Airport PFAS Information

PFAS Information Page

Welcome to the Per- and polyfluoroalkyl substances (PFAS) information page for the Dane County Regional Airport (DCRA). Here you will find information regarding PFAS and DCRA's ongoing efforts related to investigation, mitigation and remediation. This page is will help answer your questions regarding PFAS at DCRA and let you know of any upcoming public meetings. PFAS is a problem that airports and cities across the nation are working to resolve. DCRA and Dane County are committed to working with its partners on the local, state, regional and national levels to develop sound policies and apply the best science to the challenge of removing PFAS from the environment.  

Below is a video presentation created by Dane County and DCRA consultant Mead & Hunt explaining PFAS history, testing and mitigation. The presentation highlights the Dane County Regional Airport, the historical use of PFAS, and the investigation and remediation process. All work plans and testing results are submitted to the Wisconsin Department of Natural Resources (WDNR). They can be found on their Bureau for Remediation and Redevelopment Tracking System (BRRTS) website: https://dnr.wi.gov/topic/Brownfields/botw.html.

BRRTS Case Numbers
02-13-584472 – DANE CNTY REGIONAL AIRPORT
02-13-581254 – WANG-115TH FIGHTER WING
02-13-583366 – DANE COUNTY FIRE TRAINING AREAS
02-13-584369 – STARK WEATHER CRK TRUAX FIELD
02-13-585319 – WANG F35 BUILDING CONSTRUCTIONS
07-13-586274 – DANE CNTY REGIONAL AIRPORT (FedEx Construction)
 
PFAS Site Activity Summary:
(as of May 2021)
 

Updates

6/29/21 - Mead & Hunt provides the DNR with Dye Test results conducted on Starkweather creek.  Results can be found on the BRRTS website: https://dnr.wi.gov/topic/Brownfields/botw.html.

6/3/21 - The 115th Fighter Wing and Wisconsin National Guard provided an update and overview of their Remdial Investigation (RI) to the Dane County Board. You can watch that update here.

  • The Air National Guard Readiness Center selected Truax Field and Volk Field as two of the ten bases across the nation to receive a RI for PFAS. It is very fortunate that Truax was selected as the DOD has over 100 sites around the country with PFAS contamination and they tend to prioritize areas that have drinking water levels above the 70 ppt standard. Dozens of DOD sites in other states have drinking well levels above the 70 ppt standard and the DOD provides alternative water sources at those sites. No drinking wells in Madison were above that level and none of the wells are even above the lower level being proposed by the WI Department of Health Services. https://madison.com/wsj/news/local/environment/madison-water-utility-finds-pfas-in-every-well-levels-below-proposed-state-heath-guidelines/article_dd118ff7-06a0-5857-88f3-49141fc20cad.html
  • The RI is a multi-year effort coordinated by the U.S. Army Corps of Engineers that involves collecting data to characterize site conditions, determine the nature and extent of PFOS/PFOA, assess the exposure pathways to potential receptors, and assess risk to human health and the environment. During the RI, information necessary to adequately characterize the site for the purpose of developing and evaluating effective remedial alternatives will be collected. This information is critical for determining the most effective long-term cleanup remedies. You can see more information about the DOD timeline and process here: https://dma.wi.gov/DMA/pfas-actions/115FW_PFAS_FINAL.pdf

5/28/21 - DNR begins 30-month rulemaking process for establishing limits regarding PFAS.

5/10/21 - Mead & Hunt began an inspection of areas of the storm sewers in which elevated PFAS concentrations were detected to determine repairs needed to reduce PFAS-contaminated groundwater entering the system.  Based on inspection results, corrective actions such as slip lining and grouting will be taken later in the year.  Thereafter, additional testing will occur to measure the effects in the Creek. 

2/3/21 - Kick-off coordination meeting between the Wisconsin National Guard, Dane County Regional Airport, and the Wisconsin DNR for the Remidal Investiagion (RI) process.

12/15/20 - The second phase of storm water sampling results and the fire training area sampling results have been posted to the BRRTS website under the case numbers 02-13-584472 and 02-13-583366. Responsible parties are currently collaborating with the Wisconsin DNR and Mead & Hunt on next steps.

10/7/20 - Submitted questions from 8/19/20 - 9/2/20 and the responses have been posted to this web page. You can find the PDF document below the FAQ section. 

10/6/20 - Questions submitted from 8/19/20 - 9/2/20 are still under review and responses will be posted as soon as they are complete. 

9/3/20 - Thank you to all that submitted questions. The questions submission form is now closed. We anticipate having the questions and responses posted to the FAQ section the week of September 14th.  

8/19/20 - Linked at the bottom of the web page is a public question submission form. Click "Submit a Question" and fill out the form. We will be accepting questions on PFAS at DCRA from 8/19/20 to 9/2/20. Please keep your questions specific and related to PFAS at DCRA so we can provide accurate responses. Review the information provided on this page to see if your question has already been answered. Submitted questions and the respective responses will be added to the FAQ section below. 

