PFAS Management at Airports: A Guide (2024)

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2024 A I R P O R T C O O P E R A T I V E R E S E A R C H P R O G R A M ACRP RESEARCH REPORT 262 Research sponsored by the Federal Aviation Administration Subscriber Categories Aviation • Environment PFAS Management at Airports A GUIDE RS&H, Inc. Jacksonville, FL EnSafe, Inc. Memphis, TN Kaplan Kirsch & Rockwell LLP Denver, CO Harris Miller Miller & Hanson, Inc. Burlington, MA Geer Services, Inc. Jacksonville, FL

AIRPORT COOPERATIVE RESEARCH PROGRAM Airports are vital national resources. They serve a key role in transpor- tation of people and goods and in regional, national, and international commerce. They are where the nation’s aviation system connects with other modes of transportation and where federal responsibility for man- aging 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 pro- grams. ACRP is modeled after the successful National Cooperative High- way 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 of the 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 262 Project 02-93 ISSN 2572-3731 (Print) ISSN 2572-374X (Online) ISBN 978-0-309-70981-1 Library of Congress Control Number 2024937441 © 2024 by the National Academy of Sciences. National Academies of Sciences, Engineering, and Medicine and the graphical logo are trade- marks of the 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 with the understanding that none of the material will be used to imply TRB, AASHTO, APTA, FAA, FHWA, FTA, GHSA, or NHTSA 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 Transporta- tion Research Board; the National Academies of Sciences, Engineering, and Medicine; or the program sponsors. The Transportation Research Board does not develop, issue, or publish standards or spec- ifications. The Transportation Research Board manages applied research projects which provide the scientific foundation that may be used by Transportation Research Board sponsors, industry associations, or other organizations as the basis for revised practices, procedures, or specifications. The Transportation Research Board; the National Academies of Sciences, Engineering, and Medicine; and the sponsors of the Airport Cooperative Research Program do not endorse products or manufacturers. Trade or manufacturers’ names or logos appear herein solely because they are considered essential to the object of the report. Published research reports of the AIRPORT COOPERATIVE RESEARCH PROGRAM are available from National Academies Press 500 Fifth Street, NW, Keck 360 Washington, DC 20001 (800) 624-6242 and can be ordered through the Internet by going to https://nap.nationalacademies.org Printed in the United States of America

e National Academy of Sciences was established in 1863 by an Act of Congress, signed by President Lincoln, as a private, non- governmental institution to advise the nation on issues related to science and technology. Members are elected by their peers for outstanding contributions to research. Dr. Marcia McNutt is president. e National Academy of Engineering was established in 1964 under the charter of the National 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. John L. Anderson is president. e National Academy of Medicine (formerly the Institute of Medicine) was established in 1970 under the charter of the National Academy of Sciences to advise the nation on medical and health issues. Members are elected by their peers for distinguished contributions to medicine and health. Dr. Victor J. Dzau is president. e 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 other activities to solve complex problems and inform public policy decisions. e National Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in matters of science, engineering, and medicine. Learn more about the National Academies of Sciences, Engineering, and Medicine at www.nationalacademies.org. e Transportation Research Board is one of seven major program divisions of the National Academies of Sciences, Engineering, and Medicine. e mission of the Transportation Research Board is to mobilize expertise, experience, and knowledge to anticipate and solve complex transportation-related challenges. e Board’s varied activities annually engage about 8,500 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. e program is supported by state transportation departments, federal agencies including the component administrations of the U.S. Department of Transportation, and other organizations and individuals interested in the development of transportation. Learn more about the Transportation Research Board at www.TRB.org.

C O O P E R A T I V E R E S E A R C H P R O G R A M S AUTHOR ACKNOWLEDGMENTS This report and supporting research were performed under ACRP Project 02-93 by RS&H, Inc. (RS&H). RS&H was supported by EnSafe, Inc.; Kaplan Kirsch & Rockwell LLP, which authored Sections 4.2 and 4.3; Harris Miller Miller & Hanson, Inc.; and Geer Services, Inc. CRP STAFF FOR ACRP RESEARCH REPORT 262 Waseem Dekelbab, Deputy Director, Cooperative Research Programs Marci A. Greenberger, Manager, Airport Cooperative Research Program Joseph D. Navarrete, Senior Program Officer Stephanie L. Campbell-Chamberlain, Senior Program Assistant Natalie Barnes, Director of Publications Heather DiAngelis, Associate Director of Publications Janet M. McNaughton, Senior Editor ACRP PROJECT 02-93 PANEL Field of Environment Janet Kieler, Denver International Airport, Denver, CO (Chair) Mort Ames, City of Chicago Department of Law, Chicago, IL Samantha Cummings, Alaska Department of Transportation & Public Facilities, Statewide Aviation, Delta Junction, AK Mitchell Iles, Dallas–Fort Worth International Airport, DFW Airport, TX Robert A. Kostinec, Minnesota Pollution Control Agency, Rochester, MN Lori Morris, Memphis International Airport, Memphis, TN Michael Lamprecht, FAA Liaison Melinda Z. Pagliarello, Airports Council International–North America Liaison Justin Barkowski, American Association of Airport Executives Liaison

