Preliminary Assessment Aqueous Film-Forming Foam Use Portland International Airport Portland, Oregon

Transcription

1 Preliminary Assessment Aqueous Film-Forming Foam Use Portland International Airport Portland, Oregon Prepared for: Port of Portland August 3,

2

3 Table of Contents Executive Summary Introduction Background Purpose Report Organization PDX Fire Stations Original Fire Station Areas Current Fire Station Area PDX Fire Training Facilities Original Fire Training Facility ( ) Former Fire Training Facility ( ) Current Fire Training Facility Current and Historic Drainage Previous Environmental Work and Current Conditions Oregon Air National uard (OAN) History Material Use Previous Work and Current Conditions Former PAMCOR Hangar Emergency Response Other Locations Reclaimed Fire Training Facility Water Stationary Fire Suppression Systems Areas of Interest for Further Investigation Port Operated Areas Other s Operational Areas Future Investigations References Table 1 Summary of Current and Historical AFFF Use at Portland International Airport Preliminary Assessment Aqueous Film-Forming Foam Use, Portland International Airport August 3, Page i

4 Figures 1 Site Location Map 2 Site Vicinity Plan 3 Areas of Interest 4 Former Fire Station PDX Drainage Basin and Outfalls, Circa Fire Training Facilities and Current Fire Station Appendices A Safety and Data Sheets B Port Fire Training Facilities Activity Logs, C Figure 2 from OAN PFC PA Site Visit Report Preliminary Assessment Aqueous Film-Forming Foam Use, Portland International Airport August 3, Page ii

5 Executive Summary At the request of the Port of Portland (Port), Apex Companies, LLC (Apex) prepared this Preliminary Assessment (PA) to identify the current and historical uses of aqueous film-forming foams (AFFF) at Portland International Airport (PDX; Figures 1 and 2). The purpose of this PA is to provide a history of locations, materials, and parties involved in the application and use of extinguishing agents containing per-and polyfluoroalkyl substances (PFAS) during fire training operations, testing, or emergency response; the Port s storage, transfer, and disposition of fire-fighting chemicals, including AFFF and earlier chemical formulations; and the location of any other historical use areas at PDX, including those that may have been operated by parties other than the Port. Some extinguishing agents, specifically AFFF, contained PFAS. PFAS are resistant to heat, oil, and water, making AFFFs with PFAS especially effective in fighting petroleum fires. AFFFs are water-based foam used in building fire suppression systems and by firefighters to prevent, control, and extinguish flammable and combustible liquid fires. Perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) have been the primary PFAS historically used as agents in AFFF and were the PFAS produced in the largest quantities within the United States. AFFF products historically manufactured by the 3M Company were the main source of foam products containing electrochemical fluorination (ECF) produced perfluorinated surfactants, such as PFOS. The 3M Company was the only producer of PFOS and PFOS-related compounds in the United States. The 3M Company completed a voluntary phase-out of ECF produced perfluorinated compounds (e.g., PFOS and PFOA) production by 2002 (Seow, 2013 and Tyco, 2016). All other manufacturers used the telomerization process to produce chemical components of the fluorsurfactants contained in their AFFF. These formulations of foam contained telomers, compounds that can break down into PFOA and other PFAS. The manufacture and import of PFOA has also been phased out in the United States as part of the January 2006 global 2010/2015 PFOA Stewardship Program to phase out PFOA and PFOA-related chemicals by Participating companies in the PFOA phase-out include the 3M Company, DuPont, Arkema, and several others (EPA, 2017). Due to their widespread use, not just for firefighting chemicals, and their persistence and resistance to typical environmental degradation processes, PFOS and PFOA are distributed worldwide in air, soil, surface water, groundwater, rainwater, ice caps, plants, and animal tissue. The U.S. Environmental Protection Agency (EPA) has determined that the toxicity, mobility, and bioaccumulation characteristics of PFOS and PFOA pose potentially adverse effects for the environment and human health. In November 2016, EPA established the lifetime health advisory screening level for drinking water at 70 nanograms per liter (parts per trillion) for PFOS and PFOA combined, which is available at EPA is currently evaluating PFOS and PFOA under the process required by the Safe Drinking Water Act (SDWA). EPA will consider the health effects assessments supporting the health advisories to make a regulatory determination on whether to initiate the process to develop a national primary drinking water regulation. Preliminary Assessment Page 1 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

6 The Port prepared this PA to assess the use of AFFF associated with the fire training facilities and identify areas of interest (AOIs) that may require the Port or other parties to complete assessments of the potential impacts of AFFF use. AFFFs potentially containing PFOS and PFOA have been used at PDX since at least the 1970s. The use of AFFF has included firefighter training, application to fuel spills to inhibit combustion, and in mobile firefighting equipment and stationary systems. AOIs were identified based on repeated AFFF use and potential release to the ground surface. These AOIs include the former and current PDX fire training facilities, the ground area west of the former fire training facility where reclaimed water was applied, former and current PDX fire stations, Oregon Air National uard leased facilities, and the former PAMCOR Hangar (currently leased by Boeing). Other sites identified during the PA process that are not considered AOIs include hangars and buildings that store AFFF in fixed fire suppression systems, and numerous undocumented locations in which AFFF has been applied to fuel spills and through training exercises and equipment maintenance in response to fire suppression protocols. Releases or leaks were not identified in the fire suppression systems and research suggests that PFAS impacts to groundwater are less likely from one-time AFFF use, such as active firefighting or spill response protocols (ATSDR, 2009; SERDP, 2012; ASTSWMO, 2015). Therefore, these locations were not identified as AOIs. During the assessment and investigation of AOIs identified above, other information regarding the use of AFFF at PDX may become available. The Port will update this PA to include any new factual or scientific information that is identified. Preliminary Assessment Page 2 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

7 1.0 Introduction 1.1 Background This Preliminary Assessment (PA) presents the results of a review of current and historical information pertaining to the use of aqueous film forming foam (AFFF) at Portland International Airport (PDX) fire training areas, PDX fire stations (Figures 1, 2, and 3), and other areas at PDX. DEQ requested that the Port prepare this PA to assess the use of AFFF associated with firefighting, including certain per-and polyfluoroalkyl substances (PFAS) present in AFFF that are used to fight aircraft fires. PDX and its fire department are regulated under Federal Aviation Administration (FAA)and National Fire Protection Association (NFPA) regulations and guidance which identify the type, testing, use, and training that is required for lawful use of AFFF. The requirements, codes, and regulations governing the type of AFFF, frequency of live-fire training, and equipment testing protocols at airports has changed during the four decades since AFFF was originally developed and in use. Prior to 2002, the FAA required that airports use AFFF that met Underwriters Laboratory (UL) 162 Standard for Foam Equipment and Liquid Concentrates, but recommended airports provide greater aircraft rescue and firefighting capability. Consequently, Mil-Spec AFFF was the type used at over 90% of military installations and 75% of civil aviation facilities (Darwin, 2004). In accordance with current FAA CertAlert 06-02, Aqueous Film Forming Foam Meeting MIL-F-24385, and CertAlert 11-02, Identifying Mil-Spec AFFF and CFR Title 14 Aeronautics and Space Part 139 Certification of Airports, and concurrence with NFPA Code 403, PDX has been required to store, maintain, and use military-specified AFFF since The requirements for annual live-fire training are directed by FAA Advisory Circular 150/ C Programs for Training of Aircraft Rescue and Firefighting Personnel and the annual requirements for a foam concentration/quality test of applicable fire department vehicles are required by NFPA 414. The volume of AFFF on vehicles and in surplus at PDX are a requirement of NFPA 403. According to personal communication, Mil-Spec AFFF was used at PDX following the FAA Advisory in It is unknown if prior formulations of AFFF procured by the PDX fire department were Mil-Spec. Additionally, live-fire training and equipment testing were completed on a more frequent basis than the current annual requirement at PDX based on personal communications and available records. Details regarding live-fire training and equipment testing are provided in Sections 2 and Purpose The purpose of this report is to compile relevant background information on AFFF and its use at PDX to assist the Port and DEQ in further evaluating the potential impacts of AFFF. In preparation of this report, research conducted by Apex included the following: internet searches to compile chemical and risk-based data on PFAS in AFFF; Preliminary Assessment Page 3 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

8 internet searches to compile regulatory information on PFAS in AFFF; review of historical PDX documents provided by the Port;; and interviews with Port personnel on current and historical purchase and use of AFFF at PDX. 1.3 Report Organization The report sections are divided by location where AFFF may have been stored, used, or released into the environment and include: PDX fire stations, PDX fire training areas, Oregon Air National uard (OAN) facilities, former PAMCOR Hangar, historical spill/fire/crash sites, and all other locations. Where appropriate, current and former utilities in the areas and historical or current environmental investigations are summarized. Locations were identified as areas of interest (AOIs) based on the frequency and duration of AFFF use or the volume of AFFF released to the environment. Table 1 summarizes the chronology and timeline for AFFF use at PDX. This information may be updated or modified periodically as better information is identified. Figures and appendices are ordered as presented in the text.. Preliminary Assessment Page 4 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