DCRA Video Presentation

DCRA Informational Document (PDF)

Additional Resources 

US Environmental Protection Agency (EPA) PFAS page - https://www.epa.gov/pfas

Interstate Technology Regulatory Council (ITRC) - https://pfas-1.itrcweb.org/

CDC PFAS Factsheet - https://www.cdc.gov/biomonitoring/PFAS_FactSheet.html

Agency for Toxic Substances and Disease Registry - https://www.atsdr.cdc.gov/pfas/index.html

US Food & Drug Administration PFAS page - https://www.fda.gov/food/chemicals/and-polyfluoroalkyl-substances-pfas

Wisconsin Department of Natural Resources https://dnr.wi.gov/topic/Contaminants/PFAS.html

Wisconsin Department of Health Services - https://www.dhs.wisconsin.gov/chemical/pfas.htm

Public Health Madison & Dane County - https://www.publichealthmdc.com/environmental-health/environmental-hazards/per-and-polyfluoroalkyl-substances-pfas-1

City of Madison - Madison Water Utility - MadisonWater.org/PFAS

FAQs

Q: Why does the DCRA still use firefighting foam with PFAS? When will DCRA stop using it?
A:
 The Federal Aviation Administration (FAA) regulations continue to legally mandate that airports use a firefighting agent containing PFAS known as Aqueous-Film-Forming Foam (AFFF) for real-life emergencies. FAA believes AFFF is the most effective chemical available to quickly extinguish aircraft fires and save lives. Due to AFFF’s environmental impact, Congress directed the FAA to change its regulations and allow airports to use alternative foam by October 2021.

Q: Do training exercises with the firefighting foams containing PFAS still happen at the airport?
A:
No. FAA requires yearly testing of the Aircraft Rescue & Firefighting (ARFF) vehicle fire systems. This test is to ensure that the fire system is producing the correct mixture of foam and water. Testing the system is an integral part of keeping ARFF vehicles in optimal condition for emergency response. In 2019, the FAA created an exemption to this rule, allowing ARFF agencies to use testing equipment that does not require dispensing the foam. The Wisconsin Air National Guard (WI ANG) provides ARFF services to DCRA, and currently uses this equipment. Before this exception, AFFF was contained and disposed of safely when these tests occurred. There were also two historical burn pits at the airport that have not been used for multiple years. The period and use of these burn pits are currently being investigated. 

Q: Who used the fire training areas over the years?
A:
This question is currently being investigated. It is generally known that various firefighting organizations in the Dane County area used the burn pits for training.

Q: Are the fire training areas a source of PFAS contamination?
A:
We don’t know at this time. Investigation of the soils and groundwater in the area of the former burn pits is currently underway. Also, developing an understanding of the historical use of the burn pits, including the extent to which PFAS-based foam was sprayed in the fire pits, will assist in answering this question.  

Q: Was the DCRA cell phone lot constructed over the Darwin Street fire training area?
A:
The evidence to date indicates the answer is no. The County of Dane (County) and its partners are currently investigating the Darwin Street fire training area, which is located near the cell phone lot.

Q: Has the County completed all of the testing and sampling?
A:
 No. Further sampling and other investigation processes are planned and ongoing to refine our understanding of the PFAS sources to continue developing mitigation cleanup strategies. These plans include investigation of the historical fire training areas and further investigation of the stormwater system.

Q: Does all of the testing need to be completed before any mitigation happens?
A:
No. The County is taking immediate action at one of the “hotspots” found in the sampling earlier this year with a pilot project to remove PFAS from the stormwater system. The pilot includes continuous testing to evaluate whether the technology being used is successful. If the results are promising, DCRA will expand the use of this new technology to other areas of the airport property where PFAS has been detected.
 
Q: Is the state working to create legal standards for PFOA and PFOS for groundwater, surface water, and drinking water? Where can I get information on that?
A:
Yes. In October 2019, the Wisconsin Department of Natural Resources (WDNR) started the rulemaking process to develop legal standards for Wisconsin. The rulemaking process can take up to three years. You can get more information on how that process is going at the following WDNR websites: 
Q: Where can I find the current mitigation plans and sampling results from testing done so far at the Dane County Regional Airport?
A:
You can find the stormwater investigation work plan and stormwater sampling results by going to the WDNR Bureau for Remediation and Redevelopment Tracking System (BRRTS) site and searching for investigation number 02-13-584472. The fire training areas’ work plan can be found by searching for investigation number 02-13-583366. To start the search, go the following WDNR website: dnr.wi.gov/topic/Brownfields/botw.html.  

Q: Where is the PFAS detected in the DCRA stormwater system originating?
A:
We don’t know precisely at this time. Waters in the stormwater system have been sampled at various locations, and various concentrations have been detected. It will take additional sampling and likely further investigation to determine the origin of PFAS.

Q: PFAS contamination is discharging from the DCRA stormwater system into Starkweather Creek.  What is being done to stop that discharge?
A:
DCRA has implimented a pilot project to capture and remove PFAS contamination at the location where the highest PFAS concentrations have been detected. The pilot project is implementing a technology called bioavailable absorbent media (“BAM”). Based on previous pilot tests using the technology in Michigan, the hope is that the BAM will significantly reduce the PFAS concentrations.

