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PFAS are "emerging contaminants," or chemicals with limited data on human health effects. PFOS and PFOA are the most studied. PFAS are used in products that resist fire, stains, grease, and water. While PFAS can be found in firefighting foam, they can also be present in furniture and carpets treated for stain resistance, waterproof clothing, and food packaging.
Beginning in 2001, 3M and other major manufacturers of fire-fighting foams and consumer products containing PFAS-related chemicals began to phase out the use of PFOA and PFOS in these products due to findings that these chemicals can be harmful.
PFAS that enter the environment are known to persist for a long time and may travel long distances in groundwater.
The Department of Environmental Conservation (DEC) published cleanup levels for two types of Per- and Polyfluoroalkyl Substances (PFAS), perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), in groundwater in November 2016. The cleanup levels are listed in 18 AAC 75 (Article 3) available at dec.alaska.gov/spar/regulations/.
The EPA established a provisional health advisory (PHA) level for PFOS and PFOA in drinking water in 2009. However, in May 2016, the EPA issued a new lifetime health advisory (LHA) level of 70 parts per trillion (ppt) for the sum of the PFOS and PFOA concentrations.
On August 21, 2018, DEC established guidance for the State of Alaska that groups five similar compounds into a combined PFAS action level to be compared to the EPA LHA level of 70 ppt. The DEC action level is the level above which DEC will require the provision of alternative drinking water to affected properties. 70 ppt is roughly equal to three grains of rice in an Olympic-sized swimming pool.
On February 14, 2019, EPA published a PFAS action plan. This plan includes a commitment to propose a national drinking water regulatory determination for PFOS and PFOA for public comment in 2019, this is a critical step under the Safe Drinking Water Act for EPA to determine whether it will establish maximum contaminant levels. EPA also proposed to finalize toxicity assessments for five other PFAS. In order to align state actions with the EPA action plan, DEC revised its drinking water action level match the EPA LHA level of 70 ppt for PFOS and PFOA, individually or combined.
On October 2, 2019, DEC updated the Technical Memorandum that references the action levels for PFAS in water and the guidance on sampling groundwater and drinking water. The update aligns the State of Alaska’s actions with the EPA’s and states that, “Any new testing for PFAS will report the full suite of PFAS compounds analyzed by the appropriate EPA Method.”
The Alaska Department of Transportation and Public Facilities (DOT&PF) is conducting a comprehensive evaluation of PFAS contamination at state owned properties or sites that the department is responsible for. Evaluation includes all past and present Part 139 airports and formerly known Department of Defense (DoD) sites. DOT&PF has contracted with third-party environmental consultant, Shannon & Wilson, Inc. to identify and sample potentially impacted communities.
Once PFAS presence is established, DOT&PF will mobilize Shannon & Wilson, Inc. to assist with the departmental response. This will include field sampling and analysis of ground water, surface water, drinking water, and soils; implementation of a temporary water solution for impacted property owners; public and stakeholder engagement, outreach, and support; engineering and design for remediation solutions, as well as alternative permanent water supply concepts; site characterization and plume identification.
To date, DOT&PF has responded in five communities where PFAS contamination has been identified. DOT&PF recognizes the importance of immediate corrective action as the health and safety of the public is of upmost importance. In all cases, an alternate source of drinking water was immediately supplied to impacted residents. In addition to contracting with an independent environmental firm to support DOT&PF’s response across Alaska, the department has created a position to manage the response efforts related to PFAS contamination. This includes but is not limited to interdepartmental coordination and travel logistics, public and stakeholder outreach, and contract management.
Additionally, DOT&PF has begun inventorying their Aqueous Film Forming Foam (AFFF) throughout the state in order to dispose of AFFF manufactured prior to 2015. The department has been exploring alternate testing mechanisms that will allow airports to meet minimum petroleum firefighting training requirements mandated by the Federal Aviation Administration (FAA). DOT&PF is staying abreast of regulations requiring the FAA to produce a fluorine-free AFFF option for airports. The FAA Reauthorization Act contains language directing the FAA to review this issue and make changes to Aircraft Rescue and Firefighting foam requirements by no later than October 2021. DOT&PF will continue to work with the DEC, Division of Risk Management, Department of Health and Social Services and Shannon & Wilson, Inc. to ensure response efforts are met fully.
FAA Reauthorization Act Update
Monday, Oct. 4, 2021 the FAA issued CertAlert 21-05, Part 139 Extinguishing Agent Requirements advising airport operators about changes to the military specification (MIL-PRF-24385F(SH)) for firefighting foam referenced in Chapter 6 of AC 150-5210-6D.
In response to CertAlert 21-05 the American Association of Airport Executives (AAAE) issued the following update to its members outlining the guidance in the CertAlert. The AAAE continues to encourage the FAA and DOD to identify and approve an alternative foam as soon as possible as well as provide airports with transition planning support.
PFAS Program Manager
DOT&PF – Statewide Aviation