9 2.0 PDX Fire Stations 2.1 Original Fire Station Areas History Apex identified former and current Port personnel knowledgeable regarding uses of AFFF by the PDX Fire Department and by the OAN base located on the south side of PDX, and has compiled this information from interviews of those individuals. Two former Port fire stations were located near the west end of present-day Concourse C (see Figure 4 for locations). The first fire station was in operation from 1960 to The second station was located southwest of the original and was in operation from 1972 to Historical activities included firetruck and equipment storage, and, presumably, AFFF and other fire-fighting chemical storage Material Use The Port is unaware of any documents specifying the materials used, stored, or potentially released at the former fire stations. At the current fire stations, the PDX Fire Department performed annual testing of the firefighting foam in the trucks to confirm that the mixture was consistent with the manufacturer-specified concentration. This testing typically occurred on the ramp, most often near the fire stations. It was reported to be a common historical practice to dispose of foam in the equipment lines by washing out the trucks on the ground in the vicinity of the fire stations. Similar practices may have occurred at the original fire stations. During operations at the former fire stations, the materials used for the annual testing included protein-based foams (late-1960s or early-1970s) and then AFFF. The quantity and duration of AFFF use during the annual testing is unknown Current and Historical Site Drainage The former PDX fire stations are located in the current storm water Basin 6. Basin 6 includes the middle of Runway 10R/28L, several taxiways, portions of the airport terminals and parking garage, and the OAN facility, which is owned by and leased from the Port. Drainage from OAN is isolated from the Port-operated areas and passes through a detention basin prior to discharge to the Port system near the Columbia Slough outfall. Basin 6 is primarily a piped drainage system, including approximately 2.7 miles of sub-drains. Drainage from Basin 6 passes through the East Quiescent Basin and the East Detention Pond prior to discharge to the Middle Slough. The total area is 237 acres; 173 acres are impervious. Basin 6 discharges to the Slough via a pump at the East Detention Pond through a 60-inch, Port-owned pipe. Preliminary Assessment Page 5 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

10 During operations at the former PDX fire stations there were storm sewer pipes to the north and south of the fire station, which directed flow to the south through a series of storm water pipes followed by drainage ditches that discharged to the Slough. During this period, PDX was expanded to include new runways and construction of the terminal in its present location. The 1980 drainage map shows the general layout of the airport drainage representative of this period (Appendix A). The former PDX fire stations were located in the central basin. The central basin generally corresponds to a portion of Basin 2 and Basins 3 through 6. Stormwater was discharged from the basin and MCDD Outfall X (Figure 5). Outfall X was present from 1940 to approximately A pump station discharged flow in the open channel through Outfall X. The drainage basin for this outfall remained generally the same throughout its existence. 2.2 Current Fire Station Area History In 1997, prior to the expansion of Concourse C, the current fire station was built approximately 3,000 feet west of the former station, adjacent to the fire training facilities at 5250 Northeast Marine Drive (Figure 6). Activities involving the use of AFFF at the fire station include annual testing of the firefighting foam in the trucks, washing of crash/response vehicles, filling of crash/response vehicles with AFFF, and storage of AFFF. Current and former personnel indicated that the former practice for foam disposal was to wash out the trucks equipment lines and perform annual equipment testing on the ground in the vicinity of the fire stations including both asphalt and ground surfaces Material Use The fire department conducted annual testing of the firefighting foam stored in the trucks to confirm that the mixture was consistent with the manufacturer-specified concentration. This annual testing measured the percentage of foam in the water ( 3% to 6%) being distributed from the crash/response vehicles turrets. The volume of AFFF used during the annual testing is estimated to have been between 40 and 60 gallons per vehicle. This annual testing typically occurred at the fire training facility. However, a past practice of performing the annual equipment testing including foam discharge also occurred on the asphalt and ground surface adjacent to the fire station. Currently, washing of crash/response vehicles is conducted inside the fire station garage where the water drains through an oil-water separator connected to the sanitary system (Port, 2014). A former practice for foam disposal was to wash out the trucks and equipment lines on the ground in the vicinity of the fire stations. The quantity of AFFF, frequency, and time period that this practice was conducted at the current fire station is unknown. The PDX Fire Department currently has four Aircraft Rescue and Firefighting (ARFF) vehicles and one structural engine. The AFFF capacity of the vehicles ranges from 30 (structural engine) to 400 gallons (ARFF vehicles). The current PDX Fire Department stock of AFFF includes approximately 1,500 gallons within vehicles and 3,000 gallons in reserve per FAA AC 150/ A, Aircraft Rescue and Firefighting Station Building Design, dated Preliminary Assessment Page 6 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

11 September 10, 2008 (Personal communication, 2015). The AFFF concentrate is currently provided by the manufacturer in 265 gallon totes. These containers are stored in the current fire department building in an area with a blind sump. AFFF was formerly stored in 5-gallon buckets and 55-gallon drums. There are no records available nor any personal knowledge of any spills or releases inside the Fire Station. Current PDX Fire Department staff indicated minor leaks occurred during the filling of vehicles of AFFF. Minor leaks or drippage occurred inside the fire station when AFFF was supplied by the manufacturer in 5-gallon buckets or 55-gallon drums and a pump was required to the fill the response/crash vehicles. Currently, AFFF is supplied in 265-gallon totes and the vehicles are gravity filled directly from the totes using a forklift. Current staff indicate that AFFF is not disposed of, as there is no shelf life indicated by the manufacturer, and that the oldest supply is used first. Current staff indicated that due to cost, AFFF is conserved during testing, training, and cleaning. The most commonly currently used AFFF at PDX are those produced with Ansulite 3% and Ansulite 6% concentrates (Personal communication, 2015). A limited supply of National Foam Aer-O-Water is currently stored at the fire station for use as it was supplied with the purchase of the new Crash/Response vehicle. The standard AFFF acquired by the PDX Fire Department is Ansulite 3% and Ansulite 6%. The percentages refer to the concentrate mixture ratio with water. The 3% foam is used for alcohol fueled fires, while the 6% foam is used where hydrocarbons are the fuel source. The FAA does not allow use of AFFF in concentrations less than 3% on airports. These products were historically manufactured by the Ansul Corporation, now a subsidiary of Tyco Fire Protection Products. Safety data sheets (SDSs) for Ansulite 3%, Ansulite 6%, and Nation Foam Aer-O-Water are provided in Appendix A. The use of the Ansulite products has been consistent since at least the late 1980s, due to the incompatibility of different types of foam concentrates. The NFPA historically did not allow mixing of different brands or types of AFFF; however, the NFPA 11: Standard for Low Expansion Foam issued in 2002 modified this policy, indicating that foams of the same concentration and meeting Mil-Spec could be mixed for long-term storage (FAA, 2002; DoD, 2011; Tyco, 2014; Personal communication, 2015) Current and Historical Site Drainage According to Port records, the storm sewer has not changed at the current PDX fire stations. A storm sewer pipe, seven catch basins, and an oil water separator (OWS) are located around the current fire station where flow is directed to the south and where it connects to a southwest trending pipe that crosses just north of the original fire training facility. The OWS is associated with the 2,000-gallon diesel fuel above-ground storage tank located directly west of the fire station. In the vicinity of the current and historical fire training facilities, the pipe connects with another pipe and heads south. Refer to Figure 6 for the storm system. The current fire station area is located in the PDX stormwater Basin 1. Basin 1 is the western end of PDX and includes runways, taxiways, ramps, fire station, fire training area, jet fuel farm, and the deicing system storage tanks and treatment area. Non-Port properties within the drainage basin include a golf course and the Oregon Army uard facility on NE 33rd Avenue. The basin drains primarily to the southwest via a network of storm drains in the north and east side of the catchment and open channels in the southwest. Total area is 973 acres; 244 acres are impervious. There are three Port outfalls (1C, 1E, and 1S) from Basin 1 to open channels. The current fire station area drains to Port Preliminary Assessment Page 7 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

12 Outfall 1C located approximately 1.1 miles west-southwest of the current Fire Station. These open channels combine and flow is discharged via a Multnomah County Drainage District (MCDD)-owned pump (MCDD-2) to the Columbia Slough. Outfall MCDD-2 is a pump station located approximately 1.3-miles south-southwest of the Fire Station (Figure 5). Basin 1 has discharged via this outfall from 1940 to the present. Non-Port drainage also discharges via this outfall. Preliminary Assessment Page 8 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

