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Environmental Commitment: PFAS

Overview

The Gerald R. Ford International Airport (Ford Airport) deeply values its place in this community, with the health and safety of those who use the airport paramount to our service priority. We take enormous pride in connecting individuals and families to destinations worldwide; in 2019 the Ford Airport helped approximately three million passengers achieve their travel goals while contributing more than $3 billion in economic activity in the West Michigan region. While the Covid-19 pandemic brought unprecedented challenges to global travel in 2020, we remain optimistic about the future.

The Ford Airport’s success is directly related to its strong commitment to collaborative, innovative solutions in all that we do. This includes our ongoing environmental work in investigating PFAS (per-and poly-fluoroalkyl substances) on Airport property. PFAS are a group of thousands of man-made chemical compounds that have been used since in the 1940s in a wide variety of consumer and commercial products, including certain firefighting foams used around the world to help ensure the safety of the traveling public.

FAQs

 

What are PFAS (per- and poly-fluoroalkyl substances)?
Why does Ford Airport care about PFAS?
How is the Ford Airport proactively addressing the future use of AFFF?
What has Ford Airport done since PFAS concerns were first raised?
What is the current status of Ford Airport's investigation?

PFAS and its Impacts at Airports

Learning about PFAS and how to respond to any related impacts at airports has become an evolving state and national conversation (FAA, EPA, etc.), including growing concern over the potential health effects from these chemicals, primarily through PFAS-impacted drinking water.

The Federal Aviation Administration (FAA) has long mandated that commercial service airports, including the Ford Airport, use Class B firefighting foams that contain PFAS, known as aqueous film-forming foams (AFFF), due to their ability to extinguish petroleum-based fires quickly and effectively. State public-use air carrier airport licenses also require compliance with these federal requirements which are applicable to all commercial service airports. In 2016, the Environmental Protection Agency (EPA) developed its first-ever Lifetime Health Advisories for PFOA and PFOS - EPA Health Advisories and EPA Fact Sheet. Congress has directed the FAA to research, test and ultimately approve AFFF formulations that do not contain PFAS by October 21, 2021. Until then, the Ford Airport must continue to comply with the FAA mandate to use AFFF containing PFAS until a fluorine-free foam (F3) is approved.

Michigan & PFAS Investigative Sites

There are over 150 sites in Michigan currently identified as PFAS investigative sites, including the Ford Airport and six other airports, according to the Michigan Department of Environment, Great Lakes and Energy (EGLE).

Drilling 5 (Winter)
Drilling 2
Drilling 4 (Spring)
Drilling

Data-Driven Process

The Ford Airport, working with its environmental engineering consultant, LimnoTech, has conducted a multi-phase evaluation process to assess the potential impacts of historical AFFF usage on Airport property, with the results from each phase guiding subsequent investigative actions. This process, which continues through today, includes testing groundwater, soil, and stormwater on Airport property and residential drinking water wells immediately downgradient of the Airport. It also includes modifying our practices regarding the specific type of AFFF used, employing new technologies approved by FAA to eliminate any AFFF test spraying, and employing due care practices to manage any contaminated materials that we discover.

To date, more than 220 samples have been collected, with the findings from each step of the process guiding future investigative efforts, see timeline below. As part of our commitment to collaboration, all of our efforts have been coordinated with state and local agencies, including EGLE (formerly known as the Michigan Department of Environmental Quality) the Michigan Department of Health and Human Services (MDHHS), the Kent County Health Department (KCHD) and Cascade Township.

Collaboration

Ford Airport values its collaborative approach working with federal, state and local groups, associations and entities in our efforts.  Our work includes engagement with:

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  • ACI-NA Airport Council International – North America
  • American Association of Airport Executives (AAAE)
  • Cascade Township
  • Environmental Protection Agency
  • Federal Aviation Administration
  • Kent County Health Department (KCHD)
  • Michigan Department of Environment, Great Lakes, and Energy (EGLE; formerly the Michigan Department of Environmental Quality or MDEQ)
  • Michigan Department of Health and Human Services
  • Michigan Department of Transportation – Office of Aeronautics
  • Michigan PFAS Action Response Team (MPART)

Timeline

2016

The US Environmental Protection Agency established health advisories for PFOA and PFOS.

