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The National THE NATIONAL ACADEMIES PRESSAcademies of MENEGDIINCEINEERING http://nap.edu/24800 AG IP DETAILS 222 pages | 8.5 x 11 | PAPERBACK ISBN 978-0-309-44638-9 | DOI 10.17226/24800 GET THIS BOOK FIND RELATED TITLES CONTRIBUTORS Andrew H. Thalheimer, Leah B. McConney, Indra K. Kalinovich, Anne V. Pigott, Jennifer D. Franz, Heather Taylor Holbert, Dean Mericas, and Zachary J. Puchacz; Airport Cooperative Research Program; Transportation Research Board; National Academies of Sciences, Engineering, and Medicine Visit the National Academies Press at NAP.edu and login or register to get; - Access to free PDF downloads of thousands of scientific reports - 10% off the price of print titles - Email or social media notifications of new titles related to your interests - Special offers and discounts Distribution, posting, or copying of this PDF is strictly prohibited without written permission of the National Academies Press. (Request Permission) Unless otherwise indicated, all materials in this PDF are copyrighted by the National Academy of Sciences. Copyright National Academy of Sciences. All rights reserved. US00004577 Use and Potential Impacts of AFFF Containing PFASs at Airports AI RPORT COOPERATI VE RESEARCH PROGRAM Use and Potential Impacts of AFFF Containing PFASs at Airports Andrew H. Thalheimer Leah B. McConney Dillon Consulting Limited Halifax, NS, Canada Indra K. Kalinovich Dillon Consulting Limited Winnipeg, MB, Canada Anne V. Pigott Dillon Consulting Limited Vancouver, BC, Canada Jennifer D. Franz Heather Taylor Holbert JD Franz Research, Inc. Sacramento, CA Dean Mericas Mead & Hunt, Inc. Austin, TX Zachary J. Puchacz Mead & Hunt, Inc. Lansing, MI Subscriber Categories Aviation Environment Research sponsored by the Federal A via tio n A dm inistration I TRANSPORTATION RESEARCH BO ARD The National Academies of S C IE N C E S E N G IN E E R IN G M E D IC IN E 2017 Copyright National Academy of Sciences. All rights reserved. US00004578 Use and Potential Impacts of AFFF Containing PFASs at Airports AIRPORT COOPERATIVE RESEARCH PROGRAM Airports are vital national resources. They serve a key role in trans portation of people and goods and in regional, national, and interna tional commerce. They are where the nation's aviation system connects with other modes of transportation and where federal responsibility for managing and regulating air traffic operations intersects with the role of state and local governments that own and operate most airports. Research is necessary to solve common operating problems, to adapt appropriate new technologies from other industries, and to introduce innovations into the airport industry. The Airport Cooperative Research Program (ACRP) serves as one of the principal means by which the airport industry can develop innovative near-term solutions to meet demands placed on it. The need for ACRP was identified in TRB Special Report 272: Airport Research Needs: Cooperative Solutions in 2003, based on a study spon sored by the Federal Aviation Administration (FAA). ACRP carries out applied research on problems that are shared by airport operating agen cies and not being adequately addressed by existing federal research programs. ACRP is modeled after the successful National Cooperative Highway Research Program (NCHRP) and Transit Cooperative Research Program (TCRP). ACRP undertakes research and other technical activi ties in various airport subject areas, including design, construction, legal, maintenance, operations, safety, policy, planning, human resources, and administration. ACRP provides a forum where airport operators can cooperatively address common operational problems. ACRP was authorized in December 2003 as part of the Vision 100-- Century of Aviation Reauthorization Act. The primary participants in the ACRP are (1) an independent governing board, the ACRP Oversight Committee (AOC), appointed by the Secretary ofthe U.S. Department of Transportation with representation from airport operating agencies, other stakeholders, and relevant industry organizations such as the Airports Council International-North America (ACI-NA), the American Associa tion of Airport Executives (AAAE), the National Association of State Aviation Officials (NASAO), Airlines for America (A4A), and the Airport Consultants Council (ACC) as vital links to the airport community; (2) TRB as program manager and secretariat for the governing board; and (3) the FAA as program sponsor. In October 2005, the FAA executed a contract with the National Academy of Sciences formally initiating the program. ACRP benefits from the cooperation and participation of airport professionals, air carriers, shippers, state and local government officials, equipment and service suppliers, other airport users, and research organi zations. Each of these participants has different interests and responsibili ties, and each is an integral part of this cooperative research effort. Research problem statements for ACRP are solicited periodically but may be submitted to TRB by anyone at any time. It is the responsibility of the AOC to formulate the research program by identifying the highest priority projects and defining funding levels and expected products. Once selected, each ACRP project is assigned to an expert panel appointed by TRB. Panels include experienced practitioners and research specialists; heavy emphasis is placed on including airport professionals, the intended users of the research products. The panels prepare project statements (requests for proposals), select contractors, and provide technical guidance and counsel throughout the life of the project. The process for developing research problem statements and selecting research agencies has been used by TRB in managing coop erative research programs since 1962. As in other TRB activities, ACRP project panels serve voluntarily without compensation. Primary emphasis is placed on disseminating ACRP results to the intended users of the research: airport operating agencies, service pro viders, and academic institutions. ACRP produces a series of research reports for use by airport operators, local agencies, the FAA, and other interested parties; industry associations may arrange for workshops, training aids, field visits, webinars, and other activities to ensure that results are implemented by airport industry practitioners. ACRP RESEARCH REPORT 173 Project 02-60 ISSN 2572-3731 (Print) ISSN 2572-374X (Online) ISBN 978-0-309-44638-9 Library of Congress Control Number 2017939583 2017 National Academy of Sciences. All rights reserved. COPYRIGHT INFORMATION Authors herein are responsible for the authenticity of their materials and for obtaining written permissions from publishers or persons who own the copyright to any previously published or copyrighted material used herein. Cooperative Research Programs (CRP) grants permission to reproduce material in this publication for classroom and not-for-profit purposes. Permission is given w ith the understanding that none of the material will be used to imply TRB, AASHTO, FAA, FHWA, FMCSA, FRA, FTA, Office of the Assistant Secretary for Research and Technology, PHMSA, or TDC endorsement of a particular product, method, or practice. It is expected that those reproducing the material in this document for educational and not-for-profit uses will give appropriate acknowledgment of the source of any reprinted or reproduced material. For other uses of the material, request permission from CRP. NOTICE The research report was reviewed by the technical panel and accepted for publication according to procedures established and overseen by the Transportation Research Board and approved by the National Academies of Sciences, Engineering, and Medicine. The opinions and conclusions expressed or implied in this report are those of the researchers who performed the research and are not necessarily those of the Transportation Research Board; the National Academies of Sciences, Engineering, and Medicine; or the program sponsors. The Transportation Research Board; the National Academies of Sciences, Engineering, and Medicine; and the sponsors of the A irport Cooperative Research Program do not endorse products or manufacturers. Trade or manufacturers' names appear herein solely because they are considered essential to the object of the report. Published research reports o f the AIRPORT COOPERATIVE RESEARCH PROGRAM are available from Transportation Research Board Business Office 500 Fifth Street, NW Washington, DC 20001 and can be ordered through the Internet by going to http://www.national-academies.org and then searching for TRB Printed in the United States of America Copyright National Academy of Sciences. All rights reserved. US00004579 Use and Potential Impacts of AFFF Containing PFASs at Airports The National Academies o f SCIENCES ENGINEERING * MEDICINE The National Academy of Sciences was established in 1863 by an Act of Congress, signed by President Lincoln, as a private, n o n governm ental institution to advise the nation on issues related to science and technology. M embers are elected by their peers for outstanding contributions to research. Dr. M arcia M cN utt is president. The National Academy of Engineering was established in 1964 under the charter of the N ational Academy of Sciences to bring the practices of engineering to advising the nation. Members are elected by their peers for extraordinary contributions to engineering. Dr. C. D. M ote, Jr., is president. The National Academy of Medicine (form erly the Institute of M edicine) was established in 1970 u nder the ch arter of the N ational Academy of Sciences to advise the nation on medical and health issues. Members are elected by their peers for distinguished contributions to m edicine and health. Dr. V ictor J. D zau is president. The three Academies work together as the National Academies of Sciences, Engineering, and Medicine to provide independent, objective analysis and advice to the nation and conduct oth er activities to solve com plex problem s and inform public policy decisions. The Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in m atters of science, engineering, and medicine. Learn more about the N ational Academies of Sciences, Engineering, and M edicine at www.national-academies.org. The Transportation Research Board is one of seven m ajor program s of the National Academies of Sciences, Engineering, and Medicine. The mission of the T ransportation Research Board is to increase the benefits th at tran sp o rtatio n contributes to society by providing leadership in transportation innovation and progress th ro u g h research and inform ation exchange, conducted w ithin a setting th at is objective, interdisciplinary, and m ultim odal. The B oard's varied com m ittees, task forces, and panels annually engage about 7,000 engineers, scientists, and other transportation researchers and practitioners from the public and private sectors and academia, all of whom contribute their expertise in the public interest. The program is supported by state tran sp o rtatio n departm ents, federal agencies including the com ponent adm inistrations of the U.S. D epartm ent of Transportation, and other organizations and individuals interested in the development of transportation. Learn more about the T ransportation Research Board at www.TRB.org. Copyright National Academy of Sciences. All rights reserved. US00004580 Use and Potential Impacts of AFFF Containing PFASs at Airports P R O G R A M SC U U r L K A I I V K A K Hla a n r n a t i \ / r l j l ln r r r a n z"' i i CRP STAFF FOR ACRP RESEARCH REPORT 173 Christopher J. Hedges, Director, Cooperative Research Programs Lori L. Sundstrom, Deputy Director, Cooperative Research Programs Michael R. Salamoile, Manager, Airport Cooperative Research Program Joseph D. Navarrete, Senior Program Officer Hana Vagnerova, Senior Program Assistant Eileen P. Delaney, Director ofPublications Ellen M. Chafee, Senior Editor ACRP PROJECT 02-60 PANEL Field of Environment Michael R. Rantala, Halifax International Airport Authority, Enfield, NS (Chair) Jennifer A. Field, Oregon State University, Corvallis, OR Michael A. Gonsalves, CB&I, Tampa, FL Kari Junco, Dallas/Fort Worth Airport Board, DFW Airport, TX Geoff Nielsen, City ofPhoenix Fire Department, Phoenix, A Z Adam Walters, Southwest Airlines Co., Dallas, TX Michael Lamprecht, FAA Fiaison Marc Tonnacliff, FAA Fiaison Linda Gaines, U.S. Environmental Protection Agency Fiaison Christine Gerencher, TRB Fiaison Copyright National Academy of Sciences. All rights reserved. US00004581 Use and Potential Impacts of AFFF Containing PFASs at Airports FOREWORD By Joseph D. Navarrete Staff Officer Transportation Research Board ACRP Research Report 173: Use and Potential Impacts o f AFFF Containing PFASs at A ir ports is a comprehensive resource for understanding the potential environmental and health impacts of per- and polyfluoroalkyl substances (PFASs) typically found in aqueous film forming foams (AFFFs). The report will be of particular interest to airport industry practi tioners who wish to learn about the issue, take steps to identify areas of potential concern at their airport, and implement recommended management and remediation practices. AFFF has been used for extinguishing fires and for firefighter training at airports for decades. The use of AFFF results in the release of PFASs into the environment. Some PFASs are known to be persistent in the natural environment and pose potential hum an and eco logical health risks. Government agencies are developing regulation of these chemicals, and these regulations will likely impact airports. Research was needed to help airports identify potential areas im pacted by AFFF use and minimize further potential impacts from future actions. The research, led by Dillon Consulting Limited, included a review of literature regard ing environmental fate and transport and remediation of PFASs, both in N orth America and in other world regions, with a particular focus on the use of AFFF in airport settings. To gauge the level of awareness and gain a better understanding of management practices, the research team conducted an extensive survey of 167 N orth American airports. The research team also reached out to subject m atter experts, including AFFF manufacturers, emergency response personnel, industry trade organizations, academia, analytical laboratories, and government regulators. The report features a prim er on PFASs that summ arizes their com position, structure, and sources, as well as potential environmental and toxicological concerns about PFASs, regulatory issues, and how PFASs may affect airports. The report also provides a discus sion of AFFF management in an airport setting and recommended practices to investigate legacy environmental impacts, potential risks, and remediation options. To help airports identify areas of potential environmental concern, the research team developed the Managing AFFF and PFASs at Airports (MAPA) Screening Tool. The screen ing tool provides results for the airport as a whole and for individual areas of potential concern. The tool can also be used to foster collaboration among functional departments responsible for management of AFFF and assessment of contam ination by PFASs and rem e diation. The tool can be accessed at www.trb.org/main/blurbs/175866.aspx. Copyright National Academy of Sciences. All rights reserved. US00004582 Use and Potential Impacts of AFFF Containing PFASs at Airports AUTHOR ACKNOWLEDGMENTS The research upon which this report is based was performed under ACRP Project 02-60 by Dillon Consulting Limited (Dillon). Dillon was supported by JD Franz Research, Inc. (JD Franz Research) with support from Pacific Market Research, and Mead & Hunt, Inc. (Mead & Hunt). Andrew H. Thalheimer was the principal investigator and the principal in charge of the project. The other authors of this report are Dr. Indra Kalinovich, Anne Pigott, and Leah McConney of Dillon, Dr. Jennifer Franz and Heather Taylor Holbert of JD Franz Research, and Dr. Dean Mericas and Zachary Puchacz of Mead & Hunt. The research team w ould like to th an k the following airport staff and fire departm ents w ho participated in this research and contributed valuable inform ation to support the development of this reference document: Aberdeen Regional Airport Abilene Regional Airport Akron-Canton Regional Airport Albany International Airport Alexandria International Airport Anchorage International Airport Arnold Palmer Regional Airport Asheville Regional Airport Atlantic City International Airport Austin Straubel International Airport Austin-Bergstrom International Airport Baltimore/Washington International Thurgood Marshall Airport Bangor International Airport Baton Rouge Metropolitan Airport, Ryan Field Bill and Hillary Clinton National Airport/Adams Field Boeing Field/King County International Airport Bradley International Airport Brookings Regional Airport Buffalo/Niagara International Airport Burbank Bob Hope Airport Calgary International Airport Canyonlands Field Airport Cape Girardeau Regional Airport Charles B. Wheeler Downtown Airport Charles M. Schulz - Sonoma County Airport Charleston International Airport Charlotte Douglas International Airport Charlottetown International Airport Cincinnati Municipal Airport-Lunken Field Cincinnati/Northern Kentucky International Airport City of Colorado Springs Municipal Airport Cleveland Hopkins International Airport Coeur d'Alene Airport - Pappy Boyington Field Corpus Christi International Airport Dallas Love Field Dallas/Fort Worth International Airport Dane County Regional Airport-Truax Field Denver International Airport Des Moines International Airport Detroit Metropolitan Wayne County Airport Dickinson Theodore Roosevelt Regional Airport Dodge City Regional Airport Dothan Regional Airport Eagle County Regional Airport Edmonton International Airport Eglin Air Force Base El Paso International Airport Eppley Airfield Fairbanks International Airport Fort Lauderdale-Hollywood International Airport Francisco C. Ada/Saipan International Airport Fredericton International Airport Fresno Yosemite International Airport Gander International Airport General Mitchell International Airport George Bush Intercontinental Airport Gerald R. Ford International Airport Grand Junction Regional Airport Grande Prairie Airport Great Falls International Airport Greater Binghamton Airport Greater Moncton International Airport Greater Rochester International Airport Greenville Spartanburg International Airport Groton-New London Airport Hagerstown Regional Airport - Richard A. Henson Field Halifax International Airport Hartsfield-Jackson Atlanta International Airport Hector International Airport Hilo International Airport Indianapolis International Airport James M. Cox Dayton International Airport Jamestown Regional Airport John Wayne Airport-Orange County Juneau International Airport Kahului Airport Kansas City International Airport Kearney Regional Airport Kona International Airport La Crosse Regional Airport Lakeland Linder Regional Airport Lanai Airport Laramie Regional Airport Las Cruces International Airport Lehigh Valley International Airport Lihue Airport Los Angeles International Airport Louis Armstrong New Orleans International Airport Louisville International Airport - Standiford Field Manchester Airport Martha's Vineyard Airport Mason City Municipal Airport McAllen Miller International Airport McGhee Tyson Airport McNary Field Airport Melbourne International Airport Memorial Field Airport Memphis International Airport Metropolitan Oakland International Airport Midland International Airport Minneapolis-Saint Paul International/ Wold-Chamberlain Airport Mobile Downtown Airport Myrtle Beach International Airport Nashville International Airport Norfolk International Airport Norman Y. Mineta San Jose International Airport North Las Vegas Airport Orlando International Airport Orlando Sanford International Airport Owensboro-Daviess County Regional Airport Palm Beach International Airport Palm Springs International Airport Pellston Regional Airport Pensacola International Airport Philadelphia International Airport Phoenix Sky Harbor International Airport Phoenix-Mesa Gateway Airport Pittsburgh International Airport Port Columbus International Airport Portland International Airport Portland International Jetport Pullman-Moscow Regional Airport Quad City International Airport Quebec City - Jean Lesage International Airport Raleigh-Durham International Airport Reno-Tahoe International Airport Republic Airport Rhinelander-Oneida County Airport Richmond International Airport Roanoke Regional Airport/Woodrum Field Rocky Mountain Metropolitan Airport Rogue Valley International - Medford Airport Ronald Reagan Washington National Airport Sacramento International Airport Salina Regional Airport San Antonio International Airport San Francisco International Airport Santa Barbara Municipal Airport Sarasota-Bradenton International Airport Savannah/Hilton Head International Airport Seattle-Tacoma International Airport Southern California Logistics Airport Southwest Florida International Airport St. John's International Airport St. Louis Downtown Airport St. Petersburg-Clearwater International Airport Stennis International Airport Stewart International Airport Syracuse Hancock International Airport Tafuna/Pago Pago International Airport Tallahassee International Airport Theodore Francis Green State Airport Thunder Bay International Airport Toronto - Lester B. Pearson International Airport Tucson International Airport Tulsa International Airport University Park Airport Vancouver International Airport Venango Regional Airport W. K. Kellogg Airport Whitehorse International Airport Will Rogers World Airport William P. Hobby Airport Willow Run Airport Wilmington International Airport Winnipeg James Armstrong Richardson International Airport Copyright National Academy of Sciences. All rights reserved. US00004583 Use and Potential Impacts of AFFF Containing PFASs at Airports CONTENTS 1 Summary 8 Chapter 1 Introduction and Purpose 8 1.1 Understanding the Problem 8 1.2 Project Objectives 9 1.3 Report Organization 9 1.4 How to Use This Document 10 Chapter 2 Primer-- Background on PFASs 10 2.1 What Are PFASs? 12 2.2 Where Did/Do PFASs Come From? 14 2.3 Why and How Do PFASs Pose a Concern? 17 2.4 What Are the Regulatory Requirements Regarding PFASs? 23 2.5 How Might PFASs Affect an Airport? 25 Chapter 3 Research Methodology 25 3.1 Overview 25 3.2 Literature Review 26 3.3 Airport Survey 27 3.4 Subject Matter and Industry Expert Outreach 28 Chapter 4 AFFF Management Within Airport Operations 28 4.1 Overview 29 4.2 Procurement 35 4.3 Storage 38 4.4 Application 41 4.5 Disposal 47 Chapte- I Addressing Legacy Environmental Impacts 47 5.1 Overview 47 5.2 Sampling of PFASs 51 5.3 Analysis of PFASs 57 5.4 Risk Management 61 5.5 Remediation Options 68 C hapte " Screening Tool Guidance 68 6.1 Introduction to the MAPA Screening Tool 70 6.2 Module 1--Airport Scale Evaluation 80 6.3 Module 2--APEC Scale Evaluation 85 6.4 Data Gaps 86 6.5 APEC Prioritization 86 6.6 Closing 88 Chapter 7 Recommendations for Future Research Copyright National Academy of Sciences. All rights reserved. US00004584 Use and Potential Impacts of AFFF Containing PFASs at Airports 91 References 96 Abbreviations, Acronyms, Initialisms, and Symbols 99 Glossary A-1 A p p e n d ix A Survey Methodology and Findings B-1 A p p e n d ix B AFFF Alternatives C-1 A p p en d _ Quick Guide to MAPA Screening Tool Note: Photographs, figures, and tables in this report may have been converted from color to grayscale for printing. The electronic version of the report (posted on the web at www.trb.org) retains the color versions. Copyright National Academy of Sciences. All rights reserved. US00004585 Use and Potential Impacts of AFFF Containing PFASs at Airports SUMMARY Use and Potential Impacts of AFFF Containing PFASs at Airports For decades, aqueous film-forming foam (AFFF) containing per- and polyfluoroalkyl substances (PFASs) has been used at airports across the U nited 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 environm ent of AFFF containing PFASs presents potentially unacceptable hum an health and ecological risks. Since the 1990s, data have been collected showing that earlier form ulations 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 ofthe most prevalent and potentially problematic PFASs.) Although advances have been made in risk m anagement 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-peerreviewed (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 procurem ent 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. Copyright National Academy of Sciences. All rights reserved. 1 US00004586 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 m inimum , meet the requirements listed on the product sheets provided by suppliers. At m any 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, b ut they may also falsely assume that the chemical is "safe" for the environm ent 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 ExcelTM 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-l. Table S-1. Best management practices for managing AFFF and addressing environmental impacts related to PFASs. Procurement: Regulatory Requirements Use firefighting foam that fulfills regulatory requirements for safety/use. 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. Meet the requirements of The Code of Federal Regulations (CFR), Title 14 - Aeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139), in the United States Canadian Aviation Regulations, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes, Part III Aerodromes, Airports and Heliports, in Canada Comply with U.S. EPA Significant New Use Rules (40 CFR 721.9582) Canadian Environmental Protection Act Copyright National Academy of Sciences. All rights reserved. US00004587 Use and Potential Impacts of AFFF Containing PFASs at Airports Table S-1. (Continued). Summary 3 Procurement: AFFF Performance Confirm that AFFF purchased meets relevant performance standards. Procurement: Review environmental data, where Environmental available, from a product's Consideration specification. Procurement: System and Equipment Compatibility Check compatibility of AFFF. Shift toward using 3 percent AFFF concentrates where possible. Use appropriate containers. Storage Store under appropriate conditions. Store the recommended reserves. S,,taff awareness of PFASs and AFFF. Application: Handling Treracionmsmtaeffnad,nedd,fporlolocwed,iunrdeuss.try- Application: Firefighting Training .. . Training practices. Demonstrate performance and quality meeting the performance standards for AFFF in the United States and Canada as follows: 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) 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) Check compatibility with Existing systems and equipment Previous/existing AFFF type/batch AFFF that meets the above specifications comes in 3 percent and 6 percent concentrate formulations. Upgrade equipment to be compatible with lower percentage use, when applicable. Read and follow storage procedures outlined in AFFF concentrate: Material safety data sheets (SDSs) Technical data sheets (TDSs) 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 ,N, ot be mixed (with other foam concent^rat^es or .brand.s). In a designated area Roofed/sheltered Use bunded storage methods Not stacked more than two drums high 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. Ternaviin.roanllmsetanftfawl..hi.m.o...p.c.lo.i.c.u.a.l.td.iocnosmaessionctoi.a..t.c.eo..d.n..tw.a..ci.t.t.h.w..h.i.ti.s.h.t.o.A..r.Fi.c.F.a.F.l..aa..bn..od. uctutrhreenhtuAmFaFnF fhoeramltuhl,aatni.odns. 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 W.d.e...et..aa...ir.l..e.t.dh..e.i.n.a..pt.hperopprroi.ad.tuectpSeDrsSo)nal. prote. ctive. equipment (PPE) (,at a m.ini.mum as 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 Firefighting training should Follow a prescribed training schedule that aligns with the appropriate guidelines and regulations . |nvo|ve 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) (continued on next page) Copyright National Academy of Sciences. All rights reserved. US00004588 Use and Potential Impacts of AFFF Containing PFASs at Airports 4 Use and Potential Impacts of AFFF Containing PFASs at Airports Table S-1. (Continued). Use appropriate training facilities. Application: System and Equipment Testing Discharge and collect minimum volumes of AFFF. Application: Aircraft Hangars Construct the aircraft hangar following local building code and to mitigate AFFF impacts. Application: Firefighting Training/ Aircraft Rescue Provided standardized, industryrecommended training. Application: Emergency Response Improve communication and response between environmental personnel and firefighting personnel. Application: Discharge Dispose of foam-water, foamhydrocarbon, and foam-soil mixtures as appropriate given the local guidelines, legislation, and regulations. Disposal: Removal from Equipment or Systems Transfer by pump to containment vessel. Use propane as a fuel source in lieu of flammable hydrocarbons 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 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 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 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 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 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 Firefighting team should alert environmental team when deploying, moving, and/or testing AFFF Personnel handling AFFF should wear appropriate PPE Record AFFF types, quantities, and disposal method/destination Dispose of discharged AFFF at an authorized, licensed location 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 Copyright National Academy of Sciences. All rights reserved. US00004589 Use and Potential Impacts of AFFF Containing PFASs at Airports Table S-1. (Continued). Summary 5 Disposal: Removal from Equipment or Systems Legacy: Sampling for PFASs Legacy: Analysis of PFASs Disposal. Use standardized field procedures, adapted for PFASs. Avoid cross-contamination. Avoid suspended particulate matter in aqueous samples. Sampling frequency. Quality assurance/quality control. 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 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 using PTFE, aluminum foil, glass, and/or metal in sampling materials and containers Verify drilling/hydroexcavation water is free of PFASs 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) 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 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). 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 (continued on next page) Copyright National Academy of Sciences. All rights reserved. US00004590 Use and Potential Impacts of AFFF Containing PFASs at Airports 6 Use and Potential Impacts of AFFF Containing PFASs at Airports Table S-1. (Continued). Legacy: Risk Management Legacy: Remediation Use an accredited laboratory. Use standardized methodologies. Identify source areas at the airport. Identify and evaluate exposure pathways at the airport. Identify receptors at the airport. 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-servicecertification/directory-of-accredited-clients) Canadian Association for Laboratory Accreditation Inc. (CALA) (http://www.caladirectory.ca/) Check that your commercial laboratory is using suitable standard methodology to carry out analyses of PFASs 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 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 As part of the development of a CSM, identify: Fluman 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) As part of the development of a CSM, identify: Surface water bodies Fish Birds Terrestrial animals Invertebrates Human receptors Copyright National Academy of Sciences. All rights reserved. US00004591 Use and Potential Impacts of AFFF Containing PFASs at Airports Table S-1. (Continued). Summary 7 Adopt risk management strategies that intercept the exposure pathway between source term and receptor. Develop decision model to support the choice of short-term and long term remediation strategies. Soil remediation techniques. Groundwater. Discharged AFFF. Where feasible, 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 Consider Which PFASs are present and their physicochemical properties Remedial objectives Flydrogeological 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 Fligh-temperature incineration (>1100C) Landfill disposal at a facility that is appropriately designed to treat and handle PFAS- impacted soils immobilization/stabilization (e.g., amine-modified clay sorbents) 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 fo r removing short-chain PFASs 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., > 1100C) Copyright National Academy of Sciences. All rights reserved. US00004592 Use and Potential Impacts of AFFF Containing PFASs at Airports CHAPTER 1 Introduction and Purpose 1.1 U nderstanding th e Problem Aqueous film-forming foam (AFFF) has been used for extinguishing fires and training firefighters at airports for decades. AFFF formulations most frequently include surfactants of the class of chemicals called per- and polyfluoroalkyl substances (PFASs) that improve fire knock down capabilities. The historical use of AFFF is likely to have resulted in the release of PFASs into the environment. Some PFASs exhibit chemical, physical, and toxicological properties that are problematic. These problematic properties include being extremely persistent in the natural environment; potentially presenting human and ecological health risks; bioaccumulating and bio magnifying; and exhibiting physicochemical properties that challenge traditional handling, cleaning, and decontaminating methods. An increase in regulatory attention to PFASs has led to a rapidly evolving regulatory landscape that could impact airports. As a result, airports that have stored and/or used AFFF face operational considerations relative to the existing storage, use, testing, and/or disposal of AFFF containing PFASs. In addition, legacy impacts have the potential to significantly affect capital improvement projects should impacts of PFASs be encountered. ` oject Objectives The overall objective of this research was to develop an easy-to-understand reference document for airport personnel on what is known and not known about PFASs and their use in AFFF at airports and to develop an accompanying screening tool for use by operators of commercial service and general aviation airports of varying sizes to understand, diagnose, and improve management practices for AFFF and PFASs. Specific project objectives were the following: Understand what airports know about AFFF and PFASs. Identify what practices have been and are being employed by airports to store, handle, remove, and dispose of AFFF. Identify current research and knowledge regarding the chemistry, fate and transport, and toxicology of PFASs. Understand the current regulatory environment related to PFASs. Identify the currently available AFFF alternatives (including those AFFFs containing PFASs and those not containing PFASs). Facilitate an airport's understanding of where AFFF and PFASs may represent an area of potential environmental concern and help prioritize future action. Evaluate innovative approaches to sampling of PFASs and thereby advancing the state of the practice. Identify and document advances in remediation technologies in the United States, Canada, and other jurisdictions across the world. 8 Copyright National Academy of Sciences. All rights reserved. US00004593 Use and Potential Impacts of AFFF Containing PFASs at Airports Introduction and Purpose 9 Identify areas for future research. Develop a screening tool that could be used to assist airports with the identification of areas of potential environmental concern (APECs) on or near the airport. Develop an easily understood reference guidance document for airport personnel. 1.3 R eport O rganization The remainder of this research report is organized into Chapters 2 through 7: Chapter 2 is a primer on PFASs at airports that discusses the nature of PFASs, including their physical, chemical, biological, and toxicological effects, as well as properties related to their fate and transport in the environment. Chapter 3 presents the research methodology for ACRP Project 02-60, describing the literature review, airport survey, and outreach to industry and subject matter experts that provides the basis for identifying AFFF management practices discussed in Chapter 4. Chapter 4 presents suggested best management practices at key AFFF life cycle stages, including procurement, storage, application, and disposal of AFFF that contains PFASs. Chapter 5 addresses legacy environmental impacts of AFFF containing PFASs, including considerations for sampling, laboratory analysis, risk management, and remediation options for assessing and addressing the impacts of PFASs on the environment. Chapter 6 presents a screening tool that allows airport representatives to identify potential sources of PFASs at airports (i.e., sources associated with airport operations past or present or activities associated with airport tenants on airport property). Chapter 7 provides recommendations for further research related to AFFF containing PFASs at airports. A list of abbreviations, acronyms, initialisms, and symbols used in this research report and a glossary are also provided. 1.4 How to Use This Document The purpose of this research report and accompanying risk screening tool is to help airport representatives understand the potential implications of the use of AFFF containing PFASs on human health and the environment; provide guidance on identifying, understanding, and mitigating the potential risks associated with AFFF use; identify best management practices for managing AFFF during airport operations; and identify best management practices for addressing legacy environmental impacts. This research report has been developed as a tool to encourage and enable collaboration among key stakeholders involved in management of AFFF procurement, storage, use, and disposal at the airport and the environmental implications of PFASs associated with historical AFFF releases to the environment. Used alone, this research report can serve as a roadmap for airports interested in appropriately managing AFFF and addressing any impacts of PFASs. The report is designed to inform airport personnel about what is known and not known about PFASs and their use in AFFF at airports. By using the accompanying screening tool in conjunction with this report, airport personnel will be better able to 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. Copyright National Academy of Sciences. All rights reserved. US00004594 Use and Potential Impacts of AFFF Containing PFASs at Airports C iHi Aa nP tI rh nK Lt Primer-- Background on PFASs PFASs belong to a family of chemicals that are in a variety of products found at airports. The predominant "source" of these compounds at an airport is AFFF, used in firefighting, but these compounds can also be associated with commercial, industrial, or manufacturing applications of airport tenants. The impact of PFASs on environmental media (i.e., soil, groundwater, sediment, surface water) may be the result of historical activities at airports and the surrounding vicinity because PFASs do not break down easily in the environment. Elevated concentrations of PFASs found in the environment and human populations have led to increased investigation and regulation of these compounds. This chapter provides background information on PFASs, answering the following fundamental questions: What are PFASs? Where did/do PFASs come from? Why and how do PFASs pose a concern? What are the regulatory requirements regarding PFASs? How might PFASs affect an airport? 2.1 W h ASs? PFASs are a large group of related, human-made, fluorinated organic chemicals (i.e., chemicals that contain fluorine and carbon atoms bonded together) that have unique properties due to their chemical structure and composition. As described in subsequent sections, many PFASs exhibit high degrees of chemical and thermal stability that make them useful in industrial and manu facturing applications. The chemical and thermal stability of many PFASs is what enables AFFF to have better firefighting performance; however, these same properties also contribute to why some PFASs have negative impacts to human health and the environment. 2.1.1 Chemical Com position PFASs are organic chemicals that contain fluorine atoms bonded to a chain of carbon atoms. The carbon-fluorine bond is one of the strongest organic bonds in nature, and this strong bond contributes to the stability and persistence of some PFASs. Of particular interest and concern are perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). 2.1.2 Chemical Structure PFASs are generally composed of a perfluorinated carbon "tail" (i.e., carbon and fluorine) and a functional group "head." The compounds tend to be dual-natured, as the "head" and the 10 Copyright National Academy of Sciences. All rights reserved. US00004595 Use and Potential Impacts of AFFF Containing PFASs at Airports Perfluorinatect-carbon tail hydrophobic interactions Functional group head electrostatic interactions Primer-- Background on PFASs 11 Figure 2-1. Structure of a perfluoroalkyl compound: the PFOS anion. "tail" prefer different interactions (see Figure 2-1). The perfluorinated carbon tail tends to be both hydrophobic (water insoluble) and oleophobic (oil insoluble); the functional group head is more hydrophilic (water soluble). The solution chemistry (pH and ionic strength) affects the ability of PFASs to interact or bind with a surface by changing the electrostatic interactions between the head and the surface. Larger compounds can degrade or transform to smaller compounds that are more stable in the environment. Both PFOS and PFOA, for example, can be found in the environment as stable compounds resulting from the degradation of "parent" compounds, as well as being manufactured for a particular industrial application. PFASs found in AFFF can be cationic, zwitterionic, and anionic, resulting in very different fate and transport behaviors in the environment (1). In the past, PFASs were often inappropriately referred to as "PFCs" (perfluorinated compounds), but this term can also be understood as perfluorocarbons, which do not contain functional groups (i.e., the "head" shown in Figure 2-1) and consist solely of the carbon-fluorine "tail," and therefore have properties and behaviors that are different from other types of PFASs. For the purpose of this report, PFASs can be referred to as "long-chain" and "short-chain." Long-chain refers to Perfluoroalkyl carboxylic acids (PFCAs) with eight or more perfluorinated carbons. Perfluoroalkyl sulfonic acids (PFSAs) with six or more perfluorinated carbons. The definition of long-chain is different for PFCAs and PFSAs because a PFSA with a given number of carbons has a greater tendency to bioconcentrate and/or bioaccumulate than a PFCA with the same number of carbon atoms. Short-chain PFASs are PFCA compounds that have fewer than eight carbons and PFSAs that have fewer than six carbon molecules. Please note that in much of this report, short-chain PFASs are referred to as C6or less because more recent AFFF formulations do not contain PFSAs. These more recent formulations include Perfluorobutanoic acid (PFBA), with four carbons. Perfluorohexanoic acid (PFHxA) with six carbons. Table 2-1 provides the standard adopted nomenclature and hierarchy for PFASs. Given the confusion and varying acronyms (e.g., PFCs), this table has been provided to improve dialogue and understanding of terms among researchers, regulators, consultants, and stakeholders. Acronyms for subgroups of PFASs that are referred to in this document, and are more commonly known, are provided. It should be noted that the conjugate base forms (e.g., carboxylates and sulfonates) of the compounds are the forms typically found in the environment, even though in Table 2.1, these forms are referred to as acids. Copyright National Academy of Sciences. All rights reserved. US00004596 Use and Potential Impacts of AFFF Containing PFASs at Airports 12 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 2-1. Example PFASs. Perfluoroalkyl acids (PFAAs) Perfluoroalkyl carboxylic acids (PFCAs) Perfluorobutanoic acid--PFBA Perfluoropentanoic acid--PFPeA Perfluorohexanoic acid--PFHxA Perfluoroheptanoic acid--PFHpA Perfluorooctanoic acid--PFOA Perfluorononanoic acid--PFNA Perfluorodecanoic acid--PFDA Perfluoroundecanoic acid--PFUnA Perfluorododecanoic acid--PFDoA Perfluorotridecanoic acid--PFTrDA Perfluorohexadecanoic acid--PFHxDA Perfluorooctadecanoic acid--PFOcDA Perfluoroalkyl sulfonic acids (PFSAs) Perfluorobutane sulfonic acid--PFBS Perfluoropentane sulfonic acid--PFPeS Perfluorohexane sulfonic acid--PFHxS Perfluoroheptane sulfonic acid--PFHpS Perfluorooctane sulfonic acid--PFOS Perfluorononane sulfonic acid--PFNS Perfluoroalkyl sulfamido substances (FASAs) Precursor to PFSAs Perfluoroalkyl sulfamido substances (FASAs) Precursor to PFSAs N-Ethyl-perfluorooctane sulfonamido ethanol--N-EtFOSE N-Methyl-perfluorooctane sulfonamido ethanol--N-MeFOSE N-Ethyl-perfluorooctane sulfonamido acetic acid--N-Et-PFOSA-AcOH N-Methyl-perfluorooctane sulfonamido acetic acid--N-Me-PFOSA-AcOH Perfluorooctane sulfonamide--PFOSA Fluorotelomer alcohols (FTOHs) Precursor to PFCAs Fluorotelomer alcohols (FTOHs) Precursor to PFCAs Fluorotelomer sulfonic acids (FTSs) Precursor to PFCAs and PFSAs Fluorotelomer sulfonic acids (FTSs) Precursor to PFCAs and PFSAs 6:2 Fluorotelomer alcohol--6:2 FTOH 8:2 Fluorotelomer alcohol--8:2 FTOH 6:2 Fluorotelomer sulfonic acid--6:2 FTS 8:2 Fluorotelomer sulfonic acid--8:2 FTS 2.2 W here Did/Do PFASs Come From? PFASs were developed in the 1960s and adopted in AFFF formulations in the 1970s. In the airport industry, PFASs are known to have been used in AFFF for firefighting and associated training, industrial components related to aviation and aerospace, metal plating operations, biocides, and construction products. In addition, PFASs have been used in textiles, leather goods, and cooking utensils. Brief descriptions of product formulation and use are provided in the subsections below, with an emphasis on aviation-related sources. Copyright National Academy of Sciences. All rights reserved. US00004597 Use and Potential Impacts of AFFF Containing PFASs at Airports Primer-- Background on PFASs 13 2.2.1 Firefighting In accordance with federal regulations (as detailed in Section 4.2), AFFF is used in airport operations as a fire-extinguishing agent to prevent, extinguish, or control Class B fires (i.e., fires of flammable and combustible liquids such as crude oil, gasoline, and fuel oils). The presence of PFASs in AFFF generates foam that retains water and separates fuel from flame, ultimately resulting in dramatic, fast knockdown of Class B fires. Historical AFFF formulations were made with fluorocarbon surfactants containing PFOS as the predominant active ingredient. Increasing concern regarding the effects of PFOS-based AFFF on human health and the environment led users to alternatives that contained long-chain, telomer-based fluorochemicals containing eight carbons or more. Subsequently, in some cases, it was found that the breakdown of these long-chain fluorochemicals in the environment could produce PFOA and other PFASs of concern. Since 2006, both the United States and Canada have taken steps to phase out the production and use of C8-based fluorotelomers. Consequently, AFFF manufacturers have shifted toward using shorter chain (i.e., < C6, having six or fewer carbon molecules) C6and C4perfluoroalkylated chemicals. C6-based fluorotelomers are most commonly and widely used. Limited data are available on how these compounds behave in the environment and the potential risks they pose to both the environment and human health. PFASs at an airport maybe related to the following firefighting equipment and materials: Past and ongoing firefighting, training, and maintenance activities. These can lead to ground water and soil contamination by PFASs due to uncontained release of firefighting foam. Firefighting equipment, including protective clothing for firefighters. These can be surface treated with side-chain fluorinated polymers or made from fluoropolymers such as woven, porous polytetrafluoroethylene (PTFE) and its copolymers. Testing firefighting systems (e.g., deluge system, roof turrets). This activity is often an over looked source of PFASs. 2.2.2 Industrial Com ponents in Aviation and Aerospace Fluoropolymers such as PTFE (e.g., TeflonTM) are used extensively in various equipment components (e.g., semiconductors, wiring, tubing, piping, seals, gaskets, and cables). In addition, the salts of sulfonated PFASs (primarily PFOS) have been used as additives with a content of about or less than 0.1 percent in hydraulic fluids/lubricants to prevent evaporation, fires, and corrosion (2). 2.2.3 Metal Plating Operations Although metal plating operations may not be directly associated with the aviation industry, they are one of the most important ongoing users of products containing PFASs and are typically situated within industrial zones located near larger airport facilities. Fluorinated surfactants (i.e., PFOS and derivatives) are used in metal plating, and are considered to be essential for use as mist suppressants in the metal plating industry (3,4). The use of PFOS in the European Union (EU) for chromium plating was estimated as 10,000 kg/year (5). There is potential for residual concentrations of other PFASs in the surfactants used for metal plating. 2.2.4 Biocides Non-polymeric PFASs have been used as active ingredients in some plant growth regula tors and herbicides (6) and as inert ingredients in pesticide formulations in the United States (e.g., ant baits) (7). Copyright National Academy of Sciences. All rights reserved. US00004598 Use and Potential Impacts of AFFF Containing PFASs at Airports 14 Use and Potential Impacts of AFFF Containing PFASs at Airports 2.2.5 Construction Products Fluoropolymers, such as PTFE and polyvinyl fluoride (PVDF), are commonly used in paints, acting as dispersion agents and leveling agents, as well as improving gloss and antistatic properties. Fluoropolymers and fluorotelomers have also been used as fire- or weather-resistant coating in various construction-related applications (8). 2.3 W hy and How Do PFASs Pose a Concern? Some PFASs present potential risks to human health and the environment. Many PFASs are very persistent (i.e., do not break down readily).They bioaccumulate (i.e., accumulate in living tissue) and/or biomagnify (i.e., increase in concentration as they move up the food chain) in the environment. The following paragraphs provide an overview of PFASs, detailing environmental and toxicological concerns associated with PFASs, their fate and transport properties, and envi ronmental factors that affect transport. 2.3.1 Environm ental and Toxicological Concerns PFASs have been widely used throughout the world, and some types of PFASs (including PFOS and PFOA) are persistent in the environment. In the late 1990s, the U.S. EPA received information from 3M that PFOS was widespread in the blood of the general population, which raised concerns regarding persistence, bioaccumulation, and toxicity (9,10). The results provided by 3M on PFOS impacts to human health and ecology suggested that the prevalence of these compounds, combined with their increasing ubiquity in the global environment, presented potential human health and ecological risks. In July 2006, a preliminary ecological screening assessment report by Environment Canada concluded that PFOS, its salts, and its precursors are entering the environment at concentra tions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity (11). Studies evaluating the relative toxicity of the complex mixture of PFASs typically in the AFFF used at airports (a mixture consisting not just of PFOA and PFOS, but including other PFASs as well) are ongoing. Since multiple PFASs are typically found together in both human and wildlife environments, their cumulative risks and potential interactions are also being considered in ongoing research. Specific documented environmental and toxicological concerns are the following: Per- and polyfluorinated compounds have the potential to bioaccumulate and biomagnify in wildlife. Per- and polyfluorinated compounds are readily absorbed after oral exposure and accumulate primarily in the serum, kidney, and liver. Toxicological studies on animals indicate potential developmental, reproductive, and systemic effects. PFOS, its salts, and its precursors meet the criteria for persistence under the Stockholm Convention, the Canadian Environmental Protection Act (CEPA) and the U.S. EPA. 2.3.2 Fate and Transport in the Environm ent The movement of PFASs and their persistence in the environment is a function of their structure (12). Part of the molecule prefers to associate with water and part of the molecule does not; thus these compounds travel along interfaces (e.g., water-air, water-soil, and waterlipid interfaces), smearing themselves along soil particles at the water table interface. In natural Copyright National Academy of Sciences. All rights reserved. US00004599 Use and Potential Impacts of AFFF Containing PFASs at Airports Primer-- Background on PFASs 15 waters, the predominant forms of PFCAs and PFSAs will be their anionic forms; the predominance of these forms is due to the low dissociation constants of these compounds. However, at low pH, both PFCAs and PFSAs can exist in water in their fully protonated (acid) forms. Depending on compound properties, manufacturing procedures, and use and disposal patterns, PFASs and their precursors may enter the environment by various pathways, such as direct dis charge to waste (4, 13-16) and air particulate matter (17-20), as well as wash-off or direct use in the environment (2, 21-24) and inappropriate disposal of wastes containing PFASs (25--31). Emissions into the environment can be from both direct and indirect sources (13,32-34). Direct sources include emissions during the manufacture, use, and disposal of products that contain PFASs or their derivatives as ingredients, unreacted raw materials (residuals), or unintended by-products (impurities). Indirect sources refer to the formation of PFCAs and PFSAs from degradation of precursors (i.e., parent compounds). PFCAs and PFSAs are among the more stable compound groups categorized as PFASs and include PFOA and PFOS. PFOA has been in manufactured AFFF and is also formed as a recalcitrant degradation by-product in AFFF. The perfluorinated carbon tail of these compounds is known to be very resistant to degradation, a property attributed to the carbon-fluorine bond. PFOS is considered to be persistent--the environmental half-life for PFOS (greater than 41 years) (35) exceeds the half-life criteria for persistence as defined by the Persistence and Bioaccumulation Regulations of the United Nations (UN) Stockholm Convention on Persistent Organic Pollutants (POPs) in 2001 (36), and the Canadian Environmental Protection Act, CEPA 1999 (37,38). Under typical groundwater conditions (i.e., pH 6-8.5), PFOA and PFOS are water soluble and can migrate readily from soil to groundwater, where they can be transported long distances (39, 40). Different PFASs, many with different chemical structures, are often used and present in a mixture (e.g., AFFF). As a result of these chemical structure differences, release of these mixtures may result in distribution patterns of PFASs in the environment that are both sourceand site-specific: PFASs with longer perfluorinated carbon tails have a greater tendency to bioaccumulate than short-chain PFASs. There are limited studies available that have evaluated the behavior of short-chain PFASs in the environment and/or the potential risks they pose to human health or the environment (71). Short-chain PFASs are more likely to be found in aqueous phases (i.e., water), whereas long-chain PFASs are more likely to be sorbed to solid matrices. Larger and more hydrophobic molecules such as PFHxA or perfluorohexane sulfonic acid (PFHxS) can displace shorter PFASs (e.g., PFBA) from sorption sites. Short-chain PFASs may be displaced by increased flow. Short-chain PFASs have been shown to wash out in flow-through adsorption column experiments (41). Specific fate and transport considerations include the following: PFASs (particularly PFOS and PFOA) do not readily degrade in the environment to constituents that are not PFASs. Although limited studies have been conducted, the scientific literature suggests that sulfonated compounds bind more with soil than do carboxylated compounds. Perfluoroalkyl acids (PFAAs) (a subgroup of PFASs that includes PFOS and PFOA) precursors account for 41 to 100 percent ofthe total concentration of PFASs in archived AFFF formulations (on a molar basis) (12). Precursors degrade and/or transform to intermediate compounds and PFAAs in the environment. Copyright National Academy of Sciences. All rights reserved. US00004600 Use and Potential Impacts of AFFF Containing PFASs at Airports 16 Use and Potential Impacts of AFFF Containing PFASs at Airports 2.3.3 Environmental Factors That Affect Transport Groundwater geochemistry and soil properties can affect the ability of PFASs to attach to surfaces. Sorption of these compounds can be influenced by different soil types that contain reactive mineral surfaces and organic carbon (e.g., peaty soils or organic-rich fragments in sand). An increase of sorption of PFASs, such as PFOS to sediment, has been noted with increasing organic matter, decreasing pH, and increasing calcium ions (Ca2+) (42). However, in soils that have negatively charged surfaces (e.g., most clays), it has been found that pH, ionic strength, and/or calcium concentrations have minimal effect on sorption of PFOS to the mineral surface (43). Precursors are likely to have different physical and chemical properties to their degradatory products. Cationic or zwitterionic precursors may bind to clay minerals through ion exchange. The fate and transport of PFASs in the environment is very complex and influenced by many factors. The followingbox identifies factors that affect the mobility of PFASs in the environment, generally, in order of increasing mobility. The complexity of these compounds and their mobilization in the environment may be confounded by other, unidentified factors (e.g., co-contaminants, synergistic effects). Research into the fate and transport of PFASs is ongoing. A Concentrations observed in bedrock (fractured) Elevated concentrations at surface (potential for human health risks, leaching) Elevated concentrations at greater depths (indicates pathway to groundwater) Ongoing source (e.g., unlined lagoon) UT Petroleum hydrocarbon (PHC) co-contaminants present < Large water table fluctuation (larger "smear" zone) o > Greater groundwater flow _OQ Greater infiltration T<JV Large particle size (if high concentrations-- leaching) a<vs Small particle size (silt-- increased sorption--diffusive release)* u c Small particle size (clay--increased sorption)* High f oc(increased sorption)* Particle reactivity (negatively charged, mineral surfaces increased sorption)* Increased salinity (increases sorption/decreases PFOS solubility)* Increased pH (decreases sorption/increases PFOS solubility)* *lncreased sorption leads to decreased mobility, decreased leaching, "mass storage. Lighter shading indicates system chemical factors that affect the mobility o f PFASs. Darker shading indicates system physical factors that affect the mobility o f PFASs. Copyright National Academy of Sciences. All rights reserved. US00004601 Use and Potential Impacts of AFFF Containing PFASs at Airports Primer-- Background on PFASs 17 2.4 W hat Are the Regulatory Requirem ents Regarding PFASs? The regulatory environment related to PFASs is rapidly changing. Improved analytical testing technologies and methodologies have resulted in the ability to detect these substances at low concentrations that new research suggests may have human health or environmental significance. The development of regulations and guidelines for the protection of human health and the environment has followed and continues to evolve. Between the years 2000 and 2015, countries including the United States, Canada, the United Kingdom (UK), Australia, Norway, the Netherlands, Germany, and Sweden introduced regulations and guidelines to phase out and limit the use of PFOS, PFOA, and their precursors. In 2004, the UN Stockholm Convention on POPs listed the first 12 POPs and added PFOS, one of the most common compounds of PFASs, and its 96 precursors to Annex A (Elimination). Chemicals in Annex A are destined for elimination with specific, time-limited exemptions. In 2009, PFOS was added to Annex B (Restriction) of the Stockholm Convention. PFOS was banned in countries in the EU on 27 June 2008 (noting, however, that this prohibition is subject to some time-unlimited exceptions relating to certain applications in the photolithographic and photographic industries and chromium plating and hydraulic fluids in the aviation industry). In the EU, firefighting foam containing PFOS and sold on the market prior to 27 December 2006 could have been used until 27 June 2011. The regulatory frameworks for PFASs ofthe United States, Canada, EU countries, and Australia are summarized in the sections that follow. Please note that the regulatory requirements for each country are subject to change, especially in the rapidly evolving regulatory environment relating to PFASs. Please refer to the regulatory authority having jurisdiction for the most up-to-date requirements. 