As part of the development of a CSM, identify: • Surface water bodies • Fish • Birds • Terrestrial animals • Invertebrates • Human receptors Life Cycle Stage Recommended Best Management Practice Description Use an accredited laboratory. In the United States, use a laboratory that is accredited by one (or more) of the following: • U.S. Department of Defense Environmental Laboratory Accreditation Program (DoD ELAP) (http://www.denix.osd.mil/edqw/Accreditation/AccreditedLabs.cfm) • American Association for Laboratory Accreditation (A2LA) (https://www.a2la.org/ dirsearchnew/newsearch.cfm) • Perry Johnson Laboratory Accreditation, Inc. (PJLA) (http://www.pjlabs.com/ search-accredited-labs) • ANSI-ASQ National Accreditation Board (ANAB) (http://search.anab.org/search- accredited-companies.aspx) • Laboratory Accreditation Bureau (L-A-B) (http://search.l-a-b.com/) In Canada, use a laboratory that is accredited by one (or more) of the following • SCC (https://www.scc.ca/en/accreditation/product-process-and-service- certification/directory-of-accredited-clients) • Canadian Association for Laboratory Accreditation Inc. (CALA) (http://www.caladirectory.ca/) Use standardized methodologies. • Check that your commercial laboratory is using suitable standard methodology to carry out analyses of PFASs Table S-1. (Continued).

Summary 7 that intercept the exposure pathway between source term and receptor. • Eliminate direct contact to soil impacted by PFASs and limit infiltration (and potential groundwater migration) by covering a portion of the site with pavement • Eliminate surface water runoff to prevent surface water from being impacted by sediment containing PFASs • Require workers to don appropriate PPE when working with AFFF or media impacted by PFASs • Prohibit potable groundwater or surface water use by providing an alternate water supply should a potable source be suspected of being impacted by PFASs • Install erosion and sediment controls in areas where soils may be impacted by PFASs and disturbance is planned Develop decision model to support the choice of short-term and long- term remediation strategies. Consider • Which PFASs are present and their physicochemical properties • Remedial objectives • Hydrogeological conditions • Off-site and on-site risks at present and in the future • Acceptable time frames for remediation • Technology acceptance and stakeholder involvement • Costs for remediation • Acceptable impacts on day-to-day operations Soil remediation techniques. • High-temperature incineration (>1100oC) • Landfill disposal at a facility that is appropriately designed to treat and handle PFAS- impacted soils immobilization/stabilization (e.g., amine-modified clay sorbents) Groundwater. • Pump and treat (e.g., using activated carbon, ion exchange resin, coagulation, membranes) • Permeable reactive barrier. -Note that activated carbon has been shown to be ineffective for removing short-chain PFASs Discharged AFFF. • Collect and contain discharged foam • Pretreatment may be required prior to acceptance at a wastewater treatment facility • If no suitable wastewater treatment is available, high-temperature incineration (i.e., > 1100°C) Life Cycle Stage Recommended Best Management Practice Description Adopt risk management strategies Where feasible, Table S-1. (Continued).