Spokane International Airport began investigating the potential presence of per- and polyfluoroalkyl substances (PFAS) in 2017. The Airport continues to take a methodical, science-driven approach to address PFAS in collaboration with the Washington State Department of Ecology and other regional stakeholders.
Background and Voluntary Assessment
As a transportation hub for the Inland Northwest, Spokane International Airport initiated a voluntary PFAS groundwater assessment in 2017. This decision followed findings that nearby Fairchild Air Force Base had contributed to elevated PFAS levels in the City of Airway Heights’ drinking water wells.
At the time, there were no federal or state regulations for PFAS, and the presence of these substances in firefighting foam, furniture, cookware and other consumer products was not widely understood. The Airport’s assessment laid the groundwork for future decision-making and environmental management.
FAA Requirements and Historical Use
For over 50 years, the Federal Aviation Administration (FAA) historically mandated that all U.S. commercial airports, as part of its Operating Certificate, use aqueous film-forming foam (AFFF) because of its effectiveness in extinguishing and preventing re-ignition of jet fuel fires. It is now known that two of the main ingredients that make AFFF highly effective in fighting fuel fires – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – are PFAS compounds. The Airport, like others across the country, was not told about the potential environmental risks at the time of federally-mandated use of AFFF.
Spokane International Airport (GEG) was previously known as Geiger Field, a Department of Defense (DoD) facility used during World War II and throughout the Cold War. The historical use of military training and burn pit operations resulted in contamination of groundwater and soil by several different contaminants, from petroleum and heavy metals to solvents used as degreasers in the routine maintenance of military aircraft, which are now being recognized as PFAS-containing materials.
This historical use set the stage for the majority of environmental contaminants and cleanup efforts at the Airport. The site has since been designated a Formerly Used Defense Site (FUDS), with past cleanup efforts conducted under federal and state programs.
An Evolving Conversation
After the effects of PFAS on human health and the environment became better understood, the FAA, in 2016, updated its longtime guidance to indicate airports were no longer required under federal law to discharge AFFF during routine training, and provided alternatives to system testing methods that traditionally involved discharging AFFF.
In 2022, Congress directed the FAA to develop a plan to replace AFFF with an alternative, PFAS-free fire suppressant equally effective at extinguishing aviation fuel fires. That same year, the DoD authorized a new fluorine-free foam alternative without PFAS called MIL-PRF-32725, more commonly known as F3 foam.
The Airport currently maintains a supply of F3 foam, along with AFFF, which is still recognized as the most effective firefighting foam against fuel fires, onsite for emergencies. At the present time, the Airport is not aware of any agreement among the FAA, Washington State Department of Ecology, and industry experts on how airports like GEG should transition fully from AFF to F3 foam while maintaining compliance and effectiveness in aviation firefighting.
Regulatory Context
The U.S. Environmental Protection Agency (EPA) recognized that airports are not responsible for PFAS contamination caused by FAA mandated foam. Similarly, Washington State has identified PFAS manufacturers and distributors – not end users – as the responsible parties. In 2023, Washington State filed a suit against 20 such companies for knowingly concealing the environmental risks of PFAS.
Investigation Timeline and Scope of Work
The Airport has worked with the Washington State Department of Ecology since 2024 under an Enforcement Order (EO). The EO includes seven major tasks specifically focused on investigating the potential presence, scope and source of PFAS that may be present at the Airport.
The EO is separate from Ecology’s Model Toxic Control (MTCA) cleanup process (pictured below), although some of the steps outlined in the EO are conducted concurrently with steps in the MTCA process. Currently, the Airport is in the “Assess the Site” step of the Ecology cleanup process. Below is a more detailed timeline of activities at the Airport related to this process.
What We’ve Learned
Based on preliminary results from the Site Assessment Report (SAR) and Initial PFAS Investigation (IPI), the Airport identified 10 potential PFAS source areas. Three of these locations – the current firehouse, the former firehouse, and historic burn pit – showed elevated soil concentrations and are being prioritized for further testing.
The investigation also examined subsurface conveyance drainage patterns. One key finding involves a conveyance ditch known as No Name Ditch (also known as Willow Creek) that, during extended periods of precipitation, channels run off from the adjacent Fairchild Air Force Base onto Airport property. Once the conveyance reaches the Airport’s property boundary, the water appears to immediately infiltrate into the subsurface, likely impacting the ground water.
The Airport understands Fairchild Air Force Base to be a likely source of PFAS. Previous investigations completed by the base have confirmed runoff conveyed by No Name Ditch contains PFAS concentrations significantly higher than that found in shallow groundwater beneath the Airport’s property.
What’s Next
The Airport is in the second of eight stages of Ecology’s Model Toxic Control (MTCA) cleanup process. This stage, “Assess the Site”, requires the Airport to complete several steps under Ecology’s Enforcement Order before it can progress to subsequent steps in the cleanup process.
A closer look at this multi-year process is outlined below. The information gathered as part of this investigation aids our collective understanding of potential PFAS sources and movement in the region.
