Cherry Capital Airport’s Environmental Commitment: PFAS
Cherry Capital Airport is committed to working with all partners involved to ensure the health and safety of our community continues to be a top priority. At the airport, we have taken steps to reduce the use of firefighting foam, while embarking on a long-term testing process of the airport’s property. We will continue to work side by side with the Michigan Department of Transportation (MDOT) and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) throughout this testing process, and are dedicated to working with all other parties involved.
What is PFAS and why does it occur?
PFAS, or Per- and polyfluoroalkyl substance, are a group of man-made chemicals used in many industries across the globe and have been in use in the United States since the 1940s, though most widely used in industrial processes and firefighting foams by the military, airports and fire and rescue agencies.
After many decades of broad use, PFAS can be found in food, household items, workplaces, drinking water, wildlife, and in blood and tissue samples from people. PFAS’ unique properties slow its chemical breakdown, resulting in PFAS accumulating over time in soil and groundwater.
At airports, PFAS are often found in aqueous film-forming foam (AFFF), which airports deploy to quell and suppress petroleum-based fires. Because PFAS in AFFF effectively suppresses fires, the chemical has been used consistently over the years to battle fires at airports across the country as well as during testing and training at airports.
Testing and Community Protection
In January of 2018, groundwater criteria for PFOA and PFOS, two types of PFAS substances prevalent in aqueous film-forming foam (AFFF), were established by EGLE under Part 201 of the Natural Resources and Environmental Protection Act (NREPA) consistent with the United States Environmental Protection Agency health advisory criterion levels not to exceed at 70 ppt (parts per trillion) for the combined concentrations of PFOA and PFOS. In August of 2020, the State of Michigan developed more stringent standards in requiring that groundwater concentrations not exceed 8 ppt for PFOA and 16 ppt for PFOS. In conjunction with the establishment of these stricter criteria, a concerted effort has been made by EGLE to identify any locations where the use of AFFF has been employed, including airports like Cherry Capital.
To the north of the airport is the Pine Grove neighborhood, where a number of residents were still utilizing wells for their everyday drinking water needs. Due to the proximity of these wells to the airport, EGLE reached out to Cherry Capital Airport to request information regarding its use of firefighting foam. Cherry Capital Airport is committed to working side by side with EGLE and MDOT during this process to ensure that further testing is completed to support the initiative of keeping our community safe and healthy.
Why does Cherry Capital Airport care about PFAS?
Since the 1970s, aqueous film-forming foam (AFFF), which contains PFAS, has been stored and used at the Cherry Capital Airport in firefighting foam in compliance with Federal Aviation Administration (FAA) mandates. AFFF has been considered the most effective method of fighting jet fuel-based fires since its development by the U.S. Navy in the 1960s. The FAA has long required annual firefighting equipment testing, which has resulted in discharges of AFFF onto the tarmac and immediately adjacent areas on airport property.
Although AFFF containing PFAS substances are still being utilized by airports across the country until a more environmentally friendly solution is found, the FAA does allow for an exemption to not dispense AFFF during airport testing of firefighting equipment. To help support this effort, in March of 2019, the Michigan Aeronautics Commission (MAC) approved a grant program that provided each commercial service airport in Michigan with nearly $25,000 to acquire environmentally conscious firefighting foam testing devices. These types of devices connect to existing firefighting trucks to ensure proper foam proportioning without the need to dispense any firefighting foam concentrate, eliminating a potential pathway for PFAS to enter the environment while ensuring the readiness of airport firefighting equipment. In September of 2019, Cherry Capital Airport took delivery of one of these units.
A concerted effort has also been put forth at Cherry Capital Airport related to the review of its standard operating procedures related to AFFF, to ensure there are safe and environmentally effective handling, storage, and disposal procedures in place.
The FAA Reauthorization Act of 2018 directed the Federal Aviation Administration to eliminate the requirement for the use of AFFF at airports, providing a 3-year timeline to research alternatives that would be deemed just as effective. Approved alternatives were originally expected to be released by the end of 2021. However, the FAA has encountered delays in conducting its research due to the impacts of COVID-19 and as a result, completion of this project could potentially extend into 2022.
Cherry Capital Airport PFAS Response Timeline
- February 2020: Information request received from EGLE pertaining to the use of firefighting foam at Cherry Capital Airport. This included notification that 20 groundwater supply wells were still being utilized in the Pine Grove neighborhood, and at risk for PFAS exposure. >> EGLE Information Request Ltr Dtd 2020.02.19.pdf < img src=”/wp-content/uploads/2021/04/open-external-tab-blue.png” width=”14″ height=”14″ alt=”Opens link in new tab” />
- March 2020: Notified of available grant funds associated with PFAS through MPART to support monitoring and testing for PFAS substance contamination.
