CID has implemented several improvements over the years as part of its focus on environmental stewardship, including the installation of LED lighting, geothermal heating and cooling, and solar energy.
In addition, the airport has transitioned its farmland practices requiring operators to use no-till cover crop. Evaluating the impact and protecting the integrity of neighboring waterways has been a staple of CID’s development philosophy for decades.
With over 3,000 acres of land (2,000 of which is in farm production) impacting both the Cedar and Iowa River watersheds, CID provides active leadership in raising awareness and support for water quality within the entire Mississippi River watershed.
To further its work in water quality, CID launched Wings2Water (W2W) in 2019 to provide a grassroots effort for people to contribute to water quality improvement. W2W is now a stand-alone nonprofit organization that continues to be dedicated to reducing Iowa’s runoff and flood impacts, restoring local water quality, and helping eliminate the Dead Zone in the Gulf of Mexico.
CID’s commitment to environmental stewardship is part of a larger initiative to promote and protect the safety and health of our passengers and community.
In keeping with that core value, CID has begun an initiative to investigate the potential impacts related to the FAA’s mandatory use of PFAS-containing Aqueous Film-Forming Foam (AFFF) at air carrier airports.
What are PFAS?
PFAS is a short-hand term for per- and poly-fluoroalkyl substances. It includes a group of over 5,000 combinations of chemicals manufactured and used in many industries around the world. PFAS can be found in consumer-based products and industries such as:
- Food packaging
- Non-stick cooking materials
- Water-repellant and stain-resistant fabrics and carpets
- Textiles and leathers
- Resins, molds and plastics
- Protective coatings
- Application of biosolids in agriculture
- Polishes, cleaning products, waxes and paints
- Manufacturing of chrome plating, electronics, etc.
- Aqueous film-forming foams (AFFF)
PFOA and PFOS are two of the most widely-known, used and studied PFAS formations. Due to their resistance to degradation, both are highly persistent in the environment and the human body. PFAS have been coined “forever chemicals” because they can keep their chemical structure over a very long period.
Exposure to PFAS-containing products can lead to adverse health conditions and ecological impacts. It is widely assumed most people have been exposed to at least some level of PFAS-containing products, primarily through the consumption of food and through the use of commercially treated products.
Of particular interest to CID and the surrounding community is the required use of PFAS-containing AFFF at certificated air-carrier airports.
What is AFFF?
Aqueous Film-Forming Foam (AFFF) is a fire suppressant that is very effective in extinguishing flammable liquid-based fires. When dispensed, it quickly blankets the flame, separating it from oxygen and eliminating combustion. It is unparalleled in its ability to rapidly and effectively extinguish a fire, but also in its ability to deprive it of the ability to reignite. It has been used in airport and military installations for fire emergencies and training procedures since the 1960s.
Why does CID use PFAS-containing AFFF?
Due to its superiority in effectiveness and the priority of firefighters to protect life and property, the use of PFAS-containing AFFF has been mandatory in the US military and civilian airport industry for decades. Part 139 certificated airports are required to utilize AFFF that meets specifications contained in MIL-F-24385 (MIL-SPEC) via 14 CFR Part 139. Historically, CID has purchased, stored and utilized PFAS-containing AFFF in accordance with these requirements.
In addition to utilization of PFAS containing foams for emergency procedures, airports are also required to maintain their Airport Rescue and Firefighting (ARFF) vehicles and fire suppression operating systems, including the foam proportioning and discharge functions, to ensure they operate properly in an emergency situation. Historically, low volume releases of foam solution have occurred on airport property to test equipment in accordance with FAA regulations.
Current Regulatory Environment
In 2016, the EPA U.S Environmental Protection Agency (EPA) established a lifetime health advisory of 70 parts per trillion for PFOA and PFOS in drinking water. The advisories serve as technical information for agencies to create regulations. The regulatory environment for PFAS continues to be fluid at both the State and Federal levels, but many states are developing and executing regulations and PFAS Action Plans. Designating PFAS as a “hazardous substance” is currently under consideration by the US EPA, but the use of PFAS-containing AFFF is currently still required for certificated airports.
In January 2020, the State of Iowa developed a PFAS Action Plan. Within that Action Plan, the document outlines Iowa will support an initiative that focuses on minimizing future releases of PFAS to the environment. Example strategies related to AFFF include:
- Promote best management practices for storage and use
- Support surveys of existing stocks
- Support development of a take-back program for safe disposal
- Support P2 industry training workshops that promote best management practices and safe disposal
These example strategies are consistent with actions executed by other States and are consistent with Federal recommendations.
Additionally, as part of the FAA Reauthorization Act of 2018 (HR 302), the Federal Government has directed the FAA to no longer require the use of fluorinated chemicals to meet federal performance standards for extinguishing fuel-based fires by 2022. The FAA has constructed a testing facility and has begun the testing of non-fluorinated foams, but has not yet approved an acceptable non-fluorinated alternative.
CID’s Proactive Efforts
Consistent with its longstanding efforts in promoting the safety of its community and commitment to water quality, CID has developed a preliminary plan to proactively evaluate potential PFAS contamination within the airport environment.
In April 2021, CID approved efforts to evaluate several components related to PFAS:
- Research on historical storage of material
- Research on historical use for calibration and emergency procedures
- Compilation of records related to excavation and/or fill near areas of known AFFF discharge
- Up to 6 monitoring wells near areas of known AFFF discharge
- Testing of groundwater for PFOA and PFOS; determination of groundwater flow
- Soil sampling at the location of 6 monitoring wells for PFOA and PFOS
- Development of public information repository
- Determination of next steps (based upon sampling data)
In addition to investigatory procedures, CID has also completed the following voluntary measures:
- Switched AFFF material from long-chain (8 or more carbon molecules) to short-chain (6 or less carbon molecules) which have been determined to be less impactful to human health and ecological impacts.
- Purchased a no-foam dispensing system that assists in calibrating equipment without the need to dispense AFFF onto the ground.
- Supported the 2020-2021 private well testing efforts at 19 residences conducted by Linn County Public Health and University of Iowa Center for Health Effects and of Environmental Contamination (CHEEC), and conducting follow-up testing at one residence.
CID is committed to staying informed of advancements in the industry, and eagerly awaits the FAA’s development of an acceptable fluorine-free foam per the directive in the FAA Reauthorization Act of 2018. Currently, there are no fluorine-free foams that have proven to match the performance of fluorinated alternatives, but the FAA remains steadily at work in the development and approval. Our goal is to proactively and transparently assess the status while instituting procedures for the safe handling, storage, disposal and response to spills and discharges.
Additionally, the Transportation Research Board has recently begun an initiative to produce a guidebook for PFAS Management at Airports, with an anticipated publish date of June 2022. In the meantime, CID will continue to proactively investigate the historical use and potential resulting contamination. As information becomes available, regulations are determined, and best practices are published, CID will continue to modify and/or develop an approach that keeps the safety of the community at the forefront while maintaining our ability to actively operate as a commercial service airport by complying with mandatory federal firefighting procedures.
This website will be updated as testing reports become available.