13 3.0 PDX Fire Training Facilities PDX Fire Department training has been conducted within several fire training facilities areas on the northwest portion of PDX since 1963, referred to as the original, former, and current fire training facilities. The locations of these fire training facilities are shown on Figure 2 and 6. Port documents include fire drill pit activity logs with general descriptions of events and, occasionally, materials and estimated quantities used (Appendix C). Materials recorded in the logs are typically provided as general descriptions, such as fuel or foam, if any at all. The historical use of these training facilities, along with materials used and surrounding utilities are described below. 3.1 Original Fire Training Facility ( ) History The original fire training facility was located in the northwestern portion of the airport parcel, as shown on Figure 2. According to Port Fire Training Facility Activity Logs (Activity Logs) (Appendix C), recorded historical fire training activity began in 1963 and continued through June This timeline contradicts previous reports (eraghty & Miller, 1997; eraghty & Miller 1996; Century West, 1994; RNSA, 1988) and interviews with Port personnel (Personal communication, 2015) who stated the training facility was abandoned in For this report, we used the dates reported in the logs. From 1963 to 1978, fire training activity ranged from 12 to 44 recorded fire training events each year. Fire training events included the following: training fires; fire demos for local news and Port officials; helicopter drill fires; crash simulations; fuel and liquid transfers; trash burns; and fires with OAN and local fire departments, including Portland Fire Bureau, and resham, Salem, Vancouver, Hillsboro, and District 10 Fire Departments Material Use The activity logs often do not detail information as to the materials or quantity used during fire training activities. Of the detailed entries, materials used include foam, oil, diesel oil, JP-4, fuel, water, dry chemical, lightwater, F-84 lightwater, and bromochloromethane. Foam and fuel are the most commonly reported materials used in the fire training facility and vary in quantity from 5 to 350-gallons of foam and 40 to 700-gallons of fuel per event. Foam was typically used at quantities between 5 and 30 gallons during training events. On three occasions in 1963 and one in 1965, foam was used at quantities between 50 and 350 gallons. The term foam in the Activity Logs is generic and encompasses protein-based and synthetic foams. It was reported that the PDX Fire Department used protein-based foams until the late 1960s to early 1970s; after which, the department likely used synthetic AFFF. Details regarding the type of extinguishing agents used at the original fire training facility from 1963 to 1978 are as follows. Preliminary Assessment Page 9 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

14 Dry chemical was used in approximately five events starting in When documented, the fire department would use 30-pounds of the chemical per event. Lightwater was used in three events (3M s brand name for AFFF) on January 5, 1970, and March 8 and September 19, The approximate quantities were not reported. On May 5, 1977, OAN used bromochloromethane to extinguish fires in the Port training facility. The amount of the chemical used is unknown. The remainder of the Activity Log entries indicate either foam or water. 3.2 Former Fire Training Facility ( ) History In 1978, the former fire training facility was developed northeast of the original location, as shown on Figure 2. According to Port documents, fire training activity began in the new facility in June 1978 and continued through During this time span, training activity ranged from 5 to 29 recorded fire events each year, with a notable decrease in activity between 1987 and 1989 (Appendix C). Fire training events included the following: fires; disaster and crash simulations; burning trash, rags, carpet, and narcotics; fuel transfers; fire demos for local news and Port officials; and fires with OAN, Army Corps of Engineers, and local fire departments, including Portland Fire Bureau, District 10, Hillsboro, Oak Lodge, Happy Valley, and Milwaukie Fire Departments Material Use Historical fire training activity logs often do not detail the materials or quantity used during the training fires. Few entries between 1970 and 1989 specify this information. Four documented events used lightwater (AFFF), recorded on February 20, 1979, September 11, 1980, November 16, 1981, and July 19, The September 11, 1980 event used approximately 15-gallons of lightwater. The November 16, 1981 event used lightwater in conjunction with dry chemicals. No other details were provided in the logs regarding extinguishing agents. Accelerants used during this time period included diesel, waste fuel, gasoline, and fuel. 3.3 Current Fire Training Facility The current fire training facility was developed in 1990, located east of the former training facilities (Figure 2) and is currently in use. The fire training facility is lined and includes a collection system for capturing and separating fuel and water. The effluent water from the fire training facility is currently recycled and eventually discharged to the sanitary sewer under a batch discharge permit. Preliminary Assessment Page 10 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

15 3.3.1 Material Use As mentioned in Section 2.2.2, the most commonly used AFFFs at PDX are those produced with Ansulite 3% and Ansulite 6% concentrates. The percentages refer to the concentrate mixture ratio with water. The 3% foam is used for alcohol fueled fires, while the 6% foam is used where hydrocarbons are the fuel source. As described above the use of the Ansulite products is believed to have been consistent since the late 1980s due to the incompatibility of different types of foam concentrates. Fire training facility activity logs were not available from 1990 to present. According to current PDX Fire Department staff, the fire training facility is currently used annually for required training per FAA regulations. Annual training has been in implementation since at least 1993 per personal communications with PDX Fire Department staff. In addition to annual training, proficiency training (e.g., new hire training, night fire training, etc.) was conducted frequently prior to the construction of the propane aircraft mock-up installed in The current annual training event is comprised of two nights of approximately 10 fires per night. Due to the difficulty in igniting the fires, AFFF is not used during the training with the exception of the last night on approximately the last 6 fires. A conservative estimate of foam use during the annual training, assuming two response vehicles and fifteen seconds of discharge each, is approximately 20 gallons per fire. The use of two response vehicles during live-fire training is not a requirement of the FAA and not necessarily implemented during each live fire event at PDX. Current training events at PDX use propane to simulate a flammable fuel fire with water as the typical extinguishing agent. Prior to 2005, the use of hydrocarbon fuels during live-fire training events was conducted numerous times per year for annual and proficiency training. The reduction of hydrocarbon fueled fires was based on the construction of the propane equipped aircraft mock-up installed in Refer to Appendix B for the Port Fire Training Facilities Activity Logs from 1963 to Propane use during training exercises is permitted under FAA AC 150/ C Programs for Training of Aircraft Rescue and Firefighting Personnel and was implemented to eliminate environmental impacts associated with the use of petroleum hydrocarbons. This approach also reduces the use of AFFF in training exercises. 3.4 Current and Historic Drainage Currently, a storm sewer pipeline is present in the vicinity of the fire training facilities. A northeast-southwest trending pipeline cuts diagonally through the former fire training facility and crosses just north of the original fire training facility, where it connects with another pipe and heads south. Two catch basins are located along the eastern boundary of the former fire training facility and drain into north-northwest-south-southeast trending pipe that converges with the aforementioned pipeline. A catch basin is located south of the original fire training facility and connects with the aforementioned pipeline west of the fire training facility. Refer to Figure 6 for the storm system. Two additional catch basins are located east of the current fire training facility. Stormwater in these catch basins flows to a storm sewer pipeline to the east. There it converges with a southeast-northwest trending line that ultimately converges with the main pipeline mentioned above. Preliminary Assessment Page 11 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

16 The original, former, and current fire training facilities are located in Basin 1. Storm water generated in the vicinity of these facilities discharges through Port Outfall 1C combined with flow from open channels to the southwest to discharge to the Columbia Slough via an MCDD owned pump station. See Section for further discussion of Basin 1. With the exception of piping replacing ditches downstream, the storm sewer and drainage pattern at the original, former, and current fire training facilities has not substantively changed over time. 3.5 Previous Environmental Work and Current Conditions From 1988 through 2017, site characterization and groundwater monitoring were performed at the original, former, and current fire training facilities. These activities have included soil samples from 30 test pits and 45 soil borings, installing 14 groundwater monitoring wells, and performing groundwater monitoring. In 1996, a remedial action was performed at the site that included installing a protective plastic liner and gravel cap over the original, former, and current fire training facilities. Soil and groundwater at the fire training facilities contain petroleum hydrocarbons and associated constituents (e.g., polycyclic aromatic hydrocarbons [PAHs]) from fuels used for training fires, and components of AFFF are present in groundwater. Separate-phase hydrocarbons have historically been present in one monitoring well (-12). According to the Beneficial Land and Water Use Survey Update (Ash Creek, 2012), groundwater in the vicinity of the fire training facilities and in the immediate vicinity of PDX is for irrigating, landscaping, and golf courses. The City of Portland has developed the West Wellfield (in the eastern portion of PDX) as a supplemental and emergency supply of municipal water for the Portland Metro area. Otherwise, domestic use is limited to two residential areas southwest of PDX, and two marinas north of the airport. roundwater is also used for industrial purposes southwest of the airport and along Columbia Boulevard to the south. All water wells obtain groundwater from the Columbia River Sand aquifer, Troutdale ravel aquifer, or deeper aquifers. No water wells were identified that utilize shallow groundwater from fill or overbank deposits. The reasonably likely future use of the water is similar to current uses, although increased groundwater use for irrigation, industrial, and municipal purposes is likely. The following provides a summary of the investigations completed at the fire training facilities Site Characterization The former fire training facility was first investigated in 1988 by Roger N. Smith and Associates (RNSA) to assess if contamination of this area would interfere with construction of the current fire training facility. RNSA excavated 20 test pits to a maximum depth of 10.5 feet below ground surface (bgs) and collected surface and subsurface soil samples. Petroleum hydrocarbons and related volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) were detected in soil. Petroleum hydrocarbons were detected at concentrations up to 175,000 milligrams per kilogram (mg/kg). Metals in soil were generally consistent with background. VOCs were detected in groundwater Century West Characterization Century West conducted site characterization to evaluate the nature and extent of impacts to soil and groundwater from fuels used during fire training activities. Century West excavated 10 test pits, completed 33 soil borings, and installed 9 groundwater monitoring wells in the vicinity of both the original and former fire training facilities. Total petroleum hydrocarbons (TPH) were detected in Preliminary Assessment Page 12 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