2.4.1 United States of America The U.S. EPA issued the "Long-Chain Perfluorinated Chemicals (PFCs) Action Plan" in 2009 for perfluoroalkyl sulfonates (long-chain PFASs containing sulfonated functional groups, e.g., PFHxS, PFOS, their salts and precursors) and long-chain perfluoroalkyl carboxylates (long-chain PFASs containing carboxylic acid functional groups, e.g., PFOA, other higher homologues, and their salts and precursors). Since 2009, the U.S. EPA has conducted two screening reviews (in 2013 and 2015). In September 2013, U.S. EPA published a Significant New Use Rule (SNUR) that focused on the use of longchain perfluoroalkyl carboxylates in carpets. U.S. EPA amended the SNUR (40 CFR 721.9582) on PFASs (1) to add PFASs for which the Toxic Substances Control Act (TSCA) new chemical review process had been completed, but which were not yet being produced or imported and (2) to designate (for all listed PFASs) processing as a significant new use. In January 2015, U.S. EPA proposed a SNUR under TSCA that requires manufacturers (including importers) of long-chain perfluoroalkyl carboxylates to notify the U.S. EPA at least 90 days prior to starting or resuming use of these chemicals in any products. The notification timeframe would allow U.S. EPA to evaluate the new use and, if necessary, take action to prohibit or limit the activity. In 2009, the U.S. EPA's Office of Water established a provisional health advisory of 0.2 pg/L for PFOS and 0.4 pg/L for PFOA while assessing the potential risk from short-term exposure of these chemicals through drinking water. These values were revised in 2016 to 0.07 pg/L for both compounds, respectively, for chronic exposure (protective over a lifetime) (44). The new 2016 health advisory values supersede the 2009 provisional health advisory values. The health Copyright National Academy of Sciences. All rights reserved. US00004602 Use and Potential Impacts of AFFF Containing PFASs at Airports 18 Use and Potential Impacts of AFFF Containing PFASs at Airports advisories are based on the U.S. EPA's assessment of the latest peer-reviewed scientific literature and provide non-enforceable and non-regulatory guidance to state agencies and other public health officials so that they can take appropriate actions. The U.S. EPA's Office of Water derived reference doses (RfDs) of 2 X ICh5 mg/kg/day in its Health Effects Support Documents for PFOA and PFOS to support the health advisories. Using these RfDs and the standard regional screening level equations (https://www.epa.gov/ risk/regional-screening-levels-rsls), risk-based residential soil-screening levels of 1.3 mg/kg can be calculated for PFOA and PFOS. Risk-based industrial soil-screening levels for a generic composite worker of 16.4 mg/kg can also be calculated. Site-specific soil-screening levels for other exposure scenarios and receptors (e.g., recreator, worker) can also be calculated. Risk-based screening levels for perfluorobutane sulfonic acid (PFBS) can also be calculated based on a pub lished RfD by EPA on the same website. At the time of this writing, several states have established drinking water and groundwater guidelines, as follows: Maine developed a maximum exposure guideline for PFOA in drinking water of 0.1 pg/L. Michigan has established human noncancer values for drinking and non-drinking water uses for both PFOS (0.011 pg/L and 0.012 pg/L, respectively) and PFOA (0.042 pg/L and 12 pg/L, respectively) (45). Minnesota has also established a chronic health risk limit of 0.3 pg/L for both PFOS and PFOA, and 7 pg/L for both PFBS and PFBA in drinking water (46). Minnesota has established well advisory guidelines of 1.0 pg/L for PFBA, perfluoropentanoic acid (PFPeA), and PFHxA, and 0.6 pg/L for PFBS and PFHxS. New Jersey has established a preliminary health-based guidance value of 0.04 pg/L for PFOA in drinking water. The guidance level is the first phase of an ongoing process to establish a drinking water standard for this contaminant and will be adjusted as the science regarding PFOA is developed (47). New Jersey has established a human-health-based interim specific groundwater quality criterion for PFOS and perfluorononanoic acid (PFNA) of 0.040 pg/L and 0.010 pg/L in groundwater, respectively (48, 49). In 2006, North Carolina established an interim maximum allowable concentration (IMAC) of 2 pg/L for PFOA in groundwater (50). In 2010, the North Carolina Secretary's Science Advisory Board (NCSAB) on Toxic Air Pollutants recommended that the IMAC for PFOA in groundwater be reduced to 1pg/L based on a review of the toxicological literature and discussions with scientists conducting research on the health effects associated with exposure to PFOA. At the time of this writing, the NCSAB's recommendation was still pending review by the North Carolina Division ofWater Quality (51). In 2016, the Vermont Department of Health derived a drinking water health advisory of 0.02 pg/L applicable to the sum of PFOA and PFOS. In September 2016, California EPA's Office of Environmental Health Hazard Assessment issued a Notice of Intent to List PFOA and PFOS as known to the state to cause reproductive toxicity under the Safe Drinking Water and Toxic EnforcementAct of 1986 (52). Iflisted, warning requirements under the new regulatory scheme would be triggered within 1year from the date of the Office of Environmental Health Hazard Assessment's (OEHHA's) listing. The guideline values are summarized in Table 2-2. Additionally, six PFASs are considered under the U.S. EPA's Third Unregulated Contaminant Monitoring Rule (UCMR 3) (see Table 2-3). While it is not necessarily applicable to airport managers, the 1996 Safe Drinking Water Act (SDWA) amendments require that once every 5 years U.S. EPA issue a new list of no more than 30 unregulated contaminants to be monitored by public water systems. U.S. EPA uses the UCMR to collect data on contaminants that are Copyright National Academy of Sciences. All rights reserved. US00004603 Use and Potential Impacts of AFFF Containing PFASs at Airports Primer-- Background on PFASs 19 Table 2-2. Drinking water and well advisory guidelines in the United States. U.S. EPA 0.07* 0.07* NC NC NC NC NC NC Maine (maximum exposure in drinking 0.1 NC NC NC NC NC NC NC water guideline) Michigan (Health limits, drinking water) 0.42 0.011 NC NC NC NC NC NC Michigan (Health limits, non-drinking 12 0.012 NC NC NC NC NC NC water use) Minnesota (well advisory guidelines) NC NC 0.6 1.0 NC 1.0 1.0 0.6 Minnesota (chronic health risk limits, 0.3 0.3 7.0 7.0 NC NC NC NC drinking water) New Jersey (interim health-based values) 0.04 NC NC NC 0.010 NC NC NC North Carolina (IMAC) 2.0 NC NC NC NC NC NC NC Vermont (Health Department, 0.02** 0.02** NC NC NC NC NC NC drinking water) NC denotes "no criteria." * Combined concentration ofPFOA and PFOS are not to exceed 0.07 pg/L. **Combined concentration ofPFOA and PFOS are not to exceed 0.02 pg/L. Table 2-3. PFASs on UCMR 3 assessment monitoring (List 1 contaminants). Perfluorooctanesulfonic acid (PFOS) 0.04 Perfluorooctanoic acid (PFOA) Perfluorononanoic acid (PFNA) Perfluorohexane sulfonic acid (PFHxS) 0.02 0.02 0.03 Perfluoroheptanoic acid (PFHpA) Perfluorobutanesulfonic acid (PFBS) 0.01 0.09 EPTDS denotes "entry points to the distribution system." EPTDS EPTDS EPTDS EPTDS EPTDS EPTDS EPA 537 Rev 1.1 EPA 537 Rev 1.1 EPA 537 Rev 1.1 EPA 537 Rev 1.1 EPA 537 Rev 1.1 EPA 537 Rev 1.1 Copyright National Academy of Sciences. All rights reserved. US00004604 Use and Potential Impacts of AFFF Containing PFASs at Airports 20 Use and Potential Impacts of AFFF Containing PFASs at Airports suspected to be present in drinking water and do not have health-based standards set under the SDWA. U.S. EPA pays for the analysis of all samples from systems serving 10,000 or fewer people. If airport operators do not themselves participate in the program, they should be aware that nearby systems may be monitoring these compounds. 2.4.2 Canada The regulatory environment for PFASs (such as PFOS and PFOA) in Canada is in develop ment. Canadian federal guidelines that protect the human health exposure pathways for potable groundwater use and direct soil contact have been developed for federal custodian sites (53). Environment Canada has developed proposed final federal environmental quality guidelines to help assess the significance of PFOS concentrations in the environment (54). These pro posed final guideline values are based on studies that directly link laboratory exposure to adverse impacts in animals and have been developed for soil, groundwater, surface water, fish tissue, wildlife diet, and bird eggs. Concentrations above the draft guideline values indicate an increased likelihood that adverse effects in the environment may occur; however, PFOS concentrations above the guideline values do not necessarily indicate adverse effects. In August 2010, Health Canada issued provisional drinking water guidance values for PFOA and PFOS. Based on the available scientific literature and reviews conducted by other jurisdictions, Health Canada revised their 2011 values in 2016, establishing drinking water screening values of 0.0006 mg/L (0.6 jxg/L) for PFOS; 0.2 pg/L for PFOA; 15 pg/L for PFBS; 30 pg/L for PFBA; 0.6 pg/L for PFHxS; and 0.2 pg/L for PFPeA, PFHxA, perfluoroheptanoic acid (PFHpA), and PFNA based on lifetime exposure. Environment Canada has developed Canadian Federal Environmental Quality Guidelines for PFOS in aquatic life (water), fish tissue, wildlife diets, and bird eggs (see Table 2-4). Proposed final guidelines have been developed for screening for soil exposure pathways (see Table 2-5) and groundwater exposure pathways (see Table 2-6) for PFOS and were most recently updated in February 2017. In 2016, British Columbia promulgated amendments to the BC Con taminated Site Regulations, which will become effective November 1, 2017, that include regu latory criteria for PFOS, PFOA, and PFBS based on toxicity, persistence in the environment, and relevance to contaminate sites in British Columbia. In addition, guidelines are currently in development in Ontario. 2.4.3 European Union Countries The directive on "Environmental Quality Standards" (EQSD) sets environmental quality stan dards for certain priority hazardous substances for the EU. The EQSD presented in the document for PFOS were derived by the National Institute for Public Health and the Environment (RIVM) in the Netherlands. RIVM has derived scientific environmental risk limits for PFOS in fresh and marine sur face waters. RIVM (55) provides maximum permissible concentration (MPC) values for both Table 2-4. Federal Environmental Quality Guidelines for PFOS (Canada). Mammalian Avian 6 8.3 4600 8200 1.9 Copyright National Academy of Sciences. All rights reserved. US00004605 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 2-5. Federal soil quality guidelines for PFOS.* Primer-- Background on PFASs 21 Final Soil Guideline 0.01 0.01 0.14 1 0.212 0.14 1 0.212 Soil Contact (SQGsc) 11 11 61 61 Soil Ingestion (SQG1C) 2.2 2.2 NR NR Soil Ingestion--secondary and tertiary consumers (SQG2C, SQG3C) 0.01 0.01 NR NR Agricultural (Livestock watering) 12 1 92 NR NR NR Protection of Freshwater Life (SQGFL) 0.14 1 0.212 Off-site migration (SQGqm-e) NR NR 0.14 0.14 NR denotes "not required." *Federai Environmental Quality Guidelines for PFOS, Environment and Climate Change Canada, February 2017. 1Coarse-grained soil 2Fine-grained soil Table 2-6. Federal groundwater quality guidelines for PFOS.* Final Groundwater Guideline (FGWQGhnal)1 0.068 0.068 Groundwater Contact (FGWQGgc) by Soil-Dependent Organisms 2 2 Protection of Freshwater Life (FGWQGfl)2 0.068 0.068 Protection of Marine Life (FGWQGMl) NC NC Protection of Livestock Watering (FGWQGlw) NC NC Protection of Irrigation Water (FGWQGm) NC NC Management Considerations (FGWQGM)--Solubility 370 370 NCdenotes "not calculated." *Federal Environmental Quality Guidelinesfor PFOS, Environment and Climate Change Canada, February 2017. 1The federal groundwater quality guideline-final (FGWQGnNAJ is the lowest of the pathway-specific guidelines while also taking the solubility into account. 2FGWQGpLis the concentration in groundwater that is expected to protect against potential impacts on freshwater life from PFOS originating in soil that may enter groundwater and subsequently discharge to a surface water body. This pathway may be applicable under any land use category, where a surface water body sustaining aquatic life is present (i.e., within 10 kilometers of the site). Where the distance to the nearest surface water body is greater than 10 kilometers, application of the pathway should be evaluated on a case-by-case basis by considering the site-specific conditions. Copyright National Academy of Sciences. All rights reserved. US00004606 Use and Potential Impacts of AFFF Containing PFASs at Airports 22 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 2-7. EU maximum allowable drinking water concentrations. UK HPA 0.3 0.3 DEPA* 0.3 0.1 Germany Department of Environmental Protection 0.1 (sum of PFOA and PFOS) *Where PFOS, PFOA, and Perfluorooctane sulfonamide (PFOSA) occur in the drinking water at the same time, the total concentration/limit value must be < 1 ug/L. environmental and human health, with the value for human health based on consumption of fish and shellfish. The human health value represents the lowest MPC in freshwater at 0.65 ng/L. Table 2-7 presents maximum acceptable concentrations of PFOA and PFOS in drinking water as developed by the UK Health Protection Agency (HPA), the Danish Ministry of the Environment (DEPA) (56), and the Department of Environmental Protection in Germany. DEPA has also derived health-based soil quality criteria: PFOS: 0.39 mg/kg PFOSA: 0.39 mg/kg PFOA (and salts, e.g., Ammonium pentadecafluorooctanoate [APFO]): 1.3 mg/kg In the case that PFOS, PFOA, and PFOSA occur in the soil together at the same time, the concentration/limit value must be < 1 mg/kg. 2.4.4 Australia In Australia, regulations on the use, release, and disposal of PFASs and any criteria for these chemicals is primarily a state and territory responsibility. However, interim national guidance on human health reference values for PFASs for use in site investigations has been derived by the Environmental Health Standing Committee (enHealth) of the Australian Health Protection Principal Committee and have been made available as of June 2016 (57). (See Table 2-8.) Additionally, the Government of Western Australia has produced a Contaminated Sites Guideline document containing interim screening levels for soil, sediment, surface water, and groundwater (58). (See Table 2-9.) The purpose of the Contaminated Sites Guideline document is to provide guidance on the assessment and management of PFASs within the applicable legislative framework. Table 2-8. Recommended enHealth interim values. Tolerable Daily Intake (pg/kg/d) Drinking Water Quality Guideline (pg/L) Recreational Water Quality Guideline (pg/L) 0.15 0.5 5 1.5 5 50 Copyright National Academy of Sciences. All rights reserved. US00004607 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 2-9. Western Australia interim screening levels for PFOS and PFOA in environmental media. Primer-- Background on PFASs 23 Soil Human Health Residential (mg/kg) Human Health Industrial/Commercial (mg/kg) Surface Water and Groundwater Drinking Water (pg/L) Non-Potable and Recreational Uses (pg/L) Ecological--Freshwater (pg/L) 4 100 0.5 5 0.00023 0.13 2.0 31 - 19 220 632 (90% species protection) 1,824 (80% species protection) 2.5 How M ig h t PFASs A ffect an A irport? Use of AFFF (containing PFASs) at airports has the potential to impact the environmental media on, or in, the vicinity of airports. PFASs may impact airport operations and environmental management. The primary impacts to operations would be related to firefighting activities-- specifically, how airports procure, store, handle, apply, remove, and dispose of AFFF. With regard to environmental management, PFASs will have a potentially significant impact on how envi ronmental media are investigated and remediated. Similarly, media impacted by PFASs that require special handling may be encountered as capital projects are undertaken. The following sections discuss these considerations. 2.5.1 Known Practices of AFFF Use AFFF is used for fire suppression. Its role is to cool the fire and coat the fuel, preventing fuel from contacting oxygen and suppressing further combustion. In the mid-1960s, the U.S. Navy developed AFFF, which was observed to have dramatic "fire knockdown" capabilities, an important factor in crash rescue firefighting. AFFF solutions are mixed with water at the point of use to cre ate the desired mixture strength. The application mixture is typically shown on the container of AFFF concentrate or in the product manufacturer's directions. The foam forms spontaneously upon ejection of the concentrate/water mixture from a nozzle. Environmental release of PFASs related to AFFF use has historically resulted from emergency response, testing, emergency activation of fire suppression systems in hangars, leaks from storage tanks and/or supply lines, and firefighter training exercises. Additionally, storage tanks or supply lines previously containing PFASs could still contribute residual amounts. Best practices for managing release of PFASs into the environment include the following: Up-to-date document and inventory management and personnel training. Spill containment during refilling of storage containers and foam tests. Fire training activities with an environmentally benign type of foam (e.g., no PFASs). Engineered containment systems in hangars, firefighter training areas (FFTAs), and tarmac (e.g., storm sewer) that capture and direct any discharged AFFF. Copyright National Academy of Sciences. All rights reserved. US00004608 Use and Potential Impacts of AFFF Containing PFASs at Airports 24 Use and Potential Impacts of AFFF Containing PFASs at Airports 2.5.2 Potential Sources of PFASs Potential sources for PFASs at an airport facility are mostly linked to past use of AFFF and could include the following: Firefighting training areas where AFFFs were used. Firefighting equipment maintenance areas (e.g., from foam tests). Disposal areas. Treatment lagoons. Impacted soils. Drainage and wastewater systems used to contain discharged fire-extinguishing materials. Storage areas for AFFF. Tanks, vehicles, equipment, and distribution systems that were used to store or apply AFFF, and then were not adequately rinsed and may have become a continuous source. 2.5.3 Environmental Considerations As discussed previously, releases to the environment of small amounts of AFFF containing PFASs could significantly impact environmental media, wildlife, and, potentially, human popu lations. Responses to environmental impacts of PFASs that present unacceptable human health or ecological risks will be shaped by regulations. Capital projects maybe affected by impacts of PFASs on soil and groundwater because if, in the course of a capital project, PFASs are found in these media, care maybe required (potentially at significant cost) to handle and properly dispose of the soil and groundwater impacted by PFASs (e.g., dewatering). 2.5.4 Human Health Considerations Best management practices protect not only the environment from exposure, but also work to protect workers and individuals that may come into contact with AFFF containing PFASs at air ports. Firefighters, in particular, are an occupationally exposed population. PFASs in firefighting products have been measured in the blood of firefighters at concentrations above those in the average population (59-62). Special consideration must be given to ensuring contaminated sites are cleaned up. Preventative measures should be put into place to limit occupational exposure to AFFF containing PFASs and to monitor worker's health. Copyright National Academy of Sciences. All rights reserved. US00004609 Use and Potential Impacts of AFFF Containing PFASs at Airports Research Methodology CHAPTER 3 " erview The research methodology for ACRP Project 02-60 was developed based on the following understanding: The level of awareness and knowledge associated with AFFF and PFASs varies greatly among (and within) airports. Management practices associated with AFFF procurement, storage, application, and disposal vary greatly among airports. Despite PFASs being characterized as an "emerging contaminant," there has been much study and research on the effects associated with PFASs in the environment. Regulations associated with PFASs in the environment are being promulgated more frequently and becoming more stringent. Manufacturers ofAFFF have changed their formulations in response to regulatory requirements due to concerns associated with the environmental effects of PFASs in the environment. Most notably, manufacturers have removed PFOS-based AFFF and then PFOA and other "long-chain" PFASs from their formulations. Many airports that have identified issues related to PFASs that are associated with AFFF use or release are unsure of how best to respond, and some have been pursuing guidance on how to manage their liabilities (understanding that regulatory action could potentially lead to expensive assessment and remediation programs). Effective, state-of-the-practice sampling and laboratory analytical approaches for PFASs have been developed and adopted by federal government departments in both the United States and Canada. Traditional remediation approaches (e.g., "excavation and disposal" and "pump and treat") have been successfully applied in the held, but are typically limited in their effectiveness (or cost-effectiveness) to address the impacts of PFASs. The research plan included three principal data-gathering approaches: literature review, air port survey, and consultation with subject matter and industry experts. The following sections summarize the research methodology associated with each of these approaches. 3 __ a ttire R e v ie w A literature review was conducted of peer-reviewed (e.g., scientific journal articles) and non-peer-reviewed research (e.g., industry articles) available via academic search engines, online references and searches, and documents otherwise available to the research team. Recognizing that new findings regarding environmental fate and transport and remediation of PFASs are being published at an accelerated rate (10, 55-61), the research team monitored scientific journals Copyright National Academy of Sciences. All rights reserved. 25 US00004610 Use and Potential Impacts of AFFF Containing PFASs at Airports 26 Use and Potential Impacts of AFFF Containing PFASs at Airports and industry publications throughout the research. In addition, the research team identified other resources (e.g., conference proceedings) by attending conferences with key subject matter topics, including AFFF, firefighting, PFASs, AFFF alternatives, analysis of PFASs, and remediation technologies for PFASs. Specific efforts targeted jurisdictions that have been relatively (i.e., com pared to North America) proactive--such as Norway, Sweden, and Australia-- in understanding the chemistry and fate and transport of PFASs and in developing remediation solutions and AFFF alternatives. 3 rport Survey A survey was designed to effectively canvas a broad segment of the North American civilian airports that are required to have firefighting equipment (and, thus, use AFFF) to understand how these airports manage the procurement, storage, use, and disposal of AFFF, and any practices related to impacts of PFASs on the environment. Pursuant to Title 14, Code of Federal Regulations Part 139 (i.e., specifically, Part 139 Airport Certification Status List) and the Canadian Aviation Regulations (CARs) 303, 580 airports (540 airports in the United States and 40 in Canada, including commercial service and general aviation airports) were identified to provide a representative, initial sample population pool that included a broad range of firefighting and emergency response services, management practices, and airport classes. In order to provide a 95-percent confidence level with a margin of error of + /- 5 percent, a net survey sample size of 223 was targeted. Designed to place an emphasis on airports with greater aircraft rescue and firefighting (ARFF) facilities (e.g., larger storage require ments, more infrastructure and, therefore, it is assumed, more need and use of AFFF), the net sample set included all of the airports in ARFF Categories E, D, and C (including the Canadian airports, which were recategorized to "match" their U.S. category counterparts) and proportional numbers from Categories B and A to produce a total net sample set of 225 airports (199 U.S. airports and 26 Canadian airports). General aviation airports that elected to apply for a Part 139 certificate and thus are required to provide firefighting capabilities pursuant to their Part 139 certification (and were listed on the Part 139 Airport Certification Status List) were categorized among the ARFF indices as appropriate. As detailed in Appendix A of this report, 167 airports across the United States (149) and Canada (18) completed survey interviews between December 2015 and March 2016. The survey questionnaire was vetted by select airports and the ACRP Project 02-60 panel and contained 42 questions, 16 of which were open-ended; the average interview length was 21 minutes. As indi cated in Table 3-1, the overall response rate was 74 percent, and all ARFF categories had response Table 3-1. Distribution of responses by airport size category. Category A Category B Category C Category D Category E Total 48 40 83 29 22 76 90 69 77 28 19 68 30 17 57 225 I 167 I 74 Copyright National Academy of Sciences. All rights reserved. US00004611 Use and Potential Impacts of AFFF Containing PFASs at Airports Research Methodology 27 rates greater than 50 percent. The margin of error for the survey, given the population and sample sizes, is 6.7 percent at the 95-percent confidence level. Data collected from the survey (including open-ended answers) were coded (as detailed in Attachment B ofAppendix A) and used to assess the extent ofAFFF management and use across a statistically representative cross-section of civilian airports and identify current industry management practices. 3.4 Subject M a tte r and Industry Expert Outreach To supplement the information on current AFFF management practices obtained through the industry survey, the research team also solicited subject matter and industry expertise related to AFFF; airport firefighting and ARFF classification; regulations associated with PFASs; environ mental fate, transport, and remediation of PFASs; and laboratory analyses of PFASs. Specifically, the research team reached out to manufacturers ofAFFF and alternative products; industry trade organizations; airports, including airport emergency response personnel; academics specializing in the science of PFASs; commercial analytical laboratories; and representatives of government involved in the regulation of PFASs and policy development. The research also sought input from the ACRP Project 02-60 panel. Additionally, the screening tool framework was reviewed by the ACRP Project 02-60 panel, and subsequent beta testing of the screening tool was vetted by three airports. Copyright National Academy of Sciences. All rights reserved. US00004612 Use and Potential Impacts of AFFF Containing PFASs at Airports C mH Aa Pn tI rh Rn 4a AFFF Management Within Airport Operations view AFFF is used in airport operations as a fire-extinguishing agent to prevent, extinguish, or control Class B fires, i.e., fires of flammable and combustible liquids such as crude oil, gasoline, and fuel oils. AFFF generates foam that retains water, separates fuel from flame, and ultimately results in dramatic, fast knockdown of Class B fires. Fluorocarbon surfactants and specifically PFASs-- a large group of related human-made fluorinated organic chemicals--are key ingredients in AFFF. As indicated previously, some PFASs used in AFFF have been shown to exhibit multiple problematic chemical, physical, and toxicological properties. The problematic properties have largely been attributed to "long-chain" PFASs, i.e., PFCAs with eight or more carbons (including PFOA) and PFSAs with six or more carbons (including PFOS). In the past, AFFF formulations were made with PFOS as the predominant active ingredient. Early alternatives to PFOS-based AFFF contained long-chain, telomer-based fluorochemicals that in some cases could breakdown to PFOA. Like PFOS, PFOA has been observed to be persistent in the environment. Consequently, AFFF manufacturers have shifted toward using short-chain (i.e., < C6, having six or fewer carbon molecules) C6and C4perfluoroalkylated chemicals (7). Currently, the most common and widely used short-chain PFASs in AFFF are the C6-based fluorotelomers. While current AFFF formulations are believed to be potentially less problematic to human health and the environment than PFOS-based formulations, much remains unknown about the short-chain PFASs used in AFFF. Short-chain PFASs can be as environmentally persistent as long-chain substances or have persistent degradation products. A switch to short-chain and other fluorinated alternatives may not reduce the quantity of PFASs in the environment (70). In addition, because some of the short-chain PFASs are less effective than their long-chain counterparts, greater quantities of short-chain PFASs may be required to provide the same performance. Potential risks to human health and the environment may result from contact with or release into the environment of current AFFF formulations. Consequently, it is important for users of AFFF, such as airports, to develop best practices for managing the use of AFFF that mitigate potential impacts to human health and the environment. This chapter discusses management practices of AFFF at airports in North America related to procurement, storage, application (i.e., maintenance, use/testing, and training), and disposal (i.e., discharge to environment, containment, and treatment/off-site disposal). (See Figure 4-1.) Specifically, this chapter describes the following: Legislation, regulations, and/or guidance relevant to AFFF. Guidance from firefighting foam manufacturers is also identified. 28 Copyright National Academy of Sciences. All rights reserved. US00004613 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 29 j Procurement : :... >i Storage Maintenance : Ose/Testificj : Training Procu rem ent Storage Application Figure 4-1. AFFF life cycle stages. Dischargeto i Environment \ Containment Treatment' Off-Site Disposal Disposal The state of the practice ofAFFF procurement, storage, application, and disposal at airports in North America based, in part, on a survey completed by 167 airports across the United States and Canada. Further detail on the survey is provided in Appendix A. Best management practices for North American airports related to procurement, storage, application, and disposal of firefighting foams. 4___ro cu re m e n t Airports procure AFFF in the form of a liquid concentrate that, when mixed with water in the correct proportions and with the correct equipment, produces a foam solution. AFFF is procured for use in firefighting and fire suppression at civilian airports in the United States and Canada, pursuant to the requirements detailed in Section 4.2.1. The selection of firefighting foam is based on numerous factors, including compliance with governmental quality or performance specifications, cost, availability, compatibility with existing stock and systems, and environmental considerations. The following sections identify quality and performance-based procurement criteria for evaluating firefighting foams used in airport operations, describe AFFF alternatives acceptable for use in the United States and Canada, and identify best practices for AFFF procurement. 4.2.1 Procurement Criteria Quality and performance-based criteria for AFFF are established, in part, through standards established in the United States and Canada by federal agencies responsible for civil aviation (i.e., the FAA and Transport Canada, respectively). Additional considerations affecting the procurement of AFFF at airports are associated with performance, compatibility with existing firefighting equipment and systems, availability, and cost. In North America, FAA and Transport Canada regulations reference the following standards related to aircraft rescue and firefighting at airports: United States Military Specification (MIL-SPEC)-- MIL-F-24385 (Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater). MIL-F-24385 is specific to AFFF and includes performance tests on the foam concentrate itself. It is a performance specification as well as a procurement specification for the U.S. military and federal government. Underwriters Laboratories Inc. (UL)--Foam Equipment and Liquid Concentrates (UL 162). UL 162 tests foam concentrates and equipment, evaluating specific foam concentrate/ proportioner/discharge device combinations. Standards Council of Canada-- CAN/ULC-S560-06 (Standard for Category 3 AFFF Liquid Concentrates). Copyright National Academy of Sciences. All rights reserved. US00004614 Use and Potential Impacts of AFFF Containing PFASs at Airports 30 Use and Potential Impacts of AFFF Containing PFASs at Airports In addition, the FAA cites standards by the National Fire Protection Association (NFPA). These standards provide guidance on ARFF services at airports. Standards referenced include the following: NFPA 11: Standard for Low-, Medium-, and High-Expansion Foam. NFPA 18: Standard on Wetting Agents. NFPA 403: Standard for Aircraft Rescue and Fire-Fighting Services at Airports. NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Fire Equipment. NFPA 1003: Standards for Professional Qualifications for Airport Fire Fighters. NFPA 403 defines the minimum requirements for ARFF services at airports. It should be noted, however, that the Code of Federal Regulations (CFR), Title 14 - Aeronautics and Space, Part 139, Certification of Airports takes precedence over the NFPA 403 standard, which in some areas exceeds FAA requirements. Unlike the United States, Canada does not have a fire protection association that specifically provides standards for firefighting foam, aircraft rescue, and firefighting at airports. Rather, Transport Canada references NFPA 412: Standard for Evaluating Aircraft Rescue and Fire Fighting Foam Fire Equipment as a standard to be followed by Canadian airports for rescue vehicles. 4.2.2 Environmental Considerations As outlined in Chapter 2 of this report, releases of firefighting foam to the environment pose potential impacts to environmental media, wildlife, and hum an populations. Different fire fighting foams have different chemical compositions, with varying properties (1, 71). A product manufacturer's safety data sheet (SDS) may contain sections that provide toxicological, human health, and ecological information. If this information is not presented in the SDS, it can be requested from a product manufacturer. The indicator values presented on a SDS can be com pared to identify better alternatives or options for an airport facility. For example, within the same species (e.g., rabbit), a higher LD50 or LC50 would be preferred--this value indicates that a greater quantity or concentration of AFFF would be required to harm 50 percent of the rabbit test sample population. Some indicator values (LD50, LC50, and EC50) cannot be compared between species (e.g., rabbit versus guinea pig). Indicators typically found on SDSs are presented in Table 4-1. 4.2.3 Alternatives AFFF is the most widely used firefighting foam due to its film-forming and fast knock down properties. PFOS (part of the larger group of PFASs) was a key ingredient in AFFF until con cerns were identified regarding its environmental persistence, bio accumulative properties, and toxicity. In 2002, 3M voluntarily stopped production of AFFF that contained and/or degraded into PFOS. Subsequently, regulations in numerous jurisdictions, including North America, were developed to ban all production of PFOS-based products. In 2002, the U.S. EPA published a SNUR under the TSCA restricting the rintroduction into the market of the PFOS chemicals included by 3M in the voluntary phase-out. A 2007 SNUR broadened the scope to 183 chemicals within the class of PFASs. In Canada, as of June 2013, production, supply, and use of AFFF containing PFOS are banned, with some exemptions for military applications. As discussed, early alternatives to using PFOS-based AFFF were long-chain fluorotelomers, which in some cases can break down to PFOA. Later, it was found that, like PFOS, PFOA is very persistent in the environment. In response, a voluntary global directive by the U.S. EPA-- referred to as the U.S. EPA 2010/2015 PFOA Stewardship Program--was introduced calling for a 95-percent reduction of plant emissions and product content of PFOA, PFOA precursors, and Copyright National Academy of Sciences. All rights reserved. US00004615 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-1. Environmental indicators on AFFF product SDSs. AFFF Management Within Airport Operations 31 LD50 LC50 EC50 BOD COD Lethal dose at 50 percent (LD50) is the amount of an ingested substance that kills 50 percent of a test sample (short-term exposure). Same species (e.g., species are both rabbit), higher values. Lethal concentration at 50 percent (LC50) is the lethal concentration required to kill 50 percent of the population (longer-term exposure). Half maximal effective concentration (EC50) is the concentration of a substance that gives half-maximal response. Used as a measure of the substance's potency. Biochemical oxygen demand (BOD) is the amount of dissolved oxygen needed by aerobic biological organisms to break down organic material present in a given water sample at a certain temperature over a specific time period. Chemical oxygen demand (COD) is the amount of dissolved oxygen needed by chemicals to break down organic material present in a given water sample at a certain temperature over a specific time period. Same species, higher values. Same species, higher values. Lower values. Lower values. related homologue materials by 2010, and a 100-percent reduction (i.e., elimination) by 2015. In 2010, Environment Canada also published the decision to regulate PFOA (C8), its salts, and its precursors. These chemicals are now listed in the List of Toxic Substances Managed Under CEPA (Schedule 1). As of the publication of this report, amendments to include PFOA have been proposed for Environment Canada's Prohibition of Certain Toxic Substances Regulations, 2012. The implementation of regulations banning the production of PFOS and the voluntary stewardship program have brought about substantial research and development into alternative firefighting foams that do not breakdown into PFOS, PFOA, or other types of PFASs. Alternatives are described in two categories, fluorinated foams and fluorine-free foams. While fluorine-free foams are described as alternatives and are being used in some applications in Europe and Australia, there are currently no fluorine-free foams that meet specifications for use in emergency response at North American airports. All AFFFs contain fluorocarbon surfactants. The most widely used alternative for North American airports continues to be AFFF that con tains fluorocarbon surfactants that are manufactured using telomerization and are referred to as short-chain fluorotelomers. While persistent in the environment, PFCA chemicals with fewer than eight carbons and PFSA compounds with fewer than six carbons are generally believed to be less toxic and less bioaccumulative in wildlife and humans, although limited toxicological data are available. AFFF containing these short-chain PFASs can still degrade to other PFASs in the environment. The use of these compounds has persisted as testing has shown that, for a given application rate, no alternative foam agent can equal the performance of AFFF for airport applications (72). Appendix B describes AFFF alternatives in further detail, identifies their advantages and dis advantages, and lists properties of available products in the marketplace. The following sections identify the currently acceptable AFFF alternatives available in the United States and Canada. 4.2.3.1 Acceptable Alternatives Available in the United States In the United States, the FAA issues operating certificates to airports that comply with certain operational and safety standards. The regulatory requirements related to firefighting at Copyright National Academy of Sciences. All rights reserved. US00004616 Use and Potential Impacts of AFFF Containing PFASs at Airports 32 Use and Potential Impacts of AFFF Containing PFASs at Airports airports, as overseen by the FAA, are found in CFR, Title 14--Aeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139) and, specifically, 14 CFR Part 139, 139.317 Aircraft rescue and firefighting: Equipment and agents. The FAA also issues guidance documents and resources such as Advisory Circulars and CertAlerts to provide further guidance for airports on howto comply with 14 CFR Part 139. Up-to-date information can be found on the FAA website under Airports. The most recent Advisory Circular on Aircraft Fire Extinguishing Agents, AC 150/5210-6D, states that foam concentrates must meet the performance test requirements of the MIL-SPEC, MIL-F-24385, to comply with 14 CFR Part 139. Further guidance by the FAA on the procure ment of AFFF notes that Any foam purchased since July 2006 must be on the United States Department of Defense Qualified Products Database (QPD) list indicating that the foam meets the MIL-SPEC requirements. The QPD serves as the official repository for qualification information regard ing producers and manufacturers and is accessible to the public at http://qpldocs.dla.mil/. AFFF in concentrations lower than 3 percent is not acceptable for the use at airports. AFFF is available in 1-, 3-, or 6-percent concentrates. The percentages refer to the percentage of concentrate mixed with fresh water or seawater by a proportioning nozzle to create a foam solution. The 1-percent concentrate should not be used in ARFF applications because of the difficulty in consistently providing an accurate mixture. Firefighting performance is an important, if not the primary, procurement consideration for AFFF. In addition to understanding the standards used to evaluate and certify firefighting foams, the FAA suggests that airport managers request proof of tests on performance and quality by a recognized testing laboratory (e.g., UL) from prospective firefighting foam concentrate suppliers. System and equipment compatibility is also an important consideration in the procurement of firefighting foams. Guidance by the NFPA on firefighting foams suggests that The type of foam concentrate used should be a type that has been indicated as suitable for the system and equipment that will be used. Converting to use of a different type of foam concentrate requires consultation with the equipment manufacturer. Flushing of the system is required prior to using a new foam concentrate. Recalibration and resetting proportioning equipment may also be required. Regulations in the United States do not currently prohibit the purchase of AFFF contain ing long-chain fluorocarbon surfactants (i.e., C8or longer); however, there are regulations that prohibit the manufacture and import of this material. Existing stock of foams containing PFASs that may break down into PFOS or PFOA still exists and may still be used in the United States. A product's adherence to the U.S. EPA 2010/2015 PFOA Stewardship Program can often be found in the manufacturer's product information sheet, indicating that the foam concentrate formulation contains C6or short-chain fluorochemicals rather than the long-chain fluorochemicals. 4.23.2 Acceptable Alternatives Available in the Canada In Canada, Transport Canada administers the CARs, which require airports to have a safety management system in place and comply with airport safety standards and security requirements, including firefighting capabilities. Per Transport Canada's CAR Standard 323--Aircraft Fire Fighting at Airports and Aerodromes, operators of "designated airports," where the total of the number of passengers that are enplaned and the number of passengers that are deplaned is more than 180,000 per year, are to provide aircraft firefighting service with both the principal and the complementary extinguishing agents. Copyright National Academy of Sciences. All rights reserved. US00004617 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 33 The regulatory requirements related to firefighting at airports are guided by CARS Part III-- Aerodromes, Airports and Heliports, Standard 323--Aircraft Fire Fighting at Airports and Aerodromes. Information specific to firefighting foams is provided in Standard 323, Section 323.08-- Extinguishing Agents and Equipment. Section 323.08 requires the follow ing of foams provided as principal extinguishing agents: "AFFF shall meet the latest relevant performance specifications of CAN/ULC-S560." As it relates to system and equipment compatibility, Transport Canada requires that the principal extinguishing agents for aircraft firefighting service be foams suitable for the type of equipment used. Civilian airports in Canada can no longer purchase PFOS-based AFFF in accordance with the Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations (2008), which prohibit the manufacture, use, sale, offer for sale, and import of PFOS and products containing PFOS. Environment Canada has proposed amendments to existing regulations that would prohibit PFOA and products containing PFOA (e.g., possibly including AFFF formulations containing PFOA and/or its precursors). 4.2.4 State of the Practice In the survey of North American airports, about two-thirds of the respondents (65.7 percent) indicated that the most important procurement criterion for the acquisition of AFFF was com plying with government regulations. In the United States, most respondents specifically high lighted the need for the AFFF purchased to be in compliance with the MIL-SPEC and meet FAA requirements. Canadian respondents identified Transport Canada guidelines as the defining regulations. Other important criteria mentioned included cost or price, the use of an external pur chasing agency or organization, the availability of sufficient quantities, and the use of a required list of vendors. For many airports, cost influences procurement decisions. Once foam compatibility and compliance with regulations is known, many airports seek bids from a variety of suppliers. For a handful of respondents, procurement is based on municipal procurement policies and may involve selecting suppliers from a pre-approved vendor list, obtaining a minimum number of bids from suppliers, and/or working with a supplier under contract. Some Canadian airports specifically made mention of a joint procurement process for major airports and bulk buying AFFF from suppliers. Procurement decisions were also said to be made based on the required quantities and the amount a supplier could sell. In both the United States and Canada, certain quantities of firefighting foam must be held at an airport by law, driving the procurement of new foams when existing stocks are consumed or disposed. When asked about alternative formulations of AFFF, roughly a quarter of respondents indi cated that they were aware of alternative formulations, but most respondents who were aware of alternatives were unable to name specific formulations or products. As noted, some respondents indicated that procurement and the consideration of alternatives was the responsibility of others. In general, however, the survey indicated that AFFF alternatives were rarely used, principally because alternatives were not compliant with government regulations. 4.2.5 Best Management Practices Table 4-2 identifies the best management practices associated with procurement of AFFF. Consideration of these practices will allow an airport to make an informed decision on what type of AFFF will meet its current and future needs. Copyright National Academy of Sciences. All rights reserved. US00004618 Use and Potential Impacts of AFFF Containing PFASs at Airports 34 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-2. Best management practices associated with procurement of AFFF. Legislation and Regulations AFFF Performance Environmental Considerations Comply with legislation, regulation, and/or guidance in the United States Comply with legislation and regulations in Canada To meet the requirements of the Code of Federal Regulations (CFR), Title 1 4 - Aeronautics and Space, Part 139, Certification of Airports (14 CFR Part 139), 139.317 Aircraft rescue and firefighting: Equipment and agents. To follow FAA Guidance Documents (Advisory Circulars and Cert Alerts). To align with the targets of the U.S. EPA 2010/2015 PFOA Stewardship Program. To meet the requirements of the CARs, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes, which identifies the requirements to comply with Part III Aerodromes, Airports and Heliports. Section 323.08 of the Standard, Extinguishing Agents and Equipment. 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. Meet firefighting foam performance standards in the United States Use foam that is a 3-percent or 6-percent concentrate. Meet firefighting foam performance standards in Canada FAA requires that AFFF meets the requirements of the MIL-SPEC, MIL-F-24385. Qualified AFFF products are listed on the QPD, found at http://qpldocs.dla.mil/. As suggested by the FAA, foam concentrate must be either a 3-percent or 6-percent concentrate. Foam concentrate at 1 percent should not be used because of the difficulty in consistently providing an accurate mixture without the use of a computer-controlled system. In addition, there is no room for error when using a foam concentrate at a low percentage; if a discharge is on the lean side, effectively, plain water will be applied to the fire. Further information on the selection of 3-percent and 6-percent foam is included under "System and Equipment Compatibility." As per the CARs, Standard 323 Aircraft Fire Fighting at Airports and Aerodromes, AFFF purchased must meet the latest relevant performance standards of CAN/ULC-S560. Request proof of tests on performance and quality from prospective firefighting foam concentrate suppliers. To confirm that the foam purchased meets the relevant performance standards required for the country. Do not purchase PFOS-based AFFF All new production has been banned in the United States and Canada, and the sale (and purchase) of PFOS-based AFFF is prohibited in Canada. Do not use AFFF that has >=C8 fluorotelomers Select AFFF that contains C6based fluorotelomers where available (Information can be found in a product's manufacturing sheet.) To align with the targets of the U.S. EPA 2010/2015 PFOA Stewardship Program and to be in compliance in advance of the incumbent Environment Canada regulations that would ban the use of >=C8fluorotelomers that can break down to PFOA. While persistent in the environment, PFCAs with fewer than eight carbons, such as perfluorohexanoic acid (PFHxA), and PFSAs with fewer than six carbons, such as perfluorobutane sulfonic acid (PFBS), are believed to be generally less toxic and less bioaccumulative in wildlife and humans. Review environmental data, where available, from a product's specification. If available, choose a foam with the following criteria: Highest lethal dose - Lowest BOD - Lowest COD - Highest LC50 Some firefighting foams can have greater environmental impact based on the physicochemical properties of the firefighting foam product. It is important for those working with the products to understand the type of potential impacts a product may have so it can be dealt with accordingly. Copyright National Academy of Sciences. All rights reserved. US00004619 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-2. (Continued). AFFF Management Within Airport Operations 35 System and Equipment Compatibility Determine the compatibility of foam with existing systems and equipment. Use the type of device required for the foam concentrate. Check the compatibility of any new foam with the previous foam type/batch Select 3-percent foam concentrates, when system and equipment compatibility allows. Look to upgrading firefighting equipment to be compatible with the use of less foam concentrate, when applicable Based on the foam concentrate, different equipment or systems may be required (i.e., an aspirating vs. non-aspirating device). In addition, different equipment may only be compatible with a foam concentrate of a certain percentage. Older equipment may only be compatible with 6-percent foam. The type of foam concentrate should be compatible with the system and equipment to avoid coagulation concerns. Recalibration and resetting proportioning equipment may also be required. Consult with the equipment manufacturer prior to using a different type of foam concentrate in the equipment. Flushing of the system is required prior to using a new foam concentrate. 3-percent foams require half of the volume of concentrate to produce the same amount of foam, making them more cost-effective, reducing on-site storage requirements, and requiring less product in ARFF vehicles. Newer equipment is compatible with 3-percent foam concentrate, which requires the use of less foam concentrate as an input. orage Proper storage of AFFF concentrates used for firefighting purposes alleviates the likelihood of accidental releases, spills, or concentrate contamination and prolongs the shelf life of the product. At most airports, AFFF is stored within ARFF vehicles (i.e., in the vehicle's designated foam tanks), on-site in the manufacturer's containers, in on-site storage tanks, and/or within hangar deluge systems. The following sections identify legislative requirements governing AFFF storage, the current state of the practice, and best management practices associated with AFFF storage. 4.3.1 Regulations Dictating Firefighting Foam Reserves Capacity The FAA and Transport Canada dictate how much AFFF airports need to store in reserve. Reserve storage requirements vary by the size of the airport and the type of aircraft the airport services. In the United States, the FAA requires an on-airport reserve firefighting foam supply either in a single container, storage tank, or storage area that has capacity sufficient to fill all vehicles with at least twice their assigned capacity (i.e., bunded storage). Transport Canada's guidance related to firefighting foam reserves is included in Standard 323.08. It requires that a sufficient quantity of foam concentrate is held in reserve to allow four complete discharges (i.e., assuming that at the proper concentrate-to-water ratio [or percentage], there is enough concentrate on hand to empty the total water volume available within the ARFF vehicles four times). The amount held in reserve can be considered to include the volume carried on the ARFF vehicles. 4.3.2 State of the Practice The following sections describe the state of the practice associated with key storage consider ations: storage areas and type of containers. Copyright National Academy of Sciences. All rights reserved. US00004620 Use and Potential Impacts of AFFF Containing PFASs at Airports 36 Use and Potential Impacts of AFFF Containing PFASs at Airports 4.3.2.1 Storage Areas Survey respondents characterized storage areas for firefighting foams to be as follows: Enclosed Covered Have a cement or concrete floor Have double containment Underground storage tanks Have an earth or gravel floor The survey responses suggested that enclosed storage was substantially more common in the United States (95.3 percent) than in Canada (77.8 percent). While double containment for storage was not common, responses showed that larger airports were more likely than smaller ones to use double containment. The two countries also differed in the quantity of AFFF storage areas that have an earth or gravel floor. In the United States, virtually none (99.3 percent) of the respondents have such floors, whereas approximately 6 percent of Canadian airports reported storing their AFFF in storage areas with earthen or gravel floors. 4.3.2.2 Containers Regulations in the United States and Canada do not dictate how foam concentrates should be stored. On-site storage of firefighting foams at North American airports is often in tanks or in the manufacturer's containers. Guidance on conditions for storage reserves and general storage of foam concentrates can be found in a foam concentrate manufacturer's product information sheets such as an SDS and/or a technical data sheet. Additional guidance on storage conditions, storage containers, and mixing, among other things, can be found within the standards used to accredit firefighting foams (i.e., NFPA, MIL-SPEC, and UL). Manufacturers of foam concentrates suggest storing the product in its original shipping con tainer or in tanks or other containers that have been designed for foam concentrate storage. Above-ground storage tanks designed specifically for foam concentrate storage are produced and sold by a number of manufacturers, including select AFFF manufacturers. Recommended construction materials for storage containers include stainless steel (Type 304L or 316), highdensity cross-linked polyethylene, or reinforced fiberglass polyester with a vinyl ester resin. Manufacturers of storage tanks for foam concentrates suggest that above-ground storage tanks be placed on a level surface. Conditions To avoid evaporation, foam concentrate storage should be in a container that is sealed to prevent the free exchange of air. The recommended storage environment should be within the temperature range listed in the product manufacturers' information sheet. Storage tempera tures for AFFF concentrates are generally listed as being between 2C to 49C (36F to 120F). If stored in the correct environment, following manufacturer's guidelines and not otherwise contaminated, AFFF concentrates can reportedly last between 20 and 25 years. Mixing Mixing of different foam concentrates is not recommended. However, on a case-by-case basis and in consultation with the manufacturer, mixing maybe acceptable. Current guidance regard ing mixing includes the following: Different types of foam concentrates (e.g., AFFF and fluoroprotein based) should not be mixed. Different brands of the same type of concentrate should not be mixed unless data are provided by the manufacturer to, and accepted by, the authority having jurisdiction (e.g., FAA, Transport Canada) to prove that they are compatible under NFPA 11. Copyright National Academy of Sciences. All rights reserved. US00004621 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 37 In the United States, MIL-F-24385F qualified product should not be mixed with other foam concentrates that are not qualified. In Canada, foam concentrates of different types or from different manufacturers should not be mixed except where it has been established that they are completely interchangeable and compatible (CAR Standard 323, Section 323.08). 