Environmental Due Diligence

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Q&A from LightBox’s PFAS Due Diligence Webinar: Higher Risk Property Types – Part 1 Aviation

LightBox Profile
LightBox Insights
November 15, 2023 6 mins

“This webinar was helpful in trying to understand the unique complexity of the impacts of PFAS at airports.” Mathew Hunt, LOR Geotechnical Group, Inc.

Our groundbreaking PFAS webinar series continued in October with a pivot toward events featuring leading experts with technical knowledge on specific types of properties that present a high probability for PFAS risk. The October webinar brought to the surface the unique issues of PFAS use at aviation facilities, including commercial airports. Moderated by LightBox’s Principal Analyst Dianne Crocker, Alan Agadoni, SVP EDR Solutions, led a technical discussion with leading PFAS airport expert Georgeanna Nugent, Division Director of Environmental Services for McFarland-Johnson.

After the moderated discussion, we received more questions than we had time to address. Below are responses to the outstanding questions raised by attendees during the live event:

Is Puerto Rico included?

Puerto Rico does not have a State PFAS database, but Federal PFAS databases in the Radius Map Report include information reported by airports and other facilities in Puerto Rico.

Can you share your experience performing due diligence on Air Force bases? Answer: Are there any tips or guidance you can share for assessing such properties that you didn’t already share?

Unfortunately, there wasn’t time to discuss DOD airports during this presentation. Air Force bases are handled much differently with different funding sources and typically under Installation Restoration Program (IRP) site listings. The assumptions should be made that AFBs (not all) have used products containing PFAS unless proven otherwise. PFAS contamination sources can be similar to airport properties but have additional sources such as chemical storage areas or holding tanks. If you haven’t already, please subscribe to our email list so we can notify you when we will focus on DOD facilities.

Are the Superfund sites in NY mentioned airport facilities?

Yes, I’m aware of three airports that were put on the NYS Superfund list in the past two years. All three have reported impacts to drinking water sources.

With sites in some states being put on Superfund lists, etc., it would be fair to assume that other facilities in other states might not be as forthcoming with their information. What sort of basis do we have for inquiry, as in what are they legally required to divulge during a contracted Phase 1 etc.?

EDR’s federal PFAS databases include both voluntary and required information reported by airports and other facilities. According to ASTM E1527-21, disclosures during interviews by property owners, managers and others to an EP during an ESA are generally considered to be voluntary. It should be noted that PFAS is now regulated (in various ways) in approximately half of the states. If an aviation facility is located upgradient from one of your sites, your basis for inquiry may run deeper than PFAS. I can’t speak to the legal requirements for clients’ divulging information; this typically depends on your client relationship and the reason for the due diligence.

Have landfills started requiring testing for PFOS? How/where are used AFFF disposed of?

Every state is different. Some landfills still accept soils without soil analytical results for PFAS.

Can it be assumed that PFAS contamination exists at all airports, regardless of the type of airport?

It is reasonable to assume AFFF has been used, stored, and/or applied at an airport unless proven otherwise. Just because an airport is not Part 139 certified does not mean AFFF was/is not used, stored, and/or applied to the property. I am also aware of airports with no reported use, storage, or release of AFFF containing PFAS.

Is the column for use of AFFF or release of AFFF? Is that column the volume of diluted product?

It is the total volume of AFFF product that includes different compounds in addition to PFAS.

Have any vapor intrusion concerns been identified related to PFA contamination?

    According to USEPA, “it has been identified that some per- and poly-fluoroalkyl substances (PFAS) also have volatile phases that may be of concern during vapor intrusion site assessments. The release of these toxic vapors can pose serious health issues and safety hazards to building occupants, and our scientists are conducting research to help mitigate and prevent vapor intrusion.”

    What has the airport (or others) been doing with respect to soil assessment and cleanup? Now that you have detected areas, what is the plan for remediation of soils and groundwater?

    Yes, there have been several soil investigations, and the results and maps can be found on the Documents page of the ACK Website, same with any remediation efforts to date. There are various technologies on the market, many in R&D phases. I’ve also seen project-specific remediation technologies for various remediation efforts from talented environmental professionals.

    Did the saltwater environment have any impacts?

    Not that I’m aware of.

    What other high-risk PFAS sites are there?

    There are many lists available online. The OSTP Table 2 featured in our presentation includes Industrial, Medical, Pharmaceutical, Cosmetics/Personal Care, Textiles, Food Packaging, Agricultural, Fire Suppression (AFFF), and Recreational (ski wax, waterproofing, etc.). Stay tuned for an announcement on our next installment in our higher-risk properties series.

    Is the expectation of corrective action limited to remediation at the point of use only? Do you see any remediation of the plume in the cases you are involved with?

    It’s case-specific. Regarding the case study, point-of-entry-treatment systems (POETs) were installed on private water wells until a permanent solution (public water supply connection) was established. Yes, plume remediation is occurring all over the country, and there are various innovative remediation technologies.

    Who paid for all of the environmental studies, wells, new waterlines, etc. Did MA sue the chemical companies? Or was this cost passed onto taxpayers?

    The airport has funded this, as is the case with other airports. The FAA will reimburse the investigation costs if they are associated with a project on their ACIP list. Remediation costs or reimbursements are not eligible for FAA funding at this time.

      If an airport is a certified part 139 airport, then that airport handled AFFF as they were required to do so?

      Yes, the FAA mandated this for Part 139 airports.

      Is the main concern groundwater? Are there other risks we should concerned about?

      PFAS contamination travels into the groundwater, which can then impact drinking water wells. Other PFAS risks are associated with PFAS-impacted soils. Please see the McFarland Johnson website for more information.

      Can you provide reference studies that show the toxicity or health risks of PFAS?

      The OSTP Report featured in our presentation includes summaries and references to numerous PFAS toxicity studies. Much more is available online.

      With the regulatory emphasis on states but ASTM referring to CERCLA hazardous substances, are we still just waiting on EPA so we can call PFAS a REC under ASTM? What are people calling it otherwise regarding liability protection through due diligence?

      I have seen EPs referring to suspect PFAS releases as business risks, conditions beyond the scope of ASTM E1527, or simply just laying out the applicable rules and regulations for the condition. It may take some time before a consensus on how best to address PFAS in ESA reports or until the US EPA lists PFAS as Hazardous Substances under CERCLA. In March, EPA indicated that they intend to develop an enforcement discretion policy to protect some entities, including airports, from EPA enforcement actions under the Superfund law concerning PFAS contamination. There are CERCLA PFAS Listening sessions available at CERCLA PFAS Enforcement Listening Sessions | US EPA



            For the full replay of our webinar, please click here.

            To stay informed of the latest developments and technical resources related to assessing PFAS risk, as well as links to past blogs and webinar replays, visit the LightBox PFAS Resource Center.

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