The Airport Maintenance and Rescue (AMR) fire-fighting unit at Oakland County International Airport (OCIA) procured its first foam truck equipped with 400 gallons of 3M Lightwater 3% Aqueous Film Forming Foam (AFFF).
Oakland County acquired OCIA from the City of Pontiac. From 1967 to present, the AMR at OCIA has utilized AFFF only to extinguish fires. The AMR trains using only water. It also tests and cleans out its nozzles once a year east of the airport maintenance and fire building, as required by the Federal Aviation Administration (FAA).
The AMR at OCIA received a new Oshkosh T-1500 aircraft rescue and fire fighting vehicle equipped with 200 gallons of 3M Lightwater 3% AFFF.
AMR at OCIA responded to aircraft accident in middle of northern runway where it employed AFFF.
FAA issued Part 139 regulation requiring annual testing of AFFF.
The AMR at OCIA purchased a second Oshkosh T-1500(R-1) aircraft rescue and fire fighting vehicle equipped with 200 gallons of Ansulute 3% AFFF.
AMR at OCIA applied AFFF to aircraft accident west of the northern runway.
AMR at OCIA used AFFF on aircraft engine fire near Pentastar Aviation ramp.
AMR at OCIA dispatched to aircraft hangar fire in northeast corner of the airport where it utilized AFFF.
AMR at OCIA responded to aircraft accident east of the northern runway where it extinguished the fire with AFFF.
AMR at OCIA deployed to Aircraft Runup Enclosure to put out engine fire with AFFF.
As part of the FAA Reauthorization Act, the U.S. Congress directed the Federal Aviation Administration to cease requiring airports to use AFFF that contains PFAS by October of 2021. As of June 2021, FAA had not yet taken public action on the directive and continued to require airports to use AFFF that include PFAS.
EGLE sent a certified letter to OCIA stating that EGLE had information that OCIA may have used PFAS-containing fire-fighting foam as a part of routine fire protection and safety practices and requested information about the historic use of AFFF containing PFAS at OCIA. The airport is among 20 Michigan commercial airports that received similar letters.
OCIA responded to EGLE's request with information about the airport's use of AFFF containing PFAS and that it has never used foam for training purposes but only applied for fire protection. OCIA's practice is to train with water only. FAA Part 139 has required annual testing on foam since 2005.
EGLE notified OCIA via certified mail that due to historical use of PFAS at OCIA, concentrations may be present in groundwater at levels above current criteria under Part 201 of the Michigan Natural Resources and Environmental Protection Act. EGLE requested OCIA to submit a workplan to investigate potential PFAS contamination on and off-site and to assess potential for impact to drinking water wells on and off-site. An environmental consultant must be contracted to meet the requirements of Part 201.
OCIA submitted purchase request to E-ONE (a manufacturer of aircraft rescue and fire-fighting equipment and vehicles) for AFFF test cart and equipment as proposed with reimbursement from Michigan Department of Transportation. The AFFF test cart will allow the AMR at OCIA to test and clean its AFFF nozzles once a year as required by the FAA without discharging any foam into groundwater.
EGLE notified OCIA that based on historical use of AFFF containing PFAS, the airport must perform sampling at each stormwater discharge point and submit a Short-Term Storm Water Characterization Study.
OCIA and ASTi Environmental submit a Groundwater Sampling Work Plan to EGLE in accordance with EGLE's notice of August 2019.
EGLE expressed no objections to the work plan except a request for a monitoring well in the northwest section of the airport and a monitoring well at the location where nozzles were tested.
E-One test cart delivered.
AMR at OCIA accidentally released AFFF west of the airport maintenance and fire building while training to utilize test cart for first time. Approximately 40-50 gallons of Chemguard AFFF liquid diluted to 3% were released into a storm sewer.
OCIA applied for grant from Michigan PFAS Action Response Team (MPART) for funding of work plan developed to investigate groundwater for PFAS at OCIA and conduct a Short-Term Storm Water Characterization Study. Grant submitted to Board of Commissioners for approval.
EGLE provided additional feedback on work plan recommending changes which OCIA and ASTi incorporated into work plan and resubmitted to EGLE.
OCIA received Michigan Department of Transportation (MDOT) grant of $100,000 to conduct work plan with testing to begin in Spring 2021 so runway closures may be coordinated with installation of permanent wells.
ASTi Environmental submitted cost proposal to complete the work plan as approved by EGLE.
OCIA amended ASTi Environmental contract to include funds required for the cost proposal to complete the work plan.
Oakland County Water Resources Commissioner's Office held teleconference meeting with OCIA about detection of PFAS by the Clinton River Water Resources Recovery Facility (CRWRRF) in nearby wastewater discharges to the public sanitary sewer. EGLE required OCIA to submit to CRWRRF a PFAS best management plan with regard to PFAS discharges from OCIA property to the public sanitary sewer.
EGLE sent letters to homes with wells north of OCIA offering free water test due to suspected PFAS in the area.
ASTi Environmental supervised the installation of eight permanent monitoring wells at OCIA at locations where the AMR at OCIA had discharged AFFF.
ASTi received lab test results from monitoring well sampling.
EGLE contactor AECOM conducted sampling of residential wells for PFAS in homes north of the airport.
ASTi developed draft best management plan and briefed Oakland County administration on ASTi Environmental's PFAS Groundwater Sampling Report. OCIA submitted report to EGLE and began to educate the public about the results and what they mean. Lab results indicated detectable concentrations of one or more PFAS compound in seven of the eight monitoring wells. Four of the wells had PFAS concentrations exceeding EGLE standards, which are more stringent than Environmental Protection Agency standards for PFAS.