WHAT IS PFAS?
The Environmental Protection Agency (EPA) has identified per- and polyfluoroalkyl substances (PFAS) as a group of synthetic chemicals that have been in use since the 1940s. They are found in a wide array of consumer and industrial products. According to the EPA, PFAS can be found in everyday items such as:
- Some grease-resistant paper, fast food containers/wrappers, microwave popcorn bags, pizza boxes, and candy wrappers
- Nonstick cookware
- Stain resistant coatings used on carpets, upholstery, and other fabrics
- Water resistant clothing
- Cleaning products
- Personal care products (shampoo, dental floss) and cosmetics (nail polish, eye makeup)
- Paints, varnishes, and sealants
- Aqueous Film Forming Foam (AFFF)
Due to their widespread use and persistence in the environment, most people in the United States have been exposed to PFAS. There is evidence that continued exposure above specific levels to certain PFAS may lead to adverse health effects. Concerns lead the EPA to develop an Action Plan with an approach to identifying and understanding PFAS, approaches to addressing current PFAS contamination, and preventing future contamination.
In the Commonwealth of Massachusetts, the Massachusetts Department of Environmental Protection (MassDEP) Bureau of Waste Site Cleanup was tasked with ensuring the cleanup of oil and hazardous material releases pursuant to the Massachusetts Oil and Hazardous Material Release Prevention and Response Act (M.G.L. Chapter 21E). This law was implemented through regulations known as the Massachusetts Contingency Plan (310 CMR 40.0000 et seq. – the MCP). Both M.G.L. c 21E and the MCP require response actions to provide for the protection of harm to health, safety, public welfare, and the environment which may result from releases and/or threats of releases of oil and/or hazardous material (OHM) at disposal sites. See Streamlined MCP Process: Notification-to-Closure
WHAT IS BEING DONE?
MassDEP continues to analyze the use of PFAS in industrial and consumer applications as noted, including stain- and water-resistant coatings for fabrics and carpets, oil-resistant coating for paper products approved for food contact, mining and oil well surfactants, floor polishes, insecticide formulations and AFFF used at airports.
The Federal Aviation Administration (FAA) requires airports to carry chemical agents that are effective in smothering fuels and other onboard liquids such as hydraulic fluids. For decades the industry standard, and only approved chemical, has been AFFF. Currently, AFFF containing PFAS is the only substance approved by the FAA for use in airport emergency responses. The same chemicals that make it effective for fighting fires have been linked to contamination in drinking water. The FAA is currently investigating alternative chemical agents to fight fuel fires. However, to date, none have been approved as PFAS-free. In 2016, MassDEP reached out to airports across the Commonwealth of Massachusetts as they sought to understand the current and historic use of AFFF. In the interim, Cape Cod Gateway Airport has modified its use of AFFF due to the health risks associated with PFAS.
CAPE COD GATEWAY AIRPORT HAS COMPLETED THE FOLLOWING
- 2015: HYA ceased use of AFFF in 2015 for tri-annual exercises and annual testing.
- 2016: Cape Cod Gateway Airport (HYA) was the first airport in Massachusetts to purchase an ecologic unit to test AFFF consistency to meet annual FAA testing requirements without the need to deploy AFFF on the ground for testing. HYA bought this unit before it was approved by FAA as an alternative testing platform to be as proactive as possible.
- 2016: Cape Cod Gateway Airport successfully recovered AFFF used in a 2016 aircraft accident response. All 10 gallons of AFFF concentrate applied at the accident site was captured in an enclosed concrete catch basin, vacuumed out and appropriately disposed of off-site.
- 2016: Cape Cod Gateway Airport (HYA) initiated the process of reporting and analysis following requirements outlined in Massachusetts General Law, and the Massachusetts Contingency Plan (MCP)
Additionally, the Airport continues to coordinate with MassDEP and the Town of Barnstable as they complete ongoing investigations into the impacts of PFAS in soil and groundwater. The purpose of this project is to continue reporting, testing, mitigation, and monitoring as necessary to meet MassDEP Bureau of Waste Site Cleanup reporting requirements as detailed below. Please note that this is a long process and multiple reports are required to meet MCP requirements.
REPORTS BY YEAR
Massachusetts Contingency Plan Documentation
- August 2016: Request for Information (RFI)
- September 2016: Response to August 4, 2016 Request for Information (RFI)
- November 2016: Notice of Responsibility Request (NOR) for Immediate Response Action (IRA)
- December 2016: Immediate Response Action (IRA) Plan
- April 2017: IRA Status Report 1
- October 2017: Request for Information (RFI) Construction Soils
- October 2017: IRA Status Report 2
- November 2017: Phase I Initial Site Investigation and Tier Classification
- April 2019: IRA Status Report 5
- July 2019: Draft Public Involvement Plan (PIP)
- September 2019: Final Public Involvement Plan (PIP)
- October 2019: Draft IRA Modification
- October 2019: IRA Status Report 6
- December 2019: Final IRA Modification
- April 2020: IRA Status Report 7
- October 2020: IRA Status Report 8
- December 2020: Draft Phase II Report
- January 2021: Final Phase II Report
- April 2021: IRA Status Report 9
- October 2021: IRA Status Report 10
- January 2022: Revised Phase II Report
- April 2022: IRA Status Report 11
- April 2022: Draft Phase III Report
- June 2022: Final Phase III Report
- October 2022: IRA Status Report 12
- November 2022: Draft Phase IV Report
August 2020 – October 2020: HYA implemented a mitigation of PFAS-effected soils project by capping the soils and installing monitoring wells to monitor mitigation success. Boundaries of the site where AFFF use has occurred on the 639-acre parcel were identified and accepted by MassDEP. Two locations of approximately 2.25-acres (0.39% of overall airport property) were identified and confirmed with MassDEP after extensive groundwater and soils tests.
Cape Cod Gateway Airport will continue its work with MassDEP to monitor for PFAS in response to historic use and future development.
Groundwater treatment for PFAS is occurring at the Maher wells treatment plant. The Town of Barnstable through the Hyannis Water System will continue to operate the Maher Wells treatment plant and will continue to provide drinking water that meets the regulatory drinking water standards. The MassDEP periodically inspects the Maher Treatment plant under the water supply/drinking water program.
Groundwater monitoring by the Airport will continue to track the PFAS plume migration and document the reduction in concentration over time until regulatory closure is achievable (estimated to be completed by 2029). A majority of the PFAS impacted soil within the two effected areas? have been capped to reduce infiltration and groundwater impacts. The caps are inspected bi-annually to verify their effectiveness.
The actual time for treatment will be based on the collection of analytical samples for laboratory analysis. Groundwater monitoring beyond 2029 may be conducted at the Airport as part of an annual activity and use limitation (AUL) inspection or if plume concentrations have not dropped below the applicable GW-1. Bi-annual reports will continue to be uploaded to MassDEP until a permanent solution can be obtained.