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) had 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 peer-reviewed science. Although the health advisory was non-enforceable and non-regulatory, it provided the best 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 original 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).
On June 15, 2022 the, EPA released four drinking water health advisories for per- and polyfluoroalkyl substances (PFAS). In releasing these drinking water health advisories, EPA is acting in accordance with its mission and responsibility to protect public health and keep communities informed when new science becomes available. Based in this information, the Jackson Hole Airport did expand the Eligibility Boundary area for whole-house filtration system installations. The updated map can be found below under “Eligibility Boundary for Airport-Provided Residential Drinking Water Filters”.
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
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
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.
In August of 2021, six additional domestic drinking water wells were tested in the Moulton Loop area. All of these samples came back as non-detect for PFAS.
Eligibility Boundary for Airport-Provided Residential Drinking Water Filters
On June 29, 2021, the Jackson Hole Airport Board voted to offer whole-house filtration systems for installation on domestic water wells which, based on available testing data from domestic water wells, are estimated to test at or above a 10 ppt threshold for combined PFOA and PFOS. An “allowance for variability” concept was authorized for use in developing both the Eligibility Contour and the Eligibility Boundary (“EB”). This will account for possible seasonal testing, and other factors contributing to variability over time. Based on the EPA’s update to drinking water health advisories in June of 2022, the Eligibility Area was expanded.
Residents whose parcels fall within the EB will be eligible to receive, at no cost to them, a whole-house domestic water filtration system that is certified to remove PFOS and PFOA. If any portion of a parcel is located within the EB, any domestic water well on the parcel will be eligible for a filter. Water filters will be provided for domestic water wells only. It is the property owner’s responsibility to request installation of a filter system. If a single residence requires more than one filter due to its size, additional system(s) will be provided and installed.
The Board also determined to provide, at its expense, two years of replacement filters for each system installed. The original and replacement filters will together maintain the systems for a period of two years after initial installation. As this anniversary approaches, the Board will review the available groundwater data to determine if additional filters will be provided at Board expense.
If a new residence is constructed on an eligible parcel, it may receive a filter system. The owners of new residences must submit a copy of their Teton County building permit, and coordinate the timing of installation with their construction,
If a parcel that falls within the EB is subdivided in the future, only new domestic water wells on newly delineated parcels where some portion is within the Eligibility Contour will be eligible to be provided with filter systems. The owners of new residences on qualified new sub-parcels must also submit a copy of their Teton County building permit, and coordinate the timing of installation with their construction.
To request a filtrations system, please contact Meg Jenkins by emailing megan.jenkins@jhairport.org or calling (307) 699-4387.
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 main objective of the soils investigation was to measure and evaluate PFAS levels in soils that were excavated as part of the runway project. The measurements were compared against currently available safe exposure criteria to determine whether soils (1) could be safely reused as fill in the project excavations or (2) may need to be stockpiled for further evaluation. Results of the soil sampling indicated that excavated soils could be reused within the project area.
Continued Monitoring
The Jackson Hole Airport Board is committed to continued monitoring of residential wells and on-Airport monitoring wells. The purpose of continued monitoring is to evaluate the possible effect of seasonality or duration in time on PFAS concentrations in groundwater. It is also to ensure that all residential wells in which any concentration of PFAS is expected are offered whole-house filter systems.
On June 15, 2022 the, EPA released four drinking water health advisories for per- and polyfluoroalkyl substances (PFAS). In releasing these drinking water health advisories, EPA is acting in accordance with its mission and responsibility to protect public health and keep communities informed when new science becomes available. Based in this information, the Jackson Hole Airport revised its Eligibility Boundary area for whole-house filtration system installations to ensure it included all wells in which any concentration of PFAS was expected to be detected. The updated map can be found below under “Eligibility Boundary for Airport-Provided Residential Drinking Water Filters”.
Residential
In August 2021, 19 domestic water wells that had previously been tested were re-tested to evaluate potential trends in concentrations. Results for all 19 samples came back well below EPA’s Lifetime Health Advisory (“LHA”) level of 70 ppt.
In February 2022, 18 domestic water wells that had previously been tested were re-tested to evaluate potential trends in concentrations. Results for all 18 samples were well below that e LHA level.
In August 2022, 20 domestic water wells were tested pre-filtration system, if applicable. Results were generally consistent with prior testing events, but some wells showed slight increases in PFOA or PFOS. Additional semi-annual testing will be necessary to draw conclusions and conduct statistical evaluations regarding these findings.
A map showing the cumulative range of results for the domestic water well sites that are part of the continued monitoring effort can be found here. The Airport will continue to re-test these wells, at least through 2023, both in wet and dry seasons, for further analysis.
Airport
In May 2021, 12 wells (11 monitoring and 1 domestic) on the Airport, that had previously been tested, were re-tested to evaluate potential trends in concentrations. Results for two samples came back above the LHA level of 70 ppt; while the remaining 10 samples were below 70 ppt.
In November 2021, groundwater sampling was attempted at the same wells that had been previously sampled on the Airport. Two wells (JH-1.5 and JH-3.5) were dry and well JH-3D had equipment stuck in it that precluded sampling efforts. The remaining 8 monitoring wells and 1 domestic well were re-tested to evaluate potential trends in concentrations. Results for all nine samples came back below 70 ppt.
The Airport did not conduct on-airport testing of wells in the spring of 2022 because of the runway reconstruction project. However, another round of testing for on-Airport monitoring wells was conducted in August 2022. In this testing event, water samples were taken from 10 monitoring wells and one domestic well. When compared with prior testing, concentrations in 5 wells were lower, in four wells there was no change, and in one well there was a slight increase.
Regional Screening Levels (RSLs) are not cleanup standards and are calculated using conservative exposure assumptions and established LHA or cleanup levels for PFAS in groundwater or surface water and have indicated they are deferring to USEPA LHA levels (WDEQ 2021).
Overall, the results from the August 2022 sampling event showed a notable decrease in concentrations in on-Airport wells. Levels have decreased such that only PFOS concentrations detected in 1 of the 10 on-Airport monitoring wells (JH-1.5) are now above the current RSL. PFOA detected concentrations in all 10 wells were not above the current RSL.
Cumulative results for the Airport well sites that are part of the continued monitoring effort can be found here. The Airport will continue to re-test these wells over the next two years, both in wet and dry seasons, for further analysis.
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 cumulative residential testing results, please click here.
To view cumulative on-airport monitoring well testing results, please click here.
To view a map of result ranges for continued monitoring, please click here.
Resources
JAC PFAS Management, Mitigation and Remediation Plan
U.S. State Resources about PFAS
EPA Drinking Water Advisories FAQs
PFAS Frequently Asked Questions
For questions, please email community@jhairport.org or call (307) 699-4387.