4.3.3 Best Management Practices Table 4-3 identifies the best management practices associated with the storage of AFFF. Proper storage following these practices can reduce the likelihood of accidental releases, spills, or concentrate contamination and prolongs the shelf life of the AFFF. Table 4-3. Best management practices associated with the storage of AFFF at airports. Storage Containers Store in specific types of containers: Original shipping container 55-gallon drums/plastic barrels Above-ground storage tanks (double walled) Read and follow the storage procedures outlined in SDSs and TDSs for the product Use containers with recommended materials: Double-walled stainless steel (Type 304L or 316) High-density cross-linked polyethylene (XLPE) Reinforced fiberglass polyester with a vinyl ester resin Label storage containers and storage tanks to identify the type of foam concentrate and concentration. To allow for product integrity and shelf life to be maintained and to minimize the risk for leaks and spills. To meet product manufacturers' recommendations for storage. Recommended composition of storage containers are inert, so the product will not change nor will the concentrate be contaminated. To prevent mixing of foams of different brands and/or concentration and prevent inappropriate use or disposal. Storage Conditions Store under storage conditions as described in a manufacturer's product information sheet: Sealed Secured Temperature (ranges) Mixing (do not mix foam concentrates or brands) Store in a storage facility/environment that is In an area designated for the storage of these chemicals Roofed/sheltered Rack system in place when totes are used Make use of other bunded storage methods: Secondary containment (e.g., drums sit on top of a tote) Store on level ground with a hard surface (e.g., concrete, asphalt) Follow the recommended reserve quantities to be stored Reserves To meet product manufacturers' recommendations for storage, to allow for product integrity and shelf life to be maintained, and to alleviate the risk for leaks and spills. The designated storage area provides an area where foam concentrates are stored away from incompatible materials (as outlined in a product's SDS). A designated area should also allow the recommended storage conditions to exist and for storage to be away from any potential hazards (e.g., electrical). Roofed/sheltered areas are to avoid weather damage (rain, snow) that could compromise the integrity of the product. In the event of a leak or spill the product would be contained until remedial action can take place. In the event of leak or spill, to reduce the risk of the product permeating the ground surface. The FAA requires that an on-airport reserve of firefighting foam have the capacity sufficient to fill all vehicles with at least twice their assigned capacity. Transport Canada requires that the amount of foam concentrate held in reserve should allow for four complete discharges with the required quantity of water. Copyright National Academy of Sciences. All rights reserved. US00004622 Use and Potential Impacts of AFFF Containing PFASs at Airports 38 Use and Potential Impacts of AFFF Containing PFASs at Airports 4 .4 Application AFFF is applied as an extinguishing agent for Class B fires (i.e., fires of flammable and com bustible liquids such as crude oil, gasoline, and fuel oils). The application of AFFF serves to Coat a pool of flammable or combustible liquid, acting as a barrier to prevent oxygen from fueling the fire. Form an aqueous film of the water/concentrate after the foam has dissipated on the fire surface that suppresses fuel vapor and seals the fuel surface. Provide additional fire suppression through the water in the foam providing a cooling effect. The following sections describe applications where AFFF is used, handled, or tested; the current state of the practice with regard to AFFF application at airports; and best management practices associated with AFFF application. 4.4.1 Firefighting Foam Application in Airport Operations AFFF is used in airport operations for the primary purposes of preventing, extinguishing, and controlling fires involving flammable liquids. The application of AFFF occurs during aircraft rescue situations, training, testing, and/or as a result of a discharge from deluge systems in aircraft hangars. In addition, for the purposes of this report, application also refers to handling of AFFF concentrate, including the periodic removal and replacement ofAFFF concentrate from vehicles during maintenance. Please note that this report does not address how AFFF should be deployed to prevent, extinguish, or control a fire. Guidance on how to deploy AFFF for these purposes should be sought from airport emergency response personnel. 4.4.1.1 Aircraft Rescue Aircraft rescue is the firefighting action taken to prevent, control, or extinguish fire involving, or adjacent to, an aircraft (FAA 2004). Federal law in both the United States (14 CFR 139) and Canada (CAR Subpart 3 --Aircraft Rescue and Fire Fighting at Airports and Aerodromes) requires that all airports operating regularly scheduled commercial flights have firefighting capabilities appropriate for the aircraft serviced. In the United States, 14 CFR Part 139 establishes the minimum firefighting capability to respond to aircraft rescue situations. The different types, quantities, and flow rates of AFFF are described for ARFF Category A to E airports. The FAA requires airports to meet 14 CFR Part 139, but encourages them to provide greater ARFF capability, consistent with NFPA Standard 403: Aircraft Rescue and Fire-Fighting Services at Airports. In Canada, the CARs (Section 303.05) define critical categories for firefighting based on aircraft length and maximum fuselage width and the number of passenger and aircraft movements. The critical category determines the minimum aircraft firefighting service that must be provided by operators of designated airports or participating airports. Specific quantities ofwater, extinguish ing agents, and the minimum number of ARFF vehicles necessary to provide a discharge capacity of foam related to the category of firefighting are provided in Section 303.09 of the regulations. Further, as per Standard 323.08, the quantity of foam concentrate on board ARFF vehicles should be sufficient to produce foam for at least two full loads of the required quantity of water specified in Section 303.09 of the CARs. 4.4.1.2 Training AFFF is most commonly used for training purposes at airports, specifically during live-fire drill training. In the United States, the FAA requires that following initial ARFF training, all Copyright National Academy of Sciences. All rights reserved. US00004623 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 39 airport firefighting personnel who are involved in firefighting complete at least one live-fire firefighting drill every 12 consecutive calendar months. As per Advisory Circular 150/5210-17C, live-fire drills involve a pit fire with an aircraft mock-up using enough fuel to simulate the type of conditions that could be encountered during a rescue situation at that airport. If training of air port firefighting personnel who are involved in firefighting does not occur within the 12-month period, an airport will be considered out of compliance with 14 CFR 139. While not required by 14 CFR 139, FAA recommends that airports also follow NFPA 1003: Standards for Professional Qualifications for Airport Fire Fighters. The FAA's Advisory Circular 150/5220-17B: Aircraft Rescue and Fire Fighting Training Facil ity provides guidance for airports on the design, construction, and operation of ARFF training facilities. Some facilities are located on airport properties due to convenience for training. Transport Canada requires live-fire drill training to be provided to all aircraft firefighting personnel every 12 months. The required training involves a live-fire drill to simulate a realistic firefighting situation that could be encountered on a typical aircraft at an airport. During these drills, fire-extinguishing equipment that will be used in the event of an accident includes the use of firefighting foams. Where training is conducted, if at all, varies by airport. Many airports have designated fire fighting training areas. If training is not conducted in a designated training area or the desig nated training area is not an engineered system designed to contain discharged AFFF and fuel, AFFF discharge may result in PFASs being released into the environment. 4.4.13 Testing AFFF has the potential to be released to the environment during testing of an AFFF mixture and equipment. In the United States and Canada, testing of firefighting foam equipment on ARFF vehicles is done in accordance to NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment. Transport Canada, per Standard 322.08, requires the NFPA tests to determine that the correct discharge rate is being delivered and the required foam physi cal characteristics are being met. In addition to performance testing done by manufacturers on foam concentrates, NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment states that ARFF vehicles should be tested on a schedule set out by the authority having jurisdiction (e.g., FAA, Transport Canada) in the following criteria areas: expansion ratio, drainage 25 percent, and proportioning and distribution pattern. Tests for these criteria involve allowing a foam solution to discharge from a hoseline or turret. Methods for testing these criteria include the following: Expansion ratio, drainage 25 percent, and proportioning: - Selecting foam samples representative of the foam produced by the nozzle as it would be applied to a fire. - Collecting foam samples through a foam sampling apparatus or foam collector, where a foam nozzle is aimed into a collector so that discharge is collected in a 1,000 mL graduated cylinder. - Observing the level of accumulation at timed intervals and the total weight of the foam sample and performing calculations to analyze the results. Distribution pattern: - Ground sweep nozzle and hand line nozzle tests: Discharging from ground sweep nozzles and hand line foam nozzles onto a paved surface for a period of 30 seconds. Copyright National Academy of Sciences. All rights reserved. US00004624 Use and Potential Impacts of AFFF Containing PFASs at Airports 40 Use and Potential Impacts of AFFF Containing PFASs at Airports Plotting the outline of the effective foam pattern. Establishing, measuring, and recording straight stream and fully dispersed nozzle settings. - Turret ground pattern tests: Preparing a foam solution with the type of foam concentrate to be used during actual emergencies with the proportioner set for normal firefighting operations. Performing discharge tests to establish foam patterns produced and the maximum range attainable by a turret nozzle for a period of 30 seconds. Recording and analyzing results. Further details on performance criteria, test methods, and calculations are available in NFPA412. 4.4.1.4 Handling Handling of AFFF may occur during an emergency response incident, training, testing, or vehicle maintenance. Procedures for safe handling apply not just to firefighting personnel. Due to the potential for spills and leaks, airport personnel responsible for handling AFFF need to exercise caution and practice safe handling procedures. Procedures for safe handling of foam concentrates are included in the manufacturer's product SDSs. Examples of these procedures from a manufacturer's SDSs include the following: Limit all unnecessary personal contact. Wear protective clothing when risk of exposure occurs. Handle in a well-ventilated area. Avoid contact with incompatible materials. Wash hands with soap and water after handling. 4.4.1.5 Aircraft Hangars Fixed fire protection systems use AFFF to extinguish Class B fires that could occur in facilities that house aircraft. Most fire protection systems for aircraft hangars are designed in accordance with NFPA 409: Standard on Aircraft Hangars. In the United States, requirements for adherence to NFPA 409, or specific sections of NFPA 409 as it relates to aircraft hangars, are contained in the International Building Code. In Canada, local building code requirements are followed and often reference NFPA 409. There are no specific requirements by the FAA or Transport Canada related to fire suppression and the use of firefighting foams in aircraft hangars. NFPA 409 considers four aircraft hangar groups classified on the basis of aircraft access door height, single fire area, and, in some cases, the aircraft that they store. The aircraft hangar classification determines the appropriate fire protection systems. Aircraft hangars housing larger aircraft (Group I and II) have several options for protection systems, including a fixed foam-water deluge system, whereas Group III hangars do not usually require any fixed protection system, and Group IV hangars can use an automatic water sprinkler (meeting specific criteria), or high- or low-foam expansion systems. The following application rates are required for fixed foam systems in hangars: Group I: 0.20 gpm per sq ft for AFFF Group II and IV: 0.10 gpm per sq ft for AFFF Firefighting foam can be intentionally released from an aircraft hangar fire protection system in the event of a fire, or it can be released due to human error, mechanical malfunction, or electrical malfunction. A release may also occur during periodic testing of a deluge system. Trench drainage systems should be designed in a hangar system to collect and contain fuel to prevent fire hazards, but can also assist with the containment of AFFF and other discharge for Copyright National Academy of Sciences. All rights reserved. US00004625 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 41 subsequent treatment. Per NFPA 409, trench drainage systems, in addition to sufficient floor pitch to allow liquids to flow into drain inlets and be collected, are to be a part of the aircraft hangar design. Curbs, ramps, drains, or appropriate sloping of the floor at all openings of the hangar are also suggested to prevent any releases of liquids. Trench drainage systems are meant to have oil separators and a bypass around each separator to allow for emergency direct disposal of water and flammable liquid when the foam-water systems are in use in the event of a fire. The flammable liquids are then meant to be discharged to a tank, cistern, or sump away from any potential exposure. 4.4.2 State of the Practice While these events may be infrequent, close to three-quarters of the responding North American airports surveyed have used AFFF for actual firefighting purposes. The extent to which AFFF has been used for these purposes varies by airport size, with the largest airports having the highest frequency of use and the smallest airports having the lowest. The more common use ofAFFF at airports was found to be training and testing. Most airports have held firefighting training on their premises at some point in time, and the majority used AFFF in the training exercises. Of the 167 North American airports that completed the survey, 97.6 percent indicated that they conduct foam tests of both the AFFF mixture and equip ment. The majority of respondents indicated that these tests are conducted every 6 to 12 months (54.6 percent); the second largest group of respondents indicated that they conduct their tests every 4 to 6 months (33.1 percent). The survey also suggested that the testing frequency increased with increasing airport size. When handling AFFF, staff and trainees wear various types of protective equipment. Almost all respondents outfit those handling AFFF with work gloves and eye protection; strong majorities provide safety boots, turnout gear, and fire-retardant clothing. Substantially fewer respondents reported use of nitrile or other one-time-use gloves. The survey also indicated that equipment testing of deluge systems in airport hangars occurred infrequently, with only 7 percent of responding airports indicating that such test ing is conducted. 4.4.3 Best Management Practices Table 4-4 identifies the best management practices associated with the application of AFFF at airports. *__ sposal Given the potential environmental implications associated with PFASs (as documented in Chapters 2 and 5 of this report), proper disposal of AFFF and/or AFFF concentrate is required. The unique properties of PFASs, however, present challenges in disposing of AFFF in an envi ronmentally responsible manner. Moreover, traditional disposal methods suitable for other waste streams may not be effective. Regardless of waste stream or application scenario, AFFF and/or AFFF concentrate should not be directly discharged or deposited to the environment. The only exception is when AFFF is being used in an emergency response. The following sections discuss various disposal consider ations, the state of the practice as determined from the industry survey conducted as part of this research, and best management practices. Copyright National Academy of Sciences. All rights reserved. US00004626 Use and Potential Impacts of AFFF Containing PFASs at Airports 42 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-4. Best management practices for the application of AFFF at airports. Handling Aircraft Rescue Training Follow industry-recommended practices: NFPA 402: Guide for Aircraft Rescue and Fire-Fighting Operations Have a safety spill plan in place when transferring containers/testing equipment and systems Provide personnel training: Staff is educated in safety and environmental concerns Staff is trained in standardized procedures designed for safety and environmental concerns Have two or more people available to move containers with AFFF Require personnel to wear PPE: Includes but not limited to work gloves, eye protection, safety boots, and protection from contact with skin Read and follow the handling procedures outlined in SDS and TDS for the product (e.g., work in a ventilated area/ avoid inhalation). Never use galvanized pipe and fittings in contact with undiluted concentrate. When applicable, limit the distance travelled between storage areas and filling areas. Follow industry-recommended practices NFPA 402: Guide for Aircraft Rescue and Fire-Fighting Operations. Provide personnel training: Staff is educated in safety and environmental concerns. ARFF personnel possess a sound knowledge of fire behavior, as per NFPA 403 Section E.4.3 (2014). Staff is trained in standardized procedures designed for safety and environmental concerns. Hazardous waste/spill response team nearby to carry out clean-up activities after the emergency has been mitigated. Require personnel to wear appropriate PPE: Including but not limited to: nitrile or latex gloves, eye protection, safety boots, and protection from contact with skin. Implement training that follows industry-recommended practices FAA Advisory Circular No. 150/5210-17C. NFPA 1003: Standard for Airport Fire Fighter Professional Qualifications. Staff is educated in safety and environmental concerns. Staff is trained in standardized procedures designed for safety and environmental concerns. So that industry-recommended operational procedures are followed to provide the basis for airport representatives to respond to an aircraft emergency in the minimum possible time and employ rescue and firefighting techniques effectively. To promote awareness of the potential impacts to human health and the environment if the product is mishandled and to provide an understanding of mitigation measures. To minimize any potential health hazards during the handling of the foam concentrate. To meet product manufacturer's recommendation that may be specific to the product. A galvanized pipe and fittings would be at risk of corrosion upon contact with foam concentrate. Limiting the transportation of foam concentrate when not stored in fixed tanks minimizes the potential risk of leaks and spills during handling and transport. Fire control is often an essential condition to provide protection for the occupants in an aircraft rescue event. Following industry-recommended operational procedures provides the basis for airport representatives to respond to an aircraft emergency in the minimum possible time and employ rescue and firefighting techniques effectively. Responding to an emergency response incident safely should be the first priority; however, having environmental response teams ready and mobilized following the emergency can contribute to reducing the potential environmental impacts by containing and establishing a perimeter to help control the extent of environmental impacts. To minimize any potential health hazards during response activities. To promote awareness of the potential impacts to human health and the environment when the product is released during training exercises and an understanding of mitigation measures. Copyright National Academy of Sciences. All rights reserved. US00004627 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-4. (Continued). AFFF Management Within Airport Operations 43 Equipment and System Testing Follow a defined training schedule as defined by the authority having jurisdiction. Use a regional training facility or host live-fire training for multiple airports at one location. Require personnel to wear appropriate PPE: Including but not limited to: nitrile or latex gloves, eye protection, safety boots, and protection from contact with skin. Prepare for training exercises: Safety spill plan in place when transferring containers/ testing equipment and systems. Training locations: Conduct training in an area where AFFF water/foam solution can be contained and collected for treatment (e.g., bermed). Configure training area with a sump to allow collection and disposal of material used during training. Do not discharge to ground. Consider constructing a lined fire training pit. Locate training exercises away from storm drain inlets, drainage facilities, or water bodies. Make use of alternative foam products for training exercises. Optimizing firefighting program (e.g., equipment, training, procedures) Follow industry-recommended best practices: NFPA 412: Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment Discharge the minimum required to test the system/equipment: Use the same collected samples for multiple tests, where applicable. Collect discharge for storage and disposal. Put a safety spill plan in place. Maintain equipment in good condition to reduce spillage (e.g., ensure fittings are tight). Conduct ground pattern tests first with water, then with the foam solution. In the United States, each Part 139 Certificate holder must ensure all ARFF personnel participate in at least one live-fire drill every 12 consecutive calendar months. Transport Canada requires live-fire drill training to be provided to all aircraft firefighting personnel every 12 months. To reduce the potential environmental impact for individual airports and lower the frequency of firefighting foam use for training activities. To minimize any potential health hazards during the handling of the foam concentrate. In the event of a leak or spill as a result of preparing for training exercises, a plan is in place for rapid response and containment. To prevent migration of the discharged firefighting foam to locations where it cannot be collected and properly disposed of. Other international jurisdictions (e.g., Norway, Australia) make use of training foams that do not contain fluorine but have similar foaming properties for certain training exercises (e.g., equipment and/or live-fire testing). These fluorine-free foams are considered to present the lowest environmental impact. Differences in foam concentrate characteristics can be adjusted for by changing firefighting procedures To limit the amount of foam solution discharged during testing. NFPA 412 states that the portions of drained solutions used in drainage tests can be used for the "foam solution sample" for other tests. To minimize unnecessary discharge of foam solution by using water in advance of testing when adjustments are being made on equipment and systems. (continued on next page) Copyright National Academy of Sciences. All rights reserved. US00004628 Use and Potential Impacts of AFFF Containing PFASs at Airports 44 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-4. (Continued). Aircraft Flangers Construct the aircraft hangar following local building code: NFPA409: Standard on Aircraft Flangars. Design deluge (foam) testing systems with the following characteristics: Away from storm drain inlets, drainage facilities, or water bodies. Discharge AFFF waste to a sanitary sewer (industrial wastewater permitting may be required). AFFF waste should not be discharged to storm drains or water bodies. Paved with concrete or asphalt or stabilized with aggregate base. Bermed to contain AFFF and to prevent run-on. Configure discharge area with a sump to allow collection and disposal of AFFF. Discharge the minimum required to test the system/equipment. Flave a safety spill plan in place Flave 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 exposed to possible damage during discharge tests. Sandbags or similar means. Local building codes often reference NFPA 409, which contains the minimum requirements for proper construction of aircraft hangars and for fire protection at aircraft hangars. To mitigate the potential effects of AFFF discharge in the event of a testing exercise or an incident in an aircraft hangar. To limit the amount of foam solution discharged during testing. In the unlikely event that a pipe burst, above-ground piping would provide for more rapid leak detection and spill response. To prevent migration of the discharged firefighting foam to other locations in the aircraft hangar and to protect the mechanical and electrical equipment. 4.5.1 Disposal The means by which an airport disposes of AFFF or AFFF concentrate can vary based on the nature of activity resulting in waste for disposal, the nature of the material being disposed (e.g., aspirated residual AFFF, AFFF concentrate, and wastewater containing AFFF or PFASs as a result of vehicle or equipment system maintenance), an airport's waste management facilities and associated capacity, and applicable regulations. Given the stringent and evolving regulatory standards surrounding PFASs, please note that proper disposal is not to be predicated on the volume of material to be disposed (i.e., even very small quantities of material discharged into the environment could have significant human health and environmental impacts and result in significant costs to address). 4.5.1.1 Discharge Disposal Discharged AFFF will likely result in residual foam. Uncontrolled releases pf AFFF to land and surface water can occur in the event of an accidental discharge or a fire emergency; where possible, residual foam (or, if washed down, residual AFFF wastewater) should be contained so that the amount directly released to the environment is minimized. Generally, in accordance with the manufacturer's SDSs, residual AFFF/AFFF wastewater drains to existing infrastructure on the airport property and then is directed to a wastewater treatment facility (i.e., either on-site or via a municipal sewer infrastructure). Such facilities, however, vary widely in their ability to address the impacts of PFASs effectively, if at all (i.e., many studies have shown no removal of PFASs via wastewater treatment), depending on the treatment train. Prior Copyright National Academy of Sciences. All rights reserved. US00004629 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Management Within Airport Operations 45 to disposal (to the extent practicable, recognizing that weather conditions may drive runoff), airports should check with the local wastewater facility to confirm its ability to treat wastewater containing PFASs. At some airports, residual AFFF/AFFF wastewater is directed to stormwater drains that may not be directed to a treatment facility. In addition, airports need to coordinate with federal, state/province, and local authorities and other waste service managers to understand the applicable requirements and available disposal options. In the event that hydrocarbon fuels are mixed with the foam solution, a fuel-water separator can be used to allow for the AFFF/AFFF wastewater solution to be disposed of separately from the fuel. Prior to discharge, waste should be evaluated to determine whether flammable materials are still present at hazardous concentrations and to review the applicability of sewer restrictions (73). 4.5.1.2 Removal from Equipment or Systems Testing and/or maintenance may require the removal of AFFF concentrate from ARFF vehicles, equipment, and systems. Removal of AFFF from vehicles, equipment, or systems may also be required in the event that an airport switches to a different type of foam concentrate. Flushing during removal or testing generates wastewater that contains AFFF. 4.5.1.3 Disposal of AFFF Stockpiles AFFF has a long shelflife. This means that legacy AFFF containing PFOS or long-chain fluoro carbon surfactants still exists in U.S. and Canadian inventories. The manufacture and import of new PFOS-based products is banned in the United States; however, existing stocks may still be used ifthey were manufactured or imported into the United States prior to the rules taking effect in 2002 (74). While there is no explicit regulation barring the discharge of wastewater containing AFFF, in the United States it can be regulated under the Clean Water Act that regulates pollutant discharges into water. In Canada, the Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations indicated that PFOS-containing AFFF should not be used or otherwise released to the environment as PFOS has been identified as posing a risk to the environment. Consequently, PFOS-containing AFFF should be disposed of at an authorized waste management facility. Prior to the proper disposal of AFFF, provincial/territorial authorities should be contacted. 4.5.2 State of the Practice Two-thirds of the responding North American airports indicated that AFFF discharged dur ing testing is disposed of onto the ground. The remaining third of respondents discharge AFFF into an engineered containment system. For the one-third of respondents who used engineered containment systems, the type of system most widely used was a small or non-permanent vessel, and the next most widely used system was testing in a designated area such as a containment basin or training pit. Survey results regarding AFFF discharge during training activities were similar, with the majority of respondents (80 percent) indicating that AFFF was discharged directly onto the ground during training exercises. The remaining 20 percent responded that AFFF was discharged during training exercises into engineered containment systems. According to the survey, most respondents remove AFFF concentrate from firefighting equip ment or systems for maintenance by draining or pumping AFFF into containers (e.g., a training pit, a holding tank, drums, barrels, and totes) for temporary storage of AFFF and then reuse it. 4.5.3 Best Management Practices Table 4-5 identifies the best management practices associated with the disposal ofAFFF stock piles or following use at airports. Copyright National Academy of Sciences. All rights reserved. US00004630 Use and Potential Impacts of AFFF Containing PFASs at Airports 46 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4-5. Best management practices for disposal of AFFF at airports. Discharge Disposal Removal from Equipment or Systems Disposal of AFFF Stockpiles Dispose of foam-water solutions: Wastewater treatment, appropriate pretreatment steps taken. Dispose of foam-hydrocarbon solutions: Use fuel-water separator. Dispose of foam-soil mixtures. Record all disposal. Removal to containment vessel: Transfer by pump to containment vessel. Containment vessel should have secondary containment (e.g., underlying tote) during removal process. Practice proper handling protocol: Flush/clean out equipment thoroughly, retaining rinse water. Staff handling AFFF transfer should wear appropriate PPE. Dispose of removed foam concentrate at an authorized location. Comply with legislation, regulation, and/or guidance in the United States. Comply with legislation, regulation, and/or guidance in Canada. Industry guidance in the United States recommendations for disposal of PFOS-based AFFF concentrate is by incineration at a facility capable of handling the waste. Authorized disposal facilities can only dispose of waste for which they have been issued a certificate of approval or which meet their operating permits and are regulated by Province/Territory in Canada. Recording what has been disposed of, in what volumes, and where provides a record of an airport's disposal. In the event of a leak or spill, the product would be contained until remedial action can take place. To minimize any potential health hazards during the handling of the foam concentrate. The ability to dispose of unused foam concentrate may differ by jurisdiction. Disposal should occur at an authorized location that handles hazardous waste. Industry guidance in the United States recommendations for disposal of PFOS-based AFFF concentrate is by incineration at a facility capable of handling the waste. Authorized disposal facilities can only dispose of waste for which they have been issued a certificate of approval or which meet their operating permits and are regulated by Province/Territory in Canada. Copyright National Academy of Sciences. All rights reserved. US00004631 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts C iHi Aa Pn tI tr Kn rj ' erview As indicated in Chapter 2 of this report, AFFF has been used for decades at airports in the United States and Canada to extinguish fires. PFASs, principal active ingredients in AFFF, are considered an emerging contaminant in the environmental industry. Some PFASs are ubiq uitous in the environment and exhibit properties that could pose a potential human health or ecological risk to sensitive receptors at low concentrations. Historical use, training, testing, maintenance, and disposal practices may have resulted in a release of PFASs into the envi ronment. This chapter discusses how to address environmental impacts associated with past releases or applications of AFFF into the environment. Specifically, this chapter describes the following: Best practices for sampling environmental media for PFASs so that representative samples are obtained. Key information for evaluating whether there is a potential unacceptable human health or ecological risk involves identifying whether PFASs are present in environmental media (i.e., soil, sediment, groundwater, and surface water) and at what concentration. Current, commercially available laboratory analytical methods for PFASs that are necessary to achieve analytical detection limits appropriate for comparing concentrations to stringent regulatory criteria. Analytical approaches under development and not yet commercially available in the United States or Canada are also identified. Risk management considerations specific to the impacts of PFASs, including key factors in developing the conceptual site model (CSM) and strategies to manage potentially unacceptable risks. State-of-the-practice remediation technologies and approaches that have demonstrated some success (or are generally believed to hold promise) in field-scale remediation of PFASs in soil and groundwater. Emerging technologies and approaches under review and development are also identified. 5.2 Sam pling o f PFASs 5.2.1 General Challenges w ith Sam pling of PFASs Traditional, standardized environmental sampling protocols provide effective means to collect representative samples from various environmental media for most contaminants. However, as described in Chapter 2, the chemical and physical properties of some PFASs offer unique challenges in obtaining concentrations of PFASs representative of field conditions. For example, the fact that compounds containing PFASs stratify in water as they migrate to the air-water inter face means that groundwater samples need to be taken from the surface of the water table and laboratory analytical methods must involve vigorous shaking of water samples before a subsample Copyright National Academy of Sciences. All rights reserved. 47 US00004632 Use and Potential Impacts of AFFF Containing PFASs at Airports 48 Use and Potential Impacts of AFFF Containing PFASs at Airports is removed and injected into laboratory instrumentation. PFASs are also likely to "stick" to suspended particles in water or to a filter if samples are filtered to retain the "dissolved" fraction of the water sample. In addition, the ubiquity of PFASs in the environment from sources such as clothing (e.g., Gore-TexTM) or sampling equipment (e.g., PTFE or TeflonTM) could contaminate samples, resulting in measured concentrations that are greater than the actual concentrations in the environmental media being evaluated. In order to obtain representative samples, specific sample collection protocols are recommended when a site is to be investigated for PFASs. These protocols include avoiding the use of glass or metals, as some PFASs bind to these materials. Contact with materials that may contain PFASs such as PTFE (i.e., TeflonTM) should also be avoided, and samples should be collected using polyethylene or polypropylene containers and equipment. Additional guidance on conducting sampling programs for PFASs can be found in the following: 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). Transport Canada's Perfluorochemical Sampling and Analysis Guidance. United Nations Environment Programme (UNEP) Chemicals Branch's PFAS Analysis in Water for the Global Monitoring Plan of the Stockholm Convention: Set-Up and Guidelines for Monitoring. The following sections discuss best practices for sampling soil, sediment, groundwater, and surface water for PFASs and reducing the likelihood for cross-contamination. Also discussed are quality assurance and quality control considerations and innovative approaches to sampling for PFASs. 5.2.2 PFASs--Sam pling Challenges and M itigation 5.2.2.1 Cross-Contamination Cross-contamination occurs when samples collected in the field are impacted by chemicals from sources other than the media being sampled. Cross-contamination can result in a detectable concentration where no PFASs are present or a concentration that is biased high relative to what is present in the environment. The potential for cross-contamination is significant given the ubiquity and environmental persistence of some PFASs and the very low detection limits and regulatory criteria associated with many PFASs. General practices recommended to eliminate the likelihood of cross-contamination regardless of media are presented below. Sampling Equipment and Sample Containers The use of glass or metals should be avoided because compounds containing PFASs bind to these materials. Samples should be collected using polyethylene or polypropylene containers and equipment. Contact with materials that may contain PFASs such as PTFE should also be avoided (e.g., TeflonTM tubing, TeflonTM bailers, and sticky labels and adhesive tape used during sample collection and storage). Use of aluminum foil should also be avoided, as some PFAAs could be transferred from the aluminum foil to the sample. Drilling Water/Hydroexcavation Potential sources of PFASs (other than what is in the environmental media being investigated) should be considered and removed during sampling field programs to avoid cross-contamination. For example, if water is necessary to obtain a soil sample (e.g., drilling or hydroexcavation), it is important to confirm that the water does not contain PFASs that could impact the samples or, worse, impact the study area. Copyright National Academy of Sciences. All rights reserved. US00004633 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 49 Field Equipment Decontamination Field equipment that is used at multiple sampling locations (e.g., flow-through cells, held meters, and interface probes) requires proper decontamination between uses at different sampling loca tions. Decontamination should be conducted with rinsate that is free of PFASs (i.e., water that is free of PFASs) and detergents. Water that is free of PFASs can be obtained from a laboratory. Where impacts of PFASs are known to be present, held decontamination of each piece of held equipment should be conducted prior to use, at least twice between sampling locations, and before leaving the site. Personal Protective Equipment and Field Clothing Personal protective equipment and held clothing commonly worn during held investigations may represent potential sources of PFASs that could cross-contaminate samples collected in the held. The following practices are recommended: Field clothing to be worn on-site should be restricted to clothing made of natural hbers (e.g., cotton). Synthetic hbers and/or clothing that is water resistant, waterproof, or staintreated should not be worn during the held program. Field personnel should avoid documenting held notes on waterproof held books/paper as the coated paper may contain PFASs. Acceptable held documentation alternatives include held tablets, other electronic data entry interfaces, or uncoated paper. Most safety footwear is made from leather and synthetic hbers that have been treated to provide some degree ofwaterproohng/increased durability and may represent a trace source of some PFASs. For the health and safety of held personnel, the protection afforded by the footwear must be maintained. Field staff should avoid directly contacting samples after touching their footwear (e.g., tying shoelaces). Field personnel should frequently replace gloves (using disposable single-use gloves and having multiple changes per location) to mitigate the potential for cross-contamination. At a minimum, sampling gloves should be replaced after contact with equipment and prior to contact with sample bottles or containers of water that are free of PFASs. Gloves should be nitrile or latex; regular canvas or leather work gloves should not be used for sample collection or for personal protection when handling AFFF or media impacted by PFASs. Food Packaging For health and safety reasons, food and beverages should not be consumed during held activities except during a designated break in a designated clean area. However, due to the historical use of some PFASs in food packaging, held personnel must be particularly careful when sampling for PFASs. The following practices are recommended for held personnel (and visitors to the area): Do not bring food on-site in any paper packaging (i.e., do not bring any fast food to the site that uses any form of paper wrapping like sandwiches with paper wrap or coffee in paper cups). Avoid products such as aluminum foil, coated papers, and coated textiles. Wash hands after eating and prior to engaging in sample collection, and wear appropriate gloves (e.g., nitrile) for sample collection. Specific Best Practices for Sampling Aqueous Media In order to alleviate the potential for cross-contamination, the following practices, specihc to aqueous media sampling, are recommended: A well condition survey should be completed after groundwater purging and sampling has been completed to help mitigate the possibility of cross-contamination of groundwater samples. (Please note that this practice is atypical for groundwater sampling programs, which usually have static water levels, and which include monitoring well depths as one of the hrst steps.) Copyright National Academy of Sciences. All rights reserved. US00004634 Use and Potential Impacts of AFFF Containing PFASs at Airports 50 Use and Potential Impacts of AFFF Containing PFASs at Airports Aqueous samples should be collected directly into bottles prepared by a laboratory to be free of PFASs. High-density polyethylene (HDPE) tubing connected to a peristaltic pump (where feasible) with silicon tubing should be used for the groundwater sampling program. S.2.2.2 Suspended Particulate Matter in Aqueous Samples The adsorptive properties of some PFASs relative to held filtration and their ability to "stick" to particles in the water column can make quantifying PFASs in aqueous matrices challenging. To avoid suspended particulate matter and solids during groundwater sampling, procedures for compounds with PFASs in groundwater should follow the held procedures established for low-how purging and sampling, as described in the two documents listed below, with adaptations to address the sampling concerns specihc to PFASs (e.g., cross-contamination and no materials containing PTFE): Low Stress (low how) Purging and Sampling Procedure for the Collection of Groundwater Samples from Monitoring Wells, EQASOP-GW 001 US EPA (2010). ASTM D4448-01 (Reapproved 2013)--Standard Guide for Sampling Ground-Water Moni toring Wells. As with groundwater, surface water samples should be collected in accordance with standard methodologies, avoiding suspended and/or particulate matter in retrieved water samples. As men tioned earlier, the presence of particulate matter in water samples can contribute to measured concentrations that are greater than the actual environmental concentrations and, therefore, not representative of the media (i.e., water) sampled. Filtration is not recommended before laboratory extraction, as the hlter may absorb PFASs or may be a source of contamination. 5.2.23 Sampling Frequency AFFF formulations may contain precursors that transform or degrade into other, more stable and recalcitrant PFASs such as PFOS and PFOA. Changes in the concentrations of precursors and these more stable PFASs may occur over time. Consequently, in addition to assessing seasonal considerations, sampling more than once may help to better assess sites where PFASs are transforming and/or identify whether migration is occurring. 5.2.3 Quality Assurance and Quality Control A quality assurance/quality control (QA/QC) program appropriate for achieving the project's data quality objectives should be adopted for any type of environmental program. Typically, an appropriate QA/QC held sample collection program for held investigations involving PFASs includes (at a minimum) held duplicates and equipment blanks. Brief descriptions of each type of held QA/QC sample important to investigations involving PFASs (as recommended by U.S. EPA Method 537) follow: Field duplicate: a duplicate sample taken in the held from the same location as the original sample to ascertain sampling precision. The sample is given another name so it is not identihed with any held duplicate, to further test precision. Equipment blank: rinsate from the equipment used to take the sample. The purpose of the equipment blank is to assess the effectiveness of the implemented decontamination process and the potential of cross-contamination of samples due to insufficient decontamination of sampling equipment. Field reagent blank (FRB): An analyte-free water in a sample bottle that is provided by a laboratory. The FRB is shipped to the sampling site along with the sampling bottles. At the Copyright National Academy of Sciences. All rights reserved. US00004635 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 51 sampling site, the sampler opens the shipped FRB and pours the preserved reagent water into an empty shipped sample bottle, then seals it and labels it as the FRB. The FRB is shipped back to the laboratory along with the samples and is analyzed to ensure that PFASs were not introduced into the sample during sample collection/handling. Given the ubiquity of some PFASs, modifications to these standard QA/QC samples should use laboratory-supplied water and sample containers that are free from PFASs and suitable for sampling PFASs. 5.2.4 Innovative Approaches to Sam pling PFASs in Water Innovative sampling approaches are being developed by researchers to address or alleviate concerns associated with cross-contamination, biases, and extraction concerns associated with programs sampling PFASs in water and the lack of real-time characterization tools for PFASs. Two of these approaches, passive sampling and ion-selective electrodes (ISEs), are summarized below. Neither method has been standardized or adopted by the U.S. EPA. 5.2.4.1 Passive Sampling in Water Passive sampling is an efficient and cost-effective way of measuring contaminants in the environment over a measured period of time and with limited held time. Passive, or diffusive, sampling relies on the unassisted molecular diffusion of gaseous agents (analytes) through a diffusive surface onto an adsorbent. Passive sampling in water for PFOS has been implemented in environmental held assessments in Sweden by the Swedish Environmental Protection Agency. In-situ calibration with the use of reference compounds has not been observed to be successful (75); however, certain types of passive sampler (e.g., polar organic chemical integrative sampler or POCIS) may be a suitable tool for biomonitoring of PFASs (76). 5.2.4.2 Ion-Selective Electrodes An ISE is a transducer (or sensor) that converts the activity of a specihc ion dissolved in a solu tion into an electric potential. ISEs fabricated from huorous materials are used to measure PFOS in drinking and groundwater down to the part-per-trillion level with no sample preparation. Research to evaluate the applicability of this technology for measuring PFOS in soil is ongoing. This would be a rapid screening tool that could provide held results in real time (rather than waiting for laboratory analysis). A universal PFOS anion soil extraction methodology that is broadly applicable to different soil types has not been developed. Research to develop a method to categorize different soil types and develop suitable extraction methods for each soil sample type is ongoing (77). 5 .____lalfsis o f PFASs Analytical procedures are required to identify concentrations of PFASs that are representative of the environmental media being assessed and consistent with levels of potential concern. As research provides new information on human health and ecotoxicological impacts associated with PFASs and their fate and transformation in the environment, regulations and corre sponding analytical methodologies are targeting lower detection limits. Laboratory analytical methods are being developed as the working understanding of the chemicals themselves is growing (78). Commercially available analytical methodologies (e.g., the types of analyses that are undertaken by commercial analytical laboratories) are currently not capable of quantify ing the full suite of PFASs that exist in soil and groundwater; this is partially due to the lack of available reference standards. Stratification in water samples requires that samples are shaken Copyright National Academy of Sciences. All rights reserved. US00004636 Use and Potential Impacts of AFFF Containing PFASs at Airports 52 Use and Potential Impacts of AFFF Containing PFASs at Airports vigorously in the laboratory prior to analysis. Additionally, significant challenges arise due to the propensity of precursor PFASs to transform into daughter compounds in the environment (e.g., do the laboratory results adequately account for the full mass of PFASs and the associ ated potential risks, at the site?). Airport managers and operators should be aware of these limitations and identify laboratories that understand these challenges and have procedures in place to address them so that the analytical results are representative and reproducible. The following sections discuss Commercially available analytical methods used for analyses of PFASs. Key considerations associated with analyses of PFASs. Laboratory accreditation for analyses of PFASs. Promising analytical methods in development. 5.3.1 Com m ercially Available Analytical M ethodology The commercially available analytical method for PFASs in drinking water is 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), which analyzes a suite of 14 PFAAs (including PFOAand PFOS, shown in Table 5-1) following published Table 5-1. Common PFASs included in commercial laboratory analysis. N-ethyl perfluorooctane sulfonamido acetic acid N-Et-PFOSAAcOH 2991-50-6 YN N-methyl perfluorooctane sulfonamido N-Me- acetic acid PFOSA-AcOH 2355-31-9 YN Perfluorobutanoic acid PFBA/PFBTA 375-22-4 NN Perfluoropentanoic acid PFPeA 2706-90-3 NN Perfluorohexanoic acid PFHxA 307-24-4 YN Perfluoroheptanoic acid PFHpA 375-85-9 YY Perfluorooctanoic acid PFOA 335-67-1 YY Perfluorononanoic acid PFNA 375-95-1 YY Perfluorodecanoic acid PFDA 335-76-2 YN Perfluoroundecanoic acid PFUnA 2058-94-8 YN Perfluorododecanoic acid PFDoA 307-55-1 YN Perfluorotetradecanoic acid PFTA 376-06-7 YN Perfluorotridecanoic acid PFTrDA 72629-94-8 Y N Perfluorobutane sulfonic acid PFBS 375-73-5 YY Perfluorohexane sulfonic acid PFHxS 355-46-4 YY Perfluorooctane sulfonamide PFOSA 754-91-6 NN Perfluorooctane sulfonic acid PFOS 1763-23-1 YY Copyright National Academy of Sciences. All rights reserved. US00004637 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 53 methodology. Reporting limits for this methodology range from 0.005 to 0.020 pg/L, i.e., below U.S. EPA's health advisory of 0.07 pg/L for PFOS and PFOA. A drawback to U.S. EPA Method 537 is that it includes a limited range of analytes; this method does not currently report the results for the full range of short-chain PFAAs, many fluorotelomers, or the many other precursor PFASs. Additionally, U.S. EPA Method 537 was developed for the analysis of PFASs in drinking water, which is a relatively clean matrix compared to groundwater and one which will have different extraction requirements than solid matrices (e.g., soil and sediment). In order to fully under stand the potential extent of contamination by PFASs in the environment, additional laboratory techniques are being developed to increase the range of analytes for U.S. EPA Method 537 (and similar LC-MS/MS methods) to include up to 39 PFASs (i.e., Modified U.S. EPA Method 537). U.S. EPA Method 537 outlines areas where deviation from the prescribed procedure is allow able and where the described methodology must be followed (e.g., sample collection and quality control requirements). U.S. EPA Method 537 also describes possible sources of interference and standards to be utilized. The International Organization for Standardization (ISO) has also developed a method to analyze PFASs based on the same basic principles as U.S. EPA Method 537. The ISO method developed for evaluating PFASs, specifically PFOS and PFOA in unfiltered samples, is ISO 25101:2009--Water Quality--Determination of Perfluorooctanesulfonate (PFOS) and Perfluorooctanoate (PFOA)--Method for Unhltered Samples Using Solid Phase Extraction and Liquid Chromatography/Mass Spectrometry. Similar to U.S. EPA Method 537, ISO 25101:2009 uses solid phase extraction and solvent elution with analyte determination by LC-MS/MS. The focus of this methodology is linear isomers of PFOS and PFOA, but other isomers (i.e., branch isomers) can be reported separately as non-linear isomers. Further limitations to the ISO method include the following: The ISO method may result in unrepresentative results as the materials used in the method may result in contamination of the sample being analyzed (e.g., seals, O-rings, and tubing), ultimately biasing the results high. Likewise results may indicate lower concentrations than what is in the sample due to sorption to glassware or filters (79). Solid phase extraction methods generate significant amounts of liquid and solid waste, are laborious, and are predisposed to negative and positive artifacts (1 ). A standardized method has not yet been developed for extracting and analyzing PFASs in soils and sediments. Four methods for the extraction of PFASs from sediments have been described in the scientific literature: A wrist-action shaker operated at maximum deflection, extraction by methanol, followed by a graphitized carbon adsorbent clean up (80). An acetic acid wash, followed by repeated extraction with methanol/1percent acetic acid in water (90:10, v/v) in a heated sonication bath and subsequent clean up using C18cartridges (81). Pressurized fluid extraction with acetone/methanol (25:75, v/v) at 100C followed by head space solid-phase microextraction (82). Sonication with acetonitrile/water (60:40, v/v) and ion pairing clean up (83). Different extract clean-up methods can be used, either separately or in combination, depending on the characteristics of the sediment, the extraction solvent, and the concentration level. Commercial laboratories typically homogenize soil or sediment samples in water that is free of PFASs, conduct a liquid/liquid extraction, and analyze the extraction by isotope dilution LC-MS/MS. Extraction of PFASs from soil and sediment requires the use of a solvent. The resulting extraction liquid (i.e., eluent) is then homogenized by centrifugation prior to LC-MS/MS analysis, as would be done for an aqueous sample. The lack of an available standardized methodology for Copyright National Academy of Sciences. All rights reserved. US00004638 Use and Potential Impacts of AFFF Containing PFASs at Airports 54 Use and Potential Impacts of AFFF Containing PFASs at Airports extracting and analyzing PFASs in soil reinforces the need to use a reliable, accredited analytical laboratory. The following sections describe key considerations in laboratory analysis for airports or site custodians when discussing an analytical program for PFASs with an analytical laboratory and what to look for in methodology and accreditation. 5.3.2 Key Considerations in Laboratory Analysis 5.3.2.1 Laboratory Standards Standard reference chemicals have not yet been developed for each of the PFASs in AFFF; therefore, identification, let alone quantitative analysis, is limited to the known and quantifiable PFASs in AFFF. Additionally, even with available reference standards, these results may vary according to the laboratory methods used. Some PFASs (such as PFOS) are observed in AFFF as a mixture of linear and branched isomers. Depending on the calibration method used by the analytical laboratory, there may be bias in instrumental responses between linear and branched PFOS isomers using LC-MS/MS analysis, which is discussed further below. It is important that a commercial laboratory is using suitable standard methodology to carry out analyses of PFASs. Where no suitable standard methodology exists (e.g., PFASs in soils/sediments), an accredited laboratory facility should be used (as discussed in Section 5.3.3). 