Water Quality
Updates
Updates
April 19, 2024
April 10, 2024
The EPA established final drinking water standards, or (MCLs,) for PFOA, PFOS and four other PFAS compounds. The MCLs for PFOS and PFOA are 4 ppt each. Therefore, the Eligibility Boundry Map was revised to use the 4 ppt PFOS drinking water MCL as the boundary. The parcels included in the revised EB map are eligible for Airport-provided filtration systems.
June 25, 2024
The Jackson Hole PFAS Management Plan is a live document that is updated often with sample results and changes to regulatory standards.
PFAS Frequently Asked Questions are also updated on a regular basis.
Background
PFAS comprise a family of more than 10,000 man-made chemicals used in a wide range of common household, commercial, and industrial products. They are found in commercially available products such as non-stick pans, water repellant fabrics and applications, fast food packaging, Teflon tape and plastic pipe, and even some brands of dental floss. Among those products containing PFAS is Aqueous film-forming foam, (AFFF), a fire extinguishing agent used to fight petroleum-based fires.
AFFF was developed in the 1970s and used at airports for aircraft fire emergencies. AFFF is a highly effective extinguishing agent for flammable liquid fires, such as those caused by jet fuel, due to its ability to form a layer of aqueous film over fuel to extinguish and prevent fire. The effectiveness of this film forming layer is dependent upon PFAS, which has stable chemical and thermal properties that do not easily break down when exposed to water or heat. Due to its effectiveness, the United States military created specification MIL-F-24385F which required that AFFF contain PFAS. In turn, the Federal Aviation Administration (FAA) ordered certificated airports supporting air carrier operations, such as the Jackson Hole Airport, to use MIL-F-24385F-certified AFFF containing PFAS for aircraft fire emergencies. FAA also required that airports periodically test firefighting equipment to ensure its operational capability in the event of an emergency. This required AFFF to be discharged as part of the firefighting equipment testing exercise.
In recent years, PFAS has been determined to have potential health impacts. Studies have found that prolonged exposure to certain PFAS chemicals, including those contained in MIL-F-24385F AFFF, could result in risks to human health. Therefore, although AFFF containing PFAS has had a positive role in saving lives and FAA required it be used by U.S. airports in the event of an aircraft fire emergency, there is a concern that releases to the environment infiltrated groundwater and potentially affected the health of those that have prolonged exposure.
As concerns regarding PFAS grew, Congress mandated as part of the 2018 FAA Reauthorization Act that the FAA cease requiring airports to use AFFF containing PFAS by October 4, 2021. This required the FAA to test different PFAS-free firefighting foam products to find an effective alternative. In January 2023, the United States Department of Defense (DoD) released a military specification (MIL-SPEC) MIL-PRF-32725 that provided a performance specification for fluorine-free foam (F3) fire extinguishing agents which was used by the FAA as part of their testing. In September 2023, the DoD Qualified Products Database (QPD) certified the first F3 firefighting extinguishing agent liquid concentrate to meet the performance requirements of the new military specification (MIL-PRF-32725). The first product certified for use was Solberg’s 3 percent MIL-SPEC Synthetic Fluorine-Free Foam. Shortly after the QPD was published, the FAA published CertAlert 23-07, which authorized Part 139 airports to be able to use certified F3 products listed on the QPD to meet fire extinguishing agent requirements.
In October of 2023, the Jackson Hole Airport received the approved F3 product, which replaced AFFF. The Jackson Hole Airport is one of the first airports in the United States to transition to F3. This continues a longstanding effort by the Airport to address AFFF containing PFAS to fight fuel-based aircraft fires. For the full Press Release on the Airport’s transition to F3, please click here.
Actions Taken at JH Airport Regarding AFFF and F3
In October 2023, the FAA published CertAlert 23-07, which authorized Part 139 airports to be able to use certified F3 products to meet fire extinguishing agent requirements. Immediately after FAA’s October 2023 authorization to approve use of F3 agent, Jackson Hole Airport eliminated the use of AFFF containing PFAS by transitioning to use of only F3 in emergency cases.
While there was legacy use of AFFF with PFAS at Jackson Hole Airport, in 2020 and prior to the transition from AFFF to F3 agent, the Airport implemented measures to protectively manage any releases which were necessary. Under these measures, PFAS was to only be discharged when, at the discretion of the emergency responders, necessary to protect human life and property preservation. The following sections discuss measures implemented to limit, and ultimately eliminate, use of AFFF at the Airport.