- April 2020: Informed of Part 201 compliance requirements by EGLE, as PFAS may be present on the property of the airport. >> EGLE Part 201 Compliance Ltr Dtd 2020.04.02.pdf
- May 2020: Cherry Capital Airport begins the grant application process, with its formal submission on 5/29. >> TVC PFAS Grant Application 2020.05.29.pdf
- July 2020: Cherry Capital Airport awarded grant funding ($249,981) from MDOT and EGLE for Municipal Airport PFAS Grant Funding for test wells to assess five suspected areas of PFAS contamination on the airport’s property.
- July 2020: Approval received from EGLE related to the grant work plan.
- August 2020: Notification received regarding EGLE test wells being drilled on Parsons Road.
- Sept 2020: Contract awarded to Gosling Czubak for the drilling of 15 test wells in five separate locations within the property lines of the airport.
- Sept 14-18, 2020: The Geologic Service Section of EGLE completed the installation of 10 vertical aquifer sampling locations along Parsons Road.
- Oct 15, 2020: Virtual team meeting with EGLE, DHHS, and the local health department to conduct a review of the results from EGLE’s sampling.>> https://www.michigan.gov/pfasresponse/0,9038,7-365-86511_95645—,00.html
- Oct 16, 2020: Virtual team meeting with Cherry Capital Airport, the United States Coast Guard, EGLE, and local officials to provide an update on the contamination and presence of PFAS in residential wells in the Pine Grove neighborhood and need for further testing.
- Oct 21, 2020: Cherry Capital Airport conducts surface water sample testing from storm water basins in Areas 1 and 4 on the airport, as outlined in grant application.
- Oct 22, 2020: Cherry Capital Airport conducts soil sampling in Areas 1, 3, and 4 on the airport, as outlined in the grant application.
- Oct 26, 2020: Virtual town hall meeting led by EGLE to discuss their investigation and findings. Attendees included area residents, local officials, and the general public.
- Early Nov 2020: EGLE conducted testing on 15 of 18 residential wells in the Pine Grove neighborhood for PFAS.
- Nov 3-6, 2020: Cherry Capital Airport has 15 monitor wells drilled in five designated areas located on the airport, as outlined in the grant application.
- Nov 13, 2020: Town hall meeting to discuss residential well sampling results for EGLE testing on (15) wells located in the Pine Grove neighborhood.
- Dec 1-2, 2020: Cherry Capital Airport collects groundwater samples from the (15) monitor wells drilled in early November, along with samples from (3) previously existing wells located on the airport.
- Dec 4, 2020: East Bay Township solicited bids for connections to municipal water.
- Dec 7, 2020: EGLE conducted testing on the (3) remaining residential wells in the Pine Grove neighborhood for PFAS.
- Dec 11, 2020: EGLE received residential well sampling results from the last (3) locations in the Pine Grove neighborhood.
- Dec 21, 2020: Bids for water connections were evaluated, and the contract awarded, with the total projected cost being $229,000. East Bay Township, through its discussions of funding options, was able to obtain $150,000 in grant funding from EGLE for reimbursement of the water system connections. This left a funding gap of $79,000, which would be the responsibility of the property owner should no additional funding be available.
- Jan 28, 2021: Grand Traverse County unanimously passed a motion to fill this gap by approving additional funds totaling $85,000, in support of its residents in the Pine Grove neighborhood requiring water connections.
- Jan 29, 2021: Draft reports outlining sampling results from Cherry Capital Airport were provided to MDOT and EGLE for their review.>> Soil_Surface Water PFAS Sampling Results REV I 2020.01.29.pdf >> Groundwater-PFAS-Sampling-Results-2021.01.29
- March 19, 2021: Completion of water connection hookups in the Pine Grove neighborhood.
- March 2021: (6) additional monitoring wells were drilled in various locations both upgradient and down gradient within the airport’s property to conduct further groundwater sampling exercises.