53.2.2 Branched and Linear Isomers PFASs exist as both branched and linear isomers. Both versions, together, make up the total concentration of individual PFASs. This analytical concern has come to attention most recently for PFOS, but the problem exists for other PFASs, including PFOA. The analytical laboratory results should include data that addresses both "versions" so that the total concentration reported is representative. If the concentration of only one isomer is reported, the reported value may underrepresent actual concentrations in the field (and potential risk). Reference standards (other than mixed linear/branched standards) are available separately for linear PFOS and PFOA, but not for the branched isomers (84). This calibration is important to evaluating whether the total amount of PFOS reported is an accurate representation of a sample. If a laboratory is quantitating using linear standards, this may result in a systematic high bias for PFOS analysis on real samples containing any branched PFOS. This calibration concern is an issue that has been acknowledged by commercial laboratories competent in analysis of PFASs and underlies the need for selecting a reputable laboratory with the appropriate accreditations. Stable isotope dilution methods have been developed for analyzing PFASs and are an alternate to using standard calibration solutions that run into branched/linear isomer issues, as described above. Stable isotope dilution methods use relative ratios of natural to enriched isotopes to directly evaluate concentration of the target analyte, providing a more usable PFOS value. It is important to confirm that a commercial laboratory reports PFOS values that include both the branched and linear types. 5.3.23 Precursors Both past and current AFFF formulations contain "precursor compounds," or parent com pounds that can degrade to more persistent daughter products. Older formulations of AFFF contained long chains (e.g., C8or greater), which could break down to PFOA and PFOS. Newer formations contain short-chain PFASs (e.g., C6and below), which can still degrade to persistent daughter products (PFHxA and PFBA); however, these daughter products are thought to pose fewer ecotoxicological risks since the daughter products have lower potential for bio accumulation Copyright National Academy of Sciences. All rights reserved. US00004639 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 55 than the long-chain compounds. A site investigation for PFOS without an analysis for precursor PFASs may not result in a fully representative CSM or accurate understanding of the potential risk posed by PFASs at an airport. Analysis for precursor PFASs is imperative to have a comprehensive understanding of the impact of PFASs. If a site has levels of PFOS and PFOA below the levels recommended by guidelines in the region, it is possible that precursor compounds could degrade to resilient and regulated PFOS and PFOA and cause an exceedance of the level recommended by guidelines and a human health or environmental ecotoxicological risk. While many precursors are not regulated at this time, airports should be aware of the potential future liability associated with these compounds, i.e., they may become future sources of PFOS or PFOA and/or potentially other (currently) regulated compounds or become regulated themselves. There is no commercially available method for precursor analyses; however, new, commercialized, standardized methods are in development as a response to regulatory drivers and the need to effectively meet new regulations. 53.2.4 Quality Assurance and Quality Control QA/QC programs come from the methodology being used (e.g., prescribed by U.S. EPA Method 537) and from overall laboratory accreditation (discussed further in Section 5.3.3). The laboratory-provided QA/QC information should be carefully reviewed due to the many potential contamination sources. Laboratory-provided information to review can include method and/or matrix interferences notes, recovery of internal and surrogate analyte standards used, adequate calibration, and laboratory duplicate/blank values meeting internal criteria. Other data to evaluate include laboratory-blinded held duplicate sample results, equipment blank results, and held blank results. Values should comply with the pre-ordained QA/QC program that meets the data quality objectives of the held sampling program. QA/QC hags should be reviewed with the commercial laboratory prior to accepting or rejecting the results. 5.3.3 Laboratory Accreditation In addition to conducting sample analysis for PFASs using standardized methods (where available and applicable), laboratories should be accredited for analyses of PFASs by a reputable accreditation agency. Accreditation implies that a laboratory has established the technical com petence to perform specihc types of testing and analysis and that their equipment and methods will provide results that are reliable, reproducible, and representative of actual concentrations. Laboratory accreditation is for the testing and calibration for laboratories to "ISO/IEC 17025-- General requirements for the competence of testing and calibration laboratories," which is a generic standard applicable to many different analyses. Accreditation/recognition for specialty analyses such as PFOA/PFOA is distinct from laboratory accreditation. It is recommended that an accredited analytical laboratory be used and that the analytical laboratory be contacted prior to sample submission to confirm that PFASs are included in their standard analysis and to confirm the sampling requirements. Accreditation bodies, methodologies, and laboratories are described for the United States and Canada in the following subsections. 5.3.3.1 United States o f America In the United States, the following organizations provide accreditation for analyses of PFASs. Links are provided to their webpages, which list accredited laboratories and can be used to find an accredited laboratory across jurisdictions: U.S. Department of Defense Environmental Laboratory Accreditation Program (DoD ELAP) (http://www.denix.osd.mil/edqw/Accreditation/AccreditedLabs.cfm) Copyright National Academy of Sciences. All rights reserved. US00004640 Use and Potential Impacts of AFFF Containing PFASs at Airports 56 Use and Potential Impacts of AFFF Containing PFASs at Airports A m erican A sso ciatio n fo r L ab o rato ry A ccre d ita tio n (A2LA ) (h ttp s://w w w .a2 la.o rg /d irsearch new /new search.cfm ) P erry Jo h n so n L ab o rato ry A ccred itatio n , Inc. (PJLA ) (h ttp ://w w w .p jlab s.co m /search a c c re d ite d -la b s) A N SI-A SQ N a tio n a l A ccred itatio n B oard (A N A B) (h ttp ://se arch .an a b .o rg /se arch -ac cred ited com p an ies.asp x ) L ab o rato ry A ccred itatio n B u reau (L-A -B ) (h ttp ://se a rc h .l-a -b .c o m /) 5.33.2 Canada In C an ad a, m eth o d o lo g ie s to analyze PFA Ss are accred ited u n d e r C A N -P -1585: R e q u ire m en ts for the A ccred itatio n o f E n v iro n m en tal T esting L ab o rato ries, P ro g ram Specialty A rea-- E n v iro n m en tal T esting (PSA -E T )-- D ecem b er 2008. T he org an izatio n s listed below provide ac cred itatio n fo r analyses o f PFASs. L inks are p ro v id ed to th e ir w ebpages, w h ich list accred ited laboratories an d can be used to find an accredited lab o rato ry across jurisdictions: S tan d ard s C o u n cil o f C an ad a (SC C ) (h ttp s://w w w .scc.ca/en /accred itatio n /p ro d u ct-p ro cessa n d -se rv ic e -c e rtih c a tio n /d ire c to ry -o f-a c c re d ite d -c lie n ts) C an ad ian A ssociation for L aboratory A ccreditation Inc. (CALA) (http://w w w .caladirectory.ca/) 5.3.4 Analytical Method Development As co n su m er needs an d reg u lato ry drivers change, in d u stry co n tin u es to m o d ify an d develop analytical m eth o d s. C han g es in la b o ra to ry m e th o d s have resu lted in m o re PFA Ss b ein g able to b e an aly zed (e.g., s h o rt-c h a in P FA Ss), lo w e r d e te c tio n lim its (i.e., allo w in g lo w e r c o n c e n tra tio n s o f PFASs to be d etected ), an d b e tte r m an ag em en t o f p o ten tial biases in th e analytical p ro ced u res (e.g., sam p le -w are a n d filter c o m p o sitio n ). T h e follo w in g sectio n s d iscuss an aly tical m e th o d s th a t are u n d e r d ev elo p m en t in academ ic an d research co m m u n ities. 5.3.4.1 Total Organic Fluorine T h ere are tw o m eth o d s in d ev elo p m en t for qu an tify in g to ta l o rg an ic flu o rin e (sim ilar to u sin g to ta l p e tro leu m h y d ro c a rb o n analysis). T hese m eth o d s are p article -in d u ced g am m a-ray em ission (PIG E) an d adsorbable o rg an o -flu o rin e via co m b u stio n io n ch rom atography. T hese values over com e th e analytical challenges po sed b y th e lim ited availability o f reference stan d ard s. F u rth er, these m eth o d s enable a irp o rts an d th e ir e n v iro n m en ta l p ro fessionals to evaluate the ex ten t o f th e im p a c ts o f P FA Ss a t a site b e c a u s e o rg a n ic flu o rin e is a n th ro p o g e n ic . A t a site im p a c te d b y A F F F , th is is likely to b e re la te d d ire c tly to th e p re se n c e o f A FF F. T h e lim ita tio n o f th e se m e th o d s (s im ila r to th e lim ita tio n o f to ta l p e tro le u m h y d r o c a rb o n an a ly sis) is th a t sp e c ific c o m p o u n d s (su c h as P F O S ) are n o t id e n tifie d . T h e P IG E m e th o d is c u rre n tly b e in g c o m m e rc ia lly d e v e lo p e d a n d is av a ila b le in th e U n ite d S tate s, a lth o u g h it is n o t s ta n d a rd iz e d b y th e U .S . EPA . 53.4.2 Increasing the Num ber o f Identifiable PFASs M e th o d s are in d ev e lo p m e n t to analyze a m o re co m p reh en siv e ran g e o f PFASs (79). T w o p ro m isin g m ethods include liq u id ch ro m ato g rap h y /q u ad ru p o le tim e o f flig h t/tan d em m ass spectro m etry (L C -Q T O F-M S /M S ) an d to tal oxidizable p rec u rso r (T O P ) assay. L C -Q T O F -M S/M S is a s e m i-q u a n tita tiv e m e th o d re v e a lin g th e e m p iric a l fo rm u la o f m u ltip le PFA Ss b y assessing th e a c c u r a t e m a s s o f t h e m o le c u l a r io n s o f P F A S s (69). T h e T O P a s s a y in v o lv e s a r e a c t i o n w i t h h y d r o x y l radicals th a t reveals p re c u rso rs w ith th e p o te n tia l to d eg rad e in to m o re stable flu o ro ch em icals (e.g., PFA A s su ch as PFO S a n d P F O A ). C o n c e n tra tio n s b efo re a n d after o x id a tio n are c o m p a re d to d eterm in e th e co n c en tra tio n s o f ch ain -len g th -sp ecific PFA A p recu rso rs. T he T O P assay Copyright National Academy of Sciences. All rights reserved. US00004641 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 57 ap p ro ach q uantifies th e su m o f PFA Ss th a t co u ld be co n v erted to PFA A s in th e en v iro n m en t b y sim u latin g accelerated en v iro n m en tal d eg rad atio n , w ith a slightly exp an d ed range o f PFSA a n d P F C A s q u a n tifie d . P e rfo rm in g th is a n a ly sis b e fo re a n d a fte r th e s a m p le c o n ta in in g P FA Ss is p artially digested reveals th e "h id d e n m ass" o f PFA A s th a t w ere p rev io u sly n o t detectable. T he T O P m eth o d o lo g y has revealed th a t for A F F F -im pacted sites th e existing analytical L C -M S/M S m eth o d s are only detecting som e 30 percen t o f th e to tal PFA A m ass h id d en in PFASs. T he T O P assay is n o w c o m m e rc ia lly a v a ila b le in th e U K , b u t is n o t y e t c o m m e rc ia lly a v a ila b le in th e U n ited States o r C anada. C o m m ercial analytical m e th o d s are u n d e r d ev elo p m en t in C anada. . ~sk M a n a g e m e n t F or airp o rts w ith a h isto ry o f A FFF use (and th e associated release to th e en v iro n m en t o f PFA Ss), p o te n tia l h u m a n h e a lth an d ecological risks m ay exist. A irp o rts are challenged to u n d e rsta n d w h e th e r th e y h a v e a n u n a c c e p ta b le ris k a n d , i f so , h o w to m a n a g e th a t risk . R isk m a n a g e m e n t is em ployed w h en u n accep tab le risks are d eterm in e d to b e p rese n t via a h u m a n h ealth o r ecological risk assessm ent. R is k m a n a g e m e n t i n t e g r a t e s t h e s i t e 's r e m e d i a l s t r a t e g y w i t h t e c h n i c a l , p o lit ic a l, le g a l, s o c ia l, an d eco n o m ic co n sid eratio n s to develop risk re d u c tio n an d p rev en tio n strategies. R isk m an ag e m e n t effectively m an ag es o n e o r m o re o f th e th re e risk c o m p o n e n ts (i.e., so u rc e /c o n ta m in a n ts, recep to rs, an d ex p o su re p ath w ay s) alleviating o r elim in a tin g p o te n tia l risks to h u m a n h ea lth a n d /o r th e e n v iro n m e n t. G enerally, risk m a n a g e m e n t consists o f o n e o r m o re o f th e follow ing: A d m in istrativ e co n tro ls th a t lim it access o r exposure to p o te n tia l co n tam in atio n . E ngineering co n tro ls th a t ren d e r p o ten tial exposure pathw ays "in o p erab le" (or otherw ise cuts off the pathw ay b etw een co n tam in atio n an d receptors). R e m e d iatio n th a t rem o v es o r red u ces th e m ass o f c o n ta m in a n t at th e site. T he follow ing sections d escribe h o w risk m a n a g e m e n t ap p ro a ch es can b e ap p lied specifically to sites im p a cted b y PFASs. 5.4.1 Defining Risk In o rd e r fo r a h u m a n h ea lth o r ecological risk to b e p rese n t, th ree co n d itio n s m u st b e fulfilled (see F igure 5-1). T h ere m u st b e th e follow ing: A so u rce/co n tam in an t: A chem ical (or g ro u p o f chem icals) fo u n d at a co n c en tra tio n th a t represents a p o ten tial co n cern to h u m a n h ealth o r the en v iro n m en t. Source nM sk j j M p p ll Exposure Pathway I'ntrnti.if 1 = N a R k k HisV S Receptor Figure 5-1. Principles of risk model. Copyright National Academy of Sciences. All rights reserved. US00004642 Use and Potential Impacts of AFFF Containing PFASs at Airports 58 Use and Potential Impacts of AFFF Containing PFASs at Airports A receptor: A h u m a n o r ecological recep to r th a t w o u ld b e exposed to th e source. A n exposure pathw ay: A t least one com plete exposure pathw ay th ro u g h w hich the receptor(s) w o u ld b e exposed to th e so u rce /co n tam in an t. As sh o w n in th e prin cip les o f risk m o d el p resen ted in F igure 5-1, risk m an ag em en t aim s to rem o v e o n e o r m o re o f these co n d itio n s, elim in atin g p o te n tia l risk. As d escribed in the follow ing se c tio n , a c o n c e p tu a l site m o d e l (C S M ) is d e v e lo p e d to id e n tify so u rc e , p a th w a y s, a n d re c e p to rs; b e tte r u n d e rsta n d th e re la tio n sh ip a m o n g these elem en ts; a n d develop a risk m a n ag e m en t s tra te g y . 5.4.2 Conceptual Site Model T h e C S M d isc u sse d h e re is a g e n e ra l re p re s e n ta tio n o f th e n a tu re a n d fate a n d tr a n s p o r t o f PFA Ss at an a irp o rt facility. A site-specific C SM sh o u ld b e d ev elo p ed as necessary to assess p o te n tia l a n d /o r ac tu al ex p o su re to PFA Ss a n d be review ed to id e n tify w h e th e r d ata gaps exist. A ligning w ith th e risk m odel, th e CSM consists o f three m ain co m p o n en ts: so u rce/co n tam in atio n , rec ep to rs, a n d p ath w a y s (i.e., e x p o su re a n d m ig ra tio n ). F ig u re 5-2 p ro v id es a n ex am p le o f a C S M fo r an airp o rt, grapahically p resen tin g sources, p o ten tial receptors, an d exposure pathw ays. 5.4.2.1 Source/Contam ination A FFF m a n u factu red an d im p o rte d in to th e U n ited States an d C an ad a p rio r to th e v o lu n tary p h ase-o u t in p ro d u c tio n in 2002 co n tain e d PFASs, in clu d in g -- p re d o m in a n tly -- PFO S. W hile m an u factu rers have since m odified th e ir fo rm u latio n s to elim in ate PFO S, A FFF fo rm u latio n s c o n tin u e to in clu d e sh o rt-c h a in PFA Ss, th e toxicological p ro p e rtie s o f w h ich are n o t w ell k n o w n . H isto ric al a p p lic a tio n o f A FFF (i.e., via em erg en cy resp o n se, te stin g , a n d tra in in g ) to th e en v i r o n m e n t (e.g., so il o r su rfa ce w a te r) a n d in c id e n ta l releases (e.g., spills, leak s, a n d d isp o sa l), th e re fo re, rep rese n t a p o te n tia l so u rce o f c o n ta m in a tio n b y PFA Ss. Specifically, p o te n tia l sou rces o f c o n ta m in a tio n b y PFA Ss associated w ith A FFF m ay in clu d e th e follow ing: A FFF sto rag e areas (i.e., w h ere th e p o te n tia l fo r leaks an d spills existed). A reas w here A FFF w as applied as p a rt o f an em ergency response. F irefighting train in g areas, b u rn pits, o r o th e r areas w here A FFF m ay have b een discharged as p a rt o f training. A reas w here A FFF w as discharged as p a rt o f foam testing. A reas w here A FFF w as lo ad ed o r rem o v ed fro m A RFF vehicles d u rin g vehicle m ain ten an ce. H isto ric a l d isp o sal areas (e.g., w h e re e x p ire d o r c o n ta m in a te d A FFF c o n c e n tra te w as d isp o sed to th e e n v iro n m e n t o r w h ere A FFF fo am w as d irected follow ing release, in c lu d in g lag o o n s an d retention ponds). As indicated in C h ap ter 2 o f this rep o rt, o th er sources o f PFASs m a y b e p resen t at an airp o rt o r on adjacent p ro p erty . O b tain in g good quality in fo rm atio n ab o u t th e so u rce/co n tam in atio n sh o u ld follow th e b est m a n a g e m e n t p ractices for sa m p lin g an d analysis o f PFA Ss as describ ed S ectio n s 5.2 a n d 5.3. 5.4.2.2 Pathways F o r C SM s, p ath w ay s can b e categ o rized as ex p o su re p ath w ay s o r m ig ra tio n p ath w ay s. As described previously, exposure pathw ays are h o w co n tam in atio n m oves th ro u g h th e envi ro n m e n t fro m a source to a receptor. M ig ratio n pathw ays are h o w c o n tam in atio n m oves off-site, in d e p e n d e n t o f w h e th e r a re c e p to r is p re se n t. T ab le 5 -2 id en tifies ex p o su re p ath w a y s a n d m ig ra tio n p ath w a y s fo r each ty p e o f e n v iro n m e n ta l m e d ia (i.e., soil, g ro u n d w a te r, su rface w ate r, se d im e n t, an d air). Copyright National Academy of Sciences. All rights reserved. US00004643 Use and Potential Impacts of AFFF Containing PFASs at Airports Copyright National Academy of Sciences. All rights reserved. Figure 5-2. Sources, pathways, and receptors in airport firefighting. Use and Potential Impacts of AFFF Containing PFASs at Airports 60 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 5-2. Exposure and migration pathways for AFFF. Soil Groundwater Surface Water Sediment Air Human Health--dermal contact Human Health--ingestion Human Health--soil inhalation Human Health--vapor inhalation pathway Ecological Soil Contact Ecological--nutrient and energy cycling Lateral Migration--surface runoff Vertical Migration--infiltration/percolation Human Health--potable/drinking water Human Health--agricultural use--irrigation Human Health--agricultural use--livestock Human Health Contact Ecological--protection of aquatic life receptors Lateral Migration--advective/diffusive transport Human Health--protection of aquatic life (fish ingestion) Ecological--protection of aquatic life Lateral Migration--advective/diffusive transport Ecological--aquatic life receptors Migration--sediment transport Migration--long-range transport, atmospheric deposition Yes Yes No No Yes Unknown Yes Yes Yes Unknown Unknown Yes Yes Yes Yes Yes Yes Yes Yes Yes (on a global scale) 5.4.23 Receptors R ecep to rs can b e e ith e r h u m a n s o r ecological flo ra a n d fa u n a (i.e., p la n t a n d /o r an im al) th a t co u ld be exposed to co n tam in atio n . R eceptors k n o w n to be p o ten tially sensitive to PFASs include th e follow ing: Fish B irds T errestrial anim als Invertebrates H u m an s (exposure to d rin k in g w ater, d erm al co n tact pathw ays, c o n su m p tio n o f hsh) S om e PFA Ss are k n o w n to b io a cc u m u la te a n d b io m a g n ify in th e fo o d ch ain . T h is affects recep to rs a t d iffe re n t p o in ts alo n g th e fo o d c h a in , e.g., h u m a n s c o n s u m in g h sh . F ield m e a su re m e n ts o f PFO S, PFO A , PFH xS, an d PFO SA in th e G reat Lakes food w eb have suggested th a t p recu rso rs to PFA Ss m e tab o lize to PFA Ss th a t h av e k n o w n eco to x ico lo g ical p ro p e rtie s (e.g., P F O S , P F O A , P F H x S , P F O S A ) (85). T h e s e re s u lts in d ic a te th a t th e risk s to s o m e r e c e p to r s a re d iffic u lt to q u an tity w ith o u t know ledge ab o u t th e precursors. Copyright National Academy of Sciences. All rights reserved. US00004645 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 61 5.4.3 M anaging Risk Associated w ith the Impacts of PFASs T he scientific an d reg u lato ry c o m m u n ities' u n d e rsta n d in g o f th e chem istry, fate, tra n sp o rt, an d toxicology o f PFASs co n tin u es to evolve rapidly. In th e m id st o f th is ch an g in g reg u lato ry clim ate, a irp o rts are c u rre n tly challenged to u n d e rsta n d w h a t u n ac ce p ta b le risks m ay be p re s e n t an d w h at to do a b o u t th ese risks if they are p resen t. A irp o rts n eed to p ro actively m anage th e p o te n tia l risks asso ciated w ith c u rre n t o p e ra tio n s (i.e., w ith resp ect to A FFF m a n a g e m e n t th ro u g h th e life cycle stages, as d etailed in C h a p te r 4) w h ile c o n sid e rin g h o w b e st to ad d ress p o te n tia l risks associated w ith legacy e n v iro n m e n ta l im p acts, u n d e rsta n d in g th a t h isto rical use o f A FFF at a irp o rts likely resu lted in releases o f PFA Ss to th e en v iro n m e n t. R isk m a n a g e m e n t strategies fo r legacy im p acts o f PFA Ss in th e e n v iro n m e n t n eed to co n sid er th e C SM , w h e th e r th e re is a c u r r e n t u n a c c e p ta b le risk , w h e th e r th e re is a p o te n tia l fo r a f u tu re u n a c c e p ta b le risk , an d h o w to elim in ate u n accep tab le risk. G iven th e rec alc itran t n a tu re o f so m e PFA Ss to rem e d ia tio n , proactively cu ttin g off th e exposure pathw ay betw een co n tam in atio n by PFASs an d p o te n tial recep to rs m ay p ro v id e a cost-effective m ean s for m an ag in g u n accep tab le or, preem ptively, p o te n tia lly u n ac c e p ta b le risks, w h ere p erm issib le. S om e ex am p les are as follow s: E lim in atin g d irect co n tact to soil im p acted by PFA Ss an d lim itin g in filtratio n (an d p o te n tia l g ro u n d w ater m ig ratio n ) b y covering a p o rtio n o f th e site w ith p av em en t. E lim inating surface w ater ru n o ff to prev en t surface w ater from being im pacted by sedim ent co n tain in g PFASs. R equiring w orkers to d o n ap p ro p riate p erso n al protective eq u ip m en t (PPE) w h en w orking w ith A FFF o r m edia im p acted by PFASs. P rohibiting potable gro u n d w ater o r surface w ater use by providing an alternate w ater supply sh o u ld a p o tab le source b e suspected o f b ein g im p acted b y PFASs. In stallatio n o f ero sio n an d se d im e n t co n tro ls in areas w h ere soils th a t m ay be im p a c te d b y PFASs are p lan n ed to be disturbed. If u n accep tab le risks ca n n o t be m an ag ed b y m eans o f c u ttin g o ff th e exposure pathw ay, rem e d ia tio n m a y b e re q u ire d . S ectio n 5.5 d iscusses re m e d ia tio n o p tio n s th a t rem o v e o r re d u c e th e m ass o f c o n ta m in a tio n b y PFA Ss to accep tab le levels as d efin ed b y reg u la to ry sta n d ard s. Finally, a irp o rts also need to co n sid er an d p la n fo r th e p o te n tia l im p licatio n s o f c o n ta m in a tio n b y PFA Ss o n cap ital p ro jects. S hould soil o r g ro u n d w a te r im p a cted b y PFASs b e e n c o u n tered d u rin g c o n stru c tio n o f capital in frastru ctu re projects, th e cost to m anage th e im pacted m edia co u ld b e significant an d delays to th e capital p ro ject co u ld be su b stantial. im ediation Options R e m e d ia tio n o f P FA Ss in e n v iro n m e n ta l m e d ia is re q u ir e d if u n a c c e p ta b le risk s a re p re s e n t an d can n o t be ap p ro p riately m anaged w ith o u t rem ediation. PFASs, how ever, have u n iq u e p ro p erties th a t are p ro b le m a tic w h e n e n v iro n m e n ta l re m e d ia tio n is re q u ire d . T h o se p ro p e rtie s th a t have m ade m an y PFASs very useful in a w ide range o f com m ercial an d in d u strial applications (e.g., h ig h deg rees o f ch em ical a n d th e rm a l stab ility ) re su lt in challenges relative to re m e d ia tio n . M a n y P F A S s d o n o t r e a d ily d e g r a d e in th e e n v i r o n m e n t (86) a n d a re r e s is ta n t to m a n y f o rm s o f rem ed iatio n . F or exam ple, a stro n g flu o rin e-carb o n b o n d an d low v ap o r pressure m ean th a t so m e PFA Ss (e.g., P F O A a n d P F O S ) are resistan t to a n u m b e r o f co n v e n tio n a l w ate r tre a tm e n t technologies, in clu d in g direct ox id atio n , b io d eg rad atio n , air strip p in g an d v ap o r extraction, an d direct photolysis (ultraviolet rad iatio n ). A dditionally, PFASs in A FFF are a m ix tu re o f co m p o u n d s, each w ith variable p ro p erties. D ifferen t rem ed ial ap p ro ach es w ill b e successful at v ary in g degrees w ith each c o m p o u n d an d , like e n v iro n m e n ta l re m e d ia tio n in general, a m u ltitu d e o f site-sp ecific factors w ill greatly Copyright National Academy of Sciences. All rights reserved. US00004646 Use and Potential Impacts of AFFF Containing PFASs at Airports 62 Use and Potential Impacts of AFFF Containing PFASs at Airports affect th e effectiveness o f an y given rem ed ial ap p ro ach . M o reo v er, w ith PFA Ss, d e g ra d atio n o f select p rec u rso rs if p re se n t (o r h a d b ee n h isto rically p rese n t) w ith in A FFF can c o m p o u n d th e issu e b y g e n e ra tin g a d d itio n a l p e rs is te n t PFA Ss (e.g., P F O A a n d P F O S ). F inally, th e selec tio n an d u ltim ate effectiveness o f rem ed ial ap p ro ach es m ay be sig n ifican tly in flu en ced by co -m in g led co n tam in an ts as w o u ld be th e case w ith th e ap p licatio n o f A FFF for ex tin g u ish in g C lass B fires. G iven th e challenges identified above, d ev elo p m en t o f p ro v en rem edial technologies fo r PFASs h as b ee n elusive. R ecent p u b licatio n s h ave discussed so m e b en ch -scale success w ith d e g ra d atio n o r d e s tr u c tio n u s in g a d v a n c e d o x id a tio n (87), e n h a n c e d p h o to c h e m ic a l (88), a n d ir r a d ia tio n m e th o d s (89); h o w e v e r , th e s e te c h n o lo g ie s a r e o f te n n o t p r a c tic a l f o r fie ld -s c a le im p l e m e n t a t i o n (90). T rad itio n al m ethods such as "excavation an d disposal" an d "p u m p an d treat" have been success fully applied in th e held, b u t m a in ta in th e lim itatio n s th a t are typically associated w ith these m e th ods (an d w o u ld likely b e exasperated b y th e n a tu re o f so m e PFA Ss). W ith excavation an d disposal, c o n ta m in a tio n is ju s t b e in g tra n sfe rre d to a n o th e r site; w ith g ro u n d w a te r tre a tm e n t v ia "p u m p an d trea t," high costs o f o p era tio n an d m ain ten an ce are o n g o in g fo r lo n g p erio d s o f tim e. K now n available an d em erging technologies are su m m arized in T able 5-3. L ik e r e m e d ia tio n o f o th e r r e c a lc itr a n t a n d p e r s is te n t c o m p o u n d s , r e m e d ia tio n o f P F A S s is n o t likely to be achieved w ith a single rem ed ial technology; rath e r, a successful rem edial strategy w ill likely consist o f a c o m b in a tio n o f rem ed ial ap p ro ach es ap p lied ap p ro p riately . A ny tre a tm e n t te ch n o lo g y th a t uses o x id a n ts m ay release m o re m o b ile fo rm s o f PFA Ss th a t w ill b e su b seq u en tly m o re difficult to rem ove. A irp o rt o p era to rs an d th e ir co n tra cto rs sh o u ld co n sid er fully th e lim ita tio n s an d im p licatio n s o f u sin g d eg rad ato ry technologies. F u rth er, given th a t rem ed iatio n tech n o lo g ies for PFASs are u n d e r d ev elo p m en t, a rem ed iatio n strategy m ay involve sh o rt-te rm so lu tio n s (e.g., p u m p a n d tre a t o r a d m in istra tiv e m e a su re s) to a d d re ss k n o w n u n a c c e p ta b le risks u n til ap p ro p riate rem edial ap p ro ach es have b een developed. In o rd e r to develop a p p ro p ria te ap p ro a ch es fo r successful rem e d ia tio n , co n sid eratio n sh o u ld b e given to developing decision su p p o rt m odels to su p p o rt th e choice o f sh o rt- an d lo n g -te rm rem e d iatio n strategies fo r PFA Ss at sites w here A FFF has b een ap p lied o r o th erw ise released in to th e e n v ir o n m e n t (98). O n e s u c h e x a m p le d e c is io n tr e e , d e v e lo p e d b y A v in o r, c o n s id e rs th e f o llo w in g (98): W hich PFASs are p resen t an d th e ir physicochem ical properties. H ydrogeological conditions. O ff-site an d o n -site risks at p rese n t an d in th e fu tu re. A cceptable tim e fram es for rem ed iatio n . T echnology acceptance an d stakeholder involvem ent. C osts fo r rem ed iatio n . A cceptable d istu rb an ce o f d a y -to -d a y o perations. T he follow ing sections discuss th e c u rre n t state o f practice o f rem ed ial technologies an d ap p ro ach es th a t have d em o n strate d som e success (o r are generally believed to h o ld p ro m ise) in field -scale re m e d ia tio n o f PFA Ss in so il a n d g ro u n d w a te r. In a d d itio n , S ectio n 5.5.3 id en tifies lim itatio n s th a t an a irp o rt sh o u ld co n sid er in the disposal o f released A FFF an d w ater im p acted by AFFF. 5.5.1 Soil Soil re m e d ia tio n m a y b e re q u ire d if c u rre n t co n c e n tra tio n s o f PFA Ss p o se a p o te n tia l risk to h u m a n a n d /o r ecological h ealth. R em ed iatio n m a y b e req u ired to lim it c o n ta m in a n t m ig ratio n (e.g., v ertical in filtra tio n to g ro u n d w a te r p ath w a y ) a n d /o r rem o v e th e im p a c ts fro m th e site (e.g., Copyright National Academy of Sciences. All rights reserved. US00004647 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 63 Table 5-3. Summary of available and emerging technologies for PFASs. Lab scale (ScisoR for PFOS/PFOA) (91) *lt should be noted that this approach can generate ln-situ chemical oxidation Emerging short-chain PFASs that are more mobile and are difficult to remove by more traditional remediation c QJ approaches (e.g., granulated activated carbon) 03 HQi_J ln-situ enhanced bioremediation QJ N/A -- DO ln-situ thermal N/A -- Stabilization Commercial Carbon and other commercially available additives (RemBindTM and MatCARETM) Soil Removal Commercial -- Sorptive media (granulated activated carbon) Commercial Fligh-temperature thermal regeneration required to reuse carbon Sorption to carbon is low/ineffective for shortchain PFASs c QJ Sorptive media (synthetic media) Commercial Commercially available additives include RemBindTM and MatCareTM. PerfluorAd--coagulant (emerging) C 03 1Qi_-J Sorptive media (ion exchange resin) Commercial Ion exchange media (92, 93) QJ 03 Ultrafiltration Commercial Reverse osmosis and nanofiltration "5cO Investigated at the bench scale for landfill leachate o Sonochemical Emerging and groundwater (94, 95) Air stripping Commercial Spray stripper system as part of Pump and Treat for volatile organic compounds. Mobilized volatile PFASs (aerosols, volatilization), moved less volatile PFASs deeper within the soil column (96). Found to be ineffective in removing PFASs from landfill leachate adequately prior to land application (97) c o n c e n tra tio n s o f PFA Ss in soil n eed to be b ro u g h t in to co m p lian ce w ith applicable guidelines an d /o r regulations). T he follow ing sections describe rem ed iatio n m ethodologies th a t address im p acts o f PFA Ss in soil. 5.5.7.7 Excavation E xcavation m ay b e ap p ro p riate fo r rem oval o f PFASs w h en th e substances have n o t signifi c a n tly m ig ra te d v e rtic a lly a n d th e o b je c tiv e is c o n ta m in a n t m a ss re m o v a l. U n fo rtu n a te ly , so m e o f th e m o re m o b ile PFA Ss can, d ep en d in g o n site co n d itio n s, m ig rate to d ep th s th a t m ake ex cav atio n cost p ro h ib itiv e. U p o n excav atio n , th e re are tw o m a in o p tio n s fo r d isp o sal o f soils im p acted by PFASs: in cin eratio n an d landfill disposal. Incineration O ff-site, h ig h -te m p eratu re in cin eratio n (> 1100C) has p ro v e n to b e a viable (yet expensive) m e th o d fo r d e stru c tio n o f PFA Ss. H ow ever, in c in e ra tio n facilities m u st lim it th e v o lu m e o f soil Copyright National Academy of Sciences. All rights reserved. US00004648 Use and Potential Impacts of AFFF Containing PFASs at Airports 64 Use and Potential Impacts of AFFF Containing PFASs at Airports a n d g ro u n d w a te r im p a c te d b y PFA Ss th a t is in tro d u c e d in to th e ir o p e ra tio n s a t a g iven tim e to avoid o p era tio n al efficiency issues. T his circ u m sta n ce ad d s ad d itio n a l co m p lex ity to large-scale rem ed iatio n projects for PFASs. Landfill Disposal G iven th e cost o f in c in eratio n , off-site disposal at an ap p ro p riately en g in eered landfill m ay p ro v id e a m o re viable disposal alternative. A n ap p ro p riate facility m u st b e selected fo r th e d is p o sal o f soils c o n ta in in g PFA Ss, sin ce several PFA Ss (e.g., PFO S a n d P FO A ) are w ate r so lu b le a n d h a v e lim ite d b io d e g r a d a tio n p o te n tia l a n d , as a re s u lt, e n d u p in la n d fill le a c h a te (30). M o r e over, b io d e g ra d atio n o f p re c u rso r PFA Ss w ill p ro d u ce a n u m b e r o f p ersisten t a n d to x ic PFASs (e.g., PFO S an d P F O A ). L andfills m u s t b e d esig n ed to p re v e n t m ig ra tio n o f PFA Ss v ia la n d fill le a c h a te in to th e e n v iro n m e n t. T h is m a y re q u ire th e le a c h a te to b e tre a te d w ith a d v a n c e d w a te r t r e a tm e n t m e th o d s (2 9 , 30). A ir p o r ts d is p o s in g o f s o il im p a c te d b y P F A S s s h o u ld v e rify th a t th e re c e iv in g fac ility is e n g in e e re d w ith d o u b le lin e rs a n d le a c h a te c o lle c tio n sy stem s a n d is a p p ro p ria te ly c e rtifie d to rec eiv e so il im p a c te d b y PFA Ss. A irp o rts s h o u ld also v e rify th a t th e re c e iv in g w a ste w a te r tr e a tm e n t p la n t u se d to tre a t le a c h a te is c a p a b le o f tre a tin g PFA Ss, as m a n y landfills sen d th e ir leachate off-site fo r tre a tm e n t (99). T ra n sferrin g soils (an d leachate) im p a c te d b y PFA Ss fro m a site to a fac ility th a t is n o t d e s ig n e d to c o n ta in PFA Ss (o r m a n a g e th e leachate) co u ld b e co n sid ered as sim p ly relo catin g th e p ro b lem , an d , th erefo re, th e b est p ra c tic e is to e n s u re th a t th e re c e iv in g fac ility is a p p ro p ria te ly d e s ig n e d to tre a t a n d h a n d le soils im p acted by PFASs. 5.5.1.2 Im m obilization/Stabilization A d so rb en ts (also called so rb e n ts) are m aterials th a t have an ab ility to ad so rb su b stan ces, resulting in th eir im m o b ilizatio n an d stabilization. A dsorbents th a t have th e p o ten tial to treat PFO S an d PFO A include organo-clays, clay m inerals, an d carb o n n an o tu b es. C om m ercial sorbents co n tain in g activated carbon, alu m in u m hydroxide (am o rp h o u s), an d o th e r p ro p rietary additives have b een explored for th e ir so rb en t p ro p erties w ith PFASs. B ench-scale studies have sh o w n th a t so rb en t technology h olds p ro m ise for h eld application; how ever, site-specific co n d itio n s w o u ld n eed to be evaluated in o rd e r to assess th e applicability fo r im p le m e n ta tio n . A t th e held scale, use o f a m in e -m o d ih e d clay so rb en ts, as o p p o se d to activated ca rb o n , fo r tre a tm e n t o f sites im p a cted b y P F A S s (82, 83) h a s s h o w n s o m e p r o m i s e . 5.5.2 Groundwater N u m ero u s studies have evaluated the suitability o f tre a tm e n t technologies fo r PFASs in w aste w ate r an d d rin k in g w ater. U n fo rtu n a tely , th ese tech n o lo g ies are n o t alw ays directly applicable to th e tre a tm e n t o f co n tam in ate d g ro u n d w ater in -situ . T his section describes those te ch n o lo gies th a t h av e d e m o n stra te d success in h eld -scale a p p lica tio n s a n d s h o u ld b e c o n sid e re d fo r th e re m e d ia tio n o f g ro u n d w a te r a n d surface w ate r im p acted b y PFA Ss, d e p e n d in g o n site co n d itio n s an d p ro ject objectives. 5.5.2.1 Pump and Treat P u m p a n d tre a t is a c o m m o n m e th o d fo r c le a n in g u p g ro u n d w a te r im p a c ts w h e re g ro u n d w a te r is p u m p e d fro m w ells to a n a b o v e -g ro u n d tre a tm e n t facility th a t re m o v e s th e c o n ta m in a n ts p r io r to disposal o r reuse. B ecause o f th e len g th o f tim e req u ired to "tre a t" th e c o n ta m in a n t m ass in gro u n d w ater, p u m p an d treat rem edial technologies sh o u ld be view ed as "co n tro l" technologies, rath e r th a n source rem oval rem edial technologies. M u ch o f th e cu rre n t literatu re o n th e success ful application o f trea tm e n t technologies has been sh o w n for w ater trea tm e n t plants. W hile the p rin c ip le s re m a in th e sam e (e.g., in le t flow o f PFA Ss in w a te r, PFA Ss so rb to g ra n u la te d activ ated Copyright National Academy of Sciences. All rights reserved. US00004649 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 65 carb o n [G A C ]/rem oved b y m em b ran e, "treated " effluent), th e inlet concen tratio n s, q u an tity o f reactive m ed ia req u ired , an d tim e fram e to tre a t g ro u n d w a te r im p a cted b y PFASs m ay be very different. T he follow ing sections discuss p u m p an d trea t system s th a t have b een ap p lied for th e rem ediation o f PFASs in groundw ater. Activated Carbon P u m p in g a n d ex -situ tre a tm e n t o f g ro u n d w a te r w ith activ ated c a rb o n filters has p ro v en to b e viable a n d an a p p ro p ria te tre a tm e n t technology, alth o u g h th e efficiency o f activated ca rb o n filte rs h a s b e e n o b s e r v e d to b e v a r ia b le (102). U s e o f a c tiv a te d c a r b o n h a s also b e e n s h o w n to b e le s s e f f e c tiv e a t r e m o v i n g s h o r t - c h a i n P F A S s (65, 66), w h i c h m u s t b e c o n s i d e r e d g iv e n t h e overall u n c e rta in ty asso ciated w ith th e ecotoxicity, sy n erg istic effects, an d en v iro n m en ta l fate a n d tr a n s p o r t o f PFA Ss. A c tiv a te d c a rb o n is c o m m o n ly u se d to a d s o rb c o n ta m in a n ts fo u n d in w a te r. A c tiv a te d c a rb o n , w h ic h is u s e d in a g ra n u la te d o r p o w d e re d fo rm , is a n effectiv e a d s o r b e n t b e c a u s e it is h ig h ly p o ro u s a n d p ro v id e s a la rg e su rfa c e a re a o n w h ic h c o n ta m in a n ts m a y a d s o rb . S ev eral case s tu d ie s h a v e in d ic a te d th a t G A C is a c o m m o n a n d effectiv e (> 9 0 p e rc e n t rem oval) trea tm e n t for co n tam in atio n w ith lo n g -ch ain PFASs. H ow ever, sh o rt-ch ain PFASs have b een o b serv ed to b re a k th ro u g h . T he efficiency o f th is m e th o d varies b ased o n several fa c to rs : T arget effluent co n tam in an t co n cen tratio n pH W ater tem p eratu re C o n tact tim e P roperties o f th e selected carb o n C o n c en tra tio n o f in o rg an ic substances in the w ater A m bient natu ral organic m atter C hlorine co n cen tratio n s in th e w ater D u d le y e t al. (103) e v a lu a te d p o w d e r e d a c tiv a te d c a r b o n (P A C ) a n d f o u n d t h a t > 9 0 p e r c e n t rem oval o f PFN A an d PFO S w as possible b u t only w ith u n reaso n ab ly high ad so rb en t dosages, unless co n tact tim es co u ld b e ex ten d ed to ap p ro ach ad so rp tio n eq u ilib riu m . U se o f PA C has also b e e n sh o w n to b e less effective a t re m o v in g s h o rt-c h a in PFA Ss. M o d ifie d so rb e n ts o th e r th a n activ ated c a rb o n (e.g., a m in e -tre a te d clays) h av e also b e e n ev a lu a te d a t th e b e n c h -sc a le fo r applications to groundw ater. Coagulation and Activated Carbon C o a g u la tio n -flo c c u la tio n is a c h e m ic a l w a te r tr e a tm e n t te c h n iq u e ty p ic a lly a p p lie d p r io r to s e d im e n ta tio n a n d filtra tio n (e.g., ra p id sa n d filtra tio n ) to e n h a n c e th e ab ility o f a tre a tm e n t process to rem ove particles p rio r to su b seq u en t polishing treatm en ts, such as PA C o r G A C. T he co agulation process w orks w ith chem icals th a t exhibit a charge (zw itterionic, cationic, a n d /o r an io n ic), su ch as PFASs. A recen t stu d y fo u n d th a t a c o m b in a tio n o f co a g u la tio n an d a d so rp tio n b y P A C w as effective ( > 9 0 p e r c e n t r e m o v a l) a t r e m o v in g b o t h P F O S a n d P F O A f r o m w a te r (104). C o a g u la tio n a lo n e i s n o t a n effec tiv e m e a n s o f r e m o v a l f o r lo n g - c h a in P F A S s (e .g .,P F N A , P F O S a n d P F O A ) (65,105). R em oval o f PFO S an d PFO A by coagulation w orks by ad so rp tio n o f th e co n tam in an ts o n to the surface o f th e co a g u lan ts; an io n s ab so rb o n to th e p o sitiv e su rface o f co a g u lan ts a n d floes a n d are th en rem o v ed w ith se d im e n tatio n an d filtratio n . S u b seq u en t to co ag u latio n -flo ccu latio n trea tm e n ts, PA C w as sh o w n to have a significantly h ig h er ab so rp tio n rate an d capacity th a n G A C a n d h ig h e r a b s o r p ti o n e ffic ie n c y f o r P F O A t h a n P F O S (104). T h e r e m o v a l r a tio s f o r P A C increased w ith decreasing p H an d w ith increasing co ag u lan t dose, w hich w as co n sisten t w ith o t h e r r e s e a r c h r e s u lt s e v a lu a tin g p H o n P A C e ffic a c y f o r r e m o v a l o f P F A S s (103). Copyright National Academy of Sciences. All rights reserved. US00004650 Use and Potential Impacts of AFFF Containing PFASs at Airports 66 Use and Potential Impacts of AFFF Containing PFASs at Airports Ion Exchange Resin Io n exch an g e (IX ) involves th e u se o f resin s (i.e., v ery sm all p lastic p o ro u s b ead s w ith a fixed c h a rg e ) to e x c h a n g e u n d e s ira b le io n s w ith h y d ro g e n o r h y d ro x y l. T h e re m o v a l ra te is d e p e n d e n t u p o n a n u m b e r o f factors: Initial co n tam in an t co n cen tratio n C om peting ion concentration T re a tm e n t d esig n (e.g., flow rate , re sin b e a d size) R esin io n p ro p erties O n e sig n ific a n t a d v a n ta g e o f IX o v e r a c tiv a te d c a rb o n is th a t IX re sin s c a n b e re g e n e ra te d a n d re u se d , w h e re a s a c tiv a te d c a rb o n is d ifficu lt to re g e n e ra te a n d is ty p ic ally d isc a rd e d a fte r a single use. IX resins, specifically a n io n exchange trea tm e n ts, have b een investigated in p ilo t stu d ies for ap p licatio n in p u m p an d trea t system s for rem oving PFASs. T he rem oval o f PFO A an d PFO S has b een rep o rted at a N ew Jersey d rin k in g w ater trea tm e n t p la n t u sing p o ro u s an io n exchange resin im p r e g n a te d w ith i r o n o x id e (105). R e s e a r c h e r s h a v e n o t e d t h a t t h e s h o r t - c h a i n P F A S s w e re n o t r e m o v e d th r o u g h th e d o c u m e n te d IX tr e a tm e n t p ro c e s s e s (65). A p o s s ib le a lte r n a tiv e fo r rem oval o f PFASs co u ld b e a h y b rid a d so rp tio n /an io n exchange tre a tm e n t ap p ro ach , in w hich m o re stro n g ly ad so rb in g PFASs are initially rem o v ed by activated ca rb o n an d th e m o re w eakly ad so rb in g PFASs su b seq u en tly rem o v ed b y an io n exchange. T he h y b rid ap p ro ach m ay facilitate re sin re g e n e ra tio n , w h ic h is m o re re a d ily a c c o m p lish e d if o n ly PFA Ss th a t in te ra c t m o re w eak ly w ith th e resin need to be rem oved. T h e m a n a g e m e n t o f th e s p e n t resin (e.g., in c in e ra tio n , lan d fill, a n d re g e n e ra tio n ) a n d o f th e b rin e (e.g., ch em ical/b io lo g ical pro cesses o r d isp o sal) m u s t b e c o n sid ered w ith th is tech n o lo g y . Membranes (Reverse Osmosis, Nanofiltration) R everse osm osis (R O ) can rem ove m an y types o f m olecules an d io n s fro m so lu tio n s an d is u s e d in b o th in d u s tria l p ro c e s s e s a n d th e p r o d u c tio n o f p o ta b le w a te r. R O sy ste m s h a v e b een u sed for th e tre a tm e n t o f PFA Ss in d rin k in g w ater. T he so lu te (a co m p o u n d o f PFA Ss) is re ta in e d o n th e p re s s u riz e d sid e o f th e m e m b ra n e , a n d th e p u r e s o lv e n t (w a te r) p a sse s th ro u g h to th e o th e r sid e. P re tre a tm e n t is re q u ire d p r io r to im p le m e n tin g a n R O sy ste m to re d u c e m e m b ra n e fo u lin g (b io lo g ic a l, c h e m ic a l, a n d /o r p h y s ic a l). R O is effec tiv e a t r e m o v ing b o th long an d sh o rt-ch a in co m p o u n d s, filtering o u t b o th p rec u rso r m aterials an d sh o rtchain b y -p ro d u cts. N a n o f iltra tio n is a n o th e r fo rm o f m e m b r a n e te c h n o lo g y th a t is p re s s u re -d riv e n a n d h a s b e e n s h o w n to b e e ffe c tiv e in r e m o v in g P F A S s in w a te r t r e a t m e n t s y s te m s (106). T h e m e th o d is ea sy to o p erate an d reliable for p o llu ta n t rem oval. H igh PFO S rem oval rates have b een observed in n an o filtratio n system s. R O is th o u g h t to p ro v id e m o re d e s ira b le p e rfo rm a n c e th a n n a n o filtra tio n . B o th sy ste m s re s u lt in reject w ater (20 to 25 p ercen t), w hich m u st b e m anaged p ro p erly to avoid fu rth e r co n tam in atio n o f su rro u n d in g w ater an d en su re co m p lian ce w ith applicable reg u latio n s. A d d itio n al w aste to b e c o n s id e re d is m e m b ra n e d isp o sal. G iven an ticip ated low to ta l dissolved solids in g ro u n d w a te r, th e cost o f R O system s m ay be reasonable for g ro u n d w ater system s. L ow -pressure R O co u ld b e ap p lied (o p eratin g at <250 psi) fo r trea tm e n t. T he use o f cen tralized reject p ro cessin g /m an ag em en t facilities to serve several local satellite w ater tre a tm e n t p lan ts co u ld b e co n sid ered to m in im ize capital an d o p eratin g costs. R O a n d n a n o filtra tio n tre a tm e n t system s have n o t y et b e e n im p le m e n te d at th e h eld scale fo r rem ed iatio n o f g ro u n d w ater co n tam in ated by PFASs. Copyright National Academy of Sciences. All rights reserved. US00004651 Use and Potential Impacts of AFFF Containing PFASs at Airports Addressing Legacy Environmental Impacts 67 5.5.2.2 Perm eable Reactive Barrier P erm eab le reactive b a rrie rs (PR B s), w h ich essentially are v ertical w alls (o r tren c h es) created below g ro u n d to clean u p co n tam in ate d g ro u n d w ater, have b een investigated for use in treatin g g ro u n d w a te r im p a c te d b y PFA Ss. T h e w all is "p e rm e a b le ," w h ic h m e a n s th a t g ro u n d w a te r ca n flow th ro u g h it. As th e w a te r flow s th ro u g h th e w all, th e w a te r reacts w ith th e m a te ria l in th e w all a n d is th e re b y tre a te d . C o n c e rn s w ith G A C a n d o th e r rea ctiv e m e d ia fo r u se in PR B s m ir r o r th o se m e n tio n e d above for p u m p an d treat system s. C o n cern s w ith observed b rea k th ro u g h in c o lu m n e x p e rim e n ts (41,107,108) h a v e slo w e d a p p lic a tio n o f P R B s in th e field fo r g r o u n d w a te r im p acted by PFASs. 5.5.3 Disposal of Discharged Foam A FF F c o n ta in in g P FA Ss th a t is re le a se d (e.g., fro m in c id e n ts , tra in in g , a n d fo a m te sts) re q u ire s tre a tm e n t an d sh o u ld b e cap tu red an d disp o sed o f carefully. M u n icip al w astew ater tre a tm e n t system s th a t receive cap tu red A FFF/A FFF w astew ater m ay n o t have th e a p p ro p riate, advanced m e th o d s to tre a t so m e o f th e PFA Ss th a t w o u ld likely be p resen t. P re tre a tm e n t (w ith a viable te ch n o lo g y ap p licab le fo r PFA Ss in aq u eo u s so lu tio n s, as id en tified in S ectio n 5.5.2) m ay be re q u ire d fo r accep tan ce at a w astew ater tre a tm e n t facility. Copyright National Academy of Sciences. All rights reserved. US00004652 Use and Potential Impacts of AFFF Containing PFASs at Airports C iHi Aa nr tI It- nR ro Screening Tool Guidance 6.1 Introduction to th e M APA Screening Tool 6.1.1 Overview T he M anaging A FFF an d PFASs at A irp o rts (M A PA ) S creening T ool has b een designed to assist a irp o rt m an ag ers w ith th e id en tificatio n o f A PE C s o n o r n e a r th e ir airp o rt. T he id entified A PEC s account for historical an d cu rren t use o f AFFF an d o th er sources o f PFASs at an airp o rt facility. T h e M A PA S creen in g T o o l has b e e n d esig n ed to en ab le u sers to easily id en tify W h e th e r an a irp o rt has A PEC s th a t n eed to be fu rth e r evaluated. T h e n a tu re o f th ese A P E C s (i.e., o p e ra tio n a l v ersu s legacy). T he relev an t o r sig n ifican t ch a racteristics related to A FFF m a n a g e m e n t an d th e fate an d tra n sp o rt o f PFASs. R elative ra n k in g o f each A P E C to facilitate e v a lu a tio n o f fu tu re a c tio n (e.g., allo ca tio n o f resources o r im p lem en tatio n o f b est m an ag em en t practices). D ata gaps th a t n eed to b e filled to ch aracterize in d iv id u al A PE C s an d develop a CSM . T he M A PA S creening T ool p rovides airp o rt m anagers w ith a seq u en tial an d system atic ap p ro ach to identifying A PEC s o n an a irp o rt p ro p erty . C onceptually, th e M A PA S creening T ool w o rk s progressively alo n g tw o se q u en tial phases, o r m o d u le s, as follow s: M o d u le 1 focuses o n the a irp o rt p ro p e rty as a w hole an d identifies actual o r p o ten tial sources a n d /o r activities in v o lv in g A FFF a n d PFA Ss. A t th e a irp o rt scale, th e p o te n tia l p resen ce o f o ff-site so u rc e s o f P FA Ss a n d se n sitiv e re c e p to rs is also c o n s id e re d . M o d u le 2 fo c u se s o n th e A P E C s id e n tif ie d in M o d u le 1. T h e M A P A S c re e n in g T o o l c a n b e used to evaluate each A PE C b ased o n A PE C -specific features related to th e m an ag em en t o f A FFF an d im p acts o f PFA Ss in th e en v iro n m en t. T h e M A PA S creening T o o l w ill score A PEC s for fu rth er evaluation/action. T o facilitate use o f th e M A PA S creening T ool, a "Q u ick G u id e" has b een p ro v id ed in A p p en dix C o f this report. 6.1.2 How to Use the Screening Tool T h e M A PA S creening T o o l has b een designed so u sers can rely o n readily available in fo r m a tio n to c o m p le te th e sc re e n in g effo rt. I f in fo rm a tio n is n o t k n o w n , o r o th e rw ise u n a v a ila b le , th e M A P A S creening T o o l w ill flag th e m issin g in fo rm a tio n as a p o te n tia l d a ta gap, w h ich th e n can b e applied b y th e u ser for fu tu re planning. D ata fro m previous en v iro n m en tal site assessm ents o r o th e r in tru siv e investigations are n o t req u ired to use th e M A PA S creening T ool. T he M A PA S creening T ool has b een designed for a irp o rt representatives fam iliar w ith A FFF m an ag em en t an d im pacts o f PFASs at an airp o rt. As know ledge an d responsibilities related to 68 Copyright National Academy of Sciences. All rights reserved. US00004653 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 69 A FFF a n d /o r PFASs m ay exist am o n g different d ep a rtm en ts at an a irp o rt, collab o ratio n am o n g th e m e m b e rs o f d iffe re n t fu n c tio n a l d e p a rtm e n ts is b en e ficia l fo r w o rk in g w ith th e M A P A S c ree n in g T o o l to g a i n a h o l i s t i c u n d e r s t a n d i n g o f a n a i r p o r t 's le v e l o f p o t e n t i a l r is k . F o r e x a m p le , A F F F m a n a g e m e n t th ro u g h th e life cycle stages (i.e., p ro c u re m e n t, sto rag e, u se, testin g , m a in te n a n c e , a n d d isp o sa l) is ty p ic ally th e re sp o n sib ility o f e m e rg e n c y re sp o n se p e rs o n n e l, a n d a d d re ssin g legacy im p a cts in th e e n v iro n m e n t (i.e., c o n ta m in a tio n o f soil, g ro u n d w a te r, se d im e n t, a n d /o r su rfa c e w a te r w ith PFA Ss) is ty p ic ally th e re sp o n sib ility o f th e d e p a rtm e n t(s ) re sp o n sib le fo r en v iro n m e n ta l issues. T h e M A P A S creen in g T o o l also allow s th e u se r to c o n sid er w h e th e r fu tu re p ro jects (e.g., cap ital im p ro v e m e n t pro jects) m ay be affected. F or exam ple, airp o rts im p acted w ith PFASs m ay face u n ex p ected an d costly re m e d iatio n actions to address im p acted soils o r g ro u n d w a te r en c o u n te re d d u rin g a cap ital im p ro v e m e n t p ro je c t (e.g., costs asso ciated w ith th e p ro p e r d isp o sal o f im p a c te d soil o r g ro u n d w a te r, such as d ew aterin g d u rin g co n stru c tio n ). 6.1.3 MAPA Screening Tool Architecture T h e M A P A S c re e n in g T o o l is a M ic ro s o ft E x celTM -b ased to o l th a t w alk s th e u se r th r o u g h a series o f questions associated w ith tw o m odules. M o d u le 1 addresses c o n te n t related to th e airp o rt. M o d u le 2 is m o r e sp e c ific a n d ask s q u e s tio n s r e la te d to e a c h A P E C id e n tifie d in M o d u le 1. T h e details associated w ith each m o d u le are p resen ted in su b se q u en t sections. 6.1.3.1 H o w to Use the M APA Screening Tool in M icrosoft ExcelTM T h e M A P A S c re e n in g T o o l w o rk s b e st w h e n u se d in M ic ro s o ft ExcelTM 2010. If M ic ro s o ft ExcelTM 97 to 2 0 0 3 , o r 2 0 0 7 , is b e in g u se d to r u n th e sc re e n in g to o l, th e v e rsio n o f th e sc re e n in g to o l th a t is c o n ta in e d in th e file e n title d "M A P A S c re e n in g T o o l C o m p a tib ility V e rs io n " s h o u ld b e u se d . If r u n n in g a m o re re c e n t v e rs io n o f M ic ro s o ft E xcelTM , u se th e file e n title d "M A P A S cree n in g T o o l." W h e n first o p e n in g th e file, if a se c u rity w a rn in g a p p e a rs saying th a t m a c ro s have b een disabled, click "E nable c o n ten t." T he w o rk b o o k co n tain s n u m e ro u s fo rm u las an d m a c ro s to m a k e th e M A P A S cree n in g T o o l u se r frien d ly . U sers s h o u ld o n ly e d it cell c o n te n t w h e r e p r o m p t e d ; t y p i n g in a c e ll w i t h a f o r m u l a o r o t h e r t e x t w ill a d v e r s e ly i m p a c t M A P A 's fu n ctio n ality . T he M A PA S creen in g T o o l leads th e u se r fro m o n e w o rk sh eet to th e n ex t seq u en tially , as n eed ed ; filling o u t every w o rk sh eet in th e screen in g to o l m ay n o t be req u ired for every airport. 6.1.3.2 Macros Security T he M A PA S creening T ool consists o f m u ltiple w orksheets an d em bedded m acros. M acros au to m ate freq u en tly u sed tasks; th e ones u sed in th e M A PA S creening T ool are created w ith V isual B asic fo r A p p lic atio n s a n d have b ee n w ritte n b y D illo n C o n su ltin g L im ited specifically fo r the M A PA S creening T ool. W h e n users first o p en th e M A PA S creening T ool, m acro s need to b e en ab led fo r th e p ro g ra m to fu n c tio n a n d carry o u t its tasks. S om e m acro s p o se a p o te n tia l secu rity risk. A p e rso n w ith m alicio u s in te n t can in tro d u c e a d e stru c tiv e m a c ro in a d o c u m e n t o r file, w h ic h c a n sp re a d a v iru s o n c o m p u te rs. In M ic ro so ft O ffice ExcelTM , u se rs ca n c h a n g e th e m a c ro se c u rity se ttin g s to c o n tro l w h ic h m a c ro s ru n a n d u n d e r w h a t c irc u m s ta n c e s w h e n a w o rk b o o k is o p e n e d . T h e fo llo w in g ste p s d isc u ss h o w to enable m acros. W h en first o p en in g th e p ro g ram , a p o p -u p w in d o w g enerally p rovides th e u ser w ith an o p tio n to e n a b le m a c ro s. I f th e re is n o p o p -u p w in d o w , o r if th e u s e r h as a c c id e n ta lly click ed " d o n o t enable m a cro s," th e u se r sh o u ld refer to th e o n lin e in stru c tio n s p ro v id ed b y M icro so ft O ffice for Copyright National Academy of Sciences. All rights reserved. US00004654 Use and Potential Impacts of AFFF Containing PFASs at Airports 70 Use and Potential Impacts of AFFF Containing PFASs at Airports th e a p p ro p ria te v e rsio n o f ExcelTM : h ttp s://su p p o rt.o ffic e .c o m /e n -u s/a rtic le /E n a b le -o r-d isa b le m a c r o s - i n - O f f i c e - h l e s - 1 2 b 0 3 6 f d - d l 4 0 - 4 e 7 4 - b 4 5 e - 1 6 f e d l a 7 e 5 c 6 # __ t o c 3 1 1 6 9 8 3 1 0 . T ypically, th ese in stru c tio n s p ro v id e d b y M ic ro so ft O ffice in c lu d e th e follow ing step s (w ith v a ria tio n s o n n a m in g c o n v e n tio n s , e.g., File T ab v ersu s M ic ro s o ft O ffice B u tto n ). M ic ro s o ft O ffice p ro v id es a d isclaim er o n th e risks associated w ith ru n n in g m acro s fro m u n k n o w n sources. T he steps are C lick th e M ic ro so ft O ffice B u tto n (o r File T ab ), a n d th e n click Excel O p tio n s. C lick T ru st C en ter, click T ru st C e n te r S ettings, an d th e n click M acro S ettings. C lick th e o p tio n s th a t y o u w an t: E nable A ll M acro s (n o t re c o m m e n d e d , p o te n tia lly d a n g e ro u s co d e ca n ru n ). C lick th is o p tio n to allow all m acro s to ru n . T h is se ttin g m ak es y o u r c o m p u te r v u ln e ra b le to p o te n tia lly m a lic io u s c o d e a n d is n o t r e c o m m e n d e d . 