Eliminating Discharges of Foam for Training
FAA requires periodic training for firefighters at commercial service airports to prevent or extinguish fuel-based fires in the event of an emergency. Historically, this training has been conducted at an FAA-approved training site located outside Teton County, and only occasionally at the Airport itself. As the possible harmful effects of PFAS in AFFF have become known, training with AFFF on the Airport has ceased. No further training using AFFF will occur on the airfield.
Eliminating Discharges for Equipment Calibration
The FAA also requires that commercial service airports annually calibrate equipment used to dispense AFFF to ensure proper flow in the event of a life-safety emergency. Prior to January 2019, such calibration required a discharge of AFFF from the airport’s firefighting equipment. When FAA Cert-Alert 19-01 was published in January 2019 permitting the use of certified closed-loop, or “no foam” testing systems to calibrate firefighting equipment without discharging AFFF, the Airport purchased and continues to use a “no foam” system for all semi-annual testing of equipment.
Transitioning from a C8 to a C6 Foam
In 2000, 3M voluntarily initiated a phase-out of all C8 PFOS and PFOA production, and associated AFFF products. This phaseout was completed in 2002. The EPA’s 2010/2015 PFOA Stewardship Program focused on reducing C8 PFOA content in products and PFOA emissions, because data show that shorter chain C6 compounds have a lower potential for toxicity and bioaccumulation. The Airport took the step of transitioning from C8 to C6 foam in 2009. Only AFFF containing shorter chain perfluorinated chemicals since that time was used on the airfield, if necessary.
Regulatory Overview
Drinking Water Standards
EPA has regulatory authority to promulgate drinking water standards, or Maximum Contaminant Levels (MCLs). The Wyoming Department of Environmental Quality (WDEQ) adopted the national, federally promulgated MCLs into state regulations and is proceeding with implementation of the regulations. Since 2016, EPA has been researching a small subset of PFAS to determine appropriate levels in drinking water for the protection of human health. In April 2024, EPA finalized drinking water standards for six compounds in PFAS.
A timeline for EPA issuance of drinking water guidelines and standards follows:
- May 2016 – EPA established a drinking water lifetime health advisory (LHA) [“2016 LHA” hereinafter] of 70 parts per trillion (ppt) for total PFOA and PFOS (two PFAS compounds found in AFFF) in drinking water based on the EPA’s assessment of peer-reviewed science.
- June 2022 – On June 15, 2022, EPA released a revised and unexpectedly low LHA which reduced recommended levels from a combined total of 70 ppt, to 0.004 ppt for PFOA and 0.02 ppt for PFOS [“2022 LHA” hereinafter]. This is several thousand times lower than 70 ppt, and below the level which can even be detected or measured by current technology. The LHA was non-enforceable and non-regulatory and was meant to provide technical information to state agencies and other public health officials on health effects, analytical methodologies, and treatment technologies associated with drinking water.
[1] The lifetime health advisory (LHA) is derived for an adult weighing 70 kg (154 pounds) and assumes daily exposure over a period of an average lifetime (approximately 70 years). For PFAS, one would have to drink two liters (8.5 cups) of water per day from the same unfiltered tap with PFAS concentrations above 70 ppt for a total of 70 years. A ppt, or part per trillion, is an extremely small measurement unit. In units of time, it would be 1 second in 32,000 years. Even the original lifetime health advisory of 70 parts per trillion equates to approximately 3.5 droplets of water in an Olympic size swimming pool (660,000 gallons).
- November 2022 – EPA issued Regional Screening Levels (RSLs, EPA 2022a) for six PFAS compounds of which PFOS was 40 ppt and PFOA was 60 ppt. For screening purposes, the EPA RSLs were used for water results from groundwater monitoring wells. 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.
- March 2023 – EPA proposed to adopt enforceable Maximum Concentration Limits (MCLs) for PFOS and PFOA at 4 ppt each.
- April 26, 2024 – EPA established final drinking water standards, or MCLs, for PFOA, PFOS and four other PFAS compounds, in the PFAS National Primary Drinking Water Regulation Rulemaking. The MCLs for PFOS and PFOA are 4 ppt each. Over the next five years, drinking water providers will be required to meet these levels when supplying drinking water to populations.
The individual MCLs for PFOA and PFOS, at 4 ppt each, represent a significant reduction as compared to EPA’s LHA issued in 2016 of 70 ppt total PFOS and PFOA. Fortunately, EPA signaled its intent to establish these MCLs in prior publications over several years, which enabled the Airport to proactively make necessary adjustments to the PFAS Management Plan.
