PFAS at JAC Outreach Video

The Jackson Hole Airport is committed to the safety and health of our passengers, staff, and surrounding community. The Airport has therefore taken voluntary measures to investigate the potential for per- and polyfluoroalkyl substances (PFAS) to be found in groundwater on and adjacent to Airport property. PFAS has not been classified as a hazardous or toxic substance, or as a carcinogen, by any Federal or State agency. However, some studies have linked PFAS exposure to health impacts, and caution is advised.

Background

PFAS, a family of over 5,000 chemicals, is found in a wide range of every-day products such as non-stick pans, microwave popcorn bags, water repellant fabrics and applications, pizza boxes, and even some brands of dental floss. PFAS is also found in high-performance fire-fighting foams. As a certificated air carrier airport, the Jackson Hole Airport is required by the FAA to use Aqueous Film Forming Foam (AFFF), which contains PFAS, as a fire extinguishing agent for aircraft fire emergencies.

AFFF was developed in the late-1960s as an extinguishing agent for flammable liquid fires such as those caused by jet fuel. AFFF has a unique ability to form a layer of aqueous film over burning fuel to extinguish the fire and prevent reignition. This ability is dependent upon PFAS foaming agents, which do not easily break down when exposed to extreme heat. The FAA has ordered certificated airports supporting air carrier operations, such as the Jackson Hole Airport, to use AFFF that meets the stringent United States military specification MIL-F-24385F for aircraft fire emergencies. AFFF must contain PFAS to meet the current MIL-F-24385F specification.

Regulatory Environment

The U.S. Environmental Protection Agency (EPA) has established a lifetime health advisory of 70 ppt (parts per trillion) for PFOA and PFOS (two compounds in PFAS) in drinking water based on the agency’s assessment of the latest peer-reviewed science.  Although the health advisory is non-enforceable and non-regulatory, it provides the best currently available reference value for state agencies and other public health officials in evaluating PFAS concentrations in drinking water.

The following explanations may help you understand the terminology and science behind the health advisory.

-What is a lifetime exposure? A lifetime health advisory is derived for an adult (> 21 years old or a 176-lb adult), and assumes daily exposure over a period of an average lifetime (approximately 70 years). For PFAS, one would have to drink eight glasses of water per day containing more than 70ppt PFAS for 70 years to exceed the LHA.

-What is 70 ppt? A part per trillion, an extremely small measurement unit.  In units of time, it would be 1 second in 32,000 years.  The lifetime health advisory of 70 parts per trillion equates to approximately 3.5 droplets of water in an Olympic size pool (660,000 gallons).

Currently, the regulatory environment for PFAS is extremely fluid. Ongoing research and regulatory guidance for PFAS are changing almost weekly. The Airport will remain vigilant to stay abreast of scientific and regulatory developments to facilitate appropriate investigation, mitigation and potential remediation on and around the Jackson Hole Airport.

Steps Already Taken to Limit Future Use

The Airport has already implemented a number of measures to limit the use of AFFF containing PFAS at the Airport going forward. Under these measures, PFAS will only be discharged on the Airport under circumstances where its use is necessary to protect human life. These measures include:

–  Eliminating the need to discharge foam for required training exercises,

–  Purchasing and using a “No Foam” system which eliminates any discharge of AFFF for required Aircraft Rescue and Firefighting (ARFF) vehicle equipment calibration.

–  Transitioning to a MIL-F-24385F certified AFFF product containing PFAS ingredients that are currently understood to have the lowest risk to human health. and

–  Making changes to post-emergency response plans, so to the extent necessary and possible there will be timely containment, collection, and proper disposal of AFFF containing PFAS in the event of an aircraft fire emergency.

The Airport is staying abreast of possible changes to FAA requirements with respect to the use of AFFF containing PFAS.  We are preparing to shift away from such use as soon as possible, if and to the extent FAA authorizes the use of a PFAS-free AFFF product.

The Jackson Hole Airport has hired nationally recognized environmental consultants to guide the Board in making the best decisions concerning PFAS. Select members of airport staff are also dedicated to supporting this environmental team. We are invested in our community and ecosystem and will continue to collaborate with highly qualified specialists to assist us with every aspect of this process.