17 soil at up to 32,000 mg/kg and 14,000 mg/kg at the original and former fire training facilities, respectively. VOCs and PAHs were also detected in soil. Metals in soil were consistent with background. VOCs and PAHs were detected in groundwater eraghty & Miller Investigation eraghty & Miller completed 12 borings and five monitoring wells and collected 14 surface soil samples at the original and former fire training facilities. TPH was detected in soil at up to 24,000 mg/kg and 14,000 mg/kg at the original and former fire training facilities, respectively. VOCs and PAHs were also detected in soil. Metals in soil were consistent with background. Polychlorinated biphenyls (PCBs) were detected in two samples. roundwater monitoring showed that the gradient was toward a nearby storm sewer. VOCs, PAHs, and bis(2-ethylhexyl)phthalate were detected in groundwater. Lead in groundwater was likely consistent with background Remedial Action Beginning in 1996, the Port capped the original and former fire training facilities and implemented long-term groundwater monitoring as a remedial alternative. The protective cap prevents direct contact with soil containing petroleum hydrocarbons and related constituents. The cap generally consists of a demarcation layer and a gravel base. Portions of the cap expected to receive greater vehicle traffic include a cement treated gravel base or asphalt-concrete. The demarcation layer was constructed with a 5-mil, white, low-density polyethylene (LDPE) material overlain by a medium-weight, woven, polypropylene geotextile. The LDPE material served as a visible marker separating the aggregate base from underlying soils containing residual contaminants Hart Crowser roundwater Sampling Adjacent to Storm Sewer Line In May 2001, Hart Crowser completed test pit explorations adjacent to the storm sewer pipeline that intersects the former fire training facility area and runs north of the original fire training facility area. roundwater was encountered at a depth of about 7 feet. After the groundwater that initially entered the excavation was purged, a groundwater sample was collected from the sand around the sewer pipeline. The groundwater sample was analyzed for PAHs and for benzene, toluene, ethylbenzene, and xyles (BTEX), and neither PAHs nor BTEX compounds were detected in the test pit groundwater sample. roundwater Monitoring: 1994 to 2017 roundwater sampling from monitoring wells was conducted quarterly from 1994 to 1996, semi-annually in 1997, annually from 1998 through 2007, and again in The monitoring showed a groundwater gradient toward the nearby storm sewer. Early sampling identified VOCs and PAHs above human health and ecological screening levels. By 2007, only benzene in one well (-12) was above screening levels. In 2017, separate phase hydrocarbons were present in well -12 at a thickness of 0.15 foot. In the sampling event in 2017: TPH, PAHs, and VOCs were detected above screening levels in one well; PCBs were detected in one well; metals were detected in each well but may represent background conditions; and PFAS were detected in each of the six analyzed samples (PFOA and PFOS exceeded the U.S. EPA Health Advisory Limit of 70 nanograms per liter (ng/l) for combined PFOA and PFOS). Preliminary Assessment Page 13 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

18 4.0 Oregon Air National uard (OAN) 4.1 History OAN has leased property at PDX since 1949, with various leased boundaries over that time span. Use or storage of firefighting materials has occurred at several areas on the leased property, as discussed below. These areas are shown on Figure 3. Fire training for OAN was historically conducted at the uard s fire training facility, which was located to the east of the current OAN facility (Personal Communication, 2015). The OAN fire training facility was active between approximately 1957 and 1978 (Ash Creek, 2014). Between 1963 and 1978, OAN also periodically conducted training at the Port s fire training facilities. After the guard s fire training facility was closed in 1978, OAN fire training took place at the Port fire training areas, which include the original and former fire training facilities discussed in Section 3.0 of this assessment. In accordance with Military Specification Fire Extinguishing Agent, Lightwater, Concentrate, (6 Percent; MIL-F-24385) effective November 1, 1963 and Aqueous Film forming Foam (AFFF) Liquid Concentrate, Six Percent, For Fresh and Sea Water (MIL-F-24385) effective November 21, 1969, it is presumed that the OAN would have been using a sixpercent AFFF solution during training exercises at its historical fire training facility as early as 1963 (through 1978) and the Port s former fire training facility from 1978 through The U.S. military has used AFFF since the product s development in The military specification was amended and a three percent AFFF solution was allowed for mobile and stationary fire suppression systems under MIL-F-24385C effective March 12, 1981 (DoD, 1981). OAN used the PDX fire training facilities through Non-fire training areas at OAN include areas where AFFF has been stored or released such as hangars, fuel spill areas, waste storage facilities, and firefighting equipment testing areas. The following provides a summary of those areas as detailed in the OAN Perfluorinated Compounds Preliminary Assessment Site Visit Report (January 2016). Base Supply (Building 170) Building 170 was built in 1990 and has stored AFFF for, at least, the last ten years. New Fire Department (Building 180) Building 180 was constructed in AFFF is stored in fire/crash response vehicles totaling approximately 2,700 gallons. Minor spills and leaks occurred during the filling the vehicles. Three occurrences of AFFF discharge to the storm sewer were noted. Fire Suppression Systems Five hangars (Hangars 250, 255, 310, 375, and 380) constructed between 1985 and 1988 included fire suppression systems that use AFFF. Tank capacities ranged from 200 to 2,200 gallons. The AFFF system was removed from Hangar 380 in Minor spills and releases to the storm water system were noted in Hangars 255, 310, and 375. Old Fire Department (Building 290) Building 290 was built in 1986 and was the location of the OAN Fire Department from 1986 to AFFF was stored at this location in crash/response vehicles with minor spills Preliminary Assessment Page 14 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

19 and leaks noted during the filling of those vehicles. One AFFF spill of unknown quantity was noted to discharge to the drainage swale northwest of the building. POL Storage (Building 431) Petroleum, oils, and lubricants are stored in Building 431 which was built in The building stored AFFF tanks until No spills or releases were noted. Ponds and Stormwater Retention Basins Two man made stormwater retention ponds located in the west central portion of OAN receive ninety-five percent of OAN s stormwater discharge. Ditches located north of the ponds direct stormwater flow through a pipe and into the ponds. Releases to the storm sewer system mentioned above ultimately discharged to the retention ponds. Appendix C is Figure 2 from the OAN Perfluorinated Compounds Preliminary Assessment Site Visit Report (January 2016), which presents the locations of the AOIs identified in the above section. Another area of significant historical AFFF testing was the former OAN Fire Station (currently used as the UPS Ramp; shown on Figure 3), located south of the former Port fire station. AFFF was presumably stored in stationary fire suppression systems and in fire trucks. 4.2 Material Use Beyond the descriptions provided in Section 4.1, the materials and quantities used and/or stored, and any possible spills/releases at the OAN facilities are unknown. 4.3 Previous Work and Current Conditions In a letter from OAN to the Port of Portland, dated October 31, 2016 (NB, 2016), OAN informed the Port they are investigating potential PFAS sources on their currently leased facility under the authorities of the Defense Environmental Restoration Program and Comprehensive Environmental Repose Compensation and Liability Act (CERCLA). AN completed a Preliminary Assessment in April The report identified ten sites where AFFF has been stored or released based on AN records, as discussed in Section 4.1 (BB&E, 2015). OAN advised the Port that the next step within the CERCLA process is a Site Investigation (SI) to determine the presence or absence of PFAS from potential release sites on AN property in all potential media and determine if PFAS-contaminated groundwater has reached the base boundary. OAN stated it is not ready to investigate areas outside of its current leasehold. However, the Port has notified OAN that under the terms of its lease with the Port, OAN will be required to investigate former leasehold areas where AFFF may have been released. Preliminary Assessment Page 15 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

20 5.0 Former PAMCOR Hangar The former PAMCOR Hangar was constructed in 1993 in the southeastern part of PDX (see Figure 3) for use as an aircraft painting hangar. Shortly after completion, the occupant became insolvent and the property reverted to the State of Oregon. Ownership of the hangars was transferred to the Port of Portland in approximately Until its lease to Boeing for aircraft painting, the north hangar was sporadically used for aircraft painting, and the south hangar was used for aircraft and miscellaneous storage. Shortly after the hangars were constructed in 1993 by AMC/PAMCOR, a leak in a newly charged underground PVC supply line of the hangar s AFFF system resulted in a subsurface release of an unknown quantity of AFFF. According to the facility manager of the hangars, the PVC supply line was installed beneath the parking lot shortly after building construction and the release was identified when pressure was lost after the initial line charge. The contractors (Simplexrinnell and Fletcher Wright) were unable to determine where the leak had occurred and the pipe was subsequently purged and abandoned. A replacement supply line was reportedly then installed within a subgrade concrete trench (Personal communication, 2017). The facility manager indicated that there were two incidents in the south hangar and one incident in the north hangar. In the south hangar foam discharged on two occasions: one due to a sensor malfunction and a second due to a boom lift catching on fire. The sensor incident discharged up to 30,000 gallons of AFFF foam while the fire incident released up to 60,000 gallons of AFFF foam. In the north hangar a sensor was tripped and released up to 30,000 gallons of AFFF and water mixture. These incidents occurred in the mid-1990s. The majority of the foam was collected in the detention ponds and dissolved oxygen concentrations allowed to equilibrate prior to discharge to the sanitary system (Personal communication, 2017). The hangar system currently includes two 6,000-gallon AFFF tanks supplied by an underground AFFF supply line for the hangar stationary fire suppression system. Historical materials, quantities used and/or stored, and any spills/releases other than those discussed above at the facility are unknown. 6.0 Emergency Response Personal communication with current and former PDX Fire Department staff, indicated that emergency response activities including one small plane crash and numerous fuel spills and other events that required the application of AFFF at other locations at PDX outside of those previously discussed. The amount of PFAS that enter the groundwater depends on the type and amount of AFFF used, where it was used, the type of soil, and other factors (ATSDR, 2009; SERDP, 2012; ASTSWMO, 2015). Preliminary Assessment Page 16 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