Designation as Hazardous Substances
On April 19, 2024, EPA issued two key documents pertaining to PFAS: Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances, and PFAS Enforcement Discretion and Settlement Policy under CERCLA.
This action was consistent with the Biden Administration’s PFAS Roadmap, released in 2021, which identified remediating PFAS and holding polluters accountable, including through designation under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act), as key measures to address PFAS. EPA explained in the announcement published in the Federal Register that designating PFOA and PFOS as hazardous substances will allow the federal government to utilize CERCLA to address PFAS contamination. This includes a new reporting obligation for significant releases, enforcement authority to require removal and remediation, and allocation of liability for PFAS releases among responsible parties. However, as detailed below, the Biden Administration later refined its views to acknowledge that enforcement under CERCLA should focus on parties that played a significant role in PFAS releases to the environment, like manufacturers, and not on parties that perform a public service role, like airports.
Commentors on the proposed designation specifically requested that EPA exclude the use of PFOA and PFOS at airports. EPA declined to do so in part on the basis that such releases also posed a risk of adverse health effects, that an exception would require Congressional action, and that EPA has discretion to prioritize sites for removal, remediation and allocation of liability. On this last point, EPA explained in the companion policy statement that it would not pursue, based on equitable factors, enforcement against airports and similar entities:
EPA does not intend to pursue entities where equitable factors do not support seeking response actions or costs under CERCLA, including, but not limited to, community water systems and publicly owned treatment works, municipal separate storm sewer systems, publicly owned/operated municipal solid waste landfills, publicly owned airports and local fire departments, and farms where biosolids are applied to the land. For these same parties, EPA can use CERCLA statutory authorities when appropriate to enter into settlements that provide contribution protection from third party claims for matters addressed in the settlement.
The Airport will remain vigilant to stay abreast of scientific and regulatory developments to facilitate appropriate investigation, mitigation, and management of the drinking water quality on and off-airport property.
[1] USEPA Assistant Administrator for Enforcement and Compliance Assurance, PFAS Enforcement Discretion and Settlement Policy Under CERCLA, p.2 (April 19, 2024).
Initial Investigations/Sampling
Airfield – Initial Testing of On-Airport Wells
In February 2020 sampling was conducted at 13 wells on the airfield to assess the potential for PFAS to exist in groundwater. This testing event, the results for which were received in March 2020, identified the presence of PFAS in certain groundwater wells on the airfield. Of the 13 wells tested, PFAS was detected in five wells. Of these, two wells contained concentrations higher than EPA’s 2016 lifetime health advisory (LHA) (70 ppt). Reported concentrations of PFOS and PFOA in these two wells were 128.5 ppt and 382 ppt. All five wells in which PFAS was detected are monitoring wells, and none are used for drinking water.
Based on the results of this initial sampling, two additional wells were tested in late March 2020. One is on-airfield and used in connection with drinking water for the Control Tower. No PFAS was detected in this on-airport well. The other is a domestic water well located near the airfield and directly downgradient from the on-airfield well which yielded the highest PFAS readings in the first round of testing. PFAS was detected in this off-airfield well at 60 ppt, which was below the 2016 LHA (70 ppt).
[1] USEPA Assistant Administrator for Enforcement and Compliance Assurance, PFAS Enforcement Discretion and Settlement Policy Under CERCLA, p.2 (April 19, 2024).
Residential – Initial Testing of Off-Airport Wells
In light of the airfield results and understanding that fire-fighting foam containing PFAS was 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.
Phase 1 – Residential Sampling
In light of the airfield results, the Airport initiated Phase 1 Voluntary Residential Well Testing on private residential wells immediately adjacent to and downgradient of the Airport to determine if and to what extent PFAS was present. Initially, 32 residences volunteered to have their water tested in June 2020. Of these wells, 31 came back as either “or were below the 2016 LHA of 70 ppt. Only one well tested above the 2016 LHA advisory at 70.3 ppt. Since the time of the original testing, 14 additional homes in the Phase 1 area volunteered for the program, and additional testing occurred. Results for the additional homes came back as either “non-detect” or were below the 2016 LHA. Phase 1 testing results can be found here.
While only one home in the Phase 1 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 1 testing boundary.
Phase 2 – Residential Sampling
Based on results from the Phase 1 effort, the Airport moved forward with Phase 2 Testing. Using scientific criteria (i.e., Phase 1 results, groundwater flow direction, USGS reports), domestic 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 location. Results of the Phase 2 Testing event were received in late September and October of 2020. Of the 18 samples taken, 12 results were non-detect and 6 resulted in detectable levels, which were below the 2016 70 ppt LHA. Results for Phase 2 testing can be found here.
