"Oakland County International Airport has a long commitment to minimizing our impact on the environment".  Whether it's our fuel-water separator that prevents aircraft fuel from entering the stormwater sewer, our ground run-up enclosure which quiets noise pollution for our neighbors, or our LEED Gold-certified airport terminal that has reduced energy consumption, we are always looking for ways we can be better stewards of the environment. We bring that same mindset to investigating and addressing the detection of PFAS at the airport." -Oakland County Executive.

Oakland County International Airport (OCIA) in Waterford submitted a report to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) that PFAS has been detected in groundwater below airport property. ASTi Environmental of Brighton installed eight permanent detection wells on airport grounds in May and received sampling results back in June 2021.

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Timeline

1965

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).

February 1967

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).

1991

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.

January 1996

AMR at OCIA responded to aircraft accident in middle of northern runway where it employed AFFF.

2005

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.

January 2006

AMR at OCIA applied AFFF to aircraft accident west of the northern runway.

December 2009

AMR at OCIA used AFFF on aircraft engine fire near Pentastar Aviation ramp.

March 2011

AMR at OCIA dispatched to aircraft hangar fire in northeast corner of the airport where it utilized AFFF.

June 2013

AMR at OCIA responded to aircraft accident east of the northern runway where it extinguished the fire with AFFF.

October 2018

AMR at OCIA deployed to Aircraft Run-up Enclosure to put out engine fire with AFFF.

October 2018

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.

July 2019

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.

August 2019

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.

September 2019

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.

October 2019

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.

November 2019

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.

January 2020

E-One test cart delivered.

March 2020

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.

May 2020

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.

August 2020

EGLE provided additional feedback on work plan recommending changes which OCIA and ASTi incorporated into work plan and resubmitted to EGLE.

September 2020

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.

October 2020

ASTi Environmental submitted cost proposal to complete the work plan as approved by EGLE.

November 2020

OCIA amended ASTi Environmental contract to include funds required for the cost proposal to complete the work plan.

December 2020

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.

April 2021

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.

May 2021

ASTi received lab test results from monitoring well sampling.

June 2021

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.

June & August 2021

ASTI conducted stormwater sampling at the airport as part of the Short-Term Storm Water Characterization Study. Results from this study were provided to EGLE. Lab results indicated that PFAS was present at two stormwater discharge points at concentrations exceeding Michigan’s Water Quality Standards.

January & March 2022

At the request of EGLE, ASTI installed 4 additional monitoring wells on OCIA property and collected groundwater samples from the new wells. Lab results indicated that PFAS was present at a concentration exceeding EGLE criteria in one of the monitoring wells sampled during this event.

March 2022

EGLE notified OCIA that quarterly stormwater sampling is required to further characterize PFAS in stormwater discharge from the airport.

October & December 2022: ASTI conducted the first and second quarterly stormwater sampling events at OCIA. Lab results indicated that PFAS was present in stormwater discharge at concentrations exceeding Michigan’s Water Quality Standards. The results of these stormwater sampling events were shared with EGLE.

March 2023

ASTI conducted the third quarterly stormwater sampling event at OCIA. Lab results indicated that PFAS was present in stormwater discharge at concentrations exceeding Michigan’s Water Quality Standards. The results of this stormwater sampling event were shared with EGLE.

April 2023

At the request of EGLE, ASTI installed 10 additional monitoring wells on OCIA property with the objective of delineating PFAS impacts in groundwater.

May 2023

ASTI conducted the fourth and final quarterly stormwater sampling event at OCIA. Lab results indicated detections of PFAS in stormwater at concentrations less than EGLE criteria. The results of this stormwater sampling event were shared with EGLE.

June 2023

ASTI collected groundwater samples from all 22 monitoring wells on OCIA property. Lab results indicated that PFAS compounds were present in 16 of the monitoring wells at concentrations exceeding EGLE criteria. The results of this monitoring well sampling event were shared with EGLE.

October 2023-January 2024

Discussions with EGLE indicated that groundwater sampling upgradient and downgradient of the airport will be required to evaluate PFAS in regional groundwater.

May 2024

On May 16, 2024, the Federal Aviation Administration Reauthorization Act of 2024 was signed into law. The Act includes a PFAS replacement program for airports to replace AFFF with nonfluorinated alternatives that meet the same industry standards for performance.

October 2024

EGLE notified OCIA that based on the stormwater discharge sampling results, OCIA may voluntarily enter a General Administrative Consent Order for Addressing PFAS in Industrial Stormwater Discharges to Surface Waters (5-Year). This includes a framework to address PFAS exceedances in stormwater and prevent pollution to surface waters.

November 2024

OCIA is working with ASTI and EGLE to coordinate a regional PFAS groundwater investigation, including sampling from upgradient and downgradient locations, and implement a stormwater compliance program to reduce PFAS concentrations in airport stormwater discharge.

OCIA entered into a Consent of Entry (COE) of General Administrative Consent Order (GACO) to address pollutants in industrial stormwater discharges that have a reasonable potential to exceed applicable criteria for Per- and Polyfluoroalkyl (PFAS) substances.  The GACO is a settlement agreement to implement a compliance program including monitoring, development and implementation of both a source investigation and identification plan and a Pollutant Minimization Program (PMP).

OCIA submitted a Source Investigation and Identification Plan (SIIP) to EGLE for review.  A final report of its findings is due 12 months from the effective date of the GACO.

Additionally, OCIA submitted an Airport Per- and Poly – Fluoroalkyl Substances Grant Application to EGLE requesting funds for additional PFAS monitoring, testing and equipment cleanout.

OCIA ARFF staff completed the applicable training and placed a new Index B, Class  4, ARFF vehicle into operation.  The new response vehicle is equipped with non-aqueous fire-fighting foam to greatly minimize exposure to PFAS substances to both the team and the environment.  As a result, OCIA retired its 2011 Airport Rescue Fire Fighting (ARFF) vehicle.

FAQs

*Source: Michigan PFAS Action Response Team.