21 7.0 Other Locations 7.1 Reclaimed Fire Training Facility Water The current fire training facility is lined and includes a collection system for capturing fire training water. The effluent water from the fire drill facility is currently recycled and eventually discharged to the sanitary sewer, but was historically land applied in the area to the north of the facilities, as shown on Figure 3. The period of application is unknown. A limited aerial photograph review identified an apparent sprinkler system in 1990 in the area north of the facilities that was not visible in a 1988 aerial. 7.2 Stationary Fire Suppression Systems In addition to OAN and the Former PAMCOR hangars, several activities at PDX currently have AFFF stored in stationary fire suppression systems. It is possible that other historical facilities contained foam systems. The Port does not have records regarding the storage capacity, time period of use, or maintenance records from these systems. The Port is unaware of any investigations of these areas. Preliminary Assessment Page 17 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

22 8.0 Areas of Interest for Further Investigation Based on the review of available Port documents, personal communication with PDX Fire Department staff, and current understanding of the fate and transport of PFAS in the environment, locations identified at PDX of current or historical storage, use, or release of AFFF to the environment were identified as having a high or low priority for future investigation. Each area identified as having high priority is considered an AOI (Figure 3). The following provides the rationale for priority ranking and identifies the areas by operator. 8.1 Port Operated Areas High Priority Two locations currently or historically operated by the Port at PDX were identified as high priority for future investigation based on historical use of AFFF, frequency and volume of AFFF used during live-fire training exercises, historical storage and disposal practices, and known releases to the environment. The sites are presented in order of priority. Fire Training Facilities/Reclaimed Water Disposal. This site encompasses the original, former, and current fire training facilities and the area northwest of the facilities where reclaimed water was land-applied. Available Port documents identified frequent use of AFFF and application to the ground surface during live-fire training exercises; personal communication with PDX fire department staff provided information regarding the use of AFFF at the live-fire training facilities and use of reclaimed facility water for irrigation purposes; and current groundwater analytical data has identified PFAS groundwater impacts. Further investigation in this area is recommended to identify the extent and magnitude of PFAS impacts to groundwater and soil. Current and Original PDX Fire Stations. Based on personal communications with PDX fire department staff, a historical practice was to washout the ARFF equipment and conduct testing of the AFFF supplied equipment outside and adjacent to the fire stations. These practices may have resulted in PFAS impacts at the current and former fire stations. Further investigation in these areas is recommended to identify the extent and magnitude of PFAS impacts to groundwater and soil, if any Low Priority Two types of locations at PDX were identified as low priority based on current understanding of AFFF fate and transport, as well as historical and current storage practices. Due to the low priority ranking, these areas are not considered AOIs at this time. Emergency Response Areas. Personal communication with current and former PDX Fire Department staff indicated that emergency response activities, including one small plane crash and numerous fuel spills, required the application of AFFF at numerous locations at PDX. Research suggests that PFAS impacts to groundwater are less likely from Preliminary Assessment Page 18 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

23 one-time AFFF use, such as use in active firefighting or spill response. Based on this research, the emergency response areas are considered a low priority. Stationary Fire Suppression Systems. Several facilities at PDX currently have AFFF stored in stationary fire suppression systems. These include: the PFCC Fuel Farm, located north-northwest of the original and current PDX fire training facilities; Horizon Air hangar, located southeast of the former OAN fire station; and the former OAN Hanger 375 recently returned to the Port (Figure 3). The Port is unaware of any leaks, malfunctions, or instances of discharge regarding these systems. The storage of AFFF is not likely to result in a release, therefore these locations are considered a low priority. 8.2 Other s Operational Areas The following sites operated by other parties were identified during preparation of the PA. The following provides the rationale for priority ranking and identifies the operator of the area High Priority Three locations at PDX operated by other parties were identified as high priority based on historical use of AFFF, frequency and volume of AFFF used during live-fire training exercises, historical storage and disposal practices, and known releases to the environment. OAN Fire Training Facility. The Port has not identified records that provide detail regarding accelerant and extinguishing agents used at the former OAN fire training facility. However, based on materials used at the PDX fire training facilities, current groundwater impacts associated with historical AFFF use at OAN facilities worldwide, and the requirement to use Mil-Spec AFFF since 1963 (known to contain more fluorosurfactants and fluorine than other telomer based AFFFs), the former OAN fire training facility was identified as a high priority for investigation (Darwin, 2004). It is the Port s understanding that OAN is in communication with DEQ to investigate the former and current OAN fire training facilities. Former OAN Fire Stations (UPS Ramp). Based on historic practices identified at the former and current PDX Fire Stations, there is potential for similar practices including AFFF use to have occurred at the former OAN Fire Station. Additionally, the use of Mil-Spec AFFF identified this location as a high priority for investigation. It is the Port s understanding that OAN is in communication with DEQ to investigate the former and current OAN fire training facilities. Former PAMCOR Hangar. The former PAMCOR hangar was identified as a high priority location for future investigation due to several releases of AFFF to the ground surface during the early to mid-1990s. A release of AFFF occurred in 1993 when a leak in a newly charged underground PVC supply line of the hangar s AFFF system resulted in a subsurface release of an unknown quantity of AFFF. Additionally, three instances of the fire suppression system Preliminary Assessment Page 19 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

24 activating were identified with AFFF releases to the interior of the hangars which discharged to the storm sewer and associated detention ponds Low Priority OAN Leasehold. The current OAN leasehold has up to eight areas other than the fire training facilities and current and former fire stations that may be potentially impacted by AFFF use as detailed in Section 4. These areas include hangars with fire suppression systems and AFFF storage locations that OAN is currently preparing to investigate per the Perfluorinated Compounds Preliminary Assessment Site Visit Report (2016). 8.3 Future Investigations Based on the information contained in this PA; results from recent groundwater analytical data sampled from the fire training facilities; and research suggesting that PFAS impacts to groundwater are less likely from one-time AFFF use, the Port will conduct a phased approach to investigate each high priority area identified. The phased approach will include a groundwater and subsurface assessment at the fire training facilities to determine the extent and magnitude of PFAS impacts. Results from this investigation will be used to develop investigation protocols and methodologies for addressing the former and current fire stations. Following the investigations at the Port operated high priority areas, an assessment will be made to determine if further investigation is warranted at the low priority areas. The Port will monitor the progress of investigations at the high and low priority areas operated by other parties. Preliminary Assessment Page 20 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

25 9.0 References Airport Cooperative Research Program (ACRP), Use and Potential Impacts of AFFF Containing PFASs at Airports. Agency for Toxics and Disease Registry (ATSDR), Draft Toxicological profile for perfluoroalkyls. ATSDR Division of Toxicology and Environmental Medicine. U.S. overnment Printing Office. (August 2015 Update) Apex Companies, LLC (Apex), Reconnaissance Well Sampling April 2017, Original and Former Fire Training Pits, Portland International Airport. June 5, Ash Creek Associates (Ash Creek), Land and Beneficial Water Use Survey Update, Portland International Airport, Portland, Oregon. December 12, Ash Creek Associates (Ash Creek), Potentially Responsible Party Review, McBride Slough, Portland, Oregon. April 24, Association of State and Territorial Solid Waste Management Officials (ASTSWMO), Perfluorinated Chemicals (PFCs): PFOA & PFOS Information Paper. ASTSWMO Remediation and Reuse Focus roup. August BB&E, Inc., Final Perfluorinated Compounds Preliminary Assessment Site Visit Report, Portland, Oregon. Prepared for the Headquarters Air National uard (January 2016). Century West Engineering Corporation (Century West), 1994a. Quarterly Monitoring Report, Former Fire Training Areas, Portland International Airport. October Century West, 1994b. Site characterization Report, Former Fire Training Areas, Portland International Airport. October Century West, 1995a. Quarterly Monitoring Report, Former Fire Training Areas, Portland International Airport. October 23, Century West, 1995b. Quarterly Monitoring Report, Former Fire Training Areas, Portland International Airport. June 23, Century West, 1995c. Quarterly Monitoring Report, Former Fire Training Areas, Portland International Airport. January Century West, 1995d. Remedial Alternatives Evaluation, Former Fire Training Areas, Portland International Airport. January Colville, S., and McCarron, N., Environmental Issues Associated with Defense Use of Aqueous Film Forming Foam (AFFF). Environmental Stewardship, Environment, Heritage and Risk Branch of Defence Corporate Services and Infrastructure. May Darwin, Robert L., Estimated Quantities of Aqueous Film Forming Foam (AFFF) in the United States. Prepared for the Fire Fighting Foam Coalition. August U.S. Department of Defense (DoD), Military Specification: Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater. MIL-F November 21, DoD, Military Specification: Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater. MIL-F-24385C. March 12, Preliminary Assessment Page 21 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