Phase 3 – Residential Sampling
To further investigate to what extent PFAS has migrated off-airport, the Board initiated a Phase 3 testing effort. 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 sampling effort occurred in January and early February 2021. The 74 samples in the Phase 3 area resulted in 62 non-detects and 12 with values below the 2016 LHA of 70 ppt. Results for Phase 3 testing can be found here.
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.
On-Airport Soil Sampling
Prior to the runway replacement project which the Airport undertook in the spring of 2022, the Airport conducted an on-site soil investigation to determine the extent to which PFAS is found in airfield soils and to identify any potential groundwater impacts. A soil sampling and analytical investigation is usually part of a comprehensive PFAS Management Plan. At the Jackson Hole Airport, the investigation addressed two components related to sampling areas. The first was an investigation of source areas in which AFFF had been historically discharged on the airfield for purposes of testing, training, or response to emergency incidents. The second component was necessitated by the airfield construction project which involved excavating soils, pavement, and associated subbase materials under and adjacent to the runway and taxiway. Some of these materials could have contained concentrations of PFAS. If not properly mitigated, their disturbance and relocation could have caused the spread of PFAS around the airfield and/or an acceleration of PFAS leaching into groundwater. Therefore, the investigation was conducted to better understand the concentration and extent of PFAS in the soils and within the pavement and associated subbase to be excavated for the runway reconstruction project. Based upon this investigation, it was determined that the runway project did not need to plan to minimize any excavation-related PFAS risks.
The soil sampling and analytical investigation was conducted in December 2020. The 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 a grab groundwater sample was taken.
To evaluate the sampling results, the Airport used screening levels made available 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 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 the airfield, 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 were utilized in application of best practices which were employed during the Airport’s runway replacement project in the spring of 2022.
Eligibility Boundary for Airport-Provided Whole House Filtration Systems
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, were 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 the Eligibility Boundry (“EB”) to 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 Jackson Hole Airport Board expanded the Eligibility Boundary area for whole-house filtration system installations. from the previously Board-announced 10 ppt level to any detection of PFOS and PFOA within the EB.
In April 2024, the EB map was revised again to use the 4ppt Drinking water MCL as the boundary. The Parcels included in t
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, the main replacement filters for the systems for the foreseeable future for each system installed.
If a new residence is constructed on an eligible parcel, it may be eligible to 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 EB will be eligible for a filter system. 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 filtration system, please contact Meg Jenkins by emailing megan.jenkins@jhairport.org or calling (307) 699-4387.
[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 is committed to continued monitoring of residential wells and on-Airport airfield monitoring wells. The purpose of continued monitoring is to evaluate the possible effect of seasonality or duration in time on PFAS concentrations in groundwater. Both on- and off-airport wells will be monitored twice a year for the foreseeable future to account for seasonal variability in groundwater conditions. Testing events will occur in low water season (winter/spring) and in high water season (summer/fall).
Residential Continued Monitoring – Timeline and Results
August 2021: 19 domestic water wells (that had been tested in previous sampling events) were re-tested to evaluate potential trends in concentrations. Results for the 19 samples ranged from non-detect to 46ppt, all of which were well below the 2016 LHA of 70ppt. Some results were higher and some lower than previous testing.
February 2022: 18 domestic water wells that had previously been tested were re-tested. Results for all 18 samples were well below the 2016 LHA. Some results were higher and some lower than previous testing.
August 2022: 20 domestic water wells were re-tested. Results were generally consistent with prior testing events, but some wells showed slight increases in PFOA or PFOS.
February 2023: 22 domestic water wells were re-tested. Results were generally consistent with the previous testing events. A comparison of these results with the 2023 proposed MCLs for PFOS and PFOA indicated the following:
- One PFOA result exceeded 4 ppt with a value of 5.5 ppt
- Thirteen PFOS results exceeded 4 ppt with a maximum value of 46 ppt
August 2023: 22 domestic water wells were re-tested. Results were generally consistent with the previous testing events, although concentrations were typically slightly lower. A comparison of these results with the 2023 proposed MCLs for PFOS and PFOA (e.g., 4 ppt individually for PFOA and PFOS) indicated the following:
- No PFOA results exceeded 4 ppt.
- Fourteen PFOS results exceeded 4 ppt with a maximum value of 39 ppt.
February 2024: 21 domestic water wells were re-tested. Results were generally consistent with the previous testing events. A comparison of these results with the 2023 proposed MCLs for PFOS and PFOA (e.g., 4 ppt individually for PFOA and PFOS) indicated the following:
- Two PFOA results exceeded 4 ppt with a maximum value of 5 ppt.