6 .2 M o d u le 1--A ir p o r t Scale E v alu a tio n M o d u le l o f th e M A PA S creening T ool provides a rap id assessm ent for users to identify w h e th e r th e y h a v e a p o te n tia l c o n c e r n th a t n e e d s to b e e x p lo re d a t th e ir a irp o r t. If a n A P E C is id en tified , th e lo c a tio n a n d n a tu re o f th e area (e.g., k n o w n rele ase /a p p lica tio n , in c id e n ta l/lim ite d release, o r historically co n tain e d storage u n it) are d o cu m en te d . M o d u le l focuses o n id en tificatio n o f th e follow ing: A reas o n th e a irp o rt p ro p erty , b o th th o se associated w ith a irp o rt o p era tio n s an d ten an ts, w h e re A FF F (c o n ta in in g P F A S s) is c u rre n tly o r h a s h is to ric a lly b e e n s to re d , u s e d /a p p lie d , tested, h an d led , m anaged, o r disposed. A reas o n th e a irp o rt p ro p e rty w h ere th e re w ere accid en tal u n c o n tro lle d spills o r releases o f AFFF. O th er p o ten tial sources o f im pacts o f PFASs (o th er th a n A FFF) to th e en v iro n m en t o n o r near the airp o rt property. A dditionally, M o d u le l screens for p o te n tia l sensitive recep to rs at an d in th e vicinity o f the a irp o rt. B e in g f a m ilia r w ith th e A F F F life cy c le (s h o w n in F ig u re 6 - l ) a t a n a i r p o r t is c ritic a l to identifying and u n d erstan d in g A PEC s. If an airp o rt has never stored, tran sp o rted , or used AFFF, th e a irp o r t is u n lik e ly to h a v e a c o n c e rn a s so c ia te d w ith A F F F o r P F A S s, a n d th e re w ill b e few er w o rk s h e e ts to fill o u t in th e M A P A S c re e n in g T o o l. H o w e v e r, fo r a irp o rts th a t a re /w e re re q u ire d to have firefig h tin g services a n d u se A FFF (b y th e ir respective federal agency, i.e., FA A o r T ra n sp o rt C a n a d a ), u n d e rs ta n d in g h o w A FF F is (a n d h as b e e n ) p ro c u re d , s to re d , h a n d le d , d is trib u te d , tested, applied, an d disposed o f w ill help to identify A PE C s at th e airp o rt. Procurement Storage Maintenance Use./Testing Figure 6-1. AFFF life cycle stages. Training Containment Treatment/Olt-Site Disposal Copyright National Academy of Sciences. All rights reserved. US00004655 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 71 A PEC s w ill b e id en tified as th o se areas o f th e a irp o rt th a t have, o r have h ad , activities th a t co u ld resu lt in im p acts to th e e n v iro n m e n t fro m A FFF o r PFA Ss. A PE C s are likely to in c lu d e (b u t are n o t lim ited to ) areas o f A FFF storage, firefighting train in g , an d historical em ergency resp o n se in v o lv in g A FFF a p p lic a tio n , as w ell as e q u ip m e n t a n d in fra stru c tu re u sed in A FFF application, eq u ip m en t an d system testin g areas, an d disposal areas. W h ile A FF F is th e p rim a ry fo cu s o f th e M A P A S c re e n in g T o o l, th e re are o th e r p o te n tia l so u rces o f PFA Ss, as d etailed in S ectio n 2.2 th a t are also c o n sid e re d b ec au se th e y m a y in flu e n ce th e id en tificatio n an d p rio ritiz a tio n o f A PEC s. T hese so urces in clu d e th e follow ing: Aviation and/or industrial components. F lu o r o p o ly m e r s s u c h as P T F E a re u s e d e x te n s iv e ly in v ario u s e q u ip m e n t c o m p o n e n ts (e.g., se m ic o n d u c to rs, w irin g , tu b in g , p ip in g , seals, gaskets, an d cables). In ad d itio n , th e salts o f su lfo n ated PFA Ss (p rim arily P FO S) have b een u sed as a d d itiv e s w ith a c o n te n t o f a b o u t o r less th a n 0.1 p e rc e n t in h y d ra u lic flu id s /lu b ric a n ts to p rev e n t e v a p o ratio n , fires, an d co rro sio n . Metal plating operations. A lth o u g h m e ta l p la tin g o p e r a t i o n s m a y n o t b e d ir e c tly a s s o c ia te d w ith th e aviation industry, such operations are one o f the m o st im p o rtan t ongoing uses o f p ro d u c ts c o n ta in in g PFA Ss a n d are typically situ a te d w ith in in d u stria l zones th a t m ay be lo c a te d n e a r la rg e r a irp o rt facilities. A n a m m o n iu m sa lt o f P F O S is u se d in m e ta l p la tin g . T h e re is p o te n tia l fo r re sid u a l c o n c e n tra tio n s o f o th e r PFA Ss in th e P F O S p ro d u c ts u se d fo r m etal p latin g , as th ey are n o t alw ays 1 0 0 -p ercen t chem ically p u re. Herbicide/pesticide application. N o n - p o l y m e r ic P F A S s h a v e b e e n u s e d as a c tiv e in g r e d ie n ts in som e p lan t grow th regulators an d herbicides an d as in ert ingredients in pesticide fo rm ulations (e.g., a n t b a its). A PEC s can result fro m te n a n t activities (possibly sim ilar to those described above) o r b e located off-site. If an y o f these activities/sources o f PFA Ss are k n o w n to have o ccu rred o n o r in th e vicinity o f th e a irp o rt p ro p erty , the user o f th e M A PA S creening T ool sh o u ld include this in fo rm atio n , to th e extent k n o w n , to gain a m o re holistic u n d erstan d in g o f po ten tial sources th a t could affect co n cen tratio n s o f PFASs in v arious m edia o n o r n ear th e airp o rt. A lth o u g h site-specific, off-site im pacts o f A FFF an d PFASs m ay affect resources an d sensitive receptors o n th e a irp o rt property. T he M A PA S creening T ool includes q uestions fo r users th a t have b een designed to ascertain w h e th e r p o te n tia l so u rces o f A FFF (an d PFA Ss) reflect o n g o in g , active o p e ra tio n s o r legacy issues, o r b o th . T he o u tc o m es o f M o d u le 1 in clu d e th e follow ing: Identification o f w hether PFASs m ay be a concern. A n u n d e rs ta n d in g o f th e A FF F life cycle a t th e a irp o rt. In fo rm a tio n necessary to develop a geo-referenced, g eo g rap h ic-in fo rm atio n -sy stem (G IS)- enab led m a p o f th e a irp o rt p ro p e rty th a t dep icts id en tified A FFF sou rces, release sites, o th e r A PEC s (b o th o n an d o ff th e a irp o rt p ro p erty ), an d lo catio n s o f p o te n tia l sensitive recep to rs (e.g., p o ta b le w ells, su rface w a te rb o d ie s , a n d w e tla n d s). C a te g o riz atio n o f A P E C s as o p e ra tio n a l (i.e., related to a irp o rt o p e ra tio n s a n d th e re fo re th e p o te n tia l risk to h u m a n h ea lth a n d th e e n v iro n m e n t can be p ro activ ely m an ag ed ) o r legacy (i.e., im p a cts o f PFA Ss are p re s e n t in th e e n v iro n m e n t a n d n e e d to b e m a n a g e d " reactiv ely " ). T h e b a l a n c e o f t h i s s e c t i o n w a lk s t h e u s e r t h r o u g h e a c h s te p (i.e ., w o r k s h e e t ) o f M o d u l e 1. 6.2.1 Entering Module 1 Information T he first w o rk sh eet o f th e M A PA S creening T ool, called th e In tro d u c to ry W o rk sh eet, collects basic in fo rm a tio n a b o u t th e a irp o rt a n d th e users involved in co m p letin g th e M A PA S creen in g Copyright National Academy of Sciences. All rights reserved. US00004656 Use and Potential Impacts of AFFF Containing PFASs at Airports 72 Use and Potential Impacts of AFFF Containing PFASs at Airports T o o l process. T h is in fo rm a tio n w ill b e in c o rp o ra te d in to a co v er p age fo r th e d o c u m e n t p ro d u ce d as a resu lt o f c o m p le tin g M A PA . U sers sh o u ld co m p lete th e fields to th e b est o f th e ir know ledge. F ollow ing th e In tro d u c to ry W o rk sh eet, M o d u le 1 consists o f fo u r w o rksheets (it m ay n o t be n ec essary to fill o u t all fo u r w o rk s h e e ts fo r e a ch a irp o rt): M o d u le 1 O verview Q u estio n s M odule 1 A PECs M o d u le 1 Sensitive R eceptors M odule 1 S um m ary D etails o n in p u t are d escribed in th e follow ing. 6.2.1.1 Module 1 Overview Questions Worksheet A fter th e In tro d u c to ry W o rk sh eet, users b eg in th e M A PA S creening T o o l o n th e seco n d w o rk sh eet o f th e screen in g to o l, M o d u le 1 O verview Q u estio n s, w h ich consists o f tw o tables: (1) A PE C s an d (2) P o te n tia l S ensitive R ecep to rs (see F igure 6 -2). O n th is w o rk sh eet, u sers w ill id e n tify o n -site a n d off-site A PE C s a n d sensitive rec ep to rs. T h e ta b le cells hav e b e e n sh a d e d to categorize data: In fo rm a tio n asso ciated w ith o n -site A P E C s w ill b e e n te re d in cells co lo re d b lu e. In fo rm a tio n a sso cia te d w ith o ff-site A P E C s w ill b e e n te re d in cells c o lo re d green. In fo rm a tio n asso ciated w ith sen sitiv e rec ep to rs w ill b e e n te re d in cells co lo re d gray, w h ite , and red. T h e u se r w ill b e d irec ted to th e o th e r in p u t w o rk sh eets fro m M o d u le 1 O verview Q u estio n s. H '- rii'V '- MiiJult; 1 Lhftniiw ufc&ft* - IcJisrAitiHi'i. ut Pfiltrilial nurMiuwnll CtitsciiTi Mid Kiiiti-rt rtmapkitt T- -..r- !,'( -r.* v ..v r ii - v w r ' l ' f l ' - " m i- e -.-iT flfn -.11- f r ,, V W 1? ' / f - v r, n r , H y - 'V ivM fS ' v -j .. 'In'." m .r-v - v H I f r r "i yIi.v -ij Figure 6-2. Module 1 Overview Questions screenshot. Copyright National Academy of Sciences. All rights reserved. US00004657 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 73 In stru ctio n s to guide users th ro u g h M o d u le 1 are th e follow ing: 1. S ta r tin g w ith th e A P E C s ta b le lo c a te d o n th e le ft s id e o f th e M o d u le 1 O v e rv ie w Q u e s tio n s sc re en , u se th e cells in th e "Y our R esp o n ses" c o lu m n to an sw e r th e q u e stio n s p o se d in th e "Q uestions" colum n. 2. A n sw er each q u e s tio n w ith in o n e co lo r b lo c k (e.g., b lu e ) a n d th e n follow th e d ire c tio n s in th e "N ex t S teps" co lu m n (see F igure 6-3). 3. W h e n listin g resp o n sib le p a rtie s/c u sto d ia n s (e.g., a irp o rt p ro p e rty te n a n ts ), b e g in in th e c e ll b e l o w "A i r p o r t . " T h e s e r e s p o n s i b l e p a r t i e s / c u s t o d i a n s w ill b e c o m e a d r o p - d o w n lis t o n an o th er w orksheet. T his list n eed n o t be lim ited to a irp o rt ten an ts; if th ere are o th e r custodians o r p a rtie s re sp o n sib le fo r A FFF im p a cts, th e y s h o u ld b e listed as w ell. A fter g o in g th ro u g h th e n ex t steps an d filling o u t th e fo rm fo r each co lo r g ro u p , u sers w ill n eed to re tu rn to th e A PEC s "o n -site" table an d co m p lete in stru c tio n s fo r th e n ex t colo r gro u p . R ep eat fo r th e rest o f th e tab le a n d specify th e u n its o f d istan ce (i.e., e ith e r E ng lish o r m e tric) fo r use in th e M A PA S creening T ool. U p o n filling o u t th e in fo rm atio n fo r th e A PEC s table in th e M o d u le 1 O verview Q uestio n s w orksheet, users sh o u ld follow th e directions pro v id ed , as show n in F igure 6-3. U p o n co m p letio n o f th e A PEC s table in th e M o d u le 1 O verview Q uestions w orksheet, users sh o u ld answ er th e q u estio n s in th e P o ten tial Sensitive R eceptors table (o n th e rig h t h a n d side o f th e w o rk sh eet). Specifically, th e cells in th e "Y o u r R esp o n ses" c o lu m n sh o u ld b e u se d to an sw er Aliai ilJutiiijlijJLirtiionnisriLuLMiCnm (AJ'LUI l . i r t A H iMn| ir j Iv'-* t i i n l <|( .0.1 <|C| li n: , xiur*:i;,<uf F'*FA' 1Vmwn Iti.Hl'p ir 'MiIK'Ir jf o fj ( v K * W' iniHnlururKrC rn w l vi rifj; hydi ju lic "tm mtw^rifssr jwAiayiP*LnArBun"l.,ij............................................ I* I \~\\'S'-! iitliip Ifcii t SWECuwwtalwii. Citai ftfn. Of Af'JT .IPK c KHq' ^r.cnckBtu ii.n'Le1ei"r})fM'Ii"/l Aj i ,)n<i of Ih fi lu tln w in q nc1iv.itieri km lhjr fit h e r mm n i i>g`AC. VfUiWFl IjCi fXM ft iCHIffJisS kJKi'Lq ki n.'k.krkr1i1'mi|l IeI ki i il,'ill'hk.k. >k ukkrlk|i1"j ki'kkkli'I*J'I| krkk kck'jik Lii'rJk'km'ki_a IrIIuuJli,kni"Lk 'mkkllh'kk'k. rkk ik rU'r.Ikrkmk.I' v1i_rllfi'kck'ljL TIVrIIIi'HJllI. 11JlMil.:!iHIHiIE, rimiIHIIlITI XMl14'III rq31MIE.risKill, (S elec t the u n i s l'or eli efesio n c e s u s e d ihMJ^hcMil this factae-nina t o c !______________________________________ wfetoc Figure 6-3. Module 1 Overview Questions categorization. ' ] T'Ofihriiift1!Ilifi CMUkPVSlI MfWiPlIllilfi Copyright National Academy of Sciences. All rights reserved. US00004658 Use and Potential Impacts of AFFF Containing PFASs at Airports 74 Use and Potential Impacts of AFFF Containing PFASs at Airports Afc there municipal putable wells- located in the vicinity of the airport? Nc? Do not fiII out the Potable Water Sources table on the iw-ad i sensitive Receptors worksheet and continue to the next ffues-tion. Is the airport and/or the sunrouncfing are servlced byasurface water Intake? Not Are surface water bodies present on airport property? Are surface wafer bodies located within a 1 mil e or 1 kilometre radios of airport [imuertY? yes Please fill out the Stufate Walet Bwlh table on the Mod 1 Sensitive Receptor worksheet, dick here. Are welldric.h preterit c.in the airport property? Are wetlands located within 3 1 mile or 1 kilometre iadius of airport property ? Ko ve Pjg*is<_________ n ^ j ^ h &............. a t i i l titeM, Figure 6-4. Screenshot of completed Potential Sensitive Receptors table on the Module 1 Overview Questions worksheet. the questions posed in the "Questions" column to the left. The user should only complete the action listed in the "Next Steps" column after answering all the questions within a single color block (e.g., blue) (see Figure 6-4). If a potential sensitive receptor is identified based on a user's input to the Potential Sensitive Receptors table on the Module 1 Overview Questions worksheet, the user will be directed to tables specific to the category of receptor. Each sensitive receptor category (i.e., potable water sources, surface water bodies, and wetlands) is described below. 6.2.1.2 Module 7 APECs Worksheet APECs are categorized as "on-site" or "off-site." Specific details for each APEC are identified in "on-site" or "off-site" worksheets, as described in the following sections. APECS--Airport The purpose of this table is to gain a basic understanding of the life cycle of AFFF at an airport and specific locations of potential concern, if any exist. The table lists the AFFF life cycle stages and requires the user to provide the location, activity, and responsible party associated with AFFF on the airport property (see Figure 6-5). Copyright National Academy of Sciences. All rights reserved. US00004659 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 75 In j( ru c tio n s f 'i c n r `pi -</ > ic* ->v<xi L '- i" c x d p r o yr.vsr : st/ x '-,-iir in.,-*. 'i j a ? ''r t c y . ' y v jn v y --1 /.fi r ' i a O t/jr t n f / i-. -i ! ! >'I ? * r r P i.cy: 7n f j i . . i Y i . ! i n `i / | . n : ! Lit* tjpcki t (>uiLuu ,. rnFUU f Whni* ix AFFF' O no ... Cunml Operations *w Cl . -- ------------------------------------ - v S 7 F ........................................... 'r-fcy . - c n r i - e Ti-e 'Z . t 'r^t f x r e er-H-ere - r r i>-. yy<.-} >:?> r afft rce-.y y - 5 7r;*ri Hu*fancl IJ|inraliri3 gii <fafPnrni lioncurrent] L.-.if .< A,.-|,, : i aii, . .. :":>:V-:1 . : te * 1t AFTF ured 1 t e (tunoiff ."'--`.A ^ " vif'.'.-- a.i..-,- -vr^i hw liue*.s ;; Kksctefrjt! jnrDf tem>r*j r* A n t 7 MIHTCNAWCG -s.-H-.' -V -fc* ' .Ar-.* V.'ir jit J'.r fV.- ..3if'-X? |la ftF'FFfrom Ite ottpert i .........................................1..........................................f......................................... :. (j ; : j] Ais ui iffc?!tm v m m fcm-wnlo occur on (he PI It t-NIlAi WtaiMkl or Pf AS -.fr-,>-.v -.kk.- . .y:*-.... -.V . .}.f < -- APHIOn Site APbC Off-fit? . .- Figure 6-5. APECs--Airport table in Module 1APECs worksheet. ; . ' : - - ..... - - ; . : - : ----- . - i In the table: Cells in the location column allow users to type the name of the on-site APEC as it will be identified going forward in MAPA. Cells in the activity column, except those associated with the storage life cycle stage, are to be populated from drop-down lists. Cells in the responsible party/custodian column are to be populated with drop-down lists that are generated from the responsible parties/custodians identified in the Module 1 Overview Questions worksheet (see Figure 6-6). If, at this stage, a user realizes they have forgotten a responsible party/custodian (e.g., a new tenant) that should be listed, they can return to the Module 1 Overview Questions worksheet and add them to the list by using the worksheet tabs at the bottom of the screen. The MAPA Screening Tool has been designed to differentiate between current operations and historical operations for two reasons. First, the user's knowledge of and the information available for current and historical operations may vary; sometimes the user will have no information about a historical application or operation. Second, how an airport may or can act (e.g., implementing best management practices) will be different for current operations than historical operations. Consequently, MAPA asks the user to distinguish between cur rent operations and historical operations on this input table. Use the "Historical Operations" section if AFFF activities have occurred in a location that is not currently used/exposed to AFFF. For example, if AFFF training occurred in a specific hangar in the past, but now occurs at a designated firefighting training area, the hangar would be listed under the "Historical Operations" section and the firefighting training area would be listed under "Current Opera tions" section. Copyright National Academy of Sciences. All rights reserved. US00004660 Use and Potential Impacts of AFFF Containing PFASs at Airports 76 Use and Potential Impacts of AFFF Containing PFASs at Airports Figure 6-6. Responsible party/custodian lists generated from the Module 1 Overview Questions worksheet presented in a drop-down menu in the Module 1APECs worksheet. For activities on the drop-down list for the AFFF life cycle stage labeled "Use," the options of "incident response" and "accidental release" are available under the "Historical Operations" section only. This is because these are events that have already happened and are not considered to be current. APECs-- Off-Site The purpose of this table is to gain a basic understanding of the life cycle of AFFF in the vicinity of the airport and evaluate whether any locations ofpotential concern exist. The table lists the AFFF life cycle stages and requires the user to provide the location, activity, and land use type associated with AFFF on the property in the vicinity of the airport. The table has been constructed similarly to the table previously discussed and is located in the same worksheet. Please note: Cells in the location column allow users to type the name of the off-site APEC as it will be identified going forward in the MAPA Screening Tool. Cells in the activity column, except those associated with the storage life cycle stage, are to be populated from drop-down lists. Current operations and historical operations are considered unique. Use the "Historical Operations" column if AFFF activities occurred in a location in the past where they do not currently occur. 6.2.1.3 M odule 1 Sensitive Receptors W orksheet Upon completing the Module 1 APECs worksheet, users should return to the Module 1 Overview Questions worksheet to address potentially sensitive receptors. Module 1of the MAPA Screening Tool considers potentially sensitive receptors at the airport scale. If AFFF and/or other APECs related to PFASs are identified at or near an airport, recognizing the presence of Copyright National Academy of Sciences. All rights reserved. US00004661 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 77 potentially sensitive ecological receptors is critical to evaluating the potential level of concern and ranking/prioritizing individual APECs. Questions focus on identifying key receptors (or receptor habitats) of interest, i.e., potable wells, surface water bodies, and wetlands. Releases of small amounts of AFFF containing PFASs to the environment could significantly impact environmental media, wildlife, and potentially human populations as some PFASs are very persistent in the environment and bioaccumulate in living organisms. Many PFASs are water soluble and will ultimately be transported to groundwater or surface water bodies, providing potential exposure to sensitive receptors. The MAPA Screening Tool identifies receptors (or receptor habitats) that are on, in relatively close proximity to, or down-gradient of the airport property and/or APECs previously identified. Potable water sources, or drinking water sources, if impacted by PFASs, may present an unacceptable risk to human health via ingestion. The following drop-down list options in the first column of the Potable Water Sources worksheet can be used to describe the type of potable water source: Potable well: groundwater Municipal water well supply: groundwater Surface water body: A surface water body (e.g., lake or river) that is used as a source of drinking water The user should identify each potable water source by assigning a location name and indicating, if known, the proximate distance to the nearest APEC previously identified. Surface water bodies (in addition to being a potential potable water source) also represent a potential habitat for sensitive receptors. The user should identify the type of surface water body (e.g., lake, river, stream, pond, ocean, ditch) using the drop-down menu, assign a location name, and indicate, if known, the proximate distance to the nearest APEC previously identified. Wetlands, like surface water bodies, represent a potential habitat for sensitive receptors. Types of wetlands vary, but the user is encouraged to characterize the type of wetland using the basic descriptions provided in the screening tool using the drop-down menu. The user should identify each wetland by assigning a location name and indicating, if known, the proximate distance to the nearest APEC previously identified. If, upon the completion of the two tables the user is still on this worksheet (Module 1 Overview Questions), click the yellow button below the Potential Sensitive Receptors table to continue on to the next applicable worksheet. If the user is on another worksheet, then do not return to this worksheet, use the yellow button at the bottom of the worksheet to continue to the next worksheet in the screening tool. The output from Module 1 lists the identified APECs and sensitive receptors at the airport. The output is generated and presented in one worksheet, Module 1 Summary, which is divided into two tables: (1) APECs and (2) Sensitive Receptors. The following sections describe how to generate this output. 6.2.1.4 M odule 1 Sum m ary W orksheet--A P E C Table This summary worksheet describes the APECs identified on-site and off-site in relation to life cycle stage and type of activity. Additionally, with user input, the coordinates of each APEC can be added to allow for APECs to be geo-referenced on a map (as presented in the GIS Summary worksheet). To generate the list of APECs, click the button labeled Press to Start at the top of the worksheet before entering any data on this worksheet. The table will self-populate with the location name Copyright National Academy of Sciences. All rights reserved. US00004662 Use and Potential Impacts of AFFF Containing PFASs at Airports 78 Use and Potential Impacts of AFFF Containing PFASs at Airports provided for the APEC, its associated life cycle stage, and the type of activity. If using the compat ibility version of the tool, press Crtl, Shift, and F to activate the macro that populates the table appropriately. In order to further characterize the APEC associated with current operations or a legacy envi ronmental impact, users should answer the question posed in the column to the right of the "Type of Activity" column for each APEC (i.e., Is the APEC associated with past release into the environment?) using the drop-down list provided. Please note that for some activities, the corresponding cell is pre-populated based on previous input data (in an effort to make using the screening tool more efficient). Ifthe user has knowledge that calls into question the pre-populated answer for a particular APEC, the response in the cell can be changed using the drop-down list. For example, if AFFF was stored in Hangar 4, the cell will be populated with the answer "No" because, in most cases, storage locations are not involved with releases ofAFFF into the environ ment. However, if AFFF was spilled at the storage location or a storage container was leaking, the user should switch the answer to "Yes" so that on a subsequent worksheet the user will be prompted to provide more information about the release (see Figure 6-7). To generate a data table suitable for using in GIS and mapping the location of APECs (as discussed below), enter latitudes and longitudes of identified APECs in decimal degrees in the columns on the right. The "Location Name for GIS" column is populated with the name chosen for the APEC or sensitive receptor when it was first identified. In order to use these location names in ArcGIS, however, special names that don't include spaces are required. The MAPA user or a GIS specialist should replace the location names with those that are appropriate for ArcGIS (e.g., Hangar 4 could become Hangar_4) in the first column ("APEC") of the table. Visual representation helps identify potential omissions with regard to both APECs and sensitive receptors and fosters the development of a CSM, which can be used to understand and address legacy impacts of PFASs at the airport. In addition, from a capital project planning M odule 1 Sum m aru Sheet - A P E C In s tru c tio n s : Th is worksheet is auto-populated with information provided in previous worksheets. Press the button below before entering any data on this worksheet. Please fill in the latitudes and longitudes in decimal degrees. Also use the drop-down list to answer the question: "Is the OPC associated with past release into the environment?" Life C ycle Stage Typ e of Activity Press to Start A ctiv ity Is the A P E C a sso cia te d with p ast rele ase into the environm ent? R esp o n sib le Party L a titu d e G IS L o n g itu d e Lo ca tio n N am e For G IS Figure 6-7. Screenshot of the APEC table on the Module 1 Summary worksheet. Copyright National Academy of Sciences. All rights reserved. US00004663 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 79 Phase I Swnmtirv Sheai - APEC Instructions: This page is auto-populated with information provided in previous page $. Press the button below before entering any data on this page. Please fill in the Eatfttides and longitudes in deci mal degrees. Also use the drop-down list to answer the question: " is the AOPC associated with past release into the environment?' APEC life Cycle Stage hr* Department Building 1 H ing I Fin&fififitiris TrainingAsi I 1 M.Suir.vw? Mif.tr.tuJft*fl.Ctutiffg>S-r>tC m1 Manufacturing Site 2 ik o n jj. Use use Use Other Other Press S ta r t Type of Activity Sloiagt Training Incident response Mmie*Ulafii prsilikiti.rrli:g opetostiorrs Mets! plating operations Activity is f lit APEC associated with past raten* into the environment? Mo No Ves S V No latitude *75.2393527 -75.2*7*1628 -75.217941 Longitude 3?>CSS-X1-S3 / 3300 39.35-9S8941 3*.*6O991#9OJ0 39.3&32GS4213Q 39.8M 03W 7SO Figure 6-8. Screenshot o f a com pleted and com piled A PE C table. perspective, understanding where impacts of PFASs in soil and groundwater may be present is important because special handling, treatment, and/or disposal may be required (potentially at signibcant cost) for soil and groundwater impacted by PFASs (e.g., dewatering). See Figure 6-8 for an example of a completed APEC table. 6.2.1.5 M odule 1 Sum m ary W orksheet-- Sensitive Receptors Table The Module 1 Summary Worksheet Sensitive Receptors table summarizes all the sensitive receptors identibed previously based on the type of receptor (see Figure 6-9). fnsiTuednrKS, Tnr, mirkshscl'is .* jfo w p ii,5ted Maduic- 1 Sum m ary Sheet - Srenaitiwe Ftccgjafcnra in /c ir r ^ s r [ur - -i'C I - r rr -- ih - - rn- N ' prfnrr' ~n'ri(r,9 n c i u c i - i - w -ri ih - '- iill m r-lri-.fr- m c ln - ij -..d Figure 6-9. Screenshot o f the Sensitive Receptors table on the M odule 1 Sum m ary Sheet prior to data retrieval. Copyright National Academy of Sciences. All rights reserved. US00004664 Use and Potential Impacts of AFFF Containing PFASs at Airports 80 Use and Potential Impacts of AFFF Containing PFASs at Airports Click the button labeled Press to Start at the top of the worksheet before entering any data in this worksheet. This worksheet will self-populate with the type of receptor and the location name provided for the sensitive receptor. (See Figure 6-10.) 6.3 M odule EC Scale E valu atio n Module 1 of the MAPA Screening Tool compiles a list of identified APECs and sensitive receptors. Module 2 facilitates a detailed desktop characterization of each APEC identified in Module 1. Module 2 also provides a ranking associated with each APEC to facilitate making relative comparisons and prioritizing future action, i.e., either focusing resources on select APECs or evaluating the overall effect of applying best management practices at a given APEC. Finally, Module 2 identifies potential data gaps associated with developing a CSM and having a holistic understanding of potential issues associated with historical and current uses of AFFF and other potential sources of PFASs. Module 2 specifically focuses on the following: Characterizing operational APECs based on their respective AFFF life cycle stage. Characterizing legacy environmental impacts based on release characteristics and site attributes. Ranking each APEC for relative comparison. Identifying data gaps required for further consideration. The outcomes of Module 2 may include the following: Characterization of operational and environmental legacy APECs. Ranking of each APEC. Identification of data gaps needed for additional understanding of the concerns regarding AFFF and PFASs at an airport. Identification of appropriate management practices that, ifimplemented, may reduce an APEC's prioritization ranking. 6.3.1 Entering Module 2 Information Module 2 consists of four worksheets, divided into four categories: operational APECs, legacy APECs, ranking summary, and data gap identification. Operational APECs are characterized via Module 1 Summary Sheet - Sensitive Receptors instructions; This worksheet is auto-populated with information provided in previous worksheets. Press the button below before entering any data on this worksheet t^en fiii ;n the latitudes and longitudes in decimal degrees. Type of Receptor Pond River Ditch Stream Ditch Pond Swamp Press to Start : Sensitive Receptors Location Latitude Pond near Fire Dept. Butldtr River feast end of property} Ditch by Hangar 1 Pilot's Creek fbetween Runways 3 a-d 4', Ditch behind Runway 2 Pond at the nearby hotel Wildlife Refuge Click here once table is complete Longitude 7G.224-G3G3 7G.2GS3G-33 7G.2897GG 7G.2G2SG-92 7G.2712GG01 Location Name for GiS -:-cDj :j I Z3.CJ:3322 Last Uve23.33217333 la : : * r i D li" 23.33213741 -ii-b D e e V 3:J.SfciSjj4G9iHuiiway2 D ilu 33.3743337 Iole 23.33421112 W3c:ife Refuge Figure 6-10. Screenshot o f a com pleted and com piled M odule 1 Sum m ary Sheet listing sensitive receptors. Copyright National Academy of Sciences. All rights reserved. US00004665 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 81 individual worksheets for each of the following AFFF life cycle stages: storage, use, maintenance, and disposal (discussed further in Section 6.3.1.1). The balance of this section walks the user through each step (i.e., worksheet) of Module 2. 6.3.1.1 D etailed A P E C Characterization Upon completion of Module 1, the user will be prompted to consider further questions associated with each APEC that allow for detailed characterization and relative ranking of each APEC. For operational APECs, questions relate to each of the AFFF life cycle stages: specifically, how AFFF is stored, used (including testing, training, and emergency response), and disposed of and how equipment and infrastructure used for distribution and application are maintained and cleaned. For legacy APECs, questions focus on release characteristics, presence of co-mingled contaminants, surface covering, and exposure pathways. Operational APECs Module 2 has a worksheet for APECs (Mod 2 Ops APECs) identified in each operational life cycle stage from Module 1. To initiate the characterization of each APEC identified for each operational stage, click the Press to Start button in the upper left hand side of the screen and the worksheet will automatically populate the table with the names of APECs identified in Module 1 (shown in Figure 6-11). If using the compatibility version of the tool, press Crtl, Shift, and A to activate the macro that populates the table appropriately. For each APEC, the user enters responses to each question on the left using the drop-down lists. Once entered, a score associated with each response will populate the cell to the right of the response. This score is used, in summation with other scores for each APEC, to rank the APEC. Ranking and prioritization are discussed in detail in Section 6.5. Users can perform their own sensitivity analysis by changing their responses and seeing how different inputs affect the APEC ranking. This sensitivity analysis may then be considered in evaluating implementation of future operational and management practices. The final row will contain a score for that life cycle stage and APEC. Once all the questions are completed for all the locations on the worksheet the user is on, the yellow cell at the bottom of the worksheet can be clicked to continue on to the next worksheet. 'pit/l * r.i [What s tit# uH'tmm fcvtt of th Apm t M U ? m pil ti of imi-- 144 Figure 6-11. Life cycle stage scoring on the M od 2 Ops APECs worksheet. Copyright National Academy of Sciences. All rights reserved. US00004666 Use and Potential Impacts of AFFF Containing PFASs at Airports 82 Use and Potential Impacts of AFFF Containing PFASs at Airports The questions posed on the Operational APECs worksheets are mostly related to best manage ment practices: Storage. Questions posed are focused on how AFFF is being stored at the airport and whether there are any inherent risks with the storage methods in place. If containers are currently leak ing or have leaked in the past, the user should identify the location as having a historical release (that could have resulted in a release to the environment, i.e., legacy). The following describes potential responses associated with the drop-down list. Users should enter the response most representative of the condition associated with each APEC: - Covering Enclosed: AFFF storage container(s) are inside a fully enclosed space (four walls and a ceiling). Covered: AFFF storage container(s) are covered from above but are exposed to the elements from the side (e.g., covered by a tarp or located in a building with no walls). Outside or exposed directly to the elements: There is no covering of the storage container(s) (e.g., stored on the edge of a runway). - Containment Double: Storage containers have (at least) secondary containment in addition to the original manufacturer-provided container. Single: AFFF is stored only in the container in which it arrived from the manufacturer. - Flooring Paved: Uncracked paved flooring (e.g., asphalt, concrete). Slightly cracked pavement: 0 to 25 percent of the pavement is cracked or broken. Moderately cracked pavement: 25 to 50 percent of the pavement is cracked or broken. Heavily cracked/broken pavement: More than 50 percent of the pavement is cracked or broken. Earthen: The flooring is not paved and is soil and/or gravel in nature. Use (Application). For the purpose of MAPA, the Use life cycle stage includes training, testing, and emergency response. Questions for this stage relate to how much AFFF is used, what is done with the waste AFFF, and what PPE is used when handling AFFF. The follow ing describes potential responses (i.e., drop-down list) associated with select questions. Users should enter the response most representative of the condition associated with each APEC: - Amount of AFFF used: There are many options in this drop-down list as the amount of AFFF used will vary significantly with the different uses. For example, the amount of AFFF used in a foam test is expected to be significantly less than the amount used to sup press a fire. - Ultimate receiver: Potential responses are listed below. If the ultimate receiver is one of the first four listed, the user should identify the APEC in Module 1under historical operations: Washed down a drain/sewer. Allowed to soak into ground. Evaporated from pavement. Washed into a surface water body/wetland. Disposed off-site by licensed facility. - PPE: AFFF poses inhalation, dermal, and ingestion hazards to those handling the solution; therefore, PPE should be used to minimize potential health effects. This question asks how many types of PPE are regularly used when handling AFFF. Using all the PPE listed is considered ideal because it provides mitigation to the various exposure pathways. - Exposure contact: AFFF poses human health risks; therefore, this category is focused on identifying whether people are being exposed to AFFF without PPE and, if they are, how frequently, as long-term exposure increases the potential health risks. Copyright National Academy of Sciences. All rights reserved. US00004667 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 83 Maintenance. Maintenance of vehicles and deluge systems may result in handling and spills of AFFF. Questions for this stage relate to the frequency of AFFF equipment maintenance, the types of equipment cleaning agents, how AFFF is removed from the equipment, how the equipment is cleaned, and what is done with AFFF removed from the equipment. The following describes potential responses (i.e., drop-down list) associated with select questions. Users should enter the response most representative of the condition associated with each APEC: - AFFF equipment checks: Checking AFFF equipment is a good preventative measure against accidental releases as cracks and corrosion can be identified and resolved before a release occurs. Depending on the jurisdictional regulations for the airport and the frequency of incident response, AFFF and its equipment may not be in regular use; therefore, it may be worthwhile to add checking equipment for malfunctions to airport procedures. - Removal of AFFF from equipment: While for the most part AFFF is left in deluge systems and firefighting trucks after a single use, it may be removed when conducting maintenance on equipment or switching brands of AFFF solution to prevent coagulation. Methods for removal include Mechanical pump: Lowest level of risk as this provides the most control and consistency in the speed of AFFF removal. Manual pump: The risk with this method is a bit higher than with a mechanical pump as there is more room for human error and inconsistent speeds in AFFF removal, which could result in splashing and spills of the AFFF solution. Gravity/drain valve: This method provides the least amount of control over the speed and direction of the AFFF solution and is therefore associated with the highest risk of spilling or splashing the solution on workers. - Cleaning equipment: While for the most part AFFF is left in deluge systems and firefight ing trucks after a single use, it may be removed when switching brands; cleaning out the equipment at this point is common to reduce the risk of residue from the previous brand. Cleaning may involve Rinsing/flushing with water: Rinsing with water implies that clean water (not gray water) is used to flush out build-up/residue in the equipment. Cleaning with water and soap/detergent: Clean water (not gray water) and a soap or detergent is used to remove build-up/residue in the equipment. Rinsing/flushing with a solvent: Due to the chemical nature of PFASs, cleaning equip ment with an alcohol solvent, such as ethanol, is considered the most effective method of removing AFFF traces from distribution systems. - Handling procedures: Handling procedures are strong risk reduction measures when clearly communicated to all those involved in the AFFF life cycle. Methods included in the MAPA Screening Tool are two or more people involved in the handling of AFFF, clear procedural standards for AFFF use and handling, procedural training for those handling AFFF, and ensuring fittings and connections are tight on all AFFF-related equipment. - Ultimate receiver: Potential responses are listed below. If the ultimate receiver of AFFF rinsate and/or AFFF removed from distribution systems is one of the first four listed below, the user should identify the APEC in Module 1 under historical operations: Washed down a drain/sewer. Allowed to soak into ground. Evaporated from pavement. Washed into a surface water body/wetland. Disposed off-site by licensed facility. Disposal. The location of AFFF (as either concentrate or as a mixed formulation) is disposal greatly impacts the potential risk to human health and the environment. A large quantity of AFFF concentrate returned to the manufacturer will not have the same impact as a small quantity of AFFF released directly into a surface water body. Question posed are used to gain Copyright National Academy of Sciences. All rights reserved. US00004668 Use and Potential Impacts of AFFF Containing PFASs at Airports 84 Use and Potential Impacts of AFFF Containing PFASs at Airports a sense of the quantity of AFFF being disposed of and the location of the ultimate receiver of the disposed AFFF. Module 2 Legacy APECs Worksheet Within Module 2, there is a worksheet for APECs identified as legacy, i.e., historical activities that resulted in a release to the environment. On the Module 2 Legacy APECs worksheet, questions are posed to understand the nature of the release, whether other contaminants may have been present that would affect the fate and transport of PFASs in the environment, surface covering, and exposure pathways. To initiate the characterization of each legacy APEC, click the Press to Start button in the upper left hand side of the screen, and the worksheet will automatically populate the table with the names of APECs identified in Module 1. If using the compatibility version of the tool, press Crtl, Shift, and B to activate the macro that populates the table appropriately. For each APEC, enter responses to each question on the left using the drop-down lists. Once a response is entered, a score associated with that response will populate the cell to the right of the response (see Figure 6-12). This score is used, in summation with other scores for each APEC, to rank the APEC. Ranking and prioritization are discussed in detail in Section 6.5. The last row will show a score for that APEC. Once a user has completed all the questions for all the locations on the worksheet they are on, they should click the yellow cell at the bottom of the worksheet to continue onto the next worksheet. The following describes potential responses (i.e., drop-down list) associated with select ques tions on the Module 2 Legacy APECs worksheet. Users should enter the response most repre sentative of the condition associated with each APEC: Release characteristics. Questions in this area are meant to determine the basic facts of the AFFF release. AFFF concentrate is diluted to make the AFFF solution that is actually used for PRrSS TO START In s tru c tio n 's . t i f ij..tto n to the pii lo I rip I. iv .v u ' tAi.JlU'd ,`j ! r a .v o f AFT!" t o t ie or.- o " 'loi'd. J''f.liir eue k,`i,,ci:kvi, f'ivow <:'.k'1Vii.'-'iA ijsirii'i. li!'- .'Ir:"::; :t .,.,! i : "Ta. Release C h a r a c te r is tic s Co-mingle C o n ta m in a n ts Surface Cowering Exposure Pathways Site Fea tu res/5ettin g W a s A FFF fo a m o r AFIFF c o n c e n tra te re le a se d ? What volume was released? W h e n d id the re le a se occur? Foam 11 0 0 t o 5 0 0 galio ns/ 5 7 5 to 1 9 0 0 Before 2010 A H a v e petroleum h y d ro c a r b o n s b e e n k n o w n t o H a v e b e e n inpresent the sub-surface and/or released at the same tim e as AFFF? No What type of surface covering is in the immediate vicinity of th e release? U n v e g e ta te d Soit/gravel W h e re d o e s runoff flo w a t th is A P E C ? Overland flo w v ia g ra s s e d d itc h e s / s w a le s to s u r fa c e w a te r b o d y W h a t is the distance to the nearest p o ta b le water receptor identified in P h a se 1? G re a te r than 5 k m / G r e a te r than 3 miles W h a t is the distance t o th e n e a re s t se n sitiv e ecological receptor (w e tla n d or surface water body) identified in Phase 1? O t o 500 m /0 to 1 6 ft ________________ t __ I___ 1 .. A\ #8 1 121 10 1 5 10 lr1 u Figure 6-12. Scoring on the M odule 2 Legacy APECS worksheet. Copyright National Academy of Sciences. All rights reserved. US00004669 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 85 firefighting activities; therefore, this question includes the mass of AFFF released in the assess ment of risk. Timing of the release is important for the migration of AFFF in the environment and the type of PFASs contained in the AFFF, as different compositions were used prior to and after 2010. Co-mingle contaminants. PFASs behave differently in the natural environment when released at the same time as petroleum hydrocarbons (PHCs) or into soils impacted by PHCs; there fore, the presence of PHCs increases the risk of a potential concern. Surface covering. Surface covering at the release location will influence the way that PFASs could potentially interact with sensitive receptors; overland flow could result in AFFF entering surface water bodies, while infiltration may result in AFFF in groundwater supplies. Exposure pathways. In combination with the questions posed about the surface covering at the release location, the questions associated with the topic of exposure pathways are designed to gain a preliminary understanding of the likelihood that AFFF is interacting with sensitive receptors. ita Gaps The MAPA Screening Tool has been designed to preliminarily screen APECs associated with AFFF and other sources of PFASs and to provide utility as a data gap identification and analysis tool. Some of the questions in the MAPA Screening Tool, however, may be difficult for an airport to answer or address because the necessary information may not be readily available. For operational APECs, information may need to be provided by multiple departments in the airport and/or tenants. For legacy APECs, information may be available via previously conducted environmental site investigations or publicly available databases to address questions for which there is not a readily available response. The MAPA Screening Tool allows users to flag questions to which they do not know the answer (e.g., entering a "Don't Know" response). Data gaps related to potential legacy envi ronmental impacts (i.e., impacts of PFASs in environmental media such as soil, groundwater, sediment, or surface water) will be identified. A detailed CSM that identifies potential sources, exposure pathways, and receptors and includes a comprehensive understanding of the site's subsurface stratigraphy, hydrogeology, hydrogeochemistry, hydrology, and impacts of the fate and transport of PFASs will ultimately be needed to fully understand potential risks to human health and the environment. The MAPA Screening Tool does not create the CSM, but the data gap tool allows the user to inventory available information (and missing information) that would be required to develop a CSM in the future, if needed. The MAPA Screening Tool includes a Data Gaps worksheet that allows the user to identify whether they have information pertinent to developing a rigorous CSM, including the following (see Figure 6-13): Land use and zoning for on- and off-site properties (agricultural, residential, commercial, and industrial). Soil conditions (e.g., soil texture, soil type, soil depth, soil chemistry). Geological conditions (e.g., depth to bedrock, type of underlying rock, till). Hydrogeological conditions (e.g., groundwater depth, flow rate, flow direction, chemistry). Surface water and sediment conditions (e.g., flow rate and direction, depth, hydrodynamics, substrate type, water and sediment chemistry, drainage patterns and systems, surface runoff patterns). Topographic features (e.g., elevation and gradient). Local climatology and meteorological conditions. Copyright National Academy of Sciences. All rights reserved. US00004670 Use and Potential Impacts of AFFF Containing PFASs at Airports 86 Use and Potential Impacts of AFFF Containing PFASs at Airports PRESSTO START Instructions: 3ress the b..tto~ to ti e left to identify APEC that have resulted in a release of AFFF to the environ merit Under each location, answer the ouest ons osing the drop-down lists. S TP Fp.itures/Se't'ns Meteorological Information Topography Geology Hydrogeology Permafrost Groundwater Snow cower Flood potential Amount of precipitation Topography of APEC In relation to sensitive receptors Depth of soil to bedrock Type of bedrock Depth to groundwater Groundwater flow direction Groundwater flow rate Permafrost depth Precipitation infiltration rate Hydraulic conductivity rate Thickness and hydraulic conductivity of confining layer over aqulfer/gioundwater expsure pathway Figure 6-13. Site features/settings as part o f a CSM in the M odule 2 Data Gaps worksheet. Potential preferential migration pathways or conduits for PFASs (e.g., former or current trenches, ditches, underground piping, and wiring). Information not available would be considered a potential data gap or uncertainty. ~ ritiz a tio n MAPA has been designed to rank each APEC based on the characteristics identified in Module 2. Scoring, whether for individual responses or for APECs as a whole, generally rep resents an increasing potential for unacceptable risk to human health and environment as the values increase, i.e., the lower the score, the less the concern, and the higher the score, the greater the concern. Scoring is for comparative purposes only, and the absolute number has no meaning other than contextual. Attachment A of Appendix C lists the questions asked in Module 2, scores associated with each response, the maximum score, and the calculations used to calculate the overall score for applicable life cycle stages. _ _ osing The MAPA Screening Tool has been designed for airport representatives familiar with AFFF management and impacts of PFASs at the airport. The screening tool can assist airports in identi fying and characterizing APECs on or near an airport, accounting for both historical and current use of AFFF and other sources of PFASs. The MAPA Screening Tool has been designed so that users can rely on readily available information to complete the screening effort. Should APECs Copyright National Academy of Sciences. All rights reserved. US00004671 Use and Potential Impacts of AFFF Containing PFASs at Airports Screening Tool Guidance 87 be identified that require further investigation, airports should engage environmental consultants and contractors with experience and expertise in AFFF and PFASs. The results that can be produced by use of the MAPA Screening Tool are the following: Identification of APECs on and adjacent to airport property. Identification of potential sensitive receptors on and adjacent to airport property. Collection of information needed to create GIS maps for visualization of APECs, sensitive receptors, and exposure pathways. Production of a preliminary ranking of potential concern for operational and legacy APECs. Identification of gaps in data needed for future in-depth analysis of AFFF impacts for each APEC. The information resulting from the completion of the MAPA Screening Tool allows for documentation of potential liabilities and risk and planning for the future. The MAPA Screening Tool can be used As a summary of information that the airport has regarding the life cycle of AFFF. To rank areas of handling/use of PFASs by potential risk, allowing airport managers to pri oritize efforts to mitigate/manage PFASs and plan for future capital expenditures. As a first step in the remediation of APECs for future development or changes to the airport property, in consultation with an AFFF remediation specialist. To identify operational practices that would decrease the potential environmental impacts associated with AFFF use. Note that the MAPA Screening Tool is a preliminary desktop assessment of potential impacts and should not replace the consultation of a professional with experience in AFFF management and assessment and remediation of PFASs, depending on need. Copyright National Academy of Sciences. All rights reserved. US00004672 Use and Potential Impacts of AFFF Containing PFASs at Airports C mH Aa Pn tI rh nR /~ i Recommendations for Future Research Based on the findings from ACRP Project 02-60, the following data gaps regarding the use and potential impacts ofAFFF containing PFASs at airports were identified and warrant further research. The data gaps have been listed in order (relative to representing an environmental concern) of being preventative, mitigative, and restorative. Alternatives to AFFF Containing PFASs. There is a perceived need for the development of firefighting foam alternatives to AFFF that do not contain PFASs and can be used in the United States and Canada. The superior fire knockdown capabilities ofAFFF are important from efficacy and safety perspectives. However, jurisdictions outside the United States and Canada have switched to non-fluorinated foams and/or foams that do not contain PFASs, and, while they do not meet the regulatory requirements of the FAA and Transport Canada, they are acceptable pursuant to the International Civil Aviation Organization's firefighting foam criteria. More over, even though the current regulations do not specify AFFF, the requirements for the foam (through MIL-SPEC or through Transport Canada) limit the types of products that can be used as true alternatives. Initial research into AFFF alternatives was conducted under ACRP 02-60 (and included as Appendix B); however, the scope of the project required identifying suitable AFFF alternatives available to airports within the United States and Canada. Further research is warranted on whether AFFF alternatives available outside North America can or should be acceptable (e.g., through specification requirement changes, product approvals, or advances in foam development). Disposal Methods. The survey of airports conducted for this research identified a knowl edge gap in how airports dispose of AFFF concentrate. Specifically, with changing regulations and increased awareness of the potential environmental impacts of AFFF containing PFASs (and, in particular, PFOS-containing AFFF), many airports interested in proactively making the switch to more environmentally friendly AFFF alternatives are wondering how to dispose of existing stock of PFOS- or PFOA-containing AFFF concentrate. Identified disposal options (e.g., return to manufacturer and incineration) may not be available or may be too costly, leaving airports to stockpile AFFF waste until more cost-effective options become available. Further research is recommended to identify viable, cost-effective disposal options. ReplacingAFFF in Existing Systems. Further research should evaluate whether residual PFASs bind to existing systems (e.g., hoses, storage containers, etc.). In the event that it is found that PFASs do bind to these systems, methods for eliminating residual PFASs should also be studied. Costs associated with these methods, which could include flushing the systems or full replacement, could be an element of this research. Environmental Standards for AFFF. There are currently no standards for evaluating the environmental acceptability of a firefighting foam product. Further research into providing a standard that takes a more holistic approach to the potential long-term and short-term effects 88 Copyright National Academy of Sciences. All rights reserved. US00004673 Use and Potential Impacts of AFFF Containing PFASs at Airports Recommendations for Future Research 89 of these foams could be performed by looking at bioaccumulation, persistence, toxicity, and BOD/COD. A recognizable standard would assist airport representatives to more easily factor environmental considerations in the procurement, storage, application, and disposal of fire fighting foam. Evaluation of Existing Separation/Treatment Facilities for Processing Wastewater Impacted by PFASs. Responses to the survey indicated that some airports used existing glycol-water and/or fuel-water separation systems for pretreatment of wastewater impacted by PFASs prior to sending discharged foam solutions to a wastewater treatment facility. The efficacy of these systems in removing AFFF has not been studied, and it is not known whether amendments to these systems could foster adequate AFFF removal. Further research is also recommended to evaluate volume criteria for disposal in local water treatment facilities. Most local municipal or airport-specific water treatment plants may not be effective in processing large volumes of runoff impacted by PFASs following training, testing, or emergency response. The research will help airports assess the effectiveness and viability of disposing of waste impacted by PFASs (i.e., discharged AFFF/water mixtures) using existing facilities. Understanding How Firefighting Can Be Optimized. Further research is recommended to identify how foam concentrate characteristics, equipment, and application techniques can be optimized to provide overall suppression performance equivalent to AFFF without the use of fluorochemicals. The literature suggests that application techniques can help compensate for limitations associated with specific foam concentrate characteristics. For example, in using non film-forming foams, the ability of the foam to extinguish the fire (i.e., in the absence of the film formation typically provided by fluorocarbon surfactants) can be improved by adjusting other (e.g., mechanical) properties of the foam such as reducing the rate of water drainage in order to lower yield stress on the foam. Broadly Applicable Analytical Methods. Current commercially available analytical methods do not quantify all PFASs, including precursors that may degrade and/or transform into more persistent daughter compounds. As a result, available standardized laboratory methodologies may be inadequate to fully characterize the nature and extent of the impacts of PFASs and the associated environmental risk and liability to an airport. Further research is recommended to assess the applicability of precursor analysis and total organic fluorine analysis and how the analytical results (as a better representation of concentrations of PFASs in environmental media) may influ ence the assessment of human health and ecological risk and the corresponding development of regulatory criteria for PFASs. Environmental and Human Health Risks Associated with Short-Chain PFASs in AFFF. In response to evidence of potential environmental concern associated with some PFASs and subsequent changes in regulation, manufacturers have shifted to AFFF formulations that are created through telomerization using short-chain PFASs. Although the short-chain compounds of PFASs are thought to be less persistent and less bioaccumulative, limited research has evaluated the behavior of these compounds in the environment and/or the potential risks they pose to human health or the environment. Collate User Data from the Screening Tool. As part of the ACRP Project 02-60 research, a screening tool was developed to assist airport representatives with understanding the poten tial risks involved in procuring, storing, handling, and disposing of AFFF at their sites. The screening tool ranks user responses and provides valuation that is non-contextual, as there is no scale for comparison. Further research could collate user inputs and their results, creating an airport-specific scale that could then provide ranking that is relevant to airport owners and operators, improving the applicability of the screening tool to evaluate potential risks related to PFASs. Copyright National Academy of Sciences. All rights reserved. US00004674 Use and Potential Impacts of AFFF Containing PFASs at Airports 90 Use and Potential Impacts of AFFF Containing PFASs at Airports Feasible, Cost-Effective Remediation Techniques and/or Approaches. 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Quantitative Determination of Perfluorochemicals in Sediments and Domestic Sludge. Environ. Sci. Technol. 39, 3946-3956 (2005). 82. Alzaga, R., Salgado-Petinal, C., Jover, E. k Bayona, J. M. Development of a procedure for the determination of perfluorocarboxylic acids in sediments by pressurised fluid extraction, headspace solid-phase micro extraction followed by gas chromatographic-mass spectrometric determination. /. Chromatogr. A 1083, 1-6 (2005). 83. Washington, J.W., Henderson, W.M., Ellington, J.J., Jenkins, T.M. k Evans, J.J. Analysis of perfluorinated carboxylic acids in soils II: Optimization of chromatography and extraction./. Chromatogr. A 1181,21-32 (2008). 84. Weiss, J. et al. PFAS analysis in water for the Global Monitoring Plan of the Stockholm Convention Set-up and guidelines for monitoring. (2015). 85. DeWitt, J.C. Toxicological Effects ofPerfluoroalkyl and Polyfluoroalkyl Substances. (Humana Press, 2015). 86. Trautmann, A. M., Schell, H., Schmidt, K. R., Mangold, K.-M. k Tiehm, A. Electrochemical degradation of perfluoroalkyl and polyfluoroalkyl substances (PFASs) in groundwater. Water Sci. Technol. 71, 1569-1575 (2015). 