Use and Potential Impacts of AFFF Containing PFASs at Airports (2017)

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68 6.1 Introduction to the MAPA Screening Tool 6.1.1 Overview The Managing AFFF and PFASs at Airports (MAPA) Screening Tool has been designed to assist airport managers with the identification of APECs on or near their airport. The identified APECs account for historical and current use of AFFF and other sources of PFASs at an airport facility. The MAPA Screening Tool has been designed to enable users to easily identify • Whether an airport has APECs that need to be further evaluated. • The nature of these APECs (i.e., operational versus legacy). • The relevant or significant characteristics related to AFFF management and the fate and transport of PFASs. • Relative ranking of each APEC to facilitate evaluation of future action (e.g., allocation of resources or implementation of best management practices). • Data gaps that need to be filled to characterize individual APECs and develop a CSM. The MAPA Screening Tool provides airport managers with a sequential and systematic approach to identifying APECs on an airport property. Conceptually, the MAPA Screening Tool works progressively along two sequential phases, or modules, as follows: • Module 1 focuses on the airport property as a whole and identifies actual or potential sources and/or activities involving AFFF and PFASs. At the airport scale, the potential presence of off-site sources of PFASs and sensitive receptors is also considered. • Module 2 focuses on the APECs identified in Module 1. The MAPA Screening Tool can be used to evaluate each APEC based on APEC-specific features related to the management of AFFF and impacts of PFASs in the environment. The MAPA Screening Tool will score APECs for further evaluation/action. To facilitate use of the MAPA Screening Tool, a “Quick Guide” has been provided in Appen- dix C of this report. 6.1.2 How to Use the Screening Tool The MAPA Screening Tool has been designed so users can rely on readily available infor- mation to complete the screening effort. If information is not known, or otherwise unavailable, the MAPA Screening Tool will flag the missing information as a potential data gap, which then can be applied by the user for future planning. Data from previous environmental site assessments or other intrusive investigations are not required to use the MAPA Screening Tool. The MAPA Screening Tool has been designed for airport representatives familiar with AFFF management and impacts of PFASs at an airport. As knowledge and responsibilities related to C h a p t e r 6 Screening Tool Guidance

Screening tool Guidance 69 AFFF and/or PFASs may exist among different departments at an airport, collaboration among the members of different functional departments is beneficial for working with the MAPA Screening Tool to gain a holistic understanding of an airport’s level of potential risk. For example, AFFF management through the life cycle stages (i.e., procurement, storage, use, testing, maintenance, and disposal) is typically the responsibility of emergency response personnel, and addressing legacy impacts in the environment (i.e., contamination of soil, groundwater, sediment, and/or surface water with PFASs) is typically the responsibility of the department(s) responsible for environmental issues. The MAPA Screening Tool also allows the user to consider whether future projects (e.g., capital improvement projects) may be affected. For example, airports impacted with PFASs may face unexpected and costly remediation actions to address impacted soils or groundwater encountered during a capital improvement project (e.g., costs associated with the proper disposal of impacted soil or groundwater, such as dewatering during construction). 6.1.3 MAPA Screening Tool Architecture The MAPA Screening Tool is a Microsoft Excel™-based tool that walks the user through a series of questions associated with two modules. Module 1 addresses content related to the airport. Module 2 is more specific and asks questions related to each APEC identified in Module 1. The details associated with each module are presented in subsequent sections. 6.1.3.1 How to Use the MAPA Screening Tool in Microsoft Excel™ The MAPA Screening Tool works best when used in Microsoft Excel™ 2010. If Microsoft Excel™ 97 to 2003, or 2007, is being used to run the screening tool, the version of the screening tool that is contained in the file entitled “MAPA Screening Tool Compatibility Version” should be used. If running a more recent version of Microsoft Excel™, use the file entitled “MAPA Screening Tool.” When first opening the file, if a security warning appears saying that macros have been disabled, click “Enable content.” The workbook contains numerous formulas and macros to make the MAPA Screening Tool user friendly. Users should only edit cell content where prompted; typing in a cell with a formula or other text will adversely impact MAPA’s functionality. The MAPA Screening Tool leads the user from one worksheet to the next sequentially, as needed; filling out every worksheet in the screening tool may not be required for every airport. 6.1.3.2 Macros Security The MAPA Screening Tool consists of multiple worksheets and embedded macros. Macros automate frequently used tasks; the ones used in the MAPA Screening Tool are created with Visual Basic for Applications and have been written by Dillon Consulting Limited specifically for the MAPA Screening Tool. When users first open the MAPA Screening Tool, macros need to be enabled for the program to function and carry out its tasks. Some macros pose a potential security risk. A person with malicious intent can introduce a destructive macro in a document or file, which can spread a virus on computers. In Microsoft Office Excel™, users can change the macro security settings to control which macros run and under what circumstances when a workbook is opened. The following steps discuss how to enable macros. When first opening the program, a pop-up window generally provides the user with an option to enable macros. If there is no pop-up window, or if the user has accidentally clicked “do not enable macros,” the user should refer to the online instructions provided by Microsoft Office for

