Insights: PFAS Contamination, Remediate or Wait?

PFAS Contamination
Taxiway reconstruction project at a major hub airport

One of the most significant environmental issues to ever impact airports is currently at the forefront of the regulated community. Similar to asbestos, per- and polyfluoroalkyl substances (PFAS) are very effective products, but also pose significant health and environmental concerns. PFAS has been incorporated into a broad range of products including teflon coatings, stain resistant carpets, water repellant clothing, to-go food containers, and aqueous film forming foam (AFFF). The use of PFAS AFFF is mandated by the Federal Aviation Administration (FAA), and as of the date of this article, a PFAS-free alternative has not been approved, placing the regulated community in a quandary. Similar to asbestos, awareness of the consequences of PFAS use lags decades behind its widespread use.

This is an issue that is being intensely researched by the academic, consulting, and legal communities. Regulators are also working vigorously to develop guidance, standards, and regulations for the assessment, investigation, and remediation of PFAS. It is my belief that all involved want to see the development of a regulatory framework that is reasonable and logical, and also provides a legitimate measure of health and environmental protection for communities. However, the development of regulations for an emerging contaminant is extremely difficult and a sensitive matter that must be handled with great care.

Currently, there are approximately 30 states that do not have PFAS regulations.

Most of the regulated states are located in the Great Lakes Region and the Northeast (e.g. NY, MA, MI, NJ, OH) and in the west (e.g. CA, WA, NV, AK). Regulatory frameworks are essentially non-existent in the midwest, mid-south, and southeast. Generally, most existing regulations consists of thresholds for acceptable concentrations of PFAS in groundwater or soil. There is very little guidance or regulation pertaining to the remediation of PFAS. However, some states offer funding to municipal water providers to treat potable water.

The purpose of this article is not to highlight the holes in the regulatory framework or paint a dark picture of the situation; you’ll see that there is light at the end of the tunnel. It is my intent to demonstrate that we are in the same fight and that there are a lot of common sense tactics that can be taken to prepare for and mitigate PFAS issues. In my opinion, part of the struggle is mental:

  • This is a national issue. My colleagues across the country are faced with a similar situation. There is likely PFAS contamination at all airports with ARFF activity. Whether it be assessment, investigation, or remediation, all airports will have to undertake some form of PFAS work. There are already a lot of lessons to be learned on best practices to address PFAS issues, and many airports are eager to share. As I have heard said, “It is smart to learn from your own mistakes, but it is wise to learn from someone else’s.”
  • Don’t expect your regulators to be bold in their decisions or have all the answers. If you live in a state without regulations, expect nothing. As a consultant, I want to have an immediate answer for every problem, but PFAS regulation and science is still emerging, so patience is paramount. Plan to address your PFAS issue in strides and expect that you, your regulator, and your consultant will be learning together. If you endeavor into a PFAS project and expect the challenges to be handled on par with a fuel spill, expect the process to be painful.

On the technical remedial side, there are difficulties as well, but as I mentioned, there are literally thousands of very bright people trying to answer the question, “What is the best way to handle PFAS contamination?” Currently, the answer is, “It depends”. Facility-specific metrics must be considered for every project, and there is no one-size-fits-all remedy. The chemical, biological, and physical properties of PFAS make is particularly challenging to remediate. PFAS is typically recalcitrant to oxidation/reduction, they are generally resistant to biodegradation, and short-chain PFAS have questionable effectiveness with adsorption.

For water treatment, there are mature and feasible technologies, with the primary being the use of granular activated carbon (GAC) and anion/ion exchange. There is not a water treatment technology that eliminates 100% of the PFAS and technologies are often used in combination. For soil, excavation and disposal is the best way to remove a source from a site. However, disposal costs can be very high ($300-$400/ton) and until clearer regulation is created, landfill disposal may not provide liability protection for the generator. Another method is soil stabilization, although it does not result in the removal or destruction of PFAS, and there is debate whether multiple rounds of stabilization are needed. This is often completed by injecting Portland cement, specialty clays, and/or proprietary products. Incineration/thermal destruction technologies are also evolving, although it is possible that short-chain PFAS are not destroyed in the process.

Even though there are many entities tackling PFAS remediation, there are risks:

  • Except for some municipal water providers, entities under an order, or sites such as Brownfield Cleanup Program (BCP) sites, there is not a regulatory directive to treat/remediate PFAS. Remediation is generally “at risk”.
  • Even states that have PFAS regulations are updating guidance on a regular basis. As an example, New York has changed the acceptable concentrations for PFAS in soil and groundwater multiple times since inception of the original guidance. That being the case, a remedial project may meet cleanup criteria at the time of implementation and later require further remediation.
  • Most PFAS treatment technologies are not considered mature or feasible. In many cases, multiple types of treatment are required, no treatment is 100% effective, and there are numerous draw backs. As part of the decision making process, a thorough analysis should be performed. The decision should consider regulation (if applicable), timeframe, pros/cons of each remedial alternative, cost, acceptable level of risk, etc.
  • PFAS remediation is costly and airport budgets are constrained. However, as detailed below, future funding opportunities are expected.

To avoid the complexities of the above items, some airports are managing PFAS impacted soil via onsite soil stockpiles. This method is a “gray” area in the regulatory landscape. Many states have conditions for the length of time “contaminated” soil can be stored onsite. However, many states solid waste regulations pre-date PFAS issues and it’s not clear how solid waste regulations apply to PFAS contaminated soil. Many airports have taken the position that unique times call for unique measures. This is a logical approach if the soil can be handled/stored in a manner that doesn’t increase risk.

C&S Companies is capable and willing to take on PFAS remediation projects.

Our general approach has been to proceed with caution. In most cases, PFAS issues have come to light during design phase and some measure of mitigation must be employed. Currently, scenarios where PFAS must be remediated are rare. Our approach is to develop logical, cost effective, and defensible measures to mitigate PFAS as an element of the project. Detailed data collection followed by soil stockpiling has been a common approach. This approach punts the problem down the road to a future time when PFAS remedial metrics are expected to be better defined and remedial technologies are more mature and feasible.

As you may know, there are aviation and airport organization interest groups working feverishly to protect the interests of airports and control liability from the use of a product that was mandated by the government. These groups are seeking a waiver from liability for Part 139 activities. It is anticipated that Congress will set aside funds for AFFF system change over and cleaning, site investigation, and remediation. However, the timeframe is unclear at this time. C&S is following their efforts closely.

If you have already mitigated a PFAS issue, we’d love to hear about it. If you have a potential PFAS issue, we’d be glad to speak with you and see how we can help.

Matt Walker, Senior Project Enviromental Scientist

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