FAQ
The U.S. Environmental Protection Agency (EPA) defines PFAS (per- and polyfluoroalkyl) as a group of thousands of man-made chemical compounds that have been used since the 1940s in a wide variety of consumer and commercial products such as nonstick cookware, pesticides, paint, fast food packaging, water-resistant fabrics, and personal care products, including dental floss and mattresses. For decades, PFAS have been used in many industrial applications, including certain firefighting foams used worldwide to help ensure the safety of the traveling public. They are still used today, and, based on new research, these compounds are now classified by the EPA as emerging contaminants. Because of their prevalence in the environment, they can be transported by snow, rain, and wind. While no national soil clean-up standards currently exist, the Spokane International Airport (SIA) has moved forward with a scientific approach that analyzes the identified PFAS on a molecular level to begin categorizing possible sources, which provides for a holistic approach and better understanding
For over 50 years, the Federal Aviation Administration (FAA) historically mandated that all U.S. commercial airports, as part of its Operating Certificate, use aqueous film-forming foam (AFFF) because of its effectiveness in extinguishing and preventing re-ignition of jet fuel fires. It is now known that two of the main ingredients that make AFFF highly effective in fighting fuel fires – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – are PFAS compounds. The Airport, like others across the country, was not told about the potential environmental risks at the time of federally-mandated use of AFFF.
Spokane International Airport (GEG) was previously known as Geiger Field, a Department of Defense (DoD) facility used during World War II and throughout the Cold War. The historical use of military training and burn pit operations resulted in contamination of groundwater and soil by several different contaminants, from petroleum and heavy metals to solvents used as degreasers in the routine maintenance of military aircraft, which are now being recognized as PFAS-containing materials.
This historical use set the stage for the majority of environmental contaminants and cleanup efforts at the Airport. The site has since been designated a Formerly Used Defense Site (FUDS), with past cleanup efforts conducted under federal and state programs.
For air transportation safety, the Federal Aviation Administration (FAA) has long required all commercial and military airports to use aqueous film-forming foam (AFFF) because of its effectiveness in quickly extinguishing jet-fuel fires, helping save lives. All FAA-mandated AFFF products contained some form of PFAS. In September 2023, the FAA approved the first fluorine-free foam (F3) for use by commercial service airports. Following the FAA’s approval, SIA purchased F3 to replace all AFFF containing PFAS. SIA is currently working with the FAA to transition the new F3 into the Airport’s firefighting equipment.
In 2017, GEG initiated a voluntary assessment to determine the possible presence of PFAS in the groundwater on Airport property. This effort was initiated after it was discovered that nearby Fairchild Air Force Base had contributed to elevated PFAS levels in the City of Airway Heights’ drinking water wells. The data were gathered to guide future decision-making following the disclosure of the groundwater contamination caused by military activities near the Airport property.
The sources and impacts of PFAS are a challenging and complex issue and part of an evolving national conversation. In 2017, knowledge of these compounds was in its infancy, and there were no federal or state requirements for any organization to test for PFAS.
Testing methodologies and the general understanding of PFAS (per- and polyfluoroalkyl) have significantly advanced since 2017, and we are working with the Ecology, the Federal Aviation Administration (FAA), and other state and federal agencies and experts to carefully assess the complex issue of PFAS on the West Plains using a scientific, data-driven process. In fact, the SIA has been proactively working with a team of nationally recognized experts, prior to the DOE’s March 29, 2024 EO, on a scientific, data-driven investigation for the presence of per- and polyfluoroalkyl (PFAS) substances on our property.
responsible for the contamination on their property caused by a product they were required to use. The EPA’s Office of Enforcement and Compliance Assurance stated in an August 2023 memorandum: “OECA does not intend to pursue entities where equitable factors do not support CERCLA responsibility, such as farmers, water utilities, airports, or local fire departments, much as OECA exercises CERCLA enforcement discretion in other areas.”
Further, the State of Washington recognizes that the manufacturers and distributors of PFAS chemicals are the parties responsible for the contamination on the West Plains and throughout Washington and the country.
On May 30, 2023, the State of Washington commenced a lawsuit in King County Superior Court against twenty (20) manufacturers of PFAS-containing products, alleging that these companies have known about the dangers of PFAS chemicals for decades and hid that knowledge from governments and the public while continuing to make substantial profits on those products.
In 2019, the Airport purchased a specialized device approved by the FAA, the NoFoam Systems apparatus, to perform the required calibration and testing without the need to discharge AFFF for purposes of meeting FAA regulations requiring SIA to demonstrate that its fire vehicles discharge AFFF in the proper proportion of water to foam, as required by the Airport’s Part 139 operating certificate.
In 2023, the Airport purchased FAA-approved Fluorine-Free Foam (F3) and is currently working with the FAA to transition the new F3 into the Airport’s fire-fighting vehicles to protect the traveling public. However, further guidance is needed by the FAA regarding the rinsing of the existing firefighting vehicles, disposal of the wastewater from rinsing, and disposal of the existing stock of AFFF.