ACRP Research Report 262 provides information and practical considerations for man- aging aqueous film forming foams (AFFFs) containing per- and polyfluoroalkyl substances (PFAS) used for firefighting at airports. It also includes education and public outreach materials to support community involvement efforts. The report will be of particular interest to practitioners who wish to better understand AFFF characteristics and management, institutional and programmatic controls, and regulatory requirements. PFAS are found in many products, from consumer products to building materials. For airports, the primary implication is associated with firefighting foams (e.g., AFFFs). For many years, airport operators were required to use AFFF and, as a result of recommended training requirements and fire response, may have had releases of AFFF to the environment. Emerging science, increased regulatory attention, and heightened community focus are elevating PFAS issues at airports, and research was needed to help airport operators address potential impacts and manage PFAS at their facility. The research, led by RS&H, Inc., began with a review of the latest scientific, technological, and regulatory developments regarding PFAS. The research team engaged the aviation industry through a comprehensive survey to better understand PFAS issues and handling practices at airports. The team relied on its members’ scientific, engineering, legal, regulatory, and outreach experience to translate its findings into a guide and supporting tools and resources. The guide provides a background on the use of AFFF at airports and leads the reader through the chemistry of PFAS compounds and fate and transport processes in the environment. It includes practices for assessing past and current activities; reviewing policies, procedures, and operations; considering regulatory actions, financial planning, and remediation; and planning for communications and public engagement. A comprehensive set of tools and resources is provided as appendices, including material for communication and engagement (e.g., a template brochure and presentation slide deck); tutorials for inspections, document reviews, and other assessments; and checklists for developing or implementing manage- ment methods. These appendices are available on the National Academies Press website (nap.nationalacademies.org) by searching for ACRP Research Report 262: PFAS Management at Airports: A Guide and looking under “Resources.” F O R E W O R D By Joseph D. Navarrete Staff Officer Transportation Research Board

1 Summary 3 Chapter 1 Use and Goals of the Guide 5 Chapter 2 Assessment of Historical and Current Product Use and Activities 5 2.1 PFAS Properties Overview 5 2.1.1 Basic PFAS Structure and Characteristics 7 2.1.2 PFAS and Surfactant Behavior 8 2.2 Aviation Activities 9 2.2.1 ARFF Activities and Vehicles 9 2.2.2 Fixed AFFF Systems 11 2.2.3 Tenant Facilities 11 2.2.4 Joint-Use Military Facilities 12 2.3 Off-Airport Activities 12 2.3.1 Solid Waste Management Facilities 12 2.3.2 Industrial Facilities 13 2.3.3 Oil and Gas Exploration and Refining Facilities 13 2.3.4 Wastewater Treatment Plants, Biosolids Applications, and Septic Systems 13 2.3.5 Groundwater Recharge 13 2.3.6 Agricultural Areas 14 2.4 Assessing the Presence of PFAS and Associated Activities 14 2.4.1 Establish a Baseline 16 2.4.2 Investigating Potential Releases 17 2.4.3 Assessment of Nonairport Activities 18 2.4.4 Investigation Sampling Considerations 18 2.4.5 Sampling Plan Development and Implementation 22 2.4.6 Laboratory Analytical Testing Methods 24 2.5 Evaluating Fate and Transport 24 2.5.1 Transport in Soils and Subsurface Environments 25 2.5.2 Transport in Groundwater and Surface Water 27 2.5.3 Release to Air 28 Chapter 3 Policies, Procedures, and Operations 28 3.1 Procurement Policies and Procedures 28 3.1.1 Procurement Product Review and Approval 29 3.1.2 Inventory Management Procedures 31 3.2 Waste Management and Disposal Options 31 3.2.1 PFAS Status Under RCRA 31 3.2.2 Currently Available Disposal Methods 33 3.2.3 Emerging Disposal Technologies C O N T E N T S

34 3.3 ARFF Operations and Safety 35 3.3.1 ARFF Facilities 38 3.3.2 ARFF Training 39 3.3.3 ARFF Health and Safety Considerations 40 3.3.4 Fluorine-Free Alternatives to AFFF and Transition Planning 44 3.4 Construction Management Procedures 44 3.4.1 Review and Sampling of Historical Records 45 3.4.2 Preconstruction Planning 46 3.4.3 Soil Management Practices 47 3.4.4 Construction Demolition Activities with Debris Removal 47 3.4.5 Temporary Storage of Demolition Debris 48 3.4.6 Construction Stormwater Management Plan 48 3.4.7 Documentation of Construction Activities and Material Management 48 3.4.8 Decontamination 49 Chapter 4 Regulatory Action, Financial Planning, and Remediation 49 4.1 Regulatory Action 49 4.1.1 Federal PFAS Regulatory Trends 54 4.1.2 State Regulations 55 4.1.3 Other Regulatory Considerations 56 4.1.4 The Role of Uncertainty 57 4.2 Risk Reduction and Cost Recovery 58 4.2.1 Airport Planning 60 4.2.2 Future Development or Renovation Planning 62 4.2.3 Budgeting for PFAS 63 4.2.4 Limiting PFAS Legal Risk 64 4.2.5 Cost Recovery Strategies 67 4.3 Remediation Options and Controls 67 4.3.1 Remediation Strategies 76 4.3.2 Institutional and Programmatic Controls 79 Chapter 5 Communication and Public Engagement 79 5.1 EJ and Airports 81 5.1.1 Regulations and Guidance Concerning EJ 81 5.1.2 EJ Communities and Airports 83 5.2 Public Communication Strategies 83 5.2.1 Establishing Trust 84 5.2.2 Engagement Planning 85 5.2.3 Methods of Public Engagement 86 5.2.4 Lack of Engagement 87 5.3 Media Engagement Strategies 87 5.3.1 Effective Media Engagement 87 5.3.2 Media Communication Strategies 91 References and Bibliography 101 Abbreviations, Acronyms, and Initialisms 103 Appendices