70 Use and potential Impacts of aFFF Containing pFaSs at airports the appropriate version of Excel™: https://support.office.com/en-us/article/Enable-or-disable- macros-in-Office-files-12b036fd-d140-4e74-b45e-16fed1a7e5c6#__toc311698310. Typically, these instructions provided by Microsoft Office include the following steps (with variations on naming conventions, e.g., File Tab versus Microsoft Office Button). Microsoft Office provides a disclaimer on the risks associated with running macros from unknown sources. The steps are • Click the Microsoft Office Button (or File Tab), and then click Excel Options. • Click Trust Center, click Trust Center Settings, and then click Macro Settings. • Click the options that you want: Enable All Macros (not recommended, potentially dangerous code can run). Click this option to allow all macros to run. This setting makes your computer vulnerable to potentially malicious code and is not recommended. 6.2 Module 1—Airport Scale Evaluation Module 1 of the MAPA Screening Tool provides a rapid assessment for users to identify whether they have a potential concern that needs to be explored at their airport. If an APEC is identified, the location and nature of the area (e.g., known release/application, incidental/limited release, or historically contained storage unit) are documented. Module 1 focuses on identification of the following: • Areas on the airport property, both those associated with airport operations and tenants, where AFFF (containing PFASs) is currently or has historically been stored, used/applied, tested, handled, managed, or disposed. • Areas on the airport property where there were accidental uncontrolled spills or releases of AFFF. • Other potential sources of impacts of PFASs (other than AFFF) to the environment on or near the airport property. Additionally, Module 1 screens for potential sensitive receptors at and in the vicinity of the airport. Being familiar with the AFFF life cycle (shown in Figure 6-1) at an airport is critical to identifying and understanding APECs. If an airport has never stored, transported, or used AFFF, the airport is unlikely to have a concern associated with AFFF or PFASs, and there will be fewer worksheets to fill out in the MAPA Screening Tool. However, for airports that are/were required to have firefighting services and use AFFF (by their respective federal agency, i.e., FAA or Transport Canada), understanding how AFFF is (and has been) procured, stored, handled, distributed, tested, applied, and disposed of will help to identify APECs at the airport. Figure 6-1. AFFF life cycle stages.

Screening tool Guidance 71 APECs will be identified as those areas of the airport that have, or have had, activities that could result in impacts to the environment from AFFF or PFASs. APECs are likely to include (but are not limited to) areas of AFFF storage, firefighting training, and historical emergency response involving AFFF application, as well as equipment and infrastructure used in AFFF application, equipment and system testing areas, and disposal areas. While AFFF is the primary focus of the MAPA Screening Tool, there are other potential sources of PFASs, as detailed in Section 2.2 that are also considered because they may influence the identification and prioritization of APECs. These sources include the following: • Aviation and/or industrial components. Fluoropolymers such as PTFE are used extensively in various equipment components (e.g., semiconductors, wiring, tubing, piping, seals, gaskets, and cables). In addition, the salts of sulfonated PFASs (primarily PFOS) have been used as additives with a content of about or less than 0.1 percent in hydraulic fluids/lubricants to prevent evaporation, fires, and corrosion. • Metal plating operations. Although metal plating operations may not be directly associated with the aviation industry, such operations are one of the most important ongoing uses of products containing PFASs and are typically situated within industrial zones that may be located near larger airport facilities. An ammonium salt of PFOS is used in metal plating. There is potential for residual concentrations of other PFASs in the PFOS products used for metal plating, as they are not always 100-percent chemically pure. • Herbicide/pesticide application. Non-polymeric PFASs have been used as active ingredients in some plant growth regulators and herbicides and as inert ingredients in pesticide formulations (e.g., ant baits). APECs can result from tenant activities (possibly similar to those described above) or be located off-site. If any of these activities/sources of PFASs are known to have occurred on or in the vicinity of the airport property, the user of the MAPA Screening Tool should include this information, to the extent known, to gain a more holistic understanding of potential sources that could affect concentrations of PFASs in various media on or near the airport. Although site-specific, off-site impacts of AFFF and PFASs may affect resources and sensitive receptors on the airport property. The MAPA Screening Tool includes questions for users that have been designed to ascertain whether potential sources of AFFF (and PFASs) reflect ongoing, active operations or legacy issues, or both. The outcomes of Module 1 include the following: • Identification of whether PFASs may be a concern. • An understanding of the AFFF life cycle at the airport. • Information necessary to develop a geo-referenced, geographic-information-system (GIS)- enabled map of the airport property that depicts identified AFFF sources, release sites, other APECs (both on and off the airport property), and locations of potential sensitive receptors (e.g., potable wells, surface water bodies, and wetlands). • Categorization of APECs as operational (i.e., related to airport operations and therefore the potential risk to human health and the environment can be proactively managed) or legacy (i.e., impacts of PFASs are present in the environment and need to be managed “reactively”). The balance of this section walks the user through each step (i.e., worksheet) of Module 1. 6.2.1 Entering Module 1 Information The first worksheet of the MAPA Screening Tool, called the Introductory Worksheet, collects basic information about the airport and the users involved in completing the MAPA Screening

