The U.S. Environmental Protection Agency (EPA) defines PFAS (per- and polyfluoroalkyl) as a group of thousands of man made chemical compounds that have been used since the 1940s in a wide variety of consumer and commercial products such as nonstick cookware, pesticides, paint, fast food packaging, water-resistant fabrics, and personal care products, including dental floss and mattresses. For decades, PFAS have been used in many industrial applications, including certain firefighting foams used around the world to help ensure the safety of the traveling public. They are still used today, and based on new research, these compounds are now classified by the EPA as an emerging contaminant. Because of their prevalence in the environment, they can be transported by snow, rain, and wind. While no national soil clean-up standards currently exist, the Spokane International Airport (SIA) has moved forward with a scientific approach that analyzes the identified PFAS on a molecular level to begin categorizing possible sources, which provides for a holistic approach and better understanding

For over 50 years, the Federal Aviation Administration (FAA) historically mandated all U.S. commercial airports, as part of its Operating Certificate, use aqueous film-forming foam (AFFF) because of its effectiveness in extinguishing – and preventing re ignition – of jet fuel fires. It is now known that two of the main ingredients that make AFFF highly effective in fighting fuel fires – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – are PFAS compounds. The Airport, like others across the country, were not told about the potential environmental risks at the time of federally-mandated use of AFFF.

Spokane International Airport (GEG) was previously known as Geiger Field, a Department of Defense (DoD) facility used during World War II and throughout the Cold War. The historical use of military training and burn pit operations resulted in contamination of groundwater and soil by several different contaminants, from petroleum and heavy metals to solvents used as degreasers in the routine maintenance of military aircraft, which are now being recognized as PFAS-containing materials.

This historical use set the stage for the majority of environmental contaminants and cleanup efforts at the Airport. The site has since been designated a Formerly Used Defense Site (FUDS), with past cleanup efforts conducted under federal and state programs.

For air transportation safety, the Federal Aviation Administration (FAA) has long required all commercial and military airports use aqueous film-forming foam (AFFF) because of its effectiveness in quickly extinguishing jet-fuel fires in order to help save lives. All FAA-mandated AFFF products contained some form of PFAS. In September 2023, the FAA approved the first fluorine free foam (F3) for use by commercial service airports. Following the FAA’s approval, SIA purchased F3 to replace all AFFF containing PFAS. SIA is currently working with the FAA to transition the new F3 into the Airport’s fire-fighting equipment.

In 2017, GEG initiated a voluntary assessment to determine the possible presence of PFAS in the groundwater on Airport property. This effort was initiated after it was discovered that nearby Fairchild Air Force Base had contributed to elevated levels of PFAS in the drinking water wells in the City of Airway Heights. The data were gathered to guide future decision-making following the disclosure of the groundwater contamination caused by military activities near Airport property.

The sources and impacts of PFAS are a challenging and complex issue and part of an evolving national conversation. In 2017, knowledge of these compounds was in its infancy, and there were no federal or state requirements for any organization to test for PFAS.

Testing methodologies and the general understanding of PFAS (per- and polyfluoroalkyl) has significantly advanced since 2017, and we are working with the Ecology the Federal Aviation Administration (FAA), and other state and federal agencies and experts to carefully assess the complex issue of PFAS on the West Plains using a scientific, data-driven process. In fact, the SIA has been proactively working with a team of nationally recognized experts, prior to the DOE’s March 29, 2024 EO, on a scientific, data-driven investigation for the presence of per- and polyfluoroalkyl (PFAS) substances on our property

The United States EPA recognizes that airports are not responsible for the contamination on their property caused by a product they were required to use. The EPA’s Office of Enforcement and Compliance Assurance stated in an August 2023 memorandum: “OECA does not intend to pursue entities where equitable factors do not support CERCLA responsibility, such as farmers, water utilities, airports, or local fire departments, much as OECA exercises CERCLA enforcement discretion in other areas.”

Further, the State of Washington recognizes that the manufacturers and distributors of PFAS chemicals are the parties responsible for the contamination on the West Plains and throughout Washington and the country.

On May 30, 2023, the State of Washington commenced a lawsuit in King County Superior Court against twenty (20) manufacturers of PFAS containing products alleging that these companies have known about dangers of PFAS chemicals for decades and hid that knowledge from governments and the public while continuing to make substantial profits on those products.

In 2019, the Airport purchased a specialized device approved by the FAA, the NoFoam Systems apparatus, to perform the required calibration and testing without the need to discharge AFFF for purposes of meeting FAA regulations requiring SIA to demonstrate that its fire vehicles discharge AFFF in the proper proportion of water to foam, as required by the Airport’s Part 139 operating certificate.

In 2023, the Airport purchased FAA-approved Fluorine-Free Foam (F3) and is currently working with the FAA to transition the new F3 into the Airport’s fire-fighting vehicles to protect the traveling public.  However, further guidance is needed by the FAA regarding the rinsing of the existing fire-fighting vehicles, disposal of the wastewater from rinsing, and disposal of the existing stock of AFFF.