Phase I & Phase 2 Sampling – Updated November 19, 2020

Understanding that fire-fighting foam containing PFAS has been used on airport property in the past, the Airport proactively initiated water sampling off airport property to determine if and to what extent PFAS had migrated. This investigation was not mandatory; the Airport had not been directed by any agency, authority, or regulatory requirement to undertake this process. The Airport chose the path as part of its commitment to protect the community and the natural environment.

In this vein, in February 2020 the Airport sampled thirteen wells on airport property. Some level of PFAS was detected in five of the thirteen sampled monitoring wells on airport property. Of these, two wells contained concentrations higher than the EPA’s lifetime health advisory level of 70 ppt.

In light of these results, in June 2020, the Airport initiated Phase 1 Voluntary Residential Well Testing on private residential wells immediately adjacent to and downgradient of the Airport, in order to determine if and to what extent PFAS was present.  Of the 45 residences located in this area, 32 residences initially volunteered to have their water tested. Of the 32 private wells tested, 31 came back as either “no detect” or were below the EPA LHA. Only one well tested above the EPA LHA advisory at 70.3 ppt. Since the time of the original testing, the 13 remaining homes have volunteered for the program, and additional testing has occurred.  Results for all of the remaining 13 homes  came back as either “no detect” or were below the EPA LHA.

While only one home in the Phase I testing area was found to be above the 70 ppt LHA, in an abundance of caution, and because this neighborhood is located directly adjacent to the airport, the Jackson Hole Airport Board provided filtration systems (upon request) for each home located within this Phase I testing boundary.

Based on results from the Phase I  effort, the Airport moved forward with Phase 2 Testing.  Using scientific criteria (i.e., Phase I results, groundwater flow direction, USGS reports), water wells located further away from the airport were tested to better determine the geographic extent to which PFAS may exist.

Water wells included in Phase 2 consisted of 13 residential wells, 3 utility wells, 1 irrigation well, and 1 surface water test . Results of the Phase 2 Testing event were received in late September and October.  Of the 18 samples taken, 12 resulted in non-detect, and 6 resulted in detectable levels which were well below the EPA’s 70 ppt LHA.

Phase 3 Sampling and Update – Updated April 14, 2021

To further investigate to what extent PFAS has migrated off-airport, a Phase 3 testing effort was approved by the Board. Phase 3 sampling was offered to approximately 144 homeowners located in the testing area, of which 74 volunteered to have their domestic wells sampled.

The airport received Phase 3 data and all 74 samples in the Phase 3 area resulted in either non-detects or values well below the EPA’s Lifetime Health Advisory limit of 70 ppt. PFAS was detected in 12 samples in the Phase 3 area; all results showed levels well below 70 ppt.

Water Filtration System Installation

The Jackson Hole Airport Board is committed to protecting the water quality in and around JAC. Although no tests in the Phase 2 and 3 testing areas resulted in detections over the EPA’s LHA of 70 ppt , the Airport Board will be determining a strategy for whole house filtration system installation for the Phase 2 and Phase 3 areas at its May 19th Board meeting. The Board will discuss and decide on a parts per trillion threshold for eligibility to obtain, at no cost to the home owner, a whole house water filtration system that is certified to remove PFAS from drinking water.

Water Filtration System Reimbursement Policy

At its November 18, 2020 meeting, the Jackson Hole Airport Board authorized the installation of Point Of Entry Treatment (POET) water filter systems, at Airport expense, at any residence in the Phase 2 or 3 areas, where water tests at or above 70 ppt for PFOS+PFOA. This is consistent with EPA’s Lifetime Health Advisory level for drinking water, which is relied upon by 43 states, including Wyoming.  It is not anticipated that water in the Airport’s designated Phase 2 or 3 testing areas will show PFAS levels at or even approaching 70 ppt.

However, seven states have adopted standards lower than EPA’s Lifetime Health Advisory.  As the results of Phase 3 testing are received and evaluated, and the developing scientific evidence is further analyzed, the Airport will determine whether POET water treatment systems should be provided to residences in the Phase 2 and 3 areas, where PFAS has been detected in drinking water at some level below 70 ppt.  The decision as to whether such systems will be installed at Airport expense on wells which test at some level below 70 ppt for PFAS, will be made by the Airport Board in consultation with the Wyoming Department of Environmental Quality (WDEQ) and the Teton County Health Department (TCHD).