72 Use and potential Impacts of aFFF Containing pFaSs at airports Tool process. This information will be incorporated into a cover page for the document pro- duced as a result of completing MAPA. Users should complete the fields to the best of their knowledge. Following the Introductory Worksheet, Module 1 consists of four worksheets (it may not be necessary to fill out all four worksheets for each airport): • Module 1 Overview Questions • Module 1 APECs • Module 1 Sensitive Receptors • Module 1 Summary Details on input are described in the following. 6.2.1.1 Module 1 Overview Questions Worksheet After the Introductory Worksheet, users begin the MAPA Screening Tool on the second worksheet of the screening tool, Module 1 Overview Questions, which consists of two tables: (1) APECs and (2) Potential Sensitive Receptors (see Figure 6-2). On this worksheet, users will identify on-site and off-site APECs and sensitive receptors. The table cells have been shaded to categorize data: • Information associated with on-site APECs will be entered in cells colored blue. • Information associated with off-site APECs will be entered in cells colored green. • Information associated with sensitive receptors will be entered in cells colored gray, white, and red. The user will be directed to the other input worksheets from Module 1 Overview Questions. Figure 6-2. Module 1 Overview Questions screenshot.

Screening tool Guidance 73 Instructions to guide users through Module 1 are the following: 1. Starting with the APECs table located on the left side of the Module 1 Overview Questions screen, use the cells in the “Your Responses” column to answer the questions posed in the “Questions” column. 2. Answer each question within one color block (e.g., blue) and then follow the directions in the “Next Steps” column (see Figure 6-3). 3. When listing responsible parties/custodians (e.g., airport property tenants), begin in the cell below “Airport.” These responsible parties/custodians will become a drop-down list on another worksheet. This list need not be limited to airport tenants; if there are other custodians or parties responsible for AFFF impacts, they should be listed as well. After going through the next steps and filling out the form for each color group, users will need to return to the APECs “on-site” table and complete instructions for the next color group. Repeat for the rest of the table and specify the units of distance (i.e., either English or metric) for use in the MAPA Screening Tool. Upon filling out the information for the APECs table in the Module 1 Overview Questions worksheet, users should follow the directions provided, as shown in Figure 6-3. Upon completion of the APECs table in the Module 1 Overview Questions worksheet, users should answer the questions in the Potential Sensitive Receptors table (on the right hand side of the worksheet). Specifically, the cells in the “Your Responses” column should be used to answer Figure 6-3. Module 1 Overview Questions categorization.

74 Use and potential Impacts of aFFF Containing pFaSs at airports the questions posed in the “Questions” column to the left. The user should only complete the action listed in the “Next Steps” column after answering all the questions within a single color block (e.g., blue) (see Figure 6-4). If a potential sensitive receptor is identified based on a user’s input to the Potential Sensitive Receptors table on the Module 1 Overview Questions worksheet, the user will be directed to tables specific to the category of receptor. Each sensitive receptor category (i.e., potable water sources, surface water bodies, and wetlands) is described below. 6.2.1.2 Module 1 APECs Worksheet APECs are categorized as “on-site” or “off-site.” Specific details for each APEC are identified in “on-site” or “off-site” worksheets, as described in the following sections. APECS—Airport The purpose of this table is to gain a basic understanding of the life cycle of AFFF at an airport and specific locations of potential concern, if any exist. The table lists the AFFF life cycle stages and requires the user to provide the location, activity, and responsible party associated with AFFF on the airport property (see Figure 6-5). Figure 6-4. Screenshot of completed Potential Sensitive Receptors table on the Module 1 Overview Questions worksheet.

Screening tool Guidance 75 In the table: • Cells in the location column allow users to type the name of the on-site APEC as it will be identified going forward in MAPA. • Cells in the activity column, except those associated with the storage life cycle stage, are to be populated from drop-down lists. • Cells in the responsible party/custodian column are to be populated with drop-down lists that are generated from the responsible parties/custodians identified in the Module 1 Overview Questions worksheet (see Figure 6-6). If, at this stage, a user realizes they have forgotten a responsible party/custodian (e.g., a new tenant) that should be listed, they can return to the Module 1 Overview Questions worksheet and add them to the list by using the worksheet tabs at the bottom of the screen. The MAPA Screening Tool has been designed to differentiate between current operations and historical operations for two reasons. First, the user’s knowledge of and the information available for current and historical operations may vary; sometimes the user will have no information about a historical application or operation. Second, how an airport may or can act (e.g., implementing best management practices) will be different for current operations than historical operations. Consequently, MAPA asks the user to distinguish between cur- rent operations and historical operations on this input table. Use the “Historical Operations” section if AFFF activities have occurred in a location that is not currently used/exposed to AFFF. For example, if AFFF training occurred in a specific hangar in the past, but now occurs at a designated firefighting training area, the hangar would be listed under the “Historical Operations” section and the firefighting training area would be listed under “Current Opera- tions” section. Figure 6-5. APECs—Airport table in Module 1 APECs worksheet.