- Thirteen PFOS results exceeded 4 ppt with a maximum value of 46 ppt.
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. Also, a table of the cumulative results can be found here. The Airport will continue to re-test these domestic wells for the foreseeable future, in both wet and dry seasons, for further analysis.
On-Airport Continued Monitoring – Timeline & Results
The on-airfield wells in which PFAS was detected are not drinking water wells. Accordingly, the methodology was revised to reflect that these results are not compared to EPA’s LHA for drinking water (because these are not domestic drinking water wells), but rather to the EPA RSLs.
May 2021: The Airport conducted a round of testing of on-airfield monitoring wells where water was present. This sampling event was conducted for two principal purposes. The first was to test for possible variability in PFAS concentrations as a result of seasonal differences in groundwater levels. The second was to conduct “slug tests” at wells to evaluate hydraulic connectivity. The results of these tests may be utilized for future engineering design purposes. Test results showed that PFAS concentrations in some on-airfield wells decreased from February 2020 levels, concentrations in other wells increased somewhat, and some remained about the same. The differences in concentrations may be partially due to the time of year a sample was collected and/or the sampling methodology.
November 2021: The Airport conducted a round of testing from nine of the on-airfield monitoring wells and the Control Tower drinking water well. The groundwater monitoring results were generally similar to those from previous sampling events with the exception of lower PFAS concentrations in wells JH-2 and JH-3 when compared to February 2020 results. The Control Tower drinking water well resulted in non-detect.
Spring and Fall 2022: The Airport did not conduct on-airfield testing of wells because access to the wells was obstructed by the runway reconstruction project.
May/June 2023: The Airport conducted a round of testing from nine of the on-airfield monitoring wells and the Control Tower drinking water well. Levels decreased such that only PFOS concentrations detected in one on-airfield monitoring well (JH-1.5) was above the 2022 RSL (40 ppt). PFOA detected concentrations in all 10 wells were not above its RSL (60 ppt).
November 2023: The Airport conducted a round of testing from eight of the on-airfield monitoring wells and the Control Tower drinking water well. PFOS concentrations were slightly higher in some of the monitoring wells when compared with previous sampling events, which may be a result of the lower groundwater elevations. PFOS detected concentrations in three wells were above the 2022 RSL (40 ppt); while PFOA detected concentrations in all 8 wells were not above the 2022 RSL (60 ppt). A figure with the cumulative data from on-airfield well sampling events and a cumulative data table can be found here.
The Airport will continue to re-test wells for the foreseeable future, both in wet and dry seasons, for further analysis.
The Airport is continuing to evaluate next steps in the investigation process to better refine its understanding of the PFAS issue and updates to this page will continue as new information and continued monitoring results are available.
PFAS Frequently Asked Questions
Updated – December 2023
Note that current FAQs may supersede archived FAQ responses.
What is PFAS? PFAS (Perfluoroalkyl substances) are “forever chemicals” designed to be resistant to biological, chemical, and thermal breakdown. It is found in many products, such as non-stick pans, water repellant fabrics and applications, microwave popcorn, pizza boxes and even some brands of dental floss. It is also found in Aqueous Film Forming Foam (AFFF) which was previously mandated for use by some fire departments and at commercial service airports in the United States. Because PFAS is used in so many applications, most Americans have some level of PFAS in their bloodstreams.
PFAS comprises more than 10,000 individual man-made substances. Of these, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) are two of the substances most commonly associated with AFFF.
Why is PFAS a problem? Several studies have linked PFAS exposure to health issues and more studies are underway to evaluate potential health effects. PFAS have not been classified by the USEPA as a hazardous substance or a carcinogen. However, in March 2023, the USEPA proposed to adopt enforceable Maximum Concentration Limits (MCLs) for PFOS and PFOA at 4 ppt each. Once the MCLs are finalized (anticipated 2024), public water supply systems will be required to meet the limits within three years.
Why is PFAS used at Airports? From the 1970s until September 2023, the Federal Aviation Administration (FAA) required all fire departments at airports served by airlines to use AFFF containing PFAS to extinguish aircraft fires. AFFF with PFAS was required by the FAA because at the time it was the only fire extinguishing agent that was stable and did not react with other chemicals, including jet fuel. AFFF extinguished fires by sequestering fuel sources from oxygen, thus preventing them from reignition.