- April 14, 2021: Cherry Capital Airport designated by EGLE as an MPART PFAS Site.>> https://www.michigan.gov/pfasresponse/0,9038,7-365-86511_95645-556746–,00.html
- April 14, 2021: Virtual community meeting conducted by MPART to provide a public update related to PFAS investigations. Presentations were made by both the Cherry Capital Airport and the United States Coast Guard regarding recent sampling exercises and results, along with future investigation plans. >> TVC Presentation – MPART Community Meeting 4.14.21.pdf
- June 17, 2021: Draft reports outlining April 2021 sampling results from Cherry Capital Airport were provided to MDOT and EGLE for their review.>> TVC Groundwater Sampling Results – April 2021
- October 1 2021: Draft reports outlining August 2021 sampling results from Cherry Capital Airport were provided to MDOT and EGLE for their review.>>TVC Groundwater Sampling Results – August 2021
- March 15, 2022 – Draft reports outlining February 2022 sampling results from Cherry Capital Airport were provided to MDOT and EGLE for their review.>>TVC Groundwater Sampling Results – February 2022
- June 16, 2022: Final Report for PFAS Results submitted to MDOT and EGLE. >> TVC Final Sampling Results
- September 7, 2022: Senate Airport PFAS Legislation >>Bipartisan bill to reduce the spread of toxic pfas at commercial airports
- October 3, 2022 – Notice of Migration provided to Airport Neighbors >> Read the Letter
- October 12, 2022 – EGLE issues NRAA PFAS Investigation Round 2 Grant
- January 12, 2023 – New performance-based standard issued for Fluorine-Free AFFF by the FAA >> National Part 139 CertAlert
- April 30, 2023 – Vertical Aquifer Profile Results. >> TVC PFAS Q2 Report
- May 8, 2023 – Aircraft Firefighting Foam Transition Plan issued by the FAA >> AFFF Transition Plan
- September 28, 2023 – Vertical Aquifer Profile Results >>TVC PFAS Q4 Report
- January 30, 2024 – >>FY24 Quarter 1 update
- April 19, 2024 – The U.S. Environmental Protection Agency (EPA) released a final rule that designates two PFAS chemicals, PFOA and PFOS, as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as the Superfund law.
- April 30, 2024 – >>FY24 Quarter 2 update
Cherry Capital Airport PFAS Response Next Steps
The NRAA has been awarded a second grant by EGLE to undertake another phase of an investigation program. Vertical aquifer profile testing on and off-airport is anticipated during 2023.
Collaborative Efforts:
Cherry Capital Airport is dedicated to assisting EGLE with any necessary PFAS remediation efforts and is committed to being a supportive and transparent partner in order to protect the area we call home. To support this endeavor, Cherry Capital Airport has taken proactive steps in communicating with various agencies and local representatives in an effort to aid with obtaining funds to cover the cost of connecting new water lines to those residents whose wells were impacted by PFAS.
These included:
- East Bay Township – Cherry Capital Airport offered to assist the township in applying for Consolidation and Contamination Risk Reduction (C2R2) grant funding, made available through the State of Michigan for drinking water system remediation efforts.
- USDA Rural Development – Worked with its director, Jason Allen, on potential funding options through the USDA that may apply. Information provided to EGLE in November of 2020.
- U.S. Senator Gary Peters’ Office – Inquiry regarding the availability of any additional funding options through the federal government that could assist with covering the cost of the project.
- State Senator Wayne Schmidt – Inquiry regarding the availability of any additional funding options through the State of Michigan that could assist with covering the cost of the project.
- Federal Aviation Administration (FAA) – Inquiry as to the availability of any federal funds/grants.
As additional testing is completed and results are determined, we will continue to partner with federal, state and local authorities to ensure a long-term solution is reached. These organizations include:
- East Bay Township
- Grand Traverse County Commission
- Grand Traverse Health Department
- Michigan Department of Environment, Great Lakes and Energy (EGLE)
- Michigan Department of Health and Human Services (MDHHS)
- Michigan PFAS Action Response Team (MPART)
- Federal Aviation Administration (FAA)
- Michigan Department of Transportation (MDOT)
- USDA Rural Development – Michigan
- American Association of Airport Executives (AAAE)
- Environmental Protection Agency (EPA)
For more information on PFAS and PFAS remediation please visit:
Government Accountability Office (GAO) PFAS Report – Released to the Public on March 1, 2021:
https://www.hsgac.senate.gov/media/majority-media/peters-releases-gao-report-showing-more-action-is-needed-to-address-pfas-contamination
https://www.gao.gov/assets/gao-21-37.pdf
Peters Bipartisan Bill to Protect Firefighters from Hazardous PFAS Chemicals Advances in Senate
https://www.hsgac.senate.gov/media/majority-media/peters-sullivan-hassan-and-tillis-bipartisan-bill-to-protect-firefighters-from-hazardous-pfas-chemicals-advances-in-senate-
PFAS in East Bay:
https://www.michigan.gov/pfasresponse/0,9038,7-365-86511_95600_95631-543092–,00.html
Michigan PFAS Action Response Team (MPART):
https://www.michigan.gov/pfasresponse/
Environmental Protection Agency (EPA):
https://www.epa.gov/pfas/basic-information-pfas
https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos
Federal Aviation Administration:
https://www.faa.gov
Michigan Department of Transportation – Aeronautics:
https://www.michigan.gov/aero/