26 DoD, Chemical & Material Emerging Risk Alert: Aqueous Film Forming Foam (AFFF). Chemical and Risk Management Directorate. Risk Alert # July U.S. Environmental Protection Agency (EPA), Provisional health advisories for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). January 8, EPA, 2014a. Peer Review of Health Effects Documents for PFOA and PFOS. February EPA, 2014b. Emerging Contaminants Fact Sheet Perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). March EPA, EPA s Non-CBI Summary Tables for 2014 Company Progress Reports. May EPA, EPA Fact Sheet PFOA & PFOS Drinking Water Health Advisories. May EPA, EPA Fact Sheet: 2010/2015 PFOA Stewardship Program. Last visited July 11, EPA Region 4, Soil screening levels for perfluorooctanoic acid (PFOA) and perfluorooctyl sulfonate (PFOS). Memorandum. Federal Aviation Administration (FAA), National Part 139 CertAlert: Aqueous Film Forming Foam (AFFF) Concentrations, Restrictions, and Other Use uidelines. Airport Safety and Operations Division AAS-300. CertAlert No FAA, Advisory Circular: Aircraft Fire Extinguishing Agents. Airport Safety and Operations Division AAS-100. Advisory Circular No. 150/5210-6D. FAA, National Part 139 CertAlert: Identifying Mil-Spec Aqueous Film Forming Foam (AFFF). Airport Safety and Operations Division AAS-300. CertAlert No eraghty and Miller, Inc., Remedial Investigation/Feasibility Study Work Plan. Prepared for the Port of Portland. January 3, eraghty and Miller, Inc., Remedial Investigation/Feasibility Original and Former Fire Training Pits Port of Portland Portland International Airport: Volume I and Volume II. Prepared for the Port of Portland. January 3, MIL-F-24385, Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater. November 21, National uard Bureau (NB), Notice and Tender of Oregon Department of Environmental Quality s Site Cleanup Claim Regarding Fire Training Areas at the Portland International Airport, Portland, Oregon (PDX). Memorandum received October 31, 2016.Place, B., and Field, JA, Identification of Novel Fluorochemicals in Aqueous Film-Forming Foams (AFFF) Used by the US Military. Environmental Science and Technology, 46, Personal Communication, Telephone discussions with former and current PDX Fire Department Staff on November 3, 2015 and May 18, 2017November 3, Personal Communication, Telephone discussion between Apex and Facility Manager of the former PAMCOR hangar. June 15, Preliminary Assessment Page 22 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

27 Port of Portland, Portland International Airport, Port of Portland, Storm Water Pollution Control Plan. December 20, 2011, Revised February 3, Roger N. Smith Associates, Inc., Characterization and Recommended Remediation of the Soils Beneath the Burn Pit Site at Portland s International Airport. Prepared for the Port of Portland. May 15, Scheffey, Joseph L., and K. Bagot, Status Report on an Effort to Evaluate and Develop Methodologies for Calculating Firefighting Agent Quantities Needed to Combat Aircraft Fires. March 13, Seow, Jimmy, Final Version Fire Fighting Foams with Perfluorochemicals Environmental Review. Prepared for the Department of Environment and Conservation Western Australia. June 7, Strategic Environmental Research and Development Program (SERDP), FY 2014 Statement of need, environmental restoration program area, in-situ remediation of perfluoroalkyl contaminated groundwater. SON Number: ERSON Tyco Fire Protection Products (Tyco), Ansul Technical Bulletin: Compatibility of AFFF/Alcohol-Resistant AFFF Concentrates. Technical Bulletin Number 64. Form No. F Tyco, Technical Bulletin: Transition of the Firefighting Foam Industry from C8 to C6 Fluorochemistry. No. F April 2016 Form Preliminary Assessment Page 23 Aqueous Film-Forming Foam Use, Portland International Airport August 3,

28 Table 1 Summary of Current and Historical AFFF Use at Portland International Airport Preliminary Assessment, Aqueous Film-Forming Foam Use Portland, Oregon Area Facility/Incident Time Period AFFF Use Involved Parties Materials References Fire Stations Original Fire Station Former Fire Station Current Fire Stations Present Storage, Response/Crash Vehicles, Annual foam testing, Clean trucks and tanks on uncovered land Storage, Fire trucks, Annual foam testing, Clean trucks and tanks on uncovered land Storage (~3000-gallons), Fire trucks (~1500- gallons) Annual foam testing, Clean trucks and tanks on uncovered land Port Port Port Unknown. Assumed storage of similar extinguishing agents as used in fire pits logs: foam, water, dry chemical, lightwater, F-84 lightwater, and chromebromo methane. Lightwater was used for the first time in Unknown. Assumed storage of similar extinguishing agents as used in fire pits logs: foam, water, dry chemical, lightwater, F-84 lightwater, and chromebromo methane AFFF - Ansulite 3%, Ansulite 6%, and Natinoal Foam 3% concentrates. Port Fire Drill Pit Activity Logs Port Fire Drill Pit Activity Logs Personal Communications (2015 and 2016) Original Fire Training Facility Fire training, crash simulations, helicopter fire drills, fuel and liquid transfers, trash burns Port, OAN, PFB, resham FD, Salem FD, Vancouver FD, Hillsboro FD, District 10 FD Extinguishing Agents - Foam, water, dry chemical, lightwater (AFFF), F-84 lightwater, and chromebromo methane. Lightwater was used for the first time in Accelerants - Jet fuel (JP-4), fuel, diesel oil, waste fuel, oil cart, engine oil, trash, lumber, paint,truck, and explosives. Port Fire Drill Pit Activity Logs Port Fire Training Facilities Former Fire Training Facility Fire training, disaster and crash simulations, fuel and liquid transfers, trash burns Extinguishing Agent - Lightwater, dry chemicals, and Chemical 44 Port, OAN, Army Corps of Engineers, PFB, Oak Lodge FD, Happy Valley FD, Milwaukie Accelerant - Waste fuel, rags, carpet, gasoline, narcotics, FD, Hillsboro FD, District 10 FD wastetank, fuel, and diesel fuel. Port Fire Drill Pit Activity Logs Extinguishing Agent - predominantlty water. Current Fire Training Facility Present Fire training. Details of other fire pit activities are unknown AFFF - Ansulite 3%, Ansulite 6%, and Natinoal Foam 3% Port, local Municipality Fire Departments concentrates are used minimally once per year for training (City of Portland, resham, Milwaukie, etc.) purposes. Personal Communications Accelerant - Propane. Former OAN Leasehold Hangar (OAN) AFFF Storage in Fire Suppression System OAN and Port AFFF - Military Specification MIL-F BB&E (2016) Present (Port) Oregon Air National uard (OAN) PAMCOR/AMC Hangar Emergency Responses Other Locations Former Fire Training Facility Fire training. Details of other fire pit activities are unknown. OAN AFFF - Military Specification MIL-F Personal Communications (2015 and 2016) Building 170 (Base Supply) Present AFFF Storage OAN AFFF - Military Specification MIL-F BB&E (2016) Building 180 (New Fire Dept.) Present AFFF Storage in Response/Crash Veihicles OAN AFFF - Military Specification MIL-F BB&E (2016) Hangar Present AFFF Storage in Fire Suppression System OAN AFFF - Military Specification MIL-F BB&E (2016) Hangar Present AFFF Storage in Fire Suppression System OAN AFFF - Military Specification MIL-F BB&E (2016) Building 290 (Old Fire Dept./UPS AFFF Storage in Response/Crash Veihicles OAN AFFF - Military Specification MIL-F BB&E (2016) Hangar Present AFFF Storage in Fire Suppression System OAN AFFF - Military Specification MIL-F BB&E (2016) Hangar AFFF Storage in Fire Suppression System OAN AFFF - Military Specification MIL-F BB&E (2016) Building 431 (POL Storage) AFFF Storage OAN AFFF - Military Specification MIL-F BB&E (2016) Ponds/Storm water Retention AFFF Releases OAN AFFF - Military Specification MIL-F BB&E (2016) PAMCOR Hangar Present Stationary fire suppression system (two 6,000- gallon AFFF tanks) PAMCOR North Hangar 1990s Fire suppression sensor activated system. PAMCOR South Hangar 1990s Fire suppression sensor activated system. PAMCOR South Hangar 1990s Machinery fire, fire suppression system activated. PAMCOR AFFF Storage Unknown quantity of AFFF released in 1993 due to underground supply line failure. Released approxiamtely 20 tp 30,000 gallons of AFFF/water mixture. Released approxiamtely 20 tp 30,000 gallons of AFFF/water mixture. Released approxiamtely 50 tp 60,000 gallons of AFFF/water mixture. Personal Communications (2015 and 2016) Personal Communications (2017) Hanagar Fire (RE) -- Structural fire, not requiring use of AFFF. Port Personal Communications (2015 and 2016) Fuel Spills -- AFFF used for fire suppression Port AFFF used to suppress potential fires from fuel spills at numerous locations. Personal Communications (2015 and 2016) Reclaimed Fire Pit Water Port Fire Pit accelerants and extinguishing agents Personal Communications (2015 and 2016) PFCC Fuel Farm -- Fire suppression System PFCC AFFF Personal Communications (2015 and 2016) Horizon Air Hangar -- Fire suppression System Horizon Air AFFF Personal Communications (2015 and 2016) Preliminary Assessment Page 1 of 1