With an understanding of the environmental and human health considerations of PFAS, an industry effort began in the late 2010s to find a fire extinguishing agent that could have the performance of AFFF but not contain PFAS. After extensive testing of potential firefighting foams by the FAA, in January 2023 the FAA announced that fluorine-free firefighting foams which do not contain PFAS could be used at airports served by airlines. It was not until September 2023 that the first fluorine-free firefighting foam was certified by the FAA for use at airports. Presently, airports have the option to use AFFF containing PFAS or fluorine-free firefighting foams to meet FAA requirements.
What is being done regarding AFFF use at airports nationally? In December 2022, Congress directed the FAA to develop a plan for airports to transition from using AFFF to a replacement firefighting foam (fluorine-free foam or F3) that did not contain PFAS. Even before this direction, in November 2022, the Jackson Hole Airport (“JAC”) had proactively developed a Fluorine-free Foam Transition Plan that outlined steps to promptly procure and transition to the use of F3, when it became available. On May 8, 2023, the FAA released the Aircraft Firefighting Foam Transition Plan which provided high-level guidance on concepts that airports should consider in developing a transition plan but did not include details on specific technical elements. JAC’s existing Plan was compatible with FAA’s recommended approach.
In January 2023, after extensive testing, the FAA announced that F3 could be used as a fire-extinguishing agent at airports served by airlines once products had been certified. In September 2023, the FAA certified the first F3 that could be used at airports. In anticipation of this announcement, JAC prepared to transition its fleet of firefighting vehicles for use of this new extinguishing agent. Once the announcement occurred in September 2023, JAC acquired the new certified F3 and completed its transition to the PFAS-free fire extinguishing agent in October 2023. Nationwide, airports now have the option to use AFFF containing PFAS or F3 to meet FAA requirements.
What has been done to minimize PFAS use at JAC? When JAC used AFFF, its fire department updated training practices several years ago to eliminate active sprays of AFFF. This included periodic tests required by the FAA to determine the product’s usefulness in which AFFF was contained during these tests and not released into the environment. JAC’s procedures after an emergency event were also revised to contain the spread of AFFF.
Once a fluorine-free foam (F3) that did not contain PFAS was certified for use at airports by the FAA in September 2023, JAC immediately acquired this product and transitioned its fleet of firefighting emergency response vehicles. The completion of this transition occurred in October 2023; thus, JAC no longer uses a fire extinguishing agent containing PFAS.
What more is being done to investigate PFAS at JAC? JAC works with environmental consultants who are experts in PFAS to determine where PFAS exists on and off the JAC airfield as a result of prior use of AFFF. We learned that PFAS does exist in some monitoring wells on JAC’s airfield and in domestic wells in surrounding areas.
JAC continues to work with the consultants to monitor both on- and off-airport water wells and to determine next steps for PFAS mitigation and remediation. The Jackson Hole Airport Board (Board) has committed to semi-annual (approximately February and August) testing for selected residences to monitor the plume’s migration off airport, in addition to semi-annual well testing on the JAC airfield.
Does my current drinking water filtration system work for PFAS? Many household filters, such as sand and granular activated carbon (GAC), are only partially effective at removing PFAS from drinking water.
Will the Board purchase a water filtration system for my domestic water well? JAC tested and found PFAS in some domestic water wells off the JAC airfield. In an exercise of caution the Board offered to purchase, upon request, point-of-entry treatment (POET) water filtration systems for all homes located with a defined Eligibility Boundary.
The Eligibility Boundary (EB), which has expanded over time based on changes in EPA advisories, defines an area where it is estimated that any concentration of PFOS or PFOA would be detected in groundwater, or in which PFOS and PFOA were detected. Residents whose parcels fall within the EB, or within an area in which PFAS is estimated to occur or has been detected, 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 continue to 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 and to replace filters as indicated by system status lights. If a single residence requires more than one filter due to its size, additional system(s) will be provided and installed.
Will JAC continue to monitor any wells that have already been tested? Yes. JAC will continue to test a scientifically selected number of water wells both on and off the JAC airfield to better understand conditions with regard to seasonality and to track any changes over time.
What is a plume? Where is it and is it moving? A plume is a pattern of contaminant concentrations in groundwater that moves in the direction of the groundwater flow. Generally speaking, a plume is typically narrowest and most concentrated at the source of the contaminants. Concentrations may decrease and vary as it dissipates away from the source.
USGS, in conjunction with JAC, installed a series of groundwater wells on the JAC airfield in the early 2000s to evaluate water quality within the Snake River Aquifer. In February 2020, JAC voluntarily collected groundwater samples from these wells on airfield. These samples were tested for PFAS compounds, which were detected in several wells. Note that none of these on-airfield wells are drinking water wells.
