Research Projects

Guidebook for Environmental Management of PFAS at Airports In Reserve

Assigned to Jonathan Koplos
Last Edited by Jonathan Koplos

The Guidebook for Environmental Management of PFAS at Airports will provide airport managers with a comprehensive yet practical resource for managing the environmental risks of polyfluoroalkyl substances (PFAS) in water, soil, and wastewater at and near the airport.

Background (Describe the current situation or problem in the industry, and how your idea would address it.)

An unknown yet potentially significant number of airports have site soils, groundwater, and/or wastewater that contain elevated concentrations of one or more per- and polyfluoroalkyl substances (PFAS). Airports (and military bases) widely used fire-suppressing aqueous film-forming foams (AFFFs) that contained PFAS and acted as a source of PFAS releases into the environment.
Growing environmental concerns about PFAS are indicated by recent and significant regulatory developments. Since early 2019, the USEPA has published: a PFAS Action Plan (2/2019); an Interim Recommendations to Address Groundwater Contaminated with PFOA and PFOS (PFAS compounds) (12/2019); an Advance Notice of Proposed Rulemaking (ANPRM) (12/2019) that considers a rule to add some PFAS compounds to the Toxics Release Inventory (TRI) list; and a Federal Register Notice (3/10/2020) announcing that USEPA's Office of Water will regulate and set standards for PFOA and PFOS in drinking water. USEPA also now maintains a PFAS data and tools website. Addressing PFAS contamination at and near some airports is becoming more of an environmental and planning issue. Some anecdotal information indicates that insurance coverage for airports related to PFAS is becoming more restrictive. Airport managers are faced with a growing need to address PFAS legacy environmental contamination and prevent future PFAS problems.

Objective (What is the desired product or result that will help the airport industry?)

The guidebook will compile, research, and summarize technical and regulatory information that will serve as a one-stop, comprehensive resource for airport managers to assess and manage potential PFAS-related risks, plan and implement remediation and treatment, and monitor and maintain compliance with PFAS environmental regulations.

Approach (Describe in general terms the steps you think are needed to achieve the objective.)

The approach for developing the guidebook will be to: compile and review the state-of-the-science literature on existing PFAS technical, regulatory, policy, and environmental management information; identify the information that requires updating, extending, or modifying for current airport needs; research and fill information gaps; and present the comprehensive results and findings in guidance and best practices terms that are tailored to the needs of airports. In addition to a literature review, this work might entail some type of survey of airport managers to identify technical information and data gaps, limited case studies to illustrate best practices for site investigations, remediations, and compliance strategies, and development of a practical cross-walk for airport managers to better navigate PFAS management work across state and federal regulations, and across regulations of the various environmental media (soil, water, drinking water, and wastewater).

Cost Estimate and Backup (Provide a cost estimate and support for how you arrived at the estimate.)

A very approximate cost estimate is between $300,000 and $350,000. About half of the total will support the extensive literature review conducted in the context of airport needs, ACRP 173 updates and extensions, and the recommended research identified in the ACRP Research Roadmap (see below). About a quarter will support the planning and implementation of the survey and case studies, and a quarter will support the preparation of the draft and final guidance document.

Related Research - List related ACRP and other industry research; describe gaps (see link to Research Roadmaps above), and describe how your idea would address these gaps. This is a critical element of a synthesis topic submission.

ACRP Research Report 173 (2017) presented a valuable airport reference on: the sources and chemistry of PFAS; sampling, analysis, and remediation of PFAS in soils and water; and a screening tool to identify areas at airports of potential environmental concern. Recommendations for future research was also included. Some of the key recommendations from ACRP 173 are reflected in the ARCP Research Roadmap that identifies several PFAS-related topics that warrant research. These topics include identifying FAA-accepted alternative AFFFs (Idea Rank #25), best management plans for PFAS-containing foams (Idea Rank #32), identifying cost-effective disposal practices of AFFFs containing PFASs (Idea Rank #35), and guidance on using existing treatment facilities to remove AFFFs from wastewater (Idea Rank #46).
In April 2020, the Interstate Technology and Regulatory Council (ITRC) published an online PFAS Technical and Regulatory Guidance Document and related materials that provide extensive PFAS-related environmental information including: AFFF use and handling; site risk assessments; state and federal PFAS regulations; site environmental investigation and characterization; sampling and analysis; treatment technologies; and risk communication. (Given the ongoing changes in state and federal regulations, the ITRC online material reports that the companion spreadsheet that presents state and federal soil and water regulations will be periodically updated online.)
Given the changing regulatory landscape and evolving treatment technologies, the ACRP 173 might require updating and extending. The large ITRC online PFAS document contains very useful information, but is not tailored to airports. For example, this document partly or generally addresses some of the research topics identified in the ACRP Research Roadmap, but the information would be more valuable if it was researched and presented specifically for the needs of airports. The proposed Guidebook for Environmental Management of PFAS at Airports will: update and extend ACRP 173; prepare an airport user's guide for the USEPA PFAS data and tools website; synthesize and modify information from the ITRC document to specifically address airport needs; and identify remaining gaps in guidance or best practices, conduct the research to fill those gaps, and present the results specifically tailored to the needs of airports.

Annotations
Idea No. 391