76 Use and potential Impacts of aFFF Containing pFaSs at airports For activities on the drop-down list for the AFFF life cycle stage labeled “Use,” the options of “incident response” and “accidental release” are available under the “Historical Operations” section only. This is because these are events that have already happened and are not considered to be current. APECs—Off-Site The purpose of this table is to gain a basic understanding of the life cycle of AFFF in the vicinity of the airport and evaluate whether any locations of potential concern exist. The table lists the AFFF life cycle stages and requires the user to provide the location, activity, and land use type associated with AFFF on the property in the vicinity of the airport. The table has been constructed similarly to the table previously discussed and is located in the same worksheet. Please note: • Cells in the location column allow users to type the name of the off-site APEC as it will be identified going forward in the MAPA Screening Tool. • Cells in the activity column, except those associated with the storage life cycle stage, are to be populated from drop-down lists. • Current operations and historical operations are considered unique. Use the “Historical Operations” column if AFFF activities occurred in a location in the past where they do not currently occur. 6.2.1.3 Module 1 Sensitive Receptors Worksheet Upon completing the Module 1 APECs worksheet, users should return to the Module 1 Overview Questions worksheet to address potentially sensitive receptors. Module 1 of the MAPA Screening Tool considers potentially sensitive receptors at the airport scale. If AFFF and/or other APECs related to PFASs are identified at or near an airport, recognizing the presence of Figure 6-6. Responsible party/custodian lists generated from the Module 1 Overview Questions worksheet presented in a drop-down menu in the Module 1 APECs worksheet.

Screening tool Guidance 77 potentially sensitive ecological receptors is critical to evaluating the potential level of concern and ranking/prioritizing individual APECs. Questions focus on identifying key receptors (or receptor habitats) of interest, i.e., potable wells, surface water bodies, and wetlands. Releases of small amounts of AFFF containing PFASs to the environment could significantly impact environmental media, wildlife, and potentially human populations as some PFASs are very persistent in the environment and bioaccumulate in living organisms. Many PFASs are water soluble and will ultimately be transported to groundwater or surface water bodies, providing potential exposure to sensitive receptors. The MAPA Screening Tool identifies receptors (or receptor habitats) that are on, in relatively close proximity to, or down-gradient of the airport property and/or APECs previously identified. Potable water sources, or drinking water sources, if impacted by PFASs, may present an unacceptable risk to human health via ingestion. The following drop-down list options in the first column of the Potable Water Sources worksheet can be used to describe the type of potable water source: • Potable well: groundwater • Municipal water well supply: groundwater • Surface water body: A surface water body (e.g., lake or river) that is used as a source of drinking water The user should identify each potable water source by assigning a location name and indicating, if known, the proximate distance to the nearest APEC previously identified. Surface water bodies (in addition to being a potential potable water source) also represent a potential habitat for sensitive receptors. The user should identify the type of surface water body (e.g., lake, river, stream, pond, ocean, ditch) using the drop-down menu, assign a location name, and indicate, if known, the proximate distance to the nearest APEC previously identified. Wetlands, like surface water bodies, represent a potential habitat for sensitive receptors. Types of wetlands vary, but the user is encouraged to characterize the type of wetland using the basic descriptions provided in the screening tool using the drop-down menu. The user should identify each wetland by assigning a location name and indicating, if known, the proximate distance to the nearest APEC previously identified. If, upon the completion of the two tables the user is still on this worksheet (Module 1 Overview Questions), click the yellow button below the Potential Sensitive Receptors table to continue on to the next applicable worksheet. If the user is on another worksheet, then do not return to this worksheet, use the yellow button at the bottom of the worksheet to continue to the next worksheet in the screening tool. The output from Module 1 lists the identified APECs and sensitive receptors at the airport. The output is generated and presented in one worksheet, Module 1 Summary, which is divided into two tables: (1) APECs and (2) Sensitive Receptors. The following sections describe how to generate this output. 6.2.1.4 Module 1 Summary Worksheet—APEC Table This summary worksheet describes the APECs identified on-site and off-site in relation to life cycle stage and type of activity. Additionally, with user input, the coordinates of each APEC can be added to allow for APECs to be geo-referenced on a map (as presented in the GIS Summary worksheet). To generate the list of APECs, click the button labeled Press to Start at the top of the worksheet before entering any data on this worksheet. The table will self-populate with the location name