Q: Is the WI ANG working with the County to clean up the Airport site?
A:
Yes. The County is working in cooperation with the WI ANG and City of Madison. The County is leading several concurrent activities to address the PFAS contamination discovered at and near the Airport and meeting regularly with the WDNR to develop plans to address PFAS at the Airport. 

Q: The Airport Joint Use Agreement (AJUA) is up for renewal. Can members of the public get a copy of the initial draft when it is prepared by the State and Federal Government and submitted to DCRA? 
A:
No. It is in draft form and subject to further negotiations. Nonetheless, the public will get an opportunity to provide input about the AJUA. When received by DCRA, the draft AJUA will be a preliminary working document that will likely be subject to significant revisions by DCRA and the State and Federal Government. After DCRA and the State and Federal Government reach concurrence with respect to the contents of the AJUA, and well before it becomes a basis for the relationship between DCRA and the State and Federal Government, the document will be made available to the public and taken up during the public deliberations of the Dane County Airport Commission, two standing committees of the Dane County Board of Supervisors, and the County Board itself. Based on the foregoing, DCRA has determined that it will maintain its past practice of not releasing versions of the AJUA until discussions between DCRA and the State and Federal Government have resulted in a comprehensive document that is ready for consideration by the Dane County Board, its committees, and the Airport Commission.
 
Q: Can the county use the Airport Joint Use Agreement (AJUA) to force the WI ANG to clean up PFAS before they build any new structures at the airport? 
A:
No. The DNR is the agency working with the WI ANG on how to proceed with building projects on the Guard Base and regulating management of soils and other media containing PFAS through material management plans (MMPs). The DNR recently approved MMPs for the F-35 flight simulator facility and other construction.  Last month the WI ANG announced they awarded the contract for the flight simulator facility to Findorff. The 18-month project will begin this May and you can find that detailed here.
 

Q: Can the county stop the WI ANG from doing any construction at the airport through the lease or AJUA? 
A:
No.  The Guard has the right to use the airport under federal law and under the deed of conveyance by which Dane County obtained the property. The lease grants the Government the right to attach fixtures and erect structures during the lease term.  Neither the lease nor the AJUA grants the County rights to oversee or regulate the Government’s construction activities.

Q: What is the AJUA for then? 
A:
The AJUA is an agreement with the United States of America acting through the National Guard Bureau and the state of Wisconsin that details responsibilities for jointly used flying facilities and includes the WI ANG’s commitment to provide FAA-required firefighting services as part of their partnership with the airport.

Q: If the county doesn’t renew AJUA with the Guard does that mean they can’t use the airport for their fighter jets or bring the F-35s to Truax? 
A:
No. The Guard will continue to use their base without having the AJUA in place.  If the Guard elected to stop providing FAA-required firefighting services to the airport, the airport would have to arrange for those services at substantial additional expense.

Q: Why doesn’t Dane County just stop having the WI ANG do fire services and have the county provide the service or contract with the Madison Fire Department to do it? 
A:
In order to comply with FAA regulations the county would have to build another fire station and acquire all of the equipment necessary to have 24/7 fire services available, which would costs tens of millions of dollars initially and then millions more in payroll to have the fire station staffed 24/7 with the minimum staffing levels required by the FAA. The trucks would also have to be filled with firefighting foam with PFAS because it is still required by the FAA. The WI ANG would still maintain their fire station, which would result in the DCRA having two sets of fire trucks with PFAS foam on site. The Madison Fire Department cannot provide the service fast enough to meet FAA regulations and the city recently made the decision to get rid of their PFAS foam so they would no longer have any trucks that could even service the airport.

Q: Why does this process take so long? 
A:
PFAS are an emerging contaminant and there is still much being learned about the best cleanup strategies. Environmental cleanups of this scale take time, but the Biden Administration and Congress have indicated they would like to see this move faster. This is a shift from the last administration and should bring additional resources both to research and mitigation. Action has started at the federal level that could help speed resources to address PFAS. The House Armed Services Committee has created an entire subcommittee on remediation and impact of PFAS at DOD sites, a bipartisan caucus in the House of Representatives has recreated a PFAS taskforce, and President Biden has pledged to designate them a hazardous substance with standards and accelerated research timelines.

Q: Where can I find more information about what the WI ANG is doing on this issue? 
A:
They maintain an informational webpage here: https://dma.wi.gov/DMA/pfas and a timeline of their activities here: https://dma.wi.gov/DMA/pfas-actions/115FW_PFAS_FINAL.pdf

Q: Was the Airport’s cell phone lot was constructed over a historic burn pit? 
A:
No. The historic burn pit in the vicinity of Darwin Road is entirely separate from the cell phone lot, which is accessed from International Lane.   
 

 

Submitted PFAS Questions 8/19/20 - 9/2/20 (PDF)