In March 2019, the California State Water Resources Control Board (State Water Board) issued Order WQ 2019-0005-DWQ (Order), which requires certain airports, including Buchanan Field Airport, to (i) conduct a “one-time preliminary site investigation” regarding the storage and use of Per- and Polyfluoroalkyl Substances (PFAS), and (ii) obtain a preliminary understanding of PFAS concentrations in soil and/or groundwater resulting from the use of PFAS at the airport. PFAS is a family of more than 3,000 man-made and mostly unregulated chemicals that are resistant to degradation in the environment. PFAS are manufactured globally and have been used in the production of many industrial and household products such as dental floss, non-stick cookware and products, waterproof products, cleaning products, and fire-fighting foams. The Order applies to Buchanan Field because Buchanan Field operates pursuant to 14 CFR Part 139. As a result of the Order, the County is required to submit a one-time investigation work plans (Work Plan) to the local Regional Water Quality Control Board (Regional Water Board).
The contract that is the subject of this Board Order will enable Mead and Hunt to perform Phase 2 of the County’s compliance with the Order. Phase 1 was completed through a contract with Mead and Hunt dated April 15, 2019. Under that contract, Mead and Hunt prepared the Work Plan for Buchanan Field Airport which was submitted to the Regional Water Quality Control Board before the required deadline. Under the contract that is the subject of this board order, Mead and Hunt will conduct the planning, environmental, sampling, and legal support services needed to implement the Work Plan and final report.
The County’s use of PFAS at Buchanan Field is not optional. It is mandated by the Federal Aviation Administration (FAA), which requires airports with Part 139 certifications to provide aircraft rescue and firefighting (ARFF) services using aqueous film-forming foam (AFFF) that meets military specifications (MIL-PRF-24385) (MilSpec) which must include PFAS constituents. Not only must Part 139 airports have such AFFF available, FAA mandates that airport operators test and calibrate their equipment to ensure proper operation in case of an emergency. Part 139 airports have no option but to comply with FAA’s mandates in order to maintain their operating certificates.
If the Airports Division does not engage a team to implement the work plan, it will be non-compliant with the Regional Water Quality Control Board requirements and could be subject to a daily fine (up to $5,000) and criminal penalties.