78 Use and potential Impacts of aFFF Containing pFaSs at airports provided for the APEC, its associated life cycle stage, and the type of activity. If using the compat- ibility version of the tool, press Crtl, Shift, and F to activate the macro that populates the table appropriately. In order to further characterize the APEC associated with current operations or a legacy envi- ronmental impact, users should answer the question posed in the column to the right of the “Type of Activity” column for each APEC (i.e., Is the APEC associated with past release into the environment?) using the drop-down list provided. Please note that for some activities, the corresponding cell is pre-populated based on previous input data (in an effort to make using the screening tool more efficient). If the user has knowledge that calls into question the pre-populated answer for a particular APEC, the response in the cell can be changed using the drop-down list. For example, if AFFF was stored in Hangar 4, the cell will be populated with the answer “No” because, in most cases, storage locations are not involved with releases of AFFF into the environ- ment. However, if AFFF was spilled at the storage location or a storage container was leaking, the user should switch the answer to “Yes” so that on a subsequent worksheet the user will be prompted to provide more information about the release (see Figure 6-7). To generate a data table suitable for using in GIS and mapping the location of APECs (as discussed below), enter latitudes and longitudes of identified APECs in decimal degrees in the columns on the right. The “Location Name for GIS” column is populated with the name chosen for the APEC or sensitive receptor when it was first identified. In order to use these location names in ArcGIS, however, special names that don’t include spaces are required. The MAPA user or a GIS specialist should replace the location names with those that are appropriate for ArcGIS (e.g., Hangar 4 could become Hangar_4) in the first column (“APEC”) of the table. Visual representation helps identify potential omissions with regard to both APECs and sensitive receptors and fosters the development of a CSM, which can be used to understand and address legacy impacts of PFASs at the airport. In addition, from a capital project planning Figure 6-7. Screenshot of the APEC table on the Module 1 Summary worksheet.

Screening tool Guidance 79 perspective, understanding where impacts of PFASs in soil and groundwater may be present is important because special handling, treatment, and/or disposal may be required (potentially at significant cost) for soil and groundwater impacted by PFASs (e.g., dewatering). See Figure 6-8 for an example of a completed APEC table. 6.2.1.5 Module 1 Summary Worksheet—Sensitive Receptors Table The Module 1 Summary Worksheet Sensitive Receptors table summarizes all the sensitive receptors identified previously based on the type of receptor (see Figure 6-9). Figure 6-8. Screenshot of a completed and compiled APEC table. Figure 6-9. Screenshot of the Sensitive Receptors table on the Module 1 Summary Sheet prior to data retrieval.

80 Use and potential Impacts of aFFF Containing pFaSs at airports Click the button labeled Press to Start at the top of the worksheet before entering any data in this worksheet. This worksheet will self-populate with the type of receptor and the location name provided for the sensitive receptor. (See Figure 6-10.) 6.3 Module 2—APEC Scale Evaluation Module 1 of the MAPA Screening Tool compiles a list of identified APECs and sensitive receptors. Module 2 facilitates a detailed desktop characterization of each APEC identified in Module 1. Module 2 also provides a ranking associated with each APEC to facilitate making relative comparisons and prioritizing future action, i.e., either focusing resources on select APECs or evaluating the overall effect of applying best management practices at a given APEC. Finally, Module 2 identifies potential data gaps associated with developing a CSM and having a holistic understanding of potential issues associated with historical and current uses of AFFF and other potential sources of PFASs. Module 2 specifically focuses on the following: • Characterizing operational APECs based on their respective AFFF life cycle stage. • Characterizing legacy environmental impacts based on release characteristics and site attributes. • Ranking each APEC for relative comparison. • Identifying data gaps required for further consideration. The outcomes of Module 2 may include the following: • Characterization of operational and environmental legacy APECs. • Ranking of each APEC. • Identification of data gaps needed for additional understanding of the concerns regarding AFFF and PFASs at an airport. • Identification of appropriate management practices that, if implemented, may reduce an APEC’s prioritization ranking. 6.3.1 Entering Module 2 Information Module 2 consists of four worksheets, divided into four categories: operational APECs, legacy APECs, ranking summary, and data gap identification. Operational APECs are characterized via Figure 6-10. Screenshot of a completed and compiled Module 1 Summary Sheet listing sensitive receptors.