A voluntary residential well testing program was started in April 2020 with domestic well water samples collected and analyzed for PFAS compounds. Three phases of voluntary residential testing were performed between April 2020 and February 2021. The results of the airfield well data and the residential well data allowed the scientists to plot the PFAS plume and determine areas (outside the EB) which have shown no detection of PFAS. The continued residential monitoring program began in August 2021. Its purposes are to (1) collect domestic well water samples, analyze them for PFAS, and compare the results to previous data; and (2) monitor the concentrations within the plume and along the non-detect EB boundary.
The PFAS plume is traveling in a southwesterly direction along a relatively fast-moving groundwater channel and appears to have retained its shape to date. As the groundwater moves through the source area, it picks up PFAS and transports it along the channel as it flows downstream. The plume diffuses as it encounters pathways with less resistance. In addition, groundwater flows and water depths vary with the seasons, which can affect not only the speed of groundwater flow but also how and where it disperses. As a result, we see concentrations vary at different locations in the plume with time, as well as distance from the source area, in ways that are difficult to predict.
JAC used FAA-mandated AFFF products historically for training and incident responses. The FAA restricted use of certain AFFF products at airports in 2019 and JAC complied by switching AFFF products. Once the FAA certified a fluorine-free firefighting foam for use at airports serving airlines in September 2023, JAC immediately acquired the product and completed the transition of its firefighting vehicle fleet in October 2023. As such, fire extinguishing agents containing PFAS are no longer used at JAC.
Continued monitoring of domestic water wells is showing decreases in results – why is this the case? The results at any well in the plume area depend not only upon the amount of PFAS remaining in the source area, but also the amount of groundwater flowing through the area and the pathways it is taking at any given time. Because groundwater is replenished by rainfall and snowmelt, the depth, flow rate, and path of groundwater are often affected by seasonal hydrology. Variability in concentrations is inherent in groundwater investigations and the long-term goal is a trend of decreasing concentrations. To date, the overall trend shows a decrease in the residential testing area.
Will the Airport continue to provide replacement filters? Upon request, the Airport currently provides replacement filters at no cost to residents that have had filtration systems installed through the airport program.
What if I purchase a home located within the Eligibility Boundary? Call Megan Jenkins, Communications Manager of the Jackson Hole Airport, at 307-699-4387.
Does seasonality play a major role in the fluctuating results? Because groundwater is replenished by rainfall and snowmelt, the depth, flow rate, and path of groundwater are often affected by seasonal hydrology. At this time, there has not been enough historical data collected to state definitively whether seasonality is a factor in fluctuating monitoring results. JAC will continue to sample wells and collect data with the goal of better understanding trends.
What does it mean if my test result is a “J” value or reading? See “Understanding Lab Results”.
Is the plume moving enough that the Eligibility Boundary (EB) will need to be expanded? JAC continues to compile data both inside and outside the EB. A new EB will be created if and as needed based upon the data. Residents will be notified if there are changes in the EB.
What are USEPA Regulations regarding PFAS? The US EPA’s interim lifetime health advisory (LHA) for drinking water was established in 2016 at 70 parts per trillion (ppt) for either chemical or the sum of the two. An LHA is based upon the following:
- An adult
- Weighing 70 kg (154 pounds)
- Drinking 2 liters/day (8.5 cups)
- From only the unfiltered house tap (no other water sources)
- For 70 years
- Concentration of PFAS is greater than the LHA (70 ppt combined PFOS and PFOA).
So, an average-size adult would need to drink at least 8 cups of water per day from the same unfiltered tap with PFAS concentrations above 70 ppt for a total of 70 years. A ppt, or part per trillion, is an extremely small measurement unit. In units of time, it would be 1 second in 32,000 years. The original lifetime health advisory of 70 parts per trillion equates to approximately 3.5 droplets of water in an Olympic size swimming pool (660,000 gallons). When these substances were found in groundwater near the JAC airfield, in an exercise of caution the Board offered to fund the installation of whole-house water filters where detection was at a 10 ppt or less – far more stringent than the 70 ppt LHA.
In June 2022, US EPA issued revised LHAs of 0.004 ppt for PFOA and 0.02 ppt for PFOS. These are 1,000 and 100 times, respectively, lower than the ability of current laboratory methods to detect. The Board responded by expanding its filter Eligibility Boundary to encompass all areas near the JAC airfield in which any amount of PFOA or PFOS were expected to be present.