29 Site Note: Base map prepared from USS 7.5-minute quadrangle of Mount Tabor, OR-WA, dated 2014 as provided by USS.gov. Portland AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW First Avenue Portland, Oregon ,000 Approximate Scale in Feet Site Location Map Project Number June ,000 Figure 1

30 R NE MARINE DRIVE VEHICLE AND EQUIPMENT STORAE FACILITY WEATHER BUREAU RADAR TOWER NORTHWEST APRON FAA RTR FACILITY TAXIWAY D PDX FIRE STATION PFFC JET FUEL STORAE TANK TANK TANK ACCESS ROAD A.C. Former Fire Training Facility Cover SERVICE RD Current Fire Training Facility PERIMETER ROAD TAXIWAY B Original Fire Training Facility Cover B2 RUNWAY RUNWAY 10R-28L Scale in Feet Note: Base map prepared from a 2013 Port of Portland AutoCAD base (pdx-features_pop-local). Site Vicinity Plan AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW First Avenue Portland, Oregon Project Number June Figure 2

31 D ) > 1==-=-- - -r- \/ I A.JtffAV11J.,2lfll TA,XM,4'1' , = - - l.. LAND APPLICATION OF RECLAIMED FIRE TRAININ FACILITIES WATER C J:)- FIRE TRAININ FACILITY ( ). ( (., _,I J FIRE TRAININ FACILITY ( ) CURRENT FIRE TRAININ FACILITY FORMER FIRE --- STATION ( ) ri,_, JNIIAY10R FORMER OAN FIRE TRAININ FACILITY ( ) 0 I. Legend: [ -=---) Building Location Area of Interest Areas of Interest 0 1 _,o,_ 0 _ 0 2,000 Scale in Feet Base map prepared from pdx-features_pop-local.dwg and pdx-utilities_pop-local.dwg (2013).. ;......,,,.. \.\ APEX AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW Firsl Avenue Portland, Oregon 9720 I Project Number June 20 I 7 Figure 3

32 8'' 8'' 8'' 8'' 8'' 737 A319 A320 MD '' HDPE C16 C18 12'' 1 E2 co co co 18'' CSP 6'' PERF 24'' Legend: Main Stormwater Conveyance Line SP 10'' CSP 21'' 6'' PVC 6'' 6'' 8'' 10'' 10'' 10'' 8'' TAXIWAY M C22 8'' 6'' 20'' 21'' 20'' 21'' CSP 20'' DIP 24'' DIP Former Fire Station ( ) 18'' C20 A ;A MD '' MD80 18'' DIP Former Fire Station ( ) 12'' '' PERF 16'' '' co WQ V O W Flow Direction Line Cap Catch Basin rated Manhole/Catch Basin Manhole Cleanout Water Quality Manhole Vault Oil/Water Separator (Storm) Storm System Flow Valve Pump Station Abandoned Stormwater Conveyance Line and Flow Direction 21'' CSP A A , CONCOURSE C 6'' C '' 12'' 8'' 8'' 6'' PVC 6'' 8'' 8'' 737/A320 A MD80 10'' 2'' PVCP V 12'' MD80 737;A320 MD A320 8'' Scale in Feet Base map prepared from pdx-features_pop-local.dwg and pdx-utilities_pop-local.dwg (2013). 20'' Former Fire Station '' 12'' 12'' 12'' 8'' 16'' 8'' 6'' 6'' V 8'' V 8'' 8'' AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW First Avenue Portland, Oregon Project Number June Figure 4

33 COLUMBIA EDEWATER OLF COURSE MONOTORIN WELL ELEV RIVERSIDE OLF COURSE OREON WATER RESOURCE DEPT. WELL # B1 C LCPF JOINT, TYP. WEST PERIMETER RD LCPF JOINT, TYP BROADMOOR OLF MONITORIN WELL TOP PFFC FUEL 4852 R MONITORIN WELL TOP RUNWAY LCPF JOINT, TYP. ACCESS ROAD A.C. FAA RTR 5106 LCPF JOINT, TYP. B2 R TAXIWAY B C3 UNKNOWN 8540 SOLAR PANEL UIC ORANE LCPF JOINT, TYP. REFLECTOR POLE AIR CANNON AIR CANNON 1' X 1' CONC. SQUARE W/ SAWED OFF POST LCPF JOINT, TYP. RAMP TWY AIR CANNON 1.5' DIA CONC QUIESCENT POND EDE OF RAVEL 4505 NORTH WEST E6 1' WIDE ROCK WALL 2' HIH ELECTRIC FENCE DETENTION PONDS NE E ROAD AIRTRANS CRYSTAL CENTER 757;DC8; /800,900,MD88 MONITORIN WELL RIM ELEV E MONITORIN WELL RIM ELEV SATELLITE E2 767 MONITORIN WELL TOP A ;A319 A A ,300 A320 MD A319 MD QUIESCENT POND MD MD80 737/A320 A MD80 737;A MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV NORTH RAMP A E190 MD80 737, /800 MD A DC10 A319,A ,600,700 A319;A ;MD80-90 A ; ;DC10 MD ; ,400 A330;A ,400, ,900,A , MD-80/ A320;A319, ,600, ,400,800,900 MD80 MD90; ,400, ,900;A320;A , , A , ; MD-80 A319;A TAXIWAY J A318 A319/A320 A321 MD80 E190 MD ,400,700 CRJ 200/400/700 MD-88/ ,900,A320/A MD W, ,319,320,321 MD80 737;MD ,200,300/CRJ / CRJ700/800;A319/A320 MD 88/90 A318/319/320 MD80/ A /E QUIESCENT POND ,800,900 A320; /E190 MD80 CRJ 200,700, /800,900 A319,A320 MD 80/ MONITORIN WELL TOP / A319, ,A /MD MD MD80 A318,A319,A320,A MD80 MONITORIN WELL TOP MONITORIN WELL TOP B ,700 MD80; / MD-80; /800/900 A319;A320;A MD / SMITH ST. TUNNEL , JOHNSON 7000 UNKNOWN 490 A319 A320;MD80; ;E190 MD82-83/737/800, CRJ/ /D / A D400/CRJ ;700;A320,E190 A ;800, ,200 N AB-3 RIM ELEV /800/900 N AB-2 RIM ELEV TAXIWAY C TAXIWAY B USAF RESERVE 320 MILLER D400/CRJ A319;A ;700;E190 MD80 757; ;800,900 APRON NORTH PERIMETER RD. N AB-1 RIM ELEV RUNWAY 425 UIC UIC UIC 496 UIC 7100 UIC UIC UIC UIC UIC UIC UIC TAXIWAY T MILITARY PERIMETER ROAD 1 D400/CRJ700 A319;A ;E190 MD80,737, ,800, , ,300 D400 CRJ CRJ ; ; , ,800,900;E ,300 A319;A320;737;700 UIC UIC D400 CRJ700 AVE. UIC CASE RD CRJ700 D D CRJ D400 CRJ D8 120 D RR R R RR D400 CRJ B D8,CRJ 120 C D400 CRJ E-11 D400 CRJ E-12 A318/A319/A320 A319/A A5 sp sp CRJ700/D400 D400 CRJ JOHNSON CRJ700/D400 D400 CRJ MONITORIN WELL TOP FLIHTCRAFT 1004 MONITORIN WELL TOP MONITORIN WELL TOP MONITORIN WELL TOP UARD RUNWAY MONITORIN WELL TOP MONITORIN WELL TOP TRANSPORTATION PROVIDERS HOLDIN AREA 253 MONITORIN WELL TOP MONITORIN WELL TOP APRON ST R MONITORIN WELL TOP NE MARINE DRIVE A4 A RAMP FUEL ISLAND R VIEWPOINT 205 FLEMIN TAXIWAY A P UIC FPFPFP YIELD PDX CARO CENTER 8019 YIELD MONITORIN WELL RIM ELEV NE CORNFOOT RD. MONITORIN WELL TOP MONITORIN WELL RIM ELEV YIELD R 8101,8111,8205 SOUTHEAST A3 NORTHEAST RAMP RAMP MONITORIN WELL TOP COLWOOD OLF COURSE YIELD 8119 R MONITORIN WELL TOP TOP MONITORIN WELL TOP MONITORIN WELL R 7113, N RIM ELEV RIM ELEV PDX MAINT. COMPOUND 7117 N N RIM ELEV N RIM ELEV N RIM ELEV , , R R R R R R R R R R R R R R R R R R R R R R R N E R R R R R R A L D 8855 E R O O D UIC UIC UIC A UIC NE AIRPORT WAY (WEST BOUND) UIC UIC UIC UIC UIC NE AIRPORT WAY (EAST BOUND) NE DETENTION POND 9401 MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV MONITORIN WELL RIM ELEV SETTLEMENT PLATE-6 TOP OF BOLT ELEV=23.33' INTERNATIONAL ECONOMY PARKIN LOT 9955, MONITORIN WELL 2.2' TO TOP CASIN TOP , 9967 ECONOMY PARKIN LOT SETTLEMENT PLATE-5 TOP OF BOLT ELEV=24.57' SETTLEMENT PLATE-4 TOP OF BOLT ELEV=22.68' RD E5-S RIM ELEV E5-D RIM ELEV E4-D DETENTION POND W/ 3 UARD POSTS RIM ELEV E3-S RIM ELEV E4-S W/ 3 UARD POSTS RIM ELEV SETTLEMENT PLATE-1 TOP OF BOLT ELEV=17.86' E3-D RIM ELEV PP&L SUBSTATION E1-S ES-2 W/ 3 UARD POSTS RIM ELEV SETTLEMENT PLATE-2 TOP OF BOLT ELEV=18.22' SETTLEMENT PLATE-3 TOP OF BOLT ELEV=19.36' EAST ECONOMY #L22178 RIM ELEV #L17992 RIM ELEV D #22363 RIM ELEV D #L40319 ROUND ELEV TOP OF CASIN #L #L17991 RIM ELEV #L17395 RIM ELEV D #L22365 RIM ELEV ROUND ELEV TOP OF CASIN D #L22364 RIM ELEV #L17934 RIM ELEV RIM ELEV #L17989 RIM ELEV #L17990 RIM ELEV #L43577 ROUND TOP OF CASIN ' CHAIN LINK FENCE ' CHAIN LINK 6' CHAIN LINK JERSEY BARRIER 7' CHAIN LINK COLUMBIA RIVER NE MARINE DRIVE FACILITY TAXIWAY D RAMP TAXIWAY H AARF TAXIWAY E TAXIWAY E TAXIWAY T TAXIWAY T ,300; ,400,800,900 A ; , , MD-80 90, A , A TAXIWAY A NORTH RAMP BASIN 7a FLIHTCRAFT BASIN 8 BASIN 9 MT. HOOD AVE PARKIN LOT NE 112TH AVE. SERVICE RD TAXIWAY M EMPLOYEE PARKIN NE 82ND AVE NE CASCADES PARKWAY AMBASSADOR PL. MARINA STEEL STOCK TANK NE SUNDERLAND AVE. 1C NORTH PERIMETER ROAD NE 33RD DR. BASIN 1 NE 33RD AVE. NE ELROD RD. (ACCESS ROAD) BASIN 2 COURSE TAXIWAY C 1E NE 47TH AVE. (VAC.) SOUTH PERIMETER ROAD BASIN 1S BASIN 1E 2 SOUTHWEST 1S 3 (MCDD) RUNWAY TAXIWAY E E5 PERIMETER ROAD CENTRAL NE RAMP SOUTH RAMP TAXIWAY F BASIN 3 BUFFALO CENTRAL RAMP 3 (Port) LANE NE 47TH AVE. B3 NE COURIER CT. ST. B4 HORIZON BASIN 5 BASIN 4 4 (Port) NE AIRTRANS WAY NE SKYPORT WAY BASIN 6 C5M OVERENDAVE. SMITH ST. NE SKYPORT WAY JERNSTEDT ST. COLUMBIA BURNETT FISHER ST. C6M NE BRYANT O'CONNOR WAY Several Culverts Beneath Cornfoot Road 6 5 (Port) (Port) Outfall "X" NE 59TH AVE. MILITARY PERIMETER RD HAMPSHIRE OREON AIR NATIONAL MAHONEY AVE. NE 63RD AVE. BLVD. AVE. O'CONNOR WAY NE 66TH AVE. C8 C8 B8 NE CULLY BLVD. EAST PERIMETER RD 7d 7c 7b 7A 7B 7D 7C NE ALDERWOOD RD. NE 79TH CT. 7 (MCDD) W BASIN 10 NE 78TH CT. COLUMBIA BLVD. HOLMAN ST. NE 75TH AVE. RD. NE 80TH AVE. BASIN (Port) (Port) MARX BASIN (Port) DR. NE 87TH AVE. NE PORTLAND CENTER NE ALDERWOOD 8 (COP) NE 92ND DR. COLFAX ST. LASS PLANT ROAD INTERSTATE (MCDD) NE SIMPSON ST. NE 105TH AVE. SANDY NE BUFFALO ST. NE 60TH AVE. NE CULLY BLVD. 2 (MCDD) Legend: BASIN (MCDD) PDX Drainage Basin Location and Designation PDX Outfall and Basin Number Outfall to Columbia Slough and Corresponding Basin Number (Outfall Owner) MCDD = Multnomah County Drainage District Port = Port of Portland COP = City of Portland Base map Prepared from AutoCAD base maps received from the Port of Portland in April 8, Local Culvert to Columbia Slough Historical Drainage Basin Outfall to Columbia Slough Stormwater Flow 0 2,000 4,000 Scale in Feet PDX Drainage Basins and Outfalls, Circa AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW First Avenue Portland, Oregon Project Number June Figure 5