Screening tool Guidance 81 individual worksheets for each of the following AFFF life cycle stages: storage, use, maintenance, and disposal (discussed further in Section 6.3.1.1). The balance of this section walks the user through each step (i.e., worksheet) of Module 2. 6.3.1.1 Detailed APEC Characterization Upon completion of Module 1, the user will be prompted to consider further questions associated with each APEC that allow for detailed characterization and relative ranking of each APEC. For operational APECs, questions relate to each of the AFFF life cycle stages: specifically, how AFFF is stored, used (including testing, training, and emergency response), and disposed of and how equipment and infrastructure used for distribution and application are maintained and cleaned. For legacy APECs, questions focus on release characteristics, presence of co-mingled contaminants, surface covering, and exposure pathways. Operational APECs Module 2 has a worksheet for APECs (Mod 2 Ops APECs) identified in each operational life cycle stage from Module 1. To initiate the characterization of each APEC identified for each operational stage, click the Press to Start button in the upper left hand side of the screen and the worksheet will automatically populate the table with the names of APECs identified in Module 1 (shown in Figure 6-11). If using the compatibility version of the tool, press Crtl, Shift, and A to activate the macro that populates the table appropriately. For each APEC, the user enters responses to each question on the left using the drop-down lists. Once entered, a score associated with each response will populate the cell to the right of the response. This score is used, in summation with other scores for each APEC, to rank the APEC. Ranking and prioritization are discussed in detail in Section 6.5. Users can perform their own sensitivity analysis by changing their responses and seeing how different inputs affect the APEC ranking. This sensitivity analysis may then be considered in evaluating implementation of future operational and management practices. The final row will contain a score for that life cycle stage and APEC. Once all the questions are completed for all the locations on the worksheet the user is on, the yellow cell at the bottom of the worksheet can be clicked to continue on to the next worksheet. Figure 6-11. Life cycle stage scoring on the Mod 2 Ops APECs worksheet.

82 Use and potential Impacts of aFFF Containing pFaSs at airports The questions posed on the Operational APECs worksheets are mostly related to best manage- ment practices: • Storage. Questions posed are focused on how AFFF is being stored at the airport and whether there are any inherent risks with the storage methods in place. If containers are currently leak- ing or have leaked in the past, the user should identify the location as having a historical release (that could have resulted in a release to the environment, i.e., legacy). The following describes potential responses associated with the drop-down list. Users should enter the response most representative of the condition associated with each APEC: – Covering ▪ Enclosed: AFFF storage container(s) are inside a fully enclosed space (four walls and a ceiling). ▪ Covered: AFFF storage container(s) are covered from above but are exposed to the elements from the side (e.g., covered by a tarp or located in a building with no walls). ▪ Outside or exposed directly to the elements: There is no covering of the storage container(s) (e.g., stored on the edge of a runway). – Containment ▪ Double: Storage containers have (at least) secondary containment in addition to the original manufacturer-provided container. ▪ Single: AFFF is stored only in the container in which it arrived from the manufacturer. – Flooring ▪ Paved: Uncracked paved flooring (e.g., asphalt, concrete). ▪ Slightly cracked pavement: 0 to 25 percent of the pavement is cracked or broken. ▪ Moderately cracked pavement: 25 to 50 percent of the pavement is cracked or broken. ▪ Heavily cracked/broken pavement: More than 50 percent of the pavement is cracked or broken. ▪ Earthen: The flooring is not paved and is soil and/or gravel in nature. • Use (Application). For the purpose of MAPA, the Use life cycle stage includes training, testing, and emergency response. Questions for this stage relate to how much AFFF is used, what is done with the waste AFFF, and what PPE is used when handling AFFF. The follow- ing describes potential responses (i.e., drop-down list) associated with select questions. Users should enter the response most representative of the condition associated with each APEC: – Amount of AFFF used: There are many options in this drop-down list as the amount of AFFF used will vary significantly with the different uses. For example, the amount of AFFF used in a foam test is expected to be significantly less than the amount used to sup- press a fire. – Ultimate receiver: Potential responses are listed below. If the ultimate receiver is one of the first four listed, the user should identify the APEC in Module 1 under historical operations: ▪ Washed down a drain/sewer. ▪ Allowed to soak into ground. ▪ Evaporated from pavement. ▪ Washed into a surface water body/wetland. ▪ Disposed off-site by licensed facility. – PPE: AFFF poses inhalation, dermal, and ingestion hazards to those handling the solution; therefore, PPE should be used to minimize potential health effects. This question asks how many types of PPE are regularly used when handling AFFF. Using all the PPE listed is considered ideal because it provides mitigation to the various exposure pathways. – Exposure contact: AFFF poses human health risks; therefore, this category is focused on identifying whether people are being exposed to AFFF without PPE and, if they are, how frequently, as long-term exposure increases the potential health risks.