87. Liu, C.S., Higgins, C. P., Wang, F. k Shih, K. Effect of temperature on oxidative transformation of perfluorooctanoic acid (PFOA) by persulfate activation in water. Sep. Purif. Technol. 91, 46-51 (2012). 88. Hori, H. et al. Decomposition of Environmentally Persistent Perfluorooctanoic Acid in Water by Photo chemical Approaches. Environ. Sci. Technol. 38, 6118-6124 (2004). 89. Zhang, Z., Chen, J.-J., Lyu, X.-J., Yin, H. k Sheng, G.-P. Complete mineralization of perfluorooctanoic acid (PFOA) by j - irradiation in aqueous solution. Sci. Rep. 4, 7418 (2014). 90. Vecitis, C. D., Park, H., Cheng, J., Mader, B.T. k Hoffmann, M.R. Treatment technologies for aqueous perfluorooctanesulfonate (PFOS) and perfluorooctanoate (PFOA). Front. Environ. Sci. Eng. China 3, 129-151 (2009). 91. Pancras, T.A. et al. A giant leap forward for in-situ chemical oxidation of perfluorinated compounds. (2013). 92. Bachman, G., Peschman, T.J., Kellogg, D.C. k Ogle, J.T. System and Method for Treating Groundwater. Pub. No.: US 2010/0145113 Al. (2010). 93. Du, Z. et al. Adsorption behavior and mechanism of perfluorinated compounds on various adsorbents-- A review./. Hazard. Mater. 274,443-454 (2014). 94. Cheng, J., Vecitis, C.D., Park, H., Mader, B.T. & Hoffmann, M.R. Sonochemical Degradation of Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoate (PFOA) in Landfill Groundwater: Environmental Matrix Effects.Environ. Sci. Technol. 42, 8057-8063 (2008). 95. Cheng, J., Vecitis, C.D., Park, H., Mader, B.T. k Hoffmann, M.R. Sonochemical Degradation of Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoate (PFOA) in Groundwater: Kinetic Effects of Matrix Inorganics. Environ. Sci. Technol. 44,445-450 (2010). 96. Oliaei, F., Kriens, D., Weber, R. k Watson, A. PFOS and PFC releases and associated pollution from a PFC production plant in Minnesota (USA). Environ. Sci. Pollut. Res. 20,1977-1992 (2012). 97. Wilson, N. et al. Fund Treatment ofFandfill Feachate. 32 (Minnesota Pollution Control Agency, 2011). 98. Torneman, N. Remedial Methods and Strategies for PFCs. in (2012). 99. Benskin, J. R, Li, B., Ikonomou, M. G., Grace, J. R. & Li, L.Y. Per- and polyfluoroalkyl substances in landfill leachate: patterns, time trends, and sources. Environ. Sci. Technol. 46,11532-11540 (2012). Copyright National Academy of Sciences. All rights reserved. US00004679 Use and Potential Impacts of AFFF Containing PFASs at Airports 100. CRC CARE. matCARE for soil. CRC CARE (2014). Available at: http://www.crccare.com/products-andservices/technologies/matcare/matcare-for-soil/matcare-for-soil. (Accessed: 4th March 2015) 101. Stewart, R., Clark, C., Lawrence, C., Kirk, J. & Elsworth, J. Rembind used to treat firefighting foam contaminants, in P12, 470M71 (2015). 102. Biglow, C. Perfluorochemicals at Superfund sites (in Minnesota). 11-12 (Minnesota Pollution Control Agency (MPCA), 2015). 103. Dudley, L.A., Arevalo, E.C. & Knappe, D.R.U. Removal ofPerfluoroalkyl Substances by PAC Adsorption and Anion Exchange - 4344. (2015). 104. Bao, Y. et al. Removal of perfluorooctane sulfonate (PFOS) and perfluorooctanoate (PFOA) from water by coagulation: Mechanisms and influencing factors./. Colloid Interface Sci. 434, 59-64 (2014). 105. Rahman, M.F., Peldszus, S. & Anderson, W. B. Behaviour and fate of perfluoroalkyl and polyfluoroalkyl substances (PFASs) in drinking water treatment: A review. Water Res. 50, 318-340 (2014). 106. Tang, C.Y., Fu, Q.S., Criddle, C.S. k Leckie, J.O. Effect of Flux (Transmembrane Pressure) and Membrane Properties on Fouling and Rejection of Reverse Osmosis and Nanofiltration Membranes Treating Perfluo rooctane Sulfonate Containing Wastewater. (2007). Available at: http://pubs.acs.org.uml.idm.oclc.org/doi/ abs/10.1021/es062052f. (Accessed: 20th April 2016) 107. Ostlund, A. Removal Efficiency of Perfluoroalkyl Substances (PFASs) in Drinking Water - Evaluation of granular activated carbon (GAC) and anion exchange (AE) using column tests, and the effect of dissolved organic carbon. (Swedish University of Agricultural Sciences, 2015). 108. Chularueangaksorn, R, Tanaka, S., Fujii, S. &Kunacheva, C. Batch and column adsorption ofperfluorooctane sulfonate on anion exchange resins and granular activated carbon./. Appl. Polym. Sci. 131, n/a-n/a (2014). Other References Used ANSUL 3% Fluoroprotein Foam Concentrate Extinguishing Agent. 2007. https://www.ansul.com/en/us/ DocMedia/F-93202.pdf Environment and Climate Change Canada: Proposed Regulation. Regulations Amending the Prohibition of Certain Toxic Substances Regulations, 2012. http://www.ec.gc.ca/lcpe-cepa/eng/regulations/DetailReg.cfm? intReg=226 National Fire Protection Association. Standard for Low-, Medium-, and High-Expansion Foam. (2005). http ://www.nfpa.org/codes-an d-standards/document-info rmation-pages?mode=code8icode=ll The United States Department of Defense. Qualified Product Database, http://qpldocs.dla.mil/help/about.aspx Federal Aviation Administration (FAA), U.S. Department of Transportation. Advisory Circular - Aircraft Fire Extinguishing Agents. July 2004. http://www.faa.gov/airports/resources/advisory_circulars/index.cfm/go/ d o cu m en t.cu rren t/d o c u m e n tN u m b er/150_5210- 6 FAA. Airport Certification Information Bulletin - AFFF Requirements. July 2010. FAA. 2015. https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/ documentID/1027707 AA, Airport Safety and Operations Division AAD-300. CERTALERT. Aqueous Film Forming Foam (AFFF) Concentrations, Restrictions and other User Guidelines (2002). Sontake, A. and Wagh, S. (2014) The Phase-out of Perflurooctane Sulfonate (PFOS) and the Global Future of Film Forming Foam (AFFF), Innovations in Fire Fighting Foam. Chemical Engineering and Science. Accessed online at: http://pubs.sdepub.eom/ces/2/l/3/ Aer-o-Water 3 EM. Product Sheet. Transport Canada. 2015. https://www.tc.gc.ca/eng/civilaviation/regserv/cars/part3-standards-323-1022.htm. References 95 Copyright National Academy of Sciences. All rights reserved. US00004680 Use and Potential Impacts of AFFF Containing PFASs at Airports Abbreviations, Acronyms, Initialisms, and Symbols AFFF ANAB APEC APFO ARFF ASTM BOD C6 C8 0 ^2+ CALA CARs CASRN CEPA CFR COD CSM C DEPA DoD EC50 ELAP enHealth EPTDS EQSD EU FCSAP FFTA FRB FTOH FTS GAC GIS HDPE HPA IMAC Aqueous film-forming foam ANSI-ASQ National Accreditation Board Area of potential environmental concern Ammonium pentadecafluorooctanoate Aircraft rescue and firefighting ASTM International Biochemical oxygen demand Carbon chain consisting of six carbons carbon chain consisting of eight carbons Calcium ion Canadian Association for Laboratory Accreditation Inc. Canadian Aviation Regulations Chemical Abstract Services Registry Number Canadian Environmental Protection Act Code of Federal Regulations Chemical oxygen demand Conceptual site model Degrees Celsius Danish Ministry of the Environment United States Department of Defense Half maximal effective concentration (EC50) is the concentration of a substance that gives half-maximal response. Used as a measure of the substance's potency. Environmental Laboratory Accreditation Program Environmental Health Standing Committee (Australia) Entry points to the distribution system Environmental Quality Standards Directive European Union Federal Contaminated Sites Action Plan (Canada) Firefighting training area Field reagent blank Flurorotelomer alcohol Fluorotelomer sulfonic acid Granulated activated carbon Geographic information system High-density polyethylene Health Protection Agency (UK) Interim maximum allowable concentration 96 Copyright National Academy of Sciences. All rights reserved. US00004681 Use and Potential Impacts of AFFF Containing PFASs at Airports Abbreviations, Acronyms, Initialisms, and Symbols 97 ISE ISO kg L L-A-B LC-MS/MS LC-QTOF-MS/MS LC50 LD50 MAPA mg MIL-SPEC mL MPC NCSAB NFPA ng OEHHA PAC PFAA PFASs PFBA PFBS PFCA PFCs PFHpA PFHxA PFHxS PFNA PFOA PFOS PFOSA PFPeA PFSA PH PHC PIGE PJLA POCIS POP PPE PRB PTFE PVDF QA/QC QPD Ion-selective electrode International Organization for Standardization Kilogram Liter Laboratory Accreditation Bureau Liquid chromatography/tandem mass spectrometry Liquid chromatography/quadrupole time of flight/tandem mass spectrometry Lethal concentration at 50 percent. LC50 is the lethal concentration required to kill 50 percent of the population (longer-term exposure). Lethal dose at 50 percent (LD50) is the amount of an ingested substance that kills 50 percent of a test sample (short-term exposure). Managing AFFF and PFASs at Airports (Screening Tool) Milligram United States Military Specification MIL-F-24385 (Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF), Liquid Concentrate, for Fresh and Seawater) Milliliter Maximum permissible concentration North Carolina Science Advisory Board National Fire Protection Association Nanogram Office of Environmental Health Hazard Assessment (California) Powdered activated carbon Perfluoroalkyl acid Perfluoroalkyl and polyfluoroalkyl substances Perfluorobutanoic acid Perfluorobutane sulfonic acid Perfluoroalykl carboxylic acid (e.g., PFOA) Perfluorinated compounds Perfluoroheptanoic acid Perfluorohexanoic acid Perfluorohexane sulfonic acid Perfluorononanoic acid Perfluorooctanoic acid Perfluorooctane sulfonic acid Perfluorooctane sulfonamide Perfluoropentanoic acid Perfluoroalkyl sulfonic acid Measure of the acidity or basicity of an aqueous solution Petroleum hydrocarbon Particle-induced gamma-ray emission Perry Johnson Laboratory Accreditation Polar organic chemical integrative sampler Persistent organic pollutant Personal protective equipment Permeable reactive barrier Polytetrafluoroethylene Polyvinyl fluoride Quality assurance/quality control Qualified Products Database (U.S. Department of Defense) Copyright National Academy of Sciences. All rights reserved. US00004682 Use and Potential Impacts of AFFF Containing PFASs at Airports 98 Use and Potential Impacts of AFFF Containing PFASs at Airports RfD RIVM RO see SDS SDWA SNUR TDS TCD TOP TSCA UCMR3 Pg UK UL UN UNEP Reference dose National Institute for Public Health and the Environment (Netherlands) Reverse osmosis Standards Council of Canada Safety data sheet Safe Drinking Water Act Significant New Use Rule Technical data sheet Technical Cuidance Document Total oxidizable precursor Toxic Substances Control Act Third Unregulated Contaminant Monitoring Rule micro gram United Kingdom Underwriters Laboratory Inc. United Nations United Nations Environment Programme Copyright National Academy of Sciences. All rights reserved US00004683 Use and Potential Impacts of AFFF Containing PFASs at Airports Glossary Bunded Category A Airport Category B Airport Category C Airport Category D Airport Category E Airport Class B Fire Designated Airport Exposure Pathway Fluorotelomer Hydrophilic Hydrophobic Long-chain Oleophobic Participating Airport Perfluorinated Polyfluorinated A type of secondary containment around storage "where potentially polluting substances are handled, processed or stored, for the purposes of containing any unintended escape of material from that area until such time as remedial action can be taken" (Wikipedia). FAA ARFF Category airport that serves aircraft less than 90 feet in length. FAA ARFF Category airport that serves aircraft at least 90 feet but less than 126 feet in length. FAA ARFF Category airport that serves aircraft at least 126 feet but less than 159 feet in length. FAA ARFF Category airport that serves aircraft at least 159 feet but less than 200 feet in length. FAA ARFF Category airport that serves aircraft at least 200 feet in length. Fires whose fuel is flammable or combustible liquid or gas (e.g., gasoline, diesel fuel, petroleum oil, paint, propane, butane). Per Transport Canada, an airport at which the total of the number of passengers that are enplaned and the number of passengers that are deplaned is more than 180,000 per year. Pathway through which receptor(s) would be exposed to contaminants of concern. Fluorocarbon-based oligomers, or telomers, synthesized by telomerisation. A compound that is polar, that is attracted to water. A compound that is non-polar, that is not attracted to water. Perfluoroalkyl carboxylic acids (PFCAs) with eight carbons and greater (i.e., with seven or more perfluorinated carbons); perfluoroalkyl sulfonic acids (PFSAs) with six carbons and greater (i.e., with six or more perfluorinated carbons). A compound that is repelled from oil. In Canada, an airport, other than a designated airport, for which a critical category for firefighting is specified in the Canada Flight Supplement (Transport Canada). The replacement of all hydrogens by fluorine in the aliphatic chain structure. The replacement of most hydrogens by fluorine in the aliphatic chain structure. Copyright National Academy of Sciences. All rights reserved. 99 US00004684 Use and Potential Impacts of AFFF Containing PFASs at Airports 100 Use and Potential Impacts of AFFF Containing PFASs at Airports Receptor Short-chain Source Surfactant A human or ecological receptor that would be exposed to the contaminant of concern. Perfluoroalkyl carboxylic acids (PFCAs) with less than eight carbons and perfluoroalkyl sulphonates (PFSAs) with less than six carbon molecules. A chemical found at such concentration to be of potential concern to human health or the environment. A substance that tends to reduce the surface tension of a liquid in which it is dissolved. Copyright National Academy of Sciences. All rights reserved. US00004685 Use and Potential Impacts of AFFF Containing PFASs at Airports APPENDI X A Survey Methodology and Findings Copyright National Academy of Sciences. All rights reserved. A-1 US00004686 Use and Potential Impacts of AFFF Containing PFASs at Airports A-2 Use and Potential Impacts of AFFF Containing PFASs at Airports CONTENTS INTRODUCTION A-3 II. RESEARCH METHODS A-5 III. FINDINGS..............................................................................................................A-10 ATTACHMENT A: SURVEY INSTRUMENT ATTACHMENT B: DETAILED DATA TABULATIONS FOR ALL RESPONDING AIRPORTS ATTACHMENT C: VERBATIM TRANSCRIPTIONS OF OPEN-ENDED RESPONSES1 ATTACHMENT D: STATISTICALLY SIGNIFICANT CROSSTABULATIONS BY COUNTRY ATTACHMENT E: STATISTICALLY SIGNIFICANT CROSSTABULATIONS BY AIRPORT SIZE 1Attachment C is not published herein but is available upon request from Cooperative Research Programs Senior Program Officer Joe Navarrete, at jnavarrete@nas.edu. Copyright National Academy of Sciences. All rights reserved. US00004687 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-3 I. INTRODUCTION The research findings presented in this report derive from a survey of North American airports that was commissioned by Dillon Consulting on behalf of the Airport Cooperative Research Program and conducted by JD Franz Research of Sacramento. Encompassing 167 completed Interviews, the survey commenced on December 7, 2015 and was concluded on February 18, 201 6. One additional airport was contacted as late as March 7 due to a miscommunication, and that final Interview was completed. The primary purpose of the survey was to determine how airports manage Aqueous Film Forming Foam, or AFFF. Primary areas of inquiry were as follows: Criteria for the procurement of AFFF Nature of the places AFFF is stored Manner in which AFFF Is removed from firefighting equipment or systems Extent and nature of foam tests at airports Use and disposition of AFFF during foam tests Circumstances under which AFFF Is replaced Manner of disposing of AFFF Manner of handling AFFF Prevalence of firefighter training at airports Use and disposition of AFFF during firefighter training Protective gear used In handling AFFF Best management practices for preventing spills of AFFF Use of AFFF in actual airport firefighting Extent to which airports have histories of known contamination from firefighting Nature and outcomes of the contamination Prevalence, nature, and results of environmental studies relative to the release of AFFF into the environment Awareness and use of alternative formulations of AFFF Additional comments Following this Introduction, the report is divided Into two additional sections. Section II contains a detailed discussion of the Research Methods used In conducting the survey, while Section III presents and discusses the Findings. For reference, there are also five attachments. Attachment A contains a copy of the Survey Instrument that is was used In conducting the research, while Attachment B includes Detailed Data Tabulations for All Responding Airports. Attachment C presents Verbatim Copyright National Academy of Sciences. All rights reserved. US00004688 Use and Potential Impacts of AFFF Containing PFASs at Airports A-4 Use and Potential Impacts of AFFF Containing PFASs at Airports Transcriptions of Open-Ended Responses to all of the survey's questions of this nature.2 Attachment D contains Statistically Significant Cross-Tabulations by County, and Attachment E includes Statistically Significant Cross-Tabulations by Airport Size. 2 Attachment C is not published herein but is available upon request from Cooperative Research Programs Senior Program Officer Joe Navarrete, atjnavarrete@nas.edu. Copyright National Academy of Sciences. All rights reserved. US00004689 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-5 II. RESEARCH METHODS Instrument Design The instrument that was used to conduct this survey was designed by the President of JD Franz Research in consultation with representatives of Dillon Consulting and Mead & Hunt. After several rounds of review and revision, the Instrument was tested at three airports by Dillon and Mead & Hunt personnel. As these test Interviews did not reveal any major problems, the final draft of the instrument was accepted for implementation. During subsequent interviewing, it became apparent that one question was not necessarily clear to respondents. This question was then modified for clarification, but not to the extent that the meaning was altered. The final questionnaire contained 42 questions, 16 of them open-ended. The average Interview length was 21 minutes. Sample Selection The sample for the survey was provided by Dillon and was based on the population information included in the Amplified Work Plan for the project prepared In August, 2015. (National Academ y of Sciences: Airport Cooperative Research Program. Amplified Work Plan -ACRP 02-60: Use and Potential Impacts of AFFF Containing PFASs at Airports, Page 12.) Consistent with the proposed approach that emphasized larger airports, the sample included all of the airports in ARFF Categories C (90 airports), D (28 airports), and E (30 airports). The overall sample was then rounded out by adding proportional samples of airports in Categories A and Bto create a total sample of 229. After the sample was adjusted by the call center administering the interviews to account for duplications, the net sample was 225. Interviewer Training All of the staff conducting the survey were experienced business-to-business interviewers with Pacific Market Research (PMR) in the Seattle area. PMR has an extensive airport Interviewing background, both as a subcontractor to JD Franz Research and as the data collection contractor for the Seattle-Tacoma International Airport. Interviewer training at PMR includes instruction In Interviewing techniques, orientation to the mechanics of sample selection and recording, use of the firm's Computer Assisted Telephone Interviewing (CATI) software, and comprehensive practice with survey instruments as well as with a systematic approach to answering respondents' Inquiries. The Copyright National Academy of Sciences. All rights reserved. US00004690 Use and Potential Impacts of AFFF Containing PFASs at Airports A-6 Use and Potential Impacts of AFFF Containing PFASs at Airports briefing for this p articular survey, which included an in-depth introduction to the subject matter as well as a question-by-question review of the instrument, was conducted by the President of JD Franz Research. Survey Implementation Interviewing for the survey was conducted from PMR's centralized, CATI-equipped, and fully monitored facility. All of the interviewing took place under the ongoing oversight of full-time supervisors. Calls were placed during regular business hours, local airport time, unless a potential respondent requested otherwise. Customary calling hours were 6:45 a.m. to 1:45 p.m. Pacific time. Upon completion of each interview, a supervisor checked it for accuracy, clarity, and completeness. Further review was subsequently undertaken by the President of JD Franz Research (qualitative results) and the firm's Vice President & Data Analysis Manager (quantitative data). In cases where there were problems or concerns, respondents were called back for clarification or amplification. Up to 17 attempts were made to reach a potential respondent at each airport in the sample. When respondents referred interviewers to another individual for the answers to one or more of the survey questions, attempts were also made to contact and interview these individuals. From the 225 unduplicated cases with viable telephone numbers, 167 interviews were completed. Given a total population of 580 airports, the margin of error for the survey at the 95 confidence level is + 6.4 percent. The response rate for the survey based on the net sample size of 225 is 74 percent, which is generally viewed as being very good to excellent. Only eleven of the airport representatives who could be contacted actually refused to cooperate and complete the interview: three people terminated the interview before they finished it. This level of breakoffs is also a very good result. Distribution of the Com pleted Interviews Table 1 shows the distribution of the survey responses by country. As this chart indicates, most of the interviews were completed in the United States, and the response rate for that country was also higher. In both countries, however, the level of response exceeded the 50 percent rate that is the mathematical limiting case and that also represents the majority of the sample. Assuming the sample is representative, it is reasonable to conclude with a majority response that the results are representative as well. Copyright National Academy of Sciences. All rights reserved. US00004691 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-7 Table 1 DISTRIBUTION OF RESPONSES BY COUNTRYr United States Canada Total Unduplicated Valid Sample 199 26 225 Completed Interviews 149 18 167 Percent of Sample 75% 69% 74% Table 2 portrays the distribution of the responses by airport size. Here a g ain , all of the response rates are majorities, with the largest, perhaps not surprisingly, representing the smallest airports. Even am ong the largest airports, however, more than half of those sam pled p articip a te d . The largest absolute num ber of airports c a n be found in C ate g o ry C ; the smallest num ber is in C a te g o ry E. Table 2 DISTRIBUTION OF RESPONSES BY AIRPORT SIZE CATEGORY Category A Category B Category C Category D Category E Total Unduplicated Valid Sample 48 29 90 28 30 225 Completed Interviews 40 22 69 19 17 167 Percent of Sample 83% 76% 77% 68% 57% 74% Finally, Table 3 d ep icts the distribution of the responses by country and airport size. As w ould be e x p e cte d , by far the majority of the results consists of United States airports. A cco rd in g to the d a ta presented In the Am plified Work Plan for the project, 9 p ercen t of the target a u d ie n c e of airports is C a n a d ia n ; the result is a ctu a lly slightly g reater at 11 percent. Airports in C a te g o ry C predom inate in the United States; those In C a te g o ry B predom inate in C a n a d a , although the C a n a d ia n numbers a re small enough that d ifferences are not particularly m eaningful. In the United States, the smallest group of airports is found in C a te g o ry E; in C a n a d a , there is almost no differentiation am ong categ o ries. Copyright National Academy of Sciences. All rights reserved. US00004692 Use and Potential Impacts of AFFF Containing PFASs at Airports A-8 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 3 DISTRIBUTION OF RESPONSES BY COUNTRY AND AIRPORT SIZE CATEGORY Category A Category B Category C Category D Category E Total United States Frequency 37 17 65 16 14 149 Percent 22% 10% 39% 10% 8% 89% Canada Frequency 3 5 4 3 3 18 Percent 2% 3% 2% 2% 2% 11% Combined Frequency 40 22 69 19 17 167 Percent 24% 13% 41% 11% 10% 100% Data Coding, Tabulation, and Analysis Coding Coding of the survey's closed-ended questions w as accom plished by the interviewers as they co nduct the interviews. Coding of the survey's open-ended questions was then undertaken by the President of JD Franz R esearch, w ho review ed all of the responses to e a c h question, d e ve lo p e d the app ro priate co d eb o o ks, and c o d e d the responses. Thirty p ercent of this coding w as then c h e c k e d and va lid a te d by the V ice President and Data Analysis M anager. Given that the num ber of "other" responses Is relatively small, it w as not d ee m e d necessary to undertake a com m on next step, nam ely of attem pting to a d d n e w co d e s and d e c re a se the proportions of "other." For referen ce In the even t the rea d er Is Interested, how ever, all of the responses to e a c h of the op en-end ed questions c a n b e found in A ttach m e n t C 3. Interpretation of the Coded Data As the re a d e r is reviewing the co d e d d a ta , it is Important to b e a r In mind that the openend ed questions in this survey w ere extrem ely broad in nature and had the potential to encom pass a w id e variety of subtopics. In addition, there w ere no sp e cific probes interviewers w ere Instructed to use If all possible subtopics w ere not ad dressed . Although this a p p ro a c h posed som e ch allen g es, it w as an intentional a sp e c t of the research design for two reasons: first, b e c a u se no one on the research team knew with any precision w h at all of the possible answers might be (a prerequisite for constructing more 3 Attachment C is not published herein but is available upon request from Cooperative Research Programs Senior Program Officer Joe Navarrete, atjnavarrete@nas.edu. Copyright National Academy of Sciences. All rights reserved. US00004693 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -9 closed-ended items), and second, because alternative designs would have greatly added to an already lengthy interview. As a result, some people addressed one aspect of a question while others addressed a different one. A few of the data tables could therefore be a bit misleading in a purely quantitative sense. This is particularly true of Table 8 (processes and solutions for removing AFFF from firefighting equipment or systems), where some respondents explained the manner of offloading the foam, others talked about where the resulting foam was stored, and still others mentioned the ultimate disposition of the foam. This suggests that the percentages In the table are not the kinds of absolute values one might find in a purely quantitative design, but rather the more relative values of a qualitative formulation. Tables 11 and 16 were structured somewhat differently in an attempt to overcome this challenge by developing subcategories of responses, but even these subcategories are likely only quantitatively valid in comparison with one another. In all of these instances, then, we would encourage the reader to review the verbatim responses in Attachment C4, which tend to give a more thorough picture of what is actually transpiring in the field. We also believe that if truly quantitative data are needed to understand airport practices In areas such as these, additional study may be required. Analysis of the Data by Country and Airport Size In order to understand how practices and experiences might differ In the two participating countries (the United States and Canada) and across airport size categories, all of the quantitative data were cross-tabulated by these two sets of independent variables and tested for statistical significance using the chi-square technique.5 All of the statistically significant results (p<.05) were then further examined to identify results with managerlally or practically important differences and to exclude those with extremely small sub-sample sizes. The results of this analysis are presented in the following section of this report following the discussions of the main findings for the applicable questions. All of the statistically significant cross-tabulations can be found in Attachment D (country) and Attachment E (airport size). 4 Attachment C is not published herein but is available upon request from Cooperative Research Programs Senior Program Officer Joe Navarrete, atjnavarrete@nas.edu. 5 Although it is possible to cross-tabulate qualitative survey findings, the statistical techniques have in our opinion yet to be perfected. In addition, the results are difficult to interpret and commonly of limited utility. Copyright National Academy of Sciences. All rights reserved. US00004694 Use and Potential Impacts of AFFF Containing PFASs at Airports A-10 Use and Potential Impacts of AFFF Containing PFASs at Airports II Findings from the survey are presented here in the sam e order in w hich the questions w ere posed to airport representatives. Readers w ho are interested in the precise phrasing of the inquiries are invited to consult the c o p y of the survey instrument that c a n be found in Attachment A. AFFF Procurement Criteria Table 4 displays airports' answers w hen they w ere asked about their most important procurem ent criteria for the acquisition of AFFF. By far the most prominent criterion m entioned is com plying with governm ent regulations. This is followed by cost or price, the use of an external purchasing ag en cy or organization, the availability of sufficient quantities, and the use of a required list of vendors. Table 4 MOST IMPORTANT CRITERIA FOR AFFF PROCUREMENT Com pliance With Government Regulations (FAA, Transport C a n a d a , Mil Spec, Three Percent, Regulation 139) Cost Or Price/Flave A Budget To Meet/ Request Prices From Three Vendors/Flave To Take Winning Bid/Product Is Expensive Flandled By A Purchasing Agent/Other A g ency/ Other Organization Availability Of Sufficient Quantities Required To Use A List Of Vendors Provided By The Military/DOD/State/City Consistency Of Brand To Avoid Mixing Brands And Resulting Compatibility Issues Availability In A Timely Manner Environmental Considerations Other Don't Know Frequency 109 61 13 12 12 7 5 3 21 2 Percent 65.7 36.7 7.8 7.2 7.2 4.2 3.0 1.8 12.7 1.2 Characteristics of AFFF Storage Figure 1 presents the m ean existence of various ch aracteristics of the p la ce s w here AFFF is stored on a four-point sca le w here one equals none and four equals all. As this g rap hic indicates, storage a re a s are most likely to b e enclo sed , be co ve re d , and h a ve a cem ent or Copyright National Academy of Sciences. All rights reserved. US00004695 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -1 1 c o n cre te floor. Least likely to ch a ra cte rize the p la ce s w here AFFF is stored a re double co ntainm ent, underground storage tanks, and earth or gravel floors. EXTENT TO WHICH THE PLACES WHERE AFFF IS STORED HAVE VARIOUS CHARACTERISTICS Figure 1 Means The extent to w hich the p la ce s w here AFFF is stored are enclosed varies by country, as shown in Table 5. Enclosed storage Is substantially more com m on in the United States than it is In C a n a d a . Table 5 EXTENT TO WHICH AFFF STORAGE IS ENCLOSED BY COUNTRY None Some Most All (p=.003) US C a nada .7 .7 3.4 95.3 Percent 11.1 5.6 5.6 77.8 Copyright National Academy of Sciences. All rights reserved. US00004696 Use and Potential Impacts of AFFF Containing PFASs at Airports A-12 Use and Potential Impacts of AFFF Containing PFASs at Airports The extent to w hich double co ntainm ent is used for AFFF storage varies by airport size, as Table 6 indicates. While the relationship is not linear, the larger airports are more likely than the sm aller ones to use double co ntainm ent. The total a b se n c e of double co ntainm ent is most likely to be the c a s e am ong C a te g o ry B airports and least likely to be the c a s e am ong those in C a te g o ry D. Table 6 EXTENT TO WHICH AFFF STORAGE IS DOUBLE CONTAINMENT BY AIRPORT SIZE Category A Category B Category C Category D Category E None Some Most All (p=.048) 82.5 5.0 - 12.5 90.9 - - 9.1 Percent 84.1 4.3 - 11.6 57.9 70.6 21.1 5.9 - 5.9 21.1 17.6 The extent to w hich the p la ce s w here AFFF is stored h a v e earth or gravel floors varies by country, as Table 7 dem onstrates. C a n a d ia n airports are more likely than A m erican airports to h a v e such floors in their storage areas. Table 7 EXTENT TO WHICH AFFF STORAGE AREAS HAVE EARTH OR GRAVEL FLOORS BY COUNTRY None Some All (p=.003) US C a n ad a Percent 99.3 88.9 - 5.6 .7 5.6 Processes a n d Solutions fo r R e m o v a l o f AFFF fro m E q u ip m e n t o r Systems Table 8 portrays the processes or solutions airports said they use w hen AFFF needs to be rem oved from firefighting equipm ent or systems. Most prevalent am ong the responses is noting that the foam is drained or pum ped Into containers. This is followed by pumping the foam out with an unspecified type of pump, draining it out by using gravity, and pumping it with a m ech an ical or electric pump. Copyright National Academy of Sciences. All rights reserved. US00004697 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -13 Table 8 PROCESSES AND SOLUTIONS FOR REMOVING AFFF FROM EQUIPMENT OR SYSTEMS Drained Or Pumped Into Containers (Training Pit, Trailer, Flolding Tank, Drums, Barrels, Totes) Pumped From The Truck - Mechanism Not Specified Drained From The Truck/Gravity Fed From Truck Pumped By M echanical Or Electric Pump From The Truck Flave Never Done This Use The Nozzles On The Truck Flushed And Treated As Runoff/Diluted With Water Pumped By Eland From The Truck It Is Flushed Out And Contained Other Don't Know Frequency 89 70 30 24 13 7 7 6 4 14 5 Percent 53.3 41.9 18.0 14.4 7.8 4.2 4.2 3.6 2.4 8.4 3.0 Conduct of Foam Tests As shown in Figure 2, almost all airports co n d u ct foam tests, m eaning tests of both the AFFF foam mixture and the equipm ent. Only two percent do not. Copyright National Academy of Sciences. All rights reserved. US00004698 Use and Potential Impacts of AFFF Containing PFASs at Airports A-14 Use and Potential Impacts of AFFF Containing PFASs at Airports EXTENT TO WHICH AIRPORTS CONDUCT FOAM TESTS Figure 2 Figure 3 indicates that a majority of the airports that conduct foam tests do so between every six months and once a year; the second largest group conducts such tests every four to six months. When these figures are summed, they total almost nine In ten airports (88 percent). Copyright National Academy of Sciences. All rights reserved. US00004699 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -15 FR EQ U EN CY O F THESE TESTS Once A Month Once Every Two To Three Months Once Every Four To Six Months Between Every Six Months And Once A Year 0.0 20.0 40.0 60.0 80.0 100.0 Percent Figure 3 The freq u ency of foam testing varies by country, as illustrated In Table 9. Almost all C a n a d ia n airports co n d u ct these tests b etw e e n every six months and o n c e a ye a r. In the United States, the freq u ency of testing is considerably more variab le. Table 9 FREQUENCY OF FOAM TESTING BY COUNTRY US C a n ad a O nce A Month O nce Every Two To Three Months O nce Every Four To Six Months Between Every Six Months And O nce A Year (p = . 0 0 5 ) 9.7 4.1 36.6 49.7 Percent - - 5.6 94.4 Foam testing freq u en cy also varies by airport size, as portrayed In Table 10. With the excep tio n of airports In C a te g o ry E, testing b etw e e n every six months an d o n c e a y e a r d e cre a se s with increasing size, while testing o n c e every four to six months Increases with increasing size. Copyright National Academy of Sciences. All rights reserved. US00004700 Use and Potential Impacts of AFFF Containing PFASs at Airports A-16 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 10 FREQUENCY OF FOAM TESTING BY AIRPORT SIZE O nce A Month O nce Every Two To Three Months O nce Every Four To Six Months Between Every Six Months And O nce A Year (p=.039) Category A 10.0 - C a te g o ry B - - Category C Percent 10.4 4.5 C a te g o ry D 10.5 15.8 22.5 38.1 38.8 42.1 C a teg o ry E 6.3 - 18.8 67.5 61.9 46.3 31.6 75.0 As illustrated in Figure 4, only seven p ercen t of airports co n d u ct tests of h a n g a r foam systems. More than nine In ten do not. EXTENT TO WHICH AIRPORTS THAT CONDUCT FOAM TESTS TEST HANGAR FOAM SYSTEMS Figure 4 Am ong airports that co n d u ct h an g ar foam system tests, as dem onstrated in Figure 5, about nine In ten test both the sprinkler system and the foam generation system. The remaining about ten p ercen t test only the sprinkler system. No airports test only the foam generation system. Copyright National Academy of Sciences. All rights reserved. US00004701 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-17 NATURE OF HANGAR FOAM SYSTEM TESTS Figure 5 Figure 6 shows that over two-thirds of airports discharge the AFFF used in foam tests onto the ground. Only about a third discharges it into an engineered containment system. DISPOSITION O F THE AFFF USED IN FOAM TESTS Figure 6 Table 11 presents airports' descriptions of the engineered containment systems that are used in collecting the AFFF used in foam tests. For clarity, these responses have been Copyright National Academy of Sciences. All rights reserved. US00004702 Use and Potential Impacts of AFFF Containing PFASs at Airports A-18 Use and Potential Impacts of AFFF Containing PFASs at Airports subdivided into two categ o ries: those that relate to ca p tu re and co ntainm ent and those that address disposition. The latter ca te g o ry is quite small and does not a p p e a r to suggest an y particularly prominent p ra ctices. With resp ect to the former, the leading answers are ca p tu re in a small or non-perm anent vessel and ca p tu re in a more durable facility. In third p la c e is the use of some type of separator. Table 11 ENGINEERED CONTAINMENT SYSTEMS USED FOR COLLECTING AFFF FROM FOAM TESTS Capture and Containment: Captured In Container/Bucket/Inflatable Pool/ Tub/Specimen Cup Captured In Collection Facility/Containment Basin/Collection Tanks/Concrete Tub/Wash Pit/ Fire Pit/Traininq Pit Use Separator (Water/Foam, Oil/Water)/ Scrubbing System Sprayed Onto A Target/Contained Area Disposition: Released To Sewer System Someone Else Flandles This/Another Organization Flandles This Goes To Treatment Plant/Sanitary System Other Don't Know Frequency 18 14 10 4 3 3 2 10 2 Percent 36.0 28.0 20.0 8.0 6.0 6.0 4.0 20.0 4.0 Disposal of AFFF Figure 7 displays the proportions of airports that in d icated they re p la c e AFFF under various circum stances. As this ch art Illustrates, all of the listed circum stances lead to rep lace m e n t at the majority of airports. Most likely to prompt rep la ce m e n t a re use of AFFF during e m erg en cy situations, use of AFFF in testing or m aintaining equipm ent, and loss d ue to spills. Copyright National Academy of Sciences. All rights reserved. US00004703 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -19 EXTENT TO WHICH AIRPORTS REPLACE AFFF UNDER VARIOUS CIRCUM STANCES Consumed During Training Activities Consumed During Emergency Incidents Past Its Expiration Date Lost Due To Leaking Containers Lost Due To Spills Used In Testing Or Maintaining Equipment / 0.0 95 / 20.0 40.0 0.0 80.C 100.0 Percent Yes Figure 7 Figure 8 indicates that close to one in five airports replace AFFF in circumstances other than those listed in the previous question. These circumstances are depicted in Table 12. Chief among them are providing AFFF in mutual aid to another agency and situations in which the AFFF fails testing or doesn't work. Copyright National Academy of Sciences. All rights reserved. US00004704 Use and Potential Impacts of AFFF Containing PFASs at Airports A-20 Use and Potential Impacts of AFFF Containing PFASs at Airports EXTENT TO WHICH AFFF IS REPLACED IN OTHER CIRCUMSTANCES Yes No 82. 6% Figure 8 Table 12 OTHER CIRCUMSTANCES IN WHICH AFFF IS REPLACED Given To Another Agency When They Needed It Foam Fails Testing Or Doesn't Work Breakdown Of Equipment With Foam Loss Or Contamination Inventory Goes Below Required Minimum Foam Gets Contaminated Bad Batch/Manufacturer Buyback/Manufacturer Recall Used In An Emergency Other Frequency 5 5 3 3 3 2 2 6 Percent 17.2 17.2 10.3 10.3 10.3 6.9 6.9 20.7 Figure 9 shows the m ean extent to w hich airports dispose of spent or unused AFFF in various w ays. The d a ta in this figure are c a lc u la te d on a sca le of one to five w here one equals never an d five equals alw ays. As this g rap hic Illustrates, none of the listed disposal methods Copyright National Academy of Sciences. All rights reserved. US00004705 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-21 even achieve the level of "rarely," and half are closer to the level of "never." Most prominent are using a wastewater management contractor and letting It Infiltrate Into the soil. EXTENT TO W HICH AIRPORTS D ISPO SE O F SPENT OR U N U SED A FFF IN V A R IO U S W A Y S Using An On-Site W astewater M anagem ent System Using A Municipal Sewer System Using A W astewater M anagem ent Contractor Transporting It To A Landfill Incinerating It Letting It Infiltrate Into The Soil l.CO Never 2.00 R a re ly 3.00 Som etim es Means 4.00 Usually 5.00 A lw a ys Figure 9 The use of wastewater management contractors varies by country, as portrayed In Table 13. Airports In the United States are substantially less likely than their counterparts In Canada to use such services. Table 13 USE OF WASTEWATER MANAGEMENT CONTRACTORS BY COUNTRY Never Rarely Sometimes Usually Always (p=.006) US C a n ad a Percent 71.8 33.3 5.4 11.1 6.0 11.1 1.3 11.1 15.4 33.3 Copyright National Academy of Sciences. All rights reserved. US00004706 Use and Potential Impacts of AFFF Containing PFASs at Airports A-22 Use and Potential Impacts of AFFF Containing PFASs at Airports Handling Materials That C o m e Into C o n tact With AFFF Figure 10 illustrates the mean degree to which airports handle containers and other materials that come into contact with AFFF In various ways. Here again, the scale contains five points ranging from one for never to five for always. In this instance, one of the approaches - storing the materials on-site - almost achieves the level of "sometimes," and another - using a hazardous waste disposal facility - is above the level of "rarely." The remaining three strategies are below, although close to, the level of "rarely." EXTENTTO WHICH AIRPORTS HANDLE MATERIALS THAT C O M E INTO C O N T A C T WITH AFFF IN VARIO U S W AYS /T / Using Them Again Storing Them On-Site Including Them As Part Of General Waste Disposal Using A Hazardous Waste Disposal Facility 1.00 Never 2.00 R a re ly Figure 10 3.00 Som etim es Means 4.00 Usually 5.00 A lw a ys On-site storage of materials that come into contact with AFFF varies by country, as Table 14 indicates. United States airports are noticeably more likely never to do so but also somewhat more likely always to do so. Answers of never and rarely total close to half (45 percent) in the United States versus a third (33 percent) in Canada. Responses of usually or always sum to about two-fifths (42 percent) in the United States and the majority (56 percent) in Canada. Thus it would appear that, overall, this practice is more prevalent in Canada than it is in the United States. Copyright National Academy of Sciences. All rights reserved. US00004707 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -23 Table 14 EXTENT TO WHICH AIRPORTS HANDLE MATERIALS THAT COM E INTO CONTACT WITH AFFF ON-SITE BY COUNTRY US C a nada Never Rarely Sometimes Usually Always lp=.044) Percent 40.9 27.8 4.0 5.6 12.8 11.1 4.0 22.2 38.3 33.3 Firefighter Training As d e p icte d in Figure 11, close to nine in ten airports h ave held firefighter training on their premises at som e point in time. Of these, as illustrated In Figure 12, the majority h a v e used AFFF In selected training exercises. Almost a quarter, on the other hand , h a ve not used AFFF In an y training exercises. EXTENT TO WHICH AIRPORTS HAVE HELD FIREFIGHTER TRAINING Yes 88.6% No 1.4% Figure 11 Copyright National Academy of Sciences. All rights reserved. US00004708 Use and Potential Impacts of AFFF Containing PFASs at Airports A-24 Use and Potential Impacts of AFFF Containing PFASs at Airports EXTENT TO WHICH AFFF HAS BEEN USED IN TRAINING EXERCISES All Exercises 4.7% Figure 12 Figure 13 shows that by far the majority of the airports using AFFF in firefighter training discharge it onto the ground. Slightly over one in five discharge it into engineered containment systems. DISPOSITION O F THE AFFF USED IN TRAINING D ischarged 78.9% C o n tain m en t System 21 . 1% Figure 13 Table 15 portrays the manner in which the AFFF discharged during training has been handled. The most prevalent response is that it is discharged onto the ground and left to Copyright National Academy of Sciences. All rights reserved. US00004709 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -25 e va p o ra te , dissolve, or dissipate. This is followed by discharging the m aterial onto the ground w here it is left to soak In or Infiltrate and by discharging it onto the ground and diluting It. Table 15 MANNER IN WHICH THE AFFF DISCHARGED DURING FIREFIGHTER TRAINING IS HANDLED Discharged Onto The Ground And Left To Evaporate, Dissolve, Or Dissipate Discharged Onto The Ground/Soll And Left To Soak In Or Infiltrate Discharged Onto The Ground And Diluted Sent To Or Flandled By Flazardous Waste Treatment Discharged Onto The Ground And Contained Or C leaned Up Discharged Onto The Ground - No Specifics of Outcom e Discharged Into A Fire Training Pit Discharged Into W astewater Treatment System It Is Environmentally Safe Other Don't Know Frequency 32 23 16 6 6 5 2 2 2 6 2 Percent 35.6 25.6 17.8 6.7 6.7 5.6 2.2 2.2 2.2 6.7 2.2 Table 16 displays airports' descriptions of the eng ineered containm ent systems that are used In co llecting the AFFF used in firefighter training. Flere ag ain , these responses h a ve been subdivided into two categories: those that relate to cap tu re and containm ent and those that address disposition. As previously, the second category contains relatively few responses. Leading practices a p p e a r to be sending the foam to a retention pond or tank and dispersing the foam in a w a y that is not d etailed , although the numbers involved here are so small that they should be treated with co nsid erable caution. In the first ca te g o ry, the most prominent answers are capturing the m aterial In a collection facility or training pit and using som e type of separator. Copyright National Academy of Sciences. All rights reserved. US00004710 Use and Potential Impacts of AFFF Containing PFASs at Airports A-26 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 16 ENGINEERED CONTAINMENT SYSTEMS USED FOR COLLECTING AFFF FROM FIREFIGHTER TRAINING Capture and Containment: Captured In Collection Facility/Training Pit Use Separator (Water/Foam, Oil/Water)/Water Reclamation System Dispersed Onto A Paved Surface Disposition: Goes to Retention Pond/Tank Dispersed or Released - Unclear Where Vacuum ed Up With Vacuum Truck Taken A w ay By Contractor Goes To Treatment Plant/Sanitary System Other Frequency 16 9 2 4 3 2 2 2 3 Percent 66.7 37.5 8.3 16.7 12.5 8.3 8.3 8.3 12.5 Staff and Trainee Handling of AFFF Figure 14 illustrates the extent to w hich staff an d trainees w ho hand le AFFF w e a r various types of p rotective g e a r w hen doing so. As this Illustration indicates, almost all airports outfit those handling AFFF with work gloves and eye protection; strong majorities provide safety boots, turnout g ear, and fire-retardant clothing. Substantially less likely to b e used are nitrile or other one-time-use gloves. Copyright National Academy of Sciences. All rights reserved. US00004711 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -27 EXTENT TO WHICH STAFF WEAR VARIO US PROTECTIVE ITEMS WHEN HANDLING AFFF Eye Protection Work Gloves Nitrile Gloves Other One-Time-Use Gloves Safety Boots Fire-Retardant Clothing Turnout G ear 0.0 20.0 40.0 0.0 80.0 100.0 Percent Yes Figure 14 Best M anagem ent Practices for Preventing Spills during AFFF Handling Table 17 presents airports' assessments of the best m a n a g em en t p ra ctice s for preventing spills during the handling of AFFF. The two leading p ractices, m entioned by eq u al numbers of airports, a re taking o ne's time or using caution an d using som e form of co ntainm ent or containers. These are followed by providing thorough training on procedures, making sure connections are correct or tight, and actu ally following procedures. Copyright National Academy of Sciences. All rights reserved. US00004712 Use and Potential Impacts of AFFF Containing PFASs at Airports A-28 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 17 BEST MANAGEMENT PRACTICES FOR PREVENTING SPILLS Use Caution/Be Careful/Take Your Time/Pay Attention/Attend To Detail Use Containment/Containers Provide Thorough Training On Procedures Make Sure Connections Are Correct/Are Tight Follow Procedures Use Pumps Flave Clear Procedures/Checklists Use The Right Equipment/Make Sure Equipment Is Set Up Properly Do Not Do It Alone/lnvolve Multiple People We Flave Never Flad An Issue or Problem/We Don't Spill Use Safety G ear Work In A Contained A rea/ Closed Area/Safe Area Put Safety First/Make Safety A Priority/Use Safety Precautions Maintain Trucks Well/Maintain Equipment Well Make People Aw are That The Goal Is Not To Flave A Spill Use A Closed System Flave Absorbent Material Available Make Sure Spill Containm ent Is Available If Needed Make People Aware Of The Foam's Cost Other Don't Know Frequency 36 36 27 26 26 20 20 19 17 14 13 13 8 7 7 6 6 2 2 37 2 Percent 21.6 21.6 16.2 15.6 15.6 12.0 12.0 11.4 10.2 8.4 7.8 7.8 4.8 4.2 4.2 3.6 3.6 1.2 1.2 22.2 1.2 Experiences with AFFF in Firefighting Figure 15 dem onstrates that close to three-quarters of airports h a ve used AFFF for a ctu a l firefighting purposes. Of these, as shown in Table 18, the largest proportion has used AFFF in firefighting b etw e e n six and ten times. The seco nd largest groups h a ve used it two times and more than ten times. Use of AFFF in firefighting five or few er times represents the majority (61 p ercent). Copyright National Academy of Sciences. All rights reserved. US00004713 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -29 EXTENT TO WHICH AFFF HAS BEEN USED AT AIRPORTS FOR FIREFIGHTING PURPOSES Figure 15 Table 18 NUMBER OF TIMES THIS HAS OCCURRED IN THE PAST TEN YEARS 1 2 3 4 5 6 To 10 More Than 10 Frequency 15 18 17 7 15 29 18 Percent 12.6 15.1 14.3 5.9 12.6 24.3 15.0 The extent to w hich AFFF has b een used for a c tu a l firefighting purposes varies by airport size, as illustrated In Table 19. Flere, the trend Is virtually linear, with the largest airports having the highest frequency of use and the smallest airports having the second lowest. The lowest use is seen in C a te g o ry B airports, although the d ifference b etw een C ateg ories A and B Is not substantial. Copyright National Academy of Sciences. All rights reserved. US00004714 Use and Potential Impacts of AFFF Containing PFASs at Airports A-30 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 19 USE OF AFFF IN ACTUAL FIREFIGHTING BY AIRPORT SIZE Category A Category B Category C Category D Category E Yes No (p=.005) Percent 57.5 50.0 78.3 78.9 94.1 42.5 50.0 21.7 21.1 5.9 Figure 16 indicates that only three p ercen t of the airports that h a ve used AFFF in firefighting h ave a history of known contam ination as a result of these activities. Almost all do not. EXTENT TO WHICH AIRPORTS HAVE A HISTORY OF KNOWN CONTAMINATION AS A RESULT OF FIREFIGHTING ACTIVITIES 94.1% Figure 16 Verbatim descriptions of w hat happened during Instances of contam ination are presented below. As these responses represent only three airports, they do not suggest any themes. O ne time w e had a fuel spill an d they did ground testing and they rem oved the soil that w as co n tam in ated by the spill. W hen it w as d ischarg ed onto the field at the airport, the environm ental group w as c o n ta c te d an d they scra p e d of the topsoil and took it to a landfill. There w as a fire and w e knew som e AFFF got on the soil. Copyright National Academy of Sciences. All rights reserved. US00004715 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-31 Figure 17 dem onstrates that none of the airports with a known history of contam ination as a result of firefighting activities ch an g e d their AFFF m an ag em en t p ractices as a result of these incidents. Thus none w ere offered the opportunity to discuss an y ch a n g e s they might h ave made. EXTENT TO WHICH AIRPORTS' MANAGEMENT PRACTICES WERE CHANGED AS A RESULT OF THESE INCIDENTS No 100.05 Figure 17 Environmental Site Investigations As shown in Figure 18, only abo ut one in ten airports h ave co n d u cte d environm ental site investigations relative to AFFF that sp ecifically relate to the release of AFFF Into the environm ent. Of these, as d ep icte d In Figure 19, the majority h a v e co n d u cte d only a single such Investigation. Copyright National Academy of Sciences. All rights reserved. US00004716 Use and Potential Impacts of AFFF Containing PFASs at Airports A-32 Use and Potential Impacts of AFFF Containing PFASs at Airports EXTENT TO WHICH AIRPORTS HAVE CONDUCTED ANY ENVIRONMENTAL STUDIES RELATIVE TO AFFF Yes 89.2% Figure 18 NUMBER OF INVESTIGATIONS CONDUCTED 0.0 20.0 40.0 60.0 80.0 100.0 Percent Figure 19 The extent to w hich airports h ave co n d u cte d environm ental site investigations relative to the release of AFFF into the environm ent is a function of airport size, as illustrated In Table 20. Copyright National Academy of Sciences. All rights reserved. US00004717 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -33 Here, the relationship is virtually linear, with Category Eairports being most likely to say they have and Category B airports being most likely to say they have not. Category A airports are somewhat more likely to say yes than Category Bairports, but the difference represents only a single airport. Table 20 EXTENT TO WHICH AIRPORTS HAVE CONDUCTED ENVIRONMENTAL SITE INVESTIGATIONS RELATIVE TO THE RELEASE OF AFFF BY AIRPORT SIZE Category A Category B Category C Category D Category E Yes No (p=.028) Percent 2.5 - 13.0 97.5 100.0 87.0 21.1 23.5 78.9 76.5 Figure 20 indicates that among those who have conducted such an Investigation, the majority do not know what UCMR 3 Is.6 Almost all of the remainder does not know how many of the investigations were conducted in accordance with this regulation. A single airport reported a UCMR 3-compliant investigation. NUMBER OF INVESTIGATIONS CONDUCTED IN ACCORDANCE WITH UCMR 3 ______ Do Not Know How Many 41.2% Does Not Know UCMR 3 52.9% Figure 20 6This question was asked only of American airport representatives, as Canadian airports are not subject to UCMR 3. Copyright National Academy of Sciences. All rights reserved. US00004718 Use and Potential Impacts of AFFF Containing PFASs at Airports A-34 Use and Potential Impacts of AFFF Containing PFASs at Airports Figure 21 displays the extent to which the airports' environmental site Investigations relative to AFFF have included various activities. As this graphic Illustrates, the activities most likely to be included are an environmental risk assessment, a human health risk assessment, specialized field methods for sampling for PFAS, specialized analytical methods fortesting for PFAS, and measurement of the prevalence of PFAS In soil. EXTENT TO W H IC H THE IN V E S T IG A T IO N S IN C LU D ED V A R IO U S ACTIVITIES Specialized Field MetPiods - Sampling For PFAS Specialized Analytical MetPiods - Testing For PFAS Measurement Of PFAS In Soil Measurement Of PFAS In Surface Water Measurement Of PFAS In Groundwater Measurement Of PFAS In Sediment Environmental Risk Assessment Human Health Risk Assessment 0.0 20.0 40.0 0.0 Percent Yes 80.0 100.0 Figure 21 Figure 22 demonstrates that the majority of airports do not know whether their investigations led to analyses of remedial options or not; only one in ten (two airports) said they did. The descriptions these airports offered of the options that were considered and recommended are presented below. Copyright National Academy of Sciences. All rights reserved. US00004719 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -35 EXTENT TO WHICH THE INVESTIGATIONS LED TO ANALYSES OF REMEDIAL OPTIONS No 33.3% Don't Know 55.6% Figure 22 As shown in Figure 23, one of the two airports actually Implemented the remedial options that were considered and recommended. This airport's description of what was Implemented can be found below. Copyright National Academy of Sciences. All rights reserved. US00004720 Use and Potential Impacts of AFFF Containing PFASs at Airports A-36 Use and Potential Impacts of AFFF Containing PFASs at Airports EXTENT TO WHICH THE REMEDIAL OPTIONS WERE ACTUALLY IMPLEMENTED Figure 23 The analysis, everything was implemented was the way we handled that. To Isolate whenever we test or flow AFFF for training or testing. It Is flowed into a contained area where It can be contained. Alternative Formulations of AFFF Figure 24 Indicates that about a quarter of airports are aware of alternative formulations of AFFF; the majority is not. Table 21 presents these airports' descriptions of the alternatives of which they are aware. As this graphic Indicates, most of these descriptions are vague or admittedly uncertain. The leading category of comments is knowing that there are alternatives but not being able to be specific or state what their names are. Copyright National Academy of Sciences. All rights reserved. US00004721 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -37 AWARENESS OF ALTERNATIVE FORMULATIONS OF AFFF Figure 24 Table 21 ALTERNATIVES OF WHICH AIRPORTS ARE AWARE There Are Different Types/Manufacturers - Not Specific, C an't Remember Names Mentions Unique Specific Types or Names Alcohol-Based Product/Alcohol-Resistant Product Fluorine-Free Foams/Fluoride-Free Agent/PFAS and PFOA Free Environmentally Friendly Foams/Bio-Friendly Foams Training Foams Mentions Europe or European Other Frequency 13 9 5 5 5 5 4 4 Percent 34.2 23.7 13.2 13.2 13.2 13.2 10.5 10.5 Am ong those w ho are a w a re of alternative formulations of AFFF, as Illustrated in Figure 25, abo ut a quarter a ctu a lly uses alternatives. Verbatim reasons for using these alternatives am ong the nine airports that do so are presented below. Reasons for not doing so are Copyright National Academy of Sciences. All rights reserved. US00004722 Use and Potential Impacts of AFFF Containing PFASs at Airports A-38 Use and Potential Impacts of AFFF Containing PFASs at Airports displayed In Table 22. C hief am ong these is that the alternatives are not In co m p lia n c e with governm ent regulations. USE OF THESE ALTERNATIVES Figure 25 Reasons for Using Alternatives to AFFF: Alcohol AFFF on Ethanol, you can't use the non-alcohol-based on fuel. You h a v e multi-million dollar planes and it cau se s less d a m a g e to the plane. Just to re d u ce the am ount of AFFF w e use. It's environm entally friendly and c a n be only used in testing and training. Just different types of hazards that are in our response district. We use AFFF, it is alcohol resistant and works on ethanol. There are different applications for fires, like an engine fire or a fuel spill. We don't w ant to use the wrong ag ent for a specific application. We use the various foams due to cost of mitigation. We also do municipal firefighting, but not at the airport. For two railroad tracks that carry cru d e oil. We use If for a n y kind of alcohol fires. Copyright National Academy of Sciences. All rights reserved. US00004723 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -39 Table 22 REASONS FOR NOT USING ALTERNATIVES TO AFFF They Do Not Conform To Specifications/They Are Not In Com pliance With Regulations/They Are Not Mil Spec We Are Using What We Flave Always Used AFFF Is Com patible With Our Equipment/What We Already Flave We Are Looking At Alternatives For Future Procurements/We Flave Just Received Approval To Use An Alternative Alternatives Are More Expensive Other Don't Know Frequency 19 4 4 3 3 2 2 Percent 63.3 13.3 13.3 10.0 10.0 6.7 6.7 Concluding Comments At the close of the interview, respondents w ere asked, "Before w e co n clu d e this conversation, is there anything you would like to ad d abo ut the procurem ent, storage, handling, use, or mitigation of AFFF?" As shown in Table 23, by far the majority of airports answ ered this by saying either "N one," "Nothing," or something similar. Two far smaller groups in d icated that they had never had a n y problems with AFFF an d that AFFF is need ed for safety or effectiveness. The remaining com m ents follow. Table 23 CONCLUDING COMMENTS We Flave Never Flad Any Problems We Need AFFF For Safety Or Effectiveness/The Product Is Effective None/Nothing Other Frequency 5 3 143 17 Percent 3.0 1.8 85.6 10.2 At our airport w e h ave a co n tracted environm ental engineer who monitors the w ate r, but I'm not sure they look for AFFF. I h a ve b een in this Industry for 30 years and w e are heavily reg ulated. I do believe that there are suitable agents that are not AFFF. The AFFF has to have the foam en cap su late, the product to elim inate the release of foam and there are others that a re not foam . Australia b an n ed AFFF an d w ent to foam -based. There is one called Copyright National Academy of Sciences. All rights reserved. US00004724 Use and Potential Impacts of AFFF Containing PFASs at Airports A-40 Use and Potential Impacts of AFFF Containing PFASs at Airports Cold Fire, it bonds with a m olecular level, but it's not a foam . It nerves the fuel m olecule and you can n o t light it. I b elieve it is safer. I also b elieve air pressure w ate r would be effective. W e don't go through a lot of it here. We h a ve less than 500 gallons on site and have minimal use for it with an airport our size. W e w ould like to use AFFF at the airport in c a s e of fires with alcohol and ethanol. On procurem ent, I would like to see FAA fund more in regards to the foam . As aviation im proves for small an d medium airports, it would seem like w e should h ave the industry look at other standards for safety. W e don't train with it often enough b e c a u se of the expense, and our n e w recruit hasn't b een a b le to use the foam . It's just for fires only. Just that I think personally it is extrem ely hazardous to som eone's health w hen you co m e in c o n ta c t with it. Just by reading and researching online myself, I think it needs to be explored. Understanding the regulatory regulations of the US and C a n a d a . I'm fam iliar with the ACRP and Dillon Consulting. I w an t to m ake sure it addresses regulatory d ifferences in AFFF. I notice they are g e a re d tow ard the US side an d don't address the C a n a d a side, I find that quite w e a k. They are not recognizing that there are different regulatory requirements. It might not be m uch, but they don't a ck n o w le d g e that. If it's an A m erican d ocu m en t, it should state this is an A m erican requirem ent and not sure if it is a p p lica b le in C a n a d a . It should say this is an A m erican or C a n a d ia n d o cu m en t upfront, clarified for the read er. They are working on a procurem ent for all the airports to work together to buy from a central location. I think it could probably be b eneficial. Trying to follow all the rules. Federal, state, an d all the governm ent rules. And try to keep it off the floor b e c a u se it eats paint. We d on't w ant an y leaks. W e are required by FAA to m ake sure that it is all Mil Sp ec. We don't routinely use AFFF at our airport for training, w e use w ater. For our actu al fire training w e use the C h ic a g o Airport. W hatever the price co m es in the lowest is w h a t w e are going to buy, and w e don't mix brands. We don't w ant to mix two m anufacturers together, you can't be sure the formula is the sam e. I do know the technolog y in the n e w fire trucks allows to test the foam without having to d isch arg e it. I w ould just m ake sure as a Firefighter A g e n c y or O perator m ake sure they h a v e the ap p ro val from their Environm ental Division to hand le the AFFF in the even t there is a release, just ap p ro val of lo cal Environmental A g e n cy . W e need to begin to m ove from Fluorine foam an d co n ce n tra te on something less toxic. M ake it ch e a p e r. I would recom m end that a lot of airports won't train with it b e c a u se it is so expensive. That's w hy w e do it only o n ce a year. Copyright National Academy of Sciences. All rights reserved. US00004725 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-41 __________________ A Survey Instrument Copyright National Academy of Sciences. All rights reserved. US00004726 Use and Potential Impacts of AFFF Containing PFASs at Airports A-42 Use and Potential Impacts of AFFF Containing PFASs at Airports AIRPORT C O O P E R A TIV E RESEARCH P R O G R A M SURVEY ABOUT THE USE OE AQUEOUS FILM-FORMING FOAM(AFFF) 3RIH AMERICAN AIRPORTS Respondent Selection IF RESPONDENT NAME IS PROVIDED, ASK FOR RESPONDENT BY NAME. IF NO NAME IS PROVIDED, ASK TO SPEAK TO THE FOLLOWING. YOU ARE LOOKING FOR SOMEONE W HO IS FAMILIAR WITH THE AIRPORT'S USE OF AFFF AN D C A N REPRESENT THE AIRPORT ON THAT TOPIC. Fire C h ie f, Fire C a p ta in , D e p u ty Fire C h ie f, o r D e p u ty Fire C a p ta in Public S afety C hie f or D irector Environm ental M a n a g e r or D irector D irector of O perations Airport M a n a g e r or D irector Assistant A irport M a n a g e r o r D irector M a n a g e r or D irector o f Tenant O perations Introduction M r./M s .