Airport_Business_December2019-January2020 - 15

ARFF

through soil, seep into groundwater, or
be carried through air. AFFF is released to
the environment under various scenarios.
At airports AFFF is deployed intentionally
for either training, testing and operational
requirements or emergency response. It
may also be accidentally released during
delivery, transfer and storage. In the
past, the hazards to human health and
the environment were not as wellknown as they are today and there were
few guidelines in the handling and
management of AFFF and wastewater
contaminated with foam. Wastewater
contaminated with AFFF (e.g. f ire
fighting runoff ) was often treated like
storm water and was allowed to seep
into soil or was discharged as surface
water runoff. Storage tanks and drums
containing AFFF do sometimes leak

As a result of the growing
concern over PFAS, airports
face operational and
environmental challenges
relative to the existing and
previous storage, use, testing
and/or disposal of AFFF.

PFAS are environmentally
persistent and do not easily
break down. As such, these
compounds are found globally
in the environment including
bodies of water, soil, dust and
in the air.

SCS ENGINEERS

SCS ENGINEERS

water. The concentration of 70PPT is
the equivalent to about three-and-ahalf drops of water in an Olympic-sized
swimming pool. The fact PFAS are
even measured in parts-per-trillion is an
indicator of its risk potential. The EPA
has not yet established any enforceable
regulatory criteria or released health
advisories for the wider family of PFAS
compounds, nor has it designated
any PFAS compounds as "hazardous
substances" (under Superfund) or as
"hazardous wastes" (under the Resource
Conversation Recovery Act (RCRA).
Regulatory climate
Critics, scientists, and others charged
The U.S. Environmental Protection
with protecting public health, feel that
Agency (EPA) reviewed the "best
the HAL of 70PPT is not stringent
available peer-reviewed studies" enough and the federal government is
including research on laboratory animals
not moving fast enough to address this
(rats and mice) and findings reported
pervasive contamination issue. In fact,
many states are enacting their own rules,
by epidemiological studies of human
populations that have been exposed to
regulations and enforceable standards
PFAS. Subsequently, the EPA issued a
to assure public safety. Many states are
health advisory for these contaminants
actively involved with addressing PFAS
in May of 2016. The EPA lifetime Health
contamination across multiple regulatory
Advisory Level (HAL) for two of the most
programs and the regulatory requirements
well-know PFAS, perfluorooctanoic acid
throughout the U.S. and the regulatory
(PFOA) and perf luorooctanesulfonic
environment is rapidly changing. The
acid (PFOS) have been established as
Interstate Technology Regulatory
Council (ITRC) is tracking and updating
0.070 micrograms per liter (μg/L) or
70 parts per trillion (PPT) in drinking
state/country requirements on a monthly
and, in this case, can release PFAS
to the subsurface. PFSA and PFSA
contamination will migrate downward
within the soil column. If the mass is great
enough, it can migrate and contaminate
groundwater. The contaminated
groundwater can then reach sensitive
receptors by being extracted by drinking
water wells or by recharging surface water
features, such as rivers or creeks. In both
instances, the PFSA become part of the
food chain by being ingested by humans
and wildlife.

DECEMBER 2019/JANUARY 2020 \ AVIATIONPROS.COM / 15
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