Screening tool Guidance 83 • Maintenance. Maintenance of vehicles and deluge systems may result in handling and spills of AFFF. Questions for this stage relate to the frequency of AFFF equipment maintenance, the types of equipment cleaning agents, how AFFF is removed from the equipment, how the equipment is cleaned, and what is done with AFFF removed from the equipment. The following describes potential responses (i.e., drop-down list) associated with select questions. Users should enter the response most representative of the condition associated with each APEC: – AFFF equipment checks: Checking AFFF equipment is a good preventative measure against accidental releases as cracks and corrosion can be identified and resolved before a release occurs. Depending on the jurisdictional regulations for the airport and the frequency of incident response, AFFF and its equipment may not be in regular use; therefore, it may be worthwhile to add checking equipment for malfunctions to airport procedures. – Removal of AFFF from equipment: While for the most part AFFF is left in deluge systems and firefighting trucks after a single use, it may be removed when conducting maintenance on equipment or switching brands of AFFF solution to prevent coagulation. Methods for removal include ▪ Mechanical pump: Lowest level of risk as this provides the most control and consistency in the speed of AFFF removal. ▪ Manual pump: The risk with this method is a bit higher than with a mechanical pump as there is more room for human error and inconsistent speeds in AFFF removal, which could result in splashing and spills of the AFFF solution. ▪ Gravity/drain valve: This method provides the least amount of control over the speed and direction of the AFFF solution and is therefore associated with the highest risk of spilling or splashing the solution on workers. – Cleaning equipment: While for the most part AFFF is left in deluge systems and firefight- ing trucks after a single use, it may be removed when switching brands; cleaning out the equipment at this point is common to reduce the risk of residue from the previous brand. Cleaning may involve ▪ Rinsing/flushing with water: Rinsing with water implies that clean water (not gray water) is used to flush out build-up/residue in the equipment. ▪ Cleaning with water and soap/detergent: Clean water (not gray water) and a soap or detergent is used to remove build-up/residue in the equipment. ▪ Rinsing/flushing with a solvent: Due to the chemical nature of PFASs, cleaning equip- ment with an alcohol solvent, such as ethanol, is considered the most effective method of removing AFFF traces from distribution systems. – Handling procedures: Handling procedures are strong risk reduction measures when clearly communicated to all those involved in the AFFF life cycle. Methods included in the MAPA Screening Tool are two or more people involved in the handling of AFFF, clear procedural standards for AFFF use and handling, procedural training for those handling AFFF, and ensuring fittings and connections are tight on all AFFF-related equipment. – Ultimate receiver: Potential responses are listed below. If the ultimate receiver of AFFF rinsate and/or AFFF removed from distribution systems is one of the first four listed below, the user should identify the APEC in Module 1 under historical operations: ▪ Washed down a drain/sewer. ▪ Allowed to soak into ground. ▪ Evaporated from pavement. ▪ Washed into a surface water body/wetland. ▪ Disposed off-site by licensed facility. • Disposal. The location of AFFF (as either concentrate or as a mixed formulation) is disposal greatly impacts the potential risk to human health and the environment. A large quantity of AFFF concentrate returned to the manufacturer will not have the same impact as a small quantity of AFFF released directly into a surface water body. Question posed are used to gain

84 Use and potential Impacts of aFFF Containing pFaSs at airports a sense of the quantity of AFFF being disposed of and the location of the ultimate receiver of the disposed AFFF. Module 2 Legacy APECs Worksheet Within Module 2, there is a worksheet for APECs identified as legacy, i.e., historical activities that resulted in a release to the environment. On the Module 2 Legacy APECs worksheet, questions are posed to understand the nature of the release, whether other contaminants may have been present that would affect the fate and transport of PFASs in the environment, surface covering, and exposure pathways. To initiate the characterization of each legacy APEC, click the Press to Start button in the upper left hand side of the screen, and the worksheet will automatically populate the table with the names of APECs identified in Module 1. If using the compatibility version of the tool, press Crtl, Shift, and B to activate the macro that populates the table appropriately. For each APEC, enter responses to each question on the left using the drop-down lists. Once a response is entered, a score associated with that response will populate the cell to the right of the response (see Figure 6-12). This score is used, in summation with other scores for each APEC, to rank the APEC. Ranking and prioritization are discussed in detail in Section 6.5. The last row will show a score for that APEC. Once a user has completed all the questions for all the locations on the worksheet they are on, they should click the yellow cell at the bottom of the worksheet to continue onto the next worksheet. The following describes potential responses (i.e., drop-down list) associated with select ques- tions on the Module 2 Legacy APECs worksheet. Users should enter the response most repre- sentative of the condition associated with each APEC: • Release characteristics. Questions in this area are meant to determine the basic facts of the AFFF release. AFFF concentrate is diluted to make the AFFF solution that is actually used for Figure 6-12. Scoring on the Module 2 Legacy APECS worksheet.