___________________ , this is YOUR FULL NAME c a llin g o n b e h a lf o f Dillon C o n su ltin g , w h ic h is u n d e rta k in g a re s e a rc h s tu d y fo r th e A irp o rt C o o p e ra tiv e Research Program o f th e Transportation Research Board. W e are c o n d u c tin g a survey a m o n g representatives o f North A m e rica n airports to explore th e use of a q u e o u s film -fo rm in g fo a m , c o m m o n ly re fe rre d to as A-Triple F a n d used in fire fig h tin g . The results o f this re se a rch will b e used to d e v e lo p best m a n a g e m e n t p ra c tic e g u idelines fo r use b y fa c ility o p e ra to rs a n d m a n a g e rs. All o f th e results will b e Copyright National Academy of Sciences. All rights reserved. US00004727 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -43 re p o rte d in th e a g g re g a te ; in d iv id u a l responses will b e k e p t strictly c o n fid e n tia l a n d will n o t b e a ttrib u te d to p a rtic u la r airports. Is this a c o n v e n ie n t tim e to ta lk fo r a b o u t XX m inutes? YES-TH AN K AND CONTINUE NO - ACCEPT A N D RESCHEDULE Interview 1. Thinking first a b o u t th e a c q u is itio n o f AFFF (" A-Triple-F" HERE A N D HEREAFTER), w h a t a re y o u r a irp o rt's m ost im p o rta n t p ro c u re m e n t c rite ria ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER CRITERIA: W h a t else? 2. C o n s id e rin g all o f th e p la c e s w h e re AFFF is s to re d a t y o u r a irp o rt, w o u ld yo u say th a t all, m ost, som e, o r n o n e o f t h e m _______________ ? H o w a b o u t ___________________2 a re enclosed are covered a re single c o n ta in m e n t are d o u b le con ta inm e n t h a ve a c e m e n t or c o n c re te floor h a ve an earth or gravel floor are an underground storage tank ALL 4 4 n4 4 a 4 4 CO CO CO CO CO IBB 3 n3 SOME 2 2 n2 2 n2 2 2 NONE l n, Copyright National Academy of Sciences. All rights reserved. US00004728 Use and Potential Impacts of AFFF Containing PFASs at Airports A-44 Use and Potential Impacts of AFFF Containing PFASs at Airports 3. W h e n AFFF n e e d s to b e re m o v e d fro m fire fig h tin g e q u ip m e n t o r systems, w h a t processes a n d solutions d o y o u use? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER THINGS: W h a t else? 4. Does y o u r a irp o rt e v e r c o n d u c t fo a m tests, b y w h ic h w e m e a n tests o f b o th th e AFFF fo a m m ixtu re a n d th e e q u ip m e n t? 1 YES (CONTINUE) 2 NO (SKIP TO Q10) 5. A n d a b o u t h o w o fte n d o y o u c o n d u c t th e se tests? 1 ONCE A MONTH 2 O N C E EVERY TWO TO THREE MONTHS 3 O N C E EVERY FOUR TO SIX MONTHS 4 BETWEEN EVERY SIX MONTHS A N D O N C E A YEAR 5 LESS OFTEN THAN O NCE A YEAR 6. D o y o u e v e r c o n d u c t tests o f h a n g a r fo a m systems? 1 YES (CONTINUE) 2 NO (SKIP TO Q8) Copyright National Academy of Sciences. All rights reserved. US00004729 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -45 7. D uring h a n g a r system tests, d o y o u te st th e sprinkler system , th e fo a m g e n e ra tio n system, or both? 1 SPRINKLER SYSTEM 2 FOAM GENERATION SYSTEM 3 BOTH 8. Is th e AFFF used in th e fo a m tests d is c h a rg e d o n to th e g ro u n d o r c o lle c te d in a n e n g in e e re d c o n ta in m e n t system ? 1 DISCHARGED (SKIP TO Q10) 2 ENGINEERED CONTAINMENT SYSTEM (CONTINUE) * i F ENGINEERED CONTAINMENT SYSTEM, ASK: 9. C o u ld y o u p le a s e d e s c rib e th e e n g in e e re d c o n ta in m e n t system th a t is used fo r c o lle c tin g AFFF fro m fo a m tests? PROBE FOR CLARITY AN D SPECIFICS. Copyright National Academy of Sciences. All rights reserved. US00004730 Use and Potential Impacts of AFFF Containing PFASs at Airports A-46 Use and Potential Impacts of AFFF Containing PFASs at Airports 10. N o w tu rn in g to th e dispo sa l o f AFFF ... D o y o u r e p la c e th e AFFF a t y o u r a irp o rt w h e n ________________ ? Flow a b o u t _____________ ? it is c o n s u m e d d u rin g tra in in g a c tiv itie s it is c o n s u m e d d u rin g e m e rg e n c y In c id e n ts it is p a s t Its e x p ira tio n d a te it is lost d u e to le a k in g c o n ta in e rs it is lost d u e to spills it is used in te s tin g o r m a in ta in in g fire fig h tin g equipm ent YES NO 2 2 2 l 2 2 2 11. A re th e re o th e r c irc u m s ta n c e s u n d e r w h ic h y o u r e p la c e AFFF? 1 YES (CONTINUE) 2 NO (SKIP TO Q13) IF NO TO ALL OF Q10 AND TO Q11, SKIP TO Q14. 12. A n d w h a t w o u ld th o s e b e ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER CIRCUMSTANCES: W h a t else? Copyright National Academy of Sciences. All rights reserved. US00004731 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -47 13. Does y o u r a irp o rt a lw a ys, usually, so m e tim e s, ra rely, o r n e v e r d isp o se o f s p e n t o r u n use d AFFF b y ______________ ? H ow a b o u t ______________ ? using a n on-site w astew ater m a n a g e m e n t system using a m u n icip a l sew er system using a w a s te w a te r m anagem ent c o n tra c to r tra n sp orting it to a landfill In c in e ra tin g it le ttin g it in filtra te Into th e soli ALWAYS USUALLY SOMETIMES RARELY NEVER n5 a n3 n2 n, n n n n5 4 3 2 1 n5 a n3 n2 n, n5 a n3 n2 n, 5 4 3 2 5 4 3 2 14. (IF THERE IS DISPOSAL OF AFFF: A n d ) d o e s y o u r a irp o rt a lw a y s , usually, som etim es, rarely, or n ever h a n d le containers a n d o th e r m aterials th a t c o m e in to c o n ta c t w ith AFFF b y ______________ ? H o w a b o u t _______________ 2 using th e m a g a in storing th e m on-site Including th e m as part of general w aste disposal using a hazardous w aste disposal facility ALWAYS 5 5 n5 USUALLY SOMETIMES 4 3 4 3 a n3 RARELY 2 2 n2 NEVER n, n5 a n3 n2 n, 15. N o w th in k in g a b o u t fire fig h te r tra in in g ... Has fire fig h te r tra in in g e v e r b e e n held a t your airport? 1 YES (CONTINUE) 2 NO (SKIP TO Q20) Copyright National Academy of Sciences. All rights reserved. US00004732 Use and Potential Impacts of AFFF Containing PFASs at Airports A-48 Use and Potential Impacts of AFFF Containing PFASs at Airports 16. A n d has AFFF b e e n used in all o f th e tra in in g exercises, In s e le c te d tra in in g exercises, o r In n o tra in in g exercises? 3 ALL EXERCISES (CONTINUE) 2 SELECTED EXERCISES (CONTINUE) 1 NO EXERCISES (SKIP TO Q20) 9 VOLUNTEERED: ALTERNATIVE FOAMS ARE USED (CONTINUE) 17. Flos th e AFFF used In th e tra in in g b e e n d is c h a rg e d o n to th e g ro u n d o r c o lle c te d In a n e n g in e e re d c o n ta in m e n t system ? 1 DISCHARGED (CONTINUE) 2 ENGINEERED CONTAINMENT SYSTEM (SKIP TO Q 1 9) w DISCHARGED, ASK: 18. H ow has th e AFFF b e e n h a n d le d a fte r It Is d is c h a rg e d ? PROBE FOR CLARITY A N D SPECIFICS. Copyright National Academy of Sciences. All rights reserved. US00004733 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -49 .. RED CONTAINMENT SYSTEM, ASK: 19. C o u ld y o u p le a s e d e s c rib e th e e n g in e e re d c o n ta in m e n t system th a t Is used In c o lle c tin g th e fo a m used In tra in in g exercises? PROBE FOR CLARITY A N D SPECIFICS. 20. W h e n s ta ff (IF THERE IS TRAINING: o r tra in e es) a re h a n d lin g AFFF fo r w h a te v e r re a so n , d o th e y w e a r _____________ ? Flow a b o u t _______________________2 eye protection w ork gloves nitrile gloves o th e r one-tim e-use gloves safety boots fire-retardant clothing turnout g e ar 2 NO 2 2 2 n , 2 2 2 n , 2 Copyright National Academy of Sciences. All rights reserved. US00004734 Use and Potential Impacts of AFFF Containing PFASs at Airports A-50 Use and Potential Impacts of AFFF Containing PFASs at Airports 21. From y o u r p e rs p e c tiv e , w h a t a re th e best m a n a g e m e n t p ra c tic e s fo r p re v e n tin g spills d u rin g th e h a n d lin g o f AFFF? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER THINGS: W h a t else? 22. N o w I w o u ld like to ta lk a b o u t y o u r e x p e rie n c e w ith th e use o f AFFF. Has AFFF b e e n used a t y o u r a irp o rt, e ith e r o n th e a irp o rt p ro p e r o r o n te n a n t properties, for a c tu a l firefighting purposes? 1 YES (CONTINUE) 2 NO (SKIP TO Q29) 23. A n d h o w m a n y tim es has this h a p p e n e d in th e p a s t 10 years? 24. Does th e a irp o rt h a v e a n y history o f know n c o n ta m in a tio n as a result o f these firefighting activities? 1 YES (CONTINUE) 2 NO (SKIP TO Q29) 3 NOT SURE (SKIP TO Q29) Copyright National Academy of Sciences. All rights reserved. US00004735 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-51 25. C o u ld y o u p le a s e d e s c rib e w h a t h a p p e n e d ? PROBE FOR CLARITY A N D SPECIFICS. 26. A n d w h a t w a s d o n e as a result? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER ACTIONS: W h a t else? "ASK Q26 IF NOT A N S ifliE D IN 025, 27. W e re a n y o f th e a irp o rt's AFFF m a n a g e m e n t p ra c tic e s c h a n g e d as a result o f (this In c id e n t) (these In cid e nts)? 1 YES (CONTINUE) 2 NO (SKIP TO Q29) Copyright National Academy of Sciences. All rights reserved. US00004736 Use and Potential Impacts of AFFF Containing PFASs at Airports A-52 Use and Potential Impacts of AFFF Containing PFASs at Airports 28. A n d w h a t w a s c h a n g e d ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER THINGS: W h a t else? 29. N o w I w o u ld like to ask you a b o u t a n y e n v iro n m e n ta l studies yo u m a y h a ve c o n d u c te d re la tiv e to AFFF. Has y o u r a irp o rt e v e r c o n d u c te d a n e n v iro n m e n ta l site in s p e c tio n s p e c ific a lly re la te d to th e re le a s e o f AFFF in to th e environm ent? 1 YES (CONTINUE) 2 NO (SKIP TO Q37) 30. A nd h o w m a n y such investigations has your a irport c o n d u c te d ? ASK 031 IF IN THE UNITED STATES. IF IN CANADA, SKIP TO Q32. 31. H o w m a n y o f th e se in v e s tig a tio n s h a v e b e e n c o n d u c te d in a c c o r d a n c e w ith UCMR 3 ? ______ 98 DOES NOT KNOW WHAT UCMR 3 IS 99 DOES NOT KNOW HOW M A N Y Copyright National Academy of Sciences. All rights reserved. US00004737 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -53 32. Did (this in v e s tig a tio n ) (a n y o f th e s e in ve stig a tio n s) in c lu d e _______ ? H o w a b o u t _________________ ? BJC JH I s p e c ia liz e d fie ld m e th o d s fo r s a m p lin g fo r PF-A-S specialized a n a lytica l m ethods for testing fo r P-F-A-S m e a s u re m e n t o f th e p re v a le n c e o f P-F-A-S in soil m e a s u re m e n t o f th e p re v a le n c e o f P-F-A-S in s u rfa c e w a te r m e a s u re m e n t o f th e p re v a le n c e o f P-F-A-S in g ro u n d w a te r m e a s u re m e n t o f th e p re v a le n c e o f P-F-A-S in s e d im e n t 2 naaaa2 3 3 3 3 3 3 e n v iro n m e n ta l risk assessm ent 2 3 h u m a n h e a lth risk assessm ent 2 3 33. A n d d id (this in ve stig a tio n ) (a n y o f these investigations) le a d to an analysis o f re m e d ia l options? 1 YES (CONTINUE) 2 NO (SKIP TO Q37) 3 D O N 'T KNOW (SKIP TO Q37) 34. W h a t o p tio n s w e re c o n s id e re d a n d re c o m m e n d e d ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER THINGS: W h a t else? Copyright National Academy of Sciences. All rights reserved. US00004738 Use and Potential Impacts of AFFF Containing PFASs at Airports A-54 Use and Potential Impacts of AFFF Containing PFASs at Airports 35. W ere an y o f th e options a c tu a lly im p le m e n te d ? 1 YES (CONTINUE) 2 NO (SKIP TO Q37) 36. A n d w h a t o p tio n s w e re im p le m e n te d ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER THINGS: W h a t else? 37. A re y o u a w a r e o f a n y a lte rn a tiv e fo rm u la tio n s o f AFFF? 1 YES (CONTINUE) 2 NO (SKIP TO Q42) 38. A n d w h a t a lte rn a tiv e s a re y o u a w a r e o f? PROBE FOR CLARITY A N D SPECIFICS. 39. Do you use a n y o f these alternatives? 1 YES (CONTINUE) 2 NO (SKIP TO Q41) Copyright National Academy of Sciences. All rights reserved. US00004739 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -55 w ALTERNATIVES ARE USED, ASK: 40. A n d w h y d o y o u use th e m ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER REASONS: W h y else? NATIVES ARE NOT USED, ASK: 41. C o u ld y o u p le a s e tell m e w h y y o u d o n o t use th e m ? PROBE FOR CLARITY A N D SPECIFICS. PROBE FOR OTHER REASONS: W h y else? 42. B e fo re w e c o n c lu d e this c o n v e rs a tio n , is th e re a n y th in g y o u w o u ld like to a d d a b o u t th e p ro c u re m e n t, s to ra g e , h a n d lin g , use o r m itig a tio n o f AFFF? THANK RESPONDENT! Copyright National Academy of Sciences. All rights reserved. US00004740 Use and Potential Impacts of AFFF Containing PFASs at Airports A-56 Use and Potential Impacts of AFFF Containing PFASs at Airports RECORD AIRPORT CODE: RECORD AIRPORT CLASS: 21 II 3 III 4 IV NAME OF RESPONDENT: TITLE OF RESPONDENT: DATE COMPLETED: INTERVIEWER: _____________ _______________________ _______________________ ______ / ______ /. _______________________ Copyright National Academy of Sciences. All rights reserved. US00004741 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -57 _____________________________________________________________________ Detailed Data Tabulations for Responding Airports Copyright National Academy of Sciences. All rights reserved. US00004742 Use and Potential Impacts of AFFF Containing PFASs at Airports A-58 Use and Potential Impacts of AFFF Containing PFASs at Airports Valid 1 US 2 Canada Total Country Frequency 149 18 167 Percent 89.2 10.8 100.0 Valid Percent 89.2 10.8 100.0 Cumulative Percent 89.2 100.0 Sample Group Valid 1 SAMPLE GROUP1 - C A T E AIRPORTS 2 SAMPLE GROUP2 - CAT D AIRPORTS 3 SAMPLE GROUP3 - C A T C AIRPORTS 4 SAMPLE GROUP4 - CAT B AIRPORTS 5 SAMPLE GROUP5 - CAT A AIRPORTS Total Frequency 17 19 69 22 40 167 Percent Valid Percent 10.2 10.2 11.4 11.4 41.3 41.3 13.2 13.2 24.0 100.0 24.0 100.0 Cumulative Percent 10.2 21.6 62.9 76.0 100.0 $Q1 Thinking first about the acquisition of AFFF, what are your airport's most important procurement criteria? $Q1 Total Compliance With Government Regulations - FAA, Transport Canada, Mil Spec, Three Percent, Regulation 139 Consistency Of Brand To Avoid Mixing Brands And Resulting Compatibility Issues Availability Of Sufficient Quantities Availability In A Timely Manner Required To Use A List Of Vendors Provided By The Military DOD - State - City Cost Or Price - Have A Budget To Meet - Request Prices From Three Vendors - Have To Take Winning Bid - Product Is Expensive Handled By A Purchasing Agent - Other Agency - Other Organization Environmental Considerations Other Don't Know Responses N Percent Percent of Cases (166) 109 44.5% 65.7% 7 2.9% 4.2% 12 4.9% 7.2% 5 2.0% 3.0% 12 4.9% 7.2% 61 24.9% 36.7% 13 5.3% 7.8% 3 1.2% 1.8% 21 8.6% 12.7% 2 .8% 1.2% 245 100.0% 147.6% Copyright National Academy of Sciences. All rights reserved. US00004743 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -59 Q2A. Considering all of the places where AFFF is stored at your airport, would you say that all, most, some, or none of them are enclosed? Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Frequency 3 2 6 156 167 Percent 1.8 1.2 3.6 93.4 100.0 Valid Percent 1.8 1.2 3.6 93.4 100.0 Cumulative Percent 1.8 3.0 6.6 100.0 Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Q2B. How about are covered? Frequency 5 2 5 155 167 Percent 3.0 1.2 3.0 92.8 100.0 Valid Percent 3.0 1.2 3.0 92.8 100.0 Cumulative Percent 3.0 4.2 7.2 100.0 Q2C. How about are single containment? Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Frequency 38 10 6 113 167 Percent 22.8 6.0 3.6 67.7 100.0 Valid Percent 22.8 6.0 3.6 67.7 100.0 Cumulative Percent 22.8 28.7 32.3 100.0 Q2D. How about are double containment? Frequency 134 10 1 22 167 Percent 80.2 6.0 .6 13.2 100.0 Valid Percent 80.2 6.0 .6 13.2 100.0 Cumulative Percent 80.2 86.2 86.8 100.0 Copyright National Academy of Sciences. All rights reserved. US00004744 Use and Potential Impacts of AFFF Containing PFASs at Airports A-60 Use and Potential Impacts of AFFF Containing PFASs at Airports Q2E. How about have a cement or concrete floor? Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Frequency 7 2 2 156 167 Percent 4.2 1.2 1.2 93.4 100.0 Valid Percent 4.2 1.2 1.2 93.4 100.0 Cumulative Percent 4.2 5.4 6.6 100.0 Valid 1 NONE 2 SOME 4 ALL Total Q2F. How about have an earth or gravel floor? Frequency 164 1 2 167 Percent 98.2 .6 1.2 100.0 Valid Percent 98.2 .6 1.2 100.0 Cumulative Percent 98.2 98.8 100.0 Q2G. How about are an underground storage tank? Valid 1 NONE 2 SOME 3 MOST 4 ALL Total Frequency 161 1 1 4 167 Percent 96.4 .6 .6 2.4 100.0 Valid Percent 96.4 .6 .6 2.4 100.0 Cumulative Percent 96.4 97.0 97.6 100.0 Copyright National Academy of Sciences. All rights reserved. US00004745 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-61 $Q3 When AFFF needs to be removed from firefighting equipment or systems, what processes and solutions do you use? $Q3 Total Drained From The Truck - Gravity Fed From Truck Pumped By Hand From The Truck Pumped By Mechanical Or Electric Pump From The Truck Pumped From The Truck - Mechanism Not Specified Use The Nozzles On The Truck Drained Or Pumped Into Containers - Training Pit, Trailer, Holding Tank, Drums, Barrels, Totes Flushed And Treated As Runoff - Diluted With Water Have Never Done This It Is Flushed Out And Contained Other Don't Know Responses N 30 6 24 70 7 Percent 11.2% 2.2% 8.9% 26.0% 2.6% Percent of Cases (167) 18.0% 3.6% 14.4% 41.9% 4.2% 89 33.1% 53.3% 7 2.6% 4.2% 13 4.8% 7.8% 4 1.5% 2.4% 14 4.5% 8.4% 5 1.9% 3.0% 269 100.0% 161.1% Q4. Does your airport ever conduct foam tests, by which we mean tests of both the AFFF foam mixture and the equipment? Valid 1 YES 2 NO Total Frequency 163 4 167 Percent 97.6 2.4 100.0 Valid Percent 97.6 2.4 100.0 Cumulative Percent 97.6 100.0 Q5. And about how often do you conduct these tests? Valid Missing Total 1 ONCE A MONTH 2 ONCE EVERY TWO TO THREE MONTHS 3 ONCE EVERY FOUR TO SIX MONTHS 4 BETWEEN EVERY SIX MONTHS AND ONCE A YEAR Total System Frequency 14 6 Percent Valid Percent 8.4 8.6 3.6 3.7 Cumulative Percent 8.6 12.3 54 32.3 33.1 45.4 89 53.3 163 97.6 4 2.4 167 100.0 54.6 100.0 100.0 Copyright National Academy of Sciences. All rights reserved. US00004746 Use and Potential Impacts of AFFF Containing PFASs at Airports A-62 Use and Potential Impacts of AFFF Containing PFASs at Airports Q6. Do you ever conduct tests of hangar foam systems? Valid Missing Total 1 YES 2 NO Total System Frequency 12 151 163 4 167 Percent 7.2 90.4 97.6 2.4 100.0 Valid Percent 7.4 92.6 100.0 Cumulative Percent 7.4 100.0 Q7. During hangar system tests, do you test the sprinkler system, the foam generation system, or both? Valid Missing Total 1 SPRINKLER SYSTEM 3 BOTH Total System Frequency 1 11 12 155 167 Percent .6 6.6 7.2 92.8 100.0 Valid Percent 8.3 91.7 100.0 Cumulative Percent 8.3 100.0 Q8. Is the AFFF used in the foam tests discharged onto the ground or collected in an engineered containment system? Valid Missing Total 1 DISCHARGED 2 ENGINEERED CONTAINMENT SYSTEM Total System Frequency 113 Percent Valid Percent 67.7 69.3 Cumulative Percent 69.3 50 29.9 30.7 100.0 163 97.6 4 2.4 167 100.0 100.0 Copyright National Academy of Sciences. All rights reserved. US00004747 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -63 $Q9 Could you please describe the engineered containment system that is used for collecting AFFF from foam tests? $Q9 Total Captured In Container - Bucket - Inflatable Pool - Tub - Specimen Cup Captured In Collection Facility - Containment Basin - Collection Tanks - Concrete Tub - Wash Pit - Fire Pit - Training Pit Sprayed Onto A Target - Contained Area Use Separator - Water - Foam, Oil - Water - Scrubbing System Released To Sewer System Goes To Treatment Plant - Sanitary System Someone Else Handles This - Another Organization Handles This Other Don't Know Responses N Percent Percent of Cases (50) 18 27.3% 36.0% 14 21.2% 28.0% 4 6.1% 8.0% 10 15.2% 20.0% 3 4.5% 6.0% 2 3.0% 4.0% 3 4.5% 6.0% 10 10.6% 20.0% 2 3.0% 4.0% 66 100.0% 132.0% Q10A. Do you replace the AFFF at your airport when it is consumed during training activities? Valid 1 YES 2 NO Total Frequency 143 24 167 Percent 85.6 14.4 100.0 Valid Percent 85.6 14.4 100.0 Cumulative Percent 85.6 100.0 Q10B. How about when it is consumed during emergency incidents? Valid 1 YES 2 NO Total Frequency 161 6 167 Percent 96.4 3.6 100.0 Valid Percent 96.4 3.6 100.0 Cumulative Percent 96.4 100.0 Q10C. How about when it is past its expiration date? Valid 1 YES 2 NO Total Frequency 112 55 167 Percent 67.1 32.9 100.0 Valid Percent 67.1 32.9 100.0 Cumulative Percent 67.1 100.0 Copyright National Academy of Sciences. All rights reserved. US00004748 Use and Potential Impacts of AFFF Containing PFASs at Airports A-64 Use and Potential Impacts of AFFF Containing PFASs at Airports Q10D. How about when it is lost due to leaking containers? Valid 1 YES 2 NO Total Frequency 147 20 167 Percent 88.0 12.0 100.0 Valid Percent 88.0 12.0 100.0 Cumulative Percent 88.0 100.0 Q10E. How about when it is lost due to spills? Valid 1 YES 2 NO Total Frequency 153 14 167 Percent 91.6 8.4 100.0 Valid Percent 91.6 8.4 100.0 Cumulative Percent 91.6 100.0 Q10F. How about when it is used in testing or maintaining firefighting equipment? Valid 1 YES 2 NO Total Frequency 159 8 167 Percent 95.2 4.8 100.0 Valid Percent 95.2 4.8 100.0 Cumulative Percent 95.2 100.0 Q11. Are there other circumstances under which you replace AFFF? Valid 1 YES 2 NO Total Frequency 29 138 167 Percent 17.4 82.6 100.0 Valid Percent 17.4 82.6 100.0 Cumulative Percent 17.4 100.0 Copyright National Academy of Sciences. All rights reserved. US00004749 Use and Potential Impacts of AFFF Containing PFASs at Airports $Q12 And what would those be? Survey Methodology and Findings A -65 $Q12 Total Given To Another Agency When They Needed It Foam Fails Testing Or Doesn't Work Breakdown Of Equipment W th Foam Loss Or Contamination Inventory Goes Below Required Minimum Foam Gets Contaminated Bad Batch - Manufacturer Buyback - Manufacturer Recall Used In An Emergency Other Responses N 5 5 3 3 3 2 2 6 29 Percent 17.2% 17.2% 10.3% 10.3% 10.3% 6.9% 6.9% 20.6% 100.0% Percent of Cases (29) 17.2% 17.2% 10.3% 10.3% 10.3% 6.9% 6.9% 20.7% 100.0% Q13A. Does your airport always, usually, sometimes, rarely, or never dispose of spent or unused AFFF by using an on-site wastewater management system? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 140 2 9 2 14 167 Percent 83.8 1.2 5.4 1.2 8.4 100.0 Valid Percent 83.8 1.2 5.4 1.2 8.4 100.0 Cumulative Percent 83.8 85.0 90.4 91.6 100.0 Q13B. How about by using a municipal sewer system? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 145 7 4 2 9 167 Percent 86.8 4.2 2.4 1.2 5.4 100.0 Valid Percent 86.8 4.2 2.4 1.2 5.4 100.0 Cumulative Percent 86.8 91.0 93.4 94.6 100.0 Copyright National Academy of Sciences. All rights reserved. US00004750 Use and Potential Impacts of AFFF Containing PFASs at Airports A-66 Use and Potential Impacts of AFFF Containing PFASs at Airports Q13C. How about by using a wastewater management contractor? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 113 10 11 4 29 167 Percent 67.7 6.0 6.6 2.4 17.4 100.0 Valid Percent 67.7 6.0 6.6 2.4 17.4 100.0 Cumulative Percent 67.7 73.7 80.2 82.6 100.0 Q13D. How about by transporting it to a landfill? Valid 1 NEVER 2 RARELY 3 SOMETIMES Total Frequency 163 3 1 167 Percent 97.6 1.8 .6 100.0 Valid Percent 97.6 1.8 .6 100.0 Cumulative Percent 97.6 99.4 100.0 Q13E. How about by incinerating it? Valid 1 NEVER 2 RARELY 3 SOMETIMES 5 ALWAYS Total Frequency 162 3 1 1 167 Percent 97.0 1.8 .6 .6 100.0 Valid Percent 97.0 1.8 .6 .6 100.0 Cumulative Percent 97.0 98.8 99.4 100.0 Q13F. How about by letting it infiltrate into the soil? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 102 15 21 12 17 167 Percent 61.1 9.0 12.6 7.2 10.2 100.0 Valid Percent 61.1 9.0 12.6 7.2 10.2 100.0 Cumulative Percent 61.1 70.1 82.6 89.8 100.0 Copyright National Academy of Sciences. All rights reserved. US00004751 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -67 Q14A. And does your airport always, usually, sometimes, rarely, or never handle containers and other materials that come into contact with AFFF by using them again? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 114 15 13 11 14 167 Percent 68.3 9.0 7.8 6.6 8.4 100.0 Valid Percent 68.3 9.0 7.8 6.6 8.4 100.0 Cumulative Percent 68.3 77.2 85.0 91.6 100.0 Q14B. How about by storing them on-site? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 66 7 21 10 63 167 Percent 39.5 4.2 12.6 6.0 37.7 100.0 Valid Percent 39.5 4.2 12.6 6.0 37.7 100.0 Cumulative Percent 39.5 43.7 56.3 62.3 100.0 Q14C. How about by including them as part of general waste disposal? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 111 16 14 2 24 167 Percent 66.5 9.6 8.4 1.2 14.4 100.0 Valid Percent 66.5 9.6 8.4 1.2 14.4 100.0 Cumulative Percent 66.5 76.0 84.4 85.6 100.0 Q14D. How about by using a hazardous waste disposal facility? Valid 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Total Frequency 98 13 16 8 32 167 Percent 58.7 7.8 9.6 4.8 19.2 100.0 Valid Percent 58.7 7.8 9.6 4.8 19.2 100.0 Cumulative Percent 58.7 66.5 76.0 80.8 100.0 Copyright National Academy of Sciences. All rights reserved. US00004752 Use and Potential Impacts of AFFF Containing PFASs at Airports A-68 Use and Potential Impacts of AFFF Containing PFASs at Airports Q15. Has firefighter training ever been held at your airport? Valid 1 YES 2 NO Total Frequency 148 19 167 Percent 88.6 11.4 100.0 Valid Percent 88.6 11.4 100.0 Cumulative Percent 88.6 100.0 Q16. And has AFFF been used in all of the training exercises, in selected training exercises, or in no training exercises? Valid Missing Total 1 NO EXERCISES 2 SELECTED EXERCISES 3 ALL EXERCISES Total System Frequency 34 107 7 148 19 167 Percent Valid Percent 20.4 23.0 64.1 72.3 4.2 88.6 11.4 100.0 4.7 100.0 Cumulative Percent 23.0 95.3 100.0 Q17. Has the AFFF used in the training been discharged onto the ground or collected in an engineered containment system? Valid Missing Total 1 DISCHARGED 2 ENGINEERED CONTAINMENT SYSTEM Total System Frequency 90 Percent Valid Percent 53.9 78.9 Cumulative Percent 78.9 24 14.4 21.1 100.0 114 68.3 53 31.7 167 100.0 100.0 Copyright National Academy of Sciences. All rights reserved. US00004753 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -69 $Q18 How has the discharged AFFF been handled? $Q18 Total Sent To Or Handled By Hazardous Waste Treatment Discharged Into A Fire Training Pit Discharged Into Wastewater Treatment System Discharged Onto The Ground And Diluted Discharged Onto The Ground And Left To Evaporate Or Dissolve Or Dissipate It Is Environmentally Safe Discharged Onto The Ground - No Specifics of Outcome Discharged Onto The Ground - Soil And Left To Soak In Or Infiltrate Discharged Onto The Ground And Contained Or Cleaned Up Other Don't Know Responses N 6 2 2 16 Percent 5.9% 2.0% 2.0% 15.7% Percent of Cases (90) 6.7% 2.2% 2.2% 17.8% 32 31.4% 35.6% 2 2.0% 2.2% 5 4.9% 5.6% 23 22.5% 25.6% 6 5.9% 6.7% 6 5.9% 6.7% 2 2.0% 2.2% 102 100.0% 113.3% $Q19 Could you please describe the engineered containment system that is used in collecting the foam used in training exercises? $Q19 Total Captured In Collection Facility - Training Pit Use Separator - Water - Foam, Oil - Water - Water Reclamation System Dispersed Onto A Paved Surface Goes to Retention Pond - Tank Vacuumed Up With Vacuum Truck Taken Away By Contractor Dispersed or Released - Unclear Where Goes To Treatment Plant - Sanitary System Other Responses N 16 Percent 37.2% Percent of Cases (24) 66.7% 9 20.9% 37.5% 2 4.7% 8.3% 4 9.3% 16.7% 2 4.7% 8.3% 2 4.7% 8.3% 3 7.0% 12.5% 2 4.7% 8.3% 3 2.3% 12.5% 43 100.0% 179.2% Copyright National Academy of Sciences. All rights reserved. US00004754 Use and Potential Impacts of AFFF Containing PFASs at Airports A-70 Use and Potential Impacts of AFFF Containing PFASs at Airports Q20A. When staff or trainees are handling AFFF for whatever reason, do they wear eye protection? Valid 1 YES 2 NO Total Frequency 154 13 167 Percent 92.2 7.8 100.0 Valid Percent 92.2 7.8 100.0 Cumulative Percent 92.2 100.0 Valid 1 YES 2 NO Total Q20B. How about work gloves? Frequency 159 8 167 Percent 95.2 4.8 100.0 Valid Percent 95.2 4.8 100.0 Cumulative Percent 95.2 100.0 Valid 1 YES 2 NO Total Q20C. How about nitrile gloves? Frequency 63 104 167 Percent 37.7 62.3 100.0 Valid Percent 37.7 62.3 100.0 Cumulative Percent 37.7 100.0 Valid 1 YES 2 NO Total Q20D. How about other one-time-use gloves? Frequency 68 99 167 Percent 40.7 59.3 100.0 Valid Percent 40.7 59.3 100.0 Cumulative Percent 40.7 100.0 Valid 1 YES 2 NO Total Q20E. How about safety boots? Frequency 147 20 167 Percent 88.0 12.0 100.0 Valid Percent 88.0 12.0 100.0 Cumulative Percent 88.0 100.0 Copyright National Academy of Sciences. All rights reserved. US00004755 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-71 Valid 1 YES 2 NO Total Valid 1 YES 2 NO Total Q20F. How about fire-retardant clothing? Frequency 132 35 167 Percent 79.0 21.0 100.0 Valid Percent 79.0 21.0 100.0 Cumulative Percent 79.0 100.0 Q20G. How about turnout gear? Frequency 136 31 167 Percent 81.4 18.6 100.0 Valid Percent 81.4 18.6 100.0 Cumulative Percent 81.4 100.0 $Q21 From your perspective, what are the best management practices for preventing spills during the handling of AFFF? $Q21 Total Use Caution - Be Careful - Take Your Time - Pay Attention Attend To Detail Put Safety First - Make Safety A Priority - Use Safety Precautions Use Safety Gear Do Not Do It Alone - Involve Multiple People Use Containment - Containers Use Pumps Use The Right Equipment - Make Sure Equipment Is Set Up Properly Use A Closed System Make Sure Spill Containment Is Available If Needed Make Sure Connections Are Correct - Are Tight Have Clear Procedures - Checklists Provide Thorough Training On Procedures Follow Procedures Maintain Trucks Well - Maintain Equipment Well Make People Aware That The Goal Is Not To Have A Spill Make People Aware Of The Foam's Cost We Have Never Had An Issue or Problem - We Don't Spill Have Absorbent Material Available Work In A Contained Area - Closed Area - Safe Area Other Don't Know Responses N Percent Percent of Cases (167) 36 10.5% 21.6% 8 2.3% 4.8% 13 3.8% 7.8% 17 4.9% 10.2% 36 10.5% 21.6% 20 5.8% 12.0% 19 5.5% 11.4% 6 1.7% 3.6% 2 .6% 1.2% 26 7.6% 15.6% 20 5.8% 12.0% 27 7.8% 16.2% 26 7.6% 15.6% 7 2.0% 4.2% 7 2.0% 4.2% 2 .6% 1.2% 14 4.1% 8.4% 6 1.7% 3.6% 13 3.8% 7.8% 37 10.5% 22.2% 2 .6% 1.2% 344 100.0% 206.0% Copyright National Academy of Sciences. All rights reserved. US00004756 Use and Potential Impacts of AFFF Containing PFASs at Airports A-72 Use and Potential Impacts of AFFF Containing PFASs at Airports Q22. Now I would like to talk about your experience with the use of AFFF. Has AFFF been used at your airport, either on the airport proper or on tenant properties, for actual firefighting purposes? Valid 1 YES 2 NO Total Frequency 119 48 167 Percent 71.3 28.7 100.0 Valid Percent 71.3 28.7 100.0 Cumulative Percent 71.3 100.0 Q23. And how many times has this happened in the past 10 years? Valid Missing Total 1 2 3 4 5 6 7 8 9 10 12 15 20 25 30 40 50 75 100 Total System Frequency 15 18 17 7 15 8 3 3 1 14 4 1 2 1 3 1 4 1 1 119 48 167 Percent 9.0 10.8 10.2 4.2 9.0 4.8 1.8 1.8 .6 8.4 2.4 .6 1.2 .6 1.8 .6 2.4 .6 .6 71.3 28.7 100.0 Valid Percent 12.6 15.1 14.3 5.9 12.6 6.7 2.5 2.5 .8 11.8 3.4 .8 1.7 .8 2.5 .8 3.4 .8 .8 100.0 Cumulative Percent 12.6 27.7 42.0 47.9 60.5 67.2 69.7 72.3 73.1 84.9 88.2 89.1 90.8 91.6 94.1 95.0 98.3 99.2 100.0 Q24. Does the airport have any history of known contamination as a result of these firefighting activities? Valid Missing Total 1 YES 2 NO 3 NOT SURE Total System Frequency 3 112 4 119 48 167 Percent 1.8 67.1 2.4 71.3 28.7 100.0 Valid Percent 2.5 94.1 3.4 100.0 Cumulative Percent 2.5 96.6 100.0 Copyright National Academy of Sciences. All rights reserved. US00004757 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -73 Q27. Were any of the airport's AFFF management practices changed as a result of (this incident) (these incidents)? Valid Missing Total 2 NO System Frequency 3 164 167 Percent 1.8 98.2 100.0 Valid Percent 100.0 Cumulative Percent 100.0 Q29. Now I would like to ask you about any environmental studies you may have conducted relative to AFFF. Has your airport ever conducted an environmental site inspection specifically related to the release of AFFF into the environment? Valid 1 YES 2 NO Total Frequency 18 149 167 Percent 10.8 89.2 100.0 Valid Percent 10.8 89.2 100.0 Cumulative Percent 10.8 100.0 Q30. And how many such investigations has your airport conducted? Valid Missing Total 1 2 5 10 Total System Frequency 12 4 1 1 18 149 167 Percent 7.2 2.4 .6 .6 10.8 89.2 100.0 Valid Percent 66.7 22.2 5.6 5.6 100.0 Cumulative Percent 66.7 88.9 94.4 100.0 Q31. How many of these investigations have been conducted in accordance with UCMR 3? Valid Missing Total 1 98 DOES NOT KNOW WHAT UCMR 3 IS 99 DOES NOT KNOW HOW MANY Total System Frequency 1 9 7 17 150 167 Percent Valid Percent .6 5.9 5.4 52.9 4.2 10.2 89.8 100.0 41.2 100.0 Cumulative Percent 5.9 58.8 100.0 Copyright National Academy of Sciences. All rights reserved. US00004758 Use and Potential Impacts of AFFF Containing PFASs at Airports A-74 Use and Potential Impacts of AFFF Containing PFASs at Airports Q32A. Did this investigation include specialized field methods for sampling for PFAS? Valid Missing Total 1 YES 3 DON'T KNOW Total System Frequency 6 12 18 149 167 Percent 3.6 7.2 10.8 89.2 100.0 Valid Percent 33.3 66.7 100.0 Cumulative Percent 33.3 100.0 Q32B. How about specialized analytical methods for testing for PFAS? Valid Missing Total 1 YES 3 DON'T KNOW Total System Frequency 5 13 18 149 167 Percent 3.0 7.8 10.8 89.2 100.0 Valid Percent 27.8 72.2 100.0 Cumulative Percent 27.8 100.0 Q32C. How about measurement of the prevalence of PFAS in soil? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 5 2 11 18 149 167 Percent 3.0 1.2 6.6 10.8 89.2 100.0 Valid Percent 27.8 11.1 61.1 100.0 Cumulative Percent 27.8 38.9 100.0 Q32D. How about measurement of the prevalence of PFAS in surface water? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 4 2 12 18 149 167 Percent 2.4 1.2 7.2 10.8 89.2 100.0 Valid Percent 22.2 11.1 66.7 100.0 Cumulative Percent 22.2 33.3 100.0 Copyright National Academy of Sciences. All rights reserved. US00004759 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -75 Q32E. How about measurement of the prevalence of PFAS in groundwater? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 4 2 12 18 149 167 Percent 2.4 1.2 7.2 10.8 89.2 100.0 Valid Percent 22.2 11.1 66.7 100.0 Cumulative Percent 22.2 33.3 100.0 Q32F. How about measurement of the prevalence of PFAS in sediment? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 2 3 13 18 149 167 Percent 1.2 1.8 7.8 10.8 89.2 100.0 Valid Percent 11.1 16.7 72.2 100.0 Cumulative Percent 11.1 27.8 100.0 Q32G. How about environmental risk assessment? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 7 1 10 18 149 167 Percent 4.2 .6 6.0 10.8 89.2 100.0 Valid Percent 38.9 5.6 55.6 100.0 Cumulative Percent 38.9 44.4 100.0 Q32H. How about human health risk assessment? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 6 1 11 18 149 167 Percent 3.6 .6 6.6 10.8 89.2 100.0 Valid Percent 33.3 5.6 61.1 100.0 Cumulative Percent 33.3 38.9 100.0 Copyright National Academy of Sciences. All rights reserved. US00004760 Use and Potential Impacts of AFFF Containing PFASs at Airports A-76 Use and Potential Impacts of AFFF Containing PFASs at Airports Q33. And did this investigation lead to an analysis of remedial options? Valid Missing Total 1 YES 2 NO 3 DON'T KNOW Total System Frequency 2 6 10 18 149 167 Percent 1.2 3.6 6.0 10.8 89.2 100.0 Valid Percent 11.1 33.3 55.6 100.0 Cumulative Percent 11.1 44.4 100.0 Q35. Were any of the options actually implemented? Valid Missing Total 1 YES 2 NO Total System Frequency 1 1 2 165 167 Percent .6 .6 1.2 98.8 100.0 Valid Percent 50.0 50.0 100.0 Cumulative Percent 50.0 100.0 Q37. Are you aware of any alternative formulations of AFFF? Valid 1 YES 2 NO Total Frequency 39 128 167 Percent 23.4 76.6 100.0 Valid Percent 23.4 76.6 100.0 Cumulative Percent 23.4 100.0 Copyright National Academy of Sciences. All rights reserved. US00004761 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -77 $Q38 And what alternatives are you aware of? $Q38 Total Alcohol-Based Product - Alcohol-Resistant Product Fluorine-Free Foams - Fluoride-Free Agent - PFAS and PFOA Free Environmentally Friendly Foams - Bio-Friendly Foams Training Foams There Are Different Types - Manufacturers - Not Specific, Can't Remember Names Mentions Unique Specific Types or Names Mentions Europe or European Other Responses N 5 Percent 10.0% Percent of Cases (38) 13.2% 5 10.0% 13.2% 5 10.0% 13.2% 5 10.0% 13.2% 13 26.0% 34.2% 9 18.0% 23.7% 4 8.0% 10.5% 4 4.0% 10.5% 50 100.0% 131.6% Valid Missing Total 1 YES 2 NO Total System Q39. Do you use any of these alternatives? Frequency 9 30 39 128 167 Percent 5.4 18.0 23.4 76.6 100.0 Valid Percent 23.1 76.9 100.0 Cumulative Percent 23.1 100.0 $Q41 Could you please tell me why you do not use them? $Q41 Total They Do Not Conform to Specifications - They Are Not In Compliance With Regulations - They Are Not Mil Spec We Are Using What We Have Always Used We Are Looking At Alternatives For Future Procurements - We Have Just Received Approval To Use An Alternative AFFF Is Compatible With Our Equipment - What We Already Have Alternatives Are More Expensive Other Don't Know Responses N Percent Percent of Cases (30) 19 51.4% 63.3% 4 10.8% 13.3% 3 8.1% 10.0% 4 10.8% 13.3% 3 8.1% 10.0% 2 5.4% 6.7% 6 2.7% 6.7% 37 100.0% 123.3% Copyright National Academy of Sciences. All rights reserved. US00004762 Use and Potential Impacts of AFFF Containing PFASs at Airports A-78 Use and Potential Impacts of AFFF Containing PFASs at Airports $Q42 Is there anything you would like to add about the procurement, storage, handling, use or mitigation of AFFF? $Q42( We Have Never Had Any Problems a) We Need AFFF For Safety Or Effectiveness - The Product Is Effective None - Nothing Other Total a Group Responses N 5 Percent 3.0% Percent of Cases (167) 3.0% 3 1.8% 1.8% 143 85.1% 85.6% 17 10.1% 10.2% 168 100.0% 100.6% Copyright National Academy of Sciences. All rights reserved. US00004763 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -79 Valid 20151207 20151208 20151209 20151211 20151214 20151215 20151216 20151217 20151218 20151221 20151222 20151223 20151228 20151229 20160104 20160105 20160106 20160107 20160108 20160111 20160112 20160113 20160114 20160115 20160118 20160122 20160125 20160126 20160127 20160129 20160201 20160202 20160203 20160205 20160208 20160210 20160211 20160212 20160217 20160218 20160307 Total Date of Interview Frequency 12 11 13 5 7 7 4 3 4 4 5 2 5 3 5 4 5 5 4 3 2 7 2 4 1 2 3 7 4 2 1 1 4 4 1 2 1 1 4 2 1 167 Percent 7.2 6.6 7.8 3.0 4.2 4.2 2.4 1.8 2.4 2.4 3.0 1.2 3.0 1.8 3.0 2.4 3.0 3.0 2.4 1.8 1.2 4.2 1.2 2.4 .6 1.2 1.8 4.2 2.4 1.2 .6 .6 2.4 2.4 .6 1.2 .6 .6 2.4 1.2 .6 100.0 Valid Percent 7.2 6.6 7.8 3.0 4.2 4.2 2.4 1.8 2.4 2.4 3.0 1.2 3.0 1.8 3.0 2.4 3.0 3.0 2.4 1.8 1.2 4.2 1.2 2.4 .6 1.2 1.8 4.2 2.4 1.2 .6 .6 2.4 2.4 .6 1.2 .6 .6 2.4 1.2 .6 100.0 Cumulative Percent 7.2 13.8 21.6 24.6 28.7 32.9 35.3 37.1 39.5 41.9 44.9 46.1 49.1 50.9 53.9 56.3 59.3 62.3 64.7 66.5 67.7 71.9 73.1 75.4 76.0 77.2 79.0 83.2 85.6 86.8 87.4 88.0 90.4 92.8 93.4 94.6 95.2 95.8 98.2 99.4 100.0 Copyright National Academy of Sciences. All rights reserved. US00004764 Use and Potential Impacts of AFFF Containing PFASs at Airports A-80 Use and Potential Impacts of AFFF Containing PFASs at Airports Valid 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 33 36 37 41 42 48 50 59 Total Length of Interview Frequency 1 1 2 2 1 7 5 8 10 11 15 8 5 12 6 10 5 7 6 9 11 5 3 4 3 3 1 1 1 1 1 1 1 167 Percent .6 .6 1.2 1.2 .6 4.2 3.0 4.8 6.0 6.6 9.0 4.8 3.0 7.2 3.6 6.0 3.0 4.2 3.6 5.4 6.6 3.0 1.8 2.4 1.8 1.8 .6 .6 .6 .6 .6 .6 .6 100.0 Valid Percent .6 .6 1.2 1.2 .6 4.2 3.0 4.8 6.0 6.6 9.0 4.8 3.0 7.2 3.6 6.0 3.0 4.2 3.6 5.4 6.6 3.0 1.8 2.4 1.8 1.8 .6 .6 .6 .6 .6 .6 .6 100.0 Cumulative Percent .6 1.2 2.4 3.6 4.2 8.4 11.4 16.2 22.2 28.7 37.7 42.5 45.5 52.7 56.3 62.3 65.3 69.5 73.1 78.4 85.0 88.0 89.8 92.2 94.0 95.8 96.4 97.0 97.6 98.2 98.8 99.4 100.0 Copyright National Academy of Sciences. All rights reserved. US00004765 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-81 ___________________________________________________________________________________________________________ Verbatim Transcriptions of Open-Ended Responses (Note: Attachment C is not published herein, but is available upon request from Cooperative Research Programs Senior Program Officer Joe Navarrete, atjnavarrete@nas.edu.) Copyright National Academy of Sciences. All rights reserved. US00004766 Use and Potential Impacts of AFFF Containing PFASs at Airports A-82 Use and Potential Impacts of AFFF Containing PFASs at Airports ________________________________________________________________________ Statistically Significant Cross-Tabulations by Country Copyright National Academy of Sciences. All rights reserved. US00004767 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -83 Q2A. Considering all of the places where A FFF is stored at your airport, would you say that all, most, some, or none of them are enclosed? * Country Crosstab Q2A. Considering all of the places where AFFF is stored at your airport, would you say that all, most, some, or none of them are enclosed? 1 NONE ^ SOME 3 MOs t 4 ALL Total Count % within Country Count % within Country Count % within Country Count % within Country Count % within Country Country 1 US 1 .7% 1 .7% 5 3.4% 142 95.3% 149 100.0% 2 Canada 2 11.1% 1 5.6% 1 5.6% 14 77.8% 18 100.0% Total 3 1.8% 2 1.2% 6 3.6% 156 93.4% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 13.688(a) 7.976 12.863 167 Asymp. Sig. df (2-sided) 3 .003 3 .047 1 .000 a 5 cells (62.5%) have expected count less than 5. The minimum expected count is .22. Copyright National Academy of Sciences. All rights reserved. US00004768 Use and Potential Impacts of AFFF Containing PFASs at Airports A-84 Use and Potential Impacts of AFFF Containing PFASs at Airports Q2F. How about have an earth or gravel floor? * Country Crosstab Q2F. How about have an earth or gravel floor? Total 1 NONE 2 SOME 4 ALL Count % within Country Count % within Country Count % within Country Count % within Country Country 1 US 148 99.3% 0 .0% 1 .7% 149 100.0% 2 Canada 16 88.9% 1 5.6% 1 5.6% 18 100.0% Total 164 98.2% 1 .6% 2 1.2% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 11.655(a) 6.549 5.820 167 Asymp. Sig. df (2-sided) 2 .003 2 .038 1 .016 a 4 cells (66.7%) have expected count less than 5. The minimum expected count is .11. Copyright National Academy of Sciences. All rights reserved. US00004769 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -85 Q5. And about how often do you conduct these te sts? * Country Crosstab Q5. And about how often do you conduct these tests? 1 ONCE A MONTH 2 ONCE EVERY TWO TO THREE MONTHS Count % within Country Count % within Country Total 3 ONCE EVERY FOUR TO SIX MONTHS 4 BETWEEN EVERY SIX MONTHS AND ONCE A YEAR Count % within Country Count % within Country Count % within Country Country 1 US 14 9.7% 6 2 Canada 0 .0% 0 4.1% .0% 53 36.6% 72 49.7% 145 100.0% 1 5.6% 17 94.4% 18 100.0% Total 14 8.6% 6 3.7% 54 33.1% 89 54.6% 163 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 13.009(a) 16.489 9.120 163 Asymp. Sig. df (2-sided) 3 .005 3 .001 1 .003 a 2 cells (25.0%) have expected count less than 5. The minimum expected count is .66. Copyright National Academy of Sciences. All rights reserved. US00004770 Use and Potential Impacts of AFFF Containing PFASs at Airports A-86 Use and Potential Impacts of AFFF Containing PFASs at Airports Q13C. How about by using a wastewater management contractor? * Country Crosstab Q13C. How about by using a wastewater management contractor? Total 1 NEVER Count % within Country ^ RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Count % within Country Count % within Country Count % within Country Count % within Country Count % within Country Country 1 US 107 71.8% 8 5.4% 9 6.0% 2 1.3% 23 15.4% 149 100.0% 2 Canada 6 33.3% 2 11.1% 2 11.1% 2 11.1% 6 33.3% 18 100.0% Total 113 67.7% 10 6.0% 11 6.6% 4 2.4% 29 17.4% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 14.386(a) 11.724 9.073 167 Asymp. Sig. df (2-sided) 4 .006 4 .020 1 .003 a 5 cells (50.0%) have expected count less than 5. The minimum expected count is .43. Copyright National Academy of Sciences. All rights reserved. US00004771 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -87 Q14B. How about by storing them on-site? * Country Crosstab Q14B. How about by on-site? Total 1 NEVER 2 RARELY 3 SOMETIMES 4 USUALLY 5 ALWAYS Count % within Country Count % within Country Count % within Country Count % within Country Count % within Country Count % within Country Country 1 US 61 40.9% 6 4.0% 19 12.8% 6 4.0% 57 38.3% 149 100.0% 2 Canada 5 27.8% 1 5.6% 2 11.1% 4 22.2% 6 33.3% 18 100.0% Total 66 39.5% 7 4.2% 21 12.6% 10 6.0% 63 37.7% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 9.810(a) 6.731 .550 167 Asymp. Sig. df (2-sided) 4 .044 4 .151 1 .458 a 3 cells (30.0%) have expected count less than 5. The minimum expected count is .75. Copyright National Academy of Sciences. All rights reserved. US00004772 Use and Potential Impacts of AFFF Containing PFASs at Airports A-88 Use and Potential Impacts of AFFF Containing PFASs at Airports ________________________________________________________________ Statistically Significant Cross-Tabulations by Airport Size Copyright National Academy of Sciences. All rights reserved. US00004773 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A -89 Q2D. How about are double containment? * Size Crosstab Q2D. How about are double containment? 1 NONE Count % within Size 2 SOME Count % within Size 3 MOST Count % within Size 4 ALL Count % within Size Total Count % within Size CAT E 12 70.6% 1 5.9% 1 5.9% 3 17.6% 17 100.0% CAT D 11 57.9% 4 21.1% 0 .0% 4 21.1% 19 100.0% Size CAT C 58 84.1% 3 4.3% 0 .0% 8 11.6% 69 100.0% CAT B 20 90.9% 0 .0% 0 .0% 2 9.1% 22 100.0% CAT A 33 82.5% 2 5.0% 0 .0% 5 12.5% 40 100.0% Total 134 80.2% 10 6.0% 1 .6% 22 13.2% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 21.136(a) 15.367 1.945 167 df 12 12 1 Asymp. Sig. (2-sided) .048 .222 .163 a 13 cells (65.0%) have expected count less than 5. The minimum expected count is .10. Copyright National Academy of Sciences. All rights reserved. US00004774 Use and Potential Impacts of AFFF Containing PFASs at Airports A-90 Use and Potential Impacts of AFFF Containing PFASs at Airports Q5. And about how often do you conduct these te sts? * Size Crosstab Q5. And about how often do you conduct these tests? 1 ONCE A MONTH Count % within Size 2 ONCE EVERY TWO TO THREE MONTHS Count % within Size Total 3 ONCE EVERY FOUR TO SIX MONTHS 4 BETWEEN EVERY SIX MONTHS AND ONCE A YEAR Count % within Size Count % within Size Count % within Size Size Total CAT E 1 6.3% 0 CAT D 2 10.5% O CAT C 7 10.4% O CAT B 0 .0% 0 CAT A 4 10.0% 0 14 8.6% .0% 15.8% 4.5% .0% .0% 3.7% 3 18.8% 8 42.1% 26 38.8% 8 38.1% 9 22.5% 54 33.1% 12 6 31 13 27 89 75.0% 16 100.0% 31.6% 19 100.0% 46.3% 67 100.0% 61.9% 21 100.0% 67.5% 40 100.0% 54.6% 163 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 21.841(a) 23.464 1.126 163 df 12 12 1 Asymp. Sig. (2-sided) .039 .024 .289 a 9 cells (45.0%) have expected count less than 5. The minimum expected count is .59. Copyright National Academy of Sciences. All rights reserved. US00004775 Use and Potential Impacts of AFFF Containing PFASs at Airports Survey Methodology and Findings A-91 Q22. Now I would like to talk about your experience with the use of A FFF. Has A FFF been used at your airport, either on the airport proper or on tenant properties, for actual firefighting purposes? * Size Q22. Now I would like to talk about your experience with the use of AFFF. Has AFFF been used at your airport, either on the airport proper or on tenant properties, for actual firefighting purposes? 1 YES Count % within Size 2 NO Count % within Size Total Count % within Size Crosstab Size Total CAT E CAT D CATC CAT B C ATA 16 15 54 11 23 119 94.1% 78.9% 78.3% 50.0% 57.5% 71.3% 1 4 15 11 17 48 5.9% 21.1% 21.7% 50.0% 42.5% 17 19 69 22 40 100.0% 100.0% 100.0% 100.0% 100.0% 28.7% 167 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 15.089(a) 15.878 11.833 167 Asymp. Sig. df (2-sided) 4 .005 4 .003 1 .001 a 1 cells (10.0%) have expected count less than 5. The minimum expected count is 4.89. Copyright National Academy of Sciences. All rights reserved. US00004776 Use and Potential Impacts of AFFF Containing PFASs at Airports A-92 Use and Potential Impacts of AFFF Containing PFASs at Airports Q29. Now I would like to ask you about any environmental studies you may have conducted relative to A FFF. Has your airport ever conducted an environmental site inspection specifically related to the release of A FFF into the environment? * Size Crosstab Q29. Now I would like to ask you about any environmental studies you may have conducted relative to AFFF. Has your airport ever conducted an environmental site inspection specifically related to the release of AFFF into the environment? 