34 12'' CMP co 6'' 6'' 8'' co 6'' CSP 10'' CSP 30'' RCP ST co FAA RTR FACILITY 10'' CSP 10'' CSP 8'' 36'' 36'' 6'' O W 36'' DR 10'' DR 4'' 6''10'' 36'' 8'' DRDR DR DR 10'' 10'' 33'' RCP DR DR DR PDX FIRE STATION co co DR 10'' DR V 33'' 8'' CSP 8'' DR DR 6'' DR 6'' DR co 10'' CSP co 8'' CSP co 10'' 10'' TAXIWAY D 18'' CSP 18'' CSP 18'' CSP 15'' CSP 15'' CSP co 10'' CSP co co S Legend: -11 co Monitoring Well Location Main Stormwater Conveyance Line Flow Direction Line Cap Catch Basin rated Manhole/Catch Basin Manhole Cleanout co co 6'' CSP 10'' CSP 8'' 6'' CSP 6'' CSP 6'' CMP 36'' RCP 36'' RCP 8'' CMP 6'' 6'' CSP 15'' RCP 15'' RCP WQ V O W Water Quality Manhole Vault Oil/Water Separator (Storm) Storm System Flow Valve 8'' CSP Pump Station PFFC JET FUEL STORAE ACCESS ROAD A.C. 8'' 6'' co 6'' 8'' -8 36'' RCP 6'' CMP 10'' 8'' CMP SERVICE RD 8'' CSP 6'' CSP Abandoned Stormwater Conveyance Line and Flow Direction '' 36'' RCP 10'' CSP 15'' RCP '' PVC -3 FORMER FIRE TRAININ FACILITY ( ) co 15'' RCP co -4 12'' RCP -7 CURRENT FIRE TRAININ FACILITY co S '' STSCB3280 co Scale in Feet Base map prepared from pdx-features_pop-local.dwg and pdx-utilities_pop-local.dwg (2013). 15'' HDPE 18'' 12'' HDPE 36'' 36'' 60'' RCSP 8'' HDPE R 8'' HDPE 0'' A co 12'' co -9 8'' PCMP 8'' PCMP ORIINAL FIRE TRAININ FACILITY ( ) LCPF JOINT, TYP. 8'' PCMP co 8'' 8'' PCMP co 24'' RCP co co 8'' PCMP 8'' PCMP 8'' HDPE 24'' RCP 12'' HDPE 12'' HDPE 8'' PCMP co TAXIWAY B 8'' HDPE 8'' PCMP co 21'' RCP 21'' RCP 12'' 15'' 15'' co 15'' co co co 12'' HDPE 15'' RCP 8'' PCMP 12'' HDPE 8'' PCMP 8'' H LCPF JOINT, TYP Fire Training Facilities and Current Fire Station AFFF Preliminary Assessment Portland International Airport Portland, Oregon Apex Companies, LLC 3015 SW First Avenue Portland, Oregon Project Number June Figure 6

35 Appendix A Safety and Data Sheets

36 SAFETY DATA SHEET NMS#210 Aer-O-Water C6 3EM 3% Aqueous Film Forming Foam Concentrate (AFFF) 1. IDENTIFICATION Product Name Aer-O-Water C6 3EM 3% Aqueous Film Forming Foam Concentrate (AFFF) Recommended use of the chemical and restrictions on use Identified uses Firefighting Foam Concentrate Restrictions on Use See Section 15 Company Identification National Foam 350 East Union Street West Chester, PA Customer Information Number (610) Emergency Telephone Number Infotrac at (800) Issue Date November 2, 2016 Supersedes Date January 8, 2016 Safety Data Sheet prepared in accordance with OSHA s Hazard Communication Standard (29 CFR ) and the lobally Harmonized System of Classification and Labelling of Chemicals (HS) 2. HAZARD IDENTIFICATION Hazard Classification Eye Damage/Irritation - Category 2A Specific Target Organ Toxicity (Repeated Exposure) - 2 Label Elements Hazard Symbols Signal Word: Warning Hazard Statements Causes serious eye irritation. May cause damage to organs (kidney) through prolonged or repeated exposure (oral). Precautionary Statements Prevention Wash hands thoroughly after handling. Wear eye protection and face protection. Response If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: et medical advice/attention. et medical advice/attention if you feel unwell. Storage None Disposal Dispose of contents/container in accordance with local regulation. Other Hazards None identified. Revision Date: November 2, 2016 NMS#210 Page 1 of 8