2017

The National Academy of Sciences, Airport Cooperative Research Program published Report 173 Use and Potential Impacts of AFFF Containing PFASs at Airports” as a primer for U.S. airports.

APRIL/MAY 2018

Ford Airport began its data-driven, multi-phase investigation process, coordinated a work plan for EGLE approval, and began sampling.

JUNE 2018

Ford Airport shared its initial groundwater test results with those results indicating PFAS levels less than the State of Michigan cleanup criteria established for groundwater, as protection for drinking water. The results were shared with EGLE, the KCHD, the MDHHS, and the community. Although the groundwater test results were within acceptable regulatory levels, Ford Airport chose to go above and beyond to conduct additional testing of off-site residential wells. See press release here.

SEPTEMBER 2018

Results of the residential well testing indicated the drinking water at the properties all showed non-detect for PFOA and PFOS, the two PFAS compounds that comprise the basis for EPA Lifetime Health Advisories. Based on the data and results, the KCHD concurred that there was no need for the Ford Airport to continue additional residential testing. See press release here.

OCTOBER 2018

Ford Airport submitted Phase 2 groundwater and soils investigation findings to EGLE showing that reported concentrations generally decreased the further away or deeper samples were collected.

Additionally, groundwater was encountered 70-100 feet below the surface. The 60+ feet of clay between the surface and groundwater prevents downward migration. Results supported a finding that there was, "...no likelihood of a transport pathway from [the former FireFighter Training Area] offsite or to any surface waters."

EARLY 2019

EGLE conducted an independent geological review which concluded that PFAS found in groundwater beneath the former FireFighting Training Area (FFTA) does not appear to be related to former training activities. EGLE continued to explore possible PFAS sources beyond Airport property.

EGLE also completed testing of surface waters in the vicinity of the airport, with all results below established criteria.

EGLE began a multi-phase analysis of residential drinking water wells beyond the 28 residential wells tested by the Airport.

SUMMER 2019

Based on data collected to date, surface water and soil work plans were approved by EGLE and executed by the airport, contributing additional data to the overall conceptual site model.  All data were summarized and reported to EGLE.

OCTOBER 2019

EGLE and Airport team members concurred on a sampling and analysis plan for phase 3 investigation activities based on all data to date.  Phase 3 sampling began with a focus on upgradient deep groundwater analysis and possible historic migration pathways.

EARLY 2020

Short-Term Stormwater Characterization and Phase 3 investigation data were summarized and submitted to EGLE.  Findings were consistent with prior investigations showing a significant clay layer with PFAS values decreasing with depth and distance from the FFTA.

SPRING 2020

Amid the COVID-19 pandemic, the Ford Airport was one of several Michigan airports to apply for grant funding from the Michigan Department of Transportation - Office of Aeronautics.

The grant work plan recommended the continuation of soil and shallow groundwater testing at several locations on Airport property, including the FFTA. This data will advance the overall conceptual site model.

SUMMER/FALL 2020

Ford Airport was awarded a grant from the Michigan Department of Transportation (MDOT) to conduct on-site testing.

EGLE and MDOT reviewed and approved a modified work plan with sampling currently underway.

AUGUST 2020

The State of Michigan adopted new regulations limiting seven PFAS chemicals in municipal drinking water. The new drinking water standards also update Michigan’s existing groundwater cleanup criteria of 70 ppt for PFOS and PFOA. See the State of Michigan link here.

Following the promulgation of new criteria, EGLE concluded that 39 drinking water wells sampled by EGLE in the off-airport, Cascade Township Residential Well investigation exceed the new state criteria. The KCHD has offered water filtration to residents with PFAS detections.

NOVEMBER 2020

MDOT grant-funded drilling and sampling activities began to further delineate the extent and distribution of historical impacts.

OCTOBER 2021

FAA mandated deadline to approve PFAS-free AFFF for certificated airport use.

Michigan Environmental Cleanup Law, Part 201, Environmental Remediation

The Ford Airport continues to manage PFAS impacts to its property associated with its past mandatory use of AFFF, according to the requirements of Part 201 of Michigan’s Natural Resources and Environmental Protection Act.  As a public entity, the Ford Airport remains committed to our community and ongoing environmental stewardship.

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