It’s important to understand that these interim LHA concentrations are based on risk assessment analyses of toxicological studies. They are advisory concentrations and not enforceable requirements. As such, they do not reflect any consideration of feasibility or practicality relative to measurement, treatment or regulatory requirements and compliance.
In November 2022 and May 2023, USEPA issued Regional Screening Levels [(RSLs) for six PFAS compounds and an additional two PFAS compounds, respectively. For screening purposes until the MCLs are promulgated, the USEPA RSLs are used for on-airport water results from groundwater monitoring wells and domestic water wells. (Control Tower well is only drinking water well sampled as a part of semiannual monitoring activities). The RSLs are for a target hazard quotient (THQ) of 1.0. RSLs are not cleanup standards and are calculated using conservative exposure assumptions and available toxicity data.
In March 2023, the US EPA proposed to adopt enforceable Maximum Concentration Limits (MCLs) for PFOS and PFOA at 4 ppt each. Commercial laboratories using the current analytical methods can detect these compounds at 4 ppt. Certain treatment systems (including granulated activated carbon filters such as those funded by the Board) are already capable of removal of PFOS/PFOA at these proposed levels. If adopted, these proposed MCLs will supersede use of LHAs for comparing data collected from drinking water sources, such as the residential water wells.
EPA’s timeline for finalizing these MCLs into federally enforceable levels is as early as end of 2023 but could be as late as Fall 2024. Once the MCLs are finalized, public water supply systems will be required to meet the limits within 3 years.
JAC continues to monitor regulatory developments regarding PFAS, and will adapt testing, evaluation, and mitigation approaches accordingly. Currently, that includes using the concentration at which these chemicals can be detected in the laboratory as our threshold for mitigation via whole house water filtration systems on residential wells.
Why is the airport only talking about PFOA and PFOS when other PFAS substances have been detected in our water wells? PFOA and PFOS are the primary PFAS substances associated with AFFF formulations. They are also the two most studied PFAS substances amongst the 10,000+ PFAS class of substances.
Are there advisory levels for other PFAS chemicals? USEPA has not yet identified lifetime health advisory levels for several other PFAS substances in drinking water. Research studies are currently underway for dozens of PFAS substances, but it takes time for this research to generate enough data for USEPA to propose health advisories.
Do the filtration systems provided by JAC remove the PFAS substances that have been found in the water? The selected filtration systems are certified by NSF/ANSI (National Sanitation Foundation/American National Standards Institute) Standard 53 to remove PFOA and PFOS from water. PFOA or PFOS have not been detected in samples of water taken post-filtration system in off-airport wells, which is an indication that these filtration systems are indeed working. To date, NSF has certifications for only PFOA and PFOS. Other PFAS substances are probably removed using the same filtration system, but only PFOA and PFOS has thus far been certified for removal.
Why hasn’t USEPA or WDEQ set limits on all PFAS substances in drinking water? With a class of over 10,000+ substances, USEPA must select the substances which most likely represent a concern to human health and the environment. PFOA and PFOS were the first substances selected for evaluation and proposed health advisories in drinking water supplies. US EPA continues to add PFAS substances to its Unregulated Contaminant Monitoring Rule (UCMR), which can lead to setting drinking water standards. There are currently 35 PFAS substances in the UCMR process.
From where did the other PFAS substances found in the groundwater come? These other PFAS substances detected in groundwater samples collected during JAC investigations might have come from historic use of AFFF at JAC. They may be impurities introduced during the manufacture of AFFF formulations or they may be degradation (breakdown) substances from chemical, physical and biological processes in the environment. These may also have come from other sources. For instance, household plumbing may contain Teflon based plastics in the pipe, tape, or joint compounds, which contain PFAS.
What’s next? In determining our next steps locally, JAC remains in contact with Wyoming DEQ, the Teton County Health Department, the FAA and other agencies to stay up to date with the latest information regarding changes to regulations.
JAC’s number one priority is the safety of our operations – both for passengers and the surrounding community. Along with safety, JAC also makes environmental stewardship a vital part of everything The Airport does. The transition to F3 allows JAC to both enhance the safety of our passengers while limiting environmental impacts.
Additional Resources
JH Airport – Transition to Fluorine-Free Foam
Press Release – October 26, 2023
On-Airport Water Sampling
Off- Airport Water Sampling
Understanding Lab Results – “J” Readings
Continued Monitoring
Maps
Continued Monitoring Map – Depicts ranges of results from off-airport locations
Airport Water Quality Resource
Other Resources
EPA Drinking Water Advisories FAQs
For questions, please email megan.jenkins@jhairport.org or call (307) 699-4387.