1 YES Count Size CAT E CAT D CATC CAT B CAT A 4490 1 Total 18 % within Size 23.5% 21.1% 13.0% .0% 2.5% 10.8% 2 NO Count 13 15 60 22 39 149 % within Size 76.5% 78.9% 87.0% 100.0% 97.5% 89.2% Total Count % within Size 17 19 69 22 40 167 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% Chi-Square Tests Pearson Chi-Square Likelihood Ratio Linear-by-Linear Association N of Valid Cases Value 10.836(a) 13.286 9.480 167 Asymp. Sig. df (2-sided) 4 .028 4 .010 1 .002 a 4 cells (40.0%) have expected count less than 5. The minimum expected count is 1.83. Copyright National Academy of Sciences. All rights reserved. US00004777 Use and Potential Impacts of AFFF Containing PFASs at Airports AFFF Alternatives MA iPi PL Fl MM UD I IAY RD U n d erstan d in " blent Firefighting foam used for extinguishing aircraft fires has been described as being a stable mass of small air-filled bubbles, which have a lower specific gravity than that of hydrocarbon fuels or water (FAA, 2004). In airport operations in North America, AFFF is used as a fire-extinguishing agent to suppress Class B fires: i.e., fires of flammable and combustible liquids such as crude oil, gasoline and fuel oils. AFFF exhibits unique properties that make it very effective as a fire extinguishing agent, but can be potentially problematic relative to human health and the environment. Many historical AFFF formulations contained PFOS as the predominant active ingredient. Due to concerns associated with PFOS's ubiquity and persistence in the environment, alterna tive formulations containing fluorochemicals with a perfluorinated eight-carbon (C8) "tail" have been used. Similar concerns (i.e., the breakdown of these long chained fluorotelomers to PFOA, which, like PFOS, has been shown to be very persistent in the environment) caused manufac turers to look for other alternate formulations that included fluorinated chemicals with shorter chain lengths, such as C6-based fluorotelomers. Alternatives Due to the environmental concerns associated with PFOS, the United Nations Environment Programme (UNEP) (2011) referenced a PFOS alternative as: "When compared to PFOS, either reduces the potential for harm to human health or the environment or has not been shown to be a potential persistent organic pollutant itself." Two guiding documents on the identification and assessment of PFOS alternatives were prepared and released by UNEP under the Stockholm Convention (2011): Draft guidance on alternatives to perfluorooctane sulfonic acid and its derivatives (UNEP/POPS/ POPRC.6/13/Add.3/Rev.l), which presents information on alternatives to PFOS and its deriv atives. It also includes a breakdown of the uses of PFOS (e.g., coating, metal plating, firefighting foams) and indicates where alternatives have been suggested, are available, or have already been introduced to markets. The intent of this document was to enhance the capacity to tran sition to phase out of PFOS. Technical paper on the identification and assessment o f alternatives to the use o fperfluorooctane sulfonic acid in open applications (UNEP/POPS/POPRC.8/INF/17.3) prepared for use by the Persistent Organic Pollutants Review Committee to develop recommendations on alternatives to PFOS in open applications. Alternatives suggested by UNEP are in no way exhaustive. Challenges continue to exist today in that there is often more information on PFOS-based AFFF than on non-PFOS based alternatives. Copyright National Academy of Sciences. All rights reserved. B-1 US00004778 Use and Potential Impacts of AFFF Containing PFASs at Airports B-2 Use and Potential Impacts of AFFF Containing PFASs at Airports No Fluorocarbon surfactants Present Protein Foam 1 Fluoroprotein Foam 1 Increasing Amounts of Fluorocarbon surfactants Present FFFP AFFF 11 No Aqueous Film Formed; No Dry Powder Compatibility No Aqueous Film Formed; Dry Powder Compatibility Aqueous Film May Form A Dry Powder Compatibility Aqueous Film Formed Dry Powder Compatibility Figure B-1. Relationship o f different types o f foam agents with respect to fluorocarbon surfactant content, film formation capabilities, and dry p o w d e r compatibility. Source: Sch effey a n d Wright, 1994. Information on alternatives may also be protected by trade secrets or is not peer-reviewed (UNEP 2011). This document looks specifically at the evolution from the PFOS-based AFFF, provides alternatives to AFFF (and PFOS-based AFFF), and outlines some advantages and dis advantages, as suggested from a variety of sources, associated with each. Types of Firefighting Foams Firefighting foams that are commonly used range in their fluorocarbon surfactant content. Fluorine based foams differ in their content of fluorocarbon surfactants (as shown on Figure B-1) making different types of foam agents vary in their performance with regard to knockdown, heat resistance, fuel tolerance and vapor suppression. Table B-1provides further detail on the different types of firefighting foams used to combat Class B fires. A lternatives History AFFF was developed in the 1960s for use in aviation, marine and shallow pit fires (UNEP 2010). Fluorochemicals in early AFFF formulations were the result of one of two processes, electro chemical fluorination or telomerization. The electrochemical fluorination process was domi nated by 3M, a major manufacturer of firefighting foam, with AFFF containing fluorochemicals synthesized by electrochemical fluorination accounting for 75% of the total AFFF stockpiled on US military bases (Place et al. 2012). The remaining stockpiled AFFF in the US contains fluoro chemicals produced by telomerization. In 2002, 3M voluntarily removed an entire class of AFFF which contained and/or degraded into PFOS due to human health and environmental concerns. Regulations in numerous jurisdic tions followed, placing restrictions on or banning the production and/oruse ofAFFF containing PFOS and/or PFOS precursors and/or other PFASs. Regulations in the US, Canada, European Union (EU), Australia and Japan currently ban all new production of PFOS-based products. In the US, Australia and Japan, these regulations do not currently restrict the use of existing stocks of PFOS-based foam. In the EU and Canada, existing stocks of PFOS-based foam were removed Copyright National Academy of Sciences. All rights reserved. US00004779 Use and Potential Im pacts o f AFF F C ontaining PFASs at A irports Copyright National Academy of Sciences. All rights reserved. Table B-1. Types of firefighting foams for Class B fires. Type Description Use(s) Characteristics F lu o rin e-F ree l oams (F3) Protein Foam (PF) Fluoroprolcin Foam (FP) Film Form ing Fliioro-Prolcin (FFFP) Aqueous Film Form ing Foam (AFFF) A lco liol-R osisliinl A IT T' (AU-A1TT) Synthetic Protein Based Protein Based Protein Based Synthetic Synthetic Formulated without the Mechanical foam Manufactured from use of fluorochemicals. produced by protein foam proportioning foam concentrates with concentrate with water added fluorocarbon at specific rations and surfactants. using and discharging the resulting solution through an aspirating device. Based on protein foam formulations but are produced by increasing the quality and quantity of fluorocarbon surfactants. Synthetically formed by combining fluorine-free hydrocarbon foaming compounds with highly fluorinated surfactants. Uses plain AFFF concentrate as a base with the addition of a high molecular weight polymer to protect the foam blanket from being destroyed by a polar solvent. Hydrocarbon fires. Hydrocarbon fires. Aircraft rescue training foam. Re-healing for burn back resistance. Good heat resistance. Do not break down to PFOS or PFOA. Does not form an aqueous film. Acts to exclude the air from the fuel vapors to prevent the creation of a combustible mixture. Relatively slow moving due to its stability when used to cover the surface of a flammable liquid. Require gentle foam application to avoid contamination if plunged directly onto the fuel surface. Does not form an aqueous film. Hydrocarbon fires. Hydrocarbon storage tank firefighting. Hydrocarbon fires. Provides for vapor suppression and reduced fuel pick up. More resistant to fuel contamination/pickup. More mobile foam blanket when discharged onto the flammable liquid. Does not form an aqueous film. Ability to form a vapor sealing film similar to AFFF due to the higher concentrations of fluorochemicals than FP. Has the quick knockdown of AFFF with the added burn back resistance of standard fluoroprotein foam. Does not have knockdown as rapid as AFFF when used on a spill fire. Hydrocarbon fires. Aircraft rescue. Forms an aqueous film on the surface of a flammable liquid. Creates a barrier to exclude air or oxygen, and is capable of suppressing the evolution of fuel vapors. Used by city and industrial fire departments due to the effectiveness on both hydrocarbons and polar solvents. Addition of the polym er allows the foams to not be destroyed by polar solvents. Forms a membrane to separate the polar solvent from the foam blanket. (continued on next page) US00004780 Use and Potential Im pacts o f AFF F C ontaining PFASs at A irports Copyright National Academy of Sciences. All rights reserved. Table B-1. (Continued). Fluorine-Free Foams (F3) Protein Foam (PF) Fluoroprotein Foam (FP) Film Forming Fluoro-Protein (FFFP) Aqueous Film Forming Foam (AFFF) A lco h o l-R esista n t AFFF (AR-AFFF) M aterials E nvironm ental Considerations Water-soluble nonfluorinated polymer additives. Hydrocarbon surfactants. Considered to be biodegradable, low in toxicity, and can be treated in sewage treatment plants. Hydrolyzed protein (i.e., hoof and horn meal) Foam stabilizers, Preservatives (to prevent bacterial decomposition and corrosion). Protein Foam. Fluorocarbon surfactants. Considered to be Contains stable, biodegradable and low environmentally in toxicity. persistent fluorinated degradation products. May require pre treatment prior to standard wastewater treatment plants. Protein Foam. Increased quantity of fluorocarbon surfactants. Contains stable, environmentally persistent fluorinated degradation products. May require pre treatment prior to standard wastewater treatment plants. Synthetic foaming agents (hydrocarbon surfactants). Solvents (i.e., viscosity leveler) Similar inputs to AFFF concentrate. Polysaccharide polymer. Fluorocarbon surfactants. Small amount of salts. Foam stabilizers. Contains stable, environm entally persistent fluorinated degradation products. May require pre treatment prior to standard wastewater treatment plants. Contains stable, environmentally persistent fluorinated degradation products. Requires pre-treatment prior to standard wastewater treatment plants. North American Standards UL 162 (Type 3 application), Standard for Safety for Foam Equipment and Liquid Concentrates. UL 162 (Type 3 UL 162 (Type 3 application), Standard application), Standard for Safety for Foam for Safety for Foam Equipment and Liquid Equipment and Liquid Concentrates. Concentrates. UL 162 (Type 3 MH-F-24385F application), Standard CAN/ULC-S560 for Safety for Foam Equipment and Liquid Concentrates. CAN/ULC-S563 UL 162 (Type 3 application), Standard for Safety for Foam Equipment and Liquid Concentrates. CAN/ULC-S560 Application Technique Aspirating Device. Non-Aspirating Device. Sub-surface Injection Method. M ust always be used M ust always be used with an air aspirating with an air aspirating type discharge device. type discharge device. Air-aspirating or Non Air-aspirating or Non Air-aspirating nozzles. Air-aspirating nozzles Does not provide expansion ratios as good as AFFF with a non-aspirating nozzle. Air-aspirating or Non Air-aspirating nozzles. W hen used on an alcohol fire, an air aspirating nozzle will provide better performance. Application Rate .16 .16 .16 i .10 .10 .10 (g p m /sq .ft)1 1http://www.chemguard.com/about-us/documents-library/foam-info/general.htm US00004781 Use and Potential Impacts of AFFF Containing PFASs at Airports from service in 2011 and 2013, respectively. Production and sale of PFOS-based AFFF in China has continued. In the early 2000s, following 3M's decision, the US EPA indicated that some early alternatives to PFOS-based AFFF can break down into PFOA or other perfluorocarboxylic acids (PFCAs) which, like PFOS, have been observed to be persistent in the environment. As a result, in 2006, the US EPA introduced a voluntary directive through the global 2010/2015 PFOA Stewardship Program which called for a 95 percent reduction of plant emissions and product content of PFOA, PFOA precursors, and related homologue materials by 2010, and a 100 percent reduc tion by 2015. This global stewardship program has been adopted by other countries including Canada. Since 2006, both the US and Canada have taken steps to phase out the production and use of C8-based fluorotelomers. This has also contributed to a shift by AFFF manufacturers toward using shorter chain (i.e., PFCAs < C6, having six or less carbon molecules) fluorinated chemicals. The 2010/2015 PFOA Stewardship Program is voluntary, and there are no restrictions banning the use of C8-based fluorotelomers. The implementation of regulations brought about substantial research and development to find substitutes to PFOS-based AFFF. The following sections identify alternatives to PFOS-based AFFF and AFFF that can break down into other PFASs. Fluorine Based Foam Agents Description The FAA identifies the following fluorinated agents for airport firefighting involving hydro carbon fuels: Aqueous Film-Forming Foam (AFFF); Fluoroprotein Foam (FP); and, Film-Forming Fluoroprotein Foam (FFFP). Similarly, Transport Canada recognizes AFFF and FFFP foams to be the principal extinguishing agents for airports. What gives these fluorine based foams their function and properties are the fluorocarbon sur factants. Fluorocarbon surfactants are not naturally occurring; rather, they are man-made chemi cals that are used in firefighting due to their ability to reduce surface tension and form a him on top of lighter fuel (Sontake and Waugh, 2014). Since production of PFOS-based AFFF ceased, most modern AFFF (except some produced in China and India) contains fluorocarbon surfac tants produced by telomerization. These are referred to as fluorotelomers. Fluorotelomers do not break down into PFOS and do not contain any chemicals currently considered to be persistent, bioaccumulative, and toxic (Melkote et al. 2012). Although currently thought to be better practice than using PFOS-based AFFF, there is still some uncertainty with respect to potential environmental impacts associated with other types of PFASs found in fluorotelomer based foams. Early alternatives to PFOS-based AFFF that contained longer chain (C8-based) fluorotelomers are on the path towards being phased out by producers due to their potentially hazardous and long-range transport properties. This "phase-out" has created a shift towards shorter chain C6, C4and C3-based perfluoroalkylated chemicals, which are perceived to be less problematic. The most common and most widely used are C6-based fluorotelomers. The reformulated C6-based fluorotelomers are used in AFFF, FFFP, and FP foams. The predominant breakdown product from the C6-based fluorotelomers is referred to as the 6:2 fluorotelomer sulfonate (6:2 FtS) (Cortina and Korzeniowski, 2008). A broad range of existing data suggest that 6:2 FTS is not similar to PFOS in either its physical or eco-toxicological prop erties (Cortina 2010). 6:2 FTS does, however, have the potential, depending on environmental AFFF Alternatives B-5 Copyright National Academy of Sciences. All rights reserved. US00004782 Use and Potential Impacts of AFFF Containing PFASs at Airports B-6 Use and Potential Impacts of AFFF Containing PFASs at Airports conditions, to eventually degrade to PFHxA (perfluorohexane), PFPeA (perfluoropentanoic acid) and 5:3 fluorotelomer acid. Benefits The benefits presented in the literature and by product manufacturers on the use of fluorine based foams, specifically fluorotelomer-based foams, include: Strong Performance--In addition to stability, a key factor in the performance of firefighting foams containing fluorocarbon surfactants is their extremely low surface tension, which has been shown to not be matched with other surfactants apart from PFOS itself (UNEP 2011). It is this sta bility that creates rapid surface migration to contribute to high-speed coating processes, beneficial in the event of a fire that involves hydrocarbons. Fluorocarbon surfactants in firefighting foams contribute to the strong performance in quickly and effectively extinguishing fires resulting from highly combustible and flammable materials as they provide rapid extinguishment, burnback resistance, and protection against vapor release (FFFC 2014). Compliance-- In the US, the MIL-SPEC (MIL-F-24385) specifications are known to be the most stringent standards for firefighting foams. Only fluorotelomer-based AFFF foam agents extinguished gasoline and heptane fires in less than 30 seconds, passing the test to qualify for the MIL-SPEC specification. In the US, the FAA requires all US airports to carry AFFF agents that have met the MIL-SPEC specifications. In Canada, it is required that AFFF meet the ULC Standard, CAN/ULC-S560. There are many fluorotelomer based AFFF products that meet this standard for use at airports in both the US and Canada. Low Hazard Profile (based on current data)--Fluorotelomer based foams do not break down into PFOS (perfluorooctance sulfonate) or homologues of PFOS, nor do they break down into any chemicals that are currently listed as persistent organic pollutants (POPs) under the Stockholm Convention (FFFC 2014). Recent studies of fluorotelomers that break down into 6:2 FTS show it to have low acute, sub-chronic and aquatic toxicity, negative genetic and developmental toxicol ogy, not to be bio-accumulative according to regulatory criteria, and to be significantly lower than PFOS in biopersistence (Seow 2013). A pilot study determined that since the phase-out of PFOS based materials in 2002, there has been a 60% decline in PFOS concentrations in serum samples collected from the Red Cross in 2006 in comparison to 2000-2001 data (Olsen et al. 2008). This is consistent with the timeline of phase-out and the half-life of PFOS. Disadvantages The disadvantages presented in the literature and by product manufacturers on the use of fluorine-based foams include: Environmental Persistence--While fluorotelomers are low in biopersistance, they can be considered as environmentally persistent. All fluorinated materials are highly persistent in the environment due to their perfluorinated chains that degrade very slowly, if at all, under environ mental conditions (Blum et al., 2015). Measurements made at former US military firefighting foam training sites found that 6:2 FTS has an environmental half-life of at least a decade (Seow, 2013). In addition, according to the information provided by Germany in 2011 to UNEP, due to the very limited ability of the C6-based perfluroalkylates bodies to adsorb, it is difficult to remove these chemicals from water (UNEP 2011). More recently, the Madrid Statement on Poly-and Perfluoro alkyl Substances (2015) has come forward to suggest that the use of the entire class of PFAS (including the short chain alternatives) should be avoided due to their environmental persistence. Use of the short-chain alternatives may not reduce the amount of PFAS in the environment, and the environmental impacts may be compounded by use in larger quantities required to provide the same performance (Blum et al. 2015). Copyright National Academy of Sciences. All rights reserved. US00004783 Use and Potential Impacts of AFFF Containing PFASs at Airports Limited Data--There are limited independent pieces of research or studies on the environ mental and human health impacts of AFFF formulated with fluorotelomers, in comparison to the research done for foams that use PFOS and PFOA. In addition, there is little publicly avail able information on the chemical structures, properties, uses and toxicological profiles of these fluorotelomer based alternatives. As is suggested in Place et al. (2012), further research studying the fate of the fluorochemicals during biodegradation is needed as the environmental behavior and toxicity of individual fluorinated surfactants is still unknown (Place et al. 2012). Products There are a number of AFFF, FFFP, and FP products that are available today that use fluoro chemicals, particularly C6-based fluorotelomers as inputs. These firefighting foams are formu lated using their own blends or use inputs from other manufacturers (e.g., Chemours, Dynax). Inputs currently on the market include: Forafac products, with 65-95% C6fluorinated amphoteric telomers based on perfluorohexyl ethyl sulfonamide-- Produced by Chemours (Dupont). NovecTM 1230 Fire Protection Fluid containing dodecafluoro-2-methylpentan-3-one-- Produced by 3M. Dynax DX1025 - blend of C6-based fluorocarbon surfactants - Produced by Dynax America Corporation. Fluorine-Free Firefighting Foams Description Fluorine-free firefighting foams, sometimes referred to as "F3s," are formulated without the use of fluorochemicals. To be considered fluorine-free, these foams must not contain either fluo rocarbon surfactants or fluoropolymers. They instead contain water-soluble non-fluorinated polymer additives and increased levels of hydrocarbon detergents (Seow 2013). In general, the approach to reformulating foams to be fluorine free has been to increase hydrocarbon surfactant levels to compensate for the removal of fluorine (Melkote et al. 2012). Free of fluorochemicals, fluorine-free foams do not degrade into PFOS or PFOA and as such these foams are considered to be more environmentally friendly. In Norway, for example, Avinor phased out the use ofAFFF containing fluorine and fluorocarbon surfactants in 2012. The fluorinefree foam used in Avinor meets the International Civil Aviation Organization standards (ICAO level B) on hre-extinguishing performance, meeting both safety and environmental requirements. The use of fluorine-free foams has been suggested as an alternative for use as training foams and as fluids/methods for system and equipment testing. It has been noted however that some foam concentrates that degrade rapidly and completely in the environment, such as Class A and fluorine-free Class B foams containing only hydrocarbon surfactants, are likely to be more acutely toxic to aquatic organisms than Class BAFFF foams con taining fluorocarbon surfactants and hydrocarbon surfactants, which degrade more slowly and incompletely because of their organo-fluorine content. Fluorine-free foams also fail to provide the same firefighting performance as the fluorinated alternatives. Benefits The advantages presented in the literature and by product manufacturers on the use of fluorine- free foams include: Less Environmentally Persistent--Free of fluorochemicals, fluorine-free foams cannot break down to PFOS or PFOA. Bioaccumulation and persistence are also unlikely to be significant unless AFFF Alternatives B-7 Copyright National Academy of Sciences. All rights reserved. US00004784 Use and Potential Impacts of AFFF Containing PFASs at Airports B-8 Use and Potential Impacts of AFFF Containing PFASs at Airports unusual additives are present (Seow2013). Some fluorine-free foam products are also described as being substantially biodegradable. Training--Fluorine-free foams can play an important role in training exercises where con trols can be put in place to reduce environmental risks. These foams can mimic the induction performance of fluorinated foams. Disadvantages The disadvantages presented in the literature and by product manufacturers on the use of fluorine-free foams include: Decrease inPerformance-- Fluorine-free foams have been shown to not have the same perfor mance as their fluorinated counterparts. They are currently not able to provide the same level of fire suppression capability, flexibility, applicability, and scope of usage as AFFF firefighting foams (Industrial Fire Journal, 2013). An analysis of the performance of two available fluorine-free foams found that they would need to be replenished three times more often than AFFF to provide the same level of fire protection (Schaefer et al. 2008). In the same analysis, it was found that some fluorine-free foams offered little or no performance for the suppression of flammable vapors. Limitations in the effectiveness of fluorine-free foams are in large part due to the oil loving properties of the hydrocarbon surfactants. Lab experiments by Dynax show that a commercial fluorine-free foam becomes flammable and degrades when contaminated with fuel in contrast to commercial fluorocarbon surfactant-based foams that do not become flammable or degrade with fuel contamination (Jho 2013). This is observed due to the oleophilicity (fuel attraction) of hydrocarbon surfactants in fluorine-free foams. Increase in Short-Term Toxicity--In order to achieve the properties for AFFF, particularly the low surface tension, many fluorine-free foams rely on increasing the hydrocarbon surfactant levels to compensate for the removal of fluorine. While many fluorine-free foams are neither biopersistent nor bioaccumulative, the increase in hydrocarbons can cause foams to exhibit extremely high aquatic toxicity, greater than what is observed with AFFF (Melkote et al. 2012). Higher Biochemical Oxygen Demand-- Fluorine-free foams containing hydrocarbon surfac tants will emulsify with oil based fuels in an aquatic environment. This creates higher biochemical oxygen demands due to the increase in required oxygen needed to degrade the foam. An increase in required oxygen reduces available oxygen for organisms in the aquatic environment. Higher Costs-- It has been difficult for fluorine-free foams to gain a firm foothold in the market, partly because of established supplier relationships with manufacturers of C6-based fluorotelomers (UNEP 2011). In the United Kingdom, for example, it was shown that the fluorine-free alternatives to firefighting foams are 5-10% more expensive than fluorocarbon surfactant-based foams. It has been suggested, however, that as the market size for fluorine-free alternatives increases the price will fall (UNEP 2011). Products Fluorine-free foams have been developed by most foam manufacturers as alternatives to AFFF and are being used for some applications in Europe and Australia, particularly in environmen tally sensitive areas. These products use inputs that include: Silicone-based surfactants; Hydrocarbon-based surfactants; Synthetic detergent foams; and, Protein-based foams. As of late, these foams are used more for training purposes than for emergency response. Copyright National Academy of Sciences. All rights reserved. US00004785 Use and Potential Impacts of AFFF Containing PFASs at Airports Conclusion There are commercially produced alternative foam types to AFFF. Most of these alterna tive foam types contain PFASs (with the exception of the fluorine-free foams). However, all available firefighting foam alternatives exhibit properties that have the potential to impact the environment and/or human health, whether they are fluorotelomer-based or fluorine-free. Recognizing the importance of efficacy and safety in fire protection, these foams will continue to be used. Therefore, it is important to consider preventative approaches and best manage ment practices that limit the discharge off firefighting foams to the environment and protect the individuals using these foams. References 1. Blum, A., Balan, S.A., Scheringer, M., Trier, X., Goldenman, G., Cousins, I.T., & Peaslee, G. (2015). The Madrid statement on poly-andperfluoroalkyl substances (PFASs). Environmental health perspectives, 123(5), A107-A111. Accessed online at: http://ehp.niehs.nih.gov/1509934/ 2. Cortina, T., & Korzeniowski, S. (2008).AFFF industry in position to exceed environmental goals. Asia Pacific Fire June, 18-22. Accessed online at: www.fffc.org/images/APFarticle08.pdf 3. Cortina, T. May 2010. The Phaseout that Didn't Flappen. International Fire Protection. Accessed online at: http://www.fffc.org/journal.php 4. Jho, C. (2013) Interactions of Firefighting Foam with Hydrocarbon Fuel. Reebok Foam Seminar, Bolton, UK. Presentation. March 18-19,2013. Accessed online at: http://www.dynaxcorp.com/dynax-resources/ presentations .html 5. Place, B.J., and Field, J.A. (2012). Identification of novelfluorochemicals in aqueous film-formingfoams used by the US military. Environmental Science & Technology 46.13: 7120-7127. Accessed online at: http://pubs. acs.org/doi/abs/10.1021/es301465n 6. Scheffey, J.F., k Wright, J.A. (1994). Analysis of Test Criteria for Specifying Foam Firefighting Agents for Aircraft Rescue and Firefighting. HUGHES ASSOCIATES INC COFUMBIA MD. Chicago. Accessed online at: oai.dtic.mil/oai/oai?verb=getRecord8onetadataPrefix=html8ddentifier 7. Schaefer, T.H., Dlugogorski, B.Z., k Kennedy, E.M. (2008). Sealability properties offluorine-free firefighting foams (FfreeF). Fire technology, 44(3), 297-309. 8. Seow, J., and Australia, C.W. (2013). Firefighting Foams with Perfluorochemicals-Environmental Review. Hemming Information Services. 9. Sheinson, R.S., Williams, B.A., Green, C., Fleming, J.W., Anleitner, R., Ayersa, S.,. .. & Barylski, D. (2002). The future of aqueous film forming foam (AFFF): performance parameters and requirements. National Institute ofStandards and Technology (US Dept, of Commerce). 10. Sontake, A and Wagh, S. (2014). The Phase-out ofPerfluorooctane Sulfonate (PFOS) and the Global Future of Film Forming Foam (AFFF), Innovations in Firefighting Foam. Chemical Engineering and Science. Accessed online at: http://pubs.sdepub.eom/ces/2/l/3/ 11. Melkoke, R, Wang Fiangzhen and Nicolas Robinet. Next Generation Fluorine-Free Fighting Foams. Accessed online at: www.nfpa.org/~/media/files/research/. . ./22melkoterobinetwang-presentation.pdf 12. Olsen, G.W., Mair, D.C., Church, T.R., Ellefson, M.E., Reagen, W.K., Boyd, T.M., & Butenhoff, J.F. (2008). Decline in perfluorooctanesulfonate and other polyfluoroalkyl chemicals in American Red Cross adult blood donors, 2000-2006. Environmental Science & Technology, 42(13), 4989-4995. Chicago. Accessed online at: http://pubs.acs.org/doi/abs/10.1021/es800071x 13. Persistent Organic Pollutants Review Committee. Technical Paper on the Identification and Assessment ofAlternatives to the Use of Perfluorooctane Sulfonic Acid, Its Salts, Perfluorooctane Sulfonyl Fluoride and Their Related Chemicals in Open Applications (UNEP/POPS/POPRC. 8/INF/17 Rev. l).Accessed online at: http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC7/POPRC7Followup/ Requestsforinformation/RequestsforcommentsbyPOPRC7IWGs/PFOSinopenapplicationsRequestfor comments/tabid/2736/Default.aspx 14. Qualified Products Database. MIF-F-24385F (T)-Fire ExtinguishingAgent, Aqueous FUm-FormingFoam (AFFF) Liquid Concentrate, for Fresh and Sea Water (2015): http://qpldocs.dla.mil/search/parts.aspxiqpHl910 15. Williams, B., Murray, T., Butterworth, C., Burger, Z., Sheinson, R., Fleming, J., k Farley, J. (2011, March). Extinguishment and Burnback tests offluorinated andfluorine-freefirefightingfoams with and withoutfilm for mation. Suppression, Detection, and Signaling Research and Applications-A Technical Working Conference (SUPDET 2011). Accessed online: www.nfpa.org/~/media/Files/proceedings/supdetllwilliamspaper.pdf AFFF Alternatives B-9 Copyright National Academy of Sciences. All rights reserved. US00004786 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool APPENDI X C The Managing AFFF and PFASs at Airports (MAPA) screening tool has been designed to assist airports with the identification of areas of potential environmental concern (APECs) on or near their airport. There are two versions of the screening tool, one entitled "MAPA Screening Tool" and the other "MAPA Screening Tool Compatibility Version." If you are utilizing Microsoft Excel 97 to 2003 or 2007, please use the hie entitled "MAPA Screening Tool Compatibility Version." If running a more recent version of Microsoft Excel, please use the hie entitled "MAPA Screening Tool." Please note that the screening tool works best when used in Microsoft Excel 2010. Macros Security The MAPA Screening Tool consists of multiple worksheets and embedded macros. Macros automate frequently used tasks; the ones used in the MAPA Screening Tool are created with Visual Basic for Applications (VBA) and have been written by Dillon Consulting. When you hrst open the MAPA Screening Tool, macros need to be enabled for the program to function and carry out its tasks. Some macros pose a potential security risk. A person with malicious intent can introduce a destructive macro, in a document or hie, which can spread a virus on your computer. In Micro soft Office ExcelTM, you can change the macro security settings to control which macros run and under what circumstances when you open a workbook. The following steps discuss how to enable macros. When hrst opening the program, a pop-up window generally provides the user with an option to enable macros. If there is no pop-up window, or if the user has accidentally clicked "do not enable macros," the user should refer to the online instructions provided by Microsoft Office for their version of ExcelTM: https://support.ofhce.com/en-us/article/Enable-or-disable-macros-in0fhce-hles-12b036fd-dl40-4e74-b45e-16fedla7e5c6#__toc311698310 Typically, these instructions include the following steps (with variations on naming conventions, e.g., File Tab versus Microsoft Office Button). Microsoft Office provides a disclaimer on the risks associated with running unknown-source Macros. Click the Microsoft Office Button (or File Tab), and then click Excel Options. Click Trust Center, click Trust Center Settings, and then click Macro Settings. Click the options that you want: Enable all macros (not recommended, potentially dangerous code can run). Click this option to allow all macros to run. This setting makes your computer vulnerable to potentially malicious code and is not recommended. Copyright National Academy of Sciences. All rights reserved. C-1 US00004787 Use and Potential Impacts of AFFF Containing PFASs at Airports C-2 Use and Potential Impacts of AFFF Containing PFASs at Airports W orksheet t: Introductory W orksheet The first worksheet of MAPA collects basic information about the airport and the users involved in completing the screening tool, which will be incorporated into a cover page of the document produced as a result of completing MAPA. Users should complete the fields to the best of their knowledge; however, it is strongly recommended to include the input of various people in the completion of the MAPA Screening Tool as different departments will have differ ent AFFF and PFAS knowledge. Introductory Page Instructions; It is recommended that you read the guid following information for your airport. 1. Input basic information about the airport and use the drop-down lists AirjriSrt Name Import Code Location "^V ' to identify the size of the airport and the department of the person Airport Size/ ARFF Index filling out the MAPA Screening Tool \our Name YSyr Title/Role / (user). -- In order to jnpiete understanding o f AFFF managertttn L a la m iu ^ ia m ttjffija m m im lJfa siim lm n e n L i in u fa a le - 2. Use the drop-down lists to identify the other departments consulted in the completion of the screening tool and provide the person's name and role. 3. Upon completion of this worksheet, click on the yellow cell at the bottom of the page to continue to the next page of the screening tool. W o rksh e et 2: M o d u le 1 O verview Questions The purpose of worksheet #2 is to identify areas of potential environmental concern (APECs) and potential receptors through a series of overview questions. After the introductory worksheet (Worksheet l), the second worksheet of the screening tool, titled "Module l Overview Ques tions," consists of two tables: APECs and potential sensitive receptors. On worksheet #2, users will identify APECs, both on-site (on airport property) and off-site (in the vicinity of the airport property), and sensitive receptors (e.g., potable water, nearby surface water bodies, wetlands). The following information categories are color coded: Information associated with on-site APECs will be entered in cells colored blue; Information associated with off-site APECs will be entered in cells colored green; and, Information associated with sensitive receptors will be entered in cells colored gray. Copyright National Academy of Sciences. All rights reserved. US00004788 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool C-3 M odule : Please answer the hollowing questions tq ^ s is 1. Use the drop-down list in the middle column to answer the questions on the lefthand side, directions on what to do next will appear once you have answered all the questions in the same color block in the Next id S ensitive Receptors ' tve receptors to AFFF and PFa S. Use the drop-down list in the 'Your se complete el the questions in the same color-block prior to following 3. Answer all the questions in the same color block before following the directions in the Next Steps column. .................D.Q.noLf.!U..ouLSM.5.uxiaeaMMef I 4. If you are still on this page after completing j both tables, click the yellow button to proceed to the next worksheet. Ait* W L'IIjiid'.' p iu jL 'iil on Mil* airport property? A re w etlan ds Inr.ale ri w ith in a 1 m ill! nr 1k iln iiin tii: i. iiliu x nf uiip u il pruputy? W o rksh e et 3: APECs Worksheet 3, titled "APECs," seeks to gain a basic understanding of the life cycle of AFFF at your airport and specific locations of potential concern, if any exist. For the AFFF life cycle stages listed in the first column, provide the location, activity and responsible party associated with AFFF on the airport property. On the same page is an identical table for APECs that are off-site, which should be filled out in the same manner. The only difference is in the place of a "Responsible Party/Custodian" column, there is a drop-down list to identify the land use type. Copyright National Academy of Sciences. All rights reserved. US00004789 Use and Potential Im pacts o f AFF F C ontaining PFASs at A irports Copyright National Academy of Sciences. All rights reserved. Potential Areas of Concern - Airport Instructions: Please till out the follow ing table. Use the drop-down lists to provide information about activities involving a FFF toam and then include the location ot the activity. The "Current Operations" column is tor locations where there are on-going'active a FFF operations at the airport while "Historical Operations" is tor locations weie AFFF operations occurred in the past._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 1. List the locations that correspond with the different life cycle stages of AFFF at the airport. Has AFFF from the airport been disposed of? f s a ijo s, o/7-sifc; vtv, ctff-sife, n o } 2. Select the appropriate activity from the drop-down list. There is no drop-down list for the storage life cycle as storage is the only activity. 3. This drop-down list is populated from the information provided in Worksheet 2. Users can go back to Worksheet 2 and add more responsible parties/custodians if needed. 4. Only use these cells if AFFF or other sources of - PFAS were used/stored in a different location in the past then where they are currently. 5. Once you have completed the table, click the yellow button to proceed to the next page. TTTTTT1 US00004790 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool C-5 W o rk s h e e t 4: S e n s itive R eceptors Worksheet 4: Sensitive Receptors builds on the identified potential receptors from Worksheet 2 and assists with clarifying associated potential risk. Users should ensure that they are only complet ing the tables that are applicable to their site, based on their entries on Worksheet 2, as the three types ofsensitive receptors (potable water sources, surface water bodies, and wetlands) are included on Worksheet 4 in individual tables. The three sensitive receptor tables are to be completed in the same manner. Potable Water Sources: Potable water (i.e., drinking water) sources, if impacted with PFASs, may present an unacceptable risk to human health via ingestion. Use the drop-down list in the first column of the Potable Water Sources worksheet to describe the type of potable water source. Options include: Potable well: groundwater Municipal water well supply: groundwater Surface water body: A surface water body (e.g., lake or river) that is used as a source of drink ing water Surface Water Bodies: In addition to being a potential potable water source, surface water bodies also represent a potential habitat for sensitive receptors. Identify the type of surface water body (e.g., lake, river, stream, pond, ocean, or ditch) using the drop-down menu, assign a location name, and indicate, if known, the proximate distance to the nearest APEC previously identified. Wetlands: Wetlands, like surface water bodies, represent a potential habitat for sensitive recep tors. Types of wetlands vary; the user is encouraged to characterize the type of wetland using the basic descriptions provided in the screening tool using the drop-down menu. The user should identify each wetland by assigning a location name and indicating, if known, the proximate distance to the nearest APEC previously identified. Potential Sensitive Receptors Potable Water Sources instructions- Use thp d " 1. Use the drop-down list to 2. Identify the location of the tar sensitive receptor. identify the specific type of bie 3. The table will be populated with rom the units selected on worksheet 2. Use the blank cell to input the sensitive receptor. Jwater sources: poiaDi| wen, municipal water distance to the closest APEC. ' intake Copyright National Academy of Sciences. All rights reserved. US00004791 Use and Potential Impacts of AFFF Containing PFASs at Airports C-6 Use and Potential Impacts of AFFF Containing PFASs at Airports Worksheet 5: Module 1 S um m ary Worksheet 5: Module l Summary summarizes the APECs and sensitive receptors identified at the airport, based on previous worksheets. Before entering any new information, click the "Press to Start" button. If using the compatibility version of the tool, press Crtl, Shift and F to activate the macro that populates the table appropriately. Once completed, this worksheet can be used to create GIS maps, which can be useful when visualizing locations of potential concern and their interaction with potentially sensitive receptors. Press the yellow "Click here once table is complete" button upon completion of the tables. -apCf~ instructions; This w orksheet is au to -populated w ith into;,' ' v id e o in p 'e v ;o n s .v o 's s h ? N ^ P ress t longitudes in dc.m a; degrees. A lsod ; th e drop-dow n list to an sw es th e c Pressto Start 1. Click the "Press to Start" button to populate the table with the APECs identified previously. th e :a titi:d e s and 2.Use the drop-down list to answer the question: "Is the APEC associated with past release into the environment?" This includes accidental releases like leaks and spills as well as purposeful ones like those associated with training. U the APEC \ associated with \ (last release into the environment? Responsible Party C Latitude Location N am e fo r GIS Longitude \ 3. Enter the latitude and longitude of the APEC location in decimal degrees. 4. Enter a location name to identify the APEC in GIS that does not include any spaces, e.g. Fire_Trainingl. Module 1 Summary Sheet - Sensitive Receptors Instructions: This worksheet is auto-populated with information provided in previous worksheets. Press the button below before entering any data on this worksheet then fill in the latitudes and longitudes in decimal degrees. Pressto Start : Type of Receptor Sensitive Receptors Location f L attilde Longitude LocationName forC IS \~\ 00 00 DD 00 00 00 00 DD 00 00 J ie only new in' ormation that needs to be input is the latitude and longitude of the sensitive receptor as wen as a bib location 11 LU |w _ 1 oo 00 0 -- ** Click here once Table Is comD ie s 6. After completing the entire table, press the yellow "Click here once table is complete" button to proceed to the next worksheet. Copyright National Academy of Sciences. All rights reserved. US00004792 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool C-7 W orksheet 6: MOD 2 OPS APECS Worksheet 6 is used to input further details on the operational life cycle of AFFF at an airport. Worksheet 6 will self-populate with the operational APECs identified in Worksheet 3. Click the "Press to Start" button in the upper left hand corner to populate the table with APEC names. If using the compatibility version of the tool, press Crtl, Shift and A to activate the macro that populates the table appropriately. Answer questions applicable to the APECs identified at the top of each column. Each response corresponds to a numerical value that will be used to score the potential risk associated with each APEC. Once the table is complete, click the yellow "Click here once table is complete" button at the bottom of the table. Copyright National Academy of Sciences. All rights reserved. US00004793 Use and Potential Impacts of AFFF Containing PFASs at Airports C-8 Use and Potential Impacts of AFFF Containing PFASs at Airports W o rksh eet 7 : MOD 2 Legacjf APECS The table will auto-populate with the locations identified on Worksheet 5 when the "Press to Start" button is clicked. If using the compatibility version of the tool, press Crtl, Shift, and B to activate the macro that populates the table appropriately. Worksheet 7 is used to input further details associated with APECs associated with PFAS impacts in the environment. Questions are posed about the release characteristics, co-mingling of contaminants, surface covering, and exposure pathways of AFFF at each APEC. Each answer in the drop-down list is associated with a score. When all the questions for an APEC have been answered, a score for that APEC is provided at the bottom of the table. Press the yellow "Click here once table is complete" button upon completion of the table. i fy cncu 1. Click "Press to Start" button to populate the table with the = -Ten -y.Vi APECs identified previously. : i lists. ............................................. Release Characteristics Co-mingle Contaminants Surface Covering Site F eatu re s/S e ttin g Was AFFF foam or AFFF concentrate released? W hat volume was released? ( When did the release occur? Have petroleum hydrocarbons been known to have 2. Use the drop-down list to select the most appropriate answer for each APEC. rte Exposure Pathways What is the distance to the nearest potable water receptor identified in Phase 1? W hat is the distance to the nearest sensitive ecological receptor (wetland or surface water body) identified in Phase 1? .............. -- . / 3. A score will appear for each question based on the answer selected from the drop-down list. A Re ease Character sties Cft tingle C ontam inants Sit Fgaures/Stti%e jW a sA FFF foam o r AFFF concentrate released? W hat vn iun te w as released ? When did the rel ease occur ? Have petrnleun hycnc arbor's r>een krow n tn have been present rhe s.ih-si.-face a r d /c r pleased at the same tim e as AFFF? W h at ly o e o f su'-face c n w ir,g ,s ir tK -nrrediafe 5. After completing the entire table, press the yellow "Click here once table is complete" button to proceed to the next worksheet. body) >to I Q ga-icns/ ?Q to 75 L Atter 2010 4, After answering all the questions for the specified APEC, a total score will be provided at the bottom of the table. Copyright National Academy of Sciences. All rights reserved. US00004794 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool C-9 W orksheet 8: MOD 2 Ranking Summary Worksheet 8: Ranking Summary combines operational and legacy APECs for comparison and preliminary ranking in order of potential concern. This table will auto-populate with the information input previously and lists the life cycle stage, APEC, and score for comparison. If using the compatibility version of the tool, press Crtl, Shift, and C to activate the macro that populates the table appropriately, and then press Crtl, Shift and D to sort the APECs from high est to lowest scores. Sum m ary of Operational and Legacy APEC Rankings instructions: Click the "Press to Start" button to auto-populate the table with the APEC names and scores. Click the "Press to Sort" button to organize the APECs in descending order (higher score with more potential risk at the top of the table]. Press to Start Press to Sort STORAGE STORAGE USE V V \ 1.Click the "Press to Start" button to populate the table. STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE STORAGE USE USE USE USE ' APEC VALUE! VALUE! VALUE! VALUE! VALUE! VALUE ! VALUE! VALUE I VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALU# VALl/=! 2. Click the "Press to Sort" button to organize the APECs from highest , VALU! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! VALUE! Copyright National Academy of Sciences. All rights reserved. US00004795 Use and Potential Impacts of AFFF Containing PFASs at Airports C-10 Use and Potential Impacts of AFFF Containing PFASs at Airports W orksheet 9: Dal ps Worksheet 9: Data Gaps identifies additional information that is needed for a further analysis of potential impacts associated with AFFF. Click the "Press to Start" button to populate the table with APECs previously identified. If using the compatibility version of the tool, press Crtl, Shift, and E to activate the macro that populates the table appropriately. Use the drop-down list to identify whether or not the specified information is available for the APEC. For the most part, this is not information expected to be readily on hand; instead it is, in many cases, related to intrusive environmental studies (e.g., groundwater chemistry, precipitation infiltration rate, and surface water and sediment chemistry). The identification of data gaps is important when creating a plan for locations that potentially have AFFF impacts and determining where to allo cate resources. I PRESS- 0 5- AR- 1.Click the "Press to Start" button to populate the table with he APECs identified previously. Soil texture Soil depth 2. Use the drop-down list to identify if user (v possesses the information for the APEC named at the top of the table - select "Yes" if the user has the information and select "No" if they do not. I upuyi dpr ly Geology Hydrogeology Permafrost Groundwater Land-use (agricultural, residential, commercial, industrial) Potential preferential PFS pathways Surface water and sediment conditions I upuyi dpr ly ui r c t ir11 eiduur i uj sei isiuve ieuepioi s Depth to bedrock Type of bedrock Depth to groundwater Groundwater flow direction Groundwater chemistry Groundwater flow rate Permafrost depth Precipitation infiltration rate Hydraulic conductivity rate Thickness and hydraulic conductivity of confining layer over aquiferfgroundwater expsure pathway Land-use on-site Land-use off-site properties Knowledge of former or current trenches, ditches, underground piping and wiring Flow rate and direction Depth Substrate type Water and sediment chemistry jf rf f g 1 / 1 1 1 \ y \ \ Drainage patterns and systems Surface runoff patterns 'V \\ \ \ \V \ 1 - / .... 1 1 1 / / / Copyright National Academy of Sciences. All rights reserved. US00004796 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to MAPA Screening Tool C-11 End Proc eeiting Tool It is recommended that Worksheets 1, 5, 6, 7, 8, and 9 are printed at the completion of the screening tool as outputs for use in the management of AFFF at the airport. Upon the completion of the nine worksheets of the screening tool, users have Identified APECs on and adjacent to airport property. Identified potential sensitive receptors on and adjacent to airport property. Collected the information needed to create GIS maps for visualization of APECs, sensitive receptors, and exposure pathways. Produced a preliminary ranking of potential concern for operational and legacy APECs. Identified gaps in data needed for more in-depth analysis of AFFF impacts for each APEC. The MAPA screening tool can be used As a summary of information that the airport has concerning the life cycle of AFFF. As a first step in the assessment and remediation of APECs for future development or changes to the airport property in consultation with an AFFF environmental specialist. To identify operational practices that would decrease the potential environmental impacts associated with AFFF use. A printout of Worksheet 5: Module 1 Summary should be shared with your GIS specialist for the creation of maps identifying APECs and sensitive receptors. Mapping the results of Module 1 can Make exposure pathways from APECs to sensitive receptors more easily identifiable. Allow for improved communication of MAPA screening tool results with other members of staff. Provide a visual representation when consulting with an AFFF environmental specialist. If the user requires further information to complete the screening tool or more background information about the rationale behind various aspects of the screening tool, please refer to Chapter 6 of the reference document. Copyright National Academy of Sciences. All rights reserved. US00004797 Use and Potential Impacts of AFFF Containing PFASs at Airports Module 2 Questions, Answer Choices, and Scores Copyright National Academy of Sciences. All rights reserved. US00004798 Use and Potential Impacts of AFFF Containing PFASs at Airports C-14 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 1. Operational storage. Question Answer Choices Is the AFFF being stored in accordance with the MSDS and Yes TDS? No Don't Know What is the covering of the storage location? Enclosed Covered Outside or exposed directly to the elements Is the AFFF being stored in the original container? Yes No What is the volume of AFFF solution that is being stored in less than 95 L/ less than 25 gallons this location? 95 to 285 L/ 25 to 75 gallons 285 to 945 L/ 75 to 250 gallons 945 to 2,840 L/ 250 to 750 gallons 2, 840 to 3,785 L/ 750 to 1,000 gallons More than 3,785 L/ more than 1,000 gallons What is the containment of the storage vessel? Double Single Describe the type and condition of the floor where AFFF is Paved stored. Slightly cracked pavement Moderately cracked pavement Heavily cracked/broken pavement Earthen Does the storage location have a history of leaking? No, does not currently or have a history of leaking Yes, on a couple of occasions Yes, substantial leaking has occurred Yes, currently leaks OPERATIONAL STORAGE = MSDS + Covering + Original Container + Volume of AFFF + Containment + Flooring + Leaking Maximum Score: 40 Associated Score 1 5 5 1 3 5 1 5 1 2 4 6 8 10 1 5 1 2 3 4 5 0 3 4 5 Copyright National Academy of Sciences. All rights reserved. US00004799 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 2. Operational use. Question Answer Choices How frequently is AFFF used at this location? Less than once per every 5 years Between 1 and 5 years Semi-annually Annually Monthly How much AFFF is used per use? 0 to 5 gallons/ 0 to 20 L 5 to 20 gallons/20 to 75 L 20 to 50 gallons/ 75 to 190 L 50 to 100 gallons/ 190 to 375 L 100 to 500 gallons/ 375 to 1900 L 500 to 1000 gallons/ 1900 to 3800 L Greater than 1000 gallons/Greater than 3800 L Are absorbents, a spill kit, and a spill management plan in place during AFFF use? Yes No Don't Know Where (ultimate receiver) does the used AFFF (or unused if Sent off-site for disposal returned to the manufacturer) go when used? Down the drain Evaporated off of pavement Soaked into the ground Washed/runoff into surface water body How many of the following types of PPE are used during the handling and use of AFFF? (eye protection, w ork All Four gloves, nitrile/single-use gloves, fire-retardant/turnout gear, w ell-ventilated location) Three Two One None Under current operational conditions, is there exposure Yes - workers during daily operations contact via direct contact to humans without any of the PPE listed above? Yes - workers during weekly operations Yes - workers during monthly operations Yes - workers during emergency situations Yes-trespassers No Don't know Associated Score 1 2 3 4 5 1 2 4 6 8 10 15 1 5 5 1 5 5 8 10 0 1 2 3 4 5 240 48 12 5 3 0 240 OPERATIONAL USE = (Frequency of Use x Volume of AFFF x AFFF Ultimate Receiver) + Human Exposure + Spill Management + PPE Maximum Score: 1000 Copyright National Academy of Sciences. All rights reserved. US00004800 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 3. Operational maintenance. Question Answer Choices How frequently is the AFFF equipment checked for Monthly or more frequently malfunctions/degradation (leaks, cracks, erosion, etc.)? Quarterly Semi-annually Annually Never What is used to clean equipment that had contained AFFF? Nothing Rinsed/flushed with water Cleaned with water and soap/detergent Rinsed/flushed with a solvent How is AFFF removed from the distribution equipment Mechanical pump (deluge systems or fire trucks) during the maintenance Manual pump activities? Gravity/drain valve AFFF not removed When AFFF is removed from distribution equipment Discharged into temporary storage containers and (deluge systems or fire trucks), what is done with it? returned to the equipment Kept in storage containers Discharged onto ground Disposed of off-site What volume of AFFF is used during maintenance (lost in None transportation)? Less than 1 gallon 1 to 2 gallons 3 to 5 gallons More than 5 gallons What is the typical volume of rinsate that results from Less than 200 gallons/ Less than 760 L cleaning equipment that had contained AFFF? More than 200 gallons/ More than 760 L None Describe the type and condition of the floor where Paved maintenance activities are conducted. Slightly cracked pavement Moderately cracked pavement Heavily cracked/broken pavement Earthen Associated Score 1 2 4 8 10 5 3 2 0 1 3 5 10 1 2 10 1 0 1 2 3 5 4 5 0 1 2 3 4 5 Copyright National Academy of Sciences. All rights reserved. US00004801 Use and Potential Impacts of AFFF Containing PFASs at Airports Quick Guide to M APA Screening Tool C-17 Table 3. (Continued). Question Answer Choices What is the ultimate receiver of the waste produced from Sent off-site for disposal AFFF equipment maintenance activities? Down the drain Evaporated off of pavement Soaked into the ground Washed/runoff into surface water body Are absorbents, a spill kit, and a spill management plan in Yes place during AFFF use? No Don't Know How many of the following procedures are required for All the handling of AFFF? (Two or more people involved in the Three handling of AFFF (single person could do it if they had to), Two clear procedural standards, procedural training for those One handling AFFF, ensuring fittings and connections are tight) None Associated Score 1 5 5 8 10 1 5 5 0 2 3 4 5 OPERATIONAL MAINTENANCE = ((Volum e of AFFF + Volum e of Rinsate) x Ultim ate Receiver) + Equipm ent Checks + AFFF Rem oval Method + A FFF Storage during M aintenance + Cleaning Method + Handling Procedures + Spill M anagem ent + Flooring Maximum Score: 145 Copyright National Academy of Sciences. All rights reserved. US00004802 Use and Potential Impacts of AFFF Containing PFASs at Airports C-18 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 4. Operational disposal. Question What is the frequency of disposal of AFFF? What volume of AFFF is disposed of at a time? What is the ultimate receiver of the disposed AFFF? Answer Choices 1 to 2 years 2 to 5 years More than 5 years 0 to 5 gallons/ 0 to 20 L 5 to 20 gallons/ 20 to 75 L 20 to 50 gallons/ 75 to 190 L 50 to 100 gallons/ 190 to 375 L 100 to 500 gallons/ 375 to 1900 L 500 to 1000 gallons/ 1900 to 3800 L Greater than 1000 gallons/Greaterthan 3800 L Unknown Manufacturer Incinerator Down the drain/municipal sewer system Evaporated off of pavement Soaked into the ground Washed/runoff into surface water body Sent off-site for disposal (waste management contractor or landfill) Sent off-site for treatment OPERATIONAL DISPOSAL = Frequency of Disposal x Volum e of A FFF x A FFF Ultim ate Receiver Maximum Score: 500 Associated Score 5 3 1 1 2 3 6 8 10 15 15 1 2 4 6 8 10 3 3 Copyright National Academy of Sciences. All rights reserved. US00004803 Use and Potential Impacts of AFFF Containing PFASs at Airports Table 5. Legacy APEC. Question Answer Choices Was AFFF foam or AFFF concentrate released? Foam Concentrate What volume was released? 0 to 5 gallons/ 0 to 20 L 5 to 20 gallons/20 to 75 L 20 to 50 gallons/ 75 to 190 L 50 to 100 gallons/ 190 to 375 L 100 to 500 gallons/ 375 to 1900 L 500 to 1000 gallons/ 1900 to 3800 L Greater than 1000 gallons/Greater than 3800 L Unknown When did the release occur? Before 2010 After 2010 Don't know Have petroleum hydrocarbons been known to have been Yes present in the sub-surface and/or released at the same No time as the AFFF? What type of surface covering is in the immediate vicinity Paved (concrete or asphalt) of the release? Unvegetated Soil/Gravel Vegetated -Treed/forested Vegetated- Meadow/grassland Where does runoff flow at this APEC? No runoff/infiltration Overland flow via grassed ditches/swales to surface water body Overland flow via lined conveyance systems to surface water body Collected and treated on-site What is the distance to the nearest potable water receptor 0 to 500 m/ 0 to 1640 ft identified in Phase 1? 500 to 1 km/ 1640 to 0.6 miles 1 to 5 km/ 0.6 to 3 miles Greater than 5 km/ Greater than 3 miles What is the distance to the nearest sensitive ecological 0 to 500 m/ 0 to 1640 ft receptor (wetland or surface water body) identified in 500 to 1 km/ 1640 to 0.6 miles Phase 1? 1 to 5 km/ 0.6 to 3 miles Greater than 5 km/ Greater than 3 miles Associated Score 3 5 1 2 4 6 8 10 15 15 50 25 50 5 1 1 5 3 3 10 10 10 1 100 75 25 1 100 75 25 1 LEGACY APEC = ((Co ncentrate vs. Foam x AFFF V olum e x Petroleum H ydrocarbons) + Release Tim ing + Surface Covering + Runoff Flow + Distance to Potable W ater + Distance to Sensitive Ecological Receptor) Maximum Score: 650 Copyright National Academy of Sciences. All rights reserved. US00004804 Use and Potential Impacts of AFFF Containing PFASs at Airports Abbreviations and acronyms used without definitions in TRB publications: A4A AAAE AASHO AASHTO A C I-N A ACRP ADA APTA ASCE ASME ASTM ATA CTAA CTBSSP DHS DOE EPA FAA FAST FHWA FMCSA FRA FTA HMCRP IEEE ISTEA ITE MAP-21 NASA NASAO NCFRP NCHRP NHTSA NTSB PHMSA RITA SAE SAFETEA-LU TCRP TDC TEA-21 TRB TSA U .S .D O T Airlines for America A m erican Association o f A irport Executives A m erican Association o f State Highway Officials A m erican Association o f State Highway and T ransportation Officials A irports Council International-N orth America A irport Cooperative Research Program Am ericans w ith Disabilities Act Am erican Public Transportation Association A m erican Society o f Civil Engineers Am erican Society of M echanical Engineers Am erican Society for Testing and Materials Am erican Trucking Associations Com m unity Transportation Association of America Com m ercial Truck and Bus Safety Synthesis Program D epartm ent of H om eland Security D epartm ent of Energy Environm ental Protection Agency Federal Aviation A dm inistration Fixing A m erica's Surface T ransportation A ct (2015) Federal Highway A dm inistration Federal M otor C arrier Safety A dm inistration Federal Railroad A dm inistration Federal Transit A dm inistration Hazardous Materials Cooperative Research Program Institute o f Electrical and Electronics Engineers In term o d al Surface T ran sp o rtatio n Efficiency A ct o f 1991 Institute of Transportation Engineers M oving Ahead for Progress in the 21st Century Act (2012) National Aeronautics and Space A dm inistration N ational Association o f State Aviation Officials National Cooperative Freight Research Program National Cooperative Highway Research Program N ational Highway Traffic Safety A dm inistration N ational Transportation Safety Board Pipeline and H azardous M aterials Safety A dm inistration Research and Innovative Technology Adm inistration Society of Autom otive Engineers Safe, Accountable, Flexible, Efficient T ransportation Equity Act: A Legacy for Users (2005) Transit Cooperative Research Program Transit Developm ent Corporation Transportation Equity Act for the 21st Century (1998) Transportation Research Board Transportation Security Adm inistration United States D epartm ent of Transportation Copyright National Academy of Sciences. All rights reserved US00004805 TRANSPORTATION RESEARCH BOARD 500 Fifth Street, NW Washington, DC 20001 ADDRESS SERVICE REQUESTED NON-PROFIT ORG. U.S. POSTAGE PAID COLUMBIA, MD PERMIT NO. 88 CD O CD O OOO CO D Copyright National Academy of Sciences. All rights reserved. 71438944638990000 cor o aD-Dff) cr 3 3 OQ I) CD