Screening tool Guidance 85 firefighting activities; therefore, this question includes the mass of AFFF released in the assess- ment of risk. Timing of the release is important for the migration of AFFF in the environment and the type of PFASs contained in the AFFF, as different compositions were used prior to and after 2010. • Co-mingle contaminants. PFASs behave differently in the natural environment when released at the same time as petroleum hydrocarbons (PHCs) or into soils impacted by PHCs; there- fore, the presence of PHCs increases the risk of a potential concern. • Surface covering. Surface covering at the release location will influence the way that PFASs could potentially interact with sensitive receptors; overland flow could result in AFFF entering surface water bodies, while infiltration may result in AFFF in groundwater supplies. • Exposure pathways. In combination with the questions posed about the surface covering at the release location, the questions associated with the topic of exposure pathways are designed to gain a preliminary understanding of the likelihood that AFFF is interacting with sensitive receptors. 6.4 Data Gaps The MAPA Screening Tool has been designed to preliminarily screen APECs associated with AFFF and other sources of PFASs and to provide utility as a data gap identification and analysis tool. Some of the questions in the MAPA Screening Tool, however, may be difficult for an airport to answer or address because the necessary information may not be readily available. For operational APECs, information may need to be provided by multiple departments in the airport and/or tenants. For legacy APECs, information may be available via previously conducted environmental site investigations or publicly available databases to address questions for which there is not a readily available response. The MAPA Screening Tool allows users to flag questions to which they do not know the answer (e.g., entering a “Don’t Know” response). Data gaps related to potential legacy envi- ronmental impacts (i.e., impacts of PFASs in environmental media such as soil, groundwater, sediment, or surface water) will be identified. A detailed CSM that identifies potential sources, exposure pathways, and receptors and includes a comprehensive understanding of the site’s subsurface stratigraphy, hydrogeology, hydrogeochemistry, hydrology, and impacts of the fate and transport of PFASs will ultimately be needed to fully understand potential risks to human health and the environment. The MAPA Screening Tool does not create the CSM, but the data gap tool allows the user to inventory available information (and missing information) that would be required to develop a CSM in the future, if needed. The MAPA Screening Tool includes a Data Gaps worksheet that allows the user to identify whether they have information pertinent to developing a rigorous CSM, including the following (see Figure 6-13): • Land use and zoning for on- and off-site properties (agricultural, residential, commercial, and industrial). • Soil conditions (e.g., soil texture, soil type, soil depth, soil chemistry). • Geological conditions (e.g., depth to bedrock, type of underlying rock, till). • Hydrogeological conditions (e.g., groundwater depth, flow rate, flow direction, chemistry). • Surface water and sediment conditions (e.g., flow rate and direction, depth, hydrodynamics, substrate type, water and sediment chemistry, drainage patterns and systems, surface runoff patterns). • Topographic features (e.g., elevation and gradient). • Local climatology and meteorological conditions.

86 Use and potential Impacts of aFFF Containing pFaSs at airports • Potential preferential migration pathways or conduits for PFASs (e.g., former or current trenches, ditches, underground piping, and wiring). Information not available would be considered a potential data gap or uncertainty. 6.5 APEC Prioritization MAPA has been designed to rank each APEC based on the characteristics identified in Module 2. Scoring, whether for individual responses or for APECs as a whole, generally rep- resents an increasing potential for unacceptable risk to human health and environment as the values increase, i.e., the lower the score, the less the concern, and the higher the score, the greater the concern. Scoring is for comparative purposes only, and the absolute number has no meaning other than contextual. Attachment A of Appendix C lists the questions asked in Module 2, scores associated with each response, the maximum score, and the calculations used to calculate the overall score for applicable life cycle stages. 6.6 Closing The MAPA Screening Tool has been designed for airport representatives familiar with AFFF management and impacts of PFASs at the airport. The screening tool can assist airports in identi- fying and characterizing APECs on or near an airport, accounting for both historical and current use of AFFF and other sources of PFASs. The MAPA Screening Tool has been designed so that users can rely on readily available information to complete the screening effort. Should APECs Figure 6-13. Site features/settings as part of a CSM in the Module 2 Data Gaps worksheet.

Screening tool Guidance 87 be identified that require further investigation, airports should engage environmental consultants and contractors with experience and expertise in AFFF and PFASs. The results that can be produced by use of the MAPA Screening Tool are the following: • Identification of APECs on and adjacent to airport property. • Identification of potential sensitive receptors on and adjacent to airport property. • Collection of information needed to create GIS maps for visualization of APECs, sensitive receptors, and exposure pathways. • Production of a preliminary ranking of potential concern for operational and legacy APECs. • Identification of gaps in data needed for future in-depth analysis of AFFF impacts for each APEC. The information resulting from the completion of the MAPA Screening Tool allows for documentation of potential liabilities and risk and planning for the future. The MAPA Screening Tool can be used • As a summary of information that the airport has regarding the life cycle of AFFF. • To rank areas of handling/use of PFASs by potential risk, allowing airport managers to pri- oritize efforts to mitigate/manage PFASs and plan for future capital expenditures. • As a first step in the remediation of APECs for future development or changes to the airport property, in consultation with an AFFF remediation specialist. • To identify operational practices that would decrease the potential environmental impacts associated with AFFF use. Note that the MAPA Screening Tool is a preliminary desktop assessment of potential impacts and should not replace the consultation of a professional with experience in AFFF management and assessment and remediation of PFASs, depending on need.