 The Airport Board recognizes that some homeowners in the Phase 2 or 3 testing areas may themselves install POET systems before the results of Phase 3 testing are received and the Airport has had the opportunity to consult with WDEQ and TCHD.  At its December 18, 2020 meeting, the Board therefore adopted the following policy:

To review the entire policy, please click here.

On-Airport Soil Sampling

In December 2020 the Airport conducted an on-site soil investigation to determine the extent to which PFAS is found in airport soils and to identify any potential groundwater impacts. The soil investigation consisted of 28 soil borings – drilling to approximately 30 to 70 feet below ground surface, until groundwater was reached. Soil samples were taken at four depths per borehole (0 to 5 feet, 10 to 15 feet, 25 to 35 feet, and 5 feet above the groundwater table), and then a groundwater sample was taken.

To evaluate the sampling results, the Airport used screening levels published by the Interstate Technology Regulatory Council (IRTC), an industry leading organization that contributes to the development of uniform national guidance and standards.

The shallowest soil data (0 to 5 feet interval), representing soils that would potentially be disturbed by the upcoming runway replacement project, was compared to the published Human Health Screening Levels (IRTC, January 2021). These screening levels are 1,260 ug/kg for PFOA and PFOS individually, and 1,300,000 ug/kg for PFBS. These screening levels are based on residential exposure over a lifetime (approximately 70 years). In an abundance of caution, the Airport applied a safety factor of 100 to account for unknowns and provide an extra measure of protection for construction workers associated with the runway project. This resulted in using modified Human Health Screening Levels of 12.6 ug/kg each for PFOA and PFOS, and 13,000 for PFBS in evaluating the 0 to 5-foot interval results. Sampling results found no concentrations of PFOA, PFOS, or PFBS above the modified more stringent Human Health Screening Levels in the 0 to 5 feet interval in any of the 28 borings.

For soil intervals deeper than 5 feet, which would not be disturbed by construction, the ITRC Protection of Groundwater Screening Levels were used in evaluating the sampling results: PFOA (0.172 ug/kg), PFOS (0.378 ug/kg), and PFBS (130 ug/kg). Concentrations of these compounds were detected above their respective screening levels in 8 of the 28 borings at the deeper intervals. These results are consistent with previous sampling events conducted on-airport, expand the Airport’s understanding of the extent of PFAS, and support its decision to continue its PFAS investigations.

The results of the soil sampling event will inform the next steps of the investigation process. These are a Feasibility Study for design of a groundwater remediation system, and application of best practices to be employed during the Airport’s runway project which is planned for 2022.

1 Note that the EPA’s Lifetime Health Advisory for drinking water accounts for only PFOA and PFOS compounds. The ITRC standards for Human Health Soil Screening Level and protection of Groundwater Screening Level include PFBS, in addition to PFOA and PFOS.

Continued Monitoring

The Jackson Hole Airport Board also committed to continued monitoring of residential wells.  Up to 20 residential wells will be tested twice a year (spring and fall) for at least the next two years (2021 and 2022).  These 20 locations will be selected using scientific data and the Airport will reach out to homeowners directly to confirm if they would be willing to be a monitoring location. The purpose of continued monitoring is to evaluate the possible effect of seasonality or duration in time on PFAS concentrations in groundwater. The Airport will continue to test on-airport monitoring wells on the same schedule.

Engineering Study

Finally, the Board commissioned an engineering study to determine if and what extent a treatment system to remove PFAS from groundwater on the Airport is feasible.  If feasible, such a system would be designed to remove PFAS from groundwater before it can migrate off-airport.  Results of this study are expected in 2021.

The Airport is continuing to evaluate next steps in the process to better refine its understanding of the issue. First and foremost, the Airport will continue to employ measures to ensure that the community’s drinking water is safe.  Further, the Airport plans to continue collecting data to identify the best groundwater clean-up approach for Jackson Hole Airport.   We will continue to post updates as more information is obtained.

To view a map of the testing areas, please click here.

To view all testing results, please click here.

Resources 

JAC PFAS Management, Mitigation and Remediation Plan

JAC PFAS Frequently Asked Questions – Phase II

U.S. State Resources about PFAS

EPA Lifetime Health Advisory

For questions, please email community@